20221501 Ver 1_R-2588B Type III CE 23Aug2018 signed_20221024

Type III Categorical Exclusion Action Classification Form
STIP Project No.
WBS Element
Federal Project No
A. Project Description:
R-2588B
34473.1.3
STP-0191(14)
State Transportation Improvement Program (STIP) Project R-2588B is the proposed
widening of NC 191 (Haywood Road) to multi -lanes from NC 280 (Boylston Highway)
south of Mills River to Mountain Road (SR 1381) to improve safety and mobility. The
project is located in the Town of Mills River, north of Hendersonville, in Henderson
County (see Figure 1).
The proposed project (Build Alternative) includes a five -lane section through
Mills River from NC 280 (Boylston Highway) to School House Road (SR 1426) with a
multi -use path on the northside. A four -lane divided facility is proposed from School
House Road to Mountain Road (SR 1381) with a multi -use path from the West
Henderson High School driveway to the Historic Moss -Johnson Farm property. A left-
over into the Haywood Knolls subdivision will be provided for westbound traffic.
A 5-foot bike lane is proposed on the southside of NC 191 from NC 280 to School House
Road and on both sides of NC 191 from School House Road to Mountain Road, except
at Henderson High School.
B. Description of Need and Purpose:
The purpose of the proposed project is to improve safety and mobility along this section
of NC 191 (Haywood Road).
A five-year (June 2012 — May 2017) crash analysis indicates that NC 191 has a total
crash rate (257 per 100 MVM) that is higher that the statewide average rate (197 per
100 MVM) and critical rate (221 per 100 MVM). The crash rate is expressed as 257
crashes per 100 million vehicles miles traveled. There were 233 crashes over the 5-year
period analyzed which translates into 46.6 crashes per year. Additionally, the fatal (3.3
per 100 MVM), non -fatal injury (76 per 100 MVM) and wet (44 per 100 MVM) crash rates
are above the state averages (1.76, 61, and 24, respectively). The predominate crash
type along this section of NC 191 were, in order: rear end, left turn, and struck object
crashes.
The NC 191 and NC 280 intersection had the highest number of collisions (51) over the
five-year period analyzed. The area around this intersection experiences a lot of
congestion during the peak hours which could lead the higher number of crashes. The
intersection of NC 191 at Rugby Road (SR 1312/SR 1365) has a high number of
crashes. This intersection is in a horizontal curve with a posted speed limit of 45 mph.
These conditions may contribute to the high amount of crashes and the fatal accident
that occurred.
The proposed design will improve the sight distance along NC 191 at Rugby Road
through widening. The widening will help mitigate many of the congestion related
crashes. The proposed median from School House Road to Mountain Road will reduce
left -turn, angle, and head-on crashes at mid -block locations.
Bridge No. 121 on NC 191 over the French Broad River overflow was built in 1965 and
has a sufficiency rating of 6 out of a possible 100 for a new structure. The bridge is
considered structurally deficient due to a superstructure condition appraisal of 3 out of
9 according to Federal Highway Administration (FHWA) standards. The superstructure
has steel corrosion on multiple beams and spalling on the bent caps.

C. Categorical Exclusion Action Classification: Type III
D. Proposed Improvements:
The proposed project includes a five -lane section through Mills River from NC 280 (Boylston
Highway) to School House Road (SR 1426) with a multi -use path on the northside. A four -lane
divided facility is proposed from School House Road to Mountain Road (SR 1381) with a multi-
use path from the West Henderson High School driveway to the Historic Moss -Johnson Farm
property. A left -over into the Haywood Knolls subdivision will be provided for westbound traffic.
A 5-foot bike lane is proposed on the southside of NC 191 from NC 280 to School House Road
and on both sides of NC 191 from School House Road to Mountain Road, except at Henderson
High School.
E. Special Project Information:
Roadway
There are two typical sections associated with the proposed widening of NC 191.
• Typical Section 1 is from NC 280 to School House Road: This proposed curb
and gutter section will consist of two 13-foot outside lanes, two 11-foot inside
lanes, one 17-foot 6-inch center turn lane with 10-foot berms for future sidewalks
on south and a 10-foot multi -use path on the north.
• Typical Section 2 is from School House Road to Mountain Road: This proposed
curb and gutter section will consist of a four -lane divided facility with four 11-foot
lanes, one 17-foot 6-inch raised median and 10-foot berms for future sidewalks
on each side as well as a 5-foot bike lane on both sides.
Structures
• Bridge No. 121 on NC 191 over the French Broad River overflow will be replaced
with two parallel 54-inch girder bridges approximately 300-feet long and 39-feet
wide. The bridges will consist of two 11-foot lanes with a 5-foot bike lane and 5-
foot 6-inch sidewalks with bicycle safe railings.
• Bridge No. 129 on NC 191 over the French Broad River will be replaced with two
parallel 54-inch girder bridges approximately 165-feet long and 39-feet wide. The
bridges will consist of two 11-foot lanes with a 5-foot bike lane and 5-foot 6-inch
sidewalks with bicycle safe railings.
• A 400-foot retaining wall will be constructed on the northside of NC 191
approximately 300-feet east of Merriwood Lane.
Design Speed
A 50 mile per hour (MPH) design speed is proposed for the NC 191 widening project. A
posted speed limit of 45 MPH will remain on NC 191 following project construction.
Sidewalks and Bicycle Accommodations
A 10-foot multi -use path will be provided on the north side of NC 191 from NC 280 to
School House Road, and on the north side of NC 191 from West Hendersonville High
School driveway to the Historic Moss -Johnson Farm property.
A 5-foot bike lane is proposed on the southside of NC 191 from NC 280 to School House
Road and on both sides of NC 191 from School House Road to Mountain Road, except
at Henderson High School.
Right -of -Way and Access Control
Additional right-of-way will be required along both sides of NC 191 in order to
accommodate the proposed widening and intersection improvements from NC 280 to
Mountain Road. Approximately 100-feet to 120-feet of right-of-way will be required along
NC 191. Temporary and permanent easements will be required.

Full control of access will be required in the following areas:
• Left turn bulb north east of the Historic Merchant -Goodson House
• Left turn bulb across from Rugby Middle School
Public Involvement
• A local official meeting and an open -house public meeting was held on Thursday,
March 15, 2018 at the Mills River Town Hall in Mills River to share the preliminary
designs for STIP R-2588B. Property owners in the area were notified of the
meeting via postcard announcements and the local paper. Approximately 300
people attended the public meeting. Over 250 comments were received from the
community. Approximately 19% of the comments received requested a left -turn
lane at Haywood Knolls Subdivision, 18% were opposed to the project, and 10%
were concerned about noise and air quality.
Results: Meeting scheduled with the Town of Mills River for April 24 to
review and discuss public meeting comments received.
• A small group meeting was held on Tuesday, April 24, 2018 with representatives
from the Town of Mills River, City of Hendersonville, and the Henderson County
Agricultural Advisory Committee to discuss the designs presented at the public
meeting.
Results: NCDOT agreed to evaluate the proposed design through Mills
River and present findings to the Mills River Town Council on May 15,
2018. The Town requested a multi -use path from NC 280 to Town Center
Drive. The Town requested the removal of the median through Town to
avoid negative impacts to businesses and to not hinder the
access/movement of large farm equipment.
• A meeting was held with the Mills River Town Council on Tuesday, May 15, 2018
to discuss a 4-lane median divided section versus a 5-lane section through Mills
River Town Limits (NC 280 to School House Road).
Results: NCDOT agreed to evaluate a 5-lane section in Mills River.
NCDOT agreed to evaluate an intersection at the entrance to Mills River
Park.
• A meeting was held with Henderson County Officials on Tuesday, June 5, 2018
to discuss the proposed location and costs associated with the multi -use path.
Results: NCDOT will construct a concrete multi -use path on the northside
of NC 191 from West Henderson High School to the Historic Moss -
Johnson Farm. A turn lane will be provided as part of this project on
Mountain Road into the commercial center to alleviate the concern of
turning vehicles backing up traffic to the NC 191 signal. NCDOT agreed
to the extension of sidewalks from West Henderson High School and
Rugby Middle School to the school parking lots.
• A meeting was held with the Mills River Town Council on Thursday, June 14,
2018 to review the proposed 5-lane design on NC 191 from NC 280 to School
House Road.
Results: The Town of Mills River voted and approved the construction of
a 5-lane facility through Town and a multi -use path on the northside of NC
191 from NC 280 to School House Road. An intersection at Mills River
Park is not required with a 5-lane section. There were no objections from
the public regarding proposed impacts at the Mills River Park entrance.
• A small group meeting was held with the Haywood Knoll's Home Owners
Association Board on Thursday, July 12, 2018 to review and discuss the
proposed NC 191 improvements at SR 2044 (Haywood Knolls Drive) and access
to NC 191.
Results: The design will be revised to include a left -over from NC 191
westbound and a right-in/right-out from NC 191 eastbound.
Cost Estimates
The total project cost is estimated to be $58,000,000 with $4,500,000 for Right -of -Way,
$10,000,000 for Utilities and $43,500,000 for Construction.

F. Project Impact Criteria Checklists:
Type III Actions
Yes
No
If the proposed improvement is identified as a Type III Class of Action answer all questions.
• The Categorical Exclusion will require FHWA approval.
• If any questions are marked "yes" then additional information will be required for those question in
Section G.
1
Does the project involve potential effects on species listed with the USFWS or
❑
NMFS?
2
Does the project result in impacts subject to the conditions of the BGPA?
❑
❑x
3
Does the project generate substantial controversy or public opposition, for any
❑
reason, following appropriate ublic involvement?
Type III Actions (continued)
Yes
No
4
Does the project cause disproportionately high and adverse impacts relative to
❑
low-income and/or minority populations?
5
Does the project involve substantial residential or commercial displacements
❑
or right of way acquisition?
6
Does the project include a determination under Section 4(f)?
❑X
❑
7
Is a project -level analysis for direct, indirect, or cumulative effects required
❑
based on the NCDOT community studies screening tool?
8
Is a project level air quality Mobile Source Air Toxics (MSAT) analysis
❑
required?
9
Does the project impact anadromous fish?
❑
0
Does the project impact waters classified as ORW, HQW, Water Supply
10
Watershed Critical Areas, 303(d)-listed impaired water bodies, buffer rules, or
❑
0
SAV?
11
Does the project impact waters of the United States in any of the designated
❑
mountain trout streams?
12
Does the project require a USACE Individual Section 404 Permit?
❑
0
13
Will the project require an easement from a FERC licensed facility?
❑
0
Does the project include Section 106 of the NHPA effects determination other
14
than a no effect, including archaeological remains? Are there project
❑x
❑
commitments identified?
15
Does the project involve hazardous materials and landfills?
0
❑
Does the project require work encroaching and adversely effecting a
16
regulatory floodway or work affecting the base floodplain (100-year flood)
❑
elevations of a water course or lake, pursuant to Executive Order 11988 and
23 CFR 650 subpart A?
17
Is the project in a CAMA county and substantially affects the coastal zone
❑
and/or any AEC?
18
Does the project require a USCG permit?
❑
❑x
19
Does the project involve construction activities in, across, or adjacent to a
❑
designated Wild and Scenic River present within the project area?

20
Does the project involve CBRA resources?
❑
❑X
21
Does the project impact federal lands (e.g. USFS, USFWS, etc.) or Tribal
❑
Lands?
22
Does the project involve any changes in access control?
❑X
❑
23
Does the project have a permanent adverse effect on local traffic patterns or
❑
community cohesiveness?
24
Will maintenance of traffic cause substantial disruption?
❑
Q
Type III Actions (continued)
Yes
No
25
Is the project inconsistent with the STIP or the MPO's TIP (where applicable)?
❑
0
Does the project require the acquisition of lands under the protection of
Section 6(f) of the Land and Water Conservation Act, the Federal Aid in Fish
26
Restoration Act, the Federal Aid in Wildlife Restoration Act, TVA, Tribal Lands,
❑
or other unique areas or special lands that were acquired in fee or easement
with public -use money and have deed restrictions or covenants on the
property?
27
Does the project involve FEMA buyout properties under the HMGP?
❑
0
28
Is the project considered a Type I under the NCDOT's Noise Policy?
❑x
❑
29
Is there prime or important farmland soil impacted by this project as defined by
❑
the FPPA?
30
Are there other issues that arose during the project development process that
❑
effected the project decision?
G. Additional Documentation as Required from Section F
Question 1: Potential Effects on Listed Species
Appalachian Elktoe — A mussel survey conducted in the Mills River around SR 1353 in
September 2017 documented no Appalachian Elktoe. A mussel survey conducted in the
French Broad River below NC 191 in August 2017 did detect an Appalachian Elktoe. The
North Carolina Natural Heritage Program records indicates that there is an element
occurrence for the Appalachian Elktoe within the 5-mile buffer of the NC 191 crossing at
Brandy Branch along the Mills River. Based on the above, a biological conclusion of May
Affect, Likely to Adversely Affect was rendered for this species.
Gray Bat (MYGR) — The closest known occurrence of MYGR is approximately 11 miles
northwest of the project site. Based on the lack of evidence of bats using the bridges on
the project, this project will have a biological conclusion of No Effect for MYGR.
Northern long-eared Bat (NLEB) - The nearest NLEB hibernacula record is 14 miles
northeast of the project and no known NLEB roost trees occur within 150 feet of the project
area. NCDOT has determined that the proposed action does not require separate
consultation on the grounds is consistent with the final Section 4(d) Rule.
Question 6: Section 4(f) Determination & Question 14: Section 106 Effects Determination
Merchant -Goodson House was determined eligible for listing in the National Register of
Historic Places in 2000. An assessment of effects in December 2017 determined that STI P

No. R-2588B would have No Adverse Effect on the property with the minimization
alternative and no placement of sidewalks or multi -use paths.
Moss -Johnson Farm — An assessment of effects in April 2018 determined that STIP No.
R-2588B would have No Adverse Effect on this National Register listed property with the
condition of landscaping.
Allen -Johnson House was determined eligible for listing in the National Register of Historic
Places in 2000. An assessment of effects in April 2018 determined that STIP No. R-2588B
would have No Effect on this property.
Mills River Park, a Section 4(f) resource, is located on the northside of NC 191 across
from Van Wingerden International and the River Oak Subdivision. The proposed project
will acquire approximately 0.28 acres for right-of-way and 0.17 acres for permanent
construction easement. Improvements to Mills River Park include a 10-foot multi -use path
on the north side of NC 191 from NC 280 to School House Road and improvements with
full access to the Park's entrance. The Town of Mills River concurs that proposed
improvements to NC 191 will not adversely affect the activities, features, or attributes that
qualify Mills River Park for protection under Section 4(f).
The proposed improvements at Mills River Park were discussed at the Mills River Town
Council Meetings on May 14 and June 14, 2018. The Council meetings are open to the
public. Residents in attendance supported the construction of a multi -use path providing
direct access to Mills River Park and did not voice concerns regarding proposed impacts.
Concurrence on the above was obtained from the Town of Mills River and are considered
as a basis for a "de minimis" finding pursuant to Section 4(f). By FHWA signature of the
CE, the FHWA has made a de minimis finding regarding impacts to the Mills River Park.
Question 8: Air Quality
The purpose of this project is to accommodate future travel demand on NC 191 by
widening the corridor from two -lanes to a multi -lane facility. This project has been
determined to generate minimal air quality impacts for Clean Air Act criteria pollutants and
has not been linked with any special mobile source air toxic (MSAT) concerns. As such,
this project will not result in changes in traffic volumes, vehicle mix, basic project location,
or any other factor that would cause a meaningful increase in MSAT impacts of the project
from that of the no -build alternative.
Question 15: Hazardous Materials
A hazardous materials evaluation prepared in March 2018 identified seven UST facilities
within the project area. These seven sites are anticipated to present low geoenvironmental
impacts to the project. No landfills were identified within the project study area.
Question 16: Floodplains
Henderson County is a participant in the National Flood Insurance Program, administered
by the Federal Emergency Management Agency. Portions of the project cross the French
Broad River. Based on the most current information available from the NC Floodplain
Mapping Program, this river crossing is in a designated flood hazard zone which is within
a detailed flood study reach, having a regulated floodway.
Question 22: Access Control
STIP No. R-2588B is proposed as a five -lane facility from NC 280 to SR 1426 (School
House Road). The center lane will be a designated two-way left turn lane.
STIP No. R-2588B is proposed as a four -lane median divided facility from School House
Road to Mountain Road. The proposed 17.5-foot wide median restricts the number of left -
turns that can be made from side -streets. Driveways in this section will be converted to
right -in, right -out only access. Due to left -turn restrictions, median openings with exclusive
left -turn lanes will accommodate vehicles wishing to make U-turns in the study area.

Median openings will be located:
• Just west of the French Broad River bridges
• SR 1310 (Grandview Lane) west of Rugby Road
• SR 2044 (Haywood Knolls Road) — NC 191 westbound left -over
• SR 1380 (Bradley Road) — NC 191 eastbound left -over
• SR 1980 (Cimarron Boulevard)
The following locations along NC 191 will be signalized:
• NC 280 - existing
• SR 1331 (Banner Farm Road) — proposed
• SR 1426 (School House Road) — existing
• SR 1309 (Rugby Road) - existing
• Alpine Drive/West Henderson High School entrance - existing
• Rugby Middle School entrance — existing
• SR 1381 (Mountain Road)/SR 1444 (Leverette Drive) — existing
Question 28: Traffic Noise
No receptors will be impacted due to a substantial noise increase over existing conditions.
In accordance with the 2016 NCDOT Traffic Noise Manual, at least two impacted
receptors must achieve a noise reduction for 5dB(A) for a noise wall to be considered
feasible. Because all impacts in the project area are isolated, any proposed noise walls
would not be able to meet feasibility criteria. Therefore, noise abatement measures were
not considered for the NC 191 widening project. Additional noise analyses will not be
necessary unless modifications or additions to proposed alternatives occur or changes to
traffic volumes are predicted. Therefore, installation of traffic noise abatement measures
are considered unlikely for this project.
Question 29: Farmlands
Farmland soils eligible for protection under the Farmland Protection Policy Act (FPPA) are
present within the project footprint. A screening of farmland in the project area was
completed per Part VI of the NRCS CPA-106 Farmland Conversion Impact Rating Form.
A total score of 40 points out of 160 was calculated for the project study area. Because
the total site assessment score does not exceed the 60-point threshold designated by
NRCS, substantial project impacts to eligible soils are not anticipated.
There are numerous properties used for agricultural purposes within the study area. Nine
farms within the study area participate in the Henderson County Voluntary Agricultural
District/Enhanced Voluntary Agricultural District (VAD/EVAD) Program. Seven of the
farms are in the Mills River District and two of the farms are in the French Broad District.
Four VAD/EVAD properties are impacted by right-of-way acquisition. Lands within the
VADs/EVADs may be converted to non-agricultural use as part of a construction
easement. Approximately 0.15 acres of VAD/EVAD will be used for a construction
easement and 3.01 acres will be acquired for permanent right-of-way. All affected
VAD/EVAD participants will be contacted individually by a NCDOT Right -of -Way Agent.
NCDOT will work with each property owner to reach an amicable agreement and acquire
the needed property through negotiated settlements. In the event of condemnation,
Henderson County Farmland Preservation Code, Chapter 45-51 Condemnation of
Qualifying Farmland must be followed.

H. Project Commitments
NC 191 (Haywood Road) Widening
From NC 280 (Boylston Highway) to SR 1381 (Mountain Road)
Henderson County
WBS No. 34473.1.3
Federal Aid Project No. STP-0191(14)
STIP No. R-2588B
NCDOT Hydraulics Design Unit — FEMA Coordination
The Hydraulics Unit will coordinate with the NC Floodplain Mapping Program (FMP) to
determine status of project with regard to applicability of NCDOT's Memorandum of
Agreement, or approval of a Conditional Letter of Map Revision (CLOMR) and
subsequent final Letter of Map Revision (LOMR).
This project involves construction activities on or adjacent to FEMA-regulated stream(s).
Therefore, the Division shall submit sealed as -built construction plans to the Hydraulics
Unit upon completion of project construction, certifying that the drainage structure(s) and
roadway embankment that are located within the 100-year floodplain were built as shown
in the construction plans, both horizontally and vertically.
NCDOT Right of Way Branch — Voluntary Agricultural District (VAD)
This project is located within a VAD. If any property holders refuse settlement, before
pursuing condemnation, the Right of Way Branch must contact the Environmental
Analysis Unit's Public Involvement Group in order to pursue a public meeting with the
VAD. This does not mean that the Department cannot condemn but is a procedural
requirement prior to condemnation. In the event of condemnation, Henderson County
Farmland Preservation Code, Chapter 45-51 Condemnation of Qualifying Farmland must
be followed.
Division Construction and Environmental Analysis Unit —Appalachian Elktoe
Section 7 compliance will be satisfied with formal consultation in advance of construction
authorization.
Division Construction and Environmental Analysis Unit — Gray Bat
Surveys for the gray bat will be conducted during the survey window prior to construction
Division Construction and Environmental Analysis Unit — Northern long-eared bat
(NLEB)
This project is compliant with the final Section 4(d) Rule.
Division Construction — Merchant -Goodson House
No sidewalks or multi -use path will be constructed on the property.
Division Construction — Moss -Johnson Farm
Affected property must be re -landscaped after construction.
Division Construction and Right -of -Way Unit — Mills River Park
The appraised value of the park's entrance sign and landscaping will be remitted to the
Town of Mills River for replacement or the Town may have `in -kind' replacement as part
of project construction. The Town of Mills River will provide their preference prior to
December 31, 2018.
NCDOT will evaluate locations along NC 191 that may provide a visual buffer to the park.
STIP No. R-2588B Greensheet
Type III CE August 2018

Docusign Envelope ID: 9B009E6C-0130-493D-9800-8982F92ACSB8
I. Categorical Exclusion Approval
STIP Project No. R-2588B
WBS Element 34473.1.3
Federal Project No. STP-0191(14
Prepared By:
Docuftned by:
8/22/2018 12 : 34: 14; -e4T6-
Date Stacy B. O erhausen, PE, CPM
TGS Engineers
Prepared For: North Carolina Department of Transportation
Reviewed By:
❑occu-One
Siged by;
8/22/2018 4:09:0r FXkiukr, f 11
Date J. Scott Miller, III
Division Design Construction Engineer
NCDOT, Division of Highways, Division 14
Approved • If Type I (Non -Ground Disturbing) Categorical Exclusion
with an answer of "no" to question 3.
• If Type I or Type II (Ground Disturbing) Categorical
Exclusions with an answer of "no" to all of the threshold
questions (1 through 7) of Section F.
dCertified • If Type I (Non -Ground Disturbing) Categorical Exclusion
with an answer of "yes" to question 3.
• If Type I or Type II (Ground Disturbing) Categorical
Exclusions with an answer of "yes" to any of the
threshold questions (1 through 7) of Section F.
• If classified as Type III Categorical Exclusion.
ll,,'O��ocuSigned by:
8/23/2018 10:12:14° ,t&,
Date Wanda H. Austin, PE, CPM
Project Development Engineer
NCDOT, Division of Highways, Division 14
FHWA Approved: For Projects Certified by NCDOT (above), FHWA signature
required.
G :.23 "4U
Date d�m
Jonn r. Suiiivan, Ilr, i- tz, Division Administrator
Federal Highway Administration

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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
Roy COOPER
GOVERNOR
Jeff Wells
Town Manager
Town of Mills River
124 Town Center Dr.,
Mills River, NC 28759
Re: R-2588B NC 191 Improvement Project
Dear Mr. Wells
JAmEs H. TRomom III
SECRETARY
June 26, 2018
The purpose of this letter is to request your concurrence as the official with jurisdiction
over Mills River Park, that the impacts from the proposed project will not negatively affect
the activities, features, or attributes of Mills River Park.
Mills River Park is a public park and recreation facility under the Town of Mills River's
jurisdiction within the study area of R-258813. For federally -funded projects such as
R-258813, public parks and recreation facilities are afforded special protection under
Section 4(f) of the USDOT Act (recodified in 49 U.S.C. § 303 and 23 U.S.C. § 138), and
Section 6009(a) of SAFETEA-LU (23 CFR 774). Provisions in SAFETEA-LU allow that
if a proposed transportation project is determined to not "adversely affect the activities,
features, and attributes" of the resource protected under Section 4(f), then a de minimis
finding can be made by FHWA to satisfy the requirements of Section 4(f).
The project's effect on this resource are based on preliminary engineering design provided
by NCDOT.
The preliminary design would require approximately 0.28 acres of right-of-way and 0.17
acres of temporary construction easement.
The proposed improvements include:
• Improvements at the intersection at Town Center Drive and NC 191
• Installation of a 10-foot multi -use path adjacent to NC 191
Mailing Address: Telephone: [phone] Location:
NC DEPARTMENT OF TRANSPORTATION Fax: [phone] WEBSTER ROAD
DIVISION 14 Customer Service: 1-877-368-4968 SYLVA, NC 28779
253 WEBSTER ROAD COURIER #08-23-15
SYLVA, NC 28779
Website: www.ncdot.gov

NCDOT will also appraise value of the existing park entrance signage & landscaping and
remit the appraised value to the Town toward funding the replacement signage and
landscaping at the entrance to the park. OR, the Town may choose to have the sign replaced
"in kind" as part of the construction contract. The Town of Mills River should provide a
decision on the marquis reimbursement OR replacement prior to December 31, 2018.
NCDOT will also investigate vegetation at key locations along the project to act as a visual
buffer.
The NC Department of Transportation (NCDOT) has coordinated with the Town of Mills
River regarding effects of Project R-2588B (NC 191 Improvements) on public recreation
facility under the jurisdiction of the Town.
After evaluating the project's preliminary design, the Town of Mills River finds the
impacts from the proposed project will not adversely affect the activities, features, or
attributes of Mills River Park. The Town would concur with the a FWHA finding of de
minimis use relative to this property.
As the official with jurisdiction over Mills River Park, located at 124 Town Center Dr.,
Mills River, NC, I concur with the determination that R-2588B proposed improvements to
NC 191 would not adversely affect the activities, features, or attributes that qualify Mills
River Park for protection under Section 4(f). I have also been informed that, based upon
my concurrence, the FHWA intends to make a de minimis finding regarding impacts to
Mills River Park, thus satisfying the requirements under Section 4(f).
DocuSigned by:
Sign,�tl�
BDOAFI EA4D3042A...
6/29/2018 Date:
After signing and dating this letter, please return a copy to my attention within 30 days of
the date of this letter to the following address:
J. Scott Miller, III
Division Design Construction Engineer
Division of Highways -Division 14
North Carolina Department of Transportation
253 Webster Road
Sylva, NC 28779-9621
The NCDOT is thankful for your assistance in making this transportation project possible.
Should you have any questions or concerns, please contact me at 828-586-2141 or
jsmiller3gncdot. og_v
Sincerely,
J. Scott Miller, III

Project Tracking No.
17-03-0004
NO NATIONAL REGISTER OF HISTORIC PLACES
a: ELIGIBLE OR LISTED ARCHAEOLOGICAL SITES
4.
,I
". '' ` AFFECTED FORM s=
w.�p._.
:' .?= ;
This form only pertains to ARCHAEOLOGICAL RESOURCES for this project. It is not
. ;..:
valid for Historic Architecture and Landscapes. You must consult separately with the
Historic Architecture and Landscapes Group.
PROJECT INFORMATION
Project No: R-2588B
WBS No: 344731.1.3
F.A. No: STP-019(14)
Federal Permit Required?
PROJECT DESCRIPTION:
County: Henderson
Document: EA & FONSI
Funding: ❑ State ® Federal
® Yes ❑ No Permit Type: NWP
NCDOT's Division 14 is proposing to widen NC 191 (Haywood Road) from SR 1381 (Mountain Road)
to NC 280 (Boylston Highway) in Henderson County. Currently, NC 191 is a two-lane facility with
shoulders and will be upgraded to a four -lane divided section with curb -and -gutter. Project length
measures about 4.40 miles. Existing ROW along NC 191 measures 100 feet; proposed ROW will vary
between 110 feet and 120 feet wide. Since the alignment of the route has not been determined, a Study
Area measuring about 300 feet wide (150 feet to either side of centerline) and encompassing about 159
acres, inclusive of all existing roadways and development, has been generated to facilitate planning
purposes.
SUMMARY OF ARCHAEOLOGICAL FINDINGS
As previously mentioned in the Survey Required Form, "this project was accepted for review on
Wednesday, March 8, 2017. A map review and site file search was conducted at the Office of State
Archaeology (OSA) on Friday, March 10, 2017. A large-scale archaeological survey for the widening of
NC 191 has already taken place (see TIP# R-2588 [Seibel et al. 2002]). Eighteen (18) archaeological
resources have been recorded along the Study Area corridor as depicted now, of which three (3)
(31HN2/2**, 31HN164**, and 31HN165/165**) have been recommended as eligible for the National
Register of Historic Places (NRHP) and one (1) consists of a cemetery recommended for avoidance, if
possible. Digital copies of HPO's maps (Skyland and Horseshoe Quadrangles) as well as the HPOWEB
GIS Service (http://gis.ncdcr.gov/hpoweb/) were last reviewed on Friday, March 10, 2017. There are
numerous known historic architectural resources located within or adjacent to the overall Study Area;
however, because of the previous archaeological investigations along the corridor, intact archaeological
deposits associated with these historic architectural resources are not anticipated within the potential
footprint of the proposed project. In addition, topographic maps, historic maps (NCMaps website),
USDA soil survey maps, and aerial photographs were utilized and inspected to gauge environmental
factors that may have contributed to historic or prehistoric settlement within the project limits, and to
assess the level of modern, slope, agricultural, hydrological, and other erosive -type disturbances within
and surrounding the archaeological APE.
Federal funds will be utilized for this project, which will also require a Federal permit. Newly acquired
ROW will also be necessary. The overall dimensions of the Study Area will capture any areas to be
impacted beyond what is already owned and maintained by the NCDOT. Based on the description of the
project and the size of the Study Area, activities will take place beyond the NCDOT's existing ROW.
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From an environmental perspective, land use within the Study Area can be classified as a mixture of
agriculture, commercial, and suburban residential. Various soil types are present throughout the Study
Area. In the areas of the three (3) NRHP-eligible archaeological resources, only three (3) soils types are
present: Bradson gravelly loam, 2-7% slopes (BaB) in the area of Site 31HN165/165**, Comus (colvard)
fine sandy loam (Cu) in the area of Site 31HN164**, and Comus (colvard) fine sandy loam (Cu) and
Codorus loam (arkaqua) (Co) in the area of Site 31HN2/2**. As the previous archaeological survey
report has shown, intact archaeological materials have been recovered within these soil type areas.
Since there are NRHP- eligible archaeological resources (Sites 31HN2/2**, 31HN164**, and
31HN165/165**) located within the project's Study Area that will require our attention, compliance with
Section 106 of the National Historic Preservation Act (NHPA, as amended) and Section 4(f) of the
Department of Transportation Act (DOT Act, as amended) is necessary. For the purposes of compliance,
the NC-HPO concurred in a memo dated 23 May 2005 that the following properties were eligible for
listing in the NRHP under the criterion cited:
31HN2/2** - Criterion D — This is an extensive Middle Archaic through Early Woodland Period
habitation site with intact subsurface cultural deposits.
31HN164** - Criterion A — This is the old route of Haywood Road, consisting of the abandoned
19th and early 20th century abutments for King's Bridge, and a portion of the road dating from the
late 18th through mid-20th centuries.
31HN165/165** - Criterion D — This is an early 19th through mid-20th century domestic
archaeological sites including a stone foundation, preserved cellar, and intact cultural deposits.
Based on the information provided, an archaeological survey is, therefore, recommended for the proposed
project. Even though such a survey has already been completed, the known presence of NRHP-eligible
archaeological resources within the Study Area necessitates such a call so that the next phase of review
work can proceed accordingly. In addition, a reconnaissance of the Study Area may be needed to verify
current field conditions at the three (3) sites in question. None of the property on which these three (3)
sites are situated is owned by the State of North Carolina; therefore, a State Archaeological Resources
Protection Act (ARPA) permit should not be necessary. Should the description of this project change or
design plans be made available prior to construction, additional consultation regarding archaeology will
be required."
BRIEF DESCRIPTION OF REVIEW ACTIVTI'IES, RESULTS OF REVIEW, AND CONCLUSIONS:
Since the archaeological survey for this project occurred in 2002, the Management Summary for that
report will be presented here (Seibel et al. 2002:1-vi).
"Environmental Services, Inc., (ESI) conducted an intensive archaeological survey of the preferred
corridor for the proposed widening of NC 191 (Haywood Road) and proposed widening of Stoney
Mountain Road in Henderson County, North Carolina, during March to May 2002 (T.LP. R-2588; State
Project No. 8.19501301; Federal Aid No. STPNHF-191(2)). This work was requested by the North
Carolina Department of Transportation (NCDOT) to comply with Section 106 of the National Historic
Preservation Act (NHPA; 1966, as amended), with funding by the Federal Highway Administration
(FHWA) and NCDOT. All fieldwork was designed to comply with guidelines established by the Office
of the Secretary of the Interior of the United States and followed the specifications of a Scope of Work
supplied by NCDOT in consultation with the North Carolina Office of State Archaeology (OSA). The
Environmental Review number for this project as assigned by the North Carolina State Historic
Preservation Office (SHPO) is ER 99-7801.
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The NC 191 project corridor runs from SR 1411 (Kensington Road) in Hendersonville west for
approximately 7.5 miles (12 kilometers) to NC 280 in Mills River. The Stoney Mountain Road project
corridor runs for approximately 2.5 miles (4 kilometers) from US 25 in the east to NC 191 in the west.
Each corridor is 200 feet wide (66 meters), with 100 feet (33 meters) on either side of the existing
centerline of each road. The total area encompassed by the project, including the existing right-of-way, is
approximately 240 acres.
Field survey methods employed during the investigation consisted of a variety of activities, including
pedestrian inspection, shovel testing, the excavation of test units, and mapping of architectural features
using Global Positioning System (GPS) technology. Pedestrian inspection focused on areas with good
surface visibility including agricultural fields, dirt roads, and tree falls. Vegetated areas were also
inspected in an attempt to locate architectural features and abandoned cemeteries. Shovel tests were
excavated at 30 meter intervals for site discovery. No shovel tests were excavated in wetlands or on
slopes greater than 15 percent; urban disturbed areas were also not shovel tested. When artifacts were
recovered, supplemental shovel tests were dug at 15 meter intervals to delineate site boundaries and
determine the nature of subsurface deposits. Excavation units were dug at selected sites to evaluate their
eligibility for listing in the National Register of Historic Places (National Register). GPS technology was
used in the mapping of large architectural features. Field investigations took place from March to May,
2002, and were conducted by Scott Seibel, who served as project archaeologist, Giampaolo Di Gregoreo,
Sharon Penton, Corinne Lisefski, and A.J. Steffan. Greg C. Smith was Principal Investigator.
Table A: Summary of Survey Data
Site Number
Components
Site Type
Recommendations
31HN2/2**
Middle Archaic, Early
Woodland/Twentieth
Century
Habitation/Historic
Scatter
NRHP Eligible
31HN162
Lithic Prehistoric
Prehistoric Scatter
Not Eligible
31HN163**
Unknown Historic
Historic Scatter
Not Eligible
31HN164**
Late eighteenth century
to 1954
Road, bridge abutments
NRHP Eligible
31HN165/165**
Woodland/Nineteenth to
twentieth centuries
Isolate/Domestic
NRHP Eligible
31HN166
Lithic Prehistoric
Prehistoric Scatter
Not Eligible
31HN167
Lithic Prehistoric
Prehistoric Isolate
Not Eligible
31HN168**
Early to mid -twentieth
century
Dam
Not Eligible
31HN169**
Unknown Historic
Road
Not Eligible
31HN17O**
Twentieth Century
Domestic
Not Eligible
31HN171**
Nineteenth Century
Mill Dam
Not Eligible
31HN172**
Twentieth Century
Domestic
Not Eligible
31HN173**
Nineteenth to twentieth
centuries
Agricultural
Not Eligible
31HN174**
Nineteenth to twentieth
centuries
Domestic
Not Eligible
31HN175**
Nineteenth to twentieth
centuries
Road
Not Eligible
31HN176**
Nineteenth to twentieth
centuries
Domestic/Agricultural
Not Eligible
31HN177**
Nineteenth to twentieth
centuries
Domestic
Not Eligible
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31HN178**
Unknown Historic
Road
Not Eligible
31HN179**
Nineteenth to twentieth
Road
Not Eligible
centuries
31HN180/180**
Lithic
Prehistoric
Not Eligible
Prehistoric/Twentieth
Scatter/Agricultural
Century
31HN181**
Nineteenth to twentieth
Domestic
Not Eligible
centuries
31HN182**
Early nineteenth century
Cemetery
Avoidance
— Present
31HN2/2**
This site was originally recorded in the 1960s by Joffre Coe. Based on a surface scatter of prehistoric
artifacts (15 flakes and 5 sherds), he plotted the site as a large ovoid measuring 250 meters
northwest/southeast by 150 meters northeast/southwest.
The revisit of the site by ESI included a pedestrian inspection, shovel testing, and test units to investigate
subsurface cultural deposits. Pedestrian inspection revealed that the site is more extensive than recorded
by Coe. The surface scatter of artifacts was identified on both sides of NC 191 and is confined to a wide
sandy remnant levee of the French Broad River. The maximum spatial dimensions are now
approximately 250 meters northwest/southeast and 400 meters northeast/southwest. Among the artifacts
collected from the surface were lithic debitage (quartz, rhyolite, and chert), lithic tools, and ceramic
sherds. Fire cracked rock was also observed on the surface, but was not collected.
Shovel testing at 30 and 15 meter intervals resulted in 20 positive shovel tests. Of the 20 positive shovel
tests, 11 yielded artifacts from below the plow zone. Among the artifacts recovered from within the plow
zone in shovel tests were a Gypsy Stemmed projectile point, a Small Guilford projectile point, two
ceramic sherds, groundstone and pecked stone fragments, fire cracked rock, and variety of quartz, chert,
and rhyolite flakes. Artifacts recovered from below the plow zone in shovel tests include 2 ceramic
sherds, groundstone fragments, fire cracked rock, and a variety of lithic debitage. Shovel testing was not
performed more than 60 meters outside the corridor due to the large size of the site.
Two 1 meter by 2 meter test units were excavated within the first concentration of 8 shovel tests yielding
sub -plow zone artifacts located adjacent to the project corridor. The plow zone of Test Unit 1, which was
approximately 30 centimeters thick, yielded the most artifacts. Among the artifacts recovered from the
plow zone were 130 burned and fire cracked rocks, including groundstone and pecked stone, one Gypsy
Stemmed projectile point, half of a steatite pipe bowl, a fragment of a metavolcanic bowl, and over 100
pieces of lithic debitage. Level 2 (29 to 39 centimeters below datum) yielded 32 lithic flakes, 2 fire
cracked rocks, and charcoal, while Level 3 (39 to 49 centimeters below datum) produced 10 flakes, 1
small ceramic sherd, and one fire cracked rock. Levels 4-7 (49-90 centimeters below datum) each yielded
between 6 and 7 lithic flakes. The unit was terminated at 90 centimeters below datum due to the
encroachment of the water table.
Test Unit 2 was much less productive than Test Unit 1. Twelve burned and fire cracked rocks, 1 chert
biface fragment, 1 groundstone fragment, 25 flakes, and 2 modern artifacts were recovered from the plow
zone. Levels 2-5 (26-76 centimeters below datum) each yielded 2 to 4 flakes. No artifacts were
recovered below 76 centimeters below datum.
This site is considered eligible for the National Register under Criterion D — Information Potential, which
applies to properties that contain or are likely to contain information bearing on an important research
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question. Although subsurface testing of the study corridor focused only on a small portion of this
extensive site, it did reveal the presence of sub -plow zone cultural deposits and the potential for sub -plow
zone features, based on the large number of fire cracked rocks and the recovery of fire cracked rock
below the plow zone. Research contexts identified by both Mathis (1979:13-24) and Wetmore (1993:22-
23) that are applicable to this site include settlement patterning and site function, specifically in terms of
landform use and activities. General issues that can be addressed include dating periods of site use and
the identification of activity areas. Avoidance of intact cultural deposits by construction activities is
recommended. This should be achievable as only a very small portion of the intact deposits is located
within the extreme northern edge of the corridor.
31HN164** - Old Haywood Road
Pedestrian inspection within and adjacent to the project corridor revealed an asphalt paved section of the
old route of Haywood Road and two sets of bridge abutments related to the crossing of Haywood Road
over the French Broad River known as King's Bridge.
The preserved old route of Haywood Road runs from concrete bridge abutments on the east bank of the
French Broad River south and east for approximately 800 meters (2600 feet) to SR 1310 (Grandview
Lane). The road, which is 5 meters (16 feet) wide, retains its ca. 1950 asphalt pavement and crosses an
intact concrete bridge over a flood channel of the French Broad River. The asphalt paving is in good
condition, with a minimal number of potholes. The road is sometimes used by adjacent landowners for
moving farm equipment and is also used recreationally by members of the surrounding community for
walking.
The first set of bridge abutments is made of formal concrete reinforced with steel rebar. They are aligned
with the pavement of Old Haywood Road and appear to have been constructed between 1916 and 1921.
The abutment on the east bank of the river is relatively intact, while the western abutment has been
mostly destroyed or is covered by fill related to the 1954 rerouting of NC 191. Large piles of concrete
rubble line the east bank of the river and likely represent the destroyed remains of the bridge's span over
the river.
The second set of bridge abutments is of stone and mortar construction. The abutment on the east bank is
directly underneath the current bridge and is nearly intact. The west abutment has been truncated, leaving
only about 1 meter exposed above the ground surface. Interestingly, the stone abutments lie at a different
bearing than the concrete abutments, indicating that Haywood Road may have had a somewhat different
alignment at this location prior to 1921. Although the crossing at King's Bridge has been in use for
approximately 200 years, no mention has been found concerning the construction or destruction of the
bridge associated with the stone abutments.
Numerous maps dating back to 1808 show Haywood Road and the King's Bridge crossing. Haywood
Road and the river crossing are depicted on the Price-Strother Map of North Carolina (1808; the crossing
is shown in the wrong location, as are other major roads and intersections in the area). On the 1833
McRae -Brazier Map of North Carolina, the bridge is denoted as "Free Br." (Free Bridge), indicating that
no toll was collected for its use. Additionally, a post office is also shown on the north side of the road,
just east of the French Broad River. The crossing is also shown on a Union Army field map based on
work by Arnold Guyot (shown as Figure 8-A in Brunk 2001). An engineering map from 1954 for the
then proposed reroute of NC 191 shows the old alignment of Haywood Road and the locations of both the
concrete abutments and the stone abutments.
This site is significant at the local level under Criterion A. Haywood Road and the crossing of the French
Broad River at King's Bridge served as a major transportation route between the Mills River community
and settlements along the west bank of the French Broad River with communities in the east including the
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county seat in Hendersonville. The remains of two bridges at this location indicate a continuity of use for
at least 200 years. This site is also significant at the state level under Criterion A due to the connection
between the old paved route of Haywood Road and the North Carolina Good Roads Movements of the
1910s, which culminated in 1921 with the creation of the State Highway Commission. This portion of
old Haywood Road is an intact example of the road improvement projects initiated by the State Highway
Commission during the early 1920s.
In summary, this site is considered eligible for the National Register at the local and state levels under
Criterion A under the historical context of Transportation. It is associated with events that have made a
significant contribution to broad patterns of local and state history. It is recommended that the proposed
alignment avoid this site. Additionally, the old paved route of Haywood Road should not be used by
construction vehicles and traffic, in order to minimize adverse effects. It is additionally recommended
that a historic marker be erected, commemorating the crossing at King's Bridge and the old route of
Haywood Road. If avoidance of the bridge abutments is not possible, extensive documentation including
documentary research, photography and plan mapping, and limited excavation is recommended. If
avoidance of the old paved route of Haywood Road is not possible, an engineering study should be
conducted to determine if the road can withstand heavy vehicular traffic.
3114N165/165**
A study of a 1951 aerial photograph of the Mills River area indicated the presence of a house adjacent to
the present location of a business (Carolina Roses) along NC 191. Pedestrian inspection of the location
identified a domestic site containing a partially buried stone foundation, a brick pump house, a concrete
capped well, a partially buried steel tank, two large cut stone slabs, and a scatter of historic artifacts at the
edge of an old terrace overlooking the floodplain of the French Broad River. Surface artifacts include
pearlware, whiteware, and yellowware ceramic sherds, milk glass, and amethyst glass.
A total of 19 shovel tests were excavated, all of which yielded artifacts, including plain and decorated
pearlware, whiteware, yellowware, lead and salt glazed stoneware, window and vessel glass, and a large
number of cut nails. Notable artifacts recovered during shovel testing include two glass marbles, a pig
tooth, and small piece of leather. Shovel testing also revealed a cobbled front walkway and a rubble filled
cellar beneath an L-addition at the rear of the house. Probing indicated that the entire foundation of the
house and rear L-addition is intact.
Three test units were excavated at the house: a 1 meter by 2 meter unit over a portion of the foundation, a
1 meter by 1 meter unit at the rear of the house, and a 1 meter by 0.5 meter unit over the front walk. All
three revealed intact cultural deposits beneath a thin layer of demolition debris. Among the artifacts
recovered from these units are historic ceramics (pearlware and whiteware), shell buttons, faunal remains
(one pig tooth and one cut bone), and large numbers of cut nails.
Background research at the Henderson County Courthouse provided information back to 1881, when
Oliver H. Moss owned the property. The current owner is Jennie Lee Jackson Lawing, who received the
property in trust from her deceased husband E.H. in 1993 (Book 957 Page 576). Although clear title
could only be traced to the 1880s, artifacts indicate that the house dates to before the Civil War. More
extensive research, both in Henderson County and in Buncombe County, could better document the
ownership (and perhaps occupancy history) of this house.
This site is considered eligible for the National Register under Criterion D — Information Potential, which
applies to properties that contain or are likely to contain information bearing on an important research
question. Research contexts that apply are Horticulture and Agriculture in North Carolina and Yeoman
Farms. The current investigation has shown that this site, which dates from the early nineteenth to mid -
twentieth centuries, is archaeologically intact and contains personal artifacts and faunal remains in
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addition to a wide variety of ceramics. Avoidance of this site by construction activities is recommended.
If avoidance is not feasible, data recovery is recommended.
31HN182** - Mill Pond Cemetery
This is a large, well -maintained cemetery containing hundreds of interments in single and family plots
dating from the early nineteenth century to the present. While the majority of the markers are inscribed,
the southeast corner contains a large number of flagstone grave markers with no inscriptions and only a
few inscribed stones. It is believed that this portion of the cemetery is the resting place for both slaves
and free blacks, some of whom lived in the county prior to the Civil War. According to George Jones,
head of the Henderson County Genealogical and Historical Society, the cemetery began as a family grave
site in the early nineteenth century, before becoming a community burial ground in 1859.
The cemetery is associated with the French Broad Baptist Church. The first church building looked out
over the river valley somewhere upstream from the confluence with Mill Pond Creek. The land for the
church and the cemetery now known as Mill Pond Cemetery was given to the church by W.D. Miller,
Alec Henry, Benjamin King, Thomas R. Miller, James Spann, and M.B. Lance on September 7, 1859. In
the 1920s, the congregation moved to a larger building closer to King's Bridge on Grandview Lane
(Patton 1947:172).
The cemetery has been officially documented twice during the past century. The first recording occurred
in the 1930s and was conducted by the Works Progress Administration (WPA). According to the WPA
Pre-1914 Graves Index (on file, State Library and Archives), the cemetery included 81 marked and 132
unmarked graves. Although the WPA index states that the earliest burial was interred in 1845, there is a
headstone for Thomas Rhodes that bears a date of 1827. The cemetery was recorded a second time in
1995 in Henderson, North Carolina Cemeteries (on file Henderson County Genealogical and Historical
Society) on pages 186-191. This lists all the graves in the cemetery as of 1995.
The most notable person buried in the cemetery is Daniel King, son of Joseph King and grandson of
Samuel King. Daniel operated a gristmill on Mill Pond Creek (originally King's Mill Creek) during the
nineteenth century. The dam, which was built before 1827 presumably by Samuel King (Buncombe
County Deeds Book 15 Page 52), is located south of the cemetery (Patton 1947:71). The cemetery
derives its name from the pond impounded behind the dam.
The Mill Pond Cemetery does not meet the criteria for eligibility established by the National Register nor
does it qualify under Criteria Consideration D: Cemeteries. As such, it is considered not eligible for the
National Register. However, it is considered to have local significance related to its use as a family and
community burial ground since the early nineteenth century. It is recommended that the cemetery be
avoided by highway construction. Relocation of the cemetery may not be feasible due to its large size
(over 300 burials) and its use as a modern burial ground for the community."
SUMMARY AND RECOMMENDATIONS
The investigation resulted in the recording of 21 archaeological sites and isolated finds (31HN162-182)
and the revisitation of one archaeological site (31HN2). Seventeen of the sites investigated do not exhibit
qualities that would make them eligible for listing in the National Register. Three of the sites
(31HN2/2**, 31HN164**, and 31HN165/165**) however, exhibit qualities that make them eligible for
listing in the National Register. An additional site, 31HN182**, is a cemetery that while not eligible for
the National Register should be avoided by construction activities.
A total of 251 shovel tests were dug during the intensive archaeological survey. The survey focused on
240 acres within the approximately 10 mile long and 200 foot wide project corridor, 202 acres of which
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were excluded from the survey due to poor soil drainage, steep slope, and/or heavy disturbance from
development and the existing roadway.
Of the 30 cultural contexts identified at the 21 sites investigated, 8 were prehistoric and 22 were historic.
Prehistoric sites included 1 Middle Archaic component, 1 Late Archaic component, 1 Early Woodland
component, 1 undetermined Woodland component, and 4 nondiagnostic lithic scatters. Two of the
prehistoric components were isolated finds, three were small lithic scatters, and three components
reflected extensive habitation.
Field investigations encountered prehistoric sites mainly in alluvial settings (first and second terraces,
terrace scarp, levee remnant), though one site was located in an upland setting, adjacent to a small stream.
The prevalence of prehistoric sites in alluvial contexts is not surprising given that the intensive survey
focused on the French Broad River valley. All of the prehistoric sites were found on moderately well to
well drained soils.
The majority of the 22 historic contexts identified from 19 archaeological sites consisted of domestic sites
(n-7) or roads (n=5) dating from the late eighteenth century to the mid -twentieth century. Other historic
components included a nineteenth century bridge, an early twentieth century bridge, three agricultural
sites, an early nineteenth century dam, a twentieth century dam, an early nineteenth century to present
cemetery, and two artifact scatters.
Historic sites were found on a wide variety of both alluvial and upland landforms. All domestic and
agricultural sites and the cemetery were found in upland settings or on high terraces, while transportation
and earthwork/industrial sites (two roads, two bridges, and two dams) were mainly located on lower
terraces, stream banks, and floodplains; two roads were found in upland settings. Historic scatters were
found on a high second terrace, a low first terrace, and on a levee remnant. As with the prehistoric sites
recorded during the investigation, all of the historic sites were found on moderately well to well drained
soils.
This distribution on landform type shows that during the historic period people avoided living and
building farm -related structures in areas subject to flooding, which was a common occurrence along the
French Broad and Mills rivers. Roads and bridges were built in areas with a high risk of flooding when
necessary. By their very design and use, dams are always built along waterways.
Although all of the archaeological sites recorded during the present investigation were found on well
drained and moderately well drained soil types, this distribution is in part a reflection of the soil types
located within the project corridor and the scope of the investigation. Poorly drained and very poorly
drained soils were not well represented within the project corridor, and in one instance such an area had
been drained for the construction of a housing development.
Very little large-scale archaeological survey has been conducted in Henderson County. Based upon a
limited number of surveys, a site density of one archaeological site per 19 acres would have been
expected. However, this number is based on large tract surveys and not on narrow corridor surveys. If
only sites recorded within the project corridor are used, the site density encountered during the present
project was one site per 1.8 acres within the actual area surveyed. If disturbed areas are included, the
density would be one site per 7.6 acres. In the end, not enough surveys have been conducted within
Henderson County to accurately calculate site density within the county.
31HN2/2**
As recommended by Seibel et al. (2002:6.42), "Avoidance of intact cultural deposits by construction
activities is recommended. This should be achievable as only a very small portion of the intact deposits is
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located within the extreme northern edge of the corridor. Should avoidance of intact area of 31HN2/2**
prove unfeasible, data recovery is recommended. Field investigations should include more intensive
shovel testing at 7.5 or 5 meter intervals to better identify sub -plow zone artifact density and to guide the
placement of test units. The clearing of the plow zone by heavy machinery in selected areas would prove
useful in identifying features. Large block excavation within artifact concentrations and in areas
containing features in conjunction with small block excavation in areas of lesser artifact densities is
recommended for determining the spatial layout of the site. A geomorphological investigation would be
useful in conjunction with the archaeological work to better understand the depositional history of the
site. This would include backhoe trenching and study by an experienced geoarchaeologist." However,
based on the current design plans, the sub -plow zone deposits associated with Site 31HN2/2** will not be
impacted by the proposed project. The alignment for the project in this location has been shifted south of
any sub -plow zone deposits. No staging of vehicles and equipment within the limits of Site 31HN2/2**
shall occur.
31HN164** - Old Haywood Road
As recommended by Seibel et al. (2002:6.31), "It is recommended that construction activities avoid this
site. Specifically, the old paved route of Haywood Road should not be used by construction vehicles ... If
avoidance of the bridge abutments is not possible, extensive documentation including detailed
documentary research, photography and plan mapping, and limited excavation is recommended. If
avoidance of the old paved route of Haywood Road is not possible, an engineering study should be
conducted to determine if the road can withstand heavy vehicular traffic." Based on the current design
plans, the old paved route of Haywood Road will not be impacted by or used as part of the proposed
project. The staging of vehicles and equipment along the old paved route will not occur. In addition, the
locations of all four (4) bridge abutments (I set of concrete abutments and I set of stone abutments) have
been noted on the current design plans. All four abutments will be avoided by proposed project, three
of the four abutments do not fall within the Area of Potential Effects (APE) for the project whereas the
fourth abutment (i.e. the eastern stone abutment) will be preserved in place and spanned by the proposed
bridge crossing the French Broad River.
31HN165/165**
As recommended by Seibel et al. (2002:6.23), "Avoidance of this site by construction activities is
recommended. If avoidance is not feasible, data recovery of the historic component is recommended.
Should data recovery become necessary, investigations should be three -fold, focusing on detailed
background research, informant interviews, and field investigations. Background research at such
locations as the Buncombe County and Henderson County courthouses could yield additional data on
such things as the disposition of the property over time and financial transactions, while informant
interviews with long-term residents of the area could yield significant insight into the personal lives of the
former inhabitants of the site. Subsurface investigations should include uncovering of the house
foundation and uncapping of the well. Additional shovel testing or remote sensing should be used to
identify the location(s) of the privy and other outbuildings. Large and small block excavations should
focus on the yard area immediately surrounding the house, the area underneath the house and porch, the
cellar underneath the L-addition, and on the discovery of small features in the yard such as trash pits."
Based on the current design plans, the house foundation, its L-addition/cellar, and the well will not be
impacted by the proposed project despite the need for a construction easement across the south edge of
the site. The alignment for the project in this location has been shifted to the south, thus avoiding most of
the intact features associated with Site 31HN165/165**. The only feature that will be impacted (though
only partially) by the proposed project is the front cobble walkway leading from NC 191 to the front of
the house foundation. A portion of this walkway was exposed in Test Unit 3. Very few artifacts were
found in association with the cobble walkway and the front yard, in general. In addition, the interpreted
spatial layout of the historic site and perceived artifact concentrations would suggest any additional
"NO NATIONAL REGISTER ELIGIBLE OR LISTED ARCHAEOLOGICAL SITES AFFECTED"
form for the Amended Minor Transportation Projects as Qualified in the 2007 Programmatic Agreement.
9of10

Project Tracking No.
17-03-0004
outbuildings_ privies, and/or trash pits would be located somewhere behind (i.e. north) of the main
domestic structure. Therefore, such an impact to the front yard area and walkway should not be
considered an adverse effect. No staging of vehicles and equipment within the limits of Site
31HN165/165** shall occur.
31HN182** - Mill Pond Cemetery
As recommended by Seibel et al. (2002:6.51), "Based on the limited archaeological investigations of this
site, it is considered not eligible for the National Register. However, further archaeological and/or
documentary work may yield information showing significance under both Criteria A and D. If this site
is threatened by construction or other activities in the future, additional archaeological and documentary
investigation is recommended." Regardless of significance, if the Mill Pond Cemetery were to be
impacted, then compliance with applicable State statutes for the removal and reinterment of any affected
graves would be required once discussions with the State Archaeologist have occurred. However, based
on the current design plans, Site 31HN182** (Mill Pond Cemetely) will not be impacted by the proposed
project. No staging of vehicles and equipment within the limits of the cemetery shall occur.
Based on these results, no additional archaeological work is recommended in coniunction with this
groiect. I concur with the recommendations put forth by our consultant. If the groiect expands
and impacts subsurface areas beyond the study area or if design plans chance prior to construction,
further archaeological consultation will be necessary.
The North Carolina Department of Transportation (NCDOT) Archaeology Group reviewed the subject
project and determined. -
There are no National Register listed ARCHAEOLOGICAL SITES within the project's area of
potential effects. (Attach any notes or documents as needed)
❑ No subsurface archaeological investigations were required for this project.
❑ Subsurface investigations did not reveal the presence of any archaeological resources.
❑ Subsurface investigations did not reveal the presence of any archaeological resources considered
eligible for the National Register.
® All identified archaeological sites located within the APE have been considered and all
compliance for archaeological resources with Section 106 of the National Historic Preservation
Act and GS 121-12(a) has been completed for this project.
SUPPORT DOCUMENTATION
SEE ATTACHED: ® MAP(S) ❑ PREVIOUS SURVEY INFO ® PHOTOS ❑CORRESPONDENCE
Signed:
June 8, 2018
NCDOT ARCHAEOL ST Date
"NO NATIONAL REGISTER ELIGIBLE OR LISTED ARCHAEOLOGICAL SITES AFFECTED"
form for the Amended Minor Transportation Projects as Qualified in the 2007 Programmatic Agreement.
10 of 10

Project Tracking No. (Internal Use
17-03-0004
UPDATE
f HISTORIC ARCHICTECTURE AND LANDSCAPES
ASSESSMENT OF EFFECTS FORM
This form only pertains to Historic Architecture and Landscapes for this project. It
is not valid for Archaeological Resources. You must consult separately with the
Archaeology Group.
PROJECT INFORMATION
Project No:
R-2588B
County:
Henderson
WBS No.:
34473.1.3
Document
Type:
EA/FONSI Combined
Fed. Aid No:
STP-0191(14)
Funding:
❑ State ® Federal
Federal
Permits :
® Yes ❑ No
Permit
Type(s):
NWP
Project Description:
Widening of NC 191 from SR 1381 Mountain Road) to NC 280.
SUMMARY OF HISTORIC ARCHICTECTURE AND LANDSCAPES REVIEW
Description of review activities, results, and conclusions:
The Merchant Goodson House (HN0239) and the Moss -Johnson Farm (HN0043) were assessed
for effects on December 13, 2017. It was determined that there is No Adverse Effect on the
Merchant Goodson House, and No Effect on the Moss -Johnson Farm. On March 29, 2018, plans
for the section in front of the Moss -Johnson House were revised, and an updated assessment of
effects is required. It was also determined that an assessment of effects for the Allen -Jamison
House is required.
ASSESSMENT OF EFFECTS
Property Name:
Moss -Johnson Farm
Status:
National Register listed
Survey Site No.:
HN0043
PIN:
Effects
❑ No Effect
No Adverse Effect ❑ Adverse Effect
Explanation of Effects
Determination:
List of Environmental Commitments: _f' I �1' dsn�Ca t�
Historic Architecture and Landscapes EFFECTS ASSESSMENT form for Minor Transportation Projects as Qualifted in the 2007 Progranunatic Agreement.
Page 1 of 2

Property Name:
Allen -Jamison House
Status:
Determined Eligible
Survey Site No.:
HN0248
PIN:
Effects
[0 No Effect ❑ No Adverse Effect ❑ Adverse Effect
Explanation of Effects Determination:
List of Environmental Commitments:
FHWA Intends to use the State Historic Preservation Office's concurrence as a basis for a "de
minimis" finding for the following properties, pursuant to Section 4(f):
SUPPORT DOCUMENTATION
❑Map(s) ❑Previous Survey Info. ❑Photos ❑Correspondence ❑Design Plans
FINDING BY NCDOT AND STATE HISTORIC PRESERVATION OFFICE
Historic Architecture and Landscapes —ASSESSMENT OF EFFECTS
N1 H Aj qll�Izw&
NCDOT Architectural Historian Date
Lj-4, %AA- 0, - �" - 4- 1-4
State Historic Preservation Office Representa ve Date
Federal Agency Representative Date
Hisloric Architecture and Landscapes /_%F[ EC75 ASSL•:SSMENT form foi Minor Transportation Pr(yects as Qualified in the 2007 Progranmmlic Agi-eenient.
Page 2 of 2

Project Tracking No. (Interim[ Use)
17-03-0004
°►ti HISTORIC ARCHICTECTURE AND LANDSCAPES
ASSESSMENT OF EFFECTS FORM
This form only pertains to Historic Architecture and Landscapes for this project. It
`., is not valid for Archaeological Resources. You must consult separately with the
Archaeology Group.
PROJECT INFORMATION
Project No:
R-2588B
County:
Henderson
WBS No.:
34473.1.3
Document
Type:
EA/FONSI Combined
Fed. Aid No:
STP-0191(14)
Funding:
❑State ®Federal
Federal
Permits :
® Yes ❑ No
Permit
Type(s):
NWP
Project Description:
Widening of NC 191 from SR 1381 (Mountain Road) to NC 280.
cTTMMARV OF HISTORIC ARCHICTECTURE AND LANDSCAPES REVIEW
Description of review activities, results, and conclusions:
Review of HPO quad maps, HPO GIS information, historic designations roster, and indexes was
undertaken on March 9, 2017. This project was originally surveyed in November 2000, at which time
four properties were determined eligible for National Register listing. One National Register listed
property, the Moss -Johnson Farm, is also within the Area of Potential Effects. An Historic Architecture
survey was required and was performed April 5, 2017. No additional properties over fifty years of age are
eligible for National Register listing, and all properties determined eligible/not eligible retain status within
the project area. The Merchant Goodson House (HN0239) and the Moss -Johnson Farm (HN0043) will
require an assessment of effects with the State Historic Preservation Office when preliminary plans are
available.
ASSESSMENT OF EFFECTS
Property Name:
Merchant -Goodson House
Status:
Determined Eligible
Survey Site No.:
HN0239
PIN.•
Effects
❑ No Effect
NJ No Adverse Effect ❑ Adverse Effect
Explanation of Effects Determination:
ho e-iTecA LJAtn,
MD s�!���IICs of rnU 1.1-()sc
List of Environmental Commitments:
Historic Architecture and Landscapes EFFECTS ASSESSMENTform for Minor T ransporiation Projects as Qualified in the 2007 Progranrnratic Agreement.
Page 1 of 2

Property Name:
Moss -Johnson Farm
Status:
National Register listed
Survey Site No.:
HN0043
PIN.•
Effects
W No Effect ❑ No Adverse Effect ❑ Adverse Effect
Explanation of Effects Determination:
No ( Rook 0!) Ro- pej ,
List of Environmental Commitments:
FHWA Intends to use the State Historic Preservation Office's concurrence as a basis for a "de
minimis" finding for the following properties, pursuant to Section 4(f):
SUPPORT DOCUMENTATION
❑Map(s) ❑Previous Survey Info. ❑Photos ❑Correspondence ❑Design Plans
FINDING BY NCDOT AND STATE HISTORIC PRESERVATION OFFICE
Historic Architecture and Landscapes —ASSESSMENT OF EFFECTS
NCDOT Architectural Historian Date
State Historic Preservation Office Representative Date
Federal Agen y Representative Date
Historic Archilecture and Landscapes GFl7iClS ASSI:SSNIEN%'dorm lot -Minor %'ransporlalion Projects as Onalified m the 2007 Progrannnatic Agreevtenl.
Page 2 of 2