HomeMy WebLinkAboutLincoln County AirportDepartment of Environment and Natural Resources
Office of Legislative and Intergovernmental Affairs
Project Review Form
r` Date Received: 08/24/2006
Project Number: 07-0070 County: Lincoln (F-11 R 9W R-3
Due Date: 09/19/2006 ?kl9
'on: Construction of several aviation improvements to the Lincolnton-Lincgii CoAng%gional
Project Descrlptl
Airport located in Lincoln County off Highway 73. DENR - WATER QUAUTY ANDS AND STORMWATER BRANCH
This Project is being reviewed as indicated below:
Regional Regional Office Area
Asheville Air
Fayetteville Water
Mooresville Groundwater
Raleigh Land Quality Engineer
Washington
Wilmington
Winston-Salem
_ T
y
Sign-Off/Region:
In-House Review
Soil & Water
Coastal Management
Wildlife
Ron Linville
Wildlife - DOT
Forest Resources
Land Resources
Parks & Recreation
_ Water Quality
.? Water Quality - DOT
Air Quality
Reviewer/Agency:
Response (check all applicable)
No Comment
No objection to project as proposed.
Insufficient information to complete review other (specify or attach. comments)
Regional Office Only:
m and update your comments in the DSS (Decision Support System) application,
Please log into the IBEAM syste
SEPA module. If you have any questions, please contact:
Melba McGee, Environmental Coordinator at melba.mcgee@ncmail.net
Marine Fisheries
Water Resources
Environmental Health
Solid Waste Mgmt
Radiation protection
Other
SEP 12006
Lincolnton - Lincoln Ceuft)p 1 QrJ
Lincolnton, North Carolina
Runway Safety Area Improvements and
Associated Projects
The North Carolina Department of Transportation
Division of Aviation
State Block Grant Program
Administrative Action
Finding of No Significant Impact
Submitted Pursuant to the Provisions of
The National Environmental Policy Act
And
Requirements of the State Aid to Airports Program
Approve : C '/' /?J? <?/ . ?)
Richard W. Barkes
Manager Airport System Development
ate
TABLE OF CONTENTS
Page Number
Preliminary Notes: 1
Purpose And Need: 1-2
Alternatives 2
Environmental Impact Categories 3-10
Noise 3
Compatible Land Use 3
Social Impacts 3
Induced Socioeconomic Impacts 3-4
Air Quality 4
Water Quality 4
Department of Transportation Section 303/4(f) 5
Historical, Architectural, Archeological, and Cultural Resources 5
Biotic Communities 5
Endangered and Threatened Species 6
Wetlands 6
Floodplains 7
Coastal Zone Management Program 7
Coastal Barriers 7
Wild and Scenic Rivers 8
Farmland 8
Energy Supply and Natural Resources 8
Light Emissions 8
Solid Waste 8-9
Construction Impacts g
Hazardous Sites/Material g
Environmental Justice 10
Environmental Consequences - Other Considerations: 10
Recommendations 11
Preliminary Notes:
This environmental document is to be reviewed under the guidelines set forth
under the National Environmental Policy Act (NEPA). The proposed
development of this airport will require that the federal and local governmental
units participate in the funding of this project and the development has been
proposed for federal funding under the State Block Grant Program.
Under the provision of the National Environmental Policy Act (NEPA) and the
North Carolina Environmental Policy Act (NCEPA) no funds may be dispersed
until the funding agency has reviewed the potential environmental impacts of the
proposed projects and has concluded that the impacts, if any, are acceptable. Ir
1999 an Environmental Assessment (EA) was approved for the extension of
Runway 05 and installation of a glide slope. The original environmental
assessment in 1999 expired. The airport was required to do an updated EA in
the form of a FAA Form C Environmental Evaluation. The updated EA was
circulated. Projects included in this evaluation are:
• Runway 05 obstruction removal
• Terminal development area
• Glide slope and Runway 23 extended runway safety area (ERSA)
• Runway 23 obstruction removal
Lincolnton - Lincoln County was required to develop an Environmental
Assessment (EA) meeting the provisions of both the federal and state
environmental regulations. After the EA was circulated and reviewed by both
state and federal agencies, the comments and concerns were addressed and it
has been determined that the environmental impacts are minimal. As a result of
this documentation, a Finding Of No Significant Impact (FONSI) is appropriate
and acceptable in this matter.
Purpose and Need:
Lincolnton-Lincoln County Regional Airport is only ten minutes from downtown
Lincolnton. The runway length is 5,500 feet, lighted, (6,000 feet with over-runs).
Services include aircraft rental, aircraft maintenance, aircraft storage, tie-down
space, and aircraft charter service. Many local businesses and industries house
their corporate jets for fast and quick access.
Lincoln County is a growing community in the Charlotte region, the nation's thirty-
fourth largest metropolitan area. Lincoln County has a diverse workforce with a
strong emphasis on manufacturing. Wages for Lincoln County's dependable and
trained workforce are below the state and national average. Manufacturing
employment in the County increased from 1980 to 1990 and 1990 to 2000
despite losses in the region, state, and country.
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The positive aviation growth at the Lincolnton-Lincoln County Regional Airport
(IPJ) has rendered many of the existing facilities inadequate with respect to
runway safety, FAA standards and guidelines, and facility development.
Continued increases in the level of operations and the size of aircraft using IPJ,
along with changes in FAA requirements necessitated the improvements outlined
in the 1999 EA. Expansion of the terminal development area has been a need
for several years as IPJ has continued to grow. The expansion of this area will
accommodate hangar and apron expansion.
In the 1999 EA, the need was established for a glide slope to serve Runway 23
and the clearance of obstructions in the approach to Runway 05. A glide slope is
an instrument landing system navigation facility in the terminal area electronic
navigation system, providing vertical guidance for aircraft during approach and
landing.
The ERSA was necessary to provide safety for aviators, passengers, people on
the ground, and to bring IPJ up to current FAA standards. The ERSA enhances
the safety for airplanes, which undershoot, overrun, or veer off the runway end.
It also provides greater accessibility for firefighting and rescue equipment, should
that be necessary. The ERSA is a cleared, drained, graded, and sodded area
symmetrically located about the extended runway centerline and adjacent to the
end of the runway safety area (RSA). Its length is approximately 1,000 feet from
the existing runway end and its width is 400 feet.
Alternatives:
The expansion of the terminal development area in the 1999 EA stated that
hangar expansion would occur directly behind the existing terminal and that the
apron expansion would occur adjacent to and west of the existing apron. The
terminal development would occur entirely within Airport property. Installation of
the glide slope and ERSA would require site preparation, grading, and fill
material, as originally outlined in the 1999 EA. These projects would also occur
within the confines of existing Airport Property. Due to these existing constraint
the alternatives as outlined above are still the preferred course of action.
The No-Build Alternative is considered the basis of comparison for evaluating the
benefits and impacts of other reasonable alternatives. The No-Build Alternative
is also defined as the do nothing alternative, which means no major improvement
to the Airport, with the exception of every day operations. Implementation of this
alternative would potentially jeopardize the ability of the Airport to receive future
federal funding because of non-compliance with federal regulations as
associated with the Runway Safety Areas.
2
Environmental Impact Categories Summary:
Noise:
The proposed improvements are not going to alter the airport traffic patterns that
currently exist. In addition, no noise analysis is needed for proposals involving
Design Group I and II airplanes on utility or transport type airports whose forecast
operations in the period covered by the EA do not exceed 90,000 annual
adjusted propeller operations or 700 annual adjusted jet operations (FAA Order
5050.4A Airport Environmental Handbook Paragraph 47e(1)(a) [October 8,
1985]). Therefore no significant impact is expected for this topic.
Compatible Land Use:
The compatibility of existing and planned land uses in the vicinity of an airport is
usually associated with two factors: a) the extent of noise impacts related to the
airport and related development .and, b) consistency with local land use plans
and development policies. The lack of noise impacts as previously discussed in
this document and none of the planned land uses for any of the alternatives are
incompatible with planned land uses in the- Lincoln County land use guidance
and zoning regulations. It can be concluded that there are no significant
compatible land use impacts.
Social Impacts:
A principal social impact considered here is the potential relocations or other
community disruption that may be caused by the proposed activities. The
proposed extension of the runway safety area and terminal area expansions will
not involve the need to relocate any residence or business; divide or disrupt
established communities; disrupt orderly, planned development; or create an
appreciable change in employment. There will be no negative defined social
impacts as a result of the terminal area expansion, obstruction removals from
both ends of existing runways, Glideslope installation and RSA extension project.
Therefore, no further analysis is needed.
Induced Socioeconomic Impacts:
This category is primarily concerned with induced or secondary impacts on the
surrounding communities. Induced impacts are usually not considered significant
unless there are significant impacts in other categories especially noise, land use
or direct social impacts. Induced socioeconomic impacts of airport development
normally involve shifts in population, increased public service use, or changes in
the local business and economic climate. The positive economic impacts of the
airport have been substantial, and the proposed actions are expected to extend
these positive impacts to the local community and region.
The RSA and terminal area expansion would be expected to have positive
induced socioeconomic impacts due to the opportunity for the airport to serve
existing corporate users more efficiently and safely. Based on the previous
discussions here and in the EA there are not any anticipated negative impacts
that will require further analysis in this area
Air Quality:
According to the U.S. Environmental Protection Agency Green Book (September
2005) Lincoln County has a moderate 8-hour ozone classification designation, as
it is part of the Charlotte-Gastonia-Rock Hill, NC-SC metropolitan statistical area.
Based on this designation, Lincoln County has six years to achieve attainment.
A level of 180,000 total operations is required before an air quality analysis must
be performed for this category of airport. In addition, North Carolina requires an
air quality permit for the construction and modification of airport facilities
designed to have at least 100,000 annual aircraft operations. The Lincolnton -
Lincoln County Airport is below this threshold for existing and projected
operations. Since no further analysis is needed it can be determined that there is
not any significant impact. Any open burning that occurs during construction will
adhere to all federal, state, and local regulations
Water Quality:
There are no waters classified as high quality waters, outstanding resource
waters, or waters designated as WS-1 or WS-II located within the study area for
the proposed improvements and therefore; no impacts to sensitive water
resources are expected. However, Lick Run, which traverses IPJ, is classified as
C. Class C waters are used for secondary recreation, fishing, wildlife, fish and
aquatic life propagation and survival, agriculture, and other uses suitable for
Class C. Secondary recreation includes wading, boating, and other uses
involving human body contact with water where such activities take place in an
infrequent, unorganized, or incidental manner.
The projected construction is unlikely to have a significant impact on water
resources and water quality near the airport. Wetland issues will be discussed in
the wetland section. Mitigation of potential impacts will be addressed by utilizing
best management practices. All permits will be acquired prior to construction.
Consultation was made with the Army Corps. Of Engineers and the State
Division of Environmental Management and it appears that potentially 1,000 LF
of Lick Run Stream could be effected prior to any work beginning a Section 401
Water Quality Certification will be obtained. An extensive discussion of this topic
was presented in the previously circulated EA and it can be concluded that the
potential impacts on water quality will not be significant with all appropriate
mitigation and permits.
Department Of Transportation Section 303/4(f):
Section 4(f) of the Department of Transportation Act of 1966 states that the
Secretary of Transportation shall not approve any program or project which
requires the use of any publicly-owned land from a public park, recreation area,
or wildlife and waterfowl refuge of national, state, or local significance as
determined by federal, state, or local officials having jurisdiction thereof, or any
land from an historic structure of national, state, or local significance as so
determined by such officials unless: there is no feasible and prudent alternative
to the use of such land; and, the project includes all possible planning to
minimize harm to the land resulting from such use.
Construction would occur entirely on Airport property, where there are no Section
4(f) properties; therefore, there would be no impact.
Historic, Architectural, Archeological, & Cultural Resources:
On October 17-19, 2005, a cultural resources survey was conducted of
approximately 77 acres proposed for development at IPJ. The area was
investigated for the presence of historic properties (sites, buildings, objects, or
districts listed on or eligible for the National Register of Historic Places [NRHP]).
Survey tasks were completed in compliance with Section 106 of the National
Historic Preservation Act of 1966, as amended through 1992 (16 USC 470), as
well as Section 102 of the National Environmental Policy Act of 1969, as
amended through 1982 (42 USC 4332).
No cultural resources were identified during the field survey. Proposed
development at IPJ would not affect any historic properties. Further
management of IPJ with regards to archaeological resources is not warranted.
The SHPO concurred with the recommendations of the findings of the survey
report, therefore no significant impact is anticipated for this topic and no further
action is required.
Biotic Communities:
The study area is located in central Lincoln County within the Southern Inner
Piedmont ecoregion of North Carolina. The property adjacent to the study area
consists of woodland, farmland, and residential parcels. As detailed in the EA a
biological assessment was performed. The specific biotic communities will also
be discussed in other sections of this FONSI under wetlands, and endangered
species. Based on the discussion of these related impact categories, in
combination with best management practices and good construction techniques,
the biotic impacts will be kept to the minimum extent practicable and will not be
significant in nature.
Endangered & Threatened Species:
The Endangered Species Act of 1973, .as amended, gives the Secretary of the
Interior, acting for the Secretary of Commerce, U.S. Fish and Wildlife Service
(USFWS), and National Marine Fisheries Service, the power to protect and
conserve forms of wildlife and plants deemed to be in serious jeopardy. Section
7 of the Act requires federal agencies or their designated non-federal
representatives, in consultation with and assisted by the USFWS, to ensure that
their actions are not likely to jeopardize the continued existence of endangered
and threatened species or result in the destruction or adverse modification of
critical habitat of such species.
The North Carolina Natural Heritage Program (NCNHP) database and the
USFWS website were consulted regarding current federal and state listed
species within Lincoln County. Listed species and their respective federal and
state status were identified in the EA. A detailed Biological Assessment was
performed and it was determined that the dwarf-flowered heartleaf - Hexastylis
naniflora was in the project area. Detailed consultation has occurred with the
USFWS and any impacts to the species will be mitigated. Therefore with
mitigation measures in place there is not a significant impact on Endangered
Species.
Wetlands:
Executive Order 11990 Protection of Wetlands (May 24, 1977) requires federally
supported projects to preserve wetlands and avoid and minimize wetland impacts
to the maximum extent practicable. On October 19-20, 2005 and November 11-
12, 2005, a jurisdictional delineation was conducted. During the visit, areas
considered wetlands or waterways and ponds (waters of the United States) were
identified. Routine wetland delineation sampling was conducted at selected
locations to determine the presence or absence of wetlands.
The currently accepted methods of wetland determination described in the 1987
United States Army Corps of Engineers Manual for Identifying and Delineating
Wetland Areas were utilized. The Manual states that under normal
circumstances an area must demonstrate the presence of three components to
be declared a jurisdictional wetland: 1) hydrophytic vegetation, 2) hydric soils,
and 3) wetland hydrology. A wetland determination has been provided by the
USACOE in the development of the EA. It is anticipated that approximately 2
tenths (.2) acres of wetlands and potentially 1,000 LF of Lick Run may be
effected. During the design phase the wetlands will be delineated and
avoidance, minimization, and mitigation measures will be taken. There are not
any anticipated problems with obtaining all appropriate permits so therefore no
significant impacts are involved for wetlands.
Flood Plains:
As outlined in Executive Order 11988 Floodplain Management (May 24, 1977),
agencies are required to reduce the risk of flood loss; minimize the impact of
floods on human safety, health, and welfare; and restore and preserve the
natural and beneficial values served by the floodplain. Federal regulations permit
development in the 100-year floodplain if it is demonstrated through hydraulic
analysis that the development would meet the requirements set forth by the
Federal Emergency Management Agency (FEMA) for the National Flood
Insurance Program. These requirements allow encroachment in the floodplain
as long as the base flood elevation does not increase by more than one-foot.
When a regulatory floodway has been defined for a waterway, the encroachment
should remain outside the floodway limits.
Review of the Lincoln County floodplain maps indicates that the 100-year
floodplain does encroach within Airport property and therefore, the proposed
improvements would have an impact on the floodplain. This impact would be to
the floodplain associated with Lick Run Creek at the end of Runway 23. Based
on preliminary analyses, it has been determined that any impact to the floodplain
would be negligible, as it is proposed that Lick Run Creek be piped in the area of
the ERSA. This pipe would be sized to ensure that the base flood elevation does
not increase by one-foot. Prior to design of the ERSA, detailed hydraulic
analyses would be performed to minimize potential impact to the floodplain.
Therefore there is not any significant flood plain impact
Coastal Zone Management Program:
The Coastal Zone Management Act of 1972 (P.L. 104-950, as amended)
requires that development projects in the coastal zone comply to the maximum
extent practicable with approved state coastal management programs.
Lincolnton-Lincoln County Regional Airport is not located in the North Carolina
coastal zone; therefore, coordination was not conducted with the North Carolina
Division of Coastal Management to ensure consistency with the Coastal Zone
Management Act.
Coastal Barriers:
The Coastal Barrier Resource Act of 1982 (P.L. 97-348) prohibits the use of
federal funds for projects that would impact undeveloped coastal barrier units in
the Coastal Barrier Resources System. Lincolnton-Lincoln County Regional
Airport is not located in a coastal county; therefore, compliance with the Coastal
Barriers Resource Act was not required.
7
Wild and Scenic Rivers:
There are currently four rivers or portions thereof, in North Carolina listed as wild
and scenic rivers. However, none of these rivers are in the vicinity of IPJ and
therefore would not be impacted by the proposed improvements.
Farmlands:
As defined in the Farmland Protection Policy Act of 1981 (P.L. 97-98), land is not
considered prime or unique farmland if it has been committed to urban
development. Prime or unique farmland committed to urban development
includes land that has been designated for commercial, industrial, or residential
use and is not intended at the same time to protect farmland in either a zoning
code or ordinance adopted by a unit of government or comprehensive land use
plan
The proposed improvements would have an impact on soils by converting
undeveloped land, however, these soils are not considered prime or unique
because of the presence of zoning and land use ordinances for Lincoln County.
Therefore, there would be no impact on prime or unique farmlands.
Energy Supply and Natural Resources:
Construction of the proposed improvements would initially require the
consumption of energy and resources that would not be utilized if the proposed
improvements were not built. Completion of the proposed improvements
however, would compensate for the energy lost during construction by increasing
the efficiency of critical aircraft using the facility. While construction of the
proposed improvements would utilize energy resources for a short time frame,
savings would be realized over the life of the facility. Small amounts of fossil
fuels and construction materials (cement, aggregate, and bituminous material)
would be expended, and these materials are generally not retrievable. However,
these materials are not in short supply and their use would not have an adverse
effect upon continued availability of these resources. Therefore, there will be no
impact on energy supply or natural resources.
Light Emissions:
Implementation of the proposed improvements would not require relocation of
lighting systems associated with Runway 05-23. Therefore no light emissions
impacts.
Solid Waste:
The proposed improvements would not include a direct relationship to solid
waste collection, control, or disposal, other than that associated with
construction, i.e., clearing and grubbing and removal of construction debris.
Lincoln County operates a state-approved Subtitle D Landfill on approximately
300+ acres with a life expectancy of 25+ years. The landfill is located at 5291
Crouse Road, approximately 10.5 miles southwest of IPJ. Therefore there are
not any solid waste impacts for this project.
Construction Impacts:
The types of impacts to be considered primarily are related to noise, air, water
and flora and fauna impacts. There was a detailed discussion of the potential
construction impacts and possible solutions in the EA. Basically, there are not
any anticipated noise impacts that are not expected to unduly impact local
residences or businesses and the other impacts have been discussed in other
areas of this document. In general all applicable permits, (such as sediment and
erosion control plans, and burning permits) and good construction techniques
and best management practices (like those outlined in FAA Order 15015370 - 10
Standards for Specifying Construction of Airports) should alleviate any potential
impacts in this subject.
Hazardous Sites/Materials:
The purpose of a Phase I Environmental Site Assessment (ESA) is to identify, to
the extent feasible pursuant to ASTM E 1527-00, Recognized Environmental
Conditions (REC) in connection with the property. The ASTM Standard Practice
E 1527-00 defines good commercial and customary practice for conducting an
environmental site assessment of a parcel of commercial real estate with respect
to the range of contaminants within the scope of the Comprehensive
Environmental Response, Compensation and Liability Act (CERCLA) and to
petroleum products. This practice is intended to permit a user to satisfy one of
the requirements to qualify for the innocent landowner defense to CERCLA
liability.
Due to the irregular shape of the study area, Environmental Data Resources, Inc.
(EDR) provided a map with a three-mile radius from a point chosen in the center
of IPJ. The results of the EDR evaluation and site reconnaissance conducted on
October 19-20, 2005, November 11-12, 2005, and January 24, 2006 determined
the following. No onsite findings of potential environmental concern were
identified during the Phase I ESA for the study area. Two offsite findings of
potential environmental concern were identified during the Phase I ESA as
RECs. The two offsite RECs could potentially impact the airport due to surface
water. The North Carolina Department of Environment and Natural Resources
was made aware of these sites. Therefore upon resolution of the RECs no
significant impact is anticipated on this topic.
Environmental Justice:
Executive Order 12898 Federal Actions to Address Environmental Justice in
Minority Populations and Low Income Populations (February 11, 1994) states
that to the greatest extent practicable and permitted by law, each federal agency
shall make achieving environmental justice part of its mission by identifying and
addressing, as appropriate, disproportionately high and adverse human health or
environmental effects of its programs, policies, and activities on minority
populations and low-income populations.
The proposed improvements have no. environmental justice impacts, as it is not
requiring the relocation of minority or low-income populations.
Environmental Consequences - Other Considerations:
The EA has addressed all the anticipated specific environmental impacts for this
project in both the construction phase and ultimate utilization of the project.
There were not any controversial issues raised during the EA development. The
project planning and subsequent design will take into account all anticipated
environmental impacts and make great efforts to avoid and minimize them. The
potential impacts to wetlands, endangered species, and general water quality all
appear to be able to be mitigated. The proposed actions appear to be consistent
with all federal, state, and local requirements for the surrounding area.
As outlined in FAA Order 5050.4A Airport Environmental Handbook, Lincolnton
Lincoln County provided opportunity for the general public to comment on the
proposed projects contained in the EA. They received no request to conduct a
public hearing, thus no such hearing was held.
In conclusion, the EA has shown that the proposed project can be completed
with no significant impact on the environment. All necessary permits are
expected to be obtained without incident and any additional mitigation measures
that may be necessary will be completed prior to, or when applicable in the
construction process.
10
Recommendations:
After careful review of the Environmental Assessment and comments and
response from the coordination process, and the facts contained herein, the
undersigned has found that the proposed project is consistent with the objectives
of the national and state environmental policies. The objectives and polices are
set forth in the National Environmental Policy Act and the North Carolina
Environmental Policy Act, and the project will not significantly affect the quality of
human environment or otherwise include any significant condition requiring
further consultation with any federal, state, or local review agencies with the
following exceptions which shall be made a condition of the environmental
approval of this project:
+ Lincolnton - Lincoln County, or its appointed representative shall obtain any
and all federal, state, or local permits (such as burning, sediment and erosion
control, NPDES general construction permit, 401 WQC, 404, etc.,) prior to
construction of this project.
+ Any mitigation that might prove necessary shall be developed and
implemented prior to, or during the construction phase of this project. Such
mitigation may include but will not be limited to endangered species and
wetlands mitigation.
+ To the extent practicable every effort will be made to avoid and minimize
environmental impacts in the development of this project. The development
of this project will utilize best management practices and good construction
techniques.
Therefore it is the undersigned's recommendation that-the project be given a
Finding Of No Significant Impact (FONSI) under the provisions set forth by the
State of North Carolina Block Grant Program, and the National Environmental
Policy Act.
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Richard W. Barkes Date
Manager, Airport System Development Section
Division of Aviation, North Carolina Department of Transportation
11
F W ATF Michael F. Easley, Governor
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OCR QG William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
`
Uj 7 Alan W. Klimek, P.E. Director
] t Division of Water Quality
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August 22, 2006
MEMORANDUM
To: Melba McGee, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs
From: Brian L. Wrenn, Transportation Permitting Unit, NC DWQ
Subject: Environmental Assessment for the Proposed Improvements to NC 24 in Cumberland, Sampson,
and Duplin Counties, WBS Element 34416.1.1, TIP Project No. R-2303, State Clearinghouse
No. 07-0017
This office has reviewed the referenced document. The Division of Water Quality (DWQ). is responsible
for the issuance of the Section 401 Water Quality Certification for activities that impact Waters of the
U.S.,. including wetlands. The Division of Water Quality offers the following comments:
Document Specific Comments:
1. South River is listed on the Impaired Waters List, 303(d) waters of the State.. South River is on
the 303(d) list for impaired use for aquatic life due to mercury. Although mercury is not typically
a pollutant associated with road projects, DWQ is concerned with sediment and erosion impacts
that could result from this project. DWQ recommends that the most protective. sediment and
erosion control BMPs be implemented to reduce the risk of nutrient runoff to South River. DWQ
requests that road design plans provide treatment of the storm water runoff through best
management practices as detailed in the most recent version of NC DWQ Stormwater Best
Management. Practices.
2. The Concurrence Point 2A form in Appendix A, Section A.1. references. attached bridge and
culvert data,. but the data is not included in the document. The referenced bridge and culvert data
should be included in the document.
General Comments:
1. The environmental document should provide a detailed and itemized presentation of the proposed
impacts to wetlands and streams. with corresponding mapping. If mitigation is necessary as
required by 15A NCAC 2H.0506(h), it is preferable to present a conceptual (if not finalized)
mitigation plan with the environmental documentation. Appropriate mitigation plans will be
required prior to issuance of a 401 Water Quality Certification..
2. Environmental impact statement alternatives should consider design criteria that reduce the
impacts to streams and wetlands from storm water runoff. These alternatives should include road
designs that allow for treatment of the storm water runoff through best management practices as
detailed in the most recent version of NC DWQ Stormwater Best Management Practices, such as
grassed swales, buffer areas, preformed scour holes, retention basins, etc..
I?1 Caro ' a
Transportation Permitting Unit ?'"tura
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: 919-733-1786 / FAX 919-733.6893 / Internet http://h2o.enr.state.nc.us/ncwetlands
An Equal Opportunity/Affirmative Action Employer-50% Recycled/10% Post Consumer Paper
August 22, 2006
Page 2 of 5
3. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the NCDOT is respectfully reminded that they will need to demonstrate the
avoidance and minimization of impacts to wetlands (and streams) to the maximum extent
practical. In accordance with the Environmental Management Commission's Rules { 15A NCAC
2H.0506(h)), mitigation will be required for impacts of greater than 1 acre to wetlands. In the
event that mitigation is required, the mitigation plan should be designed to replace appropriate
lost functions and values. The NC Ecosystem Enhancement Program may be available for use as
wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules {15A NCAC
2H.0506(h)}, mitigation will be required for impacts of greater than 150 linear feet to any single
perennial stream. In the event that mitigation is required, the mitigation plan should be designed
to replace appropriate lost functions and values. The NC Ecosystem Enhancement Program may
be available for use as stream mitigation.
5. Future documentation, including the 401 Water Quality Certification Application, should
continue to include an itemized listing of the proposed wetland and stream impacts with
corresponding mapping.
6. DWQ is very concerned with sediment and erosion impacts that could result from this project..
NC DOT should address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the. impacts.
7. . An analysis of cumulative and secondary impacts anticipated as a result of this. project is required.
The type and detail of analysis should conform to. the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004.
8. NC DOT is respectfully reminded that all impacts,. including but not limited to, bridging, fill,
excavation and clearing, to jurisdictional wetlands, streams, and riparian buffers need to. be
included in the final impact calculations.. These impacts, in addition to any construction impacts,
temporary or otherwise, also need to be included as part of the 401 Water Quality Certification
Application.
9. Where streams must be crossed, the DWQ prefers bridges be used in lieu of culverts. However,
we realize that economic considerations often require the use of culverts.. Please be advised that
culverts should be countersunk to allow unimpeded passage. by fish and other aquatic organisms.
Moreover, in areas where high quality wetlands or streams are impacted, a bridge may prove
preferable. When applicable, DOT should not install the bridge bents in the. creek, to. the
maximum extent practicable.
10. Sediment and erosion control measures should not be placed in wetlands or streams.
11. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands
in borrow/waste areas will need to be presented in the 401 Water Quality Certification and could
precipitate compensatory mitigation.
August 22, 2006
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12. The 401 Water Quality Certification application will need to specifically address the proposed
methods for stormwater management. More specifically, stormwater should not be permitted to
discharge directly into streams or surface waters.
13. Based on the information presented in the document, the magnitude of impacts to. wetlands and
streams may require an Individual Permit application to the Corps of Engineers and
corresponding 401 Water Quality Certification. Please be advised that a 401 Water Quality
Certification requires satisfactory protection of water quality to ensure that water quality
standards are met and no wetland or stream uses are lost. Final permit authorization will require
the submittal of a formal application by the NCDOT and written concurrence from the NCDWQ.
Please be aware that any approval will be contingent on appropriate avoidance and minimization
of wetland and stream impacts to the maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where
appropriate.
14. Bridge supports (bents) should not be placed in the stream when possible.
15. Whenever possible, the DWQ prefers spanning structures.. Spanning structures usually do not
require work within the stream or grubbing of the streambanks and do not require stream channel
realignment. The horizontal and vertical clearances provided by bridges allow for human and
wildlife passage beneath the structure, do not block fish passage and do not block navigation by
canoeists and boaters.
16.. Bridge deck drains should not discharge directly into. the stream. Stormwater should be directed
across the bridge and pre-treated through site-appropriate means (grassed swales,. pre-formed
scour holes, vegetated buffers, etc.) before entering the stream. Please refer to the. most current
version of NC DWQ Stormwater Best Management Practices..
17. If concrete is used during construction, a dry work area should be maintained to. prevent direct
contact between curing concrete and stream water. Water that inadvertently contacts uncured
concrete should not be discharged to surface waters due to the potential for elevated pH and
possible aquatic life and fish kills. .
18. If temporary access roads or detours are constructed,. the site. shall be graded to its preconstruction
contours and elevations. Disturbed areas should be seeded or mulched to. stabilize the soil and
appropriate native woody species should be planted. When using temporary structures the area
should be cleared but not grubbed. Clearing the area with chain saws, mowers, bush-hogs, or
other mechanized equipment and leaving the stumps and root mat intact allows the area to re-
vegetate naturally and minimizes soil disturbance.
19. Placement of culverts and other structures in waters, streams, and wetlands shall be placed below
the elevation of the streambed by one foot for all culverts with a diameter greater than 48 inches,
and 20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow
low flow passage of water and aquatic life. Design and placement of culverts and other structures
including temporary erosion control measures shall not be conducted in a manner that may result
in dis-equilibrium of wetlands or streambeds or banks, adjacent to or upstream and down stream
of the above structures. The applicant is required to provide evidence that the equilibrium is being
maintained if requested in writing by DWQ. If this condition is unable to be met due to bedrock
or other limiting features encountered during construction, please contact the NC DWQ for
August 22, 2006
Page 4 of 5
guidance on how to proceed and to determine whether or not a permit modification will be
required.
20. If multiple pipes or barrels are required, they should be. designed to mimic natural stream ctoss
section as closely as possible including pipes or barrels at flood plain elevation and/or sills where
appropriate. Widening the stream channel should be avoided. Stream channel widening a the
inlet or outlet end of structures typically decreases water velocity causing sediment deposition
that requires increased maintenance and disrupts aquatic life passage.
21. If foundation test borings are necessary; it should be noted in the document. Geotechnical work
is approved under General 401 Certification Number 3494/Nationwide Permit No. 6 for Slirvey
Activities.
22. Sediment and erosion control measures sufficient to protect water resources must be imp emented
and maintained in accordance with the most recent version of North Carolina Sediment d
Erosion Control Planning and Design Manual and the most recent version of NCS00025 .
23. All work in or adjacent to stream waters should be conducted in a dry work area. Approved BUT
measures from the most current version of NCDOT Construction and Maintenance Activities
manual such as sandbags, rock berms, cofferdams. and other diversion structures should!be used
to prevent excavation in flowing water..
24. While the use of National Wetland Inventory (NWI) maps, NC Coastal Region Evalua 'on of
Wetland Significance (NC-CREWS) maps and soil survey maps are useful tools, their erent
inaccuracies require that qualified personnel perform onsite wetland delineations prior] to. permit
approval.
25. Heavy equipment should be operated from the bank rather than in stream channels in rder to
minimize. sedimentation and reduce the likelihood of introducing other pollutants: into streams.
This equipment should be. inspected daily and maintained to prevent contamination o surface
waters. from leaking fuels, lubricants, hydraulic fluids, or other toxic materials. .
26. Riprap should not be placed in the active thalweg channel or placed in the streambe in a manner
that precludes aquatic life passage. Bioengineering boulders or structures should be roperly
designed, sized and installed.
27. Riparian vegetation (native trees and shrubs) should be preserved to the maximum extent
possible.. Riparian vegetation must be reestablished within the construction limits of the. project
by the end of the growing season following completion of construction.
i
The NCDWQ appreciates the opportunity to provide comments on your project. Should you have any
questions or require any additional information, please contact Brian Wrenn at 919-733-5715.
August 22, 2006
Page 5 of 5
cc: Dave Timpy, US ACE Wilmington Regulatory Field Office
Travis Wilson, NC WRC
Gary Jordan, USFWS
Chris Militscher, USEPA
Ken Averitte, Fayetteville Regional Office, NC DWQ
Clarence Coleman, Federal Highway Administration
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