20110023_Environmental Assessment_20100609 (2)

Department of Environment and Natural Resources
Project Review Form
Project Number: 10-0407 County: Dare Date Received: 05/14/2010
Due Date: 6/9/2010
Project Description: Environmental Assessment - Proposal to replace the Herbert C. Bonner
Bridge (Bridge No. 11) over Oregon Inlet, NC 12, in Dare County. TIP No.
B-2500

is rolec is en, g reviewe as ff ica e e ow:
Regional Office Regional Office Area In-House Review
Asheville Air - Soil & Water ? Marine. Fisheries
Fayetteville Water
? Coastal Management
? i Water Resources
_
Mooresville Aquifer Protection Wildlife v/ Environmental Health
? Wildlife - DOT Solid Waste Mgmt
Raleigh / Land Quality Engineer Forest Resources _
_ Radiation Protection
/ Washington Land Resources Other
Wilmington
-
?/ Parks & Recreation
Winston-Salem Water Quality
/ Water Quality - DOT
Air Quality

Manager Sign Off Region: Date: In-House Reviewer/Agency:
Response (check all applicable)
_ No objection to project as proposed. No Comment
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Insufficient information to complete review y o
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If you have any questions, please contact: P
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Melba McGee, Environmental Coordinator at Melba.McGee(ancdenr.eov ?WrAl
?AY- 19 2010 /J
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NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
June 7.2010
MEMORANDUM
Dee Freeman
Secretary
To: Melba McGee, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs
Through: Brian Wrenn ?/?
From: David Wainwright, Division of Water Quality, Central Office Y?I"-
Subiect Comments on the Environmental Assessment related to proposed replacement of the
Bonner Bridge (Bridge No. l Lover Oregon Inlet) and improvements to NC 12, Dare .
County, Federal Aid Project No. BRS-2358(15), TIP B-2500
State Clearinghouse Project No. 10-0407.
This office.fias revlewe&the referenced' document dated May 2010. The NC Division of Water Quality
(NGDWQ).rs responsible for the issuance.of--the Section 401 Water Quality Certification for activitics,that
impact Wafers of the-U.S.': including wetlands. It is our understanding. that the project as presented will
result in impacts to jurisdictional wetlands, streams, and other surface waters. The NCDWQ offers the
following comments based on review of the aforementioned document:
I., This project is being planned as part of the 404/NEPA Merger Process. As a participating team
member, NCDWQ will continue to work with the team.
2., Commitment 5 discusses pile placement and jetting and indicates that potential damage from spoil
piles to wetlands, SAV; and Oregon Inlet will be minimized. The NCDOT is respectfully reminded.
that impacts from jetting will need to estimated as accurately as possible when submitting an
application for a 401 Water Quality Certification, and any impacts exceeding estimates will need to
-be submitted to the DWQ for permit modification. Mitigation may be required for impacts from
jetting.
The DWQ has had discussions with the NCDOT regarding jetting within Oregon Inlet. However, the
possibility of jetting within wetlands, as indicated in Commitment 5, has not been satisfactorily
discussed. It is unclear to the DWQ why jetting may be required in wetland areas as these areas are
easily accessible.
The NCDOT is also respectfully reminded that a satisfactory justification as to why jetting is required
for the construction this project will need to be included in the 401 Water Quality Certification
application. Additionally, the NCDOT will need to explain what measures will be taken to reduce all
impacts from jetting including turbidity, sedimentation, discharge water run-off, the removal of spoil,
etc.
Transportation Permitting Unit
1650 G4ail Service Center, Ralegh, North Carolina 27699-1650
Location: 2321 Crabtree Blvd., Ralegh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: hitp:llh2o,encstate.nc.us!mcwetlands.,
An Ecual Oopotlunire 1 Affirmative ACVOn Emeluyer
NorthCarolina
Naturally
FAA
3. It is stated in Section 2.1 and shown in Table 2-1 that residential and business relocations increased
between the FEIS and the EA for the Phased Approach/Rodanthe Bridge alternative. Residential
relocations doubled from three (3) to six (6); business relocation increased from one (1) with two (2)
partially affected to seven (7). Residential relocations doubled while business relocations increased
seven-fold. This would seem to make them significant. It is concluded that the increases were not
seen as significant because there is enough available housing and business locations, assistance will
be provided, and owners would be paid fair-market value for the property. The DWQ does not agree
that having locations available and providing services makes the relocations less significant. The
DWQ does agree that, relatively speaking, the increase in relocations is not significant. This is not
because housing or business locations are available and assistance would be paid but because, as
stated in the first bullet in the text, the numbers are no higher than what has been considered with
some of the other alternatives.
4. Section 2.l discusses impacts to a cemetery located in Rodambe. It is stated that no impacts to marked
graves would occur; a study would be undertaken to identify any unmarked graves if necessary and
those would then be avoided. It is unclear to the DWQ how it is known that unmarked graves could
be avoided, unless.impacts to the cemetery:could be.avoidedaltogether. Please clarify. .
5. The document does not discuss mitigation in much detail. A very brief mention of mitigation is in
Section3.3:4 (September,1.7,2009 Merger Meetmg).;Mitigation was discussed to some extent at that
meeting. According to NCDCM, the land use p)an P&Dare-County requires thatsome, if not all,
_
mitigal ibh,for impacts to wetlands in Daze County f}ke place, in Dare County The NPS has stated that
any impacts occurring within the Pea Island Nafional;, ?ildlrfe Refuge should be mitigated for-witbin
the Refuge. Due to these constraints mitigation, should be discussed in. more detail than is presented in ..
Section: 3:3.4
6. The A.W. a ees t
Q: gr}lat no significant increase tn•impacts have occurred with the Parallel Bridge.:: _
Corridor with NC 12 Management 1?lan alternapve.
NCDWQ appreciates the opportunity to provide comments on. your project. Should you have any questions
onrequire any additional information; please contactDavid Wainwright at.(919)7.1573415.
cc: Bill Biddlecome, US Army Corps of Engineers, Washington Field_ Office
Clarence Coleman, Federal Highway Administration
Chris Militscher, Environmental Protection Agency (electronic copy only)
Travis Wilson, NC Wildlife Resources Commission (electronic copy only)
Cathy Brittingham, Division of Coastal Management
Garcy Ward, NCDWQ Washington Regional Office .
File Copy
Administrative Action
Environmental Assessment
US Department of Transportation, Federal Highway Administration
North Carolina Department of Transportation
NC 12 Replacement of
Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet
Federal-Aid No. BRS-2358(15)
NCDOT Project Definition: 32635
TIP Project No. B-2500
Dare County, North Carolina
Branch Manager
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
Submitted Pursuant to the National Environmental Policy Act 42 USC 4332(2)(c) and 49 USC 303
Cooperating Agencies
US Coast Guard/US Army Corps of Engineers
US Fish and Wildlife Service/National Park Service
?0 zzi6:z Z???
to / ;regory J. Thorpe, Ph.D.
'r-/ / I/ ( /0 q"v 0",L?
Date 41 John F. Sullivan 111, P.E.
ivision Administrator
Federal Highway Administration
The following persons may be contacted for additional information concerning this document:
John F. Sullivan III, P.E.
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, North Carolina 27601
[phone]
Gregory J. Thorpe, Ph.D.
Project Development and Environmental
Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
[phone]
The proposed project is the construction of a bridge to replace the Herbert C. Bonner Bridge in Dare
County, the demolition and removal of Bonner Bridge, and improvements to NC 12 between the
community of Rodanthe and Oregon Inlet. This EA identifies and assesses changes that have occurred
since the approval of the Final Environmental Impact Statement/Final Section 4(f) Evaluation on
September 17, 2008.
Comments on this EA are due by
above address.
and should be sent to Gregory J. Thorpe, Ph.D. at the
NC 12 Replacement of Herbert C. Bonner Bridge
Documentation prepared by:
PB Americas, Inc.
in association with:
CZR, Incorporated / Moffatt & Nichol Engineers
Panamerican Consultants, Inc. / Mattson, Alexander & Associates
FDH Engineering, Inc. / PB Consult
with contributions from
URS Corporation-North Carolina and Arcadis G&M, Inc.
15/7/1', nj
Date Jo n Page, AICP, CEP
3 Americas, Inc.
Project Manager
(Bridge No. 11) over Oregon Inlet
Federal-Aid No. BRS-2358(15)
NCDOT Project Definition: 32635
TIP No. B-2500
Dare County, North Carolina
Administrative Action
Environmental Assessment
for the:
North Carolina Department of Transportation
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JOHN M. PAGE
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Bfian Yamamoto. '...
North Carolina epartment of Transportation
Project Development and Environmental
Analysis Branch
Consultant Group Leader (Eastern)
Elizabet,4 A. Smyre, P.E.
North Carolina Department of Transportation
Project Development and Environmental
Analysis Branch
Project Planning Engineer
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NC 12 Replacement of the
Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet
Federal-Aid No. BRS-2358(15)
NCDOT Project Definition: 32635
TIP Project No. B-2500
Dare County, North Carolina
Project Commitments
The following text lists the Project Commitments from the September 2008 Final Environmental
Impact Statement (FEIS) along with any revisions to those commitments. As indicated below,
revisions were made to several of the FEIS commitments and one new commitment has been
added.
Highway Design Branch and Technical Services Division
1. Navigation Span Location. One navigation zone would be built to serve boats passing
through Oregon Inlet. The location of the zone would be determined in coordination with the
US Army Corps of Engineers (USACE).
Bicycle Accommodations (revised). The Cape Hatteras National Seashore (Seashore)
management plan supports the use of bicycles along NC 12. All bridges associated with the
detailed study alternatives (including the Preferred Alternative) would have 8-foot (2.4-
meter) wide shoulders that would be safer for bicycle and pedestrian traffic than Bonner
Bridge's 2-foot (0.6-meter) wide shoulders. In addition, a bicycle-safe bridge rail on the
bridges also would provide increased safety for bicyclists. New roadway would have 4-foot
(1.2-meter) paved shoulders, which would be safer for use by bicycle and pedestrian traffic
than the existing NC 12's unpaved shoulders.
Highway Design Branch and Division 1
Use of Work Bridges (revised). During construction of the project, steps taken to minimize
turbidity (when possible and practicable) would include the use of work bridges (rather than
barges, which would require dredging) for movement of construction equipment in shallow
areas where submerged aquatic vegetation (SAV) is present. If SAV is in waters deep
enough to float a barge without dredging, the use of a work bridge would not be necessary.
Work bridges also would be used to carry construction equipment over intertidal marsh areas
(black needlerush and smooth cordgrass). Dredging generally would only be used in depths
less than 6 feet (1.8 meters) where SAV is not present. Work bridges will be used to cross
SAVs. Neither dredging nor haul roads would be used in SAVs.
Sedimentation and Erosion Control. All waters in the project area are classified as SA waters
(Class A salt waters) with a supplemental classification of High Quality Waters (HQW). The
most stringent application of the Best Management Practices (BMPs) is expected where
highway projects affect receiving waters of special designation, such as HQW. Also, impacts
to adjacent areas of SAV and/or wetlands should be minimized. Therefore, sedimentation
Bonner Bridge Replacement EA in May 2010
NCDOT TIP Project Number B-2500 Page I of 7
and erosion control measures shall adhere to the Design Standards in Sensitive Watersheds
[15A NCAC 04B.0124(b)-(e)]. Prior to construction, the design-build contractor will submit
the proposed sediment and erosion control plans for each stage of construction to the North
Carolina Department of Transportation (NCDOT) and permitting agencies for review.
5. Pile Placement (revised). Bridge piles in open water would be jetted to the tip elevation
(depth of the tip of the pile). Bridge piles overland would be jetted or driven. Potential
damage to wetlands, SAV, and Oregon Inlet from jetting spoils will be minimized to the
extent practicable.
6. Use of Bridge Demolition Debris for an Artificial Reef. NCDOT would work with the North
Carolina Department of Environment and Natural Resources, Division of Marine Fisheries
(NCDENR-DMF) to accommodate this desire during demolition planning. Coordination also
would be conducted with the National Marine Fisheries Service (NMFS) in association with
their regulation of several protected species.
7. Oregon Inlet Fishing Access (new). NCDOT will ensure that access to fishing at the north
end of Hatteras Island is restored once construction of the new Oregon Inlet bridge is
complete. The catwalks on the existing Bonner Bridge will remain open during construction
as long as is safely feasible.
Highway Design Branch, Project Development and Environmental Analysis Branch, and
Division I
Design Coordination (revised). NCDOT would invite NPS and USFWS, as well as the other
agencies represented on the project's National Environmental Policy Act/Section 404 of the
Clean Water Act (NEPA/Section 404) Merger Team (a full list of agencies on the Merger
Team is shown on page 8-6 of the FEIS), to participate in the development of project design
and mitigation strategies as a part of the permit application process for each phase of the
project.
9. Dredging. To avoid construction impacts to protected turtles, NCDOT's contractor would use
pipeline or clamshell dredging. A hopper dredge would not be used for bridge construction
or Bonner Bridge demolition.
10. Disposal of Dredged Material (revised). Prior to construction, during the permit preparation
process, FHWA and NCDOT would work with appropriate environmental resource and
regulatory agencies to identify the characteristics of dredged material from bridge
construction in open water and develop a disposal plan that would minimize harm to natural
resources. The appropriate location for dredged material disposal would be determined based
on the character of the materials dredged, the availability of disposal sites, and coastal
conditions near the time of construction. In addition, as noted in Commitment 25c, the terms
and conditions outlined in the Biological and Conference Opinions (USFWS, 2008) related to
piping plovers specify that "all dredge spoil excavated for construction barge access must be
used to augment either existing dredge-material islands or to create new dredge-material
islands for use by foraging plovers. This must be accomplished as per the specifications of
the North Carolina Wildlife Resources Commission."
Bonner Bridge Replacement EA iv May 2010
NCDOT TIP Project Number B-2500 Page 2 of 7
11. Night-time Construction. Because construction activities could occur 24-hours-a-day,
construction areas could be lit to daylight conditions at night. NCDOT would work with
NCDENR-DMF, NMFS, NPS, and USFWS to determine other areas near project
construction where night lighting would need to be avoided or limited. Night lighting also
would not be used close to areas where people sleep, including the campground at the
northern end of the project area and the Rodanthe area at the southern end. Night lighting
also will meet the requirements specified to protect sea turtles contained within Commitment
2628.a.
12. Manatee Protection. Construction contracts would require compliance with USFWS's
Guidelines for Avoiding Impacts to the West Indian Manatee: Precautionary Measures for
Construction Activities in North Carolina Waters (June 2003).
13. Sea Turtle and Smalltooth Sawfish Protection. NCDOT will comply with NMFS's March 23,
2006, Sea Turtle and Smalltooth Sawfish Construction Conditions (NMFS, 2006) that restrict
in-water construction-related activities when these protected species are observed in the
project area. However, NMFS and NCDOT agree that bridge construction or demolition
activities do not need to stop when a protected species is sighted in the proximity of
construction if the construction activities are not in the water. The in-water moratorium
prohibits pile installation and removal and activities associated with bridge construction and
demolition when listed species are present in the water, but does not restrict terrestrial
activity.
14. Terminal Groin Removal (revised). NCDOT would apply for a permit to retain the groin to
protect the south end of the Oregon Inlet bridge.
15. Archaeological Resources Discovered During Construction. If any historic archaeological
resources (i.e., historic watercraft) are encountered in the area west of Bodie Island during
construction, construction work affecting the resource will cease immediately until the
resource can be identified and assessed for National Register of Historic Places eligibility.
16. Construction of Future Phases (revised). In phasing the construction of the Parallel Bridge
Corridor alternatives (including the Preferred Alternative), it is NCDOT's intent to place a
high priority on the monitoring and need for implementation of improvements in the three
potential hot spot areas. This intent recognizes the need to build in the Rodanthe `S' Curves,
Sandbag Area, and Canal Zone hot spots. Final phasing decisions will be developed through
interagency collaboration and under the requirements of NEPA as project area conditions
warrant.
17. Monitoring Program (revised). NCDOT considers the 2060 high erosion shoreline a
reasonable assumption for current planning purposes, but also recognizes that decisions
related to implementation of future phases and the specific location of future phases would
likely need to evolve with actual geomorphological change relative to the NC 12 easement.
With this in mind, NCDOT would implement a monitoring program on Hatteras Island in the
project area, as described in Section 2.3.2.2 of this EA.
18. Breach Response-Related Data Gathering Program (revised). Recognizing the possibility that
a breach could occur at the southern part of the Refuge prior to completion of Phase II and
that four other locations exist in the project area that are geologically susceptible to a breach,
Bonner Bridge Replacement EA v May 2010
NCDOT TIP Project Number B-2500 Page 3 of 7
NCDOT would conduct a breach response-related data gathering program focusing on the
southern end of the Refuge.
19. Reduce the Potential Impacts from NC 12 Maintenance Prior to the Completion of Each
Phase (revised). Recognizing that storm-related NC 12 maintenance will occur before
completion of future phases, particularly before the implementation of improvements in the
three hot spot areas, NCDOT would continue to work with the Refuge to reduce potential
impacts to the Refuge and NC 12 resulting from NC 12 storm-related maintenance.
20. Shortnose Sturgeon. Conservation measures to protect shortnose sturgeon would include no
hopper dredging and measures to minimize habitat degradation. Such measures would
include BMPs involving use, storage, and disposal of construction/demolition materials to
minimize short-term turbidity or water quality degradation during over water construction in
Oregon Inlet and during periodic maintenance. Construction and demolition activities
associated with Phase I of the project would be completed as quickly as possible in order to
minimize deterring spawning sturgeon from entering Oregon Inlet. In addition, the project
would incorporate BMPs to reduce habitat degradation from stormwater runoff pollution.
Highway Design Branch, Project Development and Environmental Analysis Branch,
Division 1, Right-of-Way Branch, and Technical Services Division
21. Utilities. Project development and construction activities would be coordinated with utility
providers in the project area in order to prevent interruption of local utility services. The
following utility providers currently serve the project area: Dare County (water service);
Sprint Communications (telephone service); Charter Communications (cable television
service); and Cape Hatteras Electric Membership Association (electric power service).
Highway Design Branch, Project Development and Environmental Analysis Branch,
Division 1, and Geotechnical Unit
22. Use of Explosives During Construction. The use of explosives during construction is not
anticipated. If explosives were needed to remove Bonner Bridge's piles, NCDOT would
coordinate with the appropriate environmental resource and regulatory agencies to develop a
blasting program that would minimize adverse effects to the natural environment.
Project Development and Environmental Analysis Branch
23. Programmatic Agreement (revised). Prior to the release of the Record of Decision (ROD),
FHWA will complete a Programmatic Agreement with the State Historic Preservation Office
(HPO) and the Advisory Council on Historic Preservation (ACHP) in consultation with other
consulting parties, as per the requirements of Section 106 of the National Historic
Preservation Act of 1966.
24. Seabeach Amaranth (revised). Since the favored habitat of the seabeach amaranth is highly
ephemeral, a survey of the project area would be conducted for the habitat of this species at
least one year prior to initiating bridge construction activities. It would occur as needed for
each construction phase.
Bonner Bridge Replacement EA vi May 2010
NCDOT TIP Project Number B-2500 Page 4 of 7
Highway Design Branch, Project Development and Environmental Analysis Branch,
Division 1, and Bridge Management Unit
25. Piping Plover (revised). NCDOT will implement the following nondiscretionary measures
that include the terms and conditions outlined in the Biological and Conference Opinions
(USFWS, 2008):
a. All construction equipment and personnel must avoid all bird closure areas within the
Seashore and Refuge.
All future routine maintenance activities of bridge structures that would occur within or
adjacent to current or future plover nesting areas must occur outside the nesting season
(April 1 to July 15).
All future repair work on bridge structures that would occur within or adjacent to current
or future plover nesting areas must occur outside the nesting season (April 1 to July 15)
unless emergency or human safety considerations require otherwise. In this event, the
area must be surveyed for nesting plovers and avoided to the extent possible.
b. During the construction of Phases II, III and IV of the Phased Approach/Rodanthe Bridge
Alternative (or if selected for implementation under the NC 12 Transportation
Management Plan [Preferred]), keep all construction equipment and activity within the
existing right-of-way.
Do not moor any construction barges within 300 feet (91.4 meters) of the following
islands: Green Island, Wells Island, Parnell Island, Island MN, Island C, the small
unnamed island immediately east of Island C, Island D, and Island G (see Figure 1 in the
Biological and Conference Opinions in Appendix E of the FEIS).
c. All dredge spoil excavated for construction barge access must be used to augment either
existing dredge-material islands or to create new dredge-material islands for use by
foraging plovers. This must be accomplished as per the specifications of the North
Carolina Wildlife Resources Commission. The point of contact is Sue Cameron at 910-
325-3602. If the dredge material is used outside the current defined action area, the
action area is assumed to be expanded to cover the beneficial placement of the material.
d. To the maximum extent practical, while ensuring the safety of the traveling public, limit
or avoid the use of road signs or other potential predator perches adjacent to plover
nesting or foraging areas. Where signs or other structures are necessary, determine if
alternative designs would be less conducive for perching on by avian predators (gulls,
crows, grackles, hawks, etc.). For example, minimize or avoid the use of large cantilever
signs in favor of smaller and shorter designs.
26. Sea Turtles (green sea turtle, leatherback sea turtle, and loggerhead sea turtle) (revised).
NCDOT will implement the following nondiscretionary measures that include the terms and
conditions outlined in the Biological and Conference Opinions (USFWS, 2008):
a. All construction equipment and personnel must avoid all marked sea turtle nests.
Construction material and equipment staging areas must not be located seaward of the
artificial dune.
Bonner Bridge Replacement EA vii May 2010
NCDOT TIP Project Number B-2500 Page 5 of 7
All future routine maintenance activities of bridge structures that would occur within or
adjacent to current or future sea turtle nesting habitat, and which would require vehicles
or equipment on the beach or the use of night lighting (excluding navigation lights
required by the US Coast Guard), must occur outside the nesting season (May 1 to
November 15).
All future repair work of bridge structures that would occur within or adjacent to current
or future sea turtle nesting habitat, and which would require vehicles or equipment on the
beach or the use of night lighting (excluding navigation lights required by the US Coast
Guard) must occur outside the nesting season (May 1 to November 15) unless emergency
or human safety considerations require otherwise. In this event, the area must be
surveyed for sea turtle nests and avoided to the extent possible.
b. Provide an opportunity for USFWS or a USFWS designee to educate construction
contractor managers, supervisors, foremen and other key personnel and resident NCDOT
personnel with oversight duties (division engineer, resident engineer, division
environmental officer, etc.) as to adverse effects of artificial lighting on nesting sea
turtles and hatchlings, and to the importance of minimizing those effects.
c. During turtle nesting season (May 1 to November 15), use the minimum number and the
lowest wattage lights that are necessary for construction.
During turtle nesting season, portable construction lighting must be of the low-pressure
sodium-vapor type.
During turtle nesting season, utilize directional shields on all portable construction lights,
and avoid directly illuminating the turtle nesting beach at night.
During turtle nesting season, all portable construction lights must be mounted as low to
the ground as possible.
During turtle nesting season, turn off all lights when not needed
d. For Phases 11, III and IV if developed as defined by the Phased Approach/Rodanthe
Bridge Alternative (or if selected for implementation under the NC 12 Transportation
Management Plan [Preferred]), on the ocean side, design the bridge structure in a manner
which will shield the beach on the east side from direct light emanating from passenger
vehicle headlights. For the small portion of Phase I over land on Hatteras Island, retrofit
the bridge structure at the time that Phase II connects with Phase 1. The specific design
of the bridge will be developed in consultation with USFWS prior to re-evaluation of the
environmental document for Phase 11.
e. Avoid retrofitting the bridges and approach roads with permanent light fixtures in the
future (excluding navigation lights required by the US Coast Guard).
In addition, NCDOT does not anticipate the use of explosives during construction or
demolition of the existing bridge. NCDOT's contractor will use pipeline or clamshell
dredging, rather than a hopper dredge to minimize effects to sea turtles. No permanent light
fixtures will be installed on the bridge or the approaches (with the exception of navigation
lights as required by the US Coast Guard).
Bonner Bridge Replacement EA viii May 2010
NCDOT TIP Project Number B-2500 Page 6 of 7
Photogrammetry Unit and Project Development and Environmental Analysis Branch
27. Submerged Aquatic Vegetation (SAV) Survey (revised). The dynamic nature of the area
around Oregon Inlet results in ephemeral habitats, particularly in shallow water and shoreline
areas. Consequently, NCDOT would obtain new SAV information for use by the contractor
in construction access planning. All surveys for SAV in the vicinity of Oregon Inlet will
follow protocols endorsed by the National Oceanic and Atmospheric Administration (NOAA)
Fisheries.
Bonner Bridge Replacement EA ix May 2010
NCDOT TIP Project Number B-2500 Page 7 of 7
Table of Contents
PROJECT COMMITMENTS ................................................................................................... iii
1.0 INTRODUCTION ...........................................................................................................1-1
1.1 Purpose of the Environmental Assessment .........................................................1-1
1.2 History of Project Documentation .......................................................................1-1
1.2.1 1993 Draft Environmental Impact Statement ............................................. 1-1
1.2.2 2005 Supplemental Draft Environmental Impact Statement ...................... 1-2
1.2.3 2007 Supplement to the 2005 Supplemental Draft Environmental
Impact Statement ........................................................................................ 1-2
1.2.4 2008 Final Environmental Impact Statement ............................................. 1-2
1.3 What is New/What has Changed? .......................................................................1-2
1.3.1 Design Modifications to Detailed Study Alternatives ............................... 1-2
1.3.2 Findings of the March 2010 NC Coastal Resource Commision's
Science Panel on Coastal Hazards ............................................................. 1-3
2.0 CHANGES TO ALTERNATIVES CONSIDERED ....................................................2-1
2.1 2009 Updates to the Parallel Bridge Corridor Alternatives .............................. 2-1
2.2 Elimination of the Pamlico Sound Bridge Corridor as a Detailed Study
Alternative ........................................................................................................... 2-10
2.3 Preferred Alternative .......................................................................................... 2-12
2.3.1 Development of the Preferred Alternative ............................................... 2-12
2.3.2 Characteristics of the Preferred Alternative ............................................. 2-13
2.3.3 Impact Assessment ................................................................................... 2-22
2.3.4 Basis for Selection of the Preferred Alternative ....................................... 2-28
2.3.5 Does the Parallel Bridge Corridor with NC 12 Transportation
Management Plan Alternative (Preferred) result in "Segmentation"
under NEPA? .......................................................................................... 2-31
2.3.6 Minimizing Impacts of NC 12 Maintenance with the
Preferred Alternative ................................................................................ 2-32
2.3.7 Costs ......................................................................................................... 2-33
2.3.8 Conclusion ................................................................................................ 2-36
3.0 COMMENTS AND COORDINATION ........................................................................ 3-1
3.1 Comments on the September 2008 FEIS ............................................................. 3-1
3.2 Comments on the October 2009 Revised Final Section 4(f) Evaluation ........... 3-2
3.3 Merger Team Meetings Since Release of the FEIS ............................................ 3-3
3.3.1 November 13, 2008, Merger Team Meeting .............................................. 3-3
3.3.2 March 26, 2009, Merger Team Meeting .................................................... 3-4
3.3.3 May 21, 2009, Merger Team Meeting ....................................................... 3-4
3.3.4 September 17, 2009, Merger Team Meeting .............................................. 3-5
3.4 Section 106 Meetings Since Release of the FEIS ................................................ 3-6
Bonner Bridge Replacement EA xi NCDOT TIP Project Number B-2500
Table of Contents (concluded)
3.5 Coordination with USFWS Related to the Refuge Since Release
of the FEIS ............................................................................................................. 3-7
3.5.1 March 19, 2009, Meeting ........................................................................... 3-7
3.5.2 May 28, 2009, Teleconference Meeting ..................................................... 3-7
3.5.3 July 15, 2009, Site Visit ............................................................................. 3-8
3.5.4 September 2, 2009, Meeting ...................................................................... 3-8
3.5.5 Meetings on the Terminal Groin ................................................................ 3-8
3.5.6 November 2009 Rodanthe Storm Repair ................................................... 3-9
3.6 Endangered Species Act Consultation Since Release of the FEIS .................... 3-9
3.6.1 November 2008 Endangered Species Act Update ................................... .. 3-9
3.6.2 April 2009 Consultation with USFWS ..................................................... .. 3-9
3.6.3 May 2009 ESA Consultation with NOAA Fisheries ................................ 3-10
3.6.4 August 2009 ESA Consultation with USFWS ......................................... 3-10
3.7 December 2009 Coordination Meeting with Council on
Environmental Quality ....................................................................................... 3-10
3.8 Public Involvement .............................................................................................. 3-10
4.0 CONCLUSION ............................................................................................................... 4-1
APPENDIX A: NEPA/404 MERGER TEAM CONCURRENCE FORMS ........................ A-1
APPENDIX B: REVISED FINAL SECTION 4(F) EVALUATION ................................... B-1
APPENDIX C: AMENDED DESCRIPTION OF PARALLEL BRIDGE CORRIDOR
ALTERNATIVES WITH NC 12 MAINTENANCE SELECTED FOR
DETAILED STUDY .................................................................................................................. C-1
APPENDIX D: RESPONSE TO COMMENTS ON THE FINAL
ENVIRONMENTAL IMPACT STATEMENT ..................................................................... D-1
APPENDIX E: FINAL ENVIRONMENTAL IMPACT STATEMENT
COMMENT LETTERS ............................................................................................................ E-1
APPENDIX F: RESPONSE TO COMMENTS ON THE REVISED
FINAL SECTION 4(F) EVALUATION ..................................................................................F-1
APPENDIX G: REVISED FINAL SECTION 4(F) EVALUATION
COMMENT LETTERS ............................................................................................................ G-1
APPENDIX H: REVISED RELOCATION REPORTS ....................................................... H-1
Bonner Bridge Replacement EA xii NCDOT TIP Project Number B-2500
List of Tables
Table 2-1. Comparison of FEIS and EA Human Environment Impacts with
Road North/Bridge South, All Bridge, and Phased
Approach/Rodanthe Bridge Alternatives in the Rodanthe Area ..................... ..... 2-7
Table 2-2. Comparison of FEIS and EA Natural Environment Impacts with Road
North/Bridge South, All Bridge, and Phased Approach/Rodanthe Bridge
Alternatives in the Rodanthe Area .................................................................. ... 2-10
Table 2-3. Comparison of FEIS and EA Alternatives Human Environment
Impacts for Phase I (Oregon Inlet Bridge) ...................................................... ... 2-24
Table 2-4. Comparison of FEIS and EA Alternatives Natural Environment
Impacts for Phase I (Oregon Inlet Bridge) ...................................................... ... 2-25
Table 2-5. Phase I Shading, Fill, and Pile Placement Impacts to Wetlands and
Waters for the Parallel Bridge Corridor Alternatives ..................................... ... 2-26
Table 2-6. Total (All Phases) Shading, Fill, and Pile Placement Impacts to Wetlands
and Waters for the Parallel Bridge Corridor Alternatives ............................... ... 2-27
Table 2-7. Parallel Bridge Corridor Highway Cost to 2060 (Low) .................................. ... 2-34
Table 2-8. Parallel Bridge Corridor Highway Cost to 2060 (High) ................................. ... 2-35
List of Figures
Figure 2-1. Parallel Bridge Corridor Alternatives in Rodanthe Assessed in EA .......... .......... 2-2
Figure 2-2. Parallel Bridge Corridor Alternatives in Rodanthe Assessed in FEIS ....... .......... 2-3
Figure 2-3. Phased Approach/Rodanthe Bridge Alternative Ramp and Frontage
Roads in Rodanthe ..................................................................................... .......... 2-5
Figure 2-4. Rodanthe Area Assessed in Table 2-2 ....................................................... .......... 2-8
Figure 2-5. Change in Proposed Phase I Easement Since Revised Final
Section 4(f) Evaluation .............................................................................. ........ 2-15
Figure 2-6. Parallel Bridge Corridor Alternatives - Phase I ......................................... ........ 2-16
Figure 2-7. Hot Spot Locations .................................................................................... ........ 2-21
Bonner Bridge Replacement EA xiii NCDOT TIP Project Number B-2500
1.0 Introduction
1.1 Purpose of the Environmental Assessment
The purpose of this Environmental Assessment (EA) is to document the following:
• The decision to add anew detailed study alternative (Parallel Bridge Corridor with NC 12
Transportation Management Plan) and select it as the Preferred Alternative;
• Refinements made to the detailed study alternatives since the release of the September 2008
Final Environmental Impact Statement (FEIS);
• The elimination of the Pamlico Sound Bridge Corridor alternatives as detailed study
alternatives;
• An assessment of impacts for the new detailed study alternative and an assessment of changes
to several of the remaining detailed study alternatives at the community of Rodanthe and at
the northern end of Hatteras Island; and
• New information obtained since the publication of the FEIS.
The findings contained within this document and subsequent public review of this document shall
determine whether or not these changes or circumstances would result in significant
environmental impacts not evaluated in the FEIS and whether a Supplemental Final
Environmental Impact Statement (SFEIS) is needed. If the agency conclusion is that these
changes or circumstances would result in significant environmental impacts not evaluated in the
FEIS, then a SFEIS will be prepared.
The Federal Highway Administration (FHWA) and the North Carolina Department of
Transportation (NCDOT) are making this document available for a period of 30 days to provide
resource agencies and the public an opportunity to review it. Comments received will be
reviewed and taken into account prior either to the determination to prepare a supplement to the
FEIS or to the approval of a Record of Decision (ROD).
1.2 History of Project Documentation
1.2.1 1993 Draft Environmental Impact Statement
In 1990, NCDOT began studying replacement alternatives for Bonner Bridge (TIP No. B-2500).
The coordination for the project, including agency scoping, was initiated with a scoping letter to
government agencies in May 1990 at the start of a Bonner Bridge replacement feasibility study.
A Draft Environmental Impact Statement (DEIS) was released for review in November 1993.
The DEIS assessed a single preferred alternative, the Parallel Bridge Corridor across Oregon
Inlet. After the release of the DEIS, combined (corridor and design) Public Hearings were held in
Bonner Bridge Replacement EA 1-1 NCDOT TIP Project Number B-2500
early 1994. Comments were received regarding the DEIS from the public and from federal, state,
and local agencies.
A preliminary FEIS was prepared in 1996; however, it was never signed because formal
consultation with the US Fish and Wildlife Service (USFWS) under Section 7 of the Endangered
Species Act was not completed. Because it had been more than seven years since completion of
the DEIS, a re-evaluation was conducted in 2001 to determine if the preliminary FEIS remained a
valid assessment of project impacts. A decision was made in 2001 to prepare a Supplemental
DEIS.
1.2.2 2005 Supplemental Draft Environmental Impact Statement
Work on the Supplemental Draft Environmental Impact Statement (SDEIS) began in 2002 with a
new study of potential Bonner Bridge replacement alternatives. The study area was expanded
south to encompass NC 12 south to Rodanthe because NC 12 had begun to be regularly
threatened by shoreline erosion and overwash. Three areas on NC 12, or "hot spots," between
Oregon Inlet and Rodanthe are especially vulnerable. The SDEIS was completed and signed in
September 2005. The SDEIS assessed five alternatives in two corridors, the Pamlico Sound
Bridge Corridor and the Parallel Bridge Corridor. Two Public Hearings were held in November
2005.
1.2.3 2007 Supplement to the 2005 Supplemental Draft Environmental
Impact Statement
A proposal made during the comment period following the release of the SDEIS led to the
development of two additional Parallel Bridge Corridor alternatives. These alternatives were
assessed in the Supplement to the SDEIS, which was signed on February 14, 2007. Two Public
Hearings were held in March 2007.
1.2.4 2008 Final Environmental Impact Statement
A Final Environmental Impact Statement was signed on September 17, 2008. It identified the
Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge as the Preferred Alternative and
addressed comments received on the SDEIS and SSDEIS.
1.3 What is New/What has Changed?
1.3.1 Design Modifications to Detailed Study Alternatives
Several modifications were made to the detailed study alternatives and the impact assessment
since the release of the FEIS. These modifications were made to respond to comments on the
FEIS and take into account factors related to the history of the creation and maintenance of
NC 12 in the Seashore and the Refuge. These changes are:
1. The Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative was
added and selected as the Preferred Alternative. This alternative is a variation of the Parallel
Bridge Corridor alternatives assessed in the FEIS. It calls for Phase I (Oregon Inlet bridge) to
be built as soon as possible, followed by construction of later phases whose details would be
determined, reevaluated, and documented through interagency collaboration as project area
Bonner Bridge Replacement EA 1-2 NCDOT TIP Project Number B-2500
conditions warrant. This change was made based on discussions at a May 21, 2009, National
Environmental Policy Act/Section 404 of the Clean Water Act (NEPA/Section 404) Merger
Team meeting, during which several agency representatives stated that it was not appropriate
to determine the specifics of future phases of a Parallel Bridge Corridor Alternative at this
time. Though the team did not doubt the quality of the coastal studies conducted for the
project, they recognized that there is a great deal of uncertainty in even the best models of
future shoreline conditions.
2. A Revised Final Section 4(f) Evaluation was issued by NCDOT and FHWA in October 2009
(see Appendix B) in response to comments received on the FEIS/Final Section 4(f)
Evaluation, collection of new information on the history of transportation on the islands and
the development of Cape Hatteras National Seashore and Pea Island National Wildlife
Refuge, and the selection of a new Preferred Alternative.
The Revised Final Section 4(f) Evaluation determined that the Pamlico Sound Bridge
Corridor alternatives were not feasible and prudent avoidance alternatives to the use of a
Section 4(f) property.
3. Modifications to the conceptual designs, which eliminated adverse impacts to the
Chicamacomico Life Saving Station and the Rodanthe Historic District, were made for the
Road North/Bridge South, All Bridge, and Phased Approach/Rodanthe Bridge alternatives.
4. Based on an agreement made as part of the NEPA/Section 404 Merger Process Concurrence
Point 2A in November 2008, the Oregon Inlet bridge terminus of the Nourishment, Road
North/Bridge South, and Phased Approach (Phase I) alternatives was extended to the south
by approximately 2,000 feet (610 meters) to account for potential sound-side erosion at the
north end of Hatteras Island.
1.3.2 Findings of the March 2010 NC Coastal Resource Commission's
Science Panel on Coastal Hazards
In March 2010, the NC Coastal Resource Commission's Science Panel on Coastal Hazards
released a report entitled "North Carolina Sea-Level Rise Assessment Report," which presented a
review of the known condition of sea level rise in the state. The report surveyed four studies
regarding the rates of sea level rise in North Carolina; it noted that the amount of sea level rise
varies by latitude, with higher rates of rise more likely in the northern coastal region. The report
also noted that the rate of sea level rise has varied in the past and will likely do so again in the
future. The Science Panel recommended that a sea level rise of 1 meter (39 inches) by the year
2100 be adopted for policy development and planning purposes for the state. This
recommendation is within the range of projected sea level rise considered in the FEIS and does
not negate the conclusions of the Climate Change Peer Exchange meeting held in May 2008 that
was also utilized in the project's coastal conditions analysis. The Peer Exchange participants
concluded that the use of the high erosion shoreline for planning purposes will account for a large
portion of future sea level rise, and that an alternative that includes a coastal monitoring program
will allow new information to be incorporated into the project's design. This report, along with
other future relevant statewide studies, will be reviewed as part of the coastal monitoring program
proposed with the NC 12 Transportation Management Plan.
Bonner Bridge Replacement EA 1-3 NCDOT TIP Project Number B-2500
2.0 Changes to Alternatives
Considered
Chapter 2 of the Final Environmental Impact Statement (FEIS) described the alternatives
considered for detailed study. This section analyzes changes made to those alternatives based on
comments received on the FEIS/Final Section 4(f) Evaluation and additional coordination with
state and federal agencies. It includes:
• A description of the studies completed in 2009 that resulted in design modifications to the
alternatives in Rodanthe at the southern end of the project, beginning on page 2-1. This
section adds to descriptions of the project alternatives studies presented in Sections 2.2 to 2.8
of the FEIS.
• The reasons why the Pamlico Sound Bridge Corridor alternatives are now eliminated from
consideration as detailed study alternatives, beginning on page 2-10.
• A description of the new detailed study alternative, as well as the reason for its selection as
the Preferred Alternative, beginning on page 2-12. This section of the Environmental
Assessment (EA) replaces Section 2.15 of the FEIS.
2.1 2009 Updates to the Parallel Bridge Corridor
Alternatives
To address the concerns expressed in agency comments on the FEIS about the impacts to the
Rodanthe Historic District and the Chicamacomico Life Saving Station, the North Carolina
Department of Transportation (NCDOT) modified the conceptual designs for the Phased
Approach/Rodanthe Bridge, Road North/Bridge South, and All Bridge alternatives, all of which
were previously found to have an Adverse Effect on the station and the district under Section 106
of the National Historic Preservation Act. The designs were revised to remove the presence of
the alternatives from within the district boundaries. The revised alignments are shown in Figure
2-1. The locations of the original alignments are illustrated in Figure 2-2. These alignment
revisions can be incorporated into the Preferred Alternative (see Section 2.3) when a future phase
is constructed in Rodanthe in the vicinity of these historic resources. Because the FEIS
conceptual designs for the Nourishment and Phased Approach/Rodanthe Nourishment
alternatives do not involve road construction, beach nourishment, or dune construction within or
in proximity to the Rodanthe Historic District or the Chicamacomico Life Saving Station, these
alternatives were found to have No Effect on these historic resources. As a result, there were no
agency concerns expressed about the impacts of these alternatives on these historic resources, so
no modifications in the Rodanthe area were necessary.
After re-initiating consultation with the State Historic Preservation Office (HPO), the Advisory
Council on Historic Preservation (ACHP), and other consulting parties to the Section 106
Programmatic Agreement (see Section 3.4) to present the revised alignments, the modified
conceptual designs for the Phased Approach/Rodanthe Bridge, Road North/Bridge South, and All
Bridge alternatives were found to have No Adverse Effect on the Rodanthe Historic District and
the Chicamacomico Life Saving Station. These modifications result in a lessening of the adverse
Bonner Bridge Replacement EA 2-1 NCDOT TIP Project Number B-2500
LEGEND
® National Register of Historic Places Eligible
Rodanthe Historic District Boundary
Road North/Bridge South and All Bridge
Centerlines
Phased Approach Centerline (Phase II)
Forecast Worst-Case Shoreline Locations
Forecast 2060 Worst-Case Shoreline
Forecast 2050 Worst-Case Shoreline
Forecast 2040 Worst-Case Shoreline
® Potential Breach Location
RODANeEer?
0 0.1 0.2 KM
0 0.1 0.2 Mile
r

71 1
PARALLEL BRIDGE CORRIDOR ALTERNATIVES Figure
IN RODANTHE ASSESSED IN EA 2-1
LEGEND
® National Register of Historic Places Eligible
Rodanthe Historic District Boundary
Road North/Bridge South and All Bridge
Centerlines
Phased Approach Centerline (Phase II)
Forecast Worst-Case Shoreline Locations
Forecast 2060 Worst-Case Shoreline
Forecast 2050 Worst Case Shoreline
Forecast 2040 Worst-Case Shoreline
® Potential Breach Location
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0 0.1 0.2 KM
0 0.1 0.2 Mile

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4
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PARALLEL BRIDGE CORRIDOR ALTERNATIVES Figure
IN RODANTHE ASSESSED IN HIS 2-2
environmental impacts evaluated in the FEIS without causing any additional or new significant
environmental impacts that were not included in the FEIS, as documented in this section.
The revised designs were presented to representatives of HPO on March 24, 2009, and the
Merger Team during the March 26, 2009, informational meeting (see Chapter 3). The revisions
involved:
Road North/Bridge South and All Bridge Alternatives. The Rodanthe bridge portion of these
alternatives was revised to locate the intersection with NC 12 approximately 530 feet (161.5
meters) north of the Rodanthe Historic District. The southern terminus is a curved
intersection, similar to that designed for the Pamlico Sound Bridge Corridor with Curved
Rodanthe Terminus considered in the FEIS. NC 12 traffic would be at-grade as it enters the
Rodanthe Historic District. The section of NC 12 roadway between the southern terminus of
the bridge portion north to the Pea Island National Wildlife Refuge (Refuge) boundary would
be maintained as a service road to provide property access to homes and businesses north of
the bridge.
The original alignment terminated within the district and had been developed for the 2005
Supplemental Draft Environmental Impact Statement (SDEIS) prior to a revision to the
district boundaries with HPO concurrence in 2006. Moving the alternative from within the
historic district places the southern terminus of the alternative between the forecast 2050 and
2060 high erosion shoreline. However, the proposed NC 12 alignment could be relocated
again if the forecast 2060 high erosion shoreline were to occur. The 2060 high erosion
shoreline places almost all of the Chicamacomico Life Saving Station and approximately
one-half of the Rodanthe Historic District in the Atlantic Ocean. The Federal Highway
Administration (FHWA) and NCDOT would reassess the condition of these historic
resources prior to the implementation of subsequent phases in order to determine whether the
proposed NC 12 alignment could be modified.
The northern terminus of the Rodanthe area bridge with the Road North/Bridge South and the
All Bridge alternatives would remain the same, with bridging beginning approximately 2
miles (3.2 kilometers) north of the Refuge's southern boundary and extending into Pamlico
Sound before rejoining NC 12 in Rodanthe (see Figure C-2 and Figure C-3 in Appendix Q.
Phased Approach/Rodanthe Bridge Alternative. The original design of the Phased Approach/
Rodanthe Bridge Alternative included a bridge in Rodanthe that was contained within the
existing 100-foot (30.5-meter) easement, with one-way service roads on either side of the
bridge being used to provide local access. The alternative terminated approximately 1,560
feet (475.5 meters) south of the Rodanthe Historic District. The bridge was within the district
boundaries and adjacent to the boundary of the Chicamacomico Life Saving Station. Because
of the visual impacts of the bridge, as well as concerns over the impact of the associated
change in access both to the Chicamacomico Life Saving Station and across the Rodanthe
Historic District, the Rodanthe area bridge was shortened to stop at a point approximately 420
feet (128.0 meters) north of the district. The southern end of this bridge would not be brought
down to grade; instead, traffic would access the bridge via a two-lane ramp on the west side
of the bridge. NC 12 traffic would be at-grade through the Rodanthe Historic District. (See
Figure 2-3.)
The main bridge would not be brought down to grade because of the risk of shoreline erosion
(see Figure 2-1). In order to keep the bridge outside the Rodanthe Historic District, it must
drop below the elevation of the storm surge in the general area of the 2020 high erosion
Bonner Bridge Replacement EA 2-4 NCDOT TIP Project Number B-2500
PHASED APPROACH/RODANTHE BRIDGE ALTERNATIVE Figure
RAMP AND FRONTAGE ROADS IN RODANTHE 2-3
shoreline and reach existing grade between the forecast 2040 and 2050 high erosion
shorelines. Thus, placing this ramp back to grade on one side and continuing the bridge at
full height above the storm surge to a point between the forecast 2040 and 2050 high erosion
shorelines would reduce the risk to NC 12 of high erosion or an island breach. If high erosion
rates manifest themselves or a breach occurs that puts the ramp-to-grade at risk, then,
following additional environmental analysis, a new ramp could be built off the full height
bridge and/or the full height bridge could be extended as originally proposed. Again, the
2060 high erosion shoreline places almost all of the Chicamacomico Life Saving Station and
approximately half of the Rodanthe Historic District in the Atlantic Ocean. FHWA and
NCDOT will reassess the condition of these historic resources prior to the implementation of
subsequent phases to determine whether the proposed NC 12 alignment could be modified.
The northern terminus of the Rodanthe bridge with the Phased Approach/Rodanthe Bridge
Alternative would remain the same; bridging would begin at a point north of the Rodanthe `S'
Curves Hot Spot within the Refuge and extend south into Rodanthe while remaining within
the existing 100-foot (30.5-meter) easement (see Figure C-4 in Appendix Q.
Table 2-1 presents a comparison of the updated human environment impacts in the Rodanthe area
for the detailed study alternatives. For this comparison, the Rodanthe area was defined as the
area beginning at the Chicamacomico Life Saving Station and extending north to a point
approximately 2 miles (3.2 kilometers) north of the Refuge's southern boundary where the
"bridge south" component of the Road North/Bridge South Alternative terminates. This area is
illustrated in Figure 2-4.
Note that one change in the affected human environment described in the FEIS has occurred and
is reflected in the impact material presented in this section. Several additional homes have been
built in the Rodanthe portion of the project area. These additional homes are reflected in the
relocation and noise impacts found in Table 2-1 for both the FEIS and the EA alternatives. In
general, the revisions to the alternatives result in unchanged or lower impacts to the human
environment, including impacts to Rodanthe community cohesion and accessibility, visual
impacts, cultural resource impacts, and parks and recreation impacts. However, relocation and
noise impacts would increase.
The business relocations shown in Table 2-1 for the revised (EA) Road North/Bridge South, All
Bridge, and Phased Approach/Rodanthe Bridge alternatives are higher than for the same
alternatives as designed in the FEIS. Residential relocations are also higher with the Phased
Approach/Rodanthe Bridge Alternative. Because these alternatives were redesigned to end north
of the Rodanthe Historic District, they have a greater impact on the partially developed area north
of the district. However, the increase in the number of relocations does not represent a new
significant impact for two reasons:
The relocation impacts for these alternatives remain within the range of impacts presented for
the detailed study alternatives assessed in the FEIS. They are similar to or less than those
presented in the FEIS for the Pamlico Sound Bridge Corridor alternatives, which affected the
same area north of the Rodanthe Historic District as the revised Parallel Bridge Corridor
alternatives. Taking into account home construction since relocation studies were completed
for the Pamlico Sound Bridge Corridor, the Pamlico Sound Bridge Corridor alternatives
would displace six to I I homes (up from five to six in the FEIS) and one to six businesses.
2. Properties purchased would be purchased at fair market value, and residents and businesses
would be relocated as a part of NCDOT's relocation program described in Section 4. 1.1 of
Bonner Bridge Replacement EA 2-6 NCDOT TIP Project Number B-2500
Table 2-1. Comparison of FEIS and EA Human Environment Impacts with Road
North/Bridge South, All Bridge, and Phased Approach/Rodanthe Bridge Alternatives' in
the Rodanthe Area
Residential Relocations
Business Relocations
EA
and Visual
2
3
1 (plus 2 partially
Proposed right-of-way
would cross cemetery,
Cemetery Impacts None but no known None
gravesites would be
affected.
Rodanthe Community
Cohesion and
Accessibility
2 residential receptors
exceeding FHWA NAC
No impact.
1.1 miles (1.8
kilometers) of bridge
would bisect
community and make
vehicle access more
circuitous.
0.8 mile (1.3
kilometers) of bridge
would bisect
community and make
vehicle access more
circuitous.
3 residential receptors
exceeding FHWA
NAC, and 3 residential
receptors (including 1
ofthe 3 exceeding
FHWA NAC) and 1
business receptor with
substantial noise
increases
2 residential receptors 3 residential receptors
exceeding exceeding
FHWA NAC FHWA NAC
0.8 mile (1.3
kilometers) of elevated
structure would
substantially affect
views in Rodanthe.
Noise Impact
(estimated number of
sensitive receptors
affected)
Visual Impact
Rodanthe Historic
District and
Chicamacomico Life
Saving Station
Panoramic views of Pamlico Sound from homes
along shoreline in Rodanthe would be affected.
Adverse Effect; would
use land from district
passing 14 feet (4.3
meters) and 320 feet
(97.5 meters) away
from station and one
other contributing
structure, respectively.
Cultural Resource
No Adverse Effect; the
alternatives would end
outside the district, so
cultural resources
would not be directly
affected; alternatives
would be within view
of resources, but view
also currently includes
modern commercial and
residential structures.
1.1 miles (1.8
kilometers) of elevated
structure would
substantially affect
views in Rodanthe.
Adverse Effect;
alternative would be
contained within
existing highway right-
of-way, but alternative
would bisect district
along existing NC 12
and future access would
be from one-way
frontage roads.
Elevated structure
would bisect views
across NC 12 within the
district.
No Adverse Effect; the
alternative would end
outside the district, so
cultural resources
would not be directly
affected; alternative
would be within view
of resources, but view
also currently includes
modern commercial
and residential
structures.
The two alignments are the same in the Refuge;
Pea Island National Adverse Effect because the alternatives would The two alignments are the same in the Refuge;
Wildlife Refuge leave the existing NC 12 easement, and because of Adverse Effect because of the elevation of the
the elevation of the bridge as it passes through the bridge as it passes through the Refuge.
Refuge.
Parks and Recreation Impacts
General Refuge Access Bridge through Pamlico Sound in southern portion Bridge in existing NC 12 easement in southern
of Refuge would reduce access in that area. portion of Refuge would reduce access in that area.
Length of NC 12
Outside the Existing 0.7 mile (1.1 kilometers) None.
Easement within the
Refuge
'The Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative (Preferred) could include
implementation of the shared Road North/Bridge South and All Bridge alignment or the Phased Approach/Rodanthe
Bridge alignment as a part of a future phase in the Rodanthe area. The FEIS proposes improvements in the Rodanthe
area to be implemented as a part of Phase II of the project.
NOTE: There were no modifications made to the FEIS conceptual designs for the Nourishment and Phased
Approach/Rodanthe Nourishment alternatives in the Rodanthe area.
Bonner Bridge Replacement EA 2-7 NCDOT TIP Project Number B-2500
LEGEND
® National Register of Historic Places Eligible
Rodanthe Historic District Boundary
Road North/Bridge South and All Bridge
Centerlines
Phased Approach Centerline (Phase II) 12
Forecast Worst-Case Shoreline Locations
Forecast 2060 Worst-Case Shoreline
?G
Forecast 2050 Worst-Case Shoreline
Forecast 2040 Worst-Case Shoreline
® Potential Breach Location y

y

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END OF RODANTHE
r r? ?
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Chicamacomico
ff-T-MertriMme Life Saving Station

Dare County Water
Treatment Plant
0 0.25 0.5 0.75 KM
Rodanthe-Wa

. \\
0 0
25 0
5 Mil
.
.
e
Figure
RODANTHE AREA ASSESSED IN TABLE 2-2 2-4
the FEIS. Conceptual stage relocation studies (see Appendix H) concluded that: after project
construction, business services would be available; suitable business sites are available for
relocated businesses; decent, safe, and sanitary housing would be available during the relocation
period; and there would be no problem in finding relocation housing within the means of current
residents.
As indicated in Table 2-1, the right-of-way for the revised Road North/Bridge South and All
Bridge alternatives would cross a cemetery in Rodanthe; however, no marked gravesites would be
affected. If a future phase uses this corridor, additional research and/or field surveys would be
conducted to affirm no unmarked graves would be affected. If unmarked graves would be
affected, the right-of-way boundary could be adjusted to avoid the graves without affecting the
location of the bridge passing adjacent to the cemetery.
The additional receptors affected by increased traffic noise with the revised alternatives do not
represent a new significant impact because:
1. In the case of the Phased Approach/Rodanthe Bridge Alternative, the impact to one additional
receptor is within the range of impacts presented for the detailed study alternatives assessed
in the FEIS.
The revised Road North/Bridge South and All Bridge alternatives place the Rodanthe Bridge
terminus in the same general area as the FEIS' Pamlico Sound Bridge Corridor. The FEIS
identified noise impacts at three to four receptors with the Pamlico Sound Bridge Corridor
alternatives, whereas the revised Road North/Bridge South and All Bridge alternatives would
affect six receptors. However, the revised Road North/Bridge South and All Bridge
alternatives have fewer residential relocations (i.e., 2 residential relocations with the revised
alternatives versus 6 to 11 residential relocations with the Pamlico Sound Bridge Corridor
alternatives).
Although increases in noise and displacement impacts would occur with the revised alternatives,
as indicated in Table 2-1 the revisions represent a substantial reduction in impacts to the National
Register-eligible Rodanthe Historic District and the National Register-listed Chicamacomico Life
Saving Station. Therefore, based on the data presented in Table 2-1, the design changes in
Rodanthe would result in no new significant impacts to human environment resources.
Table 2-2 presents a comparison of key natural environment impact issues associated with the
Rodanthe area (shown in Figure 2-4) for the FEIS and revised alternatives.
Table 2-2 indicates that there would be at-grade portions of NC 12 less than 230 feet (70.1
meters) west of the forecast 2060 high erosion shoreline, whereas there were none with the
detailed study alternatives presented in the FEIS. The length of the at-grade portions of NC 12
west of the 2060 high erosion shoreline would be approximately 1,310 feet (399.3 meters) with
the Road North/Bridge South and All Bridge alternatives, and approximately 764 feet (232.9
meters) with the Phased Approach/Rodanthe Bridge Alternative. For the Road North/Bridge
South and All Bridge alternatives, there also would be an increase in wetlands impacts of
approximately 0.8 acre (0.3 hectare) in comparison to the detailed study alternatives presented in
the FEIS, although there also would be a reduction in aquatic bottom impacts of approximately
0.4 acre (0.2 hectare). For the Phased Approach/Rodanthe Bridge Alternative, there would be an
increase of approximately 1.6 acres (0.7 hectare) in biotic communities impacts in comparison to
the alternative presented in the FEIS, but all of the increased impact would be to upland areas.
Bonner Bridge Replacement EA 2-9 NCDOT TIP Project Number B-2500
Table 2-2. Comparison of FEIS and EA Natural Environment Impacts with Road
North/Bridge South, All Bridge, and Phased Approach/Rodanthe Bridge Alternatives' in
the Rodanthe Area
Road North/Bridge South and All Phased Approach/
Bride Rodanthe Bridge
FEIS EA FEIS EA
Coastal Conditions Im acts
Potential for Breach
and Need for Closing Potential breach area north of Rodanthe Potential breach area north of Rodanthe

Breach to Maintain bridged. No expected need to close future bridged. No expected need to close future

NC 12 breaches. breaches.
At-Grade Portions of
NC 12 less than 230 1,310 feet (399.3 764 feet (232.9
feet (70.1 meters) None.
meters) None.
meters)
West of 2060 High
Erosion Shoreline
Natural Resources hn acts
Biotic Communities Fi ll and Pile Impacts, acres hectares
Submerged Aquatic 0.1 (0.1) 0.1 (0.1) 0.0 (0.0) 0.0 (0.0)
Vegetation (SAV)
Wetlands 0.9 (0.4) 2.0 (0.8) 0.0 (0.0) 0.0 (0.0)
Uplands - Natural
and Man Dominated 5.3 (2.1) 5.6 (2.2) 5.0 (2.0) 7.2 (2.9)
Impoundments 0.0 (0.0) 0.0 (0.0) 0.0 (0.0) 0.0 (0.0)
Aquatic Bottom 0.3 (0.1) 0.0 (0.0) 0.0 (0.0) 0.0 (0.0)
Total 6.6 (2.7) 7.7 (3.1) 5.0 (2.0) 7.2 (2.9)
Wetlands and SAV
Shaded, acres
(hectares)
Wetlands 1.6 (0.6) 1.5 (0.6) 0.0 (0.0) 0.0 (0.0)
SAV 5.4 (2.2) 5.3 (2.1) 0.0 (0.0) 0.0 (0.0)
Protected Species
Adversely Affected None likely. None likely. None likely. None likely.
'The Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative (Preferred) could include
implementation of the shared Road North/Bridge South and All Bridge alignment or the Phased Approach/Rodanthe
Bridge alignment as a part of a future phase in the Rodanthe area. The FEIS proposes improvements in the Rodanthe
area to be implemented as a part of Phase II of the project.
NOTE: There were no modifications made to the FEIS conceptual designs for the Nourishment and Phased
Approach/Rodanthe Nourishment alternatives in the Rodanthe area.
Based on the data presented in Table 2-2, the design changes in Rodanthe would result in no new
significant impacts to natural resources.
2.2 Elimination of the Pamlico Sound Bridge Corridor
as a Detailed Study Alternative
The Pamlico Sound Bridge Corridor was not identified as the Preferred Alternative in the FEIS.
On August 27, 2007, senior representatives of NCDOT, FHWA, USACE, and the North Carolina
Department of Environment and Natural Resources (NCDENR), meeting as the Merger 01
Dispute Resolution Board for the National Environmental Policy Act/Section 404 of the Clean
Water Act (NEPA/Section 404) Merger Process, concluded that the Pamlico Sound Bridge
Corridor was not a practicable alternative based on cost estimates and available funding. The
Dispute Resolution Board also selected the Parallel Bridge Corridor with Phased Approach/
Bonner Bridge Replacement EA 2-10 NCDOT TIP Project Number B-2500
Rodanthe Bridge Alternative as the Least Environmentally Damaging Practicable Alternative
(LEDPA). The Dispute Resolution Board met to make these decisions under the terms of the
Merger Dispute Resolution Process because the full NEPA/Section 404 Merger Team could not
reach a consensus. The Merger Process, including the dispute/conflict resolution process, is used
to streamline the project development and permitting processes for NCDOT projects. This
process for project decision-making is detailed in Section 8.3.1 of the FEIS. Generally, the
Merger Process provides environmental resource and regulatory agencies with the opportunity
formally to concur with key decisions in the impact assessment process; these decisions are
known as Concurrence Points. In the event that the Merger Team cannot agree on a specific
issue, the Merger Process includes a dispute resolution procedure in which conflicts are resolved
by management staff of the primary transportation and permitting agencies. The Merger Process
is agreed to by US Army Corps of Engineers (USACE), NCDENR (Division of Water Quality
and Division of Coastal Management), FHWA, and NCDOT and supported by other partnering
agencies and local units of government.
The US Department of the Interior (USDOI) did not agree with the Dispute Resolution Board's
decision and included in its comments on the FEIS that "Even though the information presented
in the FEIS and Section 4(f) Evaluation is proposing a Parallel Bridge Corridor alternative, it still
demonstrates that the implementation of any of the Parallel Bridge Corridor Alternatives may
violate Section 4(f) because the Pamlico Sound alternative would appear to be a feasible and
prudent alternative and would minimize harm to the Refuge (a section 4(f) property)."
FHWA did not consider the Pamlico Sound Bridge Corridor as an avoidance alternative for the
Refuge and Cape Hatteras National Seashore (Seashore) in the FEIS/Final Section 4(f) Evaluation
because, at that time, FHWA found the Pamlico Sound Bridge Corridor used land from the
Seashore (a Section 4(f) property). However, FHWA and NCDOT subsequently obtained
information showing that a public vehicular thoroughfare pre-dates the establishment of the
Seashore and that both were concurrently and jointly planned and developed to co-exist. Ina
Revised Final Section 4(f) Evaluation completed in October 2009, FHWA revised its use
determination for the Seashore to say that Section 4(f) is not applicable because the impacts
resulting from relocating NC 12 from its current alignment through the Seashore would not be
considered a use as defined in Title 23 Code of Federal Regulations Section 774.17. Thus, the
Pamlico Sound Bridge Corridor must be analyzed as a feasible and prudent avoidance alternative
for the Refuge under Section 4(f).
The Revised Final Section 4(f) Evaluation included a feasible and prudent Refuge avoidance
alternative analysis for the Pamlico Sound Bridge Corridor (see the Revised Final Section 4(f)
Evaluation document's Appendix G). The complete Revised Final Section 4(f) Evaluation is
included as Appendix B in this EA. FHWA determined that the Pamlico Sound Bridge Corridor
is not a feasible and prudent avoidance alternative to using the Refuge as an historic property, as
the cost of either of the Pamlico Sound Bridge Corridor alternatives would be of an extraordinary
magnitude based on the funding currently available and reasonably expected to be available in the
future to NCDOT to operate, improve, and maintain its state highway system.
To summarize the detailed Refuge avoidance alternative analysis contained in Appendix G of the
Revised Final Section 4(f) Evaluation, implementation of any of the Pamlico Sound Bridge
Corridor alternatives would require financing in its entirety a single construction phase costing
between $942.9 million and $1.441 billion (2006 dollars). The project could not be financed by
phasing construction (i.e., spreading out the cost over many years) because much of the 17.5-mile
(28.2-kilometer) long bridge would be approximately 5 miles (8 kilometers) west of Hatteras
Island in Pamlico Sound, so there would be no point at which to tie a partial bridge into existing
Bonner Bridge Replacement EA 2-11 NCDOT TIP Project Number B-2500
NC 12 to make it operational. Funding construction of a 17.5-mile (28.2-kilometer) long bridge
would create a unique maintenance problem of extraordinary magnitude for NCDOT as it would
have to defer much needed improvements on the remainder of the state highway system in North
Carolina for a significant period of time. The Pamlico Sound Bridge Corridor also would have
severe adverse impacts to the public's access to the Refuge and portion of the Seashore between
Rodanthe and Oregon Inlet, land area shared by the Refuge and the Seashore. Therefore, the
Pamlico Sound Bridge Corridor alternatives are not carried forward as detailed study alternatives
because they are not feasible and prudent avoidance alternatives.
In conclusion, FHWA's determination that the Pamlico Sound Bridge Corridor is not a feasible
and prudent Refuge avoidance alternative does not result in new information or circumstances
relevant to environmental concerns and bearings on the proposed action or its impacts that would
result in significant environmental impacts not evaluated in the FEIS. The FEIS, based on the
outcome of the Merger Process, already concluded that the Pamlico Sound Bridge Corridor was
not the LEDPA/Preferred Alternative based on cost estimates and available funding.
2.3 Preferred Alternative
FHWA and NCDOT propose a new alternative within the Parallel Bridge Corridor for detailed
study, the Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative. It
also has been selected as the new Preferred Alternative. It proposes to proceed with construction
of Phase I of the Parallel Bridge Corridor as soon as possible. Phase I of the Parallel Bridge
Corridor would consist of a parallel replacement structure on the west side of the existing Bonner
Bridge, similar to the structure proposed for the other Parallel Bridge Corridor alternatives. The
NC 12 Transportation Management Plan Alternative (Preferred) does not specify a particular
action at this time on Hatteras Island beyond the limits of Phase I, but includes a process for
determining the implementation timing and extent of future phases. Several aspects of this
alternative, including the phasing and the coastal monitoring program, are similar to the Phased
Approach/Rodanthe Bridge Alternative, which was selected as the Preferred Alternative in the
FEIS.
2.3.1 Development of the Preferred Alternative
Following the approval of the FEIS/Final Section 4(f) Evaluation in September 2008, FHWA and
NCDOT decided to pursue the Road North/Bridge South Alternative as the new LEDPA/
Preferred Alternative. There were two primary factors that led to this decision. First, FHWA and
NCDOT obtained information documenting the existence of a public vehicular thoroughfare and
records for public roads dating back to the time when the Refuge and Seashore were established.
The research indicated that NC 12 had been relocated four times as a result of shoreline erosion
caused by storm events, and the Refuge had approved these relocations with no documented
significant effects. Second, in their comment letter on the FEIS/Final Section 4(f) Evaluation
(Appendix E), USDOI stated that impacts to the Refuge would be lessened with an at-grade road
(which the Road North/Bridge South Alternative provides) rather than the elevated roadway
included in the Phased Approach/ Rodanthe Bridge Alternative (the Preferred Alternative in the
FEIS/Final Section 4(f) Evaluation). In its comment letter (Appendix E), the North Carolina
Department of Cultural Resources (NCDCR) also stated concerns regarding the visual impact of
the Phased Approach bridges to both the Refuge and the Rodanthe Historic District. Though not
central to the decision to pursue the Road North/Bridge South Alternative as the new
LEDPA/Preferred Alternative, there also would be substantial cost savings with the Road North/
Bonner Bridge Replacement EA 2-12 NCDOT TIP Project Number B-2500
Bridge South Alternative in comparison to the Phased Approach/Rodanthe Bridge Alternative
(see Section 2.3.7).
During the May 21, 2009, Merger Team meeting (see Section 3.3.3), the representatives of
several member agencies stated that they could not concur with the Road North/Bridge South
Alternative as the new LEDPA/Preferred Alternative because of the amount of wetland impacts
caused by the road relocation component. The US Environmental Protection Agency (USEPA)
representative then recommended that NCDOT move forward with the construction of the
replacement of Bonner Bridge along the Parallel Bridge Corridor over Oregon Inlet, but not
prescribe a solution for the balance of the project at this time since it is very difficult to predict
the timing and impact of storm events on the shoreline. For later phases, the USEPA
representative recommended that an interagency, collaborative adaptive management strategy be
developed. The Merger Team agreed that the USEPA representative's proposal fit within the
terms of the August 27, 2007, Concurrence Point 3 Agreement (LEDPA) in that:
1. It would involve replacement of the Oregon Inlet bridge as Phase I; and
2. The alternative recognizes that completion of Phase I alone would not meet the purpose and
need of the project and represented a commitment by all parties to develop and implement the
entire action from Rodanthe to Bodie Island.
Following the meeting, FHWA and NCDOT developed a description of the new Preferred
Alternative, eventually titled the Parallel Bridge Corridor with NC 12 Transportation
Management Plan, and circulated it to the Merger Team on June 18, 2009, for review and
comment. The description of this alternative in the following sections is based on the initial
description, as well as comments made by Merger Team members during subsequent meetings
and comments on the Revised Final Section 4(f) Evaluation.
2.3.2 Characteristics of the Preferred Alternative
2.3.2.1 Phase I
Phase I of the NC 12 Transportation Management Plan Alternative (Preferred) is a variation of
the Oregon Inlet bridge proposed for the other Parallel Bridge Corridor alternatives in the FEIS.
The only changes proposed to the Oregon Inlet bridge are at the southern end of the structure and
are as a result of negotiations with US Fish and Wildlife Service (USFWS) on the exact location
of the southern terminus.
In June 2009, FHWA and NCDOT began coordination with the Refuge on the alignment for
Phase L NCDOT submitted revised designs for the southern terminus of the Oregon Inlet bridge
components of the Parallel Bridge Corridor with Nourishment, Road North/Bridge South, and
Phased Approach alternatives. Each of these alternatives were extended to the south by
approximately 2,000 feet (610 meters) as a part Oregon Inlet bridge construction (Phase I) to
account for potential sound-side erosion at the north end of Hatteras Island (see Figure 2-6),
based upon discussions at the November 2008 Merger Team meeting (Section 3.3.1).
In making the above revisions, the length of the navigation zone for all of the Parallel Bridge
Corridor alternatives is 3,300 feet (1,006 meters) in order to lower the Oregon Inlet bridge height
as it enters Hatteras Island. The navigation zone for the Phased Approach alternatives, already
3,300 feet (1,006 meters) in length, did not change. A final navigation zone will be determined
during final design of Phase I in coordination with the USACE and the US Coast Guard (USCG).
Bonner Bridge Replacement EA 2-13 NCDOT TIP Project Number B-2500
On July 15, 2009, FHWA and NCDOT met with Refuge representatives in the Refuge to discuss
the June 2009 modifications to the FEIS Phase I alignments described above. As an alternative to
the concepts presented by FHWA and NCDOT, Refuge representatives presented a map showing
limits of what the Refuge would consider to be a minor revision of the easement for Phase I
roadway improvements in the Refuge that would not require a compatibility determination for
compliance with the National Wildlife Refuge System Improvement Act of 1997.
Subsequently, NCDOT developed a conceptual design that stayed within the limits provided by
the Refuge. NCDOT also developed a second conceptual design in which the alignment
traversed just west of the limits provided by the Refuge and tied into NC 12 south of these limits.
The latter conceptual design was developed to provide a safer distance between existing NC 12
and the new Oregon Inlet bridge during construction, as well as improved access to the National
Park Service (NPS) parking lot on the east side of NC 12 at the northern end of Hatteras Island.
On September 2, 2009, FHWA and NCDOT presented the two conceptual designs discussed
above to Refuge representatives at a meeting at USFWS's Alligator River National Wildlife
Refuge Office in Manteo, North Carolina. FHWA and NCDOT recommended that the
conceptual design located just west of the limits provided by the Refuge be approved because of
their concerns related to traffic control during construction and access to the parking lot located at
Oregon Inlet. In correspondence to NCDOT representatives dated September 24, 2009, the
Refuge indicated that the conceptual design that was beyond the original limits provided to
FHWA and NCDOT in July was acceptable and likely represented the limits of what could be
considered a minor modification of the existing easement. This conceptual design was adopted as
Phase I of the Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative
(Preferred) as evaluated in the Revised Final Section 4(f) Evaluation, which was approved on
October 9, 2009 (see Appendix B). The area of new easement needed for this alignment would
be approximately 3.5 acres (1.4 hectares), while the amount of existing NC 12 easement returned
to the Refuge would be approximately 2.7 acres (1.1 hectares). These amounts are slightly
different from those presented in the Revised Final Section 4(f) Evaluation; it was determined
during preliminary design that additional easement area was needed in order to provide access
from NC 12 to the access road that leads to the (former) Oregon Inlet US Coast Guard Station and
to provide access to the NPS parking lot. The original NC 12 Transportation Management Plan
Alternative (Preferred) drawing, which indicated that 3.08 acres (1.25 hectares) of new easement
was needed and 2.7 acres (1.1 hectares) of existing NC 12 easement would be returned, was
based on a conceptual design. The preliminary design added additional design detail related to
the ending of the bridge approach fill and its intersection with the access road. This detail
revealed the need for additional easement to bring the access road shoulder from the access road
elevation to the elevation of the surrounding terrain. The change is reflected in Figure 2-5.
As shown in Figure 2-6, the adopted alignment of Phase I of the Parallel Bridge Corridor with
NC 12 Transportation Management Plan Alternative (Preferred) would enter the north end of
Hatteras Island approximately 212 feet (64.6 meters) west of Bonner Bridge and the existing
NC 12 easement, but it would fully return to the existing easement approximately 2,640 feet
(804.7 meters) south of the point the bridge enters Hatteras Island. With this alignment, the
Oregon Inlet bridge would end approximately 700 feet (213.4 meters) south of the end of Phase I
of the Phased Approach alternatives as presented in the FEIS. The Phase I alignment of the
NC 12 Transportation Management Plan Alternative (Preferred) falls within the termini of the
other Parallel Bridge Corridor alternatives.
A single conceptual alignment for Phase I is under consideration at the Bodie Island terminus of
the proposed project. It is unchanged from that presented in the FEIS and is the same for the
Bonner Bridge Replacement EA 2-14 NCDOT TIP Project Number B-2500

Pea Island
National Wildlife
Refuge
A*

_ 12 '---
Pea Island
National Wildlife
Refuge
efuge
irking
/ (Former) US . Coast
Guard Station /

CHANGE IN PROPOSED PHASE I EASEMENT Figure
SINCE REVISED FINAL SECTION 4(F) EVALUATION 2-5
?i
i

s Y `?
qw
.-o
G?
0 .25 .5 KM
0 .25 .5 Mile
Bodie o
Island
Hatteras
. Island

.y
?N
O?
MOM-" tI

PARALLEL BRIDGE CORRIDOR ALTERNATIVES - Figure
PHASE 1 2-6
O;tA
LEGEND
Preferred Phase I Alignment
Phased Approach (Original Alignment) and
Nourishment Alternatives - Phase I
Road North/Bridge South Alternative - Phase I
All Bridge Alternative - Phase I

? 1

NC 12 Transportation Management Plan Phase L The final design in this location would be
developed in coordination with NPS so as to minimize adverse impacts to Seashore resources
The main bridge structure for the new Oregon Inlet bridge would be designed in coordination
with USACE and USCG, including finalizing the location of the navigation zone. All aspects of
Phase I would be designed to conform to North Carolina highway specifications as approved by
FHWA and NCDOT to ensure the safe construction and operation of the highway. In addition,
other state and federal environmental resource and regulatory agencies would have an opportunity
to review and comment on the final design prior to authorization of construction.
The impacts of Phase I of the NC 12 Transportation Management Plan alignment are reflected in
the impact findings presented in Section 0, and the project costs are presented in Section 2.3.7.
As discussed in Section 4.5.3.2 of the FEIS, NCDOT maintains catwalks on the southern end of
Bonner Bridge. The catwalks provide access to the public to fish at Oregon Inlet. Because of the
design modifications made to Phase I of all of the Parallel Bridge Corridor alternatives, all of the
possible Oregon Inlet bridges would be approximately 25 feet (7.6 meters) above mean high
water (33.5 feet [ 10.2 meters] at the top of the bridge deck) as they enter Hatteras Island.
Catwalks attached to the new structure for any of the alternatives would be approximately 33.5
feet (10.2 meters) above the mean high water line; a catwalk at this height increases the
likelihood of serious, if not fatal, injuries as a result of falls. With the NC 12 Transportation
Management Plan Alternative, options for providing fishing access include:
• Leave a portion of the existing Bonner Bridge open for use as a fishing pier;
• Construction of a "boardwalk" on top of the riprap currently located on the northern shore of
Hatteras Island; and
• Widening a short section of the new structure to provide pedestrian access, separated from
traffic by a barrier.
Fishing from the terminal groin itself is still not considered a viable option because of the rapid
currents adjacent to the groin and the uneven surface of the groin itself. The type of access
provided will be determined during the final design of Phase I; however, NCDOT is committed to
restoring access to fishing at the northern end of Hatteras Island once construction of Phase I is
complete. The existing catwalks will remain open to the public during construction as long as it
is safely viable.
2.3.2.2 Later Phases (NC 12 Transportation Management Plan)
The Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative
(Preferred) does not specify a particular action at this time on Hatteras Island beyond the limits of
Phase I because of the inherent uncertainty in predicting future conditions within the dynamic
coastal barrier island environment. Instead, the alternative addresses the study and selection of
future actions on Hatteras Island beyond the limits of Phase I through a comprehensive NC 12
Transportation Management Plan. By actively monitoring the conditions and delaying decision-
making, the environmental impacts can be better quantified, minimized, and mitigated. This
process is somewhat analogous to a tiered NEPA study, in that the entire end-to-end impacts have
been studied but the detailed selection of a portion of the action is being delayed. If the Parallel
Bridge Corridor with NC 12 Transportation Management Plan Alternative (Preferred) is selected,
Bonner Bridge Replacement EA 2-17 NCDOT TIP Project Number B-2500
the details of the NC 12 Transportation Management Plan would be finalized through
commitments made in the Record of Decision.
The alternative includes the following measures:
• NCDOT will fund and implement a coastal monitoring program on Hatteras Island within the
project study area. The results of the monitoring program will be used to determine when
planning of future phases of the project should begin.
NCDOT and FHWA will utilize the results of the coastal monitoring program to determine
when the environmental review for each phase should be initiated.
• The NEPA/Section 404 Merger Process will be utilized to study, select, and finalize future
phases.
The NC 12 Transportation Management Plan set forth in this section incorporates the baseline
coastal conditions identified in the FEIS (in section 3.6.2,"Existing Coastal Conditions") and then
provides a detailed plan to closely monitor the coastal conditions for environmental changes over
the next 50 years along with changes in associated road maintenance activities. Formal reports of
the monitoring findings and updates to the forecasted shoreline predictions would be generated
annually. Regular coordination with interested federal, state, and local agencies and the public
would be conducted. When the coastal monitoring program identifies specified conditions at a
location, then the NC 12 Transportation Management Plan would provide for the initiation of an
environmental review of a future phase action at that location. The NC 12 Transportation
Management Plan then describes the process for decision-making regarding the future phase
actions.
Public and agency comments submitted about this proposed NC 12 Transportation Management
Plan may be submitted during the EA comment period. All comments received will be fully
considered, and the proposed NC 12 Transportation Management Plan may be modified in
response to such comments.
Coastal Monitoring Program
The NC 12 Transportation Management Plan would include a comprehensive coastal monitoring
program, similar to but more refined than that proposed for the Phased Approach alternatives (see
Section 2.10.2.5 of the FEIS). The coastal monitoring program would measure changes in the
conditions on NC 12 and the surrounding environment as compared to baseline coastal
conditions, for the purpose of guiding NCDOT's planning for future phases of action through
2060. NCDOT would implement the coastal monitoring program immediately after the Record
of Decision is signed.
As indicated above, the baseline coastal conditions for the NC 12 Transportation Management
Plan are set forth in section 3.6.2 of the FEIS, "Existing Coastal Conditions." In Section 3.6.3,
the FEIS summarizes the predicted average and high erosion future shorelines in the project area
for each decade through the year 2060 and assesses the potential likelihood, location, depth, and
width of a breach to open in the project area through the year 2060. Section 4.6.8.6 of the FEIS
describes the five characteristic types of maintenance activities needed to keep NC 12 clear and
open to traffic in detail and sets forth the baseline conditions for each. Based on past experience,
the five characteristic types of maintenance activities are: road scraping, dune maintenance, dune
rebuilding, sandbag-based dune and berm replenishment, and dune translation. The coastal
Bonner Bridge Replacement EA 2-18 NCDOT TIP Project Number B-2500
monitoring program detailed below would be used to update the predicted shorelines and other
coastal data discussed in the FEIS.
NCDOT would gather the following data within the project area on Hatteras Island:
• Geomorphological characteristics of the corridor including the width and elevation of the
island, dune height and vegetation, shoreline position, and nearshore bathymetry;
• Relative distance from NC 12 to critical geomorphological features including the shoreline,
dune, and estuarine shoreline for each section of the corridor;
• The extent and location of overwash occurrences for each section of the corridor;
• NC 12 roadway maintenance data, including the activities needed to maintain traffic and the
manpower and cost involved, amount of time NC 12 is closed or reduced to one-lane traffic
following storm events, etc.;
• Dredge disposal and beach nourishment projects undertaken by any party within the corridor
or the adjacent nearshore area including the volume of sand involved and the location and
method of placement; and
• Data about major storm events.
The data gathered would be compared to the baseline conditions, and any changes noted would be
tracked and assessed. The majority of the physical information would be collected utilizing
NCDOT aerial photography, which would be generated biannually and immediately following
storm events as needed. This is consistent with current NCDOT practice; in recognition of the
dynamic conditions within the project area, NCDOT has generated aerial photography biannually
and following major storm events since 2002. Roadway maintenance data would be generated by
NCDOT maintenance staff. Data regarding disposal or nourishment projects would be requested
from the appropriate federal or state agencies overseeing those projects. Storm data would be
compiled from agencies that track meteorological events, including the National Oceanic and
Atmospheric Administration (NOAA), the National Hurricane Center, the State Climate Office,
and other agencies as appropriate.
A report detailing the findings of the coastal monitoring program would be prepared on an annual
basis. The erosion rates used to generate the baseline shoreline predictions also would be
reassessed annually. NCDOT would provide a draft of each annual report to the Refuge manager
for review. The draft report may be refined based on Refuge input. NCDOT would submit the
final annual coastal monitoring reports to the Merger Team and would also post the reports on the
internet for public review. An additional report that combines the monitoring findings with other
geologic and biological datasets from other ongoing agency or university studies would be
prepared every five years.
These efforts would be combined with the existing shoreline monitoring program that is
underway as required by the existing terminal groin permit; any future monitoring efforts
required as part of any new terminal groin permit also would be combined with the coastal
monitoring. The coastal monitoring would be conducted by NCDOT staff (those with experience
in aerial photography, coastal hydraulics, surveying, and roadway maintenance) and qualified
coastal engineering consultants approved by NCDOT.
Bonner Bridge Replacement EA 2-19 NCDOT TIP Project Number B-2500
Environmental Review for Future Phases
The purpose of the environmental review is to determine, in coordination with all interested
agencies and with an opportunity for public involvement, whether additional environmental study
of a proposed future phase is needed prior to undertaking the future phase action. The
environmental review would study the proposed action and the status of compliance with
environmental laws that may be applicable to the proposed phase of action including, but not
limited to, Section 4(f), the National Historic Preservation Act, the Endangered Species Act, the
Magnuson-Stevens Fishery Conservation and Management Act, the Coastal Area Management
Act, the National Wildlife Refuge System Improvement Act of 1997, and the Clean Water Act.
FHWA and NCDOT also would complete the appropriate NEPA documentation for each future
phase of action in accordance with 23 CFR 771.129-130. Environmental conditions and the
timing of each phase would be the primary factors in determining what type of NEPA
documentation (a re-evaluation, a supplement, or a separate NEPA process) is the most
appropriate.
The results of the coastal monitoring program and the updated shoreline erosion predictions
would be used by NCDOT and FHWA, in consultation with representatives of the Refuge, to
determine when an environmental review for each individual future phase of action would be
initiated, the limits of the action area, potential actions that should be considered for the location
and measures to minimize and mitigate impacts. Based on previous NCDOT experience, findings
that may warrant initiating an environmental review of a future phase include:
• An area with weak dunes (e.g., low dunes that lack vegetation) that potentially requires
higher levels of storm-related NC 12 maintenance activity, proximity of the dune to NC 12,
and the rate dunes may be advancing towards NC 12 (this recognizes that the frequency of
dune maintenance is highest when a dune is less than 25 feet (7.6 meters) from the road);
• Significant increases in erosion rates over past trends;
• Significant increases in NC 12 storm-related maintenance frequency or activity over previous
years;
• A determination that the distance between the active shoreline (mean high water) and NC 12
is below the critical buffer distance of 230 feet (70.1 meters) within the next five years; or
• A determination that shoreline and dune conditions are such that the need for storm-related
maintenance is likely to escalate significantly in the next five years.
As of the publication of this EA, sections of the Canal Zone, Sandbag Area, and Rodanthe hot
spot areas (see Figure 2-7) may already meet one or more of the listed criteria. The Rodanthe hot
spot area was especially affected by a major storm event in November 2009 (Section 3.5.6). The
coastal monitoring program will provide the information needed to determine when future phases
of action will be initiated in these areas.
Selection ofFuture Phases for Implementation
Once NCDOT and FHWA decide to initiate an environmental review of a later phase in
consultation with the Refuge as described above, the study, selection, and finalizing of that phase
will follow the provisions of the NEPA/Section 404 Merger Process that is currently utilized by
NCDOT. Because the purpose and need (Concurrence Point 1) of the overall project will not
Bonner Bridge Replacement EA 2-20 NCDOT TIP Project Number B-2500
b
Roanoke
Island
E
Bodie
Island
0
Duck
Island
c?
x o
n
O
00
Bonner
Bridge p9
v
t?
O
C
Terminal
/ Groin
Canal Zone
Hot Spot
60 ?
r
rf
6 ?
0 1'
1
of J' Sandbag Area
Pea Island Hot Spot
National Mildlife
Refuge
Hatteras
Island
0 1 2 KM
0 1 2 Miles
RODANTHE
Emergency
Ferry Dock

Rodanthe 'S'
Curves Hot Spot
Chicamacomico
Life Saving Station
Figure
HOT SPOT LOCATIONS 2-7
change, NCDOT and FHWA would likely reconvene the Merger Team at Concurrence Point 2,
the selection of Detailed Study Alternatives.
2.3.3 Impact Assessment
2.3.3.1 FEIS PhaseIAlignmentModificationImpacts
The modifications to the FEIS Phase I alignments discussed in Section 2.3.2.1 primarily would
change the visual impact of the bridge within the Refuge and near the (former) Oregon Inlet US
Coast Guard Station. The historic resource impact in the Oregon Inlet area is related to the visual
impact (as discussed on pages 4-36 to 4-39 of the FEIS). The visual change at the north end of
Hatteras Island would increase with a longer bridge for the Road North/Bridge South and
Nourishment alternatives. The visual change associated with these revised alternatives would be
similar to the visual change with the Phased Approach alternatives, as well as with the All Bridge
Alternative, which both already include a longer Oregon Inlet bridge by definition. All of the
Phase I bridges would enter Hatteras Island approximately 25 feet (7.6 meters) above mean high
water, which is lower than the 75-foot (22.9-meter) height proposed in the FEIS. Even though all
of the proposed Phase I bridges would still be higher and longer than the existing structure,
thereby introducing additional bridging next to the (former) Oregon Inlet US Coast Guard Station
and the Refuge, the change in visual impact between the FEIS and the EA is not substantial.
Recreational facility access would be maintained in the area with these changes to the FEIS Phase
I alternatives.
Impacts to biological resources associated with these changes to the FEIS Phase I alternatives
would be similar to the impacts presented in the FEIS. The wetland impacts for the Road
North/Bridge South Alternative would decrease from 5.9 acres (2.4 hectares) to 1.9 acres (0.8
hectare) with the additional bridge length. With the Phased Approach alternatives, the wetland
impacts for Phase I were 0.6 acre (0.2 hectare) in the FEIS but would increase slightly with the
longer bridge to 0.7 acre (0.3 hectare). The reason for this slight increase in Phase I wetland
impacts for the Phased Approach alternatives is the frontage roads required on either side of the
extended bridge to maintain access to NC 12 and the (former) Oregon Inlet US Coast Guard
Station. However, these same frontage roads would be needed after the completion of Phase II to
provide access to the (former) Oregon Inlet US Coast Guard Station whether the Oregon Inlet
bridge is extended approximately 2,000 feet (610 meters) or not. Thus, this apparent difference
reflects more the timing of an impact with the Phased Approach alternatives than a difference in
total area of impact. Protected species impacts would not change from that discussed in Section
4.7.9 of the FEIS. Aside from the benefit of minimizing breach risk with the revised alternatives,
the coastal conditions impacts would be similar between the FEIS and revised alternatives (see
Section 4.6 of the FEIS).
2.3.3.2 NC 12 Transportation Management Plan Impacts
Phase I of the NC 12 Transportation Management Plan Alternative (Preferred), given its southern
terminus location between the Phased Approach alternatives and the Road North/Bridge South
Alternative, would have visual and cultural resource impacts similar to those other alternatives.
Like all of the other Parallel Bridge Corridor alternatives, recreational facility access would be
maintained in the area. For Phase I of the NC 12 Transportation Management Plan Alternative
(Preferred), the wetland impact would be 1.0 acre (0.4 hectare). The wetland impact is slightly
higher than the Phased Approach alternatives (0.6 acre [0.2 hectare]) and slightly less than the
Road North/Bridge South Alternative (1.9 acres [0.8 hectare]). These differences are not
significant given that wetlands are widespread in the area. Because of its shorter Oregon Inlet
bridge (i.e., extended only approximately 700 feet [213.4 meters] versus approximately 2,000 feet
Bonner Bridge Replacement EA 2-22 NCDOT TIP Project Number B-2500
[6 10 meters] with the other modified FEIS alignments discussed above), Phase I of the NC 12
Transportation Management Plan Alternative (Preferred) would be more likely to be affected
should a deep breach result from sound-side erosion near the terminal groin (one of the five
potential breach locations within the project area).
Table 2-3 presents a comparison of the updated human impact environments for Phase I of the
detailed study alternatives as a result of design changes at Oregon Inlet. The historic resources
effects findings presented in this table were determined in association with representatives of the
HPO and the ACHP.
Table 2-4 presents a comparison of key natural environment impact issues for Phase I of the FEIS
and revised alternatives. Key natural environment impact issues in this area are effects related to
coastal conditions and natural resource impacts.
2.3.3.3 Jurisdictional Uses
Table 2-5 shows the impact on jurisdictional resources for Phase I of the Parallel Bridge Corridor
alternatives under Section 404 of the Clean Water Act by wetland biotic community type.
Coastal Area Management Act (CAMA) coastal wetlands and impacts are identified. Table 2-6
shows the impacts for all phases of the Parallel Bridge Corridor alternatives. Table 2-6 of this EA
replaces Table 4-25 of the FEIS. Both tables reflect the updates to the Parallel Bridge Corridor
alternatives described in Sections 2.1 and 2.3.2.1. This information is being provided for the
purpose of supplying the detailed information needed by USACE as part of its responsibilities
under Section 404. The changes in total wetland impacts by fill or piles for the Parallel Bridge
Corridor alternatives between those depicted in Table 4-25 in the FEIS and those depicted in
Table 2-6 range from a decrease of 0.21 acre (0.08 hectare) to an increase of 3.05 acres (1.23
hectares). The changes in impacts from shading range from an increase of 0.38 acre (0.15
hectare) to an increase of 1.86 acres (0.75 hectare). The changes in total wetlands and waters
affected by fill or piles for the Parallel Bridge Corridor alternatives between those depicted in
Table 4-25 in the FEIS and those depicted in Table 2-6 range from a decrease of 0.30 acre (0.12
hectare) to an increase of 1.43 acres (0.58 hectare). The changes in impacts from shading range
from an increase of 1.53 acres (0.62 hectare) to an increase of 4.59 acres (1.86 hectares). Given
that wetlands and other waters dominate the project area as illustrated in Figure E-2 of the FEIS,
these changes are small and not significant.
2.3.3.4 Threatened and Endangered Species
F14WA and NCDOT contacted USFWS and NOAA Fisheries to determine whether re-initiation
of Section 7 consultation would be necessary if the Preferred Alternative changed from the
Phased Approach/Rodanthe Bridge Alternative to the Road North/Bridge South Alternative.
Both agencies agreed (USFWS in April2009 and NOAA in May 2009) that it was not necessary
to re-initiate consultation if that change were to occur. FHWA and NCDOT contacted USFWS
and NOAA Fisheries again to determine whether re-initiation of consultation was necessary for
Phase I of the new Preferred Alternative, the NC 12 Transportation Management Plan. USFWS
responded in August 2009 that it was not necessary. NOAA Fisheries has not yet responded as of
the date of this document and no additional Section 7 consultation with NOAA Fisheries is
expected.
2.3.3.5 Essential Fish Habitat
The FEIS contained an analysis of the effects of the then-preferred alternative (Parallel Bridge
Corridor with Phased Approach/Rodanthe Bridge) on Essential Fish Habitat (EFH). The analysis
found that the overall effect of the project on EFH is not anticipated to be adverse. In
commenting on the FEIS in a letter dated October 27, 2008, NOAA Fisheries did not object to
Bonner Bridge Replacement EA 2-23 NCDOT TIP Project Number B-2500
Table 2-3. Comparison of FEIS and EA Alternatives Human Environment Impacts for
Phase I (Oregon Inlet Bridge)
NC 12
Nourishment and Phased Transportation
Road North/Bridge South Approach Alternatives Management
Plan
(Preferred)
FEIS EA FEIS EA EA
Sizable visual
Sizable visual intrusion intrusion into the
into the Phase I Sizable visual intrusion into the Phase I (Oregon
Inlet) area.
(Oregon Inlet) area Phase I (Oregon Inlet) area. Bridge is
Visual change in the similar to the Phased Both the Nourishment and approximately
Visual Phase I (Oregon Inlet) Approach and All Phased Approach bridges are 1,300 feet (396
Impact area of the Refuge with Bridge alternatives. 2,000 feet (610 meters) longer, meters) shorter
higher bridge. Bridge is 2,000 feet and the Nourishment bridge is than other Parallel
(610 meters) longer, but 50 feet (15.2 meters) lower in Bridge Corridor
is 50 feet (15.2 meters) height (consistent with the
alternatives and
lower in height as it Phased Approach). the same height as
crosses Hatteras Island. it enters the
Refuge.
Cultural Resource Im acts
Pea Island
National
Wildlife Adverse Effect to the Refuge as a historic resource. Adverse Effect to the Refuge as a historic resource.
Refuge
(Former)
Oregon Inlet Adverse Effect. Adverse Effect
US Coast
Guard Station
Parks and Recreation I n pacts
Refuge Access
Access maintained to Refuge facilities and the Access maintained to Refuge facilities and the
• General (former) Oregon Inlet US Coast Guard Station in (former) Oregon Inlet US Coast Guard Station in
vicinity of Oregon Inlet. vicinity of Oregon Inlet.
• Fishing
Access No fishing catwalks; alternative access possible. No fishing catwalks; alternate access possible.
NC 12 Easement in Refuge
• New, acres
(hectares) 6.4 acres (2.6 hectares) 6.4 acres (2.6 hectares) None. None. 3.5 acres (1.4
hectares)
• Existing
returned, 4.8 acres (1.9 hectares) 4.8 acres (1.9 hectares) None. None. 2.7 (1.1 hectares)'
acres
(hectares)
Seashore The alignment is the same within the Seashore on The three alignments are the same in the Seashore on
Impact Bodie Island; no existing NPS facilities displaced. Bodie Island; no existing NPS facilities displaced.
NC 12 Easement in Seashore
• New, acres 6.3 acres 6.3 acres
(hectares) (2.6 hectares) (2.6 hectares)
• Existing
returned, 6.3 acres 6.3 acres
acres (2.6 hectares) (2.6 hectares)
(hectares)
Note: The southern terminus of the All Bridge Alternative was not modified so no FEIS versus EA impact comparison is
needed.
' Area impacts are slightly different from those listed in the Revised Final Section 4(f) Evaluation (October 2009) as a result
of minor changes made in the preliminary design of the alternative.
Bonner Bridge Replacement EA 2-24 NCDOT TIP Project Number B-2500
Table 2-4. Comparison of FEIS and EA Alternatives Natural Environment Impacts for
Phase I (Oregon Inlet Bridge)
NC 12
Nourishment and Phased Transportation
Road North/Bridge South Approach Alternatives Management
Plan
(Preferred)
FEIS EA FEIS EA EA
Coastal Conditions Impacts
Need for Terminal
Retain
Retain
Groin Retention . .
Potential deep
Potential deep breach A deep breach area
Sound-Side Erosion
A deep breach near
area associated with
breach near associated A deep breach
on North End of
the terminal groin
sound-side erosion
the terminal with sound- near the terminal
Hatteras Island that could be difficult to near terminal groin groin could side
erosion

be
groin could
Could Cause a
fill with sand.
would be bridged in
be difficult to
near
terminal

fill
difficult
Breach
Phase L
fill with sand. groin
sand.
with sand.
be bridged in
Phase I.
Natural Resources Impacts
Biotic Communities Fill and Pile Impacts, acres (hectares)
• Submerged
Aquatic
Vegetation 0.3 (0.1) 0.3 (0.1) 0.2 (0.1) 0.2 (0.1) 0.2 (0.1)
(SAV)
• Wetlands 5.9 (2.4) 1.9 (0.8) 0.6 (0.2) 0.8 (0.3) 1.0 (0.4)
• Uplands -
Natural and Man 1.5 (0.6) 2.8 (1.1) 1.5 (0.6) 4.1 (1.7) 3.8 (1.5)
Dominated
• Impoundments 0.0 (0.0) 0.0 (0.0) 0.0 (0.0) 0.0 (0.0) 0.0 (0.0)
• Aquatic Bottom 2.5(l.0) 2.4(l.0) 2.1 (0.8) 2.1 (0.8) 2.2 (0.9)
Total 10.2 (4.1) 7.5 (3.0) 4.4(l.8) 7.2 (2.9) 7.3 (2.9)
Wetlands and SAV shaded, acres (hectares)
• Wetlands 2.0 (0.8) 3.3(l.3) 1.4 (0.6) 1.4 (0.6) 2.2 (0.9)
• SAV 0.9 (0.4) 0.9 (0.4) 0.9 (0.4) 0.9 (0.4) 0.9 (0.4)
Likely disturbance to piping plover and sea Likely disturbance to piping plover and sea turtles
Protected Species turtles nesting on beach, but not likely to nesting on beach, but not likely to adversely affect in
Impacts adversely affect in ocean. Not likely to ocean. Not likely to adversely affect seabeach
adversely affect seabeach amaranth. amaranth.
Note: The southern terminus of the All Bridge Alternative was not modified so no FEIS versus EA impact comparison is
needed.
Bonner Bridge Replacement EA 2-25 NCDOT TIP Project Number B-2500
Table 2-5. Phase I Shading, Fill, and Pile Placement Impacts to Wetlands and Waters for the Parallel Bridge Corridor Alternatives
N
N
Nourishment Road North/Bridge Phased Approach/ Phased Approach/ NC 12 Transportation
Alternative in Acres South Alternative in All Bridge Alternative in Rodanthe Bridge Rodanthe Nourishment Management Plan
Biotic Community (hectares) Acres (hectares) Acres (hectares) Alternative in Acres Alternative in Acres Alternative in Acres
hectares hectares hectares
Shading Fill and Shading Fill and Shading Fill and Shading Fill and Shading Fill and Shading Fill and
Pile Pile Pile Pile Pile Pile
Open Water
• Aquatic bottom
(sound/other waters) 8.86 (3.59) 2.13 (0.86) 8.19 (3.31) 2.44 (0.99) 8.31 (3.36) 2.53 (1.02) 8.87 (3.59) 2.13 (0.86) 8.87 (3.59) 2.13 (0.86) 7.86 (3.18) 2.23 (0.90)
• SAV' 0.91 (0.37) 0.22 (0.09) 0.91 (0.37) 0.27 (0.11) 0.91 (0.37) 0.27 (0.11) 0.91 (0.37) 0.22 (0.09) 0.91 (0.37) 0.22 (0.09) 0.91 (0.37) 0.22 (0.09)
• Impoundments 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
TOTAL OPEN
WATER/SAV IMPACT 9.77 (3.95) 2.35 (0.95) 9.10 (3.68) 2.71 (1.10) 9.22 (3.73) 2.80 (1.13) 9.78 (3.96) 2.35 (0.95) 9.78 (3.96) 2.35 (0.95) 8.77 (3.54) 2.45 (0.99)
Wetland
• Wetland man-
dominated 0.00 (0.00) 0.15 (0.06) 0.02 (0.01) 0.15 (0.06) 0.00 (0.00) 0.15 (0.06) 0.00 (0.00) 0.15 (0.06) 0.00 (0.00) 0.15 (0.06) 0.12 (0.05) 0.20 (0.08)
• Salt shrub/grasslands 0.00 (0.00) 0.07 (0.03) 0.00 (0.00) 0.28 (0.11) 0.58 (0.23) 0.48 (0.19) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Wetland maritime 0.00 (0.00) 0.33 (0.13) 0.13 (0.05) 0.46 (0.19) 0.00 (0.00) 0.38 (0.15) 0.00 (0.00) 0.09 (0.04) 0.00 (0.00) 0.09 (0.04) 0.00 (0.00) 0.09 (0.04)
grassland
• Wetland overwash 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Wetland maritime 0.38 (0.15) 0.25 (0.10) 1.10 (0.45) 0.32 (0.13) 0.37 (0.15) 0.13 (0.05) 0.39 (0.16) 0.25 (0.10) 0.39 (0.16) 0.25 (0.10) 0.45 (0.18) 0.27 (0.11)
shrub thicket
• Reed stand 0.00 (0.00) 0.01 (0.00) 0.21 (0.08) 0.03 (0.01) 0.10 (0.04) 0.03 (0.01) 0.00 (0.00) 0.01 (0.00) 0.00 (0.00) 0.01 (0.00) 0.32 (0.13) 0.05 (0.02)
• Salt flat' 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Brackish marsh' 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Smooth cordgrass' 0.53 (0.21) 0.16 (0.06) 0.54 (0.22) 0.20 (0.08) 0.54 (0.22) 0.20 (0.08) 0.53 (0.22) 0.16 (0.06) 0.53 (0.22) 0.16 (0.06) 0.59 (0.24) 0.18 (0.07)
• Black needlerush' 0.47 (0.19) 0.11 (0.04) 1.28 (0.52) 0.46 (0.19) 1.67 (0.68) 0.68 (0.28) 0.47 (0.19) 0.11 (0.04) 0.47 (0.19) 0.11 (0.04) 0.75 (0.30) 0.23 (0.09)
TOTAL WETLAND
IMPACT 1.38 (0.56) 1.08 (0.44) 3.28 (1.33) 1.91 (0.77) 3.26 (1.32) 2.05 (0.83) 1.39 (0.56) 0.77 (0.31) 1.39 (0.56) 0.77 (0.31) 2.23 (0.90) 1.02 (0.41)
Intertidal Beach NA NA NA NA NA NA NA NA NA NA NA NA NA
TOTAL IMPACT (not
including intertidal 11.15 (4.51) 3.43 (1.39) 12.38 (5.01) 4.62 (1.87) 12.48 (5.05) 4.85 (1.96) 11.17 (4.52) 3.12 (1.26) 11.17 (4.52) 3.12 (1.26) 11.00 (4.45) 3.47 (1.40)
beach
Indicates area of SAV based on unpublished NOAA/DMF mapping and limited ground truthing of imagery taken during 1985-1990. A survey conducted in September 2007 indicated that the current
area of SAV coverage is similar to that reported when previous mapping was conducted (NCDOT, 2007).
z CAMA coastal wetlands.
Calculated areas are based on conditions as verified with USACE through June 2005.
Hectares were calculated from acres, thus minor rounding error exists when adding the individual hectare numbers.
Table 2-6. Total (All Phases) Shading, Fill, and Pile Placement Impacts to Wetlands and Waters
for the Parallel Bridge Corridor Alternatives
N
N
J
Road North/Bridge South Phased Approach/ Phased Approach/
Nourishment Alternative in
Alternative in Acres All Bridge Alternative in Rodanthe Bridge Rodanthe Nourishment
Acres (hectares)
(hectares) Acres (hectares) Alternative in Acres Alternative in Acres
Biotic Community hectares hectares
NC 12 Transport tion Management Plan Alternative (Preferred)'

Shading Fill and
Shading Fill and
Shading Fill and 2
Shading Fill and
2 2
Shading 2
Fill and Pile
Pile Pile Pile Pile
Open Water
• Aquatic bottom 8.87 (3.59) 2.29 (0.93) 11.98 (4.85) 4.07 (1.65) 12.42 (5.03) 3.58 (1.45) 9.18 (3.72) 2.14 (0.87) 9.18 (3.72) 2.15 (0.87)
sound/other waters
• SAV 0.91 (0.37) 0.22 (0.09) 6.22 (2.52) 0.33 (0.13) 6.22 (2.52) 0.33 (0.13) 0.91 (0.37) 0.22 (0.09) 0.91 (0.37) 0.22 (0.09)
• Impoundments 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 23.03 (9.32) 11.80 (4.78) 0.12 (0.05) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
TOTAL OPEN WATER/SAV 9.78 (3.96) 2.51 (1.02) 18.20 (7.37) 27.43 (11.10) 30.44 (12.32) 4.03 (1.63) 10.09 (4.08) 2.36 (0.96) 10.09 (4.08) 2.37 (0.96)
IMPACT
Wetland
• Wetland man-dominated 0.00 (0.00) 0.15 (0.06) 0.02 (0.01) 1.00 (0.40) 0.00 (0.00) 1.00 (0.40) 0.00 (0.00) 0.15 (0.06) 0.00 (0.00) 0.15 (0.06)
• Salt shrub/grasslands 0.05 (0.02) 0.00 (0.00) 0.03 (0.01) 31.27 (12.65) 9.63 (3.90) 3.74 (1.51) 0.46 (0.19) 0.00 (0.00) 0.46 (0.19) 0.01 (0.00)
• Wetland maritime grassland 0.33 (0.13) 0.08 (0.03) 0.04 (0.02) 0.85 (0.34) 0.00 (0.00) 1.00 (0.40) 2.52 (1.02) 0.08 (0.03) 2.52 (1.02) 0.06 (0.02)
• Wetland overwash 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 1.61 (0.65) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Wetland maritime shrub 0.48 (0.19) 0.96 (0.39) 1.69 (0.68) 4.77 (1.93) 2.07 (0.84) 1.31 (0.53) 0.77 (0.31) 0.15 (0.06) 0.74 (0.30) 0.15 (0.06)
thicket
• Reed stand 0.00 (0.00) 0.01 (0.00) 0.21 (0.08) 0.76 (0.31) 0.19 (0.08) 0.32 (0.13) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Saltflat4 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Brackish marsh' 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00) 0.00 (0.00)
• Smooth cordgrass' 0.53 (0.21) 0.16 (0.06) 0.71 (0.29) 0.20 (0.08) 0.71 (0.29) 0.20 (0.08) 0.54 (0.22) 0.15 (0.06) 0.54 (0.22) 0.16 (0.06)
• Black needlerush4 0.47 (0.19) 0.11 (0.04) 2.34 (0.95) 10.32 (4.18) 5.08 (2.06) 2.16 (0.87) 0.47 (0.19) 0.11 (0.04) 0.47 (0.19) 0.11
TOTAL WETLAND IMPACT 1.87 0.76 1.47 0.59 5.03 2.04 50.79 20.55 17.67 7.15 9.73 3.94 4.73 1.91 0.65 0.26 4.72 1.91 0.63

Intertidal Beach
NA
76.51 (30.96)
NA
NA
NA
NA
NA
NA
NA
13.80
j(5.58)
TOTAL including intertidIMPACTal ( bnoteach) 11.65 (4.72) 3.98 (1.61) 23.23 (9.41) 78.22 (31.65) 48.11 (19.47) 13.76 (5.57) 14.82 (5.99) 3.01 (1.22) 14.81 (5.99) 3.00 'The impacts shown for the five other Parallel Bridge Corridor alternatives reflect the range of reasonably foreseeable impacts associated with the Preferred Alternative.
2 Wetland impacts for the Phased Approach are lower when considering all phases because part of the frontage road for NC 12 traffic and recreational access associated with Phase I could be shortened
in Phase II and wetlands affected restored.
'Indicates area of SAV based on unpublished NOAA/DMF mapping and limited ground truthing of imagery taken during 1985-1990. A survey conducted in September 2007 indicated that the current
area of SAV coverage is similar to that reported when previous mapping was conducted (NCDOT, 2007).
4CAMA coastal wetlands.
Calculated areas are based on conditions as verified with USACE through June 2005.
Hectares were calculated from acres, thus minor rounding error exists when adding the individual hectare numbers.
this finding. NOAA Fisheries did, however, provide the following conservation
recommendation: "If NCDOT moves forward with the currently selected plan, we recommend
early initiation of a long-term study to characterize changes in habitats along Hatteras and Bodie
Islands so that adequate information is available for examining applications to USACE for project
authorization, including mitigation for unavoidable impacts to EFH."
The Parallel Bridge Corridor with NC 12 Transportation Management Plan Alternative
(Preferred) is a variation on the Parallel Bridge Corridor alternatives assessed in the FEIS.
Because this alternative calls for the details of later phases to be determined during future phase
development, the EFH analysis also focuses on Phase I separately from the later phases.
In comparing Phase I of the FEIS Preferred Alternative with Phase I of the new Preferred
Alternative, Phase I of the NC 12 Transportation Management Plan Alternative would be over the
water in a manner similar to the FEIS Preferred Phase I alignment. Therefore, the impacts to
EFH from Phase I would not change from those identified in the FEIS. Since there would be no
change in impacts with the new Preferred Alternative, Phase I of the Preferred Alternative is not
anticipated to affect adversely EFH.
The new Preferred Alternative does not stipulate (at this time) the recommended solution(s) for
the remainder of the project beyond Phase I. Possible solutions for later phases of the project
include bridging, road relocation, and/or beach nourishment. All of these solutions, which are
available for implementation as part of the Preferred Alternative, were identified and assessed as
part of the FEIS and would be reassessed at the time decisions on future phases are being made.
Should any new solutions be identified in the future, such solutions would be assessed to
determine if they include new significant impacts and/or impacts that would adversely affect
EFH.
2.3.4 Basis for Selection of the Preferred Alternative
On August 27, 2007, senior representatives of NCDOT, FHWA, USACE, and NCDENR,
meeting as the Merger 01 Dispute Resolution Board for the NEPA/Section 404 Merger Process,
identified the Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge Alternative as the
LEDPA for this project (see Section 2.15 of the FEIS). Specifically, the agencies concurred that:
• The Pamlico Sound Bridge Corridor is not practicable based on cost estimates and thus is not
the LEDPA;
• Phase I of the project should be to construct the replacement bridge within the Parallel Bridge
Corridor as soon as possible, every effort should be made to place the new bridge terminus
within the existing easement, and Phase I should be advanced through the Merger Process;
• Building Phase I alone would not meet the purpose and need of the project;
• Future phases present substantial challenges to obtaining permit approvals; and
• At the time of permit application for future phases, reasonable, practicable, and feasible
alternatives will be considered and evaluated in pursuit of the LEDPA/Selected Alternative.
Although agency representatives chose the Phased Approach/Rodanthe Bridge Alternative as the
LEDPA, they recognized that the project area is complex and the shoreline is constantly
changing. They noted that the ability to predict the effect of future storms on the project area is
Bonner Bridge Replacement EA 2-28 NCDOT TIP Project Number B-2500
extremely difficult, and they agreed that the various alternatives may need to be reassessed in the
future as the shoreline and other landscape features continue to change.
On May 21, 2009, representatives of the project's NEPA/Section 404 Merger Team met and
agreed that the concept of the NC 12 Transportation Management Plan Alternative (Preferred)
also fit within the terms of the August 27, 2007, Concurrence Point 3 Agreement (LEDPA) in
that:
• It would involve replacement of the Oregon Inlet bridge as Phase I; and
• Completion of Phase I alone would not meet the purpose and need of the project and
represented a commitment by all parties to develop and implement the entire action from
Rodanthe to Bodie Island.
The following observations were made at the May 21, 2009, meeting that led to the determination
of this alternative as the Preferred Alternative:
• The August 27, 2007, LEDPA agreement found that the Pamlico Sound Bridge Corridor is
not practicable and that the Parallel Bridge Corridor includes several different alternatives
that could be considered in the future when future conditions are better known.
• The August 27, 2007, LEDPA agreement, while identifying the Phased Approach/Rodanthe
Bridge Alternative as the LEDPA, left open the opportunity to reconsider the features of
phases beyond Phase I (new Oregon Inlet bridge) because it was felt that future coastal
conditions were uncertain in the Refuge.
• The environmental impact of multiple Parallel Bridge Corridor alternatives has been
evaluated and documented based on thorough research related to potential future coastal
conditions in the project area.
• Despite thorough coastal studies prepared during the environmental impact assessment, it is
not appropriate to determine the specifics of future phases of a Parallel Bridge Corridor
Alternative at this time given there is a great deal of uncertainty in even the best models of
future shoreline conditions.
• Phase I should be built now, and the specific features of the rest of the project should be
examined in more detail at the time they are to be built, when future conditions are more
known.
• An adaptive management plan should be developed to assist with cooperative decision-
making for future decisions related to the project.
• State and federal environmental resource and regulatory agencies should be involved in
future phase development.
• The regulatory challenges associated with finalizing future phases would likely remain when
developing future phases.
All agencies in attendance at the May 21, 2009, Merger Team meeting agreed that NCDOT and
F14WA could move forward with the Parallel Bridge Corridor with NC 12 Transportation
Management Plan Alternative as the Preferred Alternative based on the August 27, 2007,
Bonner Bridge Replacement EA 2-29 NCDOT TIP Project Number B-2500
Concurrence Point 3 Agreement (LEDPA). Based on discussions at the Merger Team meetings
on May 21, 2009, and September 17, 2009, an amendment to the 2007 LEDPA agreement was
prepared and signed by the Dispute Resolution Board on January 7, 2010 (see Appendix A). The
LEDPA agreement amendment does not change the intent of the original LEDPA agreement
"beyond the understanding that the Phased Approach/Rodanthe Bridge Alternative is no longer
considered and identified in the Record of Decision (ROD) as the LEDPA." The LEDPA
agreement amendment also stipulates that the Merger Team will be consulted about decisions on
future phases of the project. The USFWS has since raised objections to this alternative but has
continued coordination with NCDOT and FHWA, as documented in Section 3.5.
The amendment agreement affirms that the Parallel Bridge Corridor with NC 12 Transportation
Management Plan Alternative (Preferred) is consistent with the original August 27, 2007
agreement. The amendment agreement states:
At this time, there is no formally prescribed alternative for the remaining phases
of the project south of Oregon Inlet. One or more of a combination of options,
drawing from the alternatives previously studied, as well as any other alternatives
determined at the time to be reasonable, practicable and feasible, will be
evaluated, designed, and finalized prior to the implementation of actions beyond
Phase I. Any option will be evaluated and selected with multi-agency input and
concurrence as part of the Merger Process. The agencies do agree that permits
will not be granted for the remaining phases of work until their applicable laws
and regulations have been satisfied.
In addition to the coordination under the Merger Process, as part of this alternative NCDOT and
FHWA pursued an additional formalized agreement with the NPS and the USFWS (the land
management agencies within the corridor) in order to develop additional long-term protocols and
strategies to follow prior to the implementation of future phases of the project. However, both the
NPS and the USFWS, in letters dated March 11 and March 22, 2010, respectively, stated that they
would not be able to sign an agreement because they desire a decision now for the later phases of
action. NCDOT and FHWA do not agree that decisions should be made for the entire corridor
because of the extensive uncertainty inherent in the predictions of future coastal conditions. As is
stated in the Shoreline Change and Stabilization Analysis' , "the prediction of future shoreline
positions, the impacts of individual severe storms and the behavior of beach nourishment projects
are complex problems that by necessity include a relatively high level of uncertainty." In an
attempt to determine the potential likelihood and location of future inlets within the project area,
the expert panel documented in the Potential Inlet Formation Technical Report noted that "the
potential inlet site closest to Rodanthe has a risk of opening within the next 50 years. No specific
level of risk was assigned to this site and no specific dimensions (width or depth) were
developed." During the Climate Change Peer Exchange meeting hosted by FHWA in May 2008,
' FDH Engineering, Inc. (Margery F. Overton, PhD and John S. Fisher, PhD, PE). June 2005.
Bonner Bridge Replacement Parallel Bridge Corridor with NC12 Maintenance Shoreline Change
and Stabilization Analysis. Prepared for URS Corporation North Carolina and the North Carolina
Department of Transportation.
z FDH Engineering, Inc. September 2005. NC 12 Replacement of the Herbert C. Bonner Bridge
Potential Inlet Formation Technical Report. Prepared for Parsons Brinckerhoff Quade &
Douglas, Inc. and the North Carolina Department of Transportation.
Bonner Bridge Replacement EA 2-30 NCDOT TIP Project Number B-2500
it was noted that "current global sea level rise analytical models are not fully developed to predict
local effects. The wide range of future sea level rise information considered illustrates the
uncertainty associated with estimating future sea levels and shoreline locations." FHWA and
NCDOT feel that it is important to select an alternative that allows for further new analysis prior
to the implementation of future phases.
The LEDPA amendment agreement recognizes this uncertainty by stating:
The best available science has been used to forecast shoreline erosion and
potential inlet formation locations. However, it is difficult to predict reasonably
and accurately future storm events and their magnitude, intensity, and duration.
Extensive coastal engineering studies have been completed to date. Because of
uncertainty regarding future storm events, additional coastal and natural resource
data will be collected and analyzed to evaluate the available range of alternatives
for future phases.
Both the NPS and the USFWS are members of the Merger Team and will continue to be included
as part of the Merger Process, and FHWA and NCDOT would reopen discussion about a
formalized agreement with the NPS and USFWS if requested by the NPS and USFWS.
2.3.5 Does the Parallel Bridge Corridor with NC 12 Transportation
Management Plan Alternative (Preferred) result in "Segmentation"
under NEPA?
With the acknowledgement that the new Preferred Alternative, the Parallel Bridge Corridor with
NC 12 Transportation Management Plan Alternative, does not immediately prescribe
transportation solutions for the project beyond Phase I, FHWA reviewed Title 23 Code of Federal
Regulations Section 771.111(f) to determine if the new Preferred Alternative is in compliance
with the regulations in regards to logical termini. In addition, a FHWA Memorandum titled "The
Development of Logical Project Termini " (November 5, 1993) was reviewed. The memo states
"...A problem of `segmentation' may also occur where a transportation need extends throughout
an entire corridor but environmental issues and transportation need are inappropriately
discussed for only a segment of the corridor.. ". The FHWA Memorandum further states that
choosing a corridor of sufficient length to look at all impacts need not preclude staged or phased
construction. Therefore, related improvements within a transportation facility should be
evaluated as one project, rather than selecting termini based on what is programmed as short
range improvements. Construction may then be "staged," or programmed for shorter sections or
discrete construction elements as conditions warrant or funding permits. The FEIS discussed the
rationale to assess the portion of NC 12 from north of Oregon Inlet to Rodanthe. The project
limits connect logical termini of sufficient length to address environmental matters on a broad
scope. Environmental issues throughout the Parallel Bridge Corridor were thoroughly evaluated
and discussed in the FEIS. The evaluation of later phases beyond Phase I (Oregon Inlet) would
not be any different if FHWA selected a Preferred Alternative for the entire length of the project.
In the event new transportation solutions for later phases are developed that were not previously
identified in the FEIS, additional NEPA analyses and compliance with Section 4(f) and other
environmental laws for these new transportation solutions would be performed. Furthermore,
NEPA regulations (Title 23 Code of Federal Regulations Section 771.129) require FHWA to re-
evaluate its decision if a later phase occurs after more than three years have elapsed without any
activity on the project. In addition, after final approval of the EIS, NCDOT must consult with
Bonner Bridge Replacement EA 2-31 NCDOT TIP Project Number B-2500
FHWA prior to requesting any major approvals or grants to advance the project in order to
establish whether the approved EIS remains valid.
The NC 12 Transportation Management Plan Alternative has independent utility with the
implementation of Phase I immediately, since the bridge is structurally deficient with a
sufficiency rating of 4, and is vulnerable to damage from vessels because of short navigational
spans. Even if no other transportation improvements are made along NC 12, the replacement of
the bridge is a critical expenditure to ensure public safety. The implementation of subsequent
phases also is necessary to provide continued safe, reliable transportation along the Parallel
Bridge Corridor from Oregon Inlet to Rodanthe. Implementing the NC Transportation
Management Plan Alternative does not alter the need to replace the Oregon Inlet bridge (Phase I).
Therefore, the project has independent utility. Furthermore, the proposed project also does not
restrict consideration of alternatives for other reasonably foreseeable transportation improvements
within the project study area, as no further improvements other than the NC 12 Transportation
Management Plan Alternative are foreseen within the project study area, mainly because of the
island's narrow configuration and the absence of any major cross streets along the corridor. In
addition, the proposed project does not restrict consideration of alternatives for foreseeable
transportation improvements proposed at two hot spots on Hatteras Island near Buxton and
Hatteras Village, well south of the southern limit (Rodanthe) of this project.
The NEPA/Section 404 Merger Team discussed the segmentation issue at the May 21, 2009,
meeting. The Merger Team agreed to move forward with Phase I being built, and that the rest of
the project should be examined in more detail when future conditions are more known. USEPA
noted that the segmentation issue would not be a problem on this project because the
administrative record includes thorough documentation of the extensive research for the entire
corridor that has taken place related to the unpredictable future conditions in the project area.
Also, multiple alternatives for the full length project were evaluated. USEPA also stated that this
approach would keep FHWA from committing a huge amount of money to a project with a
substantial amount of future uncertainty.
In summary, although the new Preferred Alternative does not immediately prescribe preferred
activities beyond Phase I, FHWA and NCDOT have evaluated and assessed environmental issues
to maintain transportation along the Parallel Bridge Corridor for the entire project corridor. The
impacts presented for the other Parallel Bridge Corridor alternatives reflect the reasonably
foreseeable range of impacts for the NC 12 Transportation Management Plan Alternative
(Preferred). In addition, based on the projected shoreline conditions on this section of Hatteras
Island, this project has logical termini, which encompass the bridge replacement over Oregon
Inlet and the NC 12 roadway sections projected to be threatened in the future on northern Hatteras
Island. As stated above, the proposed project also does not restrict consideration of alternatives
for other reasonably foreseeable transportation improvements, as improvements are proposed
south of the southern limits of this project. After reviewing the limits of the study area, the limits
of the Preferred Alternative, and the projected shoreline conditions, and after assessing whether
the proposed project restricts future foreseeable projects, FHWA has determined that the
Preferred Alternative is not segmented in its scope or in its environmental impact assessment,
consistent with the 23 CFR 771.111(f) regulations.
2.3.6 Minimizing Impacts of NC 12 Maintenance with the Preferred
Alternative
Future phases of the Parallel Bridge Corridor with NC 12 Transportation Management Plan
Alternative (Preferred) would be built based on the evolution of new data and analysis of the
Bonner Bridge Replacement EA 2-32 NCDOT TIP Project Number B-2500
Hatteras Island shoreline, potential future beach erosion forecasts, and potential breach locations.
The coastal monitoring program would enable FHWA and NCDOT to determine the timing and
extent of each phase. The alternatives for each phase of the project would be determined in
conjunction with environmental resource and regulatory agencies through the established
NEPA/Section 404 Merger Process.
Section 4.6.8.6 of the FEIS discussed potential short-term maintenance activities that likely
would occur prior to the implementation of Phases II, III, and IV of the Phased Approach
alternatives. Since the NC 12 Transportation Management Plan is also phased, the section of
NC 12 between Oregon Inlet and Rodanthe will also require maintenance prior to the
implementation of future phases. The level of NC 12 maintenance, especially as a result of storm
events, will continue in the three hot spot areas and is likely to increase in those areas until a
second phase is completed. NCDOT will coordinate with USFWS to determine what
maintenance measures should be utilized in order to minimize impacts to the Refuge. The
completion of a Phase II would substantially decrease the amount of storm-related maintenance
on NC 12, though some would remain and would increase prior to the completion of any
remaining phases.
Prior to the implementation of future phases of the project, FHWA and NCDOT would comply
with 23 CFR 668 for completion of any repair work required following emergency events.
NCDOT will continue to work with the USFWS to reduce the impacts of storm-related NC 12
maintenance on the Refuge and will consult with the appropriate environmental regulatory
agencies following storm events to ensure that any maintenance activities follow all applicable
environmental regulations.
2.3.7 Costs
Table 2-7 and Table 2-8 show the total estimated costs for the Parallel Bridge Corridor
alternatives as assessed in the FEIS and this EA. They were updated from those presented in the
FEIS to account for the revisions to the detailed study alternatives described in Section 2.1 of this
EA. Construction costs, like those shown in the FEIS, are in 2006 dollars. Construction, right-
of-way, Bonner Bridge demolition, NC 12 pavement removal, and operation and maintenance
costs are shown.
The following observations can be made about the costs in Table 2-7 and Table 2-8:
When the cost of NC 12 maintenance through the Refuge is added to the cost of a new
Oregon Inlet bridge in the Parallel Bridge Corridor, as well as other highway-related costs
until 2060, the Road North/Bridge South Alternative would be the least expensive ($615.0 to
$759.0 million). The Nourishment Alternative is the second least expensive at $719.7 to $1.0
billion. The remaining alternatives, which involve longer bridges, would range in cost from
$1.1 to $1.5 billion.
• Right-of-way in Rodanthe would be most expensive ($8.5 to $32.5 million) with the Phased
Approach alternatives.
• Operation, inspection, and maintenance costs are greater for bridges than for roads.
Inspection costs per square foot are expected to be higher when bridges are either over or
closer to the ocean, and lower when bridges are over land.
Bonner Bridge Replacement EA 2-33 NCDOT TIP Project Number B-2500
0
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y
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0
Table 2-7. Parallel Bridge Corridor Highway Cost to 2060 (Low)
Road North/ Phased Phased Approach/
Nourishment Bridge South All Bridge Approach/ Rodanthe
Rodanthe Bride Nourishment
NC 12 Transportation Management Plan Alternative Preferred '
Replacement Bridge Construction Cost and Bonner Bridge $312
000
000 $284
000
000 $285
000
000 $312
000
000 $312
000
000
Demolition Cost (2006 dollars) ,
, ,
, ,
, ,
, ,
,
NC 12 Maintenance Construction Cost (2006 dollars)
New Road and/or Bridge Cost $0 $178,000,000 $509,000,000 $480,000,000 $451,000,000
Nourishment to 2060 $317,550,000 $0 $0 $23,694,000 $107,416,000
Dunes to 2060 (2006 dollars) $8,267,000 $1,556,000 $0 $533,000 $3,378,000
Right-of-Way $750,000 $6,075,000 $6,075,000 $32,475,000 $8,500,000
Wetland Mitigation (except SAV 2006 dollars $468,000 $14,130,000 $1,860,000 $468,000 $468,000
Road and Bridge Operation and Maintenance Costs to $80
710
000 $131
197
000 $274
173
000 $260
289
000 $245
306
000
2060 (2006 dollars) ,
, ,
, ,
, ,
, ,
,
11 TOTAL Hi hwa Cost to 2060 $719,745,000 $614,958,000 $1,076,108,000 $1,109,459,000 $1,128,068,000
'The costs shown for the six Parallel Bridge Corridor alternatives reflect the range of reasonably foreseeable costs associated with the Preferred Alternative. The replacement
bridge construction cost and Bonner Bridge demolition cost (2006 dollars) for the Preferred Phase I Alignment of the NC 12 Transportation Management Plan Alternative
(Preferred) would be $265,000,000.
0
b

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Table 2-8. Parallel Bridge Corridor Highway Cost to 2060 (High)
Phased Phased
Nourishment Road North/ All Bridge Approach/ Approach/
Bridge South Rodanthe Bridge Rodanthe
Nourishment
NC 12 Transportation Management Plan Alternative Preferred '
Replacement Bridge Construction Cost and Bonner Bridge $368
000
000 $346
000
000 $347
000
000 $368
000
000 $368
000
000
Demolition Cost 2006 dollars ,
, ,
, ,
, ,
, ,
,
NC 12 Maintenance Construction Cost (2006 dollars)
New Road and/or Bridge Cost $0 $260,000,000 $781,000,000 $746,000,000 $689,000,000
Nourishment to 2060 $567,065,000 $0 $0 $36,348,000 $189,668,000
Dunes to 2060 (2006 dollars) $8,267,000 $1,556,000 $0 $533,000 $3,378,000
Right-of-Way $750,000 $6,075,000 $6,075,000 $32,475,000 $8,500,000
Wetland Mitigation (except SAV) (2006 dollars) $468,000 $14,130,000 $1,860,000 $468,000 $468,000
Road and Bridge Operation and Maintenance Costs to
2060 2006 dollars $80,710,000 $131,197,000 $274,173,000 $260,289,000 $245,306,000
TOTAL Hi hwa Cost to 2060 $1,025,260,000 $758,958,000 $1,410,108,000 $1,444,113,000 $1,504,320,000
'The costs shown for the six Parallel Bridge Corridor alternatives reflect the range of reasonably foreseeable costs associated with the Preferred Alternative. The replacement
bridge construction cost and Bonner Bridge demolition cost (2006 dollars) for the Preferred Phase I Alignment of the NC 12 Transportation Management Plan Alternative
(Preferred) would be $315,000,000.
The nourishment costs shown in Table 2-7 and Table 2-8 for the Nourishment Alternative include
a forecast low and forecast high rate of erosion of the material placed on the beach and the
associated need to replace periodically newly eroded material. The cost through 2060, assuming
the most likely erosion rate considered, would be $429.4 million, in contrast with the low of
$317.5 million and the high of $567.1 million shown in Table 2-7 and Table 2-8, respectively. In
the case of nourishment associated with the Phased Approach alternatives, a cost between the low
and high cost also is considered the likely cost.
There is also the risk of a storm-created breach of Hatteras Island within the Refuge between now
and 2060. Such a breach would separate almost all of Hatteras Island and its associated
communities, tourism businesses, and the Seashore from Bodie Island and the mainland. The
cost of closing such a breach is discussed in Section 4.6.6 of the FEIS, but is not included in the
tables above because, although the potential for a breach exists, its occurrence is not a certainty
(unlike shoreline erosion that can be predicted through modeling) (see Section 3.6.3.4 of the
FEIS). In addition, there would be the associated economic loss, challenges for maintaining
community services, and disruptions to daily living until the breach is closed. These economic
costs are discussed in Section 4.1.5.4 of the FEIS. The other public costs of the proposed project
(i.e., non-highway costs) discussed in Section 2.12.3 of the FEIS and shown in FEIS Tables 2-11
and 2-12 were not revised.
2.3.8 Conclusion
The description and scope of the Preferred Alternative presented in this section is not anticipated
to create any new, significant impacts not previously identified in the FEIS.
Bonner Bridge Replacement EA 2-36 NCDOT TIP Project Number B-2500
3.0 Comments and Coordination
An Environmental Impact Statement (EIS) that addresses the full range of alternatives and issues
important to the selection of a Preferred Alternative can be accomplished only in consultation
with those who have a stake in the decision. This chapter summarizes comments on the Final
Environmental Impact Statement (FEIS) pertinent to the material included in this Environmental
Assessment (EA). Appendix D provides responses to comments made on the FEIS. The original
FEIS comment letters are presented in Appendix E. One outcome of the FEIS comments was a
decision to release a Revised Final Section 4(f) Evaluation in October 2009; the Evaluation is
included in Appendix B. Appendix F provides responses to comments made on the Revised Final
Section 4(f) Evaluation. The original Revised Final Section 4(f) Evaluation comment letters are
presented in Appendix G.
This chapter also summarizes agency coordination that has occurred since the completion of the
September 17, 2008, FEIS, including four National Environmental Policy Act/Section 404 of the
Clean Water Act (NEPA/Section 404) Merger Team meetings, Section 106 coordination
meetings, and coordination meetings with the US Fish and Wildlife Service (USFWS). Earlier
coordination activities are discussed in Chapter 8 of the FEIS.
3.1 Comments on the September 2008 FEIS
The September 17, 2008, FEIS was provided to 18 Federal agencies, 11 State agencies, 14 local
agencies or governments, and 23 interest groups and nongovernmental organizations (NGOs).
Several agencies expressed concerns in their written comments about the Least Environmentally
Damaging Practicable Alternative (LEDPA)/Preferred Alternative identified in the FEIS (i.e., the
Phased Approach/Rodanthe Bridge Alternative), as well as the conclusions contained in the Final
Section 4(f) Evaluation. Appendix D of this EA provides responses to agency and NGO written
comments on the FEIS, as well as a summary of the public comments received. The original
FEIS comment letters are included in Appendix E.
In part in response to comments related to the Final Section 4(f) Evaluation presented as Chapter
5 of the FEIS, the Federal Highway Administration (FHWA) and the North Carolina Department
of Transportation (NCDOT) prepared a Revised Final Section 4(f) Evaluation. This document is
included as Appendix B of this EA. Comments that led to the decision to release a Revised Final
Section 4(f) Evaluation came from the US Department of the Interior (USDOI), the North
Carolina Department of Cultural Resources (NCDCR), and the Southern Environmental Law
Center (SELC).
USDOI commented that "Though all alternatives have some form of 4(f) impact, the Preferred
Alternative [LEDPA Alternative] has far greater impacts in quantity and quality on lands
protected by section 4(f)." In USDOI's view, the FEIS LEDPA/Preferred Alternative would
constructively use the Pea Island National Wildlife Refuge (Refuge) because the elevated road
structure in the Refuge would cause noise, visual intrusion, shading of beach habitat, interference
with the flyway of shorebirds, and loss of access to Refuge visitor facilities. USDOI noted that
the impacts would be lessened with an at-grade road. USDOI further advised that the LEDPA/
Preferred Alternative would likely not avoid the need for a compatibility determination because
Bonner Bridge Replacement EA 3-1 NCDOT TIP Project Number B-2500
construction and/or maintenance work would still likely occur outside of the existing NC 12
easement through the Refuge.
NCDCR also took issue with FHWA's finding that the FEIS LEDPA/Preferred Alternative would
not constructively use historic properties. A specific concern was that "the construction of a ten-
mile long bridge, elevated thirty feet above ground level and topped with a nearly five-foot railing
(and perhaps an additional six-foot high chain-link fence as suggested by the Refuge during the
Section 106 consultation) will introduce a substantial visual intrusion that is antithetical to the
historic landscape" of the Refuge. In the Rodanthe Historic District, NCDCR was similarly
concerned that introduction of a 30-foot (9.1-meter) bridge with flanking one-way frontage roads
in the district would substantially impair the characteristics which make the district and
Chicamacomico Life Saving Station eligible for the National Register. Another concern was the
reduction in access to the Rodanthe Historic District and Chicamacomico Life Saving Station
with the FEIS LEDPA/Preferred Alternative.
SELC commented that the FEIS Section 4(f) analysis is inadequate and erroneously concluded
that the Phased Approach alternatives will not "use" Refuge lands because it operates within the
existing NC 12 easement. Specifically, the SELC commented that the analysis failed to explain
adequately how it is feasible to avoid further encroachments into the Refuge while constructing
and maintaining a bridge and service road within the existing NC 12 easement and also
maintaining existing NC 12. The SELC also commented that the analysis failed to address
adequately the expected dune building and maintenance activities through 2030 that would be
needed with the Phased Approach alternatives. Further, the SELC commented that the
constructive use analysis in the FEIS Section 4(f) evaluation was deficient because the analysis
did not adequately assess ecological impacts and access restrictions as a result of the Phased
Approach alternatives in the Refuge. The SELC also commented that the documentation failed to
acknowledge or assess the use of the Refuge that will result from retaining the terminal groin,
which does not lie within the existing NC 12 easement.
3.2 Comments on the October 2009 Revised Final
Section 4(f) Evaluation
In October 2009, FHWA and NCDOT released a Revised Final Section 4(f) Evaluation (signed
on October 9, 2009). The revised document was prepared based on: comments received on the
Final Section 4(f) Evaluation presented as Chapter 5 of the FEIS, as noted in the previous section;
new information on the history of Refuge-related land transfers; and revisions made to the
detailed study alternatives in the community of Rodanthe based on FEIS comments. Because
USFWS, NCDCR, and SELC provided comments on the FEIS Final Section 4(f) Evaluation, the
Revised Final Section 4(f) Evaluation was provided to these three entities so that they could have
an opportunity to review the changes to the Section 4(f) evaluation as a result of their prior
comments, as well as provide additional comments, if desired. The Evaluation was also provided
to the National Park Service (NPS), USDOI, and the Advisory Council on Historic Preservation
(ACHP). The Evaluation was made available for public review via the project website
(www.ncdot.org/projectsibonnerbridgerepairs) and the Outer Banks Task Force website
(www.obtforg). Comments on the Revised Final Section 4(f) Evaluation were received from
USDOI, NCDCR, and SELC. The comments and responses to those comments are presented in
Appendix F. The original comment letters are contained in Appendix G.
Bonner Bridge Replacement EA 3-2 NCDOT TIP Project Number B-2500
3.3 Merger Team Meetings Since Release of the
FEIS
Four Merger Team meetings were held between November 2008 and September 2009. These
meetings included representatives from FHWA, NCDOT, USFWS, US Army Corps of Engineers
(USACE), US Environmental Protection Agency (USEPA), National Oceanic and Atmospheric
Administration (NOAA) Fisheries, NPS, NCDCR, and North Carolina Department of
Environment and Natural Resources (NCDENR), including the Division of Coastal Management
(DCM), Division of Marine Fisheries (DMF), Division of Water Quality (DWQ), and Wildlife
Resources Commission (WRC).
3.3.1 November 13, 2008, Merger Team Meeting
A Merger Team meeting was held on November 13, 2008, for the purpose of reviewing the
proposed Bridging Decisions and Alignment (Concurrence Point 2A) and the proposed
Avoidance and Minimization efforts (Concurrence Point 4A) for Phase I (Oregon Inlet bridge) of
the Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge Alternative (the LEDPA at
that time). Materials presented at the meeting included information on proposed bridging
decisions and alignment for the Preferred Alternative, as well as proposed avoidance and
minimization measures for Phase I construction and Bonner Bridge demolition.
The project stipulations presented in the meeting materials related to proposed bridging decisions
and alignment for the Preferred Alternative included:
• The alignment of the bridge on Bodie Island was selected to avoid impacts to the Oregon
Inlet Marina and Fishing Center parking lot, as well as to minimize disturbance to the
entrances of both the Marina and the Oregon Inlet Campground.
• The alignment was also selected to minimize impacts to wetlands and submerged aquatic
vegetation (SAV) on the western side of the island.
• The bridge alignment on Bodie Island and within much of Oregon Inlet could be altered by
the design-build contractor, if the contractor can establish that its proposed alignment further
minimizes impacts.
• The alignment of the bridge on Hatteras Island is restricted to the current 100-foot (30.5-
meter) easement that NCDOT has for maintaining NC 12. All bridge construction and traffic
maintenance must remain within this easement. Therefore, any shifts made during the final
design of the bridge will still remain within the easement.
• During the Constructability Workshop in 2006, the expert panel on Geotechnical, Hydraulics,
and Coastal Engineering identified a potential threat from sound-side erosion along Davis
Slough. NCDOT has since monitored the area of potential vulnerability and deems it prudent
to extend the south terminus of Phase I an additional approximately 2,000 feet (610 meters),
contingent on the availability of funds. As with the rest of the LEDPA, the bridge would
remain within the existing 100-foot (30.5-meter) NC 12 easement.
The project stipulations related to proposed avoidance and minimization measures for Phase I
construction and Bonner Bridge demolition also were presented and discussed. Avoidance was
taken into account during the development of the entire LEDPA, including the alignment of
Bonner Bridge Replacement EA 3-3 NCDOT TIP Project Number B-2500
Phase I; however, wetlands are so pervasive in the project area that it is impossible to avoid
completely some impact. Minimization is reflected in the project commitments found in the FEIS
and this EA and would be incorporated into the project's design-build contract. The specific
stipulations presented at the meeting related to Phase I dredging, dredge spoil disposal, use of
work bridges and haul roads, protected species commitments, retention of fishing access at the
north end of Hatteras Island, and Bonner Bridge demolition.
At the meeting, the Merger Team concurred with the bridging decisions and alignment
recommendations, as well as the avoidance and minimization measures, for Phase I of the
LEDPA as included in the FEIS and stipulated at the meeting, with the following additions:
• Merger Team members will be provided, prior to Concurrence Point 413, with any major
changes in wetland/SAV impacts based on updated designs.
• The design-build contractor should minimize damage to wetlands/SAV/Oregon Inlet from
jetting spoils.
• Table 2 of the meeting packet showed temporary impacts from haul roads in SAV areas on
Bodie Island. NCDOT will not allow haul roads in SAV.
• The Merger Team also concurred that combined Concurrence Point 2A/4A Merger Team
meetings should be held prior to the completion of the final design for each subsequent phase
of the Preferred Alternative.
• The signed concurrence form for the November 13, 2008, Concurrence Point 2A/4A Merger
Team meeting is included in Appendix A. The signed form included abstentions from
USFWS, USFWS (Refuge), NOAA Fisheries, and NCDENR-WRC.
3.3.2 March 26, 2009, Merger Team Meeting
The March 26, 2009, Merger Team meeting was an informational meeting held to discuss the
possibility of revisiting the project's LEDPA decision. The team discussed FHWA's decision to
re-evaluate the applicability of the project's Section 4(f) evaluation because their recent research
of property deeds, legal documents, and history revealed an evolutionary relationship between
NC 12 and the Refuge. FHWA noted that NC 12 has been relocated within the Refuge four times
with no documented significant impacts. The team discussed the concerns of NCDCR, USDOI,
and SELC with respect to the FEIS/Final Section 4(f) Evaluation discussion of constructive use of
the Rodanthe Historic District and the Refuge, as well as USDOI's concern over loss of public
access to the Refuge. The team also reviewed changes to the Parallel Bridge Corridor alternatives
made as a result of the Section 106 process, as well as other Section 106 concerns.
3.3.3 May 21, 2009, Merger Team Meeting
The purpose of the May 21, 2009, Merger Team meeting was to seek concurrence on a revised
Concurrence Point 3 (selection of the LEDPA). The team discussed the reasons why NCDOT
and FHWA were now proposing the Parallel Bridge Corridor with Road North/Bridge South
Alternative as the LEDPA. The majority of the agencies did not feel that they could concur with
the Road North/Bridge South Alternative because of the high amount of wetland and habitat
impacts associated with that alternative. Based on a suggestion from the USEPA representative,
the team discussed moving forward with the construction of Phase I (Oregon Inlet bridge) and
Bonner Bridge Replacement EA 3-4 NCDOT TIP Project Number B-2500
determining the plan for future phases at a later time. It was also discussed that project area
shoreline erosion and other coastal conditions would continue to be monitored, allowing for
future decisions to be based on actual data rather than predicted shorelines.
The Merger Team agreed that this concept (referred to as the Parallel Bridge Corridor with NC 12
Transportation Management Plan Alternative [Preferred] in this EA) fit within the terms of the
August 27, 2007, Concurrence Point 3 Agreement (LEDPA) because it would involve
replacement of the Oregon Inlet bridge as Phase I. However, it was also discussed that
completion of Phase I alone would not meet the purpose and need of the project, so a
commitment was needed by all parties to develop and implement the entire action from Rodanthe
to Bodie Island. A draft Partnership Agreement was subsequently developed to formalize this
commitment.
The NC 12 Transportation Management Plan Alternative (Preferred) developed subsequent to this
meeting recognizes that the project area is complex and the shoreline is constantly changing. It
also recognizes that the ability to predict the effect of future storms on the project area is
extremely difficult, and that the various alternatives may need to be reassessed in the future as the
shoreline and other landscape features continue to change.
Since the NC 12 Transportation Management Plan Alternative (Preferred) also fits the terms of
the August 27, 2007, Concurrence Point 3 Agreement (LEDPA), no new Merger Team agreement
was needed. However, based on discussions at the Merger Team meetings on May 21, 2009, and
September 17, 2009 (see below), an amendment to the Concurrence Point 3 Agreement (LEDPA)
was prepared and signed by the Dispute Resolution Board on January 7, 2010 (see Appendix A).
The LEDPA agreement amendment does not change the intent of the original LEDPA agreement
"beyond the understanding that the Phased Approach/Rodanthe Bridge Alternative is no longer
considered and identified in the Record of Decision (ROD) as the LEDPA." The LEDPA
agreement amendment also stipulates that the Merger Team will be consulted about decisions on
future phases of the project.
3.3.4 September 17, 2009, Merger Team Meeting
The purpose of the September 17, 2009, Merger Team meeting was to discuss the wetland
mitigation for Phase I and a draft Preferred Alternative Partnership Agreement, which was
prepared as a result of the May 21, 2009, meeting. During the meeting, it was decided that:
• The NCDOT Natural Environment Unit would review the area called man-dominated in the
wetland impact numbers and assess the type and quality of all wetlands according to the
North Carolina Wetland Assessment Method (NCWAM).
• The NCDOT Natural Environment Unit would coordinate with NPS to develop an
appropriate, practicable phragmites control proposal for review by NCDOT and agencies as
mitigation for wetland impacts.
• The NCDOT Natural Environment Unit would provide an estimate of the total SAV habitat
area, impacts resulting from shading, and impacts resulting from fill.
• The NCDOT Natural Environment Unit would provide an estimate of the potential SAV
habitat area under the existing bridge.
Bonner Bridge Replacement EA 3-5 NCDOT TIP Project Number B-2500
The team recommended that the draft Partnership Agreement should be revised into an
amendment to the August 27, 2007, Concurrence Point 3 Agreement (LEDPA), and that the
amended concurrence form should include the following:
• Recognition that the NEPA/Section 404 Merger 01 Dispute Resolution Board agreed that
Phase I should proceed as soon as possible;
• Review of the amount of studies of the project area that have been completed to date;
• Recognition of the available solutions for later phases that were studied;
• Explanation why the team agreed during the May 21 meeting that decisions on the later
phases of the project could be postponed; and
• Recognition that an additional formalized agreement should be pursued with USFWS and
NPS that provides additional information on how decisions about later phases will be made
It was decided that NCDOT and FHWA would draft an amended concurrence form with the
above stipulations for the Merger Team's review.
However, as stated previously, both the NPS and the USFWS, in letters dated March 11 and
March 22, 2010 respectively, have stated that they would not be able to sign the draft partnership
agreement. Both the NPS and the USFWS are members of the Merger Team and will continue to
be included as part of the Merger Process, and FHWA and NCDOT would reopen discussion
about the Partnership (or other similar) Agreement if requested by the NPS and USFWS.
3.4 Section 106 Meetings Since Release of the FEIS
Since the publication of the FEIS in September 2008, FHWA, NCDOT, ACHP, and the State
Historic Preservation Office (HPO), as well as other consulting agencies, have participated in
approximately nine meetings to discuss the project with respect to Section 106 of the Historic
Preservation Act of 1966. These meetings were held to discuss the specifics of a Memorandum
of Agreement that detailed the action and appropriate mitigation. The Memorandum of
Agreement was revised in the later meetings as a Programmatic Agreement that would resolve
adverse effects for Phase I of the Parallel Bridge Corridor and set up a process for compliance
with Section 106 prior to the implementation of later phases.
During meetings held in March and April 2009, meeting participants discussed revising the
effects calls for several of the project alternatives. On March 24, 2009, FHWA, NCDOT, HPO,
and the ACHP concurred that the revised designs for the Road North/Bridge South, All Bridge,
and Phased Approach/Rodanthe Bridge alternatives (see Section 2.1) would have No Adverse
Effect on the Rodanthe Historic District and Chicamacomico Life Saving Station. The effects of
the preferred alignment for Phase I of the Parallel Bridge Corridor with NC 12 Transportation
Management Plan Alternative were discussed during a meeting on June 10, 2009; it was agreed
that, as with the other Parallel Bridge Corridor alternatives, this alternative would have an
Adverse Effect on the (former) Oregon Inlet US Coast Guard Station and the Refuge.
The final Programmatic Agreement will be included in the Record of Decision (ROD).
Bonner Bridge Replacement EA 3-6 NCDOT TIP Project Number B-2500
3.5 Coordination with USFWS Related to the Refuge
Since Release of the FEIS
3.5.1 March 19, 2009, Meeting
A meeting was held on March 19, 2009, between FHWA, NCDOT, and USFWS. The purpose of
the meeting was to provide USFWS with foreknowledge regarding FHWA's possible direction
with respect to responding to comments on the FEIS and ultimately issuing a ROD. Meeting
participants discussed proposed changes being considered in response to comments received on
the FEIS, particularly with regard to the Section 4(f) Evaluation. Issues discussed at the meeting
included:
• Whether or not the Section 4(f) Evaluation's "Constructive Use Analysis" for the Phased
Approach/Rodanthe Bridge Alternative had properly considered effects on the Refuge as a
site eligible for the NRHP, and the level of impairment based on FHWA regulations.
• The prudence of considering the Pamlico Sound Bridge Corridor alternatives based on cost
and visitor access.
• If the effects of retaining or removing the terminal groin under the Phased Approach/
Rodanthe Bridge Alternative had been properly addressed in the FEIS.
• Design changes for the Phased Approach/Rodanthe Bridge Alternative that are being
considered and their potential to maintain the current Section 106 effects determination as No
Adverse Effect.
• The potential for determining in a Final Section 4(f) Evaluation that Section 4(f) does not
apply to the Cape Hatteras National Seashore (Seashore) and the Refuge on the basis that
historically the State of North Carolina, USDOI, and its predecessors have been working to
develop, maintain, and operate a transportation corridor through both resources.
3.5.2 May 28, 2009, Teleconference Meeting
A teleconference meeting was held on May 28, 2009, between FHWA and USFWS. The purpose
of the meeting was to discuss the proposed project's compatibility with the National Wildlife
Refuge System Improvement Act of 1997. Issues discussed included:
• The FHWA submittal of examples of how the state has worked with the Refuge on roads and
maintenance thereof in the past, therefore setting precedence for road relocations being
considered compatible with the purpose of the Refuge.
• USFWS's authority to implement the Merger Team's proposed solution (from the May 21,
2009, meeting) of cooperating agencies negotiating a Memorandum of Understanding (MOU)
or Partnership Agreement. This Partnership Agreement would allow a Phase I bridge
replacement option to move forward with a cooperating plan in place for adaptive
management of the Refuge prior to implementation of future phases.
The outcomes of this meeting included: USFWS's position that since the decision to proceed
with Phase I had been previously agreed upon by the Merger Dispute Resolution Board, there was
Bonner Bridge Replacement EA 3-7 NCDOT TIP Project Number B-2500
no need to go through the process again; FHWA assurance that all applicable permits and
authorizations would be obtained prior to any USDOT authorization; agreement by NCDOT to
provide future conceptual designs within two to three weeks of future meetings; agreement to
hold a field meeting; and NCDOT preparation of a monetary appraisal of right-of-way to be
acquired based on NCDOT's conceptual designs.
3.5.3 July 15, 2009, Site Visit
On July 15, 2009, FHWA and NCDOT met with USFWS staff in the Refuge to discuss options
for the Phase I southern terminus. NCDOT had previously provided USFWS with conceptual
designs for the Parallel Bridge Corridor alternatives as discussed in Section 2.3.2.1. During the
meeting, USFWS stated that the Phase I alignments outside of the existing NC 12 easement likely
would not be found compatible with the Refuge. However, USFWS did provide an area at the
north end of Hatteras Island outside the easement that would be considered a minor modification
of the existing NC 12 easement and within which construction activities could occur. If NCDOT
decides to utilize this new area, the existing easement would be amended through a permit from
USFWS. Maintaining access to the NPS parking lot and the (former) Oregon Inlet US Coast
Guard Station also were discussed.
3.5.4 September 2, 2009, Meeting
Following the July 15, 2009, site visit, NCDOT developed a conceptual design that stayed within
the limits provided by the Refuge discussed above. NCDOT also developed a second conceptual
design in which the alignment traversed just west of the limits provided by the Refuge and tied
into NC 12 south of these limits. The latter conceptual design was developed to provide a safer
distance between existing NC 12 and the new Oregon Inlet bridge during construction, as well as
improved access to the NPS parking lot on the east side of NC 12. On September 2, 2009 FHWA
and NCDOT met with USFWS and NPS at USFWS's Alligator River National Wildlife Refuge
Office in Manteo, North Carolina, to follow-up on the discussion from the July 15, 2009 site visit
and present the two conceptual designs to Refuge representatives. FHWA and NCDOT
recommended that the conceptual design located just west of the limits provided by the Refuge be
approved because of their concerns related to traffic control during construction and access to the
parking lot located at Oregon Inlet. Following the meeting, in correspondence to NCDOT
representatives dated September 24, 2009, the Refuge indicated that the conceptual design that
was beyond the original limits provided to FHWA and NCDOT in July was acceptable and likely
represented the limits of what could be considered a minor modification of the existing easement.
This conceptual design was adopted as a part of Phase I of the Parallel Bridge Corridor with
NC 12 Transportation Management Plan Alternative (Preferred) as evaluated in the Revised Final
Section 4(f) Evaluation, which was approved on October 9, 2009 (see Appendix B). NCDOT
also agreed at the meeting to provide further impact information on the revised southern terminus
of the new Oregon Inlet bridge (Phase 1) to USFWS.
3.5.5 Meetings on the Terminal Groin
FHWA and NCDOT began working with USFWS in August 2008 on the requirements for
renewing the existing permit for the terminal groin. USFWS has stated that a new permit will be
required. FHWA and NCDOT will continue to coordinate with USFWS to meet all necessary
requirements.
Bonner Bridge Replacement EA 3-8 NCDOT TIP Project Number B-2500
3.5.6 November 2009 Rodanthe Storm Repair
Since the publication of the FEIS, NCDOT has conducted a series of repairs on a section of
NC 12 north of Rodanthe; these repairs were required to maintain traffic following storm events.
Following the nor'easter storm in November 2006, NCDOT installed a 900-foot (274.3-meter)
section of sandbags adjacent to NC 12 to protect the roadway. USFWS issued a permit for this
work that required NCDOT to place approximately 200,000 cubic yards (152,911 cubic meters)
of sand on the beach face east of the installed sandbags in order to restore beach habitat in the
area. NCDOT completed this effort in March 2010.
Remnants of Tropical Storm Ida caused additional damage to both NC 12 and the protective
dunes in November 2009. NCDOT relocated approximately 1,860 feet (566.9 meters) of the
roadway 23 feet (7.0 meters) west, remaining within the existing NC 12 easement in the Refuge.
In addition to the road relocation, the original 900 feet (274.3 meters) of sandbags, which were
damaged during the storm, were removed and replaced, and an additional 350-foot (106.7-meter)
section of sandbags was installed on the south end. The road relocation was completed in
December 2009, while the sandbag installation was completed in February 2010.
NCDOT coordinated with USFWS and other environmental regulatory agencies, including
USACE, NCDENR-DWQ, NCDENR-DCM, and NCDENR-WRC, as needed on all repair
efforts. The work was conducted under the direction of USFWS staff and outside of any
moratorium time periods as prescribed by USFWS and NCDENR-DCM.
3.6 Endangered Species Act Consultation Since
Release of the FEIS
3.6.1 November 2008 Endangered Species Act Update
USFWS's conference opinion for the proposed critical habitat of the piping plover was included
in the July 10, 2008, biological opinion. Since that time, there have been no substantial changes
in the action as planned or in the information used during the conference. Therefore, effective
November 20, 2008, USFWS officially adopted the conference opinion as the biological opinion
for critical habitat affected by the proposed project. USFWS sent a letter to FHWA on November
5, 2008, confirming the conference opinion as the biological opinion for the project. The
response provided is in accordance with Section 7 of the Endangered Species Act (ESA) of 1973,
as amended (16 U.S.C. 1531-1543).
3.6.2 April 2009 Consultation with USFWS
A meeting was held on April 1, 2009, between NCDOT, FHWA, and USFWS to identify any
further ESA consultation requirements should a different Preferred Alternative be chosen by
FHWA. It was confirmed that USFWS would treat any future changes to the biological opinion
as an "amendment" to the biological opinion. It was agreed that USFWS, FHWA, and NCDOT
would work together to draft an amendment, if needed, prior to FHWA selecting a different
Preferred Alternative. It was agreed that re-initiation of ESA Section 7 consultation was not
warranted should the Parallel Bridge Corridor with Road North/Bridge South Alternative be
selected as the Preferred Alternative.
Bonner Bridge Replacement EA 3-9 NCDOT TIP Project Number B-2500
3.6.3 May 2009 ESA Consultation with NOAA Fisheries
NOAA Fisheries agreed that re-initiation of ESA Section 7 consultation is not warranted should
NCDOT select the Road North/Bridge South Alternative as the Preferred Alternative. They
indicated in a May 14, 2009, e-mail that if NCDOT follows the protective procedures outlined in
the original consultation (i.e., sea turtle protection guidelines), the effects of the change to this
alternative would not be different from that of the original consultation.
3.6.4 August 2009 ESA Consultation with USFWS
Following the development of the Parallel Bridge Corridor with NC 12 Transportation
Management Plan Alternative (Preferred), FHWA and NCDOT again requested assistance from
USFWS in determining whether re-initiation of consultation would be necessary with the change
of the Preferred Alternative to the NC 12 Transportation Management Plan Alternative. USFWS
agreed with FHWA that re-initiation of consultation is unnecessary for the new Preferred
Alternative.
3.7 December 2009 Coordination Meeting with
Council on Environmental Quality
A meeting was held to discuss the Bonner Bridge Replacement Project on December 11, 2009, at
the Council on Environmental Quality (CEQ) office in Washington, D. C. The meeting was held
at the request of CEQ since they were contacted by USFWS after USFWS' review of the Revised
Final Section 4(f) Evaluation that was approved and circulated by FHWA and NCDOT in
October 2009. Along with representatives from CEQ and USFWS, other agencies represented
were USDOI, NCDOT, and FHWA. Issues discussed during the meeting included FHWA's
Revised Final Section 4(f) Evaluation and FHWA's decision to develop an EA to identify and
assess changes to the project since the September 2008 FEIS was approved and subsequently to
determine whether the changes result in significant impacts not previously disclosed in the FEIS.
While no issues were resolved during the meeting, CEQ stated that FHWA and NCDOT should
work with USFWS to develop a Partnership Agreement and include it in the ROD.
3.8 Public Involvement
The agencies and interest groups listed below will be sent a copy of this EA with a request for
comments. These same agencies and interest groups were sent a copy of the FEIS. The
availability of the EA will be announced via a newsletter sent to those on the project's mailing list
and in advertisements within local media outlets. The EA will also be available on the project
website (www.ncdot.org/projects/bonnerbridgerepairs) and the Outer Banks Task Force website
(www.obtforg). Public meetings will be held to gather additional comments on the EA.
Comments on the EA will be addressed in subsequent documentation.
Federal Agencies
Advisory Council on Historic Preservation Federal Energy Regulatory Commission
Federal Emergency Management Agency US Army Corps of Engineers
Bonner Bridge Replacement EA 3-10 NCDOT TIP Project Number B-2500
US Coast Guard-5th District
US Department of Agriculture-Natural
Resources Conservation Service
US Department of Commerce-National
Oceanic and Atmospheric Administration-
National Marine Fisheries Service
US Department of Health and Human
Services
US Department of Housing and Urban
Development
US Department of the Interior-US Fish and
Wildlife Service (Pea Island National
Wildlife Refuge and Raleigh Field Office);
Keeper of the National Register; National
Park Service; US Geological Survey
US Environmental Protection Agency,
Region IV (Environmental Review Branch)
State A
North Carolina Department of
Administration-State Clearinghouse
North Carolina Department of Cultural
Resources-Division of Archives and
History
North Carolina Department of Environment
and Natural Resources-Division of Air
Quality; Division of Coastal Management;
Division of Land Resources; Division of
Marine Fisheries; Division of Parks and
Recreation; Division of Water Quality
North Carolina Wildlife Resources
Commission
Local Governments and Agencies
Albemarle Regional Planning and
Development Commission (Albemarle Rural
Planning Organization)
Area Development Coordination Agency
(ADCA)
County of Dare-Chair, Dare County
Commissioners; Dare County Manager;
Emergency Management Agency
Mayor of Kill Devil Hills
Mayor of Kitty Hawk
Mayor of Manteo
Mayor of Nags Head
Mayor of Southern Shores
Oregon Inlet and Waterways Commission
Mayor of Duck
Local Interest
Audubon North Carolina
Carolina Electric Cooperatives
Center for Biological Diversity
Coastal Wildlife Refuge Society
Conservation Council of North Carolina
Dare County Tourist Bureau
Defenders of Wildlife
Eastern Surfing Association, Outer Banks
District
Environmental Defense Fund
Friends of Hatteras Island
Hatteras Civic Association
Bonner Bridge Replacement EA 3-11 NCDOT TIP Project Number B-2500
Hatteras Island Business Association
National Parks Conservation Association
North Carolina Coastal Federation
North Carolina Fisheries Association
Pamlico - Tar River Foundation
Sierra Club, North Carolina Chapter
Southern Albemarle Association
Southern Appalachian Biodiversity Project
Outer Banks Chamber of Commerce Southern Environmental Law Center
Public Review Locations
Dare County Libraries in Hatteras Village,
Kill Devil Hills, and Manteo, North Carolina
Fessenden Recreation Center in Buxton,
North Carolina
Dare County Planning and Inspections
Satellite Office in Buxton, North Carolina
NCDOT Resident Engineer's Office in
Manteo, North Carolina
Bonner Bridge Replacement EA 3-12 NCDOT TIP Project Number B-2500
4.0 Conclusion
This Environmental Assessment (EA) documents changes associated with the project as well as
changes to the project environment.
From the analysis contained in Section 2.3, the Federal Highway Administration (FHWA)
believes that the identification of a new alternative (Parallel Bridge Corridor with NC 12
Transportation Management Plan [Preferred]) does not result in new, significant impacts to
the human and natural environments not previously identified in the Final Environmental
Impact Statement (FEIS) since this alternative is a mixing and matching of the other Parallel
Bridge Corridor alternatives already assessed in the FEIS with minor revisions in Rodanthe
and at Oregon Inlet on Hatteras Island.
From the analysis contained in Sections 2.1 and 2.3, FHWA believes that the modification of
alternatives lessens several of the adverse impacts identified in the FEIS while not creating
new, significant impacts not previously identified. The principal increases in impacts that
would occur are associated with revisions to the alternatives in Rodanthe that eliminate
adverse effects to the Rodanthe Historic District. While reducing impacts in the historic
district, relocations and noise impacts increase in Rodanthe, but the increases are not
significant (see Section 2.1).
• From the analysis contained in Section 2. 1, FHWA believes that the conclusions in the
Revised Final Section 4(f) Evaluation do not suggest any new, significant impacts not
previously identified in the FEIS.
• From the analysis contained in Section 2.3.7, although the cost estimates have changed
slightly from the FEIS, FHWA does not believe that the changes are of such magnitude that
the cost estimates would be a new, significant impact not previously identified in the FEIS.
Based on this analysis and on the extensive coordination with state and federal environmental
resource and regulatory agencies, FHWA believes that the FEIS and EA adequately document the
range of impacts that could be anticipated with the Preferred Alternative. FHWA also believes
the changes identified in this EA would not result in new, significant impacts not previously
identified in the FEIS.
FHWA now seeks input on the content and tentative conclusions identified in this EA. Once
public and agency input have been received and considered, FHWA will determine whether a
Supplemental FEIS needs to be prepared.
Bonner Bridge Replacement EA 4-1 NCDOT TIP Project Number B-2500