R2303

MEMORANDUM - MEETING MINUTES
DATE: July 25, 2007
TO: File - 669580 FROM: Dana Shiflett
LOCATION: PTG - Raleigh LOCATION: Raleigh, North Carolina
PHONE: [phone] PHONE: [phone]
SUBJECT: MINUTES, 05/24/07 CONCURRENCE POINT #4A MEETING
STIP SECTIONS B, C AND D
NC 24 ENVIRONMENTAL STUDY (R-2303)
A meeting was held on May 24, 2007 at the NCDOT Board Room in Raleigh, to discuss
and seek concurrence on NEPA/ 404 Merger Point #4A (Avoidance and Minimization) for
STIP Sections B, C and D. The agencies represented are as shown on the attendee list in
Appendix A. The agenda is in Appendix B. Handouts were distributed to attendees not
receiving advance copies, and the following handout errata were distributed (note: copies
of the handouts obtained at the meeting may already include some or all of these
corrections):
Table 2, Pages 5 of 6 and 6 of 6 - The 2007 wetland impact shown for Site # 167
was changed. Consequently, the total wetland impact also changed. These
sheets are included in Appendix C of these minutes.
Although not distributed at the meeting, it also follows that the data in Table 3
for Wetland Site # 167 would change. A revised version of this table is also
included in Appendix C of these minutes.
Meeting Minutes:
1) Mr. Pierce conducted the introductions portion of the meeting and reviewed the
project for the meeting attendees:
• Mr. Joel Strickland (in attendance) is the new representative for the Mid-Carolina
RPO.
• Agencies/ organizations absent from the meeting include the US Fish and Wildlife
Service (Mr. Gary Jordan), the NC Wildlife Resources Commission (Mr. Travis
Wilson), the Eastern Carolina RPO (Mr. Alex Rickard is the new representative), NC
SHPO (Ms. Renee Geldhill-Earley), and the Fayetteville MPO (Mr. Rick Heicksen).
These agencies will be contacted by phone or face-to-face meeting to provide
meeting information.
• This portion of the meeting is to discuss avoidance and minimization for the portion
of the project from Autryville to Clinton (Sections B, C and D).
• Verbal concurrence was reached at the January 18, 2007 meeting on avoidance
and minimization for Section A.
• Minutes from both this and the January 18, 2007 meeting will be attached to the
concurrence forms.
Since the previous meeting, the USACE sent out the Public Notice and received
comments on it.
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT 4A MEETING
STIP SECTIONS B, C AND D
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 2
2) Ms. Shiflett reviewed the preliminary design plan sheets and pointed out the major
wetland and stream areas and bridging locations. She also made the following
general points regarding the avoidance and minimization efforts:
• Stream impact increases from the original preliminary design to the DEIS are, in
many cases, a result of the fact that the horizontal alignment within the wider
new location corridors (e.g., the Autryville and Roseboro bypasses) was shifted
substantively in response to agency comments to avoid wetlands in those areas.
The original preliminary designs were along the corridor centerlines.
• All bridging and associated impacts shown are based on decisions made at the CP
2A meetings.
• Modifications made by Parsons following the '02-'03 concurrence meetings were
primarily horizontal alignment changes to miss or minimize involvement with
certain wetland sites specified by the agencies.
• Newer refinements made by NCDOT included more vertical alignment changes, to
improve drainage and/or to provide wildlife passage at bridges.
• Wetland involvement increased at some sites for newer NCDOT design
refinements for the following reasons:
¦ The cut ditch (for median drainage) was not originally calculated in.
¦ In crossing the smaller streams, the grade was too low, and had to be raised,
which increased wetland takings.
¦ With a high groundwater table, the median needs to be at a higher elevation to
drain.
¦ Some changes in grade in the vicinity of bridges are to provide requested
wildlife passage.
3) Mr. Militscher noted that the specific measures used in avoidance / minimization
need to be itemized for inclusion with the concurrence form. This would include
retaining walls, noise barriers, etc., if applicable.
4) Mr. Pierce noted that 3:1 side slopes, bridging, and median reduction had been used
on this project to avoid and minimize impacts. The preliminary design revisions made
in 2003 as a result of agency suggestions received at the 2002-2003 CP 3/4A
meetings were extensive and consisted mainly of horizontal alignment changes.
5) Mr. Militscher suggested that the Merger team look at the areas of increase to
determine if they can suggest additional avoidance and minimization measures.
6) Mr. Militscher noted that the bulbout at Wetland Site # 137 is encroaching somewhat
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT 4A MEETING
STIP SECTIONS B, C AND D
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 3
on the wetland area and should be shifted to the west, assuming that the spacing
criteria can still be maintained. It was determined that the bulbout could be shifted
west.
7) Mr. Wainwright asked if Wetland Sites # 143, 144, and 145 would essentially be total
takes. Ms. Shiflett confirmed that they would be.
8) Ms. Shiflett noted that the bulbout in the vicinity of Wetland Site # 150 can be moved
to reduce/ eliminate impact to that wetland site. Mr. Militscher noted that the total
increase in impact from original to 2007 design was almost 1/3 acre. Mr. Duncan
explained that the portion of the increase not resulting from the placement of the
bulbout was the result of an approximately 5-foot raise in grade.
9) Mr. Militscher commented that both Wetland Sites # 164 and 167 showed substantial
increases in impacts. Mr. Duncan explained that the increases at both of those sites
were a result of raising the grade.
10) Mr. Duncan noted that drainage and wildlife passage issues were both factors in
increases in wetland impacts at the bridged sites. Mr. Price added that span lengths
for the bridges would be maximized. To achieve an 8-foot vertical clearance for
wildlife passage, 95-foot spans would be the maximum attainable span length, and
raising the grade would be necessary at several of the bridge sites.
11) Mr. Militscher asked if impacts using a reduced median (i.e., less than the 46-foot
standard width) were ever computed for this project. Ms. Shiflett responded that any
median reductions deemed appropriate (for example, east of Bonnetsville, across
Great Coharie Creek) were implemented from the outset of the design efforts, so
comparative figures were never developed.
12) Mr. Militscher asked about Wetland Sites # 118 and 119 (both of which increased
from an initial impact of zero). These two sites were impacted during later alignment
shifts due to attempts to miss large portions of Wetland Sites # 114, 115, 116, and
117.
13) Mr. Militscher asked if there were any equalizer pipe locations proposed by NCDOT.
Mr. Price commented that he did not recall any. Ms. Frye noted that Wetland Sites
# 150 and 151 do not seem to be associated with streams. Mr. Price commented that
equalizer pipes might be a good idea at Wetland Sites #150 and 151, especially if
there is a large wetland area to the south.
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT 4A MEETING
STIP SECTIONS B, C AND D
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 4
14) Ms. Frye asked if there were any isolated wetland sites. Mr. Herndon responded that
there were not.
15) Ms. Frye noted that jurisdictional ponds need to be accounted for. No mitigation is
needed, but any ponds need to be included in the total. She mentioned the pond near
Wetland Sites # 121 and 122 (note: pond is designated as Site # 120). Mr. Militscher
noted that this pond would be a total take.
16) Mr. Militscher indicated that he was in concurrence with CP 4A for Sections B, C and
D, and that he wanted to sign the forms as an indication to the absentees that EPA is
in concurrence.
17) Mr. Militscher inquired if there are any noise barriers proposed on this project. Ms.
Shiflett responded that the only areas densely enough populated to be even
marginally eligible for noise barriers would be the widening portions of the project.
Due to frequent driveway access points along those sections, noise abatement
measures would not be effective.
The Merger Process Team verbally concurred with the avoidance and minimization
measures for Sections B, C and D.
Agreed Upon Design Modifications and Other Avoidance / Minimization Measures:
1) Shift bulbout away from Wetland Site #137.
2) Shift bulbout away from Wetland Site # 150.
3) Examine use of equalizer pipes at Wetland Sites #150 and 151.
4) Use 3:1 side slopes in wetlands.
5) Use bridge lengths agreed on at CP 2A meetings (see table on page 8 in handout).
6) Reduce median width from Bonnetsville eastward (implemented in previous design
considerations).
7) Include Site #20 (pond) in the total impacts.
ACKNOWLEDGEMENTS
Thank you to those who participated or contributed to this concurrence meeting. These
minutes constitutes our understanding of the matters discussed and the conclusions
reached. If there are any questions, corrections, omissions, or additional comments please
advise,the author within five working days after receipt of these minutes.
PARSONS TRANSPORTATION GROUP, INC.
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Appendix B
NC 24 From 2.8 Miles East of I-95 to I-40
Cumberland, Sampson, and Duplin Counties
TIP Project Number R-2303 - Sections B, C, D, E and F
May 24, 2007 Concurrence Point 3 & 4A Meetings
10:30 a.m. - NCDOT Board Room, NCDOT Raleigh
Meeting Agenda
GENERAL PROJECT INFORMATION
Introductions
Mark Pierce, NCDOT (Project Development and Environmental Analysis Branch)
Project Description
Mark Pierce, NCDOT (Project Development and Environmental Analysis
Branch)
Project Status
Mark Pierce, NCDOT (Project Development and Environmental Analysis
Branch)
Merger Process Status
Mark Pierce, NCDOT (Project Development and Environmental Analysis
Branch)
CONCURRENCE POINT NUMBER 3 - SECTIONS E AND F
Review of Constraints Map
Dana Shiflett, Parsons Transportation Group
Public Comments and Agency Input
Dana Shiflett, Parsons Transportation Group
Evaluation of Impacts for LEDPA Decision-Making
Dana Shiflett, Parsons Transportation Group
NCDOT Recommendations
Dana Shiflett, Parsons Transportation Group
CONCURRENCE POINT NUMBER 4A - SECTIONS B, C, AND D
General Review of Sections B, C, and D Design and Constraints
Dana Shiflett, Parsons Transportation Group
Review of Jurisdictional Impacts
Dana Shiflett, Parsons Transportation Group
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MEMORANDUM - MEETING MINUTES
TO: File - 669580
LOCATION: PTG - Raleigh
PHONE: [phone]
DATE: July 25, 2007
FROM: Dana Shiflett
LOCATION: Raleigh, North Carolina
PHONE: [phone]
SUBJECT: MINUTES, 05/24/07 CONCURRENCE POINT #3 MEETING
STIP SECTIONS E AND F
NC 24 ENVIRONMENTAL STUDY (R-2303)
A meeting was held on May 24, 2007 at the NCDOT Board Room in Raleigh, to discuss
and seek concurrence on NEPA/404 Merger Point #3 (Least Environmentally Damaging
Practicable Alternative) for STIP Sections E and F. The agencies represented are as shown
on the attendee list in Appendix A. The agenda is in Appendix B. Handouts were
distributed to attendees not receiving advance copies.
Meeting Minutes:
1) Mr. Pierce conducted the introductions portion of the meeting and reviewed the
project for the meeting attendees:
• Mr. Joel Strickland (in attendance) is the new representative for the Mid-Carolina
RPO.
• Agencies/ organizations absent from the meeting include the US Fish and Wildlife
Service (Mr. Gary Jordan), the NC Wildlife Resources Commission (Mr. Travis
Wilson), the Eastern Carolina RPO (Mr. Alex Rickard is the new representative), NC
SHPO (Ms. Renee Gledhill-Earley or Ms. Sarah McBride), and Fayetteville MPO (Mr.
Rick Heicksen). These agencies will be contacted by phone or face-to-face meeting
to provide meeting information.
• This portion of the meeting was to discuss the LEDPA for the portion of the project
from Clinton to Warsaw (Sections E and F).
• Verbal concurrence was reached at the January 18, 2007 meeting on LEDPA for
Sections A through D.
• Minutes from both this and the January 18, 2007 meeting will be attached to the
concurrence forms for reference.
• Since the January 18, 2007 meeting, the USACE sent out the Public Notice and
received comments on it.
2) Mr. Militscher asked why the floodplain impacts were substantially greater for
Alternate E2-FIB-F2-F3 than for the other alternates. Ms. Shiflett noted that the
wider floodplain crossing at Six Runs Creek for F 1 B was the main factor.
3) Ms. Shiflett noted that the identification of Environmental Justice on Table 1 as an
issue indicated that a minority or low-income population was identified on the
alternate, not that any determination of disproportionate impact had been made.
PARSONS TRANSPORTATION GROUP, INC.

MINUTES, 05/24/07 CONCURRENCE POINT #3 MEETING
STIP SECTIONS E AND F
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 2
4) Mr. Militscher asked if the farmland impacts evaluated were based on the SCS
farmland ratings. Ms. Shiflett noted that the impacts weren't based on the ratings.
The impacts were to any type of soil identified as prime or important, regardless of
rating. Mr. Militscher noted from the farmland rating tables in the appendix of the
DEIS that none of the area prime farmland soils qualified for federal protection.
5) One of the identified archaeological sites is located on Segment F1 (A, B, and C), and
the other is located on Segment F5.
6) Mr. Wainwright noted that if the higher forest impacts on E1-E3-F4-F5 can
potentially be reduced through additional design measures, the same is conceivably
true for the other alternates.
7) Mr. Militscher noted that there is a potential for indirect and cumulative effects for
E1-E3-F4-F5, but it is not great. Based on this, and his previous comments, he
indicated that EPA was willing to concur with the selection of E1-E3-F4-F5 as the
LEDPA.
8) Mr. Strickland indicated that he had not heard of any specific concerns from area
residents and that most people that he has talked to are in favor of the southern
route.
9) Mr. Militscher requested clarification on the issue of the Williamson family farm. Ms.
Shiflett identified it as a historically Black farm (per the verbiage used by the farm
owners themselves). The owners have expressed concerns about division of the farm
property. Mr. Lucas noted that FHWA does not necessarily view the impacts as
disproportionate, but there is a need to address any access, land impacts and/or
relocation issues associated with the farm. He also noted that FHWA concurs with
Alternate E1-E3-F4-F5 as the LEDPA.
10) Mr. Vick noted that approximately 25 of the relocations reported for Alternate E1-E3-
F4-F5 are at the interchange near SR 1116 and SR 1934.
11) Mr. Wainwright expressed concerns about the higher stream impacts for Alternate
E1-E3-F4-F5. Mr. Vick displayed mapping showing that the interchange near SR
1116 and SR 1934 includes a substantial amount of the stream impacts reported for
Alternate E1-E3-F4-F5. Mr. Militscher commented that the systems had appeared
somewhat straightened to him. Ms. Shiflett noted that the two largest stream impacts
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT #3 MEETING
STIP SECTIONS E AND F
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 3
at this interchange were RB 15 (241 LF) and RB 16 (985 LF). Wetland Site 250 has a
DWQ score of 54. Wetland Sites 244A and 244B each have a score of 44.
12) Hog farm issues/impacts were discussed:
• Ms. Frye commented that USACE has the same concerns as EPA, and questioned if
it is possible to move spray fields, hog lagoons, etc. for a hog farm.
• Mr. Militscher commented that based on earlier field visits, most or all of the hog
lagoons on potentially impacted farms should be avoidable.
• Mr. Pope asked if there is a moratorium on new hog farms. Ms. Frye noted that a
relocation may not be considered a "new" hog farm.
• Mr. Vick commented that more detailed information would be available after
corridor selection.
13) Mr. Hennessy asked how the wetland impacts were computed. Ms. Shiflett explained
that wetlands were digitized from Microstation roadway files, and impacts computed
were for construction limits plus 10-foot buffer (which was standard at the time). Mr.
Hennessy asked if avoidance/ minimization was employed. Ms. Shiflett referred back
to the 2002-2003 concurrence meetings, during which the agencies requested
various alignment shifts to reduce wetland impacts. Those were implemented as
feasible.
14) Mr. Hennessy asked if both northern and southern routes would impact the Coharie
community. Mr. Vick and Mr. Pierce both indicated that only the northern route (E1-
E2-F1A/B/C-F2-F3) would affect the community. Ms. Shiflett added that the
community's perception has become that they wind up being impacted by virtually
every roadway project in the county.
15) Mr. Pierce noted that without the interchange at SR 1116 and SR 1934, the impacts
of the two alternates are very similar.
16) Mr. Hennessy asked who made the intermittent versus perennial stream designation
calls. Ms. Shiflett noted that Jeff Harbour from ESI and Dave Timpy from USACE
discussed some of those issues in the field. Ms. Frye noted that USACE does not
ultimately make the judgments for streams. Mr. Harbour explained that the ESI
judgments were based on DWQ classifications, insects, discussions with USACE
personnel, and seasonal investigations (i.e., looked at sites more than once).
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT #3 MEETING
STIP SECTIONS E AND F
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 4
17) Mr. Hennessy commented that other than the lower wetlands for Alternate E1-E3-F4-
F5, this alternate was higher in all other impacts. Since he was concerned about the
greater stream impacts, he saw the wetlands versus stream impacts as a wash. He
also expressed concerns about secondary and cumulative impacts. Based upon
project studies E1-E3-F4-F5 would not generate the highest impacts in all categories.
18) Mr. Militscher noted that fragmentation maybe an issue on this project, and that the
agencies that might have particular concerns about that issue were not in
attendance at the meeting. Wildlife crossings might be a point of discussion for CP
4A.
19) Ms. Frye asked DWQ which impacts were higher for Alternate El-E3-F4-F5, in
addition to the stream impacts. Mr. Hennessy mentioned relocations and hazardous
materials sites, and reiterated that the stream and wetland impacts were essentially
a wash.
20) Mr. Hennessy commented that the more southerly route would provide more access
to previously untapped lands. The more northerly routes, which are closer to existing
NC 24, would keep development more concentrated in areas that are already
disrupted.
21) Mr. Lucas noted that Alternate E1-E3-F4-F5 had received more favorable public
input and has less cemetery involvement.
22) Mr. Strickland commented that he had not received any negative commentary on
Alternate El-E3-F4-F5. Mr. Pierce noted that most of the project is in Sampson
County, and the county's advocacy group supports Alternate El-E3-F4-F5.
23) Mr. Pierce noted that Allen Canning, among the largest employers in Sampson
County, would be impacted by all three of the northern alternates. Allen Canning has
plans for expansion of their Turkey operation. Mr. Wainwright commented that
Alternate FIB does not appear to impact the Allen Canning operations. Ms. Shiflett
noted that the Allen Canning representative specifically mentioned FIB as the least
desirable alternative from the company's perspective. Mr. Pope reiterated that the
company has future expansion plans.
24) Mr. Militscher noted that the Coharie Native American group will likely perceive the
northern route as causing a disproportionate impact. It would probably be better to
not impact this group.
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT #3 MEETING
STIP SECTIONS E AND F
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 5
25) Mr. Pope commented that there is overwhelming public support for Alternate El-E3-
F4-F5, despite the higher relocations anticipated.
26) Mr. Wainwright asked if the Williamson Farm is also an issue in terms of
Environmental Justice. Ms. Shiflett noted that many of the respondents against
Alternate E1-E3-F4-F5 were members of the Williamson family / farm owners (i.e.,
no other specific EJ issues were identified along this route). Supporters of this route
had diverse interests and reasons for favoring this alternate.
27) Mr. Wainwright expressed the following concerns relating to the selection of Alternate
El-E3-F4-F5 as the Preferred Alternative (note: these will also be submitted in
writing to NCDOT):
• The streams that are a part of the system in the vicinity of the interchange at SR
1116 and SR 1934 need to be investigated to determine if they are perennial or
intermittent. The existing 66-inch culvert at this location would seem to indicate
that the stream is perennial, not intermittent. DWQ does not believe that they are
intermittent, as they are currently classified. (Note: The 66-inch culvert referred to
by DWQ is not an existing culvert but a proposed culvert for drainage of the
interchange at SR 1116 and SR 1934.)
• The issues for Allen Canning need to be clarified. Based on available information,
DWQ does not understand why Alternates F1A and F1C would have negative
impacts on the canning company's operations.
• For the Coharie Native American community, clarification is needed on the actual
location of the community and the actual impacts associated with the northern
alternates.
• During a break in the meeting, the issue of constructability was mentioned to DWQ
attendees. This concerns the railroad crossing structures that would be required
along the northern routes, which could potentially be long and expensive due to
sharp skews.
28) Ms. Frye asked that DWQ copy Merger team members on the email to NCDOT
describing the issues of concern.
29) Mr. Lucas noted that DWQ needs to provide written documentation of some sort
describing the reasons for their inability to concur with the meeting recommendation.
Mr. Yamamoto noted that there may be a non-concurrence format for use by DWQ. If
there is not a set format, perhaps a format from a prior meeting could be used.
PARSONS TRANSPORTATION GROUP, INC.
MINUTES, 05/24/07 CONCURRENCE POINT #3 MEETING
STIP SECTIONS E AND F
NC 24 ENVIRONMENTAL STUDY (R-2303)
July 25, 2007
Page 6
30) Mr. Pierce commented that it might be difficult to define the area of impact for the
Coharie tribe. Mr. Hanson noted that comments received from members of the
Coharie community at the Corridor Public Hearing should be assembled.
31) Ms. Frye asked DWQ about the differences between perennial and intermittent
streams from the DWQ's standpoint. Mr. Hennessy noted that perennial streams
tend to have higher biological function. Ms. Frye suggested that a functional
assessment of the streams in question would be more appropriate than just
classifying the streams as either perennial or intermittent. Mr. Hennessy indicated
that if NCDOT wanted to provide a functional assessment that DWQ would be willing
to look at it.
Follow-Up Actions:
1) Obtain the following information for DWQ:
• Coharie Native American community boundaries (based on property boundaries of
persons considered to be members of the community), community facilities, etc.
• Allen Canning Company current and future planned operations, including locations
of existing and proposed company facilities (e.g., buildings, spray fields). Determine
potential impacts to these facilities from Segments F1A, F113, and F1C.
• Investigations of the streams in the vicinity of the interchange at SR 1116 at SR
1934. Conduct a field visit with DWQ personnel. Search ESI files for information on
stream function at those locations.
• Constructability issues having to do with railroad crossing structures.
2) Contact representatives for those agencies not present at the concurrence meeting to
provide those persons with additional information concerning meeting discussions.
ACKNOWLEDGEMENTS
Thank you to those who participated or contributed to this concurrence meeting. These
minutes constitutes our understanding of the matters discussed and the conclusions
reached. If there are any questions, corrections, omissions, or additional comments please
advise the author within five working days after receipt of these minutes.
PARSONS TRANSPORTATION GROUP, INC.
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Appendix B
NC 24 From 2.8 Miles East of I-95 to I-40
Cumberland, Sampson, and Duplin Counties
TIP Project Number R-2303 - Sections B, C, D, E and F
May 24, 2007 Concurrence Point 3 & 4A Meetings
10:30 a.m. - NCDOT Board Room, NCDOT Raleigh
Meeting Agenda
GENERAL PROJECT INFORMATION
Introductions
Mark Pierce, NCDOT (Project Development and Environmental Analysis Branch)
Project Description
Mark Pierce, NCDOT (Project Development and Environmental Analysis
Branch)
Project Status
Mark Pierce, NCDOT (Project Development and Environmental Analysis
Branch)
Merger Process Status
Mark Pierce, NCDOT (Project Development and Environmental Analysis
Branch)
CONCURRENCE POINT NUMBER 3 - SECTIONS E AND P
Review of Constraints Map
Dana Shiflett, Parsons Transportation Group
Public Comments and Agency Input
Dana Shiflett, Parsons Transportation Group
Evaluation of Impacts for LEDPA Decision Making
Dana Shiflett, Parsons Transportation Group
NCDOT Recommendations
Dana Shiflett, Parsons Transportation Group
CONCURRENCE POINT NUMBER 4A - SECTIONS B, C, AND D
General Review of Sections B, C, and D Design and Constraints
Dana Shiflett, Parsons Transportation Group
Review of Jurisdictional Impacts
Dana Shiflett, Parsons Transportation Group