20110023_More Info Letter_20100630

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IN REPLY REFER TO
Regulatory Division
Subject: Action ID. 199303077
Dr. Gregory J. Thorpe, Ph.D.
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
Washington Regulatory Field Office
Post Office Box 1000
Washington, North Carolina 27889-1000
June 30, 2010
Environmental Management Director, PDEA
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Dr. Thorpe:
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Please reference your May 11, 2010, correspondence requesting our review and comments
concerning the Federal Environmental Assessment (EA) for the NC 12 Replacement of Herbert
C. Bonner Bridge, TIP No. 2500, Dare County, North Carolina. The purpose of this
1 Environmental Assessment is to identify and assess changes that have occurred since the
approval of the Final Environmental Impact Statement/Final section 4(f) Evaluation (FEIS) on
September 17, 2008 and to determine whether or not theses changes would result in significant
environmental impacts not evaluated in the FEIS, therefore, determining whether a Supplemental
Final Environmental Impact Statement is needed. In response to your request we have the
following comments:
1. Page 1-1, Section 1. 1, Purpose of the Environmental Assessment. It appears the
purposes identified in this section adequately document the changes for the proposed project
since the release of the September 2008 Final Environmental Assessment. Based on the
revisions contained in the EA there doesn't appear to be changes or circumstances which result
in significant environmental impacts not evaluated in the FEIS therefore prompting the
preparation of a Supplemental Final Impact Statement (SFEIS).
2. Page 2-20, Section 2.3.3.3 Later Phases (NC 12 Transportation Management Plan),
Environmental Review for Future Phases. In the last paragraph it states "as of the publication
of this EA, sections of the Canal Zone, Sandbag Area, and Rodanthe hot spot areas may already
meet one or more of the listed criteria." The facts need to be stated in this section to clarify that
these sections of NC 12 are or are not currently meeting one or more of the five listed criteria
(criteria assumed to be included in the NC 12 Transportation Management Plan) which warrant
initiating an environmental review of a future phase. It is recommended that if any of these
sections are meeting the criteria, that NCDOT and FHWA immediately implement a` plan of
action based on this section of the EA and document it in the Record of Decision (ROD). Based
on information in section 4.6.8.6 of the FEIS, NCDOT would confine future NC 12 maintenance
in the Refuge, including storm-related maintenance, to the existing NC 12 easement, after the
issuance of the ROD for the project. It also states NCDOT intends to place a high priority on the
implementation of Phase 11 which includes the three high spots mentioned above. Based on the
FEIS, Phase II is to begin post 2015. It seems logical that if any of these areas are already
meeting criterion which will be specified in the Transportation Management Plan, Phase II needs
to start immediately after the issuance of the ROD. These issues need to be addressed in the NC
12 Transportation Management Plan.
3. Page 2-29 and 2-30, Section 2.3.4 Basis for Selection of the Preferred Alternative.
This comment is in relationship to what is discussed in item 2 above. In this section it states
"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." It also
states, "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." While we agree that Phase I should be built now and that the rest of the project should
be examined in more detail later, is there enough information present now to make informed
decisions concerning the three hot spot areas?
4. Page 2-33, Section 2.3.7, Costs. Since the costs were updated from those presented in the
+ FEIS to account for the revision to the detailed study alternatives described in Section 2.1 of the
I EA, can the costs also be updated to 2010 dollars instead of 2006 dollars? During the review of
this project, the total costs for the detailed study alternatives have increased substantially in a
relatively short time frame. We feel it is important that the most accurate and up to date cost
estimates be presented for this project since funding has been a major issue for this project.
5. Page 3-9, Section 3.5.6, November 2009 Rodanthe Storm Repair. Add the following
language to the last sentence of the 1 ` paragraph - "after the remnants of Tropical Storm Ida in
2009. Also add that the majority of the approximately 200,000 cubic yards of sand placed on the
beach face east of the sandbags washed away within 2 weeks of completion of the project.
6. Page 3-10, Section 3.7, December 2009 Coordination Meeting with Council on
Environmental Quality. We are in agreement and support that FHWA and NCDOT should
work with USFWS to develop a Partnership Agreement and include in the ROD.
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As a major permitting and cooperating agency, we appreciate the opportunity to coordinate
with you prior to the finalization of the ROD. The Wilmington District is committed to
providing the highest level of support to the public. To help us ensure we continue to do so,
please complete the Customer Satisfaction Survey located at
htt:// er2.n .usace.arm .mil/curve .html to complete the survey online. If you have any
questions regarding our comments, please do not hesitate to contact me at the Washington
Regulatory Field Office, telephone [phone].
Sincerely,
William J. Biddlecome
Regulatory Project Manager
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Copies Furnished:
Renee Gledhill-Earley
North Carolina State Historic Preservation Office
4617 Mail Service Center
Raleigh, North Carolina 27699-4617
Mr. Doug Huggett
Division of Coastal Management
North Carolina Department of Environment,
And Natural Resources
400 Commerce Avenue
Raleigh, North Carolina 28557-3421
Mr. Ron Sechler
National Marine Fisheries Service
101 Pivers Island Road
Beaufort, North Carolina 28516
Mr. Pete Benjamin
U.S. Fish and Wildlife Service
Fish and Wildlife Enhancement
Post Office Box 33726
Raleigh, North Carolina 27636-3726
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Mr. Travis Wilson
Eastern Region Highway Project Coordinator
Habitat Conservation Program
1142 I-85 Service Road
Creedmoor, North Carolina 27522
Mr. Brian Wrenn
Water Quality Section
North Carolina Division of Environment
and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Ms. Jennifer Derby, Chief
Wetlands Section-Region W
Water Management Division
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
Mr. Clarence Coleman, PE
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, North Carolina 27601-1418
Mr. Mike Murray
U.S. Department of Interior
National Park Service
Cape Hatteras National Seashore
1401 National Park Drive
Manteo, North Carolina 27954
Mr. Mike Bryant
U.S, Fish and Wildlife Service
Pea Island National Wildlife Refuge
P.O. Box 1969
Manteo, North Carolina 27954

Mr. Chris Mllltscher
U.S. Environmental Protection Agency
C/O FHWA, Raleigh Area Office
310 New Bern Avenue, Room 206
Raleigh, North Carolina 27601
Mr. Travis Wilson
Eastern Region Highway Project Coordinator
Habitat Conservation Program
1142 I-85 Service Road
Creedmoor, North Carolina 27522
Mr. Brian Wrenn
Water Quality Section
North Carolina Division of Environment
and Natural Resources
1650 Mail Service Center
Raleigh, North Carolina 27699-1650
Ms. Jennifer Derby, Chief
Wetlands Section-Region IV
Water Management Division
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
Mr. Clarence Coleman, PE
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, North Carolina 27601-1418
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