20150955 Ver 1_EPA Comments_20120413

U.S. Environmental Protection Agency Region 4 Raleigh Office
Terry Sanford Federal Courthouse
310 New Bern Avenue
Raleigh, North Carolina 27601
April 13, 2012
Dr. Gregory J. Thorpe, Ph.D.
Manager, Project Development and Environmental Analysis Unit
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699 -1548
SUBJECT: Federal Environmental Assessment, Topsail Island Bridge Replacement, Surf
City, Pender County, TIP No: B -4929
Dear Dr. Thorpe:
The U.S. Environmental Protection Agency (EPA) has reviewed the subject
document and is providing comments in accordance with Section 309 of the Clean Air
Act and Section 102(2)(C) of the National Environmental Policy Act (NEPA). The North
Carolina Department of Transportation (NCDOT) and the Federal Highway
Administration (FHWA) are proposing to replace Bridge No. 16 over the Intercoastal
Waterway, in Surf City, Pender County.
The proposed project is included in the NEPA/Section 404 Merger process. EPA
has been an active participant and concurred with the purpose and need, Concurrence
Point 1, on August 20, 2009. Detailed study alternatives (DSAs) to be carried forward,
Concurrence Point 2, was agreed to on December 14, 2010. EPA's detailed technical
review comments on the Federal Environmental Assessment (EA) are attached to this
letter (See Attachment A).
EPA has not identified environmentally preferred alternative at this time from the
seven (7) Detailed Study Alternatives (DSAs) under consideration and will work with the
other Merger team agencies on the selection of the Least Environmentally Damaging
Preferred Alternative (LEDPA) at the Concurrence Point 3 meeting. We appreciate the
opportunity to review this document and request a copy of the Finding of No Significant
Impact (FONSI) when it becomes available. Please feel free to call me should you have
any questions concerning these comments at 919 - 856 -4206 or 404 -562 -9512. Thank
you.

Sincerely,
Christopher A. Militscher, REM, CHMM
Merger Team Representative
FOR:
Heinz J. Mueller, Chief
NEPA Program Office
USEPA Region 4
Cc: C. Coleman, FHWA
B. Shaver, USACE
D. Wainwright, NCDWQ
S. Sollod, NCDCM
w /Attachment

Attachment A
Detailed Technical Comments
Topsail Island Bridge Replacement
Federal EA for TIP No: B -4929
Pender County, N.C.
Evaluation of the Environmental Impacts from the Detailed Study Alternatives
Seven (7) Detailed Study Alternatives (DSAs) were carried forward for study in
the Environmental Assessment (EA), including Alternatives 44, 45, 45R, 46, 47, 411, and
417. All of the DSAs include a new bridge over the Intercoastal Waterway.
DSA 45R has substantially higher impacts to residences and businesses than the
other DSAs (i.e., 413 and 47, respectively). DSA 46 has the least impact to existing
residences and businesses at 0 residential relocation and 1 business relocation.
Table 5 -13 of the EA also includes total property impacts for each DSA. Vacant
property `impacts' are a routine cost - related effect of the transportation agencies building
new roadways and bridges. However, the DSAs with the least number of vacant property
impacts (i.e., DSA 46 and 47), actually have the greatest estimated costs (i.e.,
$93,719,530 and $101,319,530, respectively). Conversely, the DSA with the greatest
number of vacant property impacts (i.e., DSA 417 — 43) has the least total project costs
(i.e., $57,372,278). The information on vacant property impacts are not typically included
in NEPA document summary impact tables. EPA is unsure as to the relevance of
providing this information in the summary impact table.
Potential impacts to jurisdictional wetland resources for the seven (7) DSAs as
referenced above are 1. 1, 1. 1, 1. 1, 0, 0, 1.0 and 0.8 acres, respectively. DSA 46, 47 and
417 have potential impacts to 03, 0. 1, and 0.4 acres, respectively to CAMA regulated
wetlands. With the exception of DSA 46 and 47, all of the other DSAs have
jurisdictional impacts of a similar magnitude (approximately 1 acres or less).
All of the DSAs have a Section 4(f) adverse effect to the existing historic Topsail
Bridge No. 16. DSA 46 and 47 also have a potential Section 4(f) effect to the Soundside
Park (i.e., 0.03/0.4 acres and 0.01/0.4 acres; permanent /temporary impacts). All of the
DSAs have a `May Affect — Not Likely to Adversely Affect' (MA -NLAA) determination
for two Federally - protected species.
Impacts to Terrestrial Forest communities are identified in Table 5 -2 of the EA.
The estimated impacts from the DSAs range between 0.1 acres for DSA 47 to 3.6 acres
for DSA 411. DSA 411 has 1.5 acres of impact to mesic mixed hardwood forests.
Considering the past substantial loss of these types of coastal terrestrial communities
from development, and in consideration of other jurisdictional and human resources
impacts, DSA 411 is EPA's least preferred alternative. DSA 411 also includes 4
residential relocations and 1 business relocation and impacts the Faith Harbor United
Methodist Church property.