20110023 All Versions_Complete File_20081028

Memorandum
-'oo
YEARS
To: Beth Smyre
From: Bill Rice DRAFT
Date: July 27, 2007
Subject: North Carolina Department of Environment and Natural Resources (NCDENR),
Division of Water Quality (DWQ) July 25, 2007 Meeting Summary - Bonner
Bridge Replacement Project (TIP No. B-2500)
Attendees:
Robin Smith, NCDENR
Amy Simes, NCDENR
John Hennessy, NCDENR-DWQ
David Wainwright, NCDENR-DWQ
Clarence Coleman, FHWA
Beth Smyre, NCDOT-PDEA
Brian Yamamoto, NCDOT-PDEA
Rob Hanson, NCDOT-PDEA
Lori Kroll, NCDOT
John Page, PB
Bill Rice, PB
Bill Biddlecome, USACE
NCDENR/ DWQ Views of the Phased Approach Alternative Issues
Beth Smyre opened the meeting by saying that the NCDOT was in the process of meeting
with the agencies that did not concur with the Phased Approach Alternative as the LEDPA,
and that she noted that the Division of Water Quality's (DWQ) concerns with the Phased
Approach related to the cost estimates, and the loss of recreational uses and aquatic life
uses of the Atlantic Ocean. With respect to this, John Hennessy stated that the issues brief
that the DWQ submitted is clear on these issues, and that there is likely no way to address
the project aside from assuming that it will eventually be in the ocean.
NCDOT Views of The Phased Approach Alternative Issues
Lori Kroll said that similar to other agencies, the possibility of the finished project eventually
being in the Atlantic is not ideal; however the upfront construction cost of the Pamlico Sound
Bridge Corridor makes it not practicable. The other Parallel Bridge Corridors utilize land from
the Pea Island National Wildlife Refuge, a Section 4(f) resource. Clarence Coleman said the
NC 12 easement within the Refuge is not considered a Section 4(f) resource.
DOI Secretary Kempthorn's Letter Regarding the Bonner Bridge
Robin Smith about Department of Interior (DOI) Secretary Kempthorn's 2006 letter as it
relates to the LEDPA decision. Lori Kroll said that the letter only deals with the Oregon Inlet
Bridge and not the NC 12 portion of the project. The NC 12 section, however, could not be
legally separated from the bridge replacement.
Over a Century of
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July 27, 2007
page 2
Constructing a Bridge That will Eventually be In The Ocean
Robin Smith asked about the safety of a bridge that would eventually be in the surf zone.
Lori Kroll said NCDOT consulted with 65 engineers nationwide (as part of the August 2006
Constructability Workshop) who concurred that the project could be built and would be
operationally safe. Robin then asked if there were other examples of similar structures in the
ocean. Clarence Coleman said there is a structure on Interstate 10 in Mississippi on the Gulf
of Mexico, but it is shorter than the proposed Phased Approach bridges.
Environmental Aspects of a Bridge in the Ocean
Robin Smith said effects to fish, benthic organisms, and use of the beach were concerns to
DWQ. Lori Kroll said the next Merger Meeting is within two weeks, and it is likely that no
additional information related to these impacts would be available by then. Robin Smith
asked if the primary reasons for the Phased Approach as the LEDPA were the Section 4(f)
and refuge compatibility issues. She asked if other approaches were considered. Clarence
Coleman said that other approaches to the selection of a LEDPA were considered, but this
decision must meet the requirements of existing law and other approaches would not meet
existing law.
Permits
Robin Smith said that her organization had spoken with the USFWS regarding phased
permitting for subsequent road improvements and that the USFWS stated it was possible.
Clarence Coleman said that phased permitting would be acceptable to the FHWA. Robin
Smith asked if the ROD could acknowledge a plan to use phased permitting. Clarence
Coleman said that FHWA would like to see this, but the initial ROD must choose an
alternative that addresses USFWS compatibility and Section 4(f). Lori Kroll said NCDOT
and FHWA must choose an alternative for the ROD that also addresses the NC 12 section of
the project.
Beth Smyre then asked if there was a difference between permitting a project that is built on
land but later is in the ocean and permitting a project that is initially constructed over the
ocean. John Hennessey said he did not know. Bill Biddlecome then that for bridge projects
that fall under the jurisdiction of the US Coast Guard and are permitted under Section 9 of
the Rivers and Harbors Act of 1899, the bridge piles are not classified as fill and no Section
404 permit is needed. Bill noted, however, that the Corps has the additional responsibility of
ensuring that any NEPA documentation discusses impacts to endangered species and to
other trust resources.
CEQ Phased Approval Process
Lori Kroll and Robin Smith discussed the potential to employ the Council on Environmental
Quality (CEQ) phased approval process. Lori Kroll said that the project very likely does not
fall within the eligibility criteria for employing CEQ's phased approval process. It could have
met the criteria if the problems on NC 12 were an anticipated future problem. However,
problems on NC 12 exist today. Clarence Coleman said the Phased Approach is adaptive
and that the Phased Approach could evolve with changing circumstances with revisions to
the ROD. Clarence also noted that the Phased Approach design in the SSDEIS assumes a
worst-case scenario by assuming the worst case 2060 shoreline and that all potential breach
locations are bridged.
Over a Century of
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July 27, 2007
page 3
Compatibility Determination Triggering Section 4(f) Assessment
John Hennessy asked how an USFWS compatibility determination triggers a Section 4(f)
evaluation. Clarence Coleman said that to use Section 4(f) lands, the body responsible for a
Section 4(f) resource must tell the FHWA that they agree with a de minimus finding, which is
that a project will have no adverse effect on the protected resource. If the Refuge finds an
alternative incompatible with the plans and mission of the Refuge, then they are saying to the
FHWA that the alternative has adverse impacts to the Refuge. If a de minimus finding
cannot be reached, then the FHWA must pursue avoidance alternatives that do not use
Section 4(f) lands. If another Parallel Bridge Alternative were compatible with the Refuge,
then FHWA would discuss a de minimus finding with the Refuge. Clarence Coleman said
the Pamlico Sound Bridge Corridor is Section 4(f) lands avoidance alternative, but it is not
affordable with its up front construction cost. The Phased Approach also is an avoidance
alternative because it stays within the existing NC 12 easement.
Post LEDPA Flexibility
The inherent flexibility of choosing a LEDPA that assumes the Oregon Inlet bridge is built
now and decisions are made on NC 12 later was discussed further. Clarence Coleman
again said that the approach of choosing the Phased Approach now and, if needed, revising
it later offers similar flexibility. John Hennessy said that parallel bridge in the surf zone could
cause major impacts to the Green sea turtle habitat and perhaps with that consideration, one
could conclude that NC 12 improvements that remain in the Refuge would have less impact
on the Refuge. The approximately 50 acres of wetland impact associated with the Road
North/Bridge South Alternative was discussed . Brian Yamamoto said that Refuge officials
also were concerned that, after the bridge over Oregon Inlet is built, the treatment of the
roadway through the Refuge will revert to the status quo of repairing it as needed. Lori Kroll
asked if it is possible to have the flexibility to adjust the roadway improvements based on
future conditions noted as a component of the Phased Approach. Clarence Coleman again
said that the proposed LEDPA could evolve with changed conditions.
With no further questions, the meeting ended.
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direct line: 919-468-2129
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J:\PLANNING\Bonner SDEIS\Preferred Alternative Selection\Meeting Minutes\DWQ 7-25-07.doc
Over a Century of
Engineering Excellence
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 F1B 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 El-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 El-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 E 1-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 may be 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 E1-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 E1-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 F1B 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 E1-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
E1-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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AppendixB
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
MEMbRANDUM - 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 #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 CFA - 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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Potential Summary of Merger 01 Dispute Resolution Board Meeting
8.27.2007
Issue: Concurrence Point 3 - Least Environmentally Damaging Practicable
Alternative (LEDPA)
Bonner Bridge : B-2500
The Sponsoring Agencies (hereafter referred to as agencies) of Merger 01
have reached concurrence on an approach to advance the Bonner Bridge
project and provide a replacement of the Bonner Bridge essentially within
the same alignment or with minor changes to the current alignment as
presently outlined in the Parallel Bridge alternates.
- The agencies concur that a Final Supplemental Environmental
Impact Statement needs to address all comments received to date and a
Record of Decision completed as soon as possible.
- Concurrence on this point does not imply that state or federal
permits or other approvals for this activity will be granted: rather, it simply
means that the agencies agree that, given the information provided, the
Phased Approach/Bridge Alternative can be identified as the LEDPA in the
NEPA/404 document.
The environment in the study area is complex and constantly changing. The
ability to predict the effect of Mother Nature's future impact on the study
area is extremely difficult to quantify. The shoreline alone is continually
moving and unexpected storms will exacerbate the uncertainties. The
environment present today can be changed overnight by Mother Nature.
The environment outlined in an environmental document at the time of
approval will likely change before permits are requested.
Based on the information available to the agencies as of today, the agencies
concur in the following:
The Pamlico Sound Bridge corridor is not practicable,
based upon cost estimates, and thus is not the LEDPA.
The Parallel Bridge Corridor contains various
alternates, all of which include a short parallel
replacement structure adjacent to the existing Bonner
Bridge. The agencies concur that Phase I of the project
should be to construct the replacement bridge within
this corridor as soon as possible. Every possible effort
ti- .
needs to be made for the bridge touchdown point to stay
within the existing alignment on Pea Island. The
agencies agree, based upon the information available
today, Phase I should be advanced through the Merger
'01 Process in order to insure applicable permits and
other approvals can be granted when requested by
NCDOT.
Phase I alone as outlined above does not meet purpose
and need of the project and thus additional phases of
work will be needed to meet purpose and need.
The agencies concur that the remaining phases of work
present substantial challenges before the appropriate agencies
will be satisfied in order to grant applicable permit and
approvals. It will be incumbent on NCDOT to provide the
necessary information to the permitting agencies to satisfy
their needs before permits and approvals are granted.
At.the time of permit application, all reasonable, practicable
and feasible alternatives will be considered and evaluated for
each phase. This evaluation will include avoidance,
minimization, and compensatory mitigation considerations. for
each selected alternative.
The NCDOT should finalize the Supplemental Draft EIS and
address all comments to date. It is expected that the Phased
Approach/Bridge will be identified in the Record of Decision
as the LEDPA. The agencies today are concurring this
alternate is the LEDPA, but with the clear understanding that
no permitting agency is bound by this concurrence to grant
permits or approvals for the entire LEDPA. To reiterate, the
agencies.believe Phase I needs to be advanced through Merger
'01. Remaining phases beyond Phase I are more problematic
from a permitting aspect given the information available
today. These remaining phases of work in the Phased
Approach/Bridge Alternative indicate work on Pea Island will
be done within the existing easement via the construction of
short bridge segments, or other alternatives as determined at
that time. The agencies concur, based on the information
available today, they can not conclusively say that permits or
approvals will or will not be granted for these additional
phases. The agencies do agree that permits will not be granted
for these remaining phases of work until their applicable laws
i
and regulations have been satisfied. The agencies are reaching
concurrence on this approach for the purposes of advancing
the project to a ROD but are making it clear the remaining
phases of work may need further. study after the ROD but
before any permits or approvals are granted.
One of the basic principles of Merger 01 is found in Paragraph B of the
Memorandum of Understanding that states:
Regulatory/Resource Agency participation in this process does not imply
endorsement of a transportation plan or project. Nothing in these procedures
is intended to diminish, modify; or otherwise affect the statutory or
regulatory authorities of the agencies involved. In the event of any conflict
between this process and other statutes or regulations, the statutes or
regulations control.
The Signatures of Sponsor Agencies Below Signify Agreement To the
Above Points:
711 /
William G. Laxton,
Deputy Secretary, North Carolina Department of Environment and Natural
Resources
William F. Rosser
State Highway Administrator, North Carolina Department of Transportation
S. Kenneth Jolly
Chief, Regulatory Division,
of Engineers
District, United States Army Corps
Carolina Division
Assistant Division Administrator, Federal Highway Administration North
() °3g1b
I&
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
August 21, 2007
Gregory J. Thorpe, Ph.D.
Project Development and Environmental Analysis
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Dr. Thorpe:
This letter is in response to your August 9, 2007 letter which requested comments from the U.S.
Fish and Wildlife Service (Service) on the Federal Environmental Assessment (FEA) for the
widening of SR 1406 (Piney Green Road) from NC 24 (Lejeune Boulevard) to US 17 (Marine
Boulevard), Onslow County, North Carolina (TIP No. U-3810). These comments are provided
in accordance with provisions of the Fish and Wildlife Coordination Act (16 U.S.C. 661-667d)
and section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531-1543).
According to the FEA, the North Carolina Department of Transportation (NCDOT) proposes to
widen a 6.6 mile portion of SR 1406 from two lanes to a four-lane median divided facility.
There are two alternatives (1 and 3A) still under consideration. At this time the Service does not
have a preferred alternative and will defer that decision until the Concurrence Point 3 meeting.
Under the ESA, there are currently fourteen federally protected species listed for Onslow
County. In addition to the fourteen, the FEA addresses the bald eagle (Haliaeetus
leucocephalus). The bald eagle was recently delisted and therefore no longer requires section 7
consultation. However, the species is still protected under the Bald and Golden Eagle Protection
Act and the Migratory Bird Treaty Act.
Of the fourteen currently listed species, the American alligator (Alligator mississippiensis) is
listed as threatened due to similarity of appearance and therefore does not require section 7
consultation. The shortnose sturgeon (Acipenser brevirostrum) falls under the purview of the
National Marine Fisheries Service and thus we have no comment on it. Of the remaining
species, the NCDOT has determined that, due to lack of habitat, the proposed project will have
no effect on the eastern cougar (Puma concolor couguar), green sea turtle (Chelonia mydas),
leatherback sea turtle (Dermochelys coriacea), loggerhead sea turtle (Caretta caretta), piping
plover (Charadrius melodus), red-cockaded woodpecker (Picoides borealis), Cooley's
meadowrue (Thalictrum cooleyi), rough-leaved loosestrife (Lysimachia asperulaefolia),
seabeach amaranth (Amaranthus pumilus) and golden sedge (Carex lutea). The Service concurs
with the "no effect" determination for these species.
The NCDOT has determined that the project may affect, but is not likely to adversely affect the
West Indian manatee (Trichechus manatus). The NCDOT had committed to implement the
Service's GUIDELINES FOR AVOIDING IMPACTS TO THE WEST INDIAN
MANATEE: Precautionary Measures for Construction Activities in North Carolina
Waters. Based on this commitment, the Service concurs with the determination that the project
may affect, but is not likely to adversely affect the West Indian manatee.
The FEA leaves the biological determination for pondberry (Lindera melissifolia) as unresolved.
Pondberry was recently observed within the adjacent Camp Lejeune. Therefore, it is prudent to
conduct surveys for the species within suitable habitat during the flowering season (February -
March). Also, individuals who are very familiar with the species may be able to survey later in
the growing season.
At this time, the Service does not have any significant outstanding issues with the proposed
project. We believe that the FEA adequately addresses the existing fish and wildlife resources,
the waters and wetlands of the United States, and the potential impacts of this proposed project
on these resources. The Service appreciates the opportunity to review this project. If you have
any questions regarding our response, please contact Mr. Gary Jordan at [phone], ext. 32.
Sincerely,
Amt ,
- Pete Benjamin
Field Supervisor
cc: Chris Militscher, USEPA, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
David Wainwright, NCDWQ, Raleigh, NC
Jennifer Frye, USACE, Raleigh, NC
John Sullivan, FHWA, Raleigh, NC
g-5-0-1
1)
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 25, 2007
Gregory J. Thorpe, Ph.D.
North Carolina Department of Transportation
Project Development and Environmental Analysis
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Dr. Thorpe:
This letter is in response to your request for comments from the U.S. Fish and Wildlife Service
(Service) on the potential environmental effects of the proposed widening of NC 211 from SR
1500 (Midway Road) to NC 87 in Brunswick County, North Carolina (TIP No. R-5021). These
comments provide information in accordance with provisions of the Fish and Wildlife
Coordination Act (16 U.S.C. 661-667d) and section 7 of the Endangered Species Act (ESA) of
1973, as amended (16 U.S.C. 1531-1543).
The project area is located within an extensive complex of wetlands including Carolina bays and
other important wildlife habitat types. A great diversity of rare animals and plants likely occur
within the project corridor.
For road widening projects the Service recommends the following general conservation
measures to avoid or minimize environmental impacts to fish and wildlife resources:
1. Wetland and forest impacts should be avoided and minimized to the maximal extent
practical. Highway shoulder and median widths should be reduced through wetland
areas;
2. Crossings of streams and associated wetland systems should use existing crossings and/or
occur on a bridge structure wherever feasible. Bridges should be long enough to allow
for sufficient wildlife passage along stream corridors. Where bridging is not feasible,
culvert structures that maintain natural water flow and hydraulic regimes without
scouring or impeding fish and wildlife passage should be employed;
3. Bridges and approaches should be designed to avoid any fill that will result in damming
or constriction of the channel or flood plain. To the extent possible, piers and bents
should be placed outside the bank-full width of the stream;
4. Bridge designs should include provisions for roadbed and deck drainage to flow through
a vegetated buffer prior to reaching the affected stream. This buffer should be large
enough to alleviate any potential effects from run-off of storm water and pollutants;
5. If unavoidable wetland or stream impacts are proposed, a plan for compensatory
mitigation to offset unavoidable impacts should be provided early in the planning
process;
6. Best Management Practices (BMP) for Construction and Maintenance Activities should
be implemented.
Section 7(a)(2) of the Endangered Species Act requires that all federal action agencies (or their
designated non-federal representatives), in consultation with the Service, insure that any action
federally authorized, funded, or carried out by such agencies is not likely to jeopardize the
continued existence of any federally-listed threatened or endangered species. A biological
assessment/evaluation may be prepared to fulfill the section 7(a)(2) requirement and will
expedite the consultation process. To assist you, a county-by-county list of federally protected
species known to occur in North Carolina and information on their life histories and habitats can
be found on our web page at http://nc-es.fws.gov/es/countyfr.html .
Based on available information, the Service is aware of at least one federally endangered red-
cockaded woodpecker (RCW)(Picoides borealis) cluster that maybe affected by the project.
There is likely potential habitat for other clusters as well. A survey should be conducted within a
0.5 mile radius of the project area boundaries within potentially suitable habitat to determine
whether any RCW cavity trees are present. Also, there may be suitable habitat for the federally
endangered rough-leaved loosestrife (Lysimachia asperulaefolia) within the project area. A
plant survey should be conducted during the species' flowering season (mid-May through June).
If suitable habitat occurs within the project vicinity for any other listed species, surveys should
be conducted to determine presence or absence of the species.
If you determine that the proposed action may affect (i.e., likely to adversely affect or not likely
to adversely affect) a listed species, you should notify this office with your determination, the
results of your surveys, survey methodologies, and an analysis of the effects of the action on
listed species, including consideration of direct, indirect, and cumulative effects, before
conducting any activities that might affect the species. If you determine that the proposed action
will have no effect (i.e., no beneficial or adverse, direct or indirect effect) on listed species, then
you are not required to contact our office for concurrence.
We reserve the right to review any federal permits that maybe required for this project, at the
public notice stage. Therefore, it is important that resource agency coordination occur early in
the planning process in order to resolve any conflicts that may arise and minimize delays in
project implementation. In addition to the above guidance, we recommend that the
environmental documentation for this project include the following in sufficient detail to
facilitate a thorough review of the action:
1. A clearly defined and detailed purpose and need for the proposed project;
2. A description of the proposed action with an analysis of all alternatives being considered;
3. A description of the fish and wildlife resources, and their habitats, within the project
impact area that may be directly or indirectly affected;
4. The extent and acreage of waters of the U.S., including wetlands, that are to be impacted
by filling, dredging, clearing, ditching, or draining. Acres of wetland impact should be
differentiated by habitat type based on the wetland classification scheme of the National
Wetlands Inventory (NWI). Wetland boundaries should be determined by using the 1987
Corps of Engineers Wetlands Delineation Manual and verified by the U.S. Army Corps
of Engineers;
5. The anticipated environmental impacts, both temporary and permanent, that would be
likely to occur as a direct result of the proposed project. The assessment should also
include the extent to which the proposed project would result in indirect and cumulative
effects to natural resources;
6. Design features and construction techniques which would be employed to avoid or
minimize impacts to fish and wildlife resources, both direct and indirect, and including
fragmentation and direct loss of habitat;
7. Design features, construction techniques, or any other mitigation measures which would
be employed at wetland crossings and stream channel relocations to avoid or minimize
impacts to waters of the US; and,
8. If unavoidable wetland or stream impacts are proposed, project planning should include a
compensatory mitigation plan for offsetting the unavoidable impacts.
The Service appreciates the opportunity to comment on this project. Please continue to advise us
during the progression of the planning process, including your official determination of the
impacts of this project. If you have any questions regarding our response, please contact Mr.
Gary Jordan at [phone], ext. 32.
Sincerely,
-J
Pete ?.enjin
Field Supervisor
cc: Jennifer Frye, USACE, Washington, NC
David Wainwright, NCDWQ, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
Chris Militscher, USEPA, Raleigh, NC
-ql t
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 25, 2007
Gregory J. Thorpe, Ph.D.
North Carolina Department of Transportation
Project Development and Environmental Analysis
1598 Mail Service Center
Raleigh, North Carolina 27699-1598
Dear Dr. Thorpe:
This letter is in response to your letter of July 18, 2007 which provided the U.S. Fish and Wildlife Service
(Service) with the biological determination of the North Carolina Department of Transportation
(NCDOT) that the replacement of Bridge No. 51 on US 264 over Broad Creek in Beaufort County (TIP
No. B-4413) may affect, but is not likely to adversely affect the federally endangered West Indian
manatee (Trichechus manatus). In addition, NCDOT has determined that the proposed project will have
no effect on any other federally listed species. These comments are provided in accordance with section 7
of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531-1543).
The NCDOT has committed to implementing the Service's GUIDELINES FOR AVOIDING
IMPACTS TO THE WEST INDIAN MANATEE: Precautionary Measures for Construction
Activities in North Carolina Waters. Based on the commitment to this conservation measure, and due
to the project area's inland location, the Service concurs with your determination that the project may
affect, but is not likely to adversely affect the West Indian manatee. We also concur that the project will
have no effect on any other listed species. We believe that the requirements of section 7(a)(2) of the ESA
have been satisfied. We remind you that obligations under section 7 consultation must be reconsidered if:
(1) new information reveals impacts of this identified action that may affect listed species or critical
habitat in a manner not previously considered in this review; (2) this action is subsequently modified in a
manner that was not considered in this review; or (3) a new species is listed or critical habitat determined
that may be affected by this identified action.
The Service appreciates the opportunity to review this project. If you have any questions regarding our
response, please contact Mr. Gary Jordan at [phone] (Ext. 32).
Sincerely,
Pete Benjamin
Field Supervisor
cc: William Wescott, USACE, Washington, NC
David Wainwright, NCDWQ, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
Chris Militscher, USEPA, Raleigh, NC
John Sullivan, FHWA, Raleigh, NC
David Harris, NCDOT, Raleigh, NC
B-2500 Issut Briefs
Subject: B-2500 Issue Briefs
From: Beth Smyre <[e-mail]>
Date: Thu, 23 Aug 2007 10:39:59 -0400
To: Bill Biddlecome <[e-mail]>, Clarence Coleman
<clarence.coleman ,fliwa.dot.gov>, John Hennessy <[e-mail]>, Jim Gregson.
<[e-mail]>, Chris Militscher <[e-mail]>, Ron Sechler
<Ron. S echler@noaa. gov>, Mike Murray <Mike_Murray@,)nps.gov>, Mike Bryant
<mike [e-mail]>, Pete Benjamin <[e-mail]>, Renee Gledhill-Earley
<[e-mail]>, Mike Street <[e-mail]>, David Cox
<[e-mail]>, Scott McLendon <[e-mail]. mil>, Ron
Lucas <ron.lucas@fliwa. dot. gov>, David Wainwright <david.wainwri ght@ncm ail. net>, Cathy
Brittingham <[e-mail]>, Jim Hoadley <[e-mail]>, Doug Huggett
<[e-mail]>, Kathy Matthews <matthews.kathy@epamail..epa.gov>, Thayer Broili
<Thayer_Broil [e-mail]>, Dennis Stewart <dennis_stewart @fws.gov>, Gary Jordan
<gary jordan@f-%vs.gov>, Sarah McBride <[e-mail]>, Sara Winslow
<sara.winslow@ncmall. net>, Travis Wilson <[e-mail]>, Lori Kroll
<[e-mail]>, "Deborah M. Barbour PE" <[e-mail]>, Greg Thorpe
<[e-mail]>, Rob Hanson <[e-mail]>, Brian Yamamoto
<byarnamoto@dot. state.nc. us>
i
Fyi, attached are all of the Issue Briefs received as a result of ti
last week's meeting. Please let me know if you have any questions!
Enjoy, 4
Beth
Beth Smyre, P.E.
Project Planning Engineer
NC Department of Transportation
Project Development & Environmental Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
[phone] ext. 333
Content-Type: application/pH
August 2007 Issue Brief Packet pdf
Content-Encoding: base64
1 of 1 8/23/2007 11:56 AM

STATE OF NORTH CAROLINA
DEPARTN ENT OF TRANSPORTATION
MICHAEL F.. EASLEY
GOVERNOR
August 22, 2007
MEMORANDUM TO:
FROM:
Merger0l Review Board
Beth Smyre, P.E. &A 41q%
Project Planning Engineer
LYNAo TIPPETT
SECRETARY
SUBJECT: NC 12 Replacement of Herbert C. Bonner Bridge, (Bridge
No. 11) over Oregon Inlet, Dare County, WBS No. 32635,
Federal Aid Project No. BRS-2358(15), TIP No. B-2500
On August 15, 2007, the B-2500 merger team met in an attempt to reach
concurrence on CP 3, the Least Environmentally Damaging Practicable Alternative
(LEDPA). The merger team was unable to reach concurrence. Therefore, upon the request
of the North Carolina Department of Transportation (NCDOT), the project has been
elevated to the Review Board for consideration in compliance with the Section
404/NEPA Merger 01 Process.
Of the seven study alternatives for this project, NCDOT recommends the Parallel
Bridge with Phased Approach/ Rodanthe Bridge Alternative as the project's LEDPA
(Least Environmentally Damaging Practicable Alternative). This alternative includes the
Oregon Inlet crossing (Phase 1) as well as bridging portions of NC 12 within the existing
easement (Phases II-IV). The phasing of the NC 12 bridges (construction timing, length,
etc.) is inherently flexible and would be based on actual shoreline conditions and other
appropriate factors. The Federal Highway Administration supported NCDOT in this
recommendation.
At the August 15, 2007 merger meeting, nine of the 13 team members (US Army
Corps of Engineers, US Environmental Protection Agency, US Fish & Wildlife Service,
USFWS- Pea Island National Wildlife Refuge, National Park Service, National Marine
Fisheries Service, NC Division of Water Quality, NC Division of Coastal Management,
and NC Division of Marine Fisheries) did not concur with the Department's preferred
alternative, the Parallel Bridge with Phased Approach/Rodanthe Bridge. Two additional
members (NC Wildlife Resources Commission and State Historic Preservation Office)
abstained.
Initially, the Team had expressed a strong preference for the Pamlico Sound
Alternative. However, the initial bridge construction costs (not including future
MAILING ADDRESS: TELEPHONE: [phone] LOCATION:
NC DEPARTMENT CP TRANSPORTATION FAX: [phone] TRANSPORTATION BUILDING
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WEBSITE. WWW.DON.DOT.STATE.NC.US RALEIGH NC
RALEIGH NC 27699-1548
August 22, 2007
Page 2
operations and maintenance) for the Pamlico Sound Bridge Corridor range between
$929,100,000 and $1,425,500,000, well above the $548 million currently available in the
2007-2013 TIP for Division 1. The total highway costs for the Pamlico Sound Corridor
through the year 2060, including all construction, operations, and maintenance costs,
range from $1,299,066,000 to $1,797,564,000.
Cost estimates for Phase I (Oregon Inlet crossing) of the Phased Approach/
Rodanthe Bridge Alternative range between $294 and $347 million, within the $548
million appropriated for Division 1. The total highway costs for the Phased Approach/
Rodanthe Bridge Alternative through the year 2060, including all construction,
operations, and maintenance costs, range from $1,171,459,000 to $1,497,113,000.
Because the construction of Phases II-N is spread over multiple TIP periods, this
alternative is practicable.
In June 2007, the Department presented detailed cost information to the Team
substantiating that the Pamlico Sound alternative is not practicable financially. At the
August 15, 2007 merger meeting, the team members were asked whether they agreed that
the Pamlico Sound Bridge Corridor was not a LEDPA, i.e., not a practicable alternative..
Six agencies (NCDOT, FHWA, US Army Corps of Engineers, NC Division of Coastal
Management; NC Division of Water Quality, and the NC Division of Marine Fisheries)
agreed that the Pamlico Sound Corridor was not practicable and therefore should not be
the LEDPA.
Due to the high cost of the Pamlico alternative and the lack of funds available to
construct it within a single TIP period, the Pamlico Sound Bridge Corridor is not
practicable. Phasing the cost of the Pamlico Sound Bridge is not possible, since the
replacement bridge could not be opened to traffic until construction is completed in its
entirety. The elimination of Pamlico Sound as a LEDPA leaves the Parallel Bridge
corridor and its attending alternatives for consideration.
Of the Parallel Bridge Corridor alternatives, the Phased Approach/ Rodanthe
Bridge Alternative is the only alternative in which all construction activities remain
within the existing 100-foot easement within the Pea Island National Wildlife Refuge.
The US Department of Interior has indicated that any alternatives that involve work
within the Refuge but outside of the easement would likely not be found compatible with
the mission of the Refuge. Further, the federal law commonly known as "Section 4(f)"
prohibits the use of publicly owned land within a wildlife refuge for a federally-funded
transportation project unless the impact to the refuge is determined to be de minimis or
unless there is no prudent and feasible alternative to using that land. Therefore, the
Phased Approach/ Rodanthe Bridge Alternative should be the LEDPA because it does not
require a compatibility determination from PINWR, it is compliant with Section 4(f),, and
the Department is able to finance it.
NCDOT will continue to work with state and federal agencies to address their
concerns with this alternative, but it believes that the Phased Approach/ Rodanthe Bridge
Alternative should be selected as the LEDPA for this project.
Merger 01 Process
Issue Brief
Prepared by the Federal Highway Administration-NC Division
1. Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed: CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position.
NCDOT is recommending the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the project's Least Environmentally
Damaging Practicable Alternative (LED PA)/P referred Alternative. Since the
May 23, 2007 NEPA/Section 404 Merger team meeting, the Federal Highway
Administration (FHWA) has concurred with the Parallel Bridge Corridor-
Phased Approach/Rodanthe Bridge Alternative.
4. Explain the reasons for your concurrence. Please include any data or information
that would substantiate and support your position.
In the 2005 SDEIS, and in the 2007Supplement to the SDEIS, the following
alternatives were studied in detail:
• Pamlico Sound Bridge
• Parallel Bridge with Nourishment
• Parallel Bridge with All Bridge
• Parallel Bridge with Road North Bridge South
• Parallel Bridge with Phased Approach
FHWA concurs with the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the LEDPA/Preferred Alternative
because this is the only alternative that meets the purpose and need for the
project, provides flexibility in future decision-making, and is capable to be
carried out in compliance with Federal laws and regulations.
The purpose and need of the project is to provide a new means of access from
Bodie Island to Hatteras Island, and to provide a replacement crossing that
will not be endangered by shoreline movement and takes into account natural
channel migration. The purpose and need for this project was developed
through interagency coordination. Making a decision only on the Oregon Inlet
crossing does not meet the purpose need of the project. The Parallel Bridge
FHWA Issue Brief, TIP No. B-2500, Page I of 3, 8/20/2007
Corridor with Phased Approach/Rodanthe Bridge Alternative addresses the
purpose and need of the project.
The Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge
Alternative provides flexibility regarding the uncertainty of changing coastal
conditions. Coastal conditions are difficult to forecast, and the Merger Team
previously agreed that the selected alternative should address the "worst-
case" scenario. The National Environmental Policy Act (NEPA) regulations
require additional consultations and/or reevaluations prior to additional FHWA
actions. NEPA regulations also allow the Record of Decision document
(ROD) to be revised when a previously studied alternative becomes the
preferred alternative due to a change in decision-making factors. Therefore,
FHWA regulations inherently allow flexibility in decision-making when
conditions change.
The Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge
Alternative complies with applicable federal laws and regulations. The Parallel
Corridor with Phased Approach/Rodanthe Bridge Alternative complies with
section 4(f) of the Department of Transportation Act of 1966 by not having any
additional use of Pea Island National Wildlife Refuge. The proposed
improvements are contained within the existing 100-foot permanent easement.
Based on input from the United States Fish and Wildlife Service (USFWS), the
Parallel Corridor with Phased Approach/Rodanthe Bridge Alternative does not
require a compatibility determination from the USFWS concerning the project
being in compliance the Department of Interior's National Wildlife Refuge
Administration Act.
Based on information provided by NCDOT at the May 23, 2007 and June 20,
2007 meetings with the Merger Team, FHWA agrees with NCDOT that the
Pamlico Sound Alternative is not practicable based on lack of funding, and the
inability to finance the construction of the Pamlico Sound Bridge under a
single contract. At the May 23 meeting, NCDOT explained to the Merger Team
that the Pamlico Sound Bridge was not affordable and unable to be financed.
Several members of the Merger Team stated during the meeting and in their
issue briefs that additional information was needed. At the June 20 meeting,
detailed cost and financing information was presented to the Merger Team.
Since that time, no agency has further commented on the cost estimates and
financing except for EPA's request for maintenance cost information. This
information was later provided and no further concerns were expressed by
EPA.
The remaining alternatives studied in detail were not chosen as the
LEDPA/Preferred alternative for the following reasons:
The Parallel Bridge with the All Bridge, Nourishment, and the Road
North/Bridge South options do not comply with Section 4(f) of the United
FHWA Issue Brief, TIP No. B-2500, Page 2 of 3, 8/20/2007
States Department of Transportation Act (USDOT) of 1966. Section 4(f) of the
USDOT Act is stated in 23 CFR 771.135 as follows: "The Administration
(FHWA) may not approve the use of land from a significant publicly owned
public park, recreation area, or wildlife and waterfowl refuge, or any significant
historic site unless a determination is made that.
(i) There is no feasible and prudent alternative to the use of land from the
property; and
(H) The action includes all possible planning to minimize harm to the property
resulting from such use."
These alternatives require a direct use of additional Pea Island National
Wildlife Refuge lands. The Parallel Bridge with Phased Approach/Rodanthe
Bridge Alternative is a feasible and prudent alternative that avoids the use of
additional refuge lands. With an available alternative that is feasible and
prudent and avoids refuge lands, the FHWA is currently prohibited from
approving the Parallel Bridge alternative with the All Bridge, Nourishment, and
the Road North/Bridge South options on NC 12 through the Pea Island
National Wildlife Refuge.
Based on coordination with USFWS, other Parallel Bridge alternatives (All
Bridge, Nourishment, Road North/Bridge South alternatives) are likely not to
be compatible with the Refuge and therefore fail to comply with the National
Wildlife Refuge Administration Act.
Following the June 20 meeting, FHWA, along with NCDOT met with resource
agencies individually to discuss their substantive comments and concerns.
Agency comments were summarized in a table and the NCDOT/FHWA
responses to each agency were included in the table. Agencies were then
able to review the responses. No further comments were received concerning
the responses. Based on the lack of any further specific comments or any
formal suggestions from the agencies, FHWA concurs with the Parallel Bridge
Corridor with Phased Approach/Rodanthe Bridge Alternative. Delaying these
decisions any further will not meet the purpose and need of the project which
proposes to provide motorists a safer, more reliable transportation facility
along Hatteras Island.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
Any alternative that is selected as the LEDPA/Preferred Alternative will require
a Coastal Area Management Act (CAMA) major permit form the Division of
Coastal Management (DCM). Based on coordination with DCM, a CAMA permit
will likely be denied for all of the alternatives if selected. DCM has indicated
FHWA Issue Brief, TIP No. B-2500, Page 3 of 3, 8/20/2007

that NCDOT would have the option of asking for a waiver to undertake a
project that has been denied a CAMA major permit.
6. What alternative course of action do you recommend?
FHWA recommends the selection of the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the Preferred Alternative. FHWA
believes the Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge
Alternative is the only practicable alternative that meets purpose and need and
complies with applicable federal laws.

FHWA Issue Brief, TIP No. B-2500, Page 4 of 3, 8/20/2007
Merger 01 Process
Issue Brief
Prepared by the U.S. Army Corps of Engineers, 8/17/2007
1. Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed: CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT and FHWA are recommending approval of the Parallel Bridge Corridor
with Phased Approach/Rodanthe Bridge Alternative (PARBA) as the projects
Least Environmentally Damaging Practicable Alternative (LEDPA) (CP#3). The
Corps is not able to concur with NCDOT's and FHWA's selection of this
alternative as the LEDPA at this time. The Corps decision not to concur is
based on the continued concerns of other Federal and State agencies with the
adequacy of the NEPA document (Supplement to the SDEIS). There are
unresolved issues that will require additional detailed analysis as it pertains to
the environmental impacts of the PARBA. M .
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
The Corps, as a Federal permitting agency, must consider all relevant
comments received by NCDOT pertaining to other State and Federal
Regulations and laws such as the Coastal Area Management Act, Endangered
Species Act, National Wildlife Refuge System Improvement Act of 1997, Fish
and Wildlife Coordination Act, and the Magnuson Stevens Fishery
Conservation and Management Act. These comments must be answered
adequately enough to insure that the recommended alternatives comply with
federal and state laws and guidelines. Specifically, information is lacking
concerning Essential Fish Habitat (EFH) for species managed by the South
Atlantic Fishery Management Council (SAFMC), Mid-Atlantic Fishery
Management Councils (MAFMC) and the National Marine Fisheries Service
(NMFS). The Merger 01 process provides guidance for the selection of the
LEDPA. It states that project team members will be reasonable certain that the
LEDPA/Preferred Alternative will comply with all relevant regulations and
permit requirements, is safe, and can be authorized. The Corps is not
satisfied that agency concerns have been adequately addressed and therefore
cannot make a decision on the LEDPA.
1
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
33 CFR 320.4 General Policies or Evaluating Permit Applications
40 CFR 230.10 - Restrictions on Discharge
Magnuson-Stevens Fishery Conservation and Management Act and Fish and
Wildlife Coordination Act - Long term impacts to EFH and fish and wildlife
habitat. (Indirect, Secondary and Cumulative Impacts).
6. What alternative course of action do you recommend?
Submittal of an updated Essential Fish Habitat Assessment addressing
concerns raised by the NMFS that the PARBA would have significant long-
term effects on the beach front surf zone.
SECTION 404/NEPA MERGER 01 ELEVATION ISSUE BRIEF: 8/22/07
Submitted by: Christopher A. Militscher, REM, CHMM
Merger Team Representative
USEPA Raleigh Office
THRU: Heinz J. Mueller, Chief
NEPA Program Office
USEPA Region 4
Thomas C. Welborn, Chief
Wetlands, Coastal Protection Branch
USEPA Region 4
To: Merger 01 Review Board Members
Beth Smyre, P.E., Project Planning Engineer
Planning Development and Environmental Analysis Branch
NCDOT
Cc: Kathy Matthews, USEPA Wetlands Section
1. Project Name and Brief Description: TIP No.: B-2500; NC 12 Replacement of
Herbert C. Bonner Bridge over Oregon Inlet; Dare County.
2. Last Concurrence Point (signed): CP 2 Detailed Study Alternatives Carried Forward
Date of Concurrence Point 2 Meeting: 10/13/04
3. Proposal and Position: NCDOT & FHWA propose to select the Parallel Bridge
Corridor/Phased Approach Rodanthe Bridge (PBC/PA-RB) Alternative for the LEDPA.
EPA has previously identified one of the Pamlico Sound Bridge Corridor (PSBC)
Alternatives as its environmentally preferred alternative ("LEDPA") and had assigned
Environmental Objections (EO) rating to the PBC Alternatives. At the August 15, 2007,
meeting on the LEDPA, the EPA Merger team representative could not agree or disagree
(Unsure) as to the "Practicability" issue under USACE Regulatory Guidance Letter 93-02
and 40 CRF Part 230. 1 0(a)(2) for the PSBC Alternative. EPA cannot concur with the
PBC/PA-RB as the LEDPA*.
4. Reasons for Non-concurrence:
The `practicability' of the PSBC alternative has been potentially undermined by a
lack of coordinated planning and funding initiatives during the past 5 years of the NEPA
process. According to NCDOT's potential funding options for the replacement of
Bonner Bridge, the total available funds from 2007-2013 for Division 1 projects is
approximately $575 million. Funding restriction under the State's Equity formula {by
themselves) do not provide a reasonable basis for elimination under RGL 93-02 and 40
CFR Part 230 [The determination of what constitutes an unreasonable expense should
generally consider whether the projected cost is substantially greater than the costs
normally associated with the particular type of project; RGL 93-02 (3)(b)]. In this
context, long bridge alternatives are generally more expense than non-bridge projects and
that the cost of the fully implemented PBC/PA-RB alternative is also more than $1
billion. However, EPA also recognizes that the preamble to the Guidelines also states
that: [...if an alleged alternative is unreasonably expensive to the applicant, the
alternative is not `practicable']. Thus, EPA is unsure as to "Practicability" involving the
PSBC alternative. EPA has previously stated that the PSBC alternative is the `Least
Environmentally Damaging' {to Aquatic Resources of National Importance - ARNI) of
the two detailed study corridor alternatives (PBC-PA and PSBC) carried forward in the
2007 Supplement to Supplemental DEIS (2007 SSDEIS).
Furthermore, numerous projects in the Merger 01 process have been carried
forward through the Concurrence Point 3/LEDPA selection without full funding
commitments within the TIP and that individually their projects' costs sometimes
exceeded the State Equity formula requirements. The alternatives that were considered
for the LEDPA for these projects were not eliminated by the respective project teams,
including FHWA, NCDOT, ACE and DWQ, based solely upon Section 404(b)(1)
Guidelines consideration of "unreasonably expensive to the applicant".
The specific LEDPA definition contained in the Merger 01 Agreement does not
contain any specific reference to project costs, unreasonableness of project costs, the
availability of funding, or the State's Equity formula requirements. Under Merger 01,
alternatives that are advanced through the detailed study phase (Concurrence point 2)
under the Merger process are all `reasonable' and `feasible' alternatives under NEPA and
Section 404 and that the lead Federal agency can select one of these detailed study
alternatives as their `preferred' alternative following the issuance of the draft NEPA
document [...and for alternatives which were eliminated from detailed study, briefly
discuss the reasons for their having been eliminated; 40 CFR Part 1502.14(a)].
While EPA concurs with FHWA and NCDOT that the cost of bridge construction
in general has escalated beyond typical inflation within the last few years, these cost
trends should have been `reasonably foreseeable' under NEPA and should have been
further explored, defined and disclosed in the February 2007 SSDEIS. This is also true
on the disclosure of the State Equity formula requirements (Existing since 1989) and how
this project's alternatives could impact future TIP funding cycles in Division 1.
EPA also recognizes that certain costs for both the PSBC and PBC/PA-RB
alternatives have increased dramatically due to the reasons provided in the Bonner Bridge
Preliminary Cost reports from June of 2007. However, the increase in the width (typical
section) of the PSBC alternative from 36 feet to 40 feet appears to be one of the key
contributions to the changes in the cost estimates. This approximate 10% increase in
material cost for the PSBC alternative is making construction of the PSBC alternative
appear "less practicable" with respect to total project costs. NCDOT and FHWA have
not provided a full, detailed rationale ("Safety concerns") as to the need to increase the
typical width of a long bridge. Other 2-lane bridges in North Carolina have 6-foot
shoulders (or less). EPA is uncertain as to why other potentially less expense design
alternatives were not considered in the 2005 SDEIS or 2007 SSDEIS. Some of the
independent contractor cost estimates provided to FHWA and NCDOT were based on
two bridge projects (i.e., Interstate 10 Escambia Bay in Florida and Lake Pontchartrain
Causeway Bridge in Louisiana). EPA understands that one was 60-feet wide and the
other was 52-feet wide. While it was stated that the costs were `unit priced', EPA is
uncertain that there are not other increased `unit' costs associated with supporting larger
(heavier) structures (e.g., Larger support columns, additional spans, etc.).
EPA cannot concur with NCDOT and FHWA that the PBC/PA-RB Alternative
can meet the approved purpose and need for the project. EPA also has concerns that
FHWA has potentially misunderstood our use of an "Adaptive Management
Approach". Adaptive Management Approach should include those potential solutions
and alternatives that may have been dismissed in the past as unreasonable under NEPA,
but may now have merit considering the current issues of "practicability" and "permit-
ability". Based upon current research from renowned coastal geology experts, the NC 12
corridor in the long term appears to be a `failing corridor' given the project's vulnerable
coastal setting". The transportation agencies need to adapt their plans to the evolving
natural conditions. Adaptive management in EPA's viewpoint is not just "phasing" of
what has been a typical approach to maintaining NC 12: building more bridges or
rebuilding NC 12 through sand replacement after every major storm event.
The transportation agencies need to be proactive and work on longer-term options
regarding the public's expectation that the NC 12 highway corridor on Hatteras Island
and a northern access to PINWR may not always be available to them. Serious
consideration needs to be given to an expanded ferry service, and not just for
emergencies. EPA and other agencies have recognized that additional infrastructure in
this dynamic coastal landscape will continue to place an unreasonable burden on
transportation agencies to reliably, cost-effectively and safely operate and maintain the
NC 12 corridor within PINWR in the future.
EPA has continuing environmental concerns as to how the Lead Federal Agency
(FHWA) can proceed with the proposed PBC/PA-RB Alternative without first resolving
NEPA cross-cutting issues under the National Wildlife Refuge System Improvement Act,
the Endangered Species Act, the Migratory Bird Treaty Act, Essential Fish Habitat -
Magnuson-Stevens Act, etc. These specific legal/policy issues need to be adequately
resolved under the aforementioned Federal acts before a Clean Water Act Section 404
"LEDPA" can be selected, and approved by the ACE. These factors should be as much a
part of "practicability" as is the cost factor.
EPA has cited previous and unchanged environmental concerns for drastically
increasing the long-term commitment of infrastructure along a dynamic and
unpredictable barrier island system, including specifically the PBC/PA-RB Alternative.
EPA is uncertain how avoidance and minimization measures required under the Section
404(b)(1) Guidelines can be fully developed for the PBC/PA-RB Alternative.
EPA does not have any specific informational need requests at this time and is
reviewing the August 2, 2007, additional information package provided by NCDOT at
the August 15, 2007, LEDPA meeting, including the supplemental information on the
PSBC and PCB/PA-RB operations and maintenance cost projections.
5. Potentially Violated Laws/Regulations: The following EPA regulations apply to this
action: Section 1502.14, et al. of 40 CFR, CEQ National Environmental Policy Act
regulations and Section 404(b)(1) of the Clean Water Act.
6. Alternative Course of Action: EPA recommends that the B-2500 Merger project
team be re-directed by the Review Board to re-open CP 2 and re-evaluate the option of
providing a `short-bridge', strict replacement project ("Phase I" only) in conjunction
with a specific and detailed Adaptive Management Approach that would be phase
based on conditions and that longer-term include the `planned' and `timed'
implementation of a permanent ferry service between Hatteras Island and Bodie Island
(and potentially with other mainland ferry terminals). The longer-term primary objective
of the Adaptive Management plan would be the eventual and `strategic' abandonment of
the NC 12 corridor though PINWR. This approach should be planned and timed on a
number of pre-determined factors, including impact thresholds to PINWR, maintenance
and repair costs, the number and intensity of storm-related breaches, the actual shoreline
erosion rates, the `useful' life of the new replacement bridge, etc. However, this
Adaptive Management plan would need to have very specific implementation goals in the
FHWA's Record of Decision (e.g., A permanent ferry service established per detailed
criteria in the Adaptive Management plan). EPA also recommends that NCDOT and
FHWA continue to pursue innovative avoidance and minimization strategies for the
impacts from a `short bridge' that go well beyond the `typical' measures that are included
in other Merger projects. EPA would also propose that NCDOT and the Merger team
consider adding full representation from the NCDOT's Ferry Division in order to insure
that timely and expert advice is available to the team during the development of an
Adaptive Management plan.
* EPA continues to have significant environmental concerns regarding the PBC/PA Alternatives,
including the impacts of placing 25-foot high bridges along the beach, in the surf zone, in PINWR,
and affecting the near shore ocean which is an ARNI and impacting recreational uses, sea turtle
nesting, essential fish habitat, etc. EPA does not concur that construction for 12.5 out of 25 years for
the PBC/PA alternative within PINWR can be compatible with FWS's mission. Building any
additional bridges along the NC 12 corridor beyond the existing Bonner Bridge may not be consistent
with environmentally-sound principles and cost-effective solutions for the long-term transportation
needs of Hatteras Island. EPA continues to have environmental concerns regarding the completion
of requested analyses (e.g., Scour modeling, updated SLR analysis) that have not been provided to
date.
** 6/1/07 NCDCM Merger 01 Issue Brief, Item #4. Also, on September 18, 2003, Hurricane Isabel
(Category 2 at the time of landfall between Cape Lookout and Ocracoke Island in N.C.) caused a
2,000-foot breach along NC 12 (referred to as the "Hatteras Inlet") just north of Rodanthe. This
breach forced the closure of NC 12 between Hatteras Island and Bodie Island for two months while
repairs were being made by NCDOT. The direct repair cost of this one event was estimated at $11
million. Other severe storm events that damaged NC 12 in the last 25 years include Hurricanes Alex
(8/2004), Emily (9/1993), and Gloria (9/1985). This short list does not include `minor' hurricanes,
`nor-easters', tropical depressions and storms and other severe weather conditions that have
impacted the Outer Banks.
Merger 01 Process Issue Briefing
August 22, 2007
NOAA's National Marine Fisheries Service (NMFS) Issue Brief for Non-Concurrence with
Concurrence Point 3 (CP3) - Selection of the Least Environmentally Damaging Practicable
Alternative (LEDPA) at the August 15, 2007 Concurrence Meeting
1. Name of Project
Replacement of the Herbert C. Bonner Bridge over Oregon Inlet, Dare County, North Carolina;
TIP No B-2500
The North Carolina Department of Transportation (NCDOT) proposes replacement of the
existing North Carolina Highway 12 (NC 12) Bridge and address transportation needs south to
the Town of Rodanthe. Pursuant to the National Environmental Policy Act (NEPA), a
Supplemental Draft Environmental Impact Statement (SDEIS) and a Supplement to the
Supplemental Draft Environmental Impact Statement (SSDEIS) were prepared and submitted for
review. Two bridge corridors with seven alternatives are addressed in the NEPA documents.
The Wilmington District of the US Army Corps of Engineers (COE) issued a public (Action ID
No. 19930307) concerning the federal authorization of this work.
2. Last Concurrence Point (signed)
The last concurrence point signed by the NMFS was CP 2A Bridging Decisions and Alignment
Review on October 13, 2004.
3. Explanation of NCDOT's proposal for CP3
Pursuant to CP 3, NCDOT recommended selection of the Parallel Bridge Phased Approach
(PBPA) as the LEDPA. This alternative involves construction of a parallel bridge adjacent to the
existing Bonner Bridge, which would be removed. It also includes a series of new 30-foot high
bridges that would be constructed as needed, perhaps over a 30-year period, to provide
uninterrupted access over identified "hot spots" that threaten NC 12 within the Pea Island
National Wildlife Refuge (PINWR). These high erosion areas are associated with the 12-mile
section of NC 12 between Oregon Inlet and the Town of Rodanthe on Hatteras Island. In
principle, these new bridges would be constructed as sections of NC 12 are threatened with
destruction by ocean over wash. NCDOT anticipates that each new bridge section would be
limited to the existing right-of-way within PINWR, although PINWR is skeptical that this would
be possible.
4. Concerns and Rational for Non-concurrence by NMFS
NMFS does not dispute NCDOT's determination that the Bonner Bridge requires replacement or
that a long-term plan for maintaining NC 12 between Oregon Inlet and the Town of Rodanthe is
needed. We understand that substantial costs are involved for construction of any of the
alternatives. We also understand that the cost of the PBPA alternative can be deferred over a
period of 30 years, while the cost of the Pamlico Sound Bridge (PSB) alternative, which is
preferred by the NMFS, would require funding over a shorter period (5 to 10 years).
NMFS believes pursuit of the PBPA alternative in an environment that includes migration of the
barrier island and sea level rise would eventually result in one or more bridges located within the
surf zone. While NCDOT views such bridges as "technically feasible" from an engineering
standpoint, NMFS views such bridges as potentially posing a significant threat to marine
resources. The South Atlantic Fishery Management Council (SAFMC) designated intertidal
sandy beach and surf zone as essential fish habitat (EFH) for red drum, and the Mid-Atlantic
Fishery Management Council (MAFMC) has designated these habitats as EFH for bluefish and
summer flounder. Waters offshore of the project area also provide EFH for coastal pelagic
species, such as cobia, king mackerel, and Spanish mackerel, which are managed by the SAFMC,
and for highly migratory species, such as tunas and sharks, which are managed directly by
NMFS.
NCDOT has not been able to fully describe, and hence analyze, the affect of the bridges on surf
zone habitat due, in part, to the paucity of information about this habitat and it use by fishery
resources. Crashing waves, strong longshore and rip currents, and the preponderance of
unconsolidated sediments makes it very difficult to sample adequately within the surf zone. As a
result, our understanding of the use of this habitat by fish and invertebrates greatly lags our
understanding of most other inshore areas.
Hackney et al. (1996) provide the most recent review of the scant scientific literature that is
available about the surf zone. Surf zones typically harbor a diverse fish fauna. Nearly 50 species
of fish have been reported from the surf zone of North Carolina beaches, including many species
that are commercially or recreationally important or serve as prey for such species. This number
is suspected to be considerably lower than the actual number because over 130 species of fish
have been recorded in studies of the surf zone with South Carolina and Georgia. Many of the life
stages of fish found within the surf zone are also found in nearby estuaries, suggesting that the
surf zone is a nursery habitat; Florida pompano and kingfish are the species most likely to rely
upon the surf zone as their principal nursery habitat. Late spring to early summer is the major
recruitment period for larval and juvenile fish to the surf zone, which is later than the period of
maximal recruitment to estuarine nursery areas. In terms of biomass, peak use of the surf zone
occurs in the fall when juvenile and adult fish leave estuaries and migrate along the coast. It is
generally thought that use of the surf zone as a migratory corridor is vastly under documented
with respect to their actual use. The more common fish within the surf zone consume both
benthic invertebrates and plankton. Siphon cropping (grazing) also has been reported among surf
zone fish when clams, such as coquina clams, were present. If siphon cropping is common,
reported rates of secondary production within the surf zone would likely be underestimates if the
measurements were based only on standing-stock biomass. In short, little is known about the
value of surf zone habitat to fish, but the limited literature that is available suggests the value is
high.
In the absence of data to the contrary, NMFS is concerned that as the beach erodes, the bridge
supports would ultimately end up in the surf zone and could significantly affect the ecological
services that surf zone habitat provides fish along a stretch of beach that may eventually be 10
miles or longer. Construction of bridges parallel to an eroding beach is an engineering challenge.
If at a future date, one or more of these bridges become unstable, we are concerned that beach
nourishment would likely be pursued to stabilize the bridge. This is problematic because it is
inconsistent with the management plan for PINWR and impacts to NOAA trust resources within
the fill and borrow areas have not been adequately addressed in the environmental documents
produced thus far. Such assessments seem essential to any determinations of long-term cost or
practicability.
Summary of Recent Consultation History
By letter dated April 17, 2007, NMFS provided NCDOT, FHWA, and the COE with comments
on the SDEIS and SSDEIS. Prior to the concurrence meeting on August 15, 2007, NMFS
participated in a conference call on July 11, 2007 with NCDOT and the COE to discuss our
concerns. NCDOT drafted minutes from this meeting, and NNMFS revised that draft to more
clearly reflect the concerns expressed. NCDOT distributed the revised minutes in various formats
leading up to the meeting on August 15.
Citation
Hackney, CT, MH Posey, SW Ross and AR Norris (editors). 1996. A review and synthesis of
data on surf zone fishes and invertebrates in the South Atlantic Bight and the potential impacts
from beach nourishment. Final Report to the Wilmington District, US Army Corps of Engineers.
5. Relevant Laws or Regulations
As the nation's federal trustee for the conservation and management of marine, estuarine, and
anadromous fishery resources, NMFS provides comments and recommendations pursuant to
authorities of the Fish and Wildlife Coordination Act and the Magnuson-Stevens Fishery
Conservation and Management Act (Magnuson-Stevens Act). This highway project will
ultimately require authorization by the COE, and the review process will include consultation
between the NMFS and the COE to address our concerns about the impacts to EFH.
6. Alternative Course of Action
The NMFS raised concerns in our comments on the SDEIS and SSDEIS that, to date, have not
been addressed. NMFS supports selection of the PSB as the LEPDA because we believe that it
avoids the need for long-term maintenance of NC 12 and overall would have that least adverse
impact to NOAA trust resources. However, we understand that cost is a component of the project
planning process and will consider other alternatives that avoid and minimize adverse impacts to
NOAA trust resources. For additional coordination, comments or concerns please contact:
Ron Sechler
National Marine Fisheries Service (NMFS)
101 Pivers Island Road
Beaufort, North Carolina 28516
252-728-5090 or [e-mail]
so United States Department of the Interior
NATIONAL PARK SERVICE
Fort Raleigh National Historic Site Wright Brothers National Memorial
Cape Hatteras National Seashore
IN REPLY REFER TO: 1401 National Park Drive
L7621 (CAHA) Manteo, NC 27954
252-473-2111
May 31, 2007
Beth Smyre
Project Development Engineer
NC Department of Transportation
Project Development & Environmental Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
Dear Ms. Smyre:
NATIONAL
PARK
SERVICE
As requested at the May 23, 2007, Merger Team meeting regarding TIP No. B-2500 (Replacement of
Herbert C. Bonner Bridge over Oregon Inlet, Dare County) and as called for under the Merger 01 Roles
and Responsibilities Guidance, this letter explains the basis for the non-concurrence of the National Park
Service (NPS) with the Parallel Bridge Corridor with Phased .Approach/ Rodanthe Bridge alternative that
has been proposed by the NC Department of Transportation (NCDOT) as the Least Environmentally
Damaging Practicable Alternative (LEDPA).
The Supplement to the 2005 Supplemental Draft Environmental Impact Statement (SSDEIS), dated
February 14, 2007, describes the current range of alternatives for the proposed project, including
NCDOT's recommended LEDPA. The Department of the Interior (DOI) has previously expressed
concerns regarding the various alternatives in letters dated February 13, 2006, and April 27, 2007.
Additionally, the Secretary of Interior sent a letter to U.S. Senator Burr regarding the Bonner Bridge
project on July 5, 2006. Copies of these letters are attached. To date, NCDOT has provided neither
written nor verbal responses to a number of potentially significant environmental concerns expressed in
the previous letters, including concerns about the alternative that has since been recommended as the
LEPDA. Since it is currently unclear how NCDOT views the concerns or what options may be available
to resolve them, NPS cannot at this time concur that the proposal is the least environmentally damaging
practicable alternative.
NPS is eager to continue to work with the NCDOT and the other partner agencies to move the review
process forward, and we appreciate your continued attention to this matter. Should you have any
questions regarding these comments, please contact me.
Sincerely,
Michael B. Murray
Superintendent
Attachments
AMERICAA
Merger 01 Process
Issue Brief
Prepared by US Fish and Wildlife Service (Raleigh FO and Pea Island National Wildlife Refuge)
Project Name and Brief Description: Replacement of Herbert C. Bonner Bridge over
Oregon Inlet, Dare County; TIP B-2500
2. Last Concurrence Point (signed): CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT has recommended the Parallel Bridge Corridor with Phased Approach/Rodanthe
Bridge Alternative as the project's Least Environmentally Damaging Practicable
Alternative (LEDPA). In addition to a 2.6 mile bridge over Oregon Inlet, a series of
elevated bridges totaling 11.9 miles would be constructed on NC 12 through the Pea` Island
National Wildlife Refuge (Refuge). The U.S. Fish and Wildlife Service (Service) does not
concur with NCDOT's choice for the LEDPA.
4. Explain the reasons for you potential non-concurrence. Please include any data or
information that would substantiate and support your position.
While Secretary of Interior Kempthorne has stated that a short parallel bridge over the
Oregon Inlet can be constructed and could likely be found compatible with the mission of
the Refuge, compatibility remains as a significant statutory concern for the remainder of
NC 12 through the Refuge. Since maintenance of the existing highway has not been
conducted within the confines of the existing right-of-way in the past, and since the
Supplement to the 2005 Supplemental DEIS refers to utilization of all options for
maintenance, we remain unconvinced that the highway can be maintained and the Phased
Approach bridges constructed within the existing right-of-way between now and beyond
2030.
To date, the NCDOT has provided very limited written and verbal responses to the
numerous concerns expressed in our previous correspondence. As such, those concerns
remain unresolved. One of the specific, unaddressed concerns is the anticipated adverse
impacts to Refuge lands and fish and wildlife resources outside the existing right-of-way.
Based on the information in the Supplement to the 2005 Supplemental DEIS for the
portion of NC 12 in the Refuge, we calculate that approximately 27% of the habitat
currently remaining in the Refuge is subject to utilization for the transportation corridor
over the life of the proposed project. The direct, indirect and cumulative impacts, resulting
from this much utilization of the Refuge, are likely to materially interfere with or detract
from the fulfillment of the National Wildlife Refuge System Mission and the Refuge
Purpose, and therefore the project is not likely to be compatible with the mission of the
Refuge. If a proposed use is not compatible, it cannot be permitted per the National
Wildlife Refuge System Improvement Act of 1997.
List any relevant laws or regulations that you believe would be violated or jeopardized if
the proposed action were implemented and explain the basis for violation. Please attach a
copy of the relevant portion of the law or regulation or provide an email address where
the documents may be located.
National Wildlife Refuge System Improvement Act of 1997 - this can be found at:
http://frwebgate.access.gpo.gov/cgi-
bin/getdoc.c6?dbname=105 cons public laws&docid=f:publ57.pdf
Also see the following websites:
http://-tvww.fws.2ov/policy/603fwl.html
http://www.fws.gov/policy/603fw2.htmi
http: /hvww.fws.2ov/policy/340fw3.htm l
http://www.access.2po.2ov/nara/cfr/waisidx 03/50cfr29 03.html
6. What alternative course of action do you recommend?
The Service continues to support all efforts to expeditiously replace the Bonner Bridge, as
expressed in the July 5, 2006, letters from Secretary Kempthorne to Senator Burr and
Governor Easley. The Service could endorse an alternative that would replace the Bonner
Bridge if it did not limit future options regarding NC-12 to those that adversely affect the
Refuge and thus could not be reconciled with federal.law. The phased-approach as
currently conceived would necessarily result in substantial adverse impacts to the Refuge.
We remain open to additional information, but given the information we have to date, we
find it unlikely we could find this alternative to be compatible with the purposes for which
the Refuge was established, as required under the Refuge Improvement Act. Of the
alternatives currently under consideration, and based on current available information, the
Pamlico Sound Bridge Corridor is the only alternative that appears to be constructible in
compliance with applicable law; therefore, the Service recommends the Pamlico Sound
Bridge Corridor as the LEDPA.
2
Merger 01 Process
Issue Briefing Format
Prepared by the NC Division of Water Quality (updated 08/20/07)
1. Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed: CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT is recommending the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the project's Least Environmentally
Damaging Practicable Alternative (LEDPA). At the May 23, 2007 Merger Team
meeting, DWQ concurred with the first Phase of this alternative, the parallel (i.e.
short) bridge across Oregon Inlet. In addition, DWQ supports the concept of
phasing the ultimate implementation of the project along the NC 12 corridor.
However, DWQ does not support the proposed construction of permanent
bridges along NC 12 in locations that are projected to be in the Atlantic Ocean
during the project's planning period. Our reasons for this position are discussed
below. .
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
As previously indicated, the DWQ supports a parallel bridge (i.e. short bridge)
alternative. In addition, we support an approach that results in a project whose
implementation is phased in some manner. However, we do not concur with an
alternative that will result in the construction of bridges that will ultimately be in
the active wave zone of the Atlantic Ocean. It is DWQ's opinion that the presence
of bridges in the active wave zone of the ocean could result in a loss of existing
uses.
The NC Environmental Management Commission has classified the Atlantic
Ocean for the project area as SB waters. SB waters are classified as Surface
waters that are used for primary recreation, including frequent or organized
swimming and all Class SC uses. Class SC waters are all tidal salt waters
protected for secondary recreation such as fishing, boating and other activities
involving minimal skin contact; aquatic life propagation and survival; and wildlife.
DWQ believes that bridges in the near shore area could result in a loss of the
aforementioned existing recreational uses.
In addition, based on comments made by NOAA's National Marine Fisheries at
the May 23, 2007 Merger Team meeting, as well as verbal communications with
other resource agencies, DWQ has concerns that aquatic life uses (especially
fisheries resources) may be adversely impacted by the presence of permanent
bridges in the near shore ocean.
The third potential problem with the proposed alternative relates to stormwater
and stormwater treatment. Bridges located in the ocean would have limited
opportunities for proper stormwater treatment prior to discharging into the
Atlantic Ocean. After discussions with the Division of Environmental Health, it is
clear that an untreated discharge would necessitate posting a sign warning that
the beach may not be safe for recreational activities. In this'scenario, the
Division of Water Quality would be precluded from issuing a 401 Water Quality
Certification because it would constitute a loss of existing use. Since it is not
clear at this time if appropriate stormwater treatment could be achieved without
additionally development of the roadway and drainage design, DWQ believes it
imprudent to concur with the alternative being proposed by the NC Department of
Transportation.
Without the requested information along with the aforementioned potential loss
of existing uses, DWQ cannot concur with DOT's preferred alternative at this
time.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
15A NCAC 02H.0500, http://h2o.enr.state.nc.us/admin/rules/2H.0500.pdf.
15A NCAC 0213.0200,
htta://h2o.enr.state.nc.usladm i n/rules/documents/rb080104.r)df.
15A NCAC 2H .1000, http://h2o.enr.state.nc.us/admin/rules/2H. 1000.pdf
6. What alternative course of action do you recommend?
DWQ recommends that the Merger Team concur with a parallel bridge alternative
(i.e. short bridge) corridor with some type of new phased approach alternative. In
Section 2.2 of the Supplemental Draft Environmental Impacts Statement, DOT
acknowledges that the form of the ultimate phased approach was subject to
possible change due to uncertainties associated with the dynamic
geomorphologic nature of the area. Section 2.2 states "Although the Phased
Approach alternatives are described and addressed in this Supplement as a
phased alternative with specific locations and lengths for the phases.... these
details could be adjusted based on funding availability and the changing
conditions within the project area, recognizing the uncertainty of predicting
future shoreline conditions." Thus, it seems logical that a phased approach that
allowed for final decision-making more close in time to the actual impacts could
be developed more fully and described in the EIS. It is acknowledged that this
approach will necessitate some type of phased permitting process. However, the
issuance of phased permits is not without precedent and is used for projects .
where the availability of funds to construct the project in its entirety is not
immediately available. Using that fundamental premise, it seems logical that this
project could be authorized using a similar approach so long as the scope of the
initial permit included the NC 12 corridor and the estimated impacts for the later
phases of the. project were quantified in the EIS and application in an appropriate
manner. The advantages of the recommended course of action are: 1) it would
allow for the bridge design and construction to proceed immediately, 2) it would
allow for a more accurate identification and quantification of environmental
impacts because the time of impact assessment would occur more closely to the
time of impact, 3) it would improve the decision-making process by deferring
decisions until a time more closely aligned with the availability of funding, and
thus increasing the level of certainty when quantifying the potential
environmental impacts, 4) it would allow for the inclusion of other ongoing
studies (TIP R-3116, TIP R-31161), TIP R-311GE, TIP R-3116F) along NC 12 to be
incorporated into the decision-making process for NC 12, and 5) it would allow for
the inclusion of work being undertaken by the Outer Banks Task Force to develop
long-range solutions for the area.
From Werger01: Roles and Responsibilities" guidance document.
"If an organization decides to either non-concur or abstain, that organization is
responsible for documenting its reasons in writing and providing that documentation to
all Project Team Members within 5 business days of the Project Team meeting."
Merger 01 Process
Issue Brief
Prepared by the N.C. Division of Coastal Management, 6/1/07
1. Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed): CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT is recommending the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the project's Least Environmentally
Damaging Practicable Alternative. (LED PA). At the 5/23/07 NEPA/404 project team
meeting, DCM did concur with Phase I of this alternative, which is a bridge across
Oregon Inlet. However, DCM did not concur with subsequent phases of this
project, which are elevating portions of NC 12 through the Refuge and northern
Rodanthe on new bridges within the existing NC 12 easement. DCM's position is
that construction of permanent bridges in a location that is, projected to be in the
ocean on or before the project's design year would be inconsistent with the most
basic principles of the Coastal Area Management Act (CAMA) and the Rules of
the Coastal Resources Commission (CRC).
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
DCM does not believe that the two Parallel Bridge Corridor with Phased Approach
Alternatives that are presented in the 2007 Supplement are fiscally, socially and
environmentally responsible. DCM's biggest concern with these alternatives is
the phased NC 12 maintenance bridges. NCDOT's determination that the phased
NC 12 maintenance bridges are practicable is largely based upon the projected
position of the shoreline in the year 2060. However, the shoreline of North
Carolina's Outer Banks can change dramatically with a single storm event. For
example, during the time period of September 9, 1960 through March 28, 1962 the
erosion averaged between 200 and 389 feet per year, but repaired itself, through
natural processes, over approximately the next three years. In addition, if the
rate of sea level rise is increasing as quickly as reported in current scientific
literature, then the 2060 shoreline may be further west than is currently predicted.
We would anticipate that some of the phased NC 12 maintenance bridges as
proposed could be in the ocean shortly after they are constructed.
The Herbert C. Bonner Bridge and NC Highway 12 within the project study area
are located in one of the State's most significant and volatile natural
DCM Issue Brief, TIP No. B-2500, Page 1 of 4, 6/1/07
environments. The transportation link that the Herbert C. Bonner Bridge and the
connecting NC Highway 12 provide between Hatteras Island and Bodie Island is a
critical component in the safety of the residents and visitors of Hatteras Island
and Ocracoke Island, and the economic vitality of the Outer Banks. DCM believes
that the phased NC 12 maintenance bridges will have unacceptable impacts to the
natural and the human environment.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
All of the alternatives being studied for TIP No. B-2500 will impact CAMA Areas of
Environmental Concern (AEC's). Therefore, any alternative that is selected as the
LEDPA will require a CAMA major permit. It is possible that the location of such a
massive, permanent structure like the Bonner Bridge and NC Highway 12 within
the Outer Banks coastal ecosystem could prevent any of the alternatives being
studied for TIP No. B-2500 from complying completely with the Rules of the CRC.
Therefore, it is possible that DCM will.need to deny a CAMA permit application for
any of the alternatives for procedural reasons. In that situation, NCDOT would
have the option of petitioning the CRC for a variance to undertake a project that is
prohibited by the CRC's development standards. A petition for a variance
recognizes the legal restrictions as valid, but requests an exception to the
restrictions because of hardships resulting from unusual conditions. A final,,.
permit decision must be made before a petition for a variance can be submitted.
DCM will work closely with the NEPA/404 project team to ensure that whatever
alternative is selected as the LEDPA complies with the rules of the CRC to the
maximum extent practicable.
The state laws and/or regulations that may be violated or jeopardized by
construction of the two Parallel Bridge Corridor with Phased Approach
Alternatives include, but are not necessarily limited to, those that are referenced
below. The full text of the state law (CAMA) and the Rules of the CRC may be
found at the DCM web site.
The link to CAMA is: http://www.nccoastaimanagement.net/Ruies/cama.htm.
The link to the Rules of the CRC is:
http://www.nccoastalmanagement.net/Rules/Text/tl5a 07h.pdf.
Coastal Area Management Act, G.S. 113A-115.1.
The statute requires that "no person shall construct a permanent erosion
control structure in an ocean shoreline". DCM would need to carefully
consider whether or not retaining walls for bridge approaches qualify under
the exception to this statute, as set out in the North Carolina Administrative
Code [15A NCAC 07H .0308 (a)(1)(H)] Specific Use Standards for Ocean Hazard
Areas, Ocean Shoreline Erosion Control Activities.
DCM Issue Brief, TIP No. B-2500, Page 2 of 4, 6/1/07
Management Objectives of the Ocean Hazard Area of Environmental Concern
fNCAC 15A 07H .0303(b)].
For example, the management objectives state that: "....The purpose of these
Rules shall be to further the goals set out in G.S. 113A-102(b), with particular
attention to minimizing losses to life and property resulting from storms and
long-term erosion, preventing encroachment of permanent structures on
public beach areas, preserving the natural ecological conditions of the barrier
dune and beach systems, and reducing the public costs of inappropriately
sited development...."
¦ Erosion Setbacks for Oceanfront Construction fNCAC 15A 07H .0306(a)(4
"Because large structures located immediately along the Atlantic Ocean
present increased risk of loss of life and property, increased potential for
eventual loss or damage to the public beach area and other important natural
features along the oceanfront, increased potential for higher public costs for
federal flood insurance, erosion control, storm protection, disaster relief and
provision of public services such as water and sewer, and increased difficulty
and expense of relocation in the event of future shoreline loss, a greater
oceanfront setback is required for these structures than is the case with
smaller structures. Therefore, in addition to meeting the criteria in this Rule
for setback landward of the primary or frontal dune or both the primary and.
frontal dunes, for all multi-family residential structures (including motels,
hotels, condominiums and moteliminiums) of more than 5,000 square feettotal
floor„area, and for any non-residential structure with a total area of more than
5,owsquare feet, the erosion setback line shall be twice the erosion setback
as established in Subparagraph (a)(1) of this Rule, provided that in no case.
shall this distance be less than 120 feet. In areas where the rate is more than
3.5 feet per year, this setback line shall be set at a distance of 30 times the
long-term annual erosion rate plus 105 feet."
.
Public Trust Areas, 15A NCAC 07H.0306(h)
Construction of phased NC 12 maintenance bridges appears to eliminate
much of the access to public trust areas that is currently available within the
project study area. This is contrary to 15A NCAC 07H.0306(h) which states:
"Development shall not interfere with legal access to, or use of, public
resources nor shall such development increase the risk of damage to public
trust areas."
Imminently Threatened Structures, 15A NCAC 07H .0306(1) and Temporary
Erosion Control Structures, 15A NCAC 07H .0308(2)(B).
15A NCAC 07H .0306(1) states that: "Permits shall include the condition that
any structure shall be relocated or dismantled when it becomes imminently
threatened by changes in shoreline configuration as defined in .0308(2)(B).
The structure(s) shall be relocated or dismantled within two years of the time
when it becomes imminently threatened, and in any case upon its collapse or
subsidence. However, if natural shoreline recovery or beach renourishment
DCM Issue Brief, TIP No. B-2500, Page 3 of 4, 6/1/07
takes place within two years of the time the structure becomes imminently
threatened, so that the structure is no longer imminently threatened, then it
need not be relocated or dismantled at that time. This condition shall not
affect the permit holder's right to seek authorization of temporary protective
measures allowed under Rule .0308(a)(2) of this Section."
15A NCAC 07H .0308(2)(B) states that: "Temporary erosion control structures
as defined in Part (2)(A) of this Subparagraph may be used to protect only
imminently threatened roads and associated right of ways, and buildings and
associated septic systems. A structure will be considered to be imminently
threatened if its foundation, septic system, or right-of-way in the case of
roads, is less than 20 feet away from the erosion scarp. Buildings and roads
located more than 20 feet from the erosion scarp or in areas where there is no
obvious erosion scarp may also be found to be imminently threatened when
site conditions, such as a flat beach profile or accelerated erosion, tend to
increase the risk of imminent damage to the structure. "
6. What alternative course of action do you recommend?
DCM recommends that the NEPA/404 project team concur with a new Parallel
Bridge Corridor Phased Approach alternative similar to what is described in the
opening discussion of Section 2.2 of the 2007 Supplement on pages 2-3 and 24. ,
This section states that: "Although the Phased Approach alternatives are
described and`addressed in this Supplement as a phased alternative with specific
locations and lengths for the phases.... these details could be adjusted based on
funding availability and the changing conditions within the project area,
recognizing the uncertainty of predicting future shoreline conditions." The new
alternative would include the Oregon Inlet Bridge as Phase I and would include
various options for maintaining NC Highway 12 throughout the rest of the project
study area throughout the design year. The choice of the final option or options
for the subsequent phases would be deferred until a later date. This alternative
would have the following advantages: (1) it would allow NCDOT to proceed with
final design of the Oregon Inlet Bridge; (2) it would provide a detailed
environmental analysis of the various options under consideration for NC
Highway 12 maintenance within the project study area; and (3) it would allow the
NEPA1404 project team to act quickly when a decision on alternatives for
subsequent phases is warranted.
DCM Issue Brief, TIP No. B-2500, Page 4 of 4, 6/1/07
Merger 01 Process
Issue Brief
Prepared by the N.C. Division of Marine Fisheries,
August 17, 2007
1. Project Name and Brief Description: Replacement of Herbert C. Bonner
Bridge over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed): CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT recommends the Parallel Bridge Corridor with Phased
Approach/Rodanthe Alternative as the projects Least Environmentally
Damaging Practicable Alternative (LEDPA). DMF concurs with Phase I of
this alternative, the parallel bridge across Oregon Inlet. In addition, DMF
supports the concept of phasing the later implementation of the project
within the existing NC 12 corridor. However, DMF is concerned with
future construction of permanent bridges along the NC 12 easement in
locations that are projected to be in the Atlantic Ocean during the
project's designed lifetime. The reasons for this agency's position are
discussed below.
4. Explain the reasons for your potential non-concurrence. Please include any
data.or information that would substantiate and support your position.
As previously indicated, the DMF supports the parallel bridge
alternative. In addition, we support an approach that results in a project
that is constructed in a phased manner. However, DMF does not concur
with an alternative that will result in the construction of bridges that will
ultimately be in the active surf zone of the Atlantic Ocean as indicated
by analyses conducted by other agency members of this merger team.
Such an approach would result in the loss of existing uses and impacts
to marine fisheries resources, their associated habitats and the human
environment. Also comments made by Clarence Coleman, FHWA at the
August 15, 2007 merger meeting, that if changes were needed in the
phased approach by Phase II or Phase III construction time period,
those changes could be made. Even though the merger team would be
reconvened at that time, the current team cannot evaluate the possible
future impacts or issues with great certainty at this time.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulations
or provide an email address where the documents may be located.
None under the N.C. Marine Fisheries Commission jurisdiction
6. What alternative course of action do you recommend?
The DMF recommends that the Merger Team concur with the parallel
bridge alternative corridor with some type of new phased approach
alternative that relegates major decisions on those phases to a time
closer to their implementation so that more precise information will be
available to guide the decision making process. The NCDOT
acknowledges in Section 2.2 of the Supplemental DEIS that the form of
the ultimate phased approach was subject to possible change due to
uncertainties associated with the dynamic nature of the area. This
Section states "Although the Phased Approach alternatives are
described and addressed in this Supplement as a phased alternative
with specific locations and lengths for the phases ...these details could
be adjusted based on funding availability and the changing conditions
within the project area, recognizing the uncertainty of predicting future
shoreline conditions." An alternative for Phase I would include the
replacement of the Oregon Inlet bridge and various options to maintain
Hwy. 12 for the remaining project area throughout the design lifetime.
The final option or options for subsequent phases would be determined
at a later time providing better assessment of actual conditions and
impacts. Pursuing this alternative would have the following advantages:
(1) NCDOT could proceed with final design and construction of the
Oregon Inlet bridge; (2) a detailed environmental analysis could be
provided of the various options under consideration and the impacts
closer to the implementation of a given phase within the study area; and
(3) this approach would allow the decision making process by the team
to occur in a timely manner when a decision on alternatives for
additional phases was actually required.
Issue Briefing
State Historic Preservation Office/Department of Cultural Resources
1. Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed: CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position.
It is our understanding from the Concurrence Point 3 meeting held on August 15,
2007 and the materials provided for that meeting that the North Carolina Department
of Transportation (NCDOT) recommends the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the project's Least Environmentally
Damaging Project Alternative (LEDPA) and NCDOT's Preferred Alternative.
The State Historic Preservation Office is abstaining from Concurrence Point 3.
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
Given that the proposed Parallel' Bridge Corridor with Phased Approach/Rodanthe
Bridge Alternative will adversely affect all of the National Register-listed and eligible
historic properties within the undertaking's area of potential effects (Oregon Inlet
Coast Guard Station, Pea Island Wildlife Refuge, and the Rodanthe Historic District,
which includes the Chicamacomico Life Saving Station), it is the most damaging to
historic properties. The Pamlico Sound Bridge Corridor will also adversely affect the
Oregon Inlet Coast Guard Station, but will have no effect on the Pea Island Wildlife
Refuge and no adverse effect on the Rodanthe Historic District, including the life
saving station.
As the agency charged with consideration of historic resources, but not having a
regulatory role in the merger process, we respectively abstain from Concurrence
Point 3. We are prepared to continue with both the Section 106 and Merger 01
processes, once the LEDPA has been selected.

INLAND. FISH
Fax:[phone]

Aug 22 2007 15:56 P,02:1
92 North Carolina Wildlife Resources Commission 0
MEMORANDUIYI
TO: Beth Smyre, Project Planning Engineer, NCDOT
NC Department of Transportation
Project Development and Environmental Analysis
1548 Mail Service Center
Raleigh, NC 27699.1548
And
Bill Biddlecome, Merger T'ea,m Co-Chair, USACE
Washington Regulatory Field Office
P.O. Box 100
Washington, NC 27889-1000
FROM: Fred Harris, Interim Executive Director
NC Wildlife Resources Commission
DATE: August 21, 2007
SUBJECT: Replacement of He ert C. Bonner Bridge over Oregon Inlet in Dare County, North
Carolina, 'TIP number B-2500. Concurrence point 3, selection of the Least
Environmentally Damaging Pjacticable Alternative: Abstention Brief
The North Carolina Department of Transportation (NCDOT) is proposing the Parallel
Bridge Corridor with Phased Approach/Rodanthe Bridge Alternative as the Least Environmentally
Damaging Practicable Alternative (LEDPA). NCDOT presented the merger team with
information outlining the economic feasibility of the detailed study alternatives. The new
information eliminates the feasibility of the North Carolina Wildlife Resources Commission's
previously preferred alternative with the only remaining practicable alternatives consisting of a
parallel bridge replacement with various options to maintain NC 12 through Pea Island National
Wildlife Refuge.
-'Mailing Address: Division of inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
1NLHND FISH Fax:[phone] Aug 22 2007 1556 P.03
Bonner Bridge Page 2 August 21, 2007
We detailed our concerns with all parallel bridge.alternatives in addition to specific
concerns "th the phased approach alternatives in our letters of 17 January 2006 and 16 March
2007 respectively. In summary; potential direct and cumulative impacts to baiTisr island habitats
and the numerous species that depend upon these habitats are significant.. Due. to these projected
impacts we are. unable to select a LEDP.A, from the remaining f6asible alternatives; therefore We
abstain from the Merger 01 concurrence point three, selection ofa LEDPA, for B-2500
replacement of Herbert C. Bonner. Bridge.
Ec;
Chris.Militscher; USEPA
Ron Sechler, NMI~
Pete Benjamin,-U'SFWS
Mike Bryant 'U. SFWS-PINWR
John Hennessy, Dt Q
Jirrc.Gregsori,lCly(
Mike Street, DMF
Mike Murray,.NPS
Clarence Coleman, FHWA
Renee Gledhill-Earley, SHOO
Melba McGee, DENR (m ith attachments)
0
w

Merger 01 Process
Issue Brief
Prepared by the N.C. Division of Coastal Management, 6/1/07
1. Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed`
Date of Concurrence: Octobr
3. Explain what is being p, -.Tu g on including what you object to.
NCDOT is recomme, rridor with Phased
Approach/Rodanth, project's Least Environmentally
Damaging Practicabik. At the 5/23/07 NEPA/404 project team
meeting, DCM did conc. ,r this alternative, which is a bridge across
Oregon Inlet. However, L concur with subsequent phases of this
project, which are elevating, , is of NC 12 through the Refuge and northern
Rodanthe on new bridges wits, the existing NC 12 easement. DCM's position is
that construction of permanent bridges in a location that is projected to be in the
ocean on or before the project's design year would be inconsistent with the most
basic principles of the Coastal Area Management Act (CAMA) and the Rules of
the Coastal Resources Commission (CRC).
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
DCM does not believe that the two Parallel Bridge Corridor with Phased Approach
Alternatives that are presented in the 2007 Supplement are fiscally, socially and
environmentally responsible. DCM's biggest concern with these alternatives is
the phased NC 12 maintenance bridges. NCDOT's determination that the phased
NC 12 maintenance bridges are practicable is largely based upon the projected
position of the shoreline in the year 2060. However, the shoreline of North
Carolina's Outer Banks can change dramatically with a single storm event. For
example, during the time period of September 9, 1960 through March 28, 1962 the
erosion averaged between 200 and 389 feet per year, but repaired itself, through
natural processes, over approximately the next three years. In addition, if the
rate of sea level rise is increasing as quickly as reported in current scientific
literature, then the 2060 shoreline may be further west than is currently predicted.
We would anticipate that some of the phased NC 12 maintenance bridges as
proposed could be in the ocean shortly after they are constructed.
The Herbert C. Bonner Bridge and NC Highway 12 within the project study area
are located in one of the State's most significant and volatile natural
DCM Issue Brief, TIP No. B-2500, Page 1 of 4, 6/1/07
environments. The transportation link that the Herbert C. Bonner Bridge and the
connecting NC Highway 12 provide between Hatteras Island and Bodie Island is a
critical component in the safety of the residents and visitors of Hatteras Island
and Ocracoke Island, and the economic vitality of the Outer Banks. DCM believes
that the phased NC 12 maintenance bridges will have unacceptable impacts to the
natural and the human environment.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
All of the alternatives being studied for TIP No. B-2500 will impact CAMA Areas of
Environmental Concern (AEC's). Therefore, any alternative that is selected as the
LEDPA will require a CAMA major permit. It is possible that the location of such a
massive, permanent structure like the Bonner Bridge and NC Highway 12 within
the Outer Banks coastal ecosystem could prevent any of the alternatives being
studied for TIP No. B-2500 from complying completely with the Rules of the CRC.
Therefore, it is possible that DCM will need to deny a CAMA permit application for
any of the alternatives for procedural reasons. In that situation, NCDOT would
have the option of petitioning the CRC for a variance to undertake a project that is
prohibited by the CRC's development standards. A petition for a variance
recognizes the legal restrictions as valid, but requests an exception to the
restrictions because of hardships resulting from unusual conditions. A final
permit decision must be made beforea petition for a variance can be submitted.
DCM will work closely with the NEPA/404 project team to ensure that whatever
alternative is selected as the LEDPA complies with the rules of the CRC to the
maximum extent practicable.
The state laws and/or regulations that may be violated or jeopardized by
construction of the two Parallel Bridge Corridor with Phased Approach
Alternatives include, but are not necessarily limited to, those that are referenced
below. The full text of the state law (CAMA) and the Rules of the CRC may be
found at the DCM web site.
The link to CAMA is: http:l/www.nccoastalmanagement.net/Rules/cama.htm.
The link to the Rules of the CRC is:
http://www.nccoastaimanagement.net/Ruies/Text/tl5a 07h.pdf.
Coastal Area Management Act, G.S. 113A-115.1.
The statute requires that "no person shall construct a permanent erosion
control structure in an ocean shoreline". DCM would need to carefully
consider whether or not retaining walls for bridge approaches qualify under
the exception to this statute, as set out in the North Carolina Administrative
Code [15A NCAC 07H .0308 (a)(1)(H)] Specific Use Standards for Ocean Hazard
Areas, Ocean Shoreline Erosion Control Activities.
DCM Issue Brief, TIP No. B-2500, Page 2 of 4, 6/1/07
Management Objectives of the Ocean Hazard Area of Environmental Concern
FNCAC 15A 07H .0303(b)l.
For example, the management objectives state that: "....The purpose of these
Rules shall be to further the goals set out in G.S. 113A-102(b), with particular
attention to minimizing losses to life and property resulting from storms and
long-term erosion, preventing encroachment of permanent structures on
public beach areas, preserving the natural ecological conditions of the barrier
dune and beach systems, and reducing the public costs of inappropriately
sited development...."
Erosion Setbacks for Oceanfront Construction FNCAC 15A 07H .0306(a)(4)1.
"Because large structures located immediately along the Atlantic Ocean
present increased risk of loss of life and property, increased potential for
eventual loss or damage to the public beach area and other important natural
features along the oceanfront, increased potential for higher public costs for
federal flood insurance, erosion control, storm protection, disaster relief and
provision of public services such. as water and sewer, and increased difficulty
and expense of relocation in the event of future shoreline loss, a greater
oceanfront setback is required for these structures than is the case with
smaller structures. Therefore, in addition to meeting the criteria in this Rule
for setback landward of the primary or frontal dune or both the primary and
frontal dunes, for all multi-family residential structures (including motels,
hotels, condominiums and moteliminiums) of more than 5,000 square feet total
floor area, and for any non-residential structure with a total area of more than
5,000 square feet, the erosion setback line-shall be twice the erosion setback
as established in Subparagraph (a)(1) of this Rule, provided that in no case
shall this distance be less than 120 feet. In areas where the rate is more than
3.5 feet per year, this setback line shall be set at a distance of 30 times the
long-term annual erosion rate plus 105 feet."
Public Trust Areas, 15A NCAC 07H .0306(h).
Construction of phased NC 12 maintenance bridges appears to eliminate
much of the access to public trust areas that is currently available within the
project study area. This is contrary to 15A NCAC 07H .0306(h) which states:
"Development shall not interfere with legal access to, or use of, public
resources nor shall such development increase the risk of damage to public
trust areas."
Imminently Threatened Structures, 15A NCAC 07H .0306(1) and Temporary
Erosion Control Structures, 15A NCAC 07H .0308(2)(B).
15A NCAC 07H .0306(1) states that: "Permits shall include the. condition that
any structure shall be relocated or dismantled when it becomes imminently
threatened by changes in shoreline configuration as defined in .0308(2)(B).
The structure(s) shall be relocated or dismantled within two years of the time
when it becomes imminently threatened, and in any case upon its collapse or
subsidence. However, if natural shoreline recovery or beach renourishment
DCM Issue Brief, TIP No. B-2500, Page 3 of 4, 6/1/07
takes place within two years of the time the structure becomes imminently
threatened, so that the structure is no longer imminently threatened, then it
need not be relocated or dismantled at that time. This condition shall not
affect the permit holder's right to seek authorization of temporary protective
measures allowed under Rule .0308(a)(2) of this Section."
15A NCAC 07H .0308(2)(B) states that: "Temporary erosion control structures
as defined in Part (2)(A) of this Subparagraph may be used to protect only
imminently threatened roads and associated right of ways, and buildings and
associated septic systems. A structure will be considered to be imminently
threatened if its foundation, septic system, or right-of-way in the case of
roads, is less than 20 feet away from the erosion scarp. Buildings and roads
located more than 20 feet from the erosion scarp or in areas where there is no
obvious erosion scarp may also be found to be imminently threatened when
site conditions, such as a flat beach profile or accelerated erosion, tend to
increase the risk of imminent damage to the structure. "
6. What alternative course of action do you recommend?
DCM recommends that the NEPA1404 project team concur with a new Parallel
Bridge Corridor Phased Approach alternative similar to what is described in the
opening discussion of Section 2.2 of the 2007 Supplement on pages 2-3 and 2-4.
This section states that: "Although the Phased Approach alternatives are
described and addressed in this Supplement as a phased alternative with specific
locations and lengths for the phases.... these details could be adjusted based on
funding availability and the changing conditions within the project area,
recognizing the uncertainty of predicting future shoreline conditions." The new
alternative would include the Oregon Inlet Bridge as Phase I and would include
various options for maintaining NC Highway 12 throughout the rest of the project
study area throughout the design year. The choice of the final option or options
for the subsequent phases would be deferred until a later date. This alternative
would have the following advantages: (1) it would allow NCDOT to proceed with
final design of the Oregon Inlet Bridge; (2) it would provide a detailed
environmental analysis of the various options under consideration for NC
Highway 12 maintenance within the project study area; and (3) it would allow the
NEPA/404 project team to act quickly when a decision on alternatives for
subsequent phases is warranted.
DCM Issue Brief, TIP No. B-2500, Page 4 of 4, 6/1/07
A#V_0: Reminder

Subject: Re: B-2500: Reminder
From: [e-mail]
Date: Wed, 22 Aug 2007 09:04:23 -0400
To: Beth Smyre <[e-mail]. nc.us>
CC: Brian Yamamoto <byam.amoto@.dot.state.nc.us>, Cathy Brittingham
<Cathy.Brittingham iicinail.net>, Clarence Coleman <[e-mail]>, David Cox
<david.cox cc•ncwildlife.org>, David Wainwright <[e-mail]>, "Deborah M.
Barbour PE" <[e-mail]>, Dennis Stewart <dennis stewart c Avs.gov>, Doug Huggett
<Doug.Huggett a,ncmail.net>, Gary Jordan <[e-mail]>, Greg Thorpe
<gthorpe cr dot. state.nc.us>, Julie Hunkins <[e-mail]>, Jim Gregson.
<[e-mail]>, Jim Hoadley <[e-mail]>, John Hennessy
<[e-mail]>, Lori Kroll <lkroll@.dot.state.nc.us>, Kathy Matthews
<matthews.kathy @epamail.epa.gov>, Mike Street <mike.street @ncmail.net>, Mike Bryant
<mike [e-mail]>, Mike Murray <Mike_Murray cr,nps.gov>, Chris Militscher
<[e-mail]>, Pete Benjamin <[e-mail]>, Renee
Gledhill-Earley <[e-mail]>, Rob Hanson <[e-mail]>, Ron
Lucas <ron.lucas a,fhwa.dot.gov>, Ron Seehler <Ron.Sechler a noaa.gov>, Sarah McBride
<[e-mail]>, Sara Winslow <sara.wir slow @ncmail.net>, Scott McLendon
<[e-mail]>, Travis Wilson <[e-mail]>, Bill
Biddlecome <[e-mail]'e.army, rn l>
As follow-up to the August 15, 2007 Merger Team Meeting for 2-2500, the
National Park Service briefing comments, submitted May 31, 2007, do not
need to be updated and still represent National Park Service's concerns
with the proposed project. If you have any questions, please call me.
Thayer Broili
Chief of Resource Management
Cape Hatteras National Seashore
Phone [phone] ext.137
Fax [phone]
Beth Smyre
<[e-mail] To: Bill Biddlecome
<[e-mail]>, Clarence Coleman
.nc.us> <[e-mail]>, John
Hennessy <[e-mail]>, Jim Gregson
<[e-mail]>, Chris
Militscher <[e-mail]>, Ron Sechler
08/16/2007 03:27 <[e-mail]>, Mike Murray
<_Mike [e-mail]>, Mike Bryant <mike [e-mail]>,
PM AST Pete Benjamin
<[e-mail]>, Renee Gledhill-Earley
<Renee.Gledhill-Earley@.ncmail.net>,
Mike Street <[e-mail]>, David Cox
<[e-mail]>
CC: Scott McLendon
<[e-mail]>, Ron Lucas
<[e-mail]>, David
Wainwright <[e-mail]>, Cathy Brittingham
<[e-mail]>, Jim
Hoadley <[e-mail]>, Doug Huggett
<[e-mail]>, Kathy
8/22/2007 2:30 PM
Rem BL?0: Reminder
Matthews <[e-mail]>, Thayer B.roili
<Thayer [e-mail]>, Dennis
Stewart <dennis [e-mail]>, Gary Jordan
<gary [e-mail]>, Sarah McBride
<[e-mail]>, Sara Winslow
<[e-mail]>, Travis
Wilson <travis..wilso_n@ncwildlife.o_?2>, Lori Kroll
<[e-mail]>, "Deborah M.
Barbour PE" <[e-mail]>, Julie Hunkins
<[e-mail]>, Greg
Thorpe <[e-mail]>, Rob Hanson
Yamamoto <[e-mail]>
<[e-mail]>, Brian
Subject: B-2500: Reminder
B-2500 Merger Team Members:
Just a reminder of what is needed following yesterday's
meeting: all agencies that either abstained or did not concur
with the NCDOT preferred alternative (Phased Approach/ Rodanthe
Bridge) need to submit (by email is fine) an updated or new Issue
Brief to me by the close of business on Wednesday, August 22.
(Based on yesterday's vote, all team members will need to submit
a brief. FHWA and NCDOT will also be submitting position papers.)
If you feel that the brief you submitted in May does not need to
be updated, simply send me an email stating so.
Since the Review Board meeting is on August 27, it is
critical that we receive all briefs by the 22nd.
Please let me know if you have any questions!
Thanks,
Beth
Beth Smyre, P.E.
Project Planning Engineer
NC Department of Transportation
Project Development & Environmental Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
[phone] ext. 333
2 of 2 8/22/2007 2:30 PM
JR , %
Merger 01 Process
Issue Briefing Format
Prepared by the NC Division of Water Quality (updated 08/20/07)
Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed): CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT is recommending the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the project's Least Environmentally
Damaging Practicable Alternative (LEDPA). At the May 23, 2007 Merger Team
meeting, DWQ concurred with the first Phase of this alternative, the parallel (i.e.
short) bridge across Oregon Inlet. In addition, DWQ supports the concept of
phasing the ultimate implementation of the project along the NC 12 corridor.
However, DWQ does not support the proposed construction of permanent
bridges along NC 12 in locations that are projected to be in the Atlantic Ocean
during the project's planning period. Our reasons for this position are discussed
below.
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
As previously indicated, the DWQ supports a parallel bridge (i.e. short bridge)
alternative. In addition, we support an approach that results in a project whose
implementation is phased in some manner. However, we do not concur with an
alternative that will result in the construction of bridges that will ultimately be in
the active wave zone of the Atlantic Ocean. It is DWQ's opinion that the presence
of bridges in the active wave zone of the ocean could result in a loss of existing
uses.
The NC Environmental Management Commission has classified the Atlantic
Ocean for the project area as SB waters. SB waters are classified as Surface
waters that are used for primary recreation, including frequent or organized
swimming and all Class SC uses. Class SC waters are all tidal salt waters
protected for secondary recreation such as fishing, boating and other activities
involving minimal skin contact; aquatic life propagation and survival; and wildlife.
DWQ believes that bridges in the near shore area could result in a loss of the
aforementioned existing recreational uses.
In addition, based on comments made by NOAA's National Marine Fisheries at
the May 23, 2007 Merger Team meeting, as well as verbal communications with
A -4
other resource agencies, DWQ has concerns that aquatic life uses (especially
fisheries resources) may be adversely impacted by the presence of permanent
bridges in the near shore ocean.
The third potential problem with the proposed alternative relates to stormwater
and stormwater treatment. Bridges located in the ocean would have limited
opportunities for proper stormwater treatment prior to discharging into the
Atlantic Ocean. After discussions with the Division of Environmental Health, it is
clear that an untreated discharge would necessitate posting a sign warning that
the beach may not be safe for recreational activities. In this scenario, the
Division of Water Quality would be precluded from issuing a 401 Water Quality
Certification because it would constitute a loss of existing use. Since it is not
clear at this time if appropriate stormwater treatment could be achieved without
additionally development of the roadway and drainage design, DWQ believes it
imprudent to concur with the alternative being proposed by the NC Department of
Transportation.
Without the requested information along with the aforementioned potential loss
of existing uses, DWQ cannot concur with DOT's preferred alternative at this
time.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
15A NCAC 02H.0500, http://h2o.enr.state.nc.us/admin/rules/2H.0500.pdf.
15A NCAC 0213.0200,
http://h2o.enr.state.nc.us/admin/rules/documents/rb080l O4.pdf.
15A NCAC 2H .1000, http://h2o.enr.state.ne.us/admin/rules/2H. 1000.pdf
6. What alternative course of action do you recommend?
DWQ recommends that the Merger Team concur with a parallel bridge alternative
(i.e. short bridge) corridor with some type of new phased approach alternative. In
Section 2.2 of the Supplemental Draft Environmental Impacts Statement, DOT
acknowledges that the form of the ultimate phased approach was subject to
possible change due to uncertainties associated with the dynamic
geomorphologic nature of the area. Section 2.2 states "Although the Phased
Approach alternatives are described and addressed in this Supplement as a
phased alternative with specific locations and lengths for the phases.... these
details could be adjusted based on funding availability and the changing
d,..
conditions within the project area, recognizing the uncertainty of predicting
future shoreline conditions." Thus, it seems logical that a phased approach that
allowed for final decision-making more close in time to the actual impacts could
be developed more fully and described in the EIS. It is acknowledged that this
approach will necessitate some type of phased permitting process. However, the
issuance of phased permits is not without precedent and is used for projects
where the availability of funds to construct the project in its entirety is not
immediately available. Using that fundamental premise, it seems logical that this
project could be authorized using a similar approach so long as the scope of the
initial permit included the NC 12 corridor and the estimated impacts for the later
phases of the project were quantified in the EIS and application in an appropriate
manner. The advantages of the recommended course of action are: 1) it would
allow for the bridge design and construction to proceed immediately, 2) it would
allow for a more accurate identification and quantification of environmental
impacts because the time of impact assessment would occur more closely to the
time of impact, 3) it would improve the decision-making process by deferring
decisions until a time more closely aligned with the availability of funding, and
thus increasing the level of certainty when quantifying the potential
environmental impacts, 4) it would allow for the inclusion of other ongoing
studies (TIP R-3116, TIP R-31161), TIP R-3116E, TIP R-3116F) along NC 12 to be
incorporated into the decision-making process for NC 12, and 5) it would allow for
the inclusion of work being undertaken by the Outer Banks Task Force to develop
long-range solutions for the area.
From Werger01: Roles and Responsibilities" guidance document:
"If an organization decides to either non-concur or abstain, that organization is
responsible for documenting its reasons in writing and providing that documentation to
all Project Team Members within 5 business days of the Project Team meeting."
SECTION 404/NEPA MERGER 01 ELEVATION ISSUE BRIEF: 8/22/07
Submitted by: Christopher A. Militscher, REM, CHMM
Merger Team Representative
USEPA Raleigh Office
THRU: Heinz J. Mueller, Chief
NEPA Program Office
USEPA Region 4
Thomas C. Welborn, Chief
Wetlands, Coastal Protection Branch
USEPA Region 4
To: Merger 01 Review Board Members
Beth Smyre, P.E., Project Planning Engineer
Planning Development and Environmental Analysis Branch
NCDOT
Cc: Kathy Matthews, USEPA Wetlands Section
1. Project Name and Brief Description: TIP No.: B-2500, NC 12 Replacement of
Herbert C. Bonner Bridge over Oregon Inlet; Dare County.
2. Last Concurrence Point (signed): CP 2 Detailed Study Alternatives Carried Forward
Date of Concurrence Point 2 Meeting: 10/13/04
3. Proposal and Position: NCDOT & FHWA propose to select the Parallel Bridge
Corridor/Phased Approach Rodanthe Bridge (PBC/PA-RB) Alternative for the LEDPA.
EPA has previously identified one of the Pamlico Sound Bridge Corridor (PSBC)
Alternatives as its environmentally preferred alternative ("LEDPA") and had assigned
Environmental Objections (EO) rating to the PBC Alternatives. At the August 15, 2007,
meeting on the LEDPA, the EPA Merger team representative could not agree or disagree
(Unsure) as to the "Practicability" issue under USACE Regulatory Guidance Letter 93-02
and 40 CRF Part 230. 1 0(a)(2) for the PSBC Alternative. EPA cannot concur with the
PBC/PA-RB as the LEDPA*.
4. Reasons for Non-concurrence:
The `practicability' of the PSBC alternative has been potentially undermined by a
lack of coordinated planning and funding initiatives during the past 5 years of the NEPA
process. According to NCDOT's potential funding options for the replacement of
Bonner Bridge, the total available funds from 2007-2013 for Division 1 projects is
approximately $575 million. Funding restriction under the State's Equity formula {by
themselves) do not provide a reasonable basis for elimination under RGL 93-02 and 40
CFR Part 230 [The determination of what constitutes an unreasonable expense should
generally consider whether the projected cost is substantially greater than the costs
normally associated with the particular type of project; RGL 93-02 (3)(b)]. In this
context, long bridge alternatives are generally more expense than non-bridge projects and
that the cost of the fully implemented PBC/PA-RB alternative is also more than $1
billion. However, EPA also recognizes that the preamble to the Guidelines also states
that: [...if an alleged alternative is unreasonably expensive to the applicant, the
alternative is not `practicable']. Thus, EPA is unsure as to "Practicability" involving the
PSBC alternative. EPA has previously stated that the PSBC alternative is the `Least
Environmentally Damaging' {to Aquatic Resources of National Importance - ARNI) of
the two detailed study corridor alternatives (PBC-PA and PSBC) carried forward in the
2007 Supplement to Supplemental DEIS (2007 SSDEIS).
Furthermore, numerous projects in the Merger 01 process have been carried
forward through the Concurrence Point 3/LEDPA selection without full funding
commitments within the TIP and that individually their projects' costs sometimes
exceeded the State Equity formula requirements. The alternatives that were considered
for the LEDPA for these projects were not eliminated by the respective project teams,
including FHWA, NCDOT, ACE and DWQ, based solely upon Section 404(b)(1)
Guidelines consideration of "unreasonably expensive to the applicant".
The specific LEDPA definition contained in the Merger 01 Agreement does not
contain any specific reference to project costs, unreasonableness of project costs, the
availability of funding, or the State's Equity formula requirements. Under Merger 01,
alternatives that are advanced through the detailed study phase (Concurrence point 2)
under the Merger process are all `reasonable' and `feasible' alternatives under NEPA and
Section 404 and that the lead Federal agency can select one of these detailed study
alternatives as their `preferred' alternative following the issuance of the draft NEPA
document [...and for alternatives which were eliminated from detailed study, briefly
discuss the reasons for their having been eliminated; 40 CFR Part 1502.14(a)].
While EPA concurs with FHWA and NCDOT that the cost of bridge construction
in general has escalated beyond typical inflation within the last few years, these cost
trends should have been `reasonably foreseeable' under NEPA and should have been
further explored, defined and disclosed in the February 2007 SSDEIS. This is also true
on the disclosure of the State Equity formula requirements (Existing since 1989) and how
this project's alternatives could impact future TIP funding cycles in Division 1.
EPA also recognizes that certain costs for both the PSBC and PBC/PA-RB
alternatives have increased dramatically due to the reasons provided in the Bonner Bridge
Preliminary Cost reports from June of 2007. However, the increase in the width (typical
section) of the PSBC alternative from 36 feet to 40 feet appears to be one of the key
contributions to the changes in the cost estimates. This approximate 10% increase in
material cost for the PSBC alternative is making construction of the PSBC alternative
appear "less practicable" with respect to total project costs. NCDOT and FHWA have
not provided a full, detailed rationale ("Safety concerns") as to the need to increase the
typical width of a long bridge. Other 2-lane bridges in North Carolina have 6-foot
shoulders (or less). EPA is uncertain as to why other potentially less expense design
alternatives were not considered in the 2005 SDEIS or 2007 SSDEIS. Some of the
independent contractor cost estimates provided to FHWA and NCDOT were based on
two bridge projects (i.e., Interstate 10 Escambia Bay in Florida and Lake Pontchartrain
Causeway Bridge in Louisiana). EPA understands that one was 60-feet wide and the
other was 52-feet wide. While it was stated that the costs were `unit priced', EPA is
uncertain that there are not other increased `unit' costs associated with supporting larger
(heavier) structures (e.g., Larger support columns, additional spans, etc.).
EPA cannot concur with NCDOT and FHWA that the PBC/PA-RB Alternative
can meet the approved purpose and need for the project. EPA also has concerns that
FHWA has potentially misunderstood our use of an "Adaptive Management
Approach". Adaptive Management Approach should include those potential solutions
and alternatives that may have been dismissed in the past as unreasonable under NEPA,
but may now have merit considering the current issues of "practicability" and "permit-
ability". Based upon current research from renowned coastal geology experts, the NC 12
corridor in the long term appears to be a `failing corridor' given the project's vulnerable
coastal setting". The transportation agencies need to adapt their plans to the evolving
natural conditions. Adaptive management in EPA's viewpoint is not just "phasing" of
what has been a typical approach to maintaining NC 12: building more bridges or
rebuilding NC 12 through sand replacement after every major storm event.
The transportation agencies need to be proactive and work on longer-term options
regarding the public's expectation that the NC 12 highway corridor on Hatteras Island
and a northern access to PINWR may not always be available to them. Serious
consideration needs to be given to an expanded ferry service, and not just for
emergencies. EPA and other agencies have recognized that additional infrastructure in
this dynamic coastal landscape will continue to place an unreasonable burden on
transportation agencies to reliably, cost-effectively and safely operate and maintain the
NC 12 corridor within PINWR in the future.
EPA has continuing environmental concerns as to how the Lead Federal Agency
(FHWA) can proceed with the proposed PBC/PA-RB Alternative without first resolving
NEPA cross-cutting issues under the National Wildlife Refuge System Improvement Act,
the Endangered Species Act, the Migratory Bird Treaty Act, Essential Fish Habitat -
Magnuson-Stevens Act, etc. These specific legal/policy issues need to be adequately
resolved under the aforementioned Federal acts before a Clean Water Act Section 404
"LEDPA" can be selected, and approved by the ACE. These factors should be as much a
part of "practicability" as is the cost factor.
EPA has cited previous and unchanged environmental concerns for drastically
increasing the long-term commitment of infrastructure along a dynamic and
unpredictable barrier island system, including specifically the PBC/PA-RB Alternative.
EPA is uncertain how avoidance and minimization measures required under the Section
404(b)(1) Guidelines can be fully developed for the PBC/PA-RB Alternative.
EPA does not have any specific informational need requests at this time and is
reviewing the August 2, 2007, additional information package provided by NCDOT at
the August 15, 2007, LEDPA meeting, including the supplemental information on the
PSBC and PCB/PA-RB operations and maintenance cost projections.
5. Potentially Violated Laws/Regulations: The following EPA regulations apply to this
action: Section 1502.14, et al. of 40 CFR, CEQ National Environmental Policy Act
regulations and Section 404(b)(1) of the Clean Water Act.
6. Alternative Course of Action: EPA recommends that the B-2500 Merger project
team be re-directed by the Review Board to re-open CP 2 and re-evaluate the option of
providing a `short-bridge', strict replacement project ("Phase I" only) in conjunction
with a specific and detailed Adaptive Management Approach that would be phase
based on conditions and that longer-term include the `planned' and `timed'
implementation of a permanent ferry service between Hatteras Island and Bodie Island
(and potentially with other mainland ferry terminals). The longer-term primary objective
of the Adaptive Management plan would be the eventual and `strategic' abandonment of
the NC 12 corridor though PINWR. This approach should be planned and timed on a
number of pre-determined factors, including impact thresholds to PINWR, maintenance
and repair costs, the number and intensity of storm-related breaches, the actual shoreline
erosion rates, the `useful' life of the new replacement bridge, etc. However, this
Adaptive Management plan would need to have very specific implementation goals in the
FHWA's Record of Decision (e.g., A permanent ferry service established per detailed
criteria in the Adaptive Management plan). EPA also recommends that NCDOT and
FHWA continue to pursue innovative avoidance and minimization strategies for the
impacts from a `short bridge' that go well beyond the `typical' measures that are included
in other Merger projects. EPA would also propose that NCDOT and the Merger team
consider adding full representation from the NCDOT's Ferry Division in order to insure
that timely and expert advice is available to the team during the development of an
Adaptive Management plan.
* EPA continues to have significant environmental concerns regarding the PBC/PA Alternatives,
including the impacts of placing 25-foot high bridges along the beach, in the surf zone, in PINWR,
and affecting the near shore ocean which is an ARNI and impacting recreational uses, sea turtle
nesting, essential fish habitat, etc. EPA does not concur that construction for 12.5 out of 25 years for
the PBC/PA alternative within PINWR can be compatible with FWS's mission. Building any
additional bridges along the NC 12 corridor beyond the existing Bonner Bridge may not be consistent
with environmentally-sound principles and cost-effective solutions for the long-term transportation
needs of Hatteras Island. EPA continues to have environmental concerns regarding the completion
of requested analyses (e.g., Scour modeling, updated SLR analysis) that have not been provided to
date.
** 6/1/07 NCDCM Merger 01 Issue Brief, Item #4. Also, on September 18, 2003, Hurricane Isabel
(Category 2 at the time of landfall between Cape Lookout and Ocracoke Island in N.C.) caused a
2,000-foot breach along NC 12 (referred to as the "Hatteras Inlet") just north of Rodanthe. This
breach forced the closure of NC 12 between Hatteras Island and Bodie Island for two months while
repairs were being made by NCDOT. The direct repair cost of this one event was estimated at $11
million. Other severe storm events that damaged NC 12 in the last 25 years include Hurricanes Alex
(8/2004), Emily (9/1993), and Gloria (9/1985). This short list does not include `minor' hurricanes,
`nor-easters', tropical depressions and storms and other severe weather conditions that have
impacted the Outer Banks.
too
YEARS
To:
From:
Date:
Subject:
Attendees:
August 15, 2007 Bonner Bridge Merger Team Meeting Attendees
Bill Rice, PB
August 20, 2007
Meeting Minutes - August 15, 2007 Merger Team Meeting for the Bonner
Bridge Replacement Project (TIP No. B-2500)
Adrian Cox
Margery Overton
Clarence Coleman*
Ron Lucas
Tom Drda
Ron Sechler*
Thayer Broili**
Lisa Glover
Renee Gledhill-Earley*
Robin Smith
Mary Penny Thompson
Amy Simes
Jim Gregson*
Cathy Brittingham
John Hennessy*
David Wainwright
Sara Winslow**
Rodger Rochelle
Nilesh Surti
Don Idol
Daniel Holderman
Christian Brill
Teresa Bruton
Jerry Jennings
Clay Willis
Mohammed Mulla
Don Moore
Ed Lewis
Matt Wilkerson
Elizabeth Lusk
Michael Turchy
Chris Rivenbark
Julie Hunkins
Deborah Anderson
Albemarle RPO
FDH
FHWA - NC Division
FHWA - NC Division
FHWA - NC Division
National Marine Fisheries Service
National Park Service
NC Attorney General's Office - NCDOT
NCDCR - SHPO
NCDENR
NCDENR
NCDENR
NCDENR - DCM
NCDENR - DCM
NCDENR - DWQ
NCDENR - DWQ
NCDENR - DMF
NCDOT - Alternative Delivery Unit
NCDOT - Alternative Delivery Unit
NCDOT - Bridge Maintenance Unit
NCDOT - Bridge Maintenance Unit
NCDOT - Communications Office
NCDOT - DB (Alternative Delivery Unit)
NCDOT - Division 1
NCDOT - Division 1
NCDOT - Geotechnical
NCDOT - Geotechnical
NCDOT - Human Environment Unit
NCDOT - Human Environment Unit
NCDOT - Natural Environment Unit
NCDOT - Natural Environment Unit
NCDOT - Natural Environment Unit
NCDOT - OEQ
NCDOT-PDEA
Over a Century of
Engineering Excellence
moo
YEARS
Page 2
Minutes: August 15, 2007 Merger Team Meeting for Bonner Bridge
Beth Smyre* NCDOT -PDEA
Brian Yamamoto NCDOT - PDEA
Rob Hanson NCDOT - PDEA
Greg Thorpe NCDOT - PDEA
Eileen Fuchs NCDOT - Human Environment Unit
Debbie Barbour NCDOT - Preconstruction
Mark Staley NCDOT - Roadside Environmental Unit
Scott Blevins NCDOT - Roadway Design
Byron Kyle NCDOT - Roadway Design
Lori Kroll NCDOT - Secretary's Office
Lonnie Brooks NCDOT - Structure Design Unit
Paul Garrett NCDOT - Structure Design Unit
Ray McIntyre NCDOT - TIP Development Unit
Robert Memory NCDOT - Utilities Coordination Unit
Travis Wilson** NCWRC
John Page PB
Bill Rice PB
Bobby Norburn PB
Scott McLendon US Army Corps of Engineers (via phone)
Ken Jolly US Army Corps of Engineers
Bill Biddlecome* US Army Corps of Engineers
Christopher A. Militscher* USEPA
Kathy Matthews USEPA
Pete Jerome** USFWS - Atlanta Office
Dennis Stewart USFWS - Pea Island National Wildlife Refuge
Gary Jordan** USFWS - Raleigh Field Office
*B-2500 Merger Team Member
**B-2500 Merger Team Member Substitute
The meeting began at 2:00 PM in the Board Room of the NCDOT Transportation Building.
Bill Biddlecome started the meeting by saying that the purpose of the meeting was to obtain
the decisions of the attending agencies on the concurrence with the Least Environmentally
Damaging Practicable Alternative (LEDPA) proposed by NCDOT and FHWA. Bill said the
meeting would have the following parts:
• A review of activity since the May 23, 2007 Merger Meeting;
• The posing of an additional question by NCDOT regarding the agencies' positions on the
Pamlico Sound Corridor;
• A presentation by FHWA on the flexibility of the NEPA process in adapting project phases
to changing conditions;
• Request for concurrence with NCDOT's Preferred Alternative as the LEDPA; and
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• If concurrence is not reached, a description of the elevation process and the requirements
for updated Issue Briefs.
Bill Biddlecome said that any agency decision on the LEDPA should be based on the
information that has been provided up to this point. He also said that responding agencies did
not need to cite at the meeting the reasons for their concurrence decision but were welcome to
do so if they wished. Bill introduced Julie Hunkins of NCDOT and indicated that she would
serve as a facilitator for a portion of the meeting.
Review of Activity Since the May 23 Merger Meeting
Beth Smyre provided a review of the project's activity since the last meeting on May 23, 2007.
Following the May meeting, all agencies that did not concur with the NCDOT Preferred
Alternative submitted Issue Briefs stating their agency's position. One of the main concerns
noted during the meeting and included in the Issue Briefs dealt with project costs and funding
availability. The June 20, 2007 meeting briefed the Merger Team on potential funding sources
as well as the development of the cost estimates in the Supplement to the Supplemental Draft
Environmental Impact Statement (SSDEIS). Following the June meeting, only the USEPA
asked an additional question related to cost, asking for more information on the project's
operations and maintenance costs. This information was included in the packet provided to the
Merger Team on August 2. Also, since the June 20 Merger Team briefing, NCDOT held
individual meetings with several agencies to discuss their concerns. Minutes from those
meetings also were included in the August 2 packet. The August 2 packet also included a table
that lists the major agency questions that seemed to be the key concerns related to concurrence
as well as NCDOT's responses to each of the concerns. The Corps of Engineers submitted
additional questions to NCDOT on August 13; those questions and NCDOT's responses were
distributed to meeting participants and briefly described by Beth. That handout is attached to
these minutes.
Additional Question by NCDOT
Julie Hunkins facilitated this portion of the meeting. Julie asked the meeting participants
whether they agreed that the Pamlico Sound Bridge Corridor Alternative is not "practicable"
and therefore ineligible for consideration as the project LEDPA. Bill Biddlecome said that a
positive response to this question would not be an indication that the responder felt the Phased
Approach Alternative with Rodanthe Bridge Alternative was the LEDPA.
6
Dennis Stewart asked the definition of a LEDPA. Clarence Coleman said that the acronym
LEDPA is not a NEPA term, though NEPA does require identification of a preferred
alternative. Beth Smyre read the definition of a LEDPA from the Section 404INEPA Merger
01 Process Information Glossary of Terms, in which LEDPA is defined as:
"Based upon the Clean Water Act Section 404(b)(1) Guidelines, the LEDPA is the
preferred alternative that is least damaging to aquatic resources (i.e., Wetlands and other
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waters of the U.S.), unless this alternative results in other significant adverse impacts. The
evaluation of practicable alternatives must consider the impact to waters of the U.S. that
would result from an alternative before compensatory mitigation is considered and requires
the selection of an alternative that avoids and minimizes impacts to wetlands and other
waters of the U.S. The Section 404(b)(1) Guidelines require that the LEDPA to aquatic
resources be chosen unless this alternative results in other significant environmental
consequences. Impacts to other resources such as residential and business relocations,
historic resources, endangered species, and public community facilities, may be considered
in selecting the LEDPA. The selection of a LEDPA also occurs after the public and other
parties have had an opportunity to review and comment on alternatives under consideration
in an USACE Public Notice or an environmental document. In the Merger 01 process, the
selection of the LEDPA is Concurrence Point 3."
To clarify the definition of practicable as related to LEDPA, Bill Biddlecome read from 40
CFR 230.3(q) which states that:
"The term practicable means available and capable of being done after taking into
consideration cost, existing technology, and logistics in light of overall project purposes."
Bill noted that the preamble to the guidelines clarifies how cost is to be considered. Chris
Militscher then asked for further clarification. In response, Beth Smyre read from Section
404INEPA Merger 01 Process Information Glossary of Terms, which states that practicable is
defined as:
"Available and capable of being done after taking into consideration cost, existing
technology, and logistics in light of overall project purposes. Practical means capable of
being used or put into effect. The difference between practical and practicable lies in the
feasibility of an action. Practicable means "feasible as well as "usable". An action may
be practical but not practicable."
Renee Gledhill-Early asked why NCDOT was asking the question. Julie Hunkins said it was
felt that an answer would clarify subsequent discussion.
The following responses were given to the question: Do you agree that the Pamlico Sound
Bridge Corridor Alternative is not "practicable" and therefore ineligible for consideration as
the project LEDPA?
• NCDOT - Yes
• FHWA -- Yes
• USACE - Yes, but the Corps still feels the Pamlico Sound Corridor is the least
environmentally damaging alternative
• USEPA - Unsure
• NPS - No
• USFWS - No
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• PINWR - No
• NMFS - No
• NCDENR-DWQ - Yes
• NCDENR-DCM - Yes, based on practicability and cost information.
• NCWRC - Abstain
• NCDENR-DMF - Yes
• NCDCR-SHPO - No
Clarence Coleman asked for the reasons that some agencies answered "no" and why they think
that the Pamlico Sound Bridge Corridor Alternative is a practicable alternative. Bill
Biddlecome cited his earlier comments in which he stated that respondents did not have to give
reasons for their positions. Clarence affirmed that approach, saying that he would not question
a position that the Pamlico Sound Bridge Corridor Alternative was the Least Environmentally
Damaging Alternative (LEDA) part, but he would be interested in knowing why some agencies
felt the alternative was practicable if agency representatives would like to explain.
Chris Militscher said that the definition of practicability discusses how costs are to be applied
and asked if the Pamlico Sound Bridge Corridor Alternative costs more than other bridges of
similar length. Chris indicated that the LEDPA for the Western Wake Expressway was
selected even when it was known that there were insufficient funds to construct it and the
state's equity formula also applied to that project. Ray McIntyre said that the equity formula
did not apply to urban loops and that the Pamlico Sound Bridge Corridor Alternative could not
be built in phases like an urban loop. Chris said that he thinks that the Pamlico Sound Bridge
Corridor Alternative could be built in phases and that is why the EPA is unsure on whether or
not the Pamlico Sound Bridge Corridor Alternative is practicable or not.
Ron Sechler stated that as a resource agency, the NMFS is charged with protecting resources
that they are responsible for. He feels that, at his level, he is not in the position to make a
practicability judgment based on cost, though he does not dispute the information that was
provided. It is not the NMFS's charge to make this decision.
Clarence Coleman said that the Pamlico Sound Bridge Corridor Alternative would have been
carried forward to its current point even knowing that the NCDOT could not build it because of
affordability, and he felt it likely that the agencies would have urged NCDOT and FHWA to
do so. Pete Jerome said the Pea Island National Wildlife Refuge's position on the Pamlico
Sound Bridge Corridor Alternative is reflected in USFWS issue briefs. Thayer Broili and
Renee Gledhill-Early echoed Pete's position. (Note: Upon review of the May 2007 Issue Briefs
from the US Fish & Wildlife Service, the National Park Service, and the State Historic
Preservation Office, no position on the practicability of the Pamlico Sound Alternative was
noted)
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Minutes: August 15, 2007 Merger Team Meeting for Bonner Bridge
Review of Phased Approach/ Rodanthe Bridge Alternative and
Flexibility within NEPA
Beth Smyre reviewed the components of the Parallel Bridge with Phased Approach/Rodanthe
Bridge Alternative. Beth indicated that the phasing, specifically the length of the bridging,
could change based on actual future shoreline movement.
Clarence Coleman described the FHWA procedures that would apply to each phase after
Phase I (Oregon Inlet Bridge) that would provide the flexibility to change the project as the
setting evolves. Clarence said that, should three years transpire between the completion of one
phase and any activity associated with the subsequent phase, consultation with the FHWA as
well as a written re-evaluation of the project, its setting (e.g. new protected species), and its
impact would occur based on the requirement of NEPA regulations (23 CFR 771.129). If
based on the re-evaluation, it is decided that another alternative assessed in detail in the FEIS
should be built, the Record of Decision (ROD) would be revised and the other alternative
implemented. This is standard FHWA procedure for adaptive management that involves no
stretching or bending of NEPA regulations. If changes warrant the consideration of
alternatives not assessed in detail in the FEIS, then an additional supplemental EIS can be
prepared.
Bill Biddlecome asked for a further description of how the three-year rule is applied. Clarence
Coleman stated, as an example, if the Oregon Inlet bridge (Phase 1) were built from 2010 to
2013 and no action was taken to move Phase 11 forward until 2016, then a re-evaluation would
be required. Bill asked if the project had to be dormant for a re-evaluation to occur. Clarence
said no, that each phase of the project would be a new federal action. If three years of
inactivity had not occurred between phases, then the requirement for consultation with FHWA
by NCDOT found in 23 CFR 771.129(c) would apply. The consultation process could
conclude that revisions to the ROD or an additional EIS supplement was warranted.
Scott McClendon asked Clarence Coleman if changes in the decision on the alternative to
implement in a future phase would be subject to public and agency comments. Clarence
Coleman said the change would be subject to internal dialogue between FHWA and NCDOT.
(Note: According to FHWA Technical Advisory T6640.8A, Section XI- Reevaluations,
appropriate coordination with other agencies should be undertaken to address any new
impacts or issues, and the results included in the written evaluation.)
Ron Sechler asked for affirmation that a totally different alternative could be considered in
subsequent phases. Clarence indicated, yes, under the NEPA documentation conditions just
described. Ed Lewis asked if authorization is required for right-of-way acquisition; Clarence
stated that the process is the same. Cathy Brittingham asked if the Merger Team would be
involved in the decision to change alternatives. Clarence said that procedural requirements
would be met.
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Minutes: August 15, 2007 Merger Team Meeting for Bonner Bridge
Request for Concurrence with NCDOT Preferred Alternative
Bill Biddlecome then asked for agency concurrence with the Parallel Bridge with Phased
Approach/Rodanthe Bridge Alternative as the LEDPA. The responses were:
• NCDOT - Yes
• FHWA - Yes
• USACE - No
• USEPA - No, but indicated that they could concur with a phased approach alternative, just
not the one defined by NCDOT
• NPS - No
• USFWS - No
• P1NWR - No
• NMFS - No
• NCDENR-DWQ - No, but indicated that they could concur with a phased approach
alternative, just not the one defined by NCDOT
• NCDENR-DCM - No
• NCWRC - Abstain
• NCDENR-DMF - No, but indicated that they could concur with a phased approach
alternative, just not the one defined by NCDOT
• NCDCR-SHPO - Abstain
Concurrence was not achieved. Beth Smyre asked the meeting participants if there were any
further comments; none were offered.
Elevation Process
Beth Smyre said that the LEDPA decision will be elevated based on the Section 404/NEPA
Merger 01 Process Guidelines. NCDOT requested updated or new Issue Briefs from all non-
concurring or abstaining agencies by August 22, 2007. No late Issue Briefs would be accepted.
Beth said that NCDOT and FHWA also will develop Issue Briefs. Beth said that the Merger
Implementation Team, normally the first level in the elevation process, had agreed to elevate
the decision to the Review Board. The Review Board will meet on August 27, 2007 at 2:30
PM. Beth said a decision on who would be invited to the Review Board meeting has not yet
been made, but she will inform those who are invited by email. Clarence Coleman requested
that all Issue Briefs submitted be clear, use the format in the Merger 01 guidance, be specific,
be complete, and not refer to previous letters or briefs.
Renee Gledhill-Early asked if Issue Briefs should be submitted that address responses to the
question of whether the Pamlico Sound Bridge Corridor Alternative is a practicable alternative.
Beth Smyre said that the issue briefs need only discuss the LEDPA decision, not the Pamlico
Sound Bridge Corridor practicability question. Travis Wilson asked what format should be
used by those that abstain. Beth Smyre stated that an abstention brief can be in a different
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Minutes: August 15, 2007 Merger Team Meeting for Bonner Bridge
format. Ken Jolly noted in closing that permit decisions are made by the USACE, and they
will not delegate that responsibility.
Bill Biddlecome adjourned the meeting.
attachment: USACE key concerns and responses
PB file no.: 3301-2.7.2
JAPLANNING\Bonner SDEIS\Stakeholder Involvement\Merger Meetings\8-15-07 Merger Meeting\Bonner Merger Team
Meeting Minutes (8-15-07) Draft.doe
Over a Century of
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HYDRAULICS DESIGN/PERMIT DRAWINGS REVIEW
Hydraulics Conference Room
NCDOT Century Center Complex
August 22, 2007
Y
9:00 Clawson R-2633A, US 17/Wilmington Bypass from NC 87
South of Bishop to US 74-76 East of Malmo
New Hanover County, Division 3
4B Hydraulic Design Review
Team Members: Jennifer Frye- USACE
Gary Jordan- USFWS
Travis Wilson- NCWRC
Cathy Brittingham- NCDCM
Steve Sollod- NCDCM
David Wainwright- NCDWQ
Chris Militscher- EPA
Kathy Matthews- EPA
Donnie Brew- FHWA
Cathy Houser- Roadway
Lonnie I. Brooks- Structures
Derrick G. Weaver- PDEA
Rachelle L. Beauregard- NEU
David Harris- REU
Joe Blair- Division 3
10:30 Clawson R-2633B, US 18/Wimington Bypass from US 74-76
East of Malmo in Brunswick County to US 421 North
of Wilmington in New Hanover County
Brunswick County, Division 3
413 Hydraulic Design Review
Team Members: Jennifer Frye- USACE
Gary Jordan- USFWS
Travis Wilson-NCWRC
Cathy Brittingham- NCDCM
Steve Sollod- NCDCM
,P'David Wainwright- NCDWQ
-Chris Militscher- EPA
Kathy Matthews- EPA
Donnie Brew- FHWA
Bryan D. Taylor-Roadway
Lonnie I. Brooks- Structures
Derrick G. Weaver- PDEA
Rachelle L. Beaurgard- NEU
David Harris- REU
Joe Blair- Division 3
c co?ad? p
A 1 r, 0 8 2007
DENR - WATER QUALITY
WETLANDS AND STORMWATER BRANCH

12:00 Lunch
1:00 Nottingham U-3462, Shallotte - SR-1357 (Smith Avenue) at NC 130
Brunswick County, Division 3
4C Permit Drawing Review (4B Meeting held 10/20/04)
Team Members: Jennifer Frye- USACE
Gary Jordan- USFWS
Travis Wilson- NCWRC
Cathy Brittingham- NCDCM
Steve Sollod- NCDCM
Ron Sechler- NMFS
David Wainwright- NCDWQ
Chris Militscher- EPA
Kathy Matthews- EPA
Donnie Brew- FHWA
Greg Brew- Roadway
Omar Azizi- Structures
Brian F. Yamamoto- PDEA
Brett Feulner- NEU
David Harris- REU
Joe Blair- Division 3
2:00 Nottingham U-2810, Fayetteville - SR-1003 (Camden Road) from
NC 59 (Hope Mills Road) to SR-1007 (Owen Drive)
Cumberland County, Division 6
4C Permit Drawing Review (4B Meeting held 6/15/05)
Team Members: Richard Spencer- USACE
Gary Jordan- USFWS
Travis Wilson- NCWRC
Rob Ridings- NCDWQ
Chris Militscher- EPA
Kathy Matthews- EPA
Donnie Brew- FHWA
Roger Thomas- Roadway
John Frye- Structures
Charles R. Cox- PDEA
Tyler Stanton- NEU
David Harris- REU
Tracey Pittman- Division 6
Lee Puckett- Construction
3:00 Adjourn

Oa STATt' P
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY LYNDO TIPPETT
GOVERNOR SECRETARY
AGENDA
Eastern Concurrence Meeting
Thursday, August 23, 2007
Board Room, Transportation Building
Raleigh, North Carolina
9:00 AM to 10:30 AM, Olivia Farr, Project Planning Engineer, PDEA Branch
TIP No. U-4751, US 17 Corridor Study
Hanover and Pender Counties, Division 3
Team Members:
Jennifer Frye, USACE
Olivia Farr, PDEA
Chris Militscher, USEPA
Gary Jordan, USFWS
Ron Sechler, NMF
Travis Wilson, WRC
Steve Sollod, DCM
Fritz Rohde, DMF
David Wainwright, DWQ
Sarah McBride, SHPO
Don Eggert, Cape Fear RPO (non-signatory)
Mike Kozlosky, Wilmington MPO
NCDOT Technical Support Staff and Other Agency Staff:
Allen Pope, Division 3
Joe Blair, Division 3
Mason Herndon, Division 3
Gary Lovering, Roadway Design
Ron Allen, Roadway Design
David Chang, Hydraulics
Ray McIntyre, Program Development
Don Moore, Geotech
Mark Staley, Roadside Environmental
Earlene Thomas, TPB
Phil Harris; NEU
Mary Pope Furr, HEU
Greg Smith, HEU
Ed Lewis, HEU
Matt Wilkerson, HEU
Jay McInnis, PDEA
Rob Hanson, PDEA
Consultants:
Liz Kovasckitz, Mulkey, Inc.
Jay Bissett, Mulkey, Inc.
* The purpose of this meeting is to reach concurrence on CP 2.
Please bring the Packet mailed to you for the June 1.9t" meeting.
MAILING ADDRESS: TELEPHONE: [phone] LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: [phone] TRANSPORTATION BUILDING
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WEBSITE: WWW.DOH.DOT.STATE.NC.US RALEIGH NC
RALEIGH NC 27699-1548
AGENDA
Eastern Concurrence Meeting
Thursday, August 23, 2007
Board Room, Transportation Building
Raleigh, North Carolina
10:30 AM to 12:00 Noon, Jennifer Fuller, Project Planning Engineer, PDEA Branch
TIP No. B-3654, Bridges 29 and 53 on NC 55 over the Mingo Swamp
Harnett and Sampson Counties, Division 6 & 3
Team Members:
Richard Spencer, USACE, Div. 6
Jennifer Fuller, PDEA
Jake Riggsbee, FHWA, Div. 6
Chris Militscher, EPA
Gary Jordan, FWS
Rob Ridings, DWQ, Div. 6
Sarah McBride, SHPO
Joel Strickland, Mid-Carolina RPO (non-signatory)
NCDOT Technical Support Staff and Other Agency Staff:
Jennifer Frye, USACE, Div. 3
Ron Lucas, FHWA, Div. 3
David Wainwright, DWQ, Div 3
Allen Pope, Division 3
Terry Gibson, Division 6
Tracey Pittman, Division 6
Tony Houser, Roadway Design
Charles Hunt, Structures
Andrew Nottingham, Hydraulics
Don Idol, Bridge Maintenance
Chris Underwood, NEU
Derrick Weaver, PDEA
Eric Midkiff, PDEA
Consultants:
Mark Reep, Ko and Associates
Clay Oliver, Ko and Associates
* The purpose of the meeting is to reach concurrence on CP 2A and CP 4A.
` . A
Merger 01 Process
Issue Briefing Format
Prepared by the NC Division of Water Quality (updated 08/20/07)
Project Name and brief description: Replacement of Herbert C. Bonner Bridge
over Oregon Inlet, Dare County; TIP No. B-2500
2. Last Concurrence Point (signed): CP 2
Date of Concurrence: October 13, 2004
3. Explain what is being proposed and your position including what you object to.
NCDOT is recommending the Parallel Bridge Corridor with Phased
Approach/Rodanthe Bridge Alternative as the project's Least Environmentally
Damaging Practicable Alternative (LEDPA). At the May 23, 2007 Merger Team
meeting, DWQ concurred with the first Phase of this alternative, the parallel (i.e.
short) bridge across Oregon Inlet. In addition, DWQ supports the concept of
phasing the ultimate implementation of the project along the NC 12 corridor.
However, DWQ does not support the proposed construction of permanent
bridges along NC 12 in locations that are projected to be in the Atlantic Ocean
during the project's planning period. Our reasons for this position are discussed
below.
4. Explain the reasons for your potential non-concurrence. Please include any data or
information that would substantiate and support your position.
As previously indicated, the DWQ supports a parallel bridge (i.e. short bridge)
alternative. In addition, we support an approach that results in a project whose
implementation is phased in some manner. However, we do not concur with an
alternative that will result in the construction of bridges that will ultimately be in
the active wave zone of the Atlantic Ocean. It is DWQ's opinion that the presence
of bridges in the active wave zone of the ocean could result in a loss of existing
uses.
The NC Environmental Management Commission has classified the Atlantic
Ocean for the project area as SB waters. SB waters are classified as Surface
waters that are used for primary recreation, including frequent or organized
swimming and all Class SC uses. Class SC waters are all tidal salt waters
protected for secondary recreation such as fishing, boating and other activities
involving minimal skin contact; aquatic life propagation and survival; and wildlife.
DWQ believes that bridges in the near shore area could result in a loss of the
aforementioned existing recreational uses.
In addition, based on comments made by NOAA's National Marine Fisheries at
the May 23, 2007 Merger Team meeting, as well as verbal communications with
other resource agencies, DWQ has concerns that aquatic life uses (especially
fisheries resources) may be adversely impacted by the presence of permanent
bridges in the near shore ocean.
Finally, and third potential problem with the proposed alternative relates to
stormwater and stormwater treatment. Bridges located in the ocean would have
limited opportunities for proper stormwater treatment prior to discharging into
the Atlantic Ocean. After discussions with the Division of Environmental Health,
it is clear that an untreated discharge would necessitate posting a sign warning
that the beach may not be safe for recreational activities. In this scenario, the
Division of Water Quality would be precluded from issuing a 401 Water Quality
Certification because it would constitute a loss of existing use. Since it is not
clear at this time if appropriate stormwater treatment could be achieved without
additionally development of the roadway and drainage design, DWQ believes it
imprudent to concur with the alternative being proposed by the NC Department of
Transportation.
Without the requested information along with the aforementioned potential loss
of existing uses, DWQ cannot concur with DOT's preferred alternative at this , .
time.
5. List any relevant laws or regulations that you believe would be violated or
jeopardized if the proposed action were implemented and explain the basis for
violation. Please attach a copy of the relevant portion of the law or regulation or
provide an email address where the documents may be located.
15A NCAC 02H.0500, http://h2o.enr.state.nc.us/admin/ruies/2H.0500.pd
f.
15A NCAC 0213.0200,
http://h2o.enr.state.nc.us/admin/rules/documents/rb080104 pdf.
15A NCAC 2H .1000, http://h2o.eur.state.ne.us/admin/rules/2H. 1000.pdf
6. What alternative course of action do you recommend?
DWQ recommends that the Merger Team concur with a parallel bridge alternative
(i.e. short bridge) corridor with some type of new phased approach alternative. In
Section 2.2 of the Supplemental Draft Environmental Impacts Statement, DOT
acknowledges that- the form of the ultimate phased approach was subject to
possible change due to uncertainties associated with the dynamic
geomorphologic nature of the area. Section 2.2 states "Although the Phased
Approach alternatives are described and addressed in this Supplement as a
phased alternative with specific locations and lengths for the phases.... these
details could be adjusted based on funding availability and the changing
1
conditions within the project area, recognizing the uncertainty of predicting
future shoreline conditions." Thus, it seems logical that a phased approach that
allowed for final decision-making more close in time to the actual impacts could
be developed more fully and described in the EIS. It is acknowledged that this
approach will necessitate some type of phased permitting process. However, the
issuance of phased permits is not without precedent and is used for projects
where the availability of funds to construct the project in its entirety is not
immediately available. Using that fundamental premise, it seems logical that this
project could be authorized using a similar approach so long as the scope of the
initial permit included the NC 12 corridor and the estimated impacts for the later
phases of the project were quantified in the EIS and application in an appropriate
manner. The advantages of the recommended course of action are: 1) it would
allow for the bridge design and construction to proceed immediately, 2) it would
allow for a more accurate identification and quantification of environmental
impacts because the time of impact assessment would occur more closely to the
time of impact, 3) it would improve the decision-making process by deferring
decisions until a time more closely aligned with the availability of funding, and
thus increasing the level of certainty when quantifying the potential
environmental impacts, 4) it would allow for the inclusion of other ongoing
studies (TIP R-3116, TIP R-31161), TIP R-3116E, TIP R-3116F) along NC 12 to be
incorporated into the decision-making process for NC 12, and 5) it would allow for
the inclusion of work being undertaken by the Outer Banks Task Force to develop
long-range solutions for the area.
From Werger01: Roles and Responsibilities"guidance document:
"If an organization decides to either non-concur or abstain, that organization is
responsible for documenting its reasons in writing and providing that documentation to
all Project Team Members within 5 business days of the Project Team meeting."

TABLE 3
R-2582/R-2584 High Quality Wetland Crossings and
Major Hydraulic Crossings Recommendations (Revised 611912007)
Major
Wetland's Impacted
Wetland / Stream
System High
Quality Hydraulic
Crossin * Segment Existing
Structure NCDOT Recommendation Agency Comments from Field Visit Potential Bridging Solutions Cost acres
WA 02 Yes No Al None None Not observed See NCDOT Recommendation
WA 03-WA 061 No Yes Al 3 at 9 feet x 9 Retain and extend as needed Not observed See NCDOT Recommendation
SA 02 feet RCBC
WA 16 / WA 17 /
Y
Yes
D 1 2 at 84 inch Bridge at 340 feet Agree with NCDOT recommendation. Bridge at
s See NCDOT Recommendation
WB 35 I SA 07 " es CMP 377
WA 23 / WA 19/ Yes Yes DI 1 at 24 inch 2 at 8 feet x 5 feet RCBC Not observed See NCDOT Recommendation
SA 08 RCP
FWS and WRC request 10 feet of clear ground
10 feet of clear ground is standard procedure for
WA 251 261 Yes Yes D1 45-foot bridge Bridge at 95 feet adjacent to the stream bridging. Each bridge along the project will
SA 10 0
%
j()
adhere to this policy.
WA 30 / SA 11 /
Yes
No
Dl
New
Equalizer pipes Agree with NCDOT recommendation. EPA asks
h See NCDOT Recommendation
SA 13 ? .
to look at minimizing to the sout
WA 34 / WA 33 / Yes Yes Dl 2 at 120 inch 3 at 7 feet x 6 feet RCBC Agree with NCDOT recommendation. See NCDOT Recommendation
SA 16 CSPA
WA 40 / WA 38 / Yes Yes Dl 60 inch CMP 2 at 6 feet x 6 feet RCBC Not observed See NCDOT Recommendation
WA 39 I SA 22
WA 41 Yes No F4 None None Not observed _ See NCDOT Recommendation
WA 42 / SA 29 ^ Yes No F6 New Pipe, less than 72 inches Agree with NCDOT recommendation See NCDOT Recommendation
WA 46 / WA 47 / No Yes F2 54 inch CMP 2 at 6 feet x 5 feet RCBC Not observed See NCDOT Recommendation
SA 25
WA 53 / SA 30
Yes
No
F6
New
Pipe, less than 72 inches
Agree with NCDOT recommendation
See NCDOT Recommendation
Agree with NCDOT recommendation. Implement See NCDOT Recommendation. Use 48-inch
WA 54 / SA 35 Yes No F6 New Pipe, less than 72 inches 48-inch equalizer pipes to accommodate equalizer pipes, buried a foot.
channelization and bury a foot.
WA 55 I SA 36 /
Yes
No
F6
New
Pipe, less than 72 inches Not observed See NCDOT Recommendation
SA37
+ r Look at minimizing to the south. Not observed in See NCDOT Recommendation F I I ?
o
WA57 ?5,ieA
? ?dYes No F9IF10 None Fill the field.
sr-4, 5
N 787
$ 141 0
7
e SA 41 at 260 feet;
Brid ost/impact comparison of bridge versus
Look at a Pipe, less than 72 inches , .
WA 59 /
SA 41-43-44-59 Yes No F9/F10 New g
Pipe at other locations y
fill. <,2 i v?( iffl" s Bride at 260 feet $ 1,965,600 0
i L
WA 60 / SA 46 Yes No F10 New Pipe, less than 72 inches Not observed on
See NCDOT Recommendat - sn 6
WA 63 / SA 48 No Yes G1 New 1 at 6 feet x 6 feet RCBC Not observed See NCDOT Recommendation -
Look at minimizing to the south. 80-foot bride nummum span $1,141,887 3.39
WA 70-72-73 / t RCBC
6 f
6 f
SA 51 / SA 52 Yes Yes GI New ee
eet x
2 at 5h;JGf Sn (,,- 7 ' Y 975-foot bridge spans system $ 7,420,011 0.88
WA 75-76 / SA 54 Yes No G6 New Pipe, less than 72 inches Not observed See NCDOT Recommendation - -
WA 77 (1-24) / Agencies are ok with not bridging. Look at Pipe, less than 72 inches. Use 48-inch equalizer - -
SA 61 / SA 59 Yes No G6 New Bridge at 360 feet equalizer pipes pipes, buried a foot.
WA 93 / WA 92 !
Yes
Yes
Fl/F3/F4 3 at 77 inch x
3 at 7 feet x 6 feet RCBC Not observed See NCDOT Recommendation
SA 90 52 inch CSPA
WB 04 / SB 01 Yes No B3/B4 New Pipe, less than 72 inches Agree with NCDOT recommendation See NCDOT Recommendation -
WB 06 I SB 03 No Yes B3 New 1 at 6 feet x 5 feet RCBC Not observed See NCDOT Recommendation
WB 09 / SB 05 No Yes B1/B3 3 at 8 feet x 6 Retain and extend as needed Not observed See NCDOT Recommendation
feet RCBC
WB 10 / SB 08 No Yes B4 New 2 at 9 feet x 6 feet RCBC Not observed See NCDOT Recommendation - -
SB 09 No Yes B4 New 1 at 7 feet x 6 feet RCBC Not observed See NCDOT Recommendation - -
WB 17 / WB 18 / Y
CI 3 at 8 feet x 9 Retain and extend 3 at 8 feet x Not observed See NCDOT Recommendation
SBl l Yes es feet RCBC 9 feet RCBC
WB 20 / WB 21 I Y
E2 120-foot Add parallel 120-foot bridge Not observed See NCDOT Recommendation
SB 15 No es bride to the south
Look at bridging options; short, medium, and long e $ 6,353,014 1.23
WB 25-27 Yes Yes E3 New Bridge at 805 feet with a comparison of impacts versus cost. An 805' 1295 foot bridge (fully spans HQW) ?" $ 9,790,200 0
bride would span the `wet' area.
V- ; Ma) o? Crefri?J C 2f} M,-c* q J
r
R-2582/R-2584 Bridging Decisions
. o. o gin CSC $ 975,036 4.75
WB 29
30
31 Y Yes El New 3 at 9 feet x 7 feet RCBC Consider bridging; look at short, medium and a
9W &G4 bridge $ 6,279,768 1.53
-
- es long options. Compare impacts versus cost. ,41'25-foot bridge full sans HQW $ 9,261,000 0
WB 32-36 / SB 20 Yes Yes El New 2 at 10 feet x 7 feet RCBC Agree with NCDOT recommendation. Look at
shifting the alignment north to minimize. See NCDOT Recommendation - -
investigate small culvert crossings for wildlife Culvert -3 e lb X '% $ 755,355 2.89
WB 41 / SB 22 Yes Yes E1 New Bridge at 475 feet passage. Disregard wildlife crossings if we bridge $ 3,787,321 0,1
at 475 feet.
SB 24 No Yes E4 New 1 at 8 feet x 7 feet RCBC Not observed See NCDOT Recommendation -
UT to Gumberry No Yes E2 2 at 46 inch x 1 at 8 feet x 5 feet RCBC Not observed See NCDOT Recommendation -
Swam 31 inch CSPA
WB 74 / SB 41 No Yes G3 New 1 at 7 feet x 6 feet CBC Not observed See NCDOT Recommendation -
Observed a braided system in the field. Request See NCDOT Recommendation. Use 48-inch
WB 47-48 / SB Yes Yes E4 New 4 at 7 feet x 6 feet RCBC implementing 48-inch equalizer pipes buried a equalizer pipes, buried a foot.
26A foot.
The existing culvert is being utilized for east- Retain and extend 3 at 8 feet x 8 feet RCBC $ 850,682 2.83
WB 55
WB 54 Y Yes 3 at 8 feet x 8 Retain and extend 3 at 8 feet x ac
s/cos g 2
3
- es feet RCBC 8 feet RCBC "I t
y "y,,
compa son for bridging to the north. p e s ans HQW
840-footbrid $ 6,350,400 0
WB 60-61 / SB 30 Yes Yes F8 New 3 at 8 feet x 6 feet RCBC Not observed See NCDOT Recommendation - -
WB 62 Yes No F8 New None Not observed See NCDOT Recommendation -
WB 64-66 Yes No F8 New -Equalizer pipes Not observed See NCDOT Recommendation -
Two RCBC at 9 feet x 7 feet; Recommend a two barrel culvert at the eastern Two RCBC at 9 feet x 7 feet at the eastern
WB 711 SB 32 Yes Yes G3 New Note that the second barrel is crossing and a single barrel culvert at the western crossing; one barrel is for wildlife passage. One -
for wildlife passage crossing. 11 o+1 w C? n? Q? e w 815 37/583 RCBC at 9 feet x 7 feet at the western crossing.
One barrel RCBC at 7 feet x 9 feet $758,082 3.68
Look at a small culvert and other bridging options $ 1,019,256 3.27
WB 73 / SB 34 -
/ Yes No G3 New Pipe, less than 72 inches for comparison. I Exttmlzd-railroad-bridge $ 8,013,600 0
ful
WB 75 / SB 36 No Yes G4 New 1 at 8 feet x 6 feet RCBC Not observed See NCDOT Recommendation -
WB 76 / SB 35 i Yes Yes G7 1 at 10 feet x 6 Retain and extend 1 at 10 feet Not observed See NCDOT Recommendation
feet RCBC x 6 feet RCBC
WB 77 - WA 78 Yes Yes G4 New 1 at 7 feet x 6 feet RCBC Agree with NCDOT recommendation. Shifting the See NCDOT Recommendation
79 / SB 63 alignment does not appear to reduce impacts.

WB 79-78-81 ?
Yes
Yes
G'.
New
1 at 8 feet x 6 feet RCBC Agree with NCDOT recommendation. FWS
e quests oversized equalizer pipes buried a foot. See NCDOT Recommendation
* A major hydraulic crossing is defined by the NCDOT Hydraulics Unit as one requiring a conveyance capacity equivalent to that of a 72-inch diameter pipe or larger drainage structure.

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
August 2, 2007
MEMORANDUM TO
FROM:
B-2500 Merger Team
Beth Smyre, P.E.
Project Planning Engineer
LYNDo TIPPETT
SECRETARY
SUBJECT: NC 12 Replacement of Herbert C. Bonner Bridge, (Bridge
No. 11) over Oregon Inlet, Dare County, WBS No. 32635,
Federal Aid Project No. BRS-2358(15), TIP No. B-2500
Enclosed is additional information to be discussed at the August 15, 2007 Merger
Team Meeting. The following information is included:
• The final "Summary of Agency Concerns" spreadsheet (a draft of which was
mailed to all merger team members on July 20), including NCDOT's
responses.
• Minutes from meetings held with individual merger team members in June
and July 2007. Meeting attendees were given the opportunity to review drafts
of these minutes, and any requested changes have been incorporated into the
version in this package.
• Supplemental information as requested during meetings with merger team
members.
The enclosed information, along with the materials presented as part of the
May 23 and June 20 merger meetings, will serve as the packet for the August 15 meeting.
Please bring this with you to the meeting.
If you have questions or comments about the enclosed documents, please feel free
to contact me at 919-733-7844, extension 333 or at [e-mail].
Enclosures
MAILING ADDRESS:
NC DEPARTMENT OF TRANSPORTATION
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS
1548 MAIL SERVICE CENTER
RALEIGH NC 27699-1548
TELEPHONE: [phone]
FAX: [phone]
WEBSITE: WWW.DOH.DOT.STATE.NC.US
LOCATION:
TRANSPORTATION BUILDING
1 SOUTH WILMINGTON STREET
RALEIGH NC
Summary of Agency Concerns
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Meeting Minutes
• DOI- USFWS, PINWR, NPS (June 11, 2007)
• NCDCM (July 5, 2007)
• NMFS (July 12, 2007)
• USEPA (July 19, 2007)
• NCDWQ (July 25, 2007)
too
YEARS
To: June 11, 2007 USFWS/NCDOT Meeting Attendees
From: John Page, PB
Date: July 31, 2007
Subject: Meeting Minutes - June 11, 2007 USFWS/NCDOT Meeting for the Bonner
Bridge Replacement Project (TIP No. B-2500)
Attendees:
Mike Bryant USFWS (Pea Island National Wildlife Refuge)
Dennis Stewart USFWS (Pea Island National Wildlife Refuge)
Pete Benjamin USFWS - Raleigh Field Office
Gary Jordan USFWS - Raleigh Field Office
Mike Murray NPS
Ron Lucas FHWA - NC Division
Rob Hanson NCDOT -PDEA
Beth Smyre NCDOT - PDEA
Brian Yamamoto NCDOT - PDEA
John Page PB
Bobby Norburn PB
The meeting was held after the OBTF Meeting at Martin Community College (Building 1,
Room 14) in Williamston, NC. The following topics were discussed:
• USFWS reiterated that any construction outside of the existing NCDOT easement through
the Refuge, including emergency actions, would trigger a compatibility determination.
• USFWS said that they have to perform a NEPA analysis on any action that triggers a
compatibility determination.
• NCDOT, on average, requests two special use permits per year to repair damage to NC 12
associated with overwash. USFWS can find such actions compatible only if they can
assume that there is less than 10 years of impact because a long-term solution, such as the
Pamlico Sound Bridge Corridor, is expected.
• USFWS said that because the Phased Approach would constitute a long-term solution to
NC 12 needs through the Refuge and the NCDOT says it will stay in the existing easement,
USFWS would not be able to allow NCDOT to conduct any more "emergency repairs" or
other activities that impact the Refuge outside of the NC 12 easement once the ROD for
the Phased Approach is issued.
• Mike Bryant said that NCDOT's requests for emergency repairs to NC 12 are not really
USFWS' concern; however, these requests, which have negative impacts on the Refuge
Over a Century of
Engineering Excellence
moo
YEARS
Page 2
Minutes: June 11, 2007 USFWS/NCDOT Meeting for Bonner Bridge
and go against the Refuge's mission, become a problem for USFWS because of the
importance of keeping NC 12 open. USFWS feels that there have been too many impacts
over too much time with short-term or emergency actions.
USFWS said that the Phased Approach/Rodanthe Bridge Alternative is supposed to stay
within the existing easement through the Refuge so that impacts will be confined to the
existing easement, but the NEPA document says that it will actually have impacts outside
of the existing easement (e.g., the potential implementation of a short-term relocation of
NC 12 in the Rodanthe area). If these impacts are more than "minor," then the alternative
would not be found compatible with the Refuge.
• USFWS said that in the past they have allowed minor changes in the NC 12 easement for
safety improvements as long as appropriate mitigation also was provided.
• USFWS does not want to perpetuate the "emergency" in regards to accommodating
NCDOT's requests for emergency repairs to NC 12 that have negative impacts on the
Refuge, and they believe that the Phased Approach/Rodanthe Bridge Alternative will cause
this to happen.
• The USFWS would like more information on what impacts will occur inside and outside of
the existing easement.
• The USFWS would guess that the project would have impacts in the entire area between
mean high water and 230 feet west of the worst-case shoreline. For example, even if the
existing pavement is removed, the habitat in that area will not be of as high a quality as
habitat never covered by NC 12.
• As long as NC 12 is within the Refuge, USFWS is concerned that the history of NCDOT
periodically having to make emergency repairs that impact the Refuge outside of the
easement, as well as requesting to move portions of NC 12 to the west within the Refuge,
will repeat itself.
• USFWS said that the NEPA document does not address the fact that the habitat under the
Phased Approach bridges will change over time, which will lead to changing impacts to
the Refuge over time.
• The USFWS would like more information on the Phased Approach's effects on long-shore
and cross-shore sand movement.
• The USFWS is not sure that we have a range of practicable alternatives.
Following this meeting, Mike Bryant submitted an email to Beth Smyre clarifying what he
stated during the meeting. That email is attached to these minutes.
Over a Century of
Engineering Excellence
00
YEARS
Page 3
Minutes: June 11, 2007 USFWS/NCDOT Meeting for Bonner Bridge
Attachment
file no.: 3301-2.7.2
JAPLANNING\Bonner SDEIS\Stakeholder Involvement\Merger Meetings\USFWS Meeting (after 6-11-07 OBTF Meeting) - first
draft.doc
Over a Century of
Engineering Excellence
Bonner Bridge Meeting Jun 11, 2007
Subject: Bonner Bridge Meeting Jun 11, 2007
Date: Tue, 12 Jun 2007 08:13:32 -0400
From: [e-mail]
To: Beth Smyre <bsmyre @dot. state.nc.us>
CC: [e-mail], [e-mail], [e-mail],
[e-mail], [e-mail]
Yesterday after the Outer Banks Task Force meeting we met with you and
several other NCDOT staff and a FHWA staff member. You asked us to discuss
our concerns about the NCDOT and FHWA selection of the alternative that
describes a short bridge with additional phased bridges within the existing
right-of-way as your Least Environmentally Damaging and Practicable
Alternative (LEDPA) which becomes the preferred alternative.
I said that the selection of this alternative would change the way we
consider NCDOT's future requests for use of the refuge outside the existing
right-of-way. I do not concur with your preferred alternative because I
do not agree that it is the least environmentally damaging. It would be
confusing to the public if I concurred and in future denied NCDOT a use of
the refuge. Let me be clear:
Until NCDOT and FHWA sign off on the final EIS I will continue to work with
the NCDOT operations and maintenance division much the same as I have in
the past. I'll look at each proposed use and look at what I identify as
the direct, indirect, and cumulative impacts of the proposed use to inform
my decision.
As the Refuge Manager, I must make decisions based on the potential impacts
of proposed uses to the refuge. NCDOT and FHWA have characterized their
preferred alternative as feasible, reasonable, prudent, and practical. You
say you can construct, operate, and maintain it within the existing
right-of-way. I'm saying that, when you've made your decision final, you
do it with the knowledge that future requests for construction,'
maintenance, or operation of NC Hwy 12 outside the existing right-of-way
will not be compatible and will not be permitted.
There is only one exception: I will not make a compatibility determination
and will deny any request for maintenance of an existing right-of-way which
will affect [this refuge], unless: [I conclude that] the design [of the
proposed maintenance] adopts appropriate measures to avoid resource impacts
and includes provisions to ensure no net loss of habitat quantity or
quality; restored or replacement areas identified in the design are
afforded permanent protection as part of [this refuge that is] affected by
the maintenance; and all restoration work is completed by the applicant
prior to any title transfer . . . . Maintenance of an existing
right-of-way includes minor expansion or minor realignment to meet safety
standards. The replacement of lost habitat values in this exception to
compatibility is considered compensatory mitigation [50 CFR 26.41 (b) &
(c)].
NCDOT has identified, through their Bonner Bridge replacement planning
process, alternatives (i.e., the long bridge) that avoid having to react to
emergencies that in the past required NCDOT to seek Special Use Permits for
work outside the existing right-of-way. But, now, NCDOT is choosing an
alternative which will likely require use of the refuge outside the
existing right-of-way to maintain and operate NC Hwy 12. Those proposed
uses of the refuge outside the existing right-of-way are not compatible.
NCDOT's plan identifies future emergency actions and you say you can
maintain and operate NC Hwy 12 within the existing right-of-way. Therefore,
NCDOT's response to a declared emergency will be confined to the existing
right-of-way. Overwash events increase the elevation of the refuge,
increase the width of the refuge, and create and restore important habitat
types for federal trust resources on the refuge. It is these overwash
events that NCDOT identifies as the threat to NC Hwy 12. You've planned a
future for NC Hwy 12 that says you can manage these threats within the
1 of 2 7/31/2007 2:25 PM
Bonner Bridge Meeting Jun 11, 2007
4
existing right-of-way. Since you've planned for the threat and you say you
can accomplish the work within the existing right-of-way, then you'll have
no need to work outside the existing right-of-way. When overwash occurs,
generally it's not a threat or an emergency to the refuge - it's a benefit
because it creates, restores, and maintains important wildlife habitat.
I'll honor your right to construct, maintain, and operate your public road
in the way you've planned to do it - all your construction, maintenance,
and operation actions will occur within the existing right-of-way. In the
near future, based on NCDOT's planned course of action, NC Hwy 12
construction, maintenance, and operation work outside the existing
right-of-way will not be compatible.
(Embedded
image moved Mike Bryant, Project Leader
to file: USFWS
pic26500.jpg) North Carolina Coastal Plain
Refuges Complex
P. 0. Box 1969 (shipping: 708 N Hwy
64)
Manteo, NC 27954
office: 252-473-1131 ext. 222 cell:
252-216-7505
fax: [phone]
[e-mail]
Name: pic26500.jpg
pic26500 JpR Type: JPEG Image (image/jpeg)
Encoding: base64
2 of 2 7/31/2007 2:25 PM
Memorandum
moo
YEARS
To: Beth Smyre
From: Bill Rice
Date: August 1, 2007
Subject: Division of Coastal Management (DCM) July 5, 2007 Conference Call Meeting
Summary - Bonner Bridge Replacement Project (TIP No. B-2500)
Attendees:
Jim Gregson, DCM
Cathy Brittingham, DCM
Rob Hanson, NCDOT- PDEA
Beth Smyre, NCDOT-PDEA
Ron Lucas, FHWA
Margery Overton, FDH
John Page, PB Americas, Inc.
Bill Rice, PB Americas, Inc.
Shoreline Erosion Assumptions
Beth Smyre opened the meeting by discussing DCM's comment on the design of the
Phased Approach alternatives relying upon the estimated 2060 shoreline. She
indicated that, for the FEIS, the project team will need to develop "trigger" criteria for
the implementation of the phases of the Phased Approach Alternative. Margery
Overton said that the worst case shoreline includes a "prediction interval" that
accounts for shoreline erosion occurring faster than past trends. The worst case
shoreline was used in developing all of the Parallel Bridge Alternatives. No additional
factor was included for sea level rise.
John Page asked how the shoreline erosion rates used in the SDEIS compare to the
shoreline erosions rates used by DCM. Margery stated that the DCM's rates take
into account just two data points and no prediction interval. John also asked how
different the two rates are. Margery said that the rates of erosion are comparable
within one foot, but there is still some uncertainty in the predicted rates.
Ability of Bridge to Withstand Coastal Processes
Cathy Brittingham said there was a period between September 1960 and March
1962 where the erosion averaged between 200 and 389 feet per year, but repaired
itself through natural processes over approximately the next three years. Cathy said
that in an extreme event, such as her example, the bridge would be more
vulnerable, and she is concerned as to whether the bridge could be built to withstand
such extreme conditions. She continued by stating that if a bridge is a major
evacuation route and its design does not hold up to coastal processes, it will be a
detriment to the community.
John said that the new bridge design would have to meet any design guidelines
being developed as part of the FHWA Wave Vulnerability Task Force. Ron Lucas
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affirmed this statement. In response, Cathy suggested that the team would need to
incorporate FHWA's findings before deciding on the Least Environmentally
Damaging Practicable Alternative (LEDPA). Cathy asked if it is wise to consider
putting the NC 12 maintenance bridges east of existing NC 12 when the existing
conditions are problematic. Beth noted that the guidelines from the Task Force are
supposed to focus on structural specifications for bridges built in coastal areas.
NCDOT recognizes the challenges of locating bridges within an eventual surf zone,
but the placement of the bridges are limited by location of the existing NC 12
easement.
Adaptive Management
Cathy asked about the use of Adaptive Management, which would allow NCDOT to
proceed with the final design of the Oregon Inlet Bridge and defer the choice of the
final option or options for the subsequent phases until a later date. Ron said that
adapting NC 12 maintenance (Phases II, III, IV) as conditions warrant can be
handled without an AM approach. Changes could be made through revisions to the
Record of Decision (ROD). Therefore, the flexibility of Adaptive Management could
be achieved but in a different manner. Ron stated that this approach has been given
a lot of consideration at high levels of FHWA, and that he also believes that the team
should select the LEDPA based on what is known at this time and revise the ROD
as the conditions change. Rob added that the decision to take this approach was
based upon the advice of the FHWA and NCDOT attorneys. John stated that the
FEIS will consider conditions and variables that have potential to affect the project in
the future.
DCM Rules Related to Structures on the Beach and the Near Shore
Cathy stated that DCM's position is that construction of permanent bridges in a
location that is projected to be in the ocean on or before the project's design year
would be inconsistent with the most basic principles of the Coastal Area
Management Act (CAMA) and the Rules of the Coastal Resources Commission
(CRC). She went further in saying that the DCM will only process permit
applications for portions of the project that have final design, and that permit
modification requests would need to be submitted by NCDOT for later phases at the
time that the final design is complete. She also stated that it is possible that the
location of such a massive, permanent structure like the Bonner Bridge and NC
Highway 12 within the Outer Banks coastal ecosystem could prevent any of the
alternatives being studied for TIP No. B-2500 from complying completely with the
Rules of the CRC. Therefore, it is possible that DCM will need to deny a CAMA
permit application for any of the alternatives for procedural reasons. In that situation,
NCDOT would have the option of petitioning the CRC for a variance to undertake a
project that is prohibited by the CRC's development standards. Jim indicated that the
CRC may decide differently but that permits to develop the bridge across Oregon
Inlet may not include provisions for subsequent construction of additional phases. A
variance would likely be required for each phase.
Cathy said that the objective of CRC rules is to not allow construction of structures
prone to be damaged or to cause change or damage to coastal processes. In
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addition, the CRC rules require that any structure shall be relocated or dismantled
when it becomes imminently threatened by changes in shoreline configuration as
defined by 15A NCAC 07H .0308(2)(B). It was noted that the definition of
"imminently threatened" doesn't account for how structures are constructed, only the
proposed location. Cathy then stated that her organization is concerned with bridge
piers and approach retaining walls used as they relate to erosion control and
structure setback rules. Cathy also stated that public access to the Refuge is a
concern. Beth stated there would be more of a guarantee of access with the Phased
Approach Alternative than the Pamlico Sound Bridge Alternative, since the Phased
Approach includes access points at the north end of the PINWR as well as within the
existing stable area.
Cathy stated that erosion setbacks, their criteria and rules, was included in DCM's
June 1st issue brief. John noted that the bridge would be designed so it would
withstand the impacts of storms and coastal processes. Jim said that, however, it
would still be a permanent fixture on the beach. Margery asked whether the
placement of a bridge would be allowed if an inlet developed. Jim responded that if
the structure were over an inlet, it would possibly then be allowed, but it was not
acceptable over an existing beach.
Beth asked Jim to provide the DCM's definition of "practicable" with respect to
bridges and structures in the coastal zone. It was said that the CRC has no
definition.
Other
Beth asked if DCM had questions on the cost data provided at the July Merger Team
meeting. In response, Cathy stated that the DCM does not have any questions
about the cost data.
Beth said that with regards to DCM comments on beach nourishment, NCDOT did
not plan to provide more information on the Nourishment Alternatives because
nourishment isn't part of NCDOT's preferred alternative.
Cathy asked if there is a maintenance plan, specifically requesting information as to
what would be done with the Phased Approach's bridges after they are demolished
at the end of their service life. She also asked if this should be discussed in the
FEIS. John said that all we know is what are current policies and procedures and
those could be stated. The difference between the disposal of the Bonner Bridge
and the Phased Approach would be the quantity of material to dispose.
Margery then asked if the USFWS sand compatibility criteria for beach nourishment
is more stringent that the Coastal Resource Commission's (CRC). Cathy stated that
she spoke with Gary Jordan of the USFW S after the Outer Banks Task Force
meeting (June 11, 2007) and the USFWS's criteria is different than the CRC's.
Therefore, satisfying one agency's sediment criteria wouldn't necessarily satisfy the
other agency's criteria; both sets would need to be satisfied.
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Jim stated that it may be beneficial to discuss the CRC variance issue related to the
Phased Approach with Jill Hickey, Counsel for the CRC.
With no further questions, the call was ended.
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To: Beth Smyre (NCDOT)
From: Bill Rice
Date: July 31, 2007
Subject: National Marine Fisheries Service July 12, 2007 Conference Call Meeting
Summary - Bonner Bridge Replacement Project (TIP No. B-2500)
Attendees:
Rob Hanson, NCDOT-PDEA
Brian Yamamoto, NCDOT-PDEA
Beth Smyre, NCDOT-PDEA
Scott McLendon, USACE
Bill Biddlecome, USACE
Ron Sechler, NMFS
Pace Wilber, NMFS
Ron Lucas, FHWA
John Page, PB
Bill Rice, PB
Sam Cooper, CZR
Modeling of Coastal Processes for Impact Assessment
Ron Sechler stated that he is concerned about structures in the surf zone and how
modeling for coastal processes and the assessment of related impacts will be
performed. Ron said that scour at the base of coastal structures is a concern to
marine species that utilize the surf zone in general and specifically its value as EFH
for red drum. He then indicated that surf zone habitat was not adequately addressed
in the DEIS and asked how NCDOT would assess the related impacts based upon
the information available. Ron mentioned that he had conducted a preliminary
search for related scour information and had not found any relevant information. Ron
stated that although scour is the underlying issue, the bigger-picture issue is the
change over time in the physical makeup of about 10 miles of the beach itself and its
ability to support the full range of invertebrates and fishes that utilize the nearshore
waters and the surf zone as habitat.
John Page said that the studies performed at the Duck' pier for coastal processes
were used in the SSDEIS. It was not known whether biological impact studies are
also conducted at the pier. Impacts would be evaluated through a combination of
modeling changes in coastal processes and an understanding of the habitat
requirements and the behavior of marine species the inhabit the area. The
assessment would be based on the foundation type proposed as a result of further
coastal studies and would point to potential minimization and mitigation measures.
' Duck, North Carolina is located on the beach side of Hatteras Island, approximately 24 miles north
of the northern project terminus.
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Beth Smyre cited the relationship of this discussion to the NMFS comments 3J and 3K
regarding benthic communities and fish in the surf zone. FEIS- level studies would be
needed to respond to these comments, but that NCDOT would coordinate with NMFS to
determine potential study parameters. Ron agreed that comments 3J and 3K were the
crucial NMFS comments and that more information is needed, and added that the
information needed could also respond to comment 3H.2
Coastal Process Modeling Timing With Respect to Determining the LEDPA
Ron Sechler cited a comment in the SSDEIS made by staff at UNC Wilmington
about using the Bonner Bridge as an example of how coastal structures respond to
coastal processes. Ron concluded that the Bonner Bridge example would not be
fitting to use because the structure being discussed by the project team would run
parallel to the beach and would eventually be in the surf zone, and the Bonner
Bridge is different because it is in an inlet with different coastal processes at work.
Sam Cooper asked if it was known how much bridging would be offshore and how
far offshore those bridges would be. John said that there are estimates based on
the predicted 2060 shoreline, but by 2060 the four ends of the full bridges would be
within the surf zone and the rest offshore.
Ron said there has been no project similar to the parallel bridge and that studies on
the parallel bridge's performance with respect to coastal processes would be difficult
to perform to an acceptable level of quality in the short time available prior to
determining the LEDPA. Beth Smyre then asked Ron what he would like to see
studied. Ron replied that the NMFS could not discuss that at the current time. Pace
Wilber noted that the comments that have been provided thus far by NMFS were
general, as only general corridors are currently proposed.
NCDOT intends to conduct the needed modeling after the LEDPA is selected and
use the results to respond to comments and develop mitigation. Bill Biddlecome said
that the modeling after the LEDPA is determined does not change USACE's position
on the project. Ron stated that NMFS position on the LEDPA is based on information
currently available which indicates that impacts to fishery resources including surf
zone EFH and other near shore habitats have not been adequately addressed.
Therefore, NMFS cannot concur on a LEDPA that directly, indirectly, and
cumulatively impacts NMFS trust resources over time and on a large scale when a
less damaging alternative is available.
Funding Availability
Beth Smyre asked if there were any further questions related to the cost estimates
and project funding information that was provided at the June 20 merger meeting.
Ron Sechler said that he had spoken with the other resource agencies, and he had
no comment on the data provided on funding.
2 Comments 3H, 3J and 3K are found in the document Bonner Bridge Supplement to the 2005 SDE/S
Agency Comment Summary. This document was included as Appendix B of the May 23, 2007 Merger
Meeting handout that was developed by PB.
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Elevating Concerns Under Merger 01 and Under Federal Processes
Beth Smyre said that the permitting agencies will be meeting on August 15, 2007 to again
discuss the LEDPA and either concur or elevate under Merger 01. Scott McLendon asked if
NCDOT was expecting USACE to concur on the LEDPA, stating that he is aware that the
project team's attention is greatly focused upon NEPA issues at the current time, but there
are also Clean Water Act Section 404 issues at the current time as well. Scott said that he is
still concerned about the lack of information that they need in order to grant a Section 404
permit. The other Federal agencies' ability to elevate USACE permit decisions, under
Section 404q, are still available regardless of the Merger elevation process.
Ron and Pace said that NMFS shares the concerns that USFWS has expressed to NCDOT
and FHWA regarding impact to the Pea Island National Wildlife Refuge. On behalf of DOI,
USFWS has asked NOAA if DOC would join DOI in an informal discussion with CEQ about
the project and how CEQ might help resolve differences between the Departments and
FHWA. To prepare the DOC Secretary for this request from DOI, NOAA has briefed the
DOC Secretary and recommended DOC join DOI in this discussion. Normally, such briefings
occur after NOAA has notified the federal action agency that elevation under federal
processes is being contemplated. NOAA expects to provide the federal action agency with
that notice once the action agency has indicated its preferred alternative in a NEPA
document.
Army Corps of Engineers Concerns
Scott said that the USACE is still wrestling the with Pamlico Sound Bridge Corridor
Alternative versus the Parallel Bridge Corridor with Phased Approach Alternative and
his main concern is the uncertain nature of the future funding sources. Bill
Biddlecome asked that if the money were to become available, would the Pamlico
Sound Bridge become the preferred alternative for NCDOT. Ron indicated that
NMFS continues to support selection of the Pamlico Sound Bridge Corridor as the
LEDPA.
With no further questions, the call was ended.
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To: Beth Smyre (NCDOT)
From: Bill Rice
Date: August 1, 2007
Memorandum
Subject: US Environmental Protection Agency July 19, 2007 Meeting Summary - Bonner
Bridge Replacement Project (TIP No. B-2500)
Attendees:
Brian Yamamoto, NCDOT-PDEA
Beth Smyre, NCDOT-PDEA
Rob Hanson, NCDOT-PDEA
Chris Militscher, USEPA
Kathy Mathews, USEPA
Ron Lucas, FHWA
Bill Biddlecome, USACE
Margery Overton, FDH
John Page, PB
Bill Rice, PB
Beth Smyre began the meeting by saying that she will be sending out a comment
summary to Merger Team members do July 20th, and she will ask that the Merger
Team members submit their amendments and additions to the summary by July 27.
She also said that she will send out NCDOT responses to the comments on August
1 so that they may be used as discussion points for the August 15th Merger Meeting.
The summary includes just those comments that are important to the concurrence
decision. Beth distributed the EPA portion of this comment summary for discussion.
Discussion of Existing Bridge Operations and Maintenance Costs
Chris Militscher indicated that NCDOT had responded to cost-related comments with
the exception of those related to operations and maintenance (O&M) of the existing
Bonner Bridge. He asked for detail on the factors used to determine the operations
and maintenance (O&M) costs. Beth provided Chris with the original unit cost
estimate showing how the O&M costs were generated for the Pamlico Sound Bridge
Corridor. Chris asked for further detail on how the unit O&M costs shown in the
estimate were used to generate the final O&M cost shown in the SSDEIS; Beth said
she would look into this information and provide it to Chris.
Discussion of Project Construction Costs
Chris Militscher questioned the accuracy of project construction cost estimates when
compared with those of Interstate 10. Brian Yamamoto said that FHWA performed
an independent review of the costs to verify their accuracy and applicability. Chris
Militscher then asked why the costs to construct replacement bridges in Mississippi
and Florida were less expensive. Brian Yamamoto responded that the bridges that
were replaced in Mississippi and Florida were not complete reconstructions, but
were more extensive repairs to existing structures.
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Disclosure of Bonner Bridge Maintenance Contract in FEIS
Chris Militscher a how the FHWA would disclose the planned $44 million
rehabilitation contract for the existing Bonner Bridge since it is an interim project that
would be carried out while bridge replacement alternatives were being considered in
the NEPA process. Ron Lucas said that a NEPA Categorical Exclusion (CE) was
completed for the rehabilitation project (TIP No. B-5014) in June 2007. Chris
Militscher then quoted the CEQ guidelines regarding actions that are related but
independent of a larger project. Chris Militscher then asked if the rehabilitation
activities should have been disclosed in the SSDEIS since they have the potential to
push out the schedule of the replacement project. Beth Smyre said that the full ten
years of projected additional design life would be needed to open the replacement
bridge, noting that construction would take a minimum 3.5 years, with at least an
additional year required for the design-build phase.
Chris Militscher said that rehabilitating the Bonner Bridge was an alternative in the
1993 DEIS. Rob Hanson said that the rehabilitated Bonner Bridge would be a
temporary solution and not a permanent solution, and was not connected to the
bridge replacement alternatives being considered. Chris Militscher said that he
would like to see a copy of the CE for the rehabilitation project and that he believes
that the rehabilitation project's existence should be disclosed as an addendum to the
SDEIS before the FEIS is completed. Beth Smyre said that she would send copies
of the CE to the Merger Team members. .
Potential for Additional Projects
Chris Militscher said he was concerned that adding new bridges along the shore
would set up the NCDOT and FHWA for a series of multi-million dollar replacement
projects as the planned bridges failed or needed retrofitting prior to their planned
design life.
Coastal Barrier Resources Act
Chris Milischer said he did not believe that the project complied with the Coastal
Barrier Resources Act.
Revising Project Purpose and Need and Alternatives
Chris Militscher asked Bill Biddlecome to consider the need for revising the
Concurrence Point 1 and 2 agreements. Bill said that he did not think that the
Merger Team was at that point at this time. Chris Militscher said that the Merger
Team should revert to having the short bridge replacement project with no
improvements to NC 12 as one of the alternatives being considered, citing that the
Merger Team set itself up for a protracted effort when it dropped the alternative for
the sake of considering only the Pamlico Sound Corridor. With respect to a short
bridge alternative, Chris Militscher discussed legislation citing general bridge design
attributes in NC House Bill 253/Session Law 2005-275. It says the project termini
should be in the same location as existing termini. Ron Lucas clarified that the bill
was amended shortly after it was a passed to indicate that a bridge with termini near
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the existing termini was a preference and acknowledging that the decision would
come from the environmental analysis process.'
Coastal Processes Modeling
Chris Militscher said he would like to see more information on sea level rise with
respect to the coastal processes modeling, specifically for scour. Chris said that the
NCDOT should model the coastal processes in relation to the project prior to the
concurrence of a LEDPA because the project ultimately will be in the ocean. Chris
said that although it would be environmentally damaging, armoring the bridge
foundations ultimately would be necessary. Chris said that he had doubts that
coastal modeling could model all of potential impacts of the proposed bridges on
coastal processes since such,bridges had not been built before. Kathy Mathews
said that one potential example could be the Sebastian Inlet Bridge in Florida, which
is armored with a groin or jetty on both sides of the inlet. Kathy is concerned that the
Phased Approach Alternative may not be reasonable and feasible, if most of the
structures (and perhaps even the southern terminus) will be in the ocean in the
design year, and/or if the scour modeling shows significant issues. USEPA does not
have adequate information on sea level rise projections or the scour modeling to
support that it is a reasonable, feasible (practicable) alternative.
Stormwater Runoff and Treatment on Bridges
Chris Militscher said that he has concerns regarding water quality impact from
stormwater runoff from any of the alternatives and that any stormwater runoff from
bridges would have to be treated. Chris said there is the potential that an NPDES
permit would not be granted should the FEIS demonstrate that the runoff could or
would not be treated.
Development of LEDPA without Full Funding
Chris Militscher noted there have been some projects where the LEPDA was agreed
to without knowledge of future funding sources (e.g. Western Wake Expressway
[Interstate 540]), but recognized that some past projects had alternatives dropped
because of funding issues (e.g. Blowing Rock).
With respect to Chris Militscher's citation of the Western Wake Expressway, Brian
Yamamoto said that the Western Wake Expressway could be developed in
segments, ending at an interchange. Beth Smyre continued Brian's thought by
saying that NCDOT can build part of a roadway project but not part of a bridge.
Chris Militscher suggested obtaining a waiver from the State General Assembly so
' North Carolina General Statute 136-89.1838 (b) states, "Replacement Bridge; Termini. - The
General Assembly recommends that the replacement bridge constructed pursuant to this section shall
be located with north and south termini located in general proximity to the termini of the existing
Herbert C. Bonner Bridge. It is recognized, however, that the preferred alternative for the bridge
location cannot be determined prior to compliance with all federal and State laws and regulations."
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the Pamlico Sound Bridge could be funded. Beth said that the General Assembly is
unlikely to grant a waiver. Chris Militscher asked about toll financing.
Chris Militscher indicated that reasonable and feasible under NEPA and practicable
under Section 404 are equivalents. This redundancy allows the response to the two
laws to be considered together. The SDEIS and SSDEIS says there are two
reasonable and feasible corridors and now the NCDOT says one (Pamlico Sound
Bridge Corridor) is not reasonable and feasible. Chris indicated that he is not sure
that state law associated with funding distribution can trump NEPA.
EPA's Closing Comments
Chris Militscher said that he will provide the NCDOT with a revised list of the issues
discussed in the meeting. Chris also said that the EPA could not make a decision
on a LEDPA with the available information but that the EPA could pick the Pamlico
Sound alternative. He continued to say that mitigation will be critical. He said EPA
will provide NCDOT with a new issue brief and request that the decision be elevated.
Margery Overton indicated she will contact the EPA for clarification on the sea level
rise references EPA included in their comments.
Chris Militscher said that the Merger Process does not address projects like this very
well and also said that USFWS permits were critical. He recommended that the
NCDOT begin serious discussions with the USFWS to. come to an agreement,
stating that the team needs to resolve the legal issues (e.g. easement through the
Refuge). Chris said NCDOT needs an "out of the box" approach, perhaps including
an independent mediator to facilitate FHWA and USFWS conflict resolution. Chris
also said that NCDOT and FHWA could begin independent discussions with CEQ
informally and then ask for more formal arbitration. Rob Hanson said that NCDOT
wants to go through normal channels first because of potential court challenges, and
NCDOT is trying to get done what can be done at this decision-making level. Chris
Militscher asked again if a state funding statute can limit the range of alternatives
considered under NEPA.
With no further questions, the meeting ended.
Action Items:
• Provide to EPA more details on the operations and maintenance costs in the SSDEIS.
• Provide more information on SSDEIS construction costs relative to 1-10 bridge costs.
• Provide copies of the CE for the new Bonner Bridge rehabilitation project to the Merger
Team members.
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YEARS
To: Beth Smyre
From: Bill Rice
Date: August 1, 2007
Memorandum
Subject: North Carolina Department of Environment and Natural Resources (NCDENR),
Division of Water Quality (DWQ) July 25, 2007 Meeting Summary - Bonner
Bridge Replacement Project (TIP No. B-2500)
Attendees:
Robin Smith, NCDENR
Amy Simes, NCDENR
John Hennessy, NCDENR-DWQ
David Wainwright, NCDENR-DWQ
Clarence Coleman, FHWA
Beth Smyre, NCDOT-PDEA
Brian Yamamoto, NCDOT-PDEA
Rob Hanson, NCDOT-PDEA
Lori Kroll, NCDOT
John Page, PB
Bill Rice, PB
Bill Biddlecome, USACE
NCDENR/ DWQ Views of the Phased Approach Alternative Issues
Beth Smyre opened the meeting by saying that the NCDOT was in the process of meeting
with the agencies that did not concur with the Phased Approach Alternative as the LEDPA,
and she noted that the Division of Water Quality's (DWQ) concerns with the Phased
Approach related to the cost estimates, and the loss of recreational uses and aquatic life
uses of the Atlantic Ocean. With respect to this, John Hennessy stated that the issues brief
that the DWQ submitted is clear on these issues, and that there is likely no way to address
the project aside from assuming that it will eventually be in the ocean.
NCDOT Views of The Phased Approach Alternative Issues
Lori Kroll said that similar to other agencies, the possibility of the finished project eventually
being in the Atlantic is not ideal; however the upfront construction cost of the Pamlico Sound
Bridge Corridor makes it not practicable. The other Parallel Bridge Corridors utilize land from
the Pea Island National Wildlife Refuge, a Section 4(f) resource. Clarence Coleman said the
NC 12 easement within the Refuge is not considered a Section 4(f) resource.
DOI Secretary Kempthorn's Letter Regarding the Bonner Bridge
Robin Smith about Department of Interior (DOI) Secretary Kempthorn's 2006 letter as it
relates to the LEDPA decision. Lori Kroll said that the letter only deals with the Oregon Inlet
Bridge and not the NC 12 portion of the project. The NC 12 section, however, could not be
legally separated from the bridge replacement.
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Constructing a Bridge That will Eventually be In the Ocean
Robin Smith asked about the safety of a bridge that would eventually be in the surf zone.
Lori Kroll said NCDOT consulted with 65 engineers nationwide (as part of the August 2006
Constructability Workshop) who concurred that the project could be built and would be
operationally safe. Robin then asked if there were other examples of similar structures in the
ocean. Clarence Coleman said there is a structure on Interstate 110 in Mississippi on the
Gulf of Mexico, but it is shorter than the proposed Phased Approach bridges.
Environmental Aspects of a Bridge in the Ocean
Robin Smith said effects to fish, benthic organisms, and use of the beach were concerns to
DWQ. Lori Kroll said the next Merger Meeting is within two weeks, and it is likely that no
additional information related to these impacts would be available by then. Robin Smith
asked if the primary reasons for the Phased Approach as the LEDPA were the Section 4(f)
and refuge compatibility issues. She asked if other approaches were considered. Clarence
Coleman said that other approaches to the selection of a LEDPA were considered, but this
decision must meet the requirements of existing law and other approaches would not meet
existing law.
Permits
Robin Smith said that her organization had spoken with the USACE regarding phased
permitting for subsequent road improvements and that the USACE stated it was possible.
Clarence Coleman said that phased permitting would be acceptable to the FHWA. Robin
Smith asked if the ROD could acknowledge a plan to use phased permitting. Clarence
Coleman said that this would be acceptable, but the initial ROD must choose an alternative
that addresses USFWS compatibility and Section 4(f). Lori Kroll said NCDOT and FHWA
must choose an alternative for the ROD that also addresses the NC 12 section of the project.
Beth Smyre then asked if there was a difference between permitting a project that is built on
land but later is in the ocean and permitting a project that is initially constructed over the
ocean. John Hennessy said he did not know. Bill Biddlecome then that for bridge projects
that fall under the jurisdiction of the US Coast Guard and are permitted under Section 9 of
the Rivers and Harbors Act of 1899, the bridge piles are not classified as fill and no Section
404 permit is needed. Bill noted, however, that the Corps has the additional responsibility of
ensuring that any NEPA documentation discusses impacts to endangered species and to
other trust resources.
CEO Phased Approval Process
Lori Kroll and Robin Smith discussed the potential to employ the Council on Environmental
Quality (CEQ) phased approval process. Lori Kroll said that the project very likely does not
fall within the eligibility criteria for employing CEQ's phased approval process. It could have
met the criteria if the problems on NC 12 were an anticipated future problem. However,
problems on NC 12 exist today. Clarence Coleman said the Phased Approach is adaptive
and that the Phased Approach could evolve with changing circumstances with reevaluations
of the FEIS and/or revisions to the ROD. Clarence also noted that the Phased Approach
design in the SSDEIS assumes a worst-case scenario by assuming the worst case 2060
shoreline and that all potential breach locations are bridged.
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Engineering Excellence
Yoo
YEARS
File
August 1, 2007
page 3
Compatibility Determination Triggering Section 4(f) Assessment
John Hennessy asked how an USFWS compatibility determination triggers a Section 4(f)
evaluation. Clarence Coleman said that to use Section 4(f) lands, the body responsible for a
Section 4(f) resource must tell the FHWA that they agree with a De Minimis finding, which is
that a project will have no adverse effect on the protected resource. If the Refuge finds an
alternative incompatible with the plans and mission of the Refuge, then they are saying to the
FHWA that the alternative has adverse impacts to the Refuge. If a De Minimis finding
cannot be reached, then the FHWA must pursue avoidance alternatives that do not use
Section 4(f) lands. If another Parallel Bridge Alternative were compatible with the Refuge,
then FHWA would discuss a De Minimis finding with the Refuge. Clarence Coleman said the
Pamlico Sound Bridge Corridor is Section 4(f) lands avoidance alternative, but it is not
affordable with its up front construction cost. The Phased Approach also is an avoidance
alternative because it stays within the existing NC 12, easement.
Post LEDPA Flexibility
The inherent flexibility of choosing a LEDPA that assumes the Oregon Inlet bridge is built
now and decisions are made on NC 12 later was discussed further. Clarence Coleman
again said that the approach of choosing the Phased Approach now and, if needed, revising
it later offers similar flexibility. John Hennessy said that parallel bridge in the surf zone could
cause major impacts to the Green sea turtle habitat and perhaps with that consideration, one
could conclude that NC 12 improvements that. remain in the Refuge would have less impact
on the Refuge. The approximately 50 acres of wetland impact associated with the Road
North/Bridge South Alternative was discussed. Brian Yamamoto said that Refuge officials
also were concerned that, after the bridge over Oregon Inlet is built, the treatment of the
roadway through the Refuge will revert to the status quo of repairing it as needed. Lori Kroll
asked if it is possible to have the flexibility to adjust the roadway improvements based on
future conditions noted as a component of the Phased Approach. Clarence Coleman again
said that the proposed LEDPA could evolve with changed conditions.
With no further questions, the meeting ended.
e-mail: [e-mail]
direct line: 919-468-2129
file no.: 3301 2.7.2
J:\PLANNING\Bonner SDEIS\Preferred Alternative Selection\Meeting Minutes\DWQ 7-25-07.doc
Over a Century of
Engineering Excellence
Supplemental Information
• B-5014 (Bonner Bridge Repair) CE (June 2007)
• Operations & Maintenance Costs Information (June 2006)
. 919 856 4353
ur, Nib 0,"/ 03: 10r=FIWH North Carolina Divis 919-856-4353 y p
JUL 2 5 2007
CATEGORICAL EXCLUSION ACTION CLASSIFICATION FORM
lrnimllf=: <:fnkiti.•,:.S;iiii
TIP Project Number: R-5014 ;::ithlrOttiii!)ti% I l.rtuk sk.:. t t,.tr,;:';t
State Project Number: 41490.3.1
Federal Aid Project Number: BRMS 0012 (34)
A Project Description: Bridge pile and cap reinforcement and fender system
repair on Bonner bridge over Oregon Inlet in Dare County.
H. Purpose and Need: Bridge Maintenance
C. Proposed Improvements: Sirbcap replacement at besets 196,197 and 190. Pile
jackets rc:`nforcctncnt at bent 129,144,1451) 146,159 and 160. Repairs to the
fender system and installation of one pile cluster (dolphin).
Check one or nriore of the following Type II improvements that apply to the
proj ert:
1. 0 Modernization of a highway by resurfacing, restoration, rehabilitation,
reconstruction, adding shoulders, or adding auxiliary lanes (e.g. parking,
weaving, twining, combing)
a. ? I:estaring, Resurfacing, Rehabilitating, fund Rcconstnicting pavement
(3R and 4R improvements)
b. Cl widening roadway and shoulders without adding through lanes
c. El Modernizing gore treatments
d. ? Constructing lane improvements (merge, auxiliary, and tun lanes)
e. (] Adding shoulder drains
L Rcplacing and rehabilitating culverts, inlets, and drainage pipes,
including safety treatments
g. (J Providing driveway pipes
h. ? Performing minor bridge widening (less than one duough lane)
2, (1 Highway safety or traffic operations improvement projects including the
installation of ramp metering control devices and lighting.
a. [] Installing ramp metering devices
b. j Installing lights
c. C? Adding or upgrading guardrail
d. Installing safety barriers including Jersey type harriers and pier
protection
e. CJ Installing or replacing impact attenuators
f Q Upgrading medians including adding or upgrading median barriers
g. improding intersections including relocation andlor realignment
h. Q Making minor roadway realignment
i. E_1 Channcli Ling traffic
JwA 15 1J'7 03:11p FI4WA (North Carolina Divis 919-856-4353 P-2'
x :l 5. l.? r'Y.AJI /-I.•l.) 1?1 VI _I, UIi A. UVr-IN IIAY "Y X01 J; :N:I?RYIJJ•,1
, :'1?.1. l JJ WU.J
j.Performing clear zone safety improvements including rrrrloving
hazards and flattening slopes
k. [] Implementing traffic aid systems, signals, and motorist aid
1. Installing bridge safety hardware including midge rail retrofit
3. Bridge rehabilitation, reconstruction, or replacement or the construction of
grade separation to replace existing at-grade raslroad crossings.
u. [ I Rehabilitating, reconstructing, or replacing bridge approach slabs
b. El Rehabilitating or replacing bridge decks
c" M Rehabilitating bridges including painting (no red lead paint), scorer
repair, fender systems, and minor stnteturai improvements
d. ? Replacing a bridge (structure and/or fill)
4. 0 Transportation conidor fringe parking facilities
S. ? Construction of new truck weigh stations or rest areas
6. ? Approvals for disposal of excess right-of-way or for joint or limited use of
Tight•of-way, where the proposed use does not have signi.flcant adverse:
impacts,
. 7. .[] Approvals for changes in access control
8. C] Construction of new bus stone and maintenance facilities in areas used
predominantly for industrial or transportation purposes,wha-re such
construction is not inconsistent with existing zoning and located on or near
a street with adequate capacity to handle anticipated bus and support
vehicle traffic
9.^
Rehabilitation or reconstruction of existing rail and bus buildings and
ancillary facilities Where only minor amounts of additional land are
required and there is not a substantial increase, in the number of users
10. ? Construction of bus transfer facilities (an open area consisting of
passenger shelters, boarding areas, kiosks, and related street
improvements) when located in a commercial area or other high activity
center in which there is adequate street capacity for projected bus traffic
11. ? Construction. of rail storage and maintenance facilities in was used
predominantly for industrial or transportation purposes where such
construction is not inconsistent with existing zoning and.where there is no
significant noise impact on the surroi mding community
12, 0 A cquiwion of land for hardship or protective purposes, advance land
acquisition loans under section 3 (b) of the UMT Asst. Hardship and
turh .15 '07` 03: 11pFFIWH North Carolina Divis 919-856-435,0

protective buying will be per nitted only for a particular. pwcti or a limited
i:Ltrribr:r of parcels. These types of land acquisitions qualify for a C£; only
-where the acquisition will not limit the evaluation of alternatives,
including shins in alignment for planned construction projects, which troy
be required in the NEPA process. No project development on such laxtd
may proceed until the NEPA process has been completed.
D_ Special Project Information (Include Envirorunental Cotnmitments and Permits
Required)
1W 3 Permit from COE, 401,WaterQuality Certification from DNVQ and a
CANNA major Permit froin the Division of Coastal Management
E. Threshold Criteria
The follawing evaluation of threshold criteria mast be mrnpleted for Type It
actions.
ECOLOGIC- AY YES NO
(1) Will the project have a substantial impact on imy unique or
important natural resaozce?
(2) Toes the pralect involve any habitat where federally listed
endangered or threatened species may occur?
i
(3) Will the project affect anadroartous fish?
If the project. involves wetlaxids, is the amount of permanent

) andlor temporary wetland taking less than one-third (1/3) acre.
t and have all practicable trmeasures to avoid and minimize
wetlwid to curs been evaluated?
(5) Will cite project require use of U.S. Forest Service lands?

(6) Will the quality of adjacent water resources be adversely
`
impacted by proposed construction activities
.

??) Does the project involve waters classified as Outstanding
'
Dilater Resources (OWR) and/or High Quality Waters (HQW)?
(8) Will the project require fill in Waters of the United States in
any of the designated mountain trout counties?

(9) Does die project involve any krown underground storage tarries r t
I
(USTs) or hazardous materiMs sites? "„?
7u6. 15 '07 03: 11p _ FHWA North Carolina Bivis 919-856-4:353
PERMITS AND COORDINATION YES NO
If the project is located within a CAMA county, will the
(10) project signi{;candy affect the coastal zone and/or any "Area ?
of EnpironmentM Concern" (AF.C)?
(1 1) Doss the project involve Coastal Harrier Resources Act ?
resources?
(I2) Willa U.S. Coast Guard permit be requited? ?
Will the project result in the modification of any existing
t l) regulatory £loodway? ?
(14) Will the project require any stream. relocations or channel ? 0
changes?
SOCIAL, ECONOMIC, AND CULTURAL RESOU'RCES YES NO

{ 15) Will the project induce substantial impacts to planned growth
?
or land use for the r=?

(16) Will the project require the reloce lion of any family or
business?
Will the project have a disproportionately high and adverse
(17) human health and environmental effect an any minority or ?
law-income population?
(18) If the project involves the acquisition of right ofway, is the
' ? 0
amount of
right of way acquisition considered minor.
(19) Will the project involve any changes in access control? ?
,0)
(` Will the project subtantially alter the. usefuhleas and/or land
use of adjacent propelty?
(21) W"il I the project have an adverse effect on permanent rmanent local ?
traffic patterns or community cohesiveness.
Is the project included in an approved thoroughfare plan and/or
(?.?.) Transporto6on Improvement Program (and is, therefore, in ? ?
conformance with the Clean Air Act of 1990)?
(23) Is the project anticipated to cause an increase in traffic F1
voltunes?
p•4
tu;i 15 £f? 03: 11 Flit.ifl North Carolina Divis 919-€56•-4353
(24) 'Will traffic, be Maintained during construction using existing ?
roads, sreged construction, or on-site detours?
"YES NO
If the project is a bridge replacement project, will the bridge be
)5) replaced at its existing location (along the existing facility) and
t"' will all construction proposed in association with the bridge ? ?
replacement project be contained on the existing facility?.
?6) is there substantial controversy on social, economic, and
i" envirorar ental grounds concerning aspects of the action? ?
(27) Is the project consistent with all Federal, State, and local lays,
relating to the envirnnamental aspects of the action?
Will the project have an "effect" on structures/properties
(?8) eligible for or listed on the National Register of Historic ?
PISCS^i:'J?
(29) Will the project affect any archaeological remains which are ?
important to ,ziS,ory or pre4iistory?
Wilt the project require the use of Section 4(1) resources
30)
( (public barks, recreation lands, wildlife and waterfowl refuges,.
?
historic sites or historic bridges, as defined in Section 4(1) of
the MS. Department of Transportation Act of 1966)?
Will the projeceresttit in any conversion of assisted public

t;1) recreation sites or facilities to non-recreation uses, as defined ?
by Section G(f) of the Land and Water Conservation Act of
1965, as amentlt d?
Will the project involve Constructian in, across, or Adjacent to
(32) a river designated as a component of or proposed for inclusion 11 LA
in the naiuml Will aad Scenic Rivers?
F. Additional Doctunentation Required for Unfavorable Responses in Part E
(Discussion regarding all unfavorable responses in Part E should be provided
below. Additional supporting documentation -nay be attached, as necessary)
Pottntial staging urea is on NPS parking fat udjarent to Oregon Inlet Fishing
Center. Thi9 parking lot has been used on previous projects for staging
equipment and supplies during bridge repair. Thert is also barge access on
the IJSMS property an the south side of the inlet, which way be used.
P. ', ....
Jun 15-07 03:11p F"Fiwn North Carolina Divis 919 056-4353 P.6
1 3: Utp O J V I S 11 ki I F_ll1=iV 1 L 1-4- , '. 3191'-?43b i M3. 1tt`_f ylf:l'!
5•
0. CE Approval
"rip Project Number. B-5014
State P.rojeet Number. 41470.3.1
Federal Aid Project Number: IBRNHS 0012 (34)
Project Description: (Include project scope and location)
Bridge pile and cap reinforcement and fender system repair on Bonner
bridge over Oregon Inlet in Dare Ct?unty.
Categorical Exclusion Action Classification: (Check one)
LJ Type H (A)
M 'T'ype 11(1)
Approved:
, a-t? Division Maintenance Engineer
Date Division Project Manager
Dote Divisi Environmental Officer
For Type 11(B) projects only:
Elate Division Administrator
Federal Highway Administrator
Operations and Maintenance Costs
Supporting Documentation
Table of Contents
SSDEIS Table 2-2 - Highway Costs to 2060 (High) ..............................................................A-2
Pamlico Sound Bridge Corridor with Curved Rodanthe Terminus O&M Costs .............A-3
Pamlico Sound Bridge Corridor with Intersection Rodanthe Terminus O&M Costs ... ... A-4
Parallel Bridge Corridor with Nourishment Alternative O&M Costs ..............................A-5
Parallel Bridge Corridor with Road North/Bridge South Alternative O&M Costs .......... A-6
Parallel Bridge Corridor with All Bridge Alternative O&M Costs .................................. ...A-7
Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge Alternative
O&M Costs ............................................................................................................................... ..A-8
Parallel Bridge Corridor with Phased Approach/Rodanthe Nourishment Alternative
O&M Costs ..................................................................................................................................A-9
Operations Cost Estimates for Bonner Bridge Replacement
Alternatives (3/28/06) ............................................................................................................. A-10
Existing NC 12 Maintenance Cost Estimates (3/06) ........................................................... A-15
Bridge Inspection, Maintenance, and Rehabilitation Cost Estimates
for Bonner Bridge Replacement Alternatives (3/06) .......................................................... A-16
A-1
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Supplement to the Bonner Bridge A-2 2-17 NCDOT TIP Project Number B-2500
Replacement SDEIS
Pamlico Sound Bridge Corridor with Curved Rodanthe Terminus Operations and Maintenance Costs
Road and Bridge Operation and Mainte

Year

Curved Rodanthe
--Road Annual

Curved Rodanthe
-- 12-Year Operations
Equipment
Capital Cost
(Initial and
Periodic
Replacement
Operations
Equipment
Annual
Maintenance Cost

Storm Related NC
12 Maintenance

Bridge Inspection
and Maintenance

Curved Rodanthe
Terminus
200 $ $0 sc $0 $
2009 $129,8 $ $553,000 $0 $682,800
201 $129,8 $ $553,000 $0 $682,80
2011 $129,80 $ $ $553,000 $0 $682,80
201 $129,80 $,9,275,00( $0 $553,000 $0 $5,957,800
201 $3,70 - $596,472 $0 $4,938,43 $5,538,604
201 $3,70 $596,472 $0 $4,938,43 $5,538,604
207 $3,70 $596,472 $0 $4,938,432 $5,538,604,
201 $3,70 $ $596,472 $4,938,432 $5,538,60
201 $3,70 $596,472 $ $4,938,43 $5,538,604
201 $3,7 $596,472 $0 $4,938,43 $5,538,604
201 $3,7 $596,472 $4,938,43 $5,538,60
202 - $3,70 $ $596,472 $ $4,938,432 $5,538,60
2021 $3,7 $ $596,47 $ $4,938,43 $5,538,604
2022 $3,7 $1,405, $596,472 $0 $4,938,43 $6,943,604
2023 $3,70 $55 $596,472 $0 $4,938,43 $5,594,104
202 $3,7 $596,472 $0 $4,938,432 $5,538,604
2025 $3,70 $596,47 $0 $4,938,432 $5,538,604
202 $3,70 $0 $596,472 $0 $4,938,432 $5,538,604
2027 $3,70( $0 $596,472 9 $4,938,43 $5,538,604
202 $3,7 - $596,472 $0 $4,938,43 $5,538,604
202 $3;70 $596,472 $0 $4,938,43 $5,538,604
2030 $3,70 $ $596,472 $ $4,938,432 $5,538,604
2031 - $3,70( V $0 $596,472 $0 $4,938,43 $5,538,604
203 $3,70( V $1,405,0001 $596,472 $0 $4,938,43 $6,943,604
20331 $3,7 $596,47 $4,938,43 $5,538,604
20 $3,7 $596,47 $4,938,43 $5,538,60
20 $3,70 $55,5 $596,47 $4,938,43 $5,594,104
2036 $3,70 $596,47 $4,938,43 $5,538,604
203 $3,7 $596,472 $( $4,938,43 $5,538,604
203 $3,7 $596,47 $4,938,43 $5,538,604
203 $3,70 $596,472 $0 $4,938,432 $5,538,604
2 $3,7 $596,472 $0 $4,938,432 $5,538,60
2041 $3,7 $596,472 $0 $4,938,43 $5,538,
2044 $3,7 $1,405, $596,472 $0 $4,938,43 $6,943,604
2 $3,7 $596,472 $0 $4,938,43 $5,538,604
20 $3,70 $596,472 $0 $4,938,432 $5,538,604
204 $3,70 $596,472 $( $4,938,43 $5,538,6041
2046 $3,7 $596,472 $( $4,938,43 $5,538,604
204 $3,7 $55,50( V $596,472 $( $4,938,43 $5,594,104
2048 $3,70 $596,472 $( $4,938,43 $5,538,604
204 $3,70( V $ $596,472 $4,938,43 $5,538,60
2050 $3,7 $596,472 $( $4,938,43 $5,538,604
2051 $3,7 $5%,472 $0 $4,938,43 $5,538,604
205 $3,70C $( $1,405, $596,47 $43,291,165 $45,296,33
205 $3,7 $596,47 $43,291,165 $43,891,33
205 $3,70( V $ $596,472 $0 $4,938,43 $5,538,604
205 $3,7 $ $596,472 $0 $4,938,43 $5,538,604
205 $3,7 $596,472 $0 $4,938,43 $5,538,604
205 $3,70 $596,47 $4,938,432 $5,538,604
205 $3,700 1 $( $0 1 $596,472 1 0 $4,938,432 $5,538,6
205 $3,70 $55,50 $596,47 $ $4,938,432 $5,594,10
2060 $3,7 $596,47 $4,938,43 $5,538,604
TOTAL $696,800.0 $222,000.0 $10,895,000. $28,630,656.00 $2,212,000.01 $313,750,179. 44 $356,406,635.
A-3
Pamlico Sound Bridge Corridor with Intersection Rodanthe Terminus Operations and Maintenance Costs
Road and Bridge Operation and 6laintenence Costs to 206

Year

Intersection
Rodanthe - Road
Annual

Intersection
Rodanthe -12-
Year Operations
Equipment

Capital Cost
(Initial and
Periodic
Replacement)
Operations

Equipment
Annual
Maintenance Cost

torm Related NC
72 Maintenance

ridge Inspection
and Maintenance

Intersectlon
Rodanthe
Teminus
2008 $0 $C $0 $0 $0 $0 $C
2009 $129,8 $ $553,0 $682,80
201 $129,80 $ $ $0 $553,000 $ $682,80
2011 $129,8 $ $0 $553,000 $ $682,80
201 $129,8 $ $5,275,000 $553,000 $ $5,957,800
201 $1,2 $ $596,4 $4,938,43 $5,536,10
201 $1,20 $ $596,472 $0 $4,938,43 $5,536,104
201 $1,20( $01 $ $596,472 $0 $4,938,43 $5,536,1041
201 $1,2 $596,472 $0 $4,938,43 $5,536,1
201 $1,2 $ $596,472 $0 $4,938,43 $5,536,104
201 $1,2 $596,472 $4,938,43 $5,536,104
201 $1,20 $596,472 $4,938,43 $5,536,104
202 $1,20 $ $596,47 $0 $4,938,43 $5,536,104
2021 $1,20 $ $ $596,47 $ $4,938,43 $5,536,10
2022 $1,2 $ $1,405,0 $596,47 $ $4,938,43 $6,941,104
2023 $1,2 $18,00 $596,4 $4,938,43 $5,554,10
202 $1,2 $596,4 $4,938,43 $5,536,104
2025 $1,2 $596,47 $ $4,938,43 $5,536,104
202 $1,2 $596,472 $0 $4,938,43 $5,536,104
2027 $1,2 $596,472 $0 $4,938,43 $5,536,104
202 $1,2 $596,472 $0 $4,938,43 $5,536,1
202 $1,20 $596,472 $0 $4,938,432 $5,536,1
2030 $1120 $ $596,47 $0 $4,938,43 $5,536,1
2031 $1,20( $1 $ $596,472 $ $4,938,43 $5,536,1
203 $1,2 $ $1,405, $596,47 $ $4,938,43 $6,941,1
2033 $112 $596,47 $4,938,43 $5,536,1
2034 $1,2 $596,472 $0 $4,938,43 $5,536,1
2035 $1,2 $18, $596,472 $0 $4,938,43 $5,554,1
2036 $1,2 $596,472 $0 $4,938,43 $5,536,1
203 $1,20C $( $596,472 $0 $4,938,43 $5,536,104
2038 $1,2 $596,47 $4,938,43 $5,536,104
203 $1,2 $596,472 $4,938,43 $5,536,104
2040 $1120 $596,472 $4,938,43 $5,536,104
2041 $1,2 $596,472 $0 $4,938,4321 $5,536,104
2042 $1,2 $1,405, $596,472 $0 $4,938,43 $6,941,104
2043 $1,2 $596,472 $0 $4,938,43 $5,536,104
2 $1,2 $596,472 $0 $4,938,43 $5,536,104
2045 $1,2 $596,472 $0 $4,938,43 $5,536,104
2046 $1,2 $596,472 $0 $4,938,43 $5,536,1
204 $1,2 $181 $596,472 $( $4,938,43 $5,554,104
2048 $1,2 $596,47 $4,938,43 $5,536,104
204 $1,20 $ $596,472 $0 $4,938,43 $5,536,104
205 $1,20 $596,472 $0 $4,938,432 $5,536,104
2051 , $1,2 $596,472 $( $4,938,43 $5,536,104
205 $1,20C $( $1,405, $596,472 $( $43,291,165 $45,293,83
205 $1,2 $596,472 $0 $43,291,165 $43,888,83
2054 $1,2 $596,472 $0 $4,938,43 $5,536,1
205 $1,2 $596,472 $0 $4,938,43 $51536,1
- 205 $1,2 $596,472 $0 $4,938,43 $5536,10
205 $1,20 $ $596,472 1 $0 $4,938,43 $5536,1
205 $1,20 $0 1 $596,472 $0 $4,938,432 $5,536,10
205 $1,2 $18,00 $ $596,47 $0 $4,938,43 $5,554,10
20 $1,20 $596,47 $4,936,43 $5,536,10
TOTA $576,800.0 $72,000.0 $10,895,000. $28,630,656.0 $2,212,000.00 $313,750,179. $356,136,635.44
A-4
Parallel Bridge Corridor with Nourishment Alternative Operations and Maintenance Costs

Year

Nourishment--
Road Annual

Nourishment--12
Year Operations
Equipment
Capital Cost
(Initial and
Periodic
Replacement
Operations
Equipment
Annual
Maintenance Cost

Storm Related NC
12 Maintenance

Bridge Inspection
and Maintenance

Nourishment
200 $ $0 $0 $0 $0 $0 $0
2001, $129,80 $ $0 $ $0 $129,800,
201 $129,8 $ $ $ $ $129,800
201 $129,8 $ $ $0 $0 $129,800
201 $129,80 $4,316, $ $0 $0 $4,445,800
201 $129,8 $ $165,07 $ $828,73 $1,123,611
201, $129,80 $165,072 $ $828,73 $1,123,611
20151 $129,80C $1 $( $165,072 $0 $828,73 $1,123,611
201 $129,8 $ $165,07 $ $828,73 $1,123,611
201 $129,8 $165,07 $ $828,73 $1,123,611
201 $129,8 $165,072 $828,73 $1,123,611
201 $129,8 $165,072 $828,73 $1,123,611
202 $129,8 $165,072 $0 $828,73 $1,123,611
2021 $129,8 $ $165,072 $ $828,73 $1,123,611
2022 $129,80 $836,00 $165,07 $ $828,739 $1,959,611
2023 $129,80 $1,947,0 $165,072 $ $828,73 $3,070,611
202 $129,8 $165,07 $ $828,73 $1,123,611
2025 $129,80 $ $165,07 $ $828,73 $1,123,611
202 $129,80 $165,072 $ $828,73 $1,123,611
202 $129,8 $165,07 $ $828,73 $1,123,611
202 $129,80C $( $01 $165,072 $0 $828,73 $1,123,611
202 $129,80 $165,072 $0 $828,73 $1,123,611
2030 $129,8 $165,072 $ $828,73 $1,123,611
2031 $129,8 $165,072 $828,73 $1,123,611
203 $129,8 $836, $165,07 $ $828,73 $1,959,611
2033 $129,8 $165,072 $0 $828,73 $1,123,611
2034 $129,8 $165,072 $0 $828,73 $1,123,611
203 $129,80 $1,947,0 $ $165,072 $0 $828,73 $3,070,611
2036 $129,8 $165,07 $ $828,73 $1,123,611
203 $129, $165,072 $0 $828,73 $1,123,611
2038 $129,8 $165,07 $ $828,73 $1,123,611
203 $129,80 $165,072 $ $828,73 $1,123,611
2040 $129,80 $165,07 $ $828,73 $1,123,611
2041 $129, $165,072 $( $828,73 $1,123,611
2042 $129,80( $q $836,001 $165,072 V $828,73 $1,959,611
2043 $129,80 $165,072 $( $828,73 $1,123,611
2044 $129,8 $ $165,07 $828,73 $1,123,611
2045 $129,8 $165,07 $ $828,73 $1,123,611
2046 $129, $165,072 $0 $828,73 .$1,123,611
204 $129,8 $1,947,00( $q $165,072 $0 $828,73 $3,070,611
204 $129,80 $ $165,072 $ $828,73 $1,123,611
204 $129,8 $165,07 $ $828,73 $1,123,611
2050 $129,8 $165,072 $0 $828,73 $1,123,611
2051 $129, $165,07 $828,73 $1,123,611
205 $129, $836, $165,072 $ $11,637,821 $12,768,693
205 $129, $165,07 $828,73 $1,123,611
2054 $129,M $( V $165,07 $ $828,73 $1,123,611
205 $129, $165,07 $828,73 $1,123,611
205 $129,80 $165,072 $ $828,73 $1,123,611
205 $129,80 $165,072 1 $0 1 $828,739 $1,123,611
205 $129,80 $165,07 $ $828,739 1 $1,123,611
205 $129,8 $1,947, $165,07 $828,73 $3,070,611
206 $129,80 $165,07 $828,73 $1,123,611
TOTA $6,749,600.0 $7,788,000.0 $7,660,000.00 $7,923,456.00 $0.00 $50,588,564.56 $80,709,620.5
A-5
Parallel Bridge Corridor with Road North/Bridge South Alternative Operations and Maintenance Costs
j Road and Bridge Operation and Maintenance Costs to 2060

Year

Road North/
Bridge South -
Road Annual

Road North/
Bridge South --
12-Year Operations
Equipment
Capital Cost
(Initial and
periodic
Replacement
Operations
Equipment
Annual
Maintenance Cos

Storm Related NC
12 Maintenance

Bridge Inspection
and Maintenance

Road Northl
Bridge South
200 $ $ $ $ $0 $
2009 $129,80 $ $ $553,000 $0 $6B2,800
207 $129,80 $ $ $553,000 $0 $682,800
2011 $129,8 W3,000 $0 $682,800
201 $129,80C $( $4,336, $165,93 $553,000 $1,637,955 $6,822,691
201 $107,2 $ $ $165,93 $ $1,637,955 $1,911,091
201 $107,20 $ $165,936 $ $1,637,95 $1,911,091
20151 $107,2 $ $165,936 $0 $1,637,95 $1,911,091
201 $107,2 $165,936 $0 $1,637,95 $1,911,091
201 $107,20 $165,936 $0 $1,637,95 $1,911,091
201 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
201 $107,20 $ $ $165,93 $0 $1,637,95 $1,911,091
202 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
2021 $107,20 $ $165,936 $ $1,637,95 $1,911,091
20221 $107,2 $ $856,0001 $165,936 $0 $1,637,95 $2,767,091
2023 $107,20 $1,608,00 $165,93 $ $1,637,95 $3,519,091
202 $107,20 $ $165,936 $ $1,637,95 $1,911,091
2025 $107,20 $ $165,936 $ $1,637,95 $1,911,091
202 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
2027 $107,20 $ $165,936 $0 $1,637,95 - $1,911,091
202 $107,20 $165,936 $0 $1,637,95 $1,911,091
202 $107,20 $ $165,936 $ $1,637,95 $1,911,091
2030 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
2031 $107,20 $165,936 $0 $1,637,95 $1,911,091
203 $107,20 $856, $165,936 $ $1,637,95 $2,767,091
203 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
2034 $107,20 $ $ $165,936 $0 $1,637,95 $1,911,091
203 $107,20 $1,608, $165,936 $ $1,637,95 $3,519,091
2036 $107,20 $ $ $165,936 $0 $1,637,95 $1,911,091
203 $107,20 $165,936 $0 $1,637,95 $1,911,091
2038 $107,20 $165,936 $0 $1,637,955 $1,911,091
203 $107,20 - $165,936 $( $1,637,955 $1,911,091
20 $107,20 $ $165,936 $( $1,637,95 $1,911,091
2041 $107,20 $ $165,936 $( $1,637,95 $1,911,091
2042 $107,20 $856,OCq $165,936 $( $1,637,95 $2,767,091
2043 $107,20 $165,936 $( $1,637,95 $1,911,091
2 $107,20 $165,936 $( $1,637,95 $1,911,091
204 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
2046 $107,2 $ $165,93 $ $1,637,95 $1,911,091
204 $107,20 $1,608,00( V $165,936 $0 $1,637,95 $3,519,091
2 $107,20 $165,936 $0 $1,637,95 $1,911,091
204 $107,20 $165,936 $0 $1,637,95 $1,911,091
205 $707,20 $ $165,936 $0 $1,637,955 $1,911,091
2051 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
205 $107,20 $8561 $165,93 6 $0 $22,375,74 $23,504,88
205 $107,20 $ $165,936 $ $1,637,95 $1,911,091
2054 $107,20 $165,936 $0 $1,637,95 $1,911,091
205 $107,2 $165,93 $ $1,637,95 $1,911,091
205 $107,20 $ $ $165,936 $0 $1,637,955 $1,911,091
2057 $107,20 $ $165,936 1 $0 $1,637,95 $1,911,091
205 $107,20 $ $165,936 $0 $1,637,95 $1,911,091
205 $107,2 $1,608, $165,936 $ $1,637,95 $3,519,091
20 $107,20 $165,936 $0 $1,637,95 $1,911,091
TOTA 15,664,800.0 $6,432,000.00 1 $7,760,000.0 $8,130,864.0 $2,212,000.00 $100,997,566.91 $131,197,230.91
A-6
Parallel Bridge Corridor with All Bridge Alternative Operations and Maintenance Costs
Road and Bridge Operation and Maintunance Costs to 2060

Year

All Bridge -- Road
Annual

All Bridge --12-
Year Operations
Equipment
Capital Cost
(Initial and
Periodic
Replacement)
Operations
Equipment
Annual
Maintenance Cos

Storm Related NC
12 Maintenance

Bridge Inspection
and Maintenance

All Bridge
200 $ $0 $0 $
2009 $129, $ $ $ $553,000 $0 $682,800,
201 $129,80 $ $ $ $553, $682,800
2011 $129,80 $ $ $ $553,000 $0 $682,800
201 $129,80 $ $5,195,000 $ $553,000 $0 $5,877,800
.201 $35,00( V $ $517,972 $3,819,69 $4,372,669
201 $35, $ $517,972 $3,819,69 $4,372,66
201 $35,00( R $01 $517,97 $3,819,69 $4,372,66
201 $35,00( -
V $0 $517,97 $3,819,69 $4,372,66
201 $35, $517,97 $3,819,69 $4,372,66
201 $35, $ $517,97 $3,819,69 $4,372,66
201 $35,0 $ $ $517,972 $3,819,69 $4,372,66
202 $35,0 $ $517,972 $3,819,69 $4,372,66
2021 $35,00 $ $ $517,972 $ $3,819,69 $4,372,66
2022 $35,00 $ $1,405,0001 $517,97 $ $3,819,69 $5,777,66
2023 $35,00 $5251 $ $517,97 $ $3,819,69 $4,897,669
202 $35,00 $517,97 $ $3,819,69 $4,372,66
2025 $35,00 $517,97 $3,819,69 $4,372,669
202 $35, $517,972 $0 $3,819,697 $4,372,66
2027 $35,00 $517,972 $( $3,819,69 $4,372,66
202 $35, $517,972 $( $3,819,69 $4,372,66
202 $35,00 $ $517,972 $( $3,819,69 $4,372,6691
203 $35,0 $ $517,972 $3,819,69 $4,372,66
2031 $35,0 $ $517,97 $ $3,819,69 $4,372,66
203 $35,00 $ $1,405,000 $517,97 $3,819,69 $5,777,66
203 $35,00 $517,972 $0 $3,819,69 $4,372,66
2034 $35, $517,972 $0 $3,819,69 $4,372,66
2035 $35, $525, $517,972 $0 $3,819,69 $4,897,66
2036 $35, $517,972 $0 $3,819,697 $4,372,6691
203 $35,00 $517,972 $0 $3,819,69 $4,372,66
203 $35, $ $517,97 $3,819,69 $4,372,66
203 $35,00 $517,972 $( -$3,819,69 $4,372,66
2040 $35,00 $( V $517,972 V $3,819,69 $4,372,66
2041 $35,0 $( $0 1 $517,972 $3,819,6971 $4,372,66
2042 $35,0 $1,405, $517,97 $3,819,69 $5,777,66
204 $35, $517,97 $3,819,69 $4,372,66
2044 1 $35, $517,972 V $3,819,69 $4,372,66
204 $35, $517,97 $3,819,69 $4,372,66
2046 $35,00 $517,972 $0 $3,819,69 $4,372,66
204 $35, $525, $517,972 $0 1 $3,819,69 $4,897,66
2048 $35, $517,97 $3,819,69 $4,372,66
204 $35, $( $0 1 $517,97 $3,819,69 $4,372,66
205 $35,0 $ $517,972 $ $3,819,69 $4,372,66
2051 $35, $ $517,972 $ll $3,819,69 $4,372,66
205 $35,00 $1,405, $517,97 $ $52,458,76 $54,416,734
205 $35,00 $ $517,97 $3,819,69 $4,372,66
205 $35, - $517,97 $3,819,69 $4,372,66
205 $35, $517,972 $0 $3,819,69 $4,372,66
205 $35, $517,972 $0 $3,819,69 $4,372,66
205 $35, $ $517,972 $0 $3,819,69 $4,372,66
205 $35,00 $( $U I $517,972 $ $3,819,697 $4,372,66
205 $35,0 $525,00( $517,97 $0 $3,819,69 $4,897,669
206 $35,00 $ $517,972 $Id $3,819,69 $4,372,669
TOTA $2,199,200.00 $2,100,000.0 $10,815,000.00 $24,862,656.00 $2,212,000. $231,984,541.16 $274,173,397.1
A-7
Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge Alternative Operations and Maintenance Costs
g oad and Bridge Operation and Maintenance Costs to 2060

Year

oad Annual

oad 12-Year Operations
Equipment
Capital Cost
(Initial and

Periodic
Replacement
Operations
Equipment
Annual

Maintenance Cos

Storm Related NC
12 Maintenance

Bridge Inspection
and Maintenance

Phased Approach
(with Bridge Into
Rodanthe)
2008 $0 $0 $C $0
2 $1i=;8v $276, $276500
201 ..*.12 V,00 - $0 $276,50 $276,500
2011 5t 29 8" $0 $0 $276, $276,500
201 $129,50(. $4,336,000 $0 $276, $4,612,500
201 $1,9160; $167,43 $276,5 $7Sz,529 $1,227,465
201 µl27£04. $ $167,436 $276, :783.529 $1,357,265
20151 $129;8(7. $1,155,0 $167,436 $276,500 $1-1113,529 $2,512,265
201 $63,60 $637,972 $0 X2.720,629 $3,422,201
201 6,3,6tR $ $637,972 $-0 52,72((;29 $3,422,201
201 *3,601 $( $637,972 so +^_720,629 $3,422,201
201 $63,6(x) $637,972 $0 $2,730:629 $3,422,201
202 $61,6tk $637,9 52.720,620 $3,422,201
2021 39:9Rf. $637,972 V 5z,.335;:ks9 $4,073,311
2022 $39,9)U WK000 $637,9 $3,395,43; $4,929,311
2023 X39,90(? Z?598,0(+0 $637,972 53,395.459 $4,671,311
202 $:9,9tly $637,97 $3.395,439 $4,073,311
2025 <19,900 $845,000 $637,972 $3,3?15;459 $4,918,311
2026 533„tOCr $0 $637,97 $,1,395,439 $4,073,311
202 539.900. $637,9 $3,395.459 $4,073,311
2028 $32%,90!; $C $637,972 $0 $3;59 ;439 $4,073,311
2029 ,19.90( $C $637,972 $0 $3,395.9 $4,073,311
2030 S?Fi,:1uG $637,972 $0 $3,395,439 $4,073,311
2031 $637,97 $ $4,2&4.60 o $4,945,372
203 $22,Stk $856,OOC $637,972 $0 $4,284,btY $5,801,372
2033 $22.80. $ $637,972 ` ,2- 4,60: $4,945,372
2034 1 $( $637,97 $4,2,K& $4,945,372
203 $22,5(u. $8451 $637,972 $( X4,2-1.60; $6,131,372
2036 $( $637,97 $4,2.14,60 $4,945,372
203 $22,Stk $637,97 ?4.284,6(4 $4,945,372
2038 C22,8f}(' $637,97 $4,284,1,00 $4,945,372
203 $22,1',CR $637,972 $( 4;284,6PO, $4,945,372
2040 $2^.8(H, $637,97 $4,284:600 $4,945,372
2041 $2z, kk $637,97 $ 54284,600 $4,945,372
2042 1 ?..80t. $856, $637,97 $4,84,6(.. $5,801,372
2043 $22,800 $637,972 $( 54.284,600 $4,945,372
2044 ,22;800 $637,972 $( $4;2_84;600 $4,945,372
204 $22,8i'C $845, $637,972 $( 44,284,(,00
2046 .,22.800. $637,97 44,281,600 $4,945,372
204 522,80!; 5:-41,0(;4 $637,972 $( $4,2S4,e01J1 $5,286,372
204 ,22.80(. $637,972 $( $4,284. W $4,945,372
204 522,800 $637,972 $0 $4,254,600 $4,945,372
2050 522180( $637,972 $0 $4,28-1,6(2 $4,945,372
2051 52?,800 $637,972 $4,254,600 $4,945,372
205 $22,5(?: $856, $637,972 $ $16,610,454
2053 V $637,972 $0 $4,254,E+(H; $4,945,372
205 :922,$00 $637,972 $0 X4,284,000 $4,945,372
2055 1 22,0. $845, $637,972 $0 $28.395,;}2; $30,100,795
205 $22,500 $ $637,97 $ -,?4,28 ,600 $4,945,372
205 e22.d(;i $637,972 $0 54,2S4,tv}' $4,945,372
205 $22,50, $637,9 4,284,6a $4,945,372
205 ""go ( 1341,010' $ $637,97 54,284,6iR $5,286,372
2060 S22,S40 $637,972 4 54.264,6.0 $4,945,372
TOTA $2,309,600.00 $1,621,000.00 $12,295,000.0 $29,211,048.0 $1,935500.00 $213,565,624.18 $260,288,772.18
A-8
Parallel Bridge Corridor with Phased Approach/Rodanthe Nourishment Alternative Operations and Maintenance Costs
A eration and Maintenance Costs to 2060

Year

Road Annual

Road 12-Year Operations
Equipment
Capital Cost
(Initial and
Periodic
Replacement
Operations
Equipment
Annual
Maintenance Cost

Storm Related NC
12 Maintenance

Bridge Inspection
and Maintenance
Phased Approach
(with
Nourishment at
RMantho)
200 $0 $C $0 9 $0
2009 $124 Ak $ $276,500 $276,500
201 29'800 $ $276,500 $276,500
2011 $124,86'.6 $0 $276,500 $276,500
2012 5129,fi(h. $0 $4,336,00( $0 $276 $4,612,500
201 $124 $ $167,436 $276,500 $753,52 $1,227,465
201 5129,$1+. $167,436 $276,500 5?8352 $1,227,465
201 $i $1,155, $167,436 $276, $783,52 $2,382,465
201 $71,310 $ $637,97 52.450,-:0(. $3,159,978
2017 571.,30E $0 $637,97 $2,450,70 $3,159,978
2018 $71,30{ $0 $0 $637,972 $( 52.450,70 $3,159,978
201 $0 $637,97 $2,4:+0;706 $3,159,978
202 $71,3('6 $ $637,97 5^_:450;,'@t $3,159,978
2021 i?47.600 $0 $637,972 $ 53,125,5, 17 $3,811,087
2022 $111,11,00 $0 $956,OOC - $637,972 $3.72,515 $4,667,087
20 47,600 $7i 4,{10(` $637,972 $ $3,125.:15 $4,525,087
202 $-V oX' $0 $637,972 $ 53.12.'^,545 $3,811,087
2025 °47,601? $ $845,000 $637,972 $33,125. 5 15 $4,656,087
202 $47,600 $0 $C $637,972 $3,125,515 $3,811,087
202 $47.600 $ $ $637,972 $ $3,125.515 $3,811,087
202 $47,600 $0 $637,972 $0 ?,,,i,l?+,;1715 $3,811,087
202 $47,600 $0 so $637,972 $0 $3,1'25.515 $3,811,087
20 $4,',600 $0 $637,972 $0 $5,125,-515 $3,811,087
2031 $30,500 $0 $0 $$637,972 $0 $4,014.676 $4,683,148
203 530,506 $856,000 $637,97 $ $3,014,676 $5,539,148
2033 $30,50 $637,972 $0 14,014.676 $4,683,148
2034 5A0 501 $637,9'P $4,014,67( $4,683,148
2035 $30,50{ $4 7,N,0 $845, $637,972 $0 54,031,67,c $5,985,148
2036 S30,500 $637,972 $0 $4,0.14,676 $4,683,148
203 $.5,0,500 $ $637,97 ±4014,6,76 $4,683,148
203ZI 530,5(' $0 $( $637,972 $0 $4,014,67 $4,683,148
203 $30150G $0 $01 $$637,972 $( 54014,671 $4,683,148
2040 530501: $637,972 V 54,d 14,G7 $4,683,148
2041 Kt)"RK $637,972 $( 54.014,676 $4,683,148
2042 530.58. $856, $637,972 $( $4,01+67 $5,539,148
204 530,51 $637,972 $( $4.034,6.76 $4,683,148
2044 530.500. $637,972 $( $4,1614.676 $4,683,148
2045 530;+610 $0 1 $845, $637,972 $0 $4,014,676 $5528,148
2046 1 430100 $0 $0 $637,972 $0 $4,01€.676 $4,683,148
2041 $50,50' S4-5',013{. $0 $637,972 $0 $U114,676 $5,140,148
204 $30.501' $0 $0 $637,972 <4,014.676 $4,683,148
204 $30,!i0G $0 so $637,972 $0 $014,676 $4,683,148
205 :301,100 $0 $637,972 $0 "A,01 4,67A, $4,683,148
2051 530,5tYJ $0 $637,972 $0 $4,014,67(, $4,683,148
205 530,5{4^ $856,000 $637,972 $0 5.1,4 K> 7R $16,348,950
205 $A0.500 $0 $ $637,972 $0 $4.,014,676 $4,683,148
2054 1 'S3f),SOS? $0 $ $637,972 $0 -L0146'r $4,683,148
205 530,500 $845,000 $637,972 $0 $24,93-!_im $26,451,053
205 $3>(,500 - $ $0 $637,972 $0 4,014,676 $4,683,148
205 530,50' $ $637,972 $ $4,014,{;76 $4,683,148
2058 $0 $637,97 541714,676 $4,683,148
205 0,50' ?457.OOC $637,97 $4,014,676 $5,140,148
20 $:5,0,$01 $637,97 54.014,6.71 $4,683,148
TOTA $2,656,100.00 $2,085,000.00 $12,295,000.0 $29,211,048.00 $1,935,500.00 $198,032,253.05 $245,306,301.0
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A-15

B-2500 DRI
PAMLICO SOUND BRIDGE CORRIDOR ALTERNATIVE 3/22/2006
Length 17.5 miles 92,400.00 ft Area = 3,936,240.0 sq ft
Out-to-Out Deck Width 42.6 ft
Segmental
Item Average Total
Cost per Estimated
Sq Ft per Cost per
Year Year
Total Inspection Estimated Cast per year $ 0.411 $ 1,016,99120
Total Estimated Maintenance Cost Per Year $ 0.844 $ 3,321,438.33
Total Estimated Cost For 1 Rehabilitation $ 19»48 $ 76,706,465.99 each
Ai Cost Estimates are In today's dollars.
I
A-16
r

B-2500
PARALLEL BRIDGE CORRIDOR WITH NOURISHMENT
Oregon Inlet Bridge
Length 14,370.00 ft Area =
Out-to-Out Deck Width 38.6 it
Segmental
Item Average
Cost per
Sq Ft per
Year
DRI
3122/2006
554,682.0 sq ft
Total
Estimated
Cost per
Year
tal Inspection Estimated Cost per year $ 0.369 $ 204,677.66
l Estimated Maintenance Cost Per Year $ 1.125 $ 624,061.56
ta
To
Total Estimated Cost For 1 Rehabilitation $ 19.49 $ 10,809,082.09 each
Ail Cost Estimates are in today's dollars.
I
A-17
s
f
%
B-2500 DRI
PARALLEL BRIDGE CORRIDOR ROAD NORTH/BRIDGE SOUTH 3/22/2006
Parallel Oregon Inlet Bridge
Length 14,528.00 ft Area = 560,780.8 sq ft
Out-to-Out Deck Width 38.6 ft
Segmental
Item Average Total
Cost per Estimated
Sq Ft per Cost per
Year Year
Total Inspection Estimated Cost per year $ 0.428 $ 240,001.20
Total Estimated Maintenance Cost Per Year $ 1.125 $ 630,923.20
Total Estimated Cost For 1 Rehabilitation $ 19.49 $ 10,927,929.34 each
All Cost Estimates are in today's dollars.
South Bridge AT Rodanthe
Length 2.47 miles 13,041.60 ft Area = 503,405.76 sq ft
Out-to-Out Deck Width 38.6 ft
Girder
Item Average Total
Cost per Estimated
Sq Ft per Cost per
Year Year
Total Inspection Estimated Cost per year $ 0.399 $ 200,658.50
Total Estimated Maintenance Cost Per Year $ 1.13 $ 566,371.69
Total Estimated Cost For 1 Rehabilitation $ 19.49 $ 9,809,862.56
All Cost Estimates are in today's dollars.
A-18
B-2500
PARALLEL BRIDGE CORRIDOR WITH ALL BRIDGE
DRI
3/22/2006
Oregon Inlet Parallel 1
Length
Out-to-Out Deck Width
Segmental
Total Inspection Estimated Cost per year
Total Estimated Maintenance Cost Per Year
Total Estimated Cost For 1 Rehabilitation
IAll Cost Estimates are in today's dollars.
14,661.00 ft Area =
38.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
565,914.6 sq ft
Total
Estimated
Cost per
Year
$ 242,198.34
$ 636,699.13
$ 11,027,971.64 each
South Bridge AT Rodanthe
Length 2.47 miles 13,041.60 ft Area = 503,405.76 sq ft
Out-to-Out Deck Width 38.6 ft
Girder
Item Average Total
Cost per Estimated
Sq Ft per Cost per
Year Year
Total Inspection Estimated Cost per year $ 0.399 $ 200,658.50
Total Estimated Maintenance Cost Per Year $ 1.13 $ 566,371.69
Total Estimated Cost For 1 Rehabilitation $ 19.49 $ 9,809,862.56
All Cost Estimates are in today's dollars.
5.2 Mile Bridge
Length 5.2 miles 27,456.00 ft Area =
Out-to-Out Deck Width 38.6 ft
Girder
Item Average
Cost per
Sq Ft per
Year
Total Inspection Estimated Cost per year $ 0.399
Total Estimated Maintenance Cost Per Year $ 1.13
Total Estimated Cost For 1 Rehabilitation $ 19.49
All Cost Estimates are in today's dollars.
1,059,801.60 sq ft
Total
Estimated
Cost per
Year
$ 422,438.94
$ 1,192,361.46
$ 20,652,342.23
A-19
c
3
i
E#
t
f
B-2500
PARALLEL BRIDGE CORRIDOR WITH ALL BRIDGE
DRI
3/22/2006
1.4 Mile Bridge
;Length
!Out-to-Out Deck Width
C Total Inspection Estimated Cost per year
Total Estimated Maintenance Cost Per Year
Total Estimated Cost For 1 Rehabilitation
All Cost Estimates are In today's dollars.
- - - - ------------ -
idge
0.4 miles
Deck Width
Total Inspection Estimated Cost per year
Total Estimated Maintenance Cost Per Year
"total Estimated Cost For 1 Rehabilitation
All Cost Estimates are in today's dollars.
7,392.00 ft Area = 285,331.20 sq ft
38.6 ft
Average Total
Cost per Estimated
Sq Ft per Cost per
Year Year
$ 0.399 $ 113,733.56
$ 1.13 $ 321,020.39
$ 19.49 $ 5,560,245.99
1.4 miles
2,112.00 ft Area = 81,523.20 sq ft
38.6 ft

Average Total
Cost per Estimated
Sq Ft per Cost per
Year Year
$ 0.399 $ 32,495.30
$ 1.13 $ 91,720.11
$ 19.49 $ 1,588,641.71
A-20
S .
OREGON INLET BRIDGE
270011 - BONNER BRIDGE
SUMMARY of ESTIMATED COSTS
DRI
REVISED
3!22/2006
SEGMENTAL
;
Item
Average
Cost per
Sq Ft per
- v A Year
Routine Inspection $ 0.206
UW inspection $ 0.222
Total Inspection Estimated Cost per year $ 0.428 per sq ft
Total Estimated Maintenance Cost Per Year $ 1.13 per sq ft
Total Estimated Rehabilitation Cost per Rehabilitation $ 19.49 per sq ft each
Prestressed I or Bulb T Girders Average
Item Cost per
Sq Ft per
Year
Routine Inspection $ 0.147
UW inspection $ 0.222
Total Inspection Estimated Cost per year $ 0.369 per sq ft
Total Estimated Maintenance Cost Per Year $ 1.13 per sq ft
Total Estimated Rehabilitation Cost per Rehabilitation $ 19.49
Above Estimates are F o% cean Front Bridges
SEGMENTAL
Item Average
Cost per
Sq Ft per
Year
Routine Inspection $ 0.189
UW inspection $ 0.222
Total Inspection Estimated Cost per year 0.411 per sq ft
Total Estimated Maintenance Cost Per Year $ 0.844 per sq ft
Total Estimated Rehabilitation Cost per Rehabilitation $ 19.49
Prestressed I or Bulb T Girders
Item Average
Cost per
Sq Ft per
Year
Routine Inspection $ 0.135
UW inspection $ 0.222
Total Inspection Estimated Cost per year $ 0.367 per sq ft
Total Estimated Maintenance Cost Per Year $ 0.844 per sq ft
Total Estimated Rehabilitation Cost per Rehabilitation $ 19.49

Above Estimates are Fo ound Bridge

A-21
e
I
4
s
t
B-2500
Balanced Approach
Phase II Structures (Post 2015)
DRI
3/31/2006
Bridge #1 Sta 2856+51
Length
Out-to-Out Deck Width
Segmental
Item
I otal inspection tstimatea cost per year
Total Estimated Maintenance Cost Per Year
Total Estimated Cost For 1 Rehabilitation
9,980.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
425,148.0 sq ft
Total
Estimated
Cost per
Year
$ 181,963.34
$ 478,291.50
$ 8,286,134.52 eact
Deck Width
inspection tstimatea cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
2720.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
115,872.0 sq ft
Total
Estimated
Cost per
Year
$ 49,593.22
$ 130,356.00
$ 2,258,345.28 each
Deck Width
Item
Total Inspection Estimated Cost per year
Total Estimated Maintenance Cost Per Year
Total Estimated Cost For 1 Rehabilitation
3615.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
6 0.428
E 1.125
6 19.49
153,999.0 sq ft
Total
Estimated
Cost per
Year
65,911.57
Bridge #4 Sta 3379+2
Length
Out-to-Out Deck Width
Segmental
inspection tstimatea cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
9180.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
391,068.0 sq ft
Total
Estimated
Cost per
Year
167,377.10
439,951.50
7,621,915.32 eact
All Cost Estimates are in today's dollars.
Include 1 Rehabilitation at 30 to 40 Years
A-22
B-2500 DRI
Balanced Approach 3/31/2006
Phase III Structures (Post 2025)
Bridae #1A (Extensio
Length
Out-to-Out Deck Width
Segmental
Item
Inspection Estimated Cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
1,265.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
6 0.428
6 1.125
6 19.49
53,889.0 sq it
Total
Estimated
Cost per
Year
23,064.49
1
60,625.13
1,050,296.61 eact
I(Extensio
Deck Width
inspection tstimatea cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
1130.00 it Area =
42.6 it
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
48,138.0 sq ft
Total
Estimated
Cost per
Year
$ 20,603.06
$ 54,155.25
$ 938,209.62 eacF
Out-to-Out Deck Width
Segmental
Item
Total Inspection Estimated Cost per year
Total Estimated Maintenance Cost Per Year
Total Estimated Cost For 1 Rehabilitation
1105.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
47,073.0 sq ft
Total
Estimated
Cost per
Year
20,147.24
52,957.13
917,452.77 eacF
Bridae #3B to #4A (Ei
Length
Out-to-Out Deck Width
Segmental
Item
inspection tstimatea cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
6155.00 it Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
262,203.0 sq ft
Total
Estimated
Cost per
Year
$ 112,222.88
$ 294,978.38
$ 5,110,336.47 eacF
I(Extensio
Deck Width
Inspection Estimated cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
855.00 ft Area =
42.6 it
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
36,423.0 sq ft
Total
Estimated
Cost per
Year
$ 15,589.04
$ 40,975.88
$ 709,884.27 eacF
Above estimated costs are in addition to costs from Phase II
All Cost Estimates are in today's dollars.
Probably Should include 1 rehabilitation about 2055. A-23
B-2500 DRI
Balanced Approach 3/31/2006
Phase IV Structures (Post 2035)
Bridae #2A (Extension) Sta 3120+00 to 3181+
Length
Out-to-Out Deck Width
Segmental
Item
otai inspection t_stimatea Lost per year
Total Estimated Maintenance Cost Per Year
Total Estimated Cost For 1 Rehabilitation
6,175.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
263,055.0 sq ft
Total
Estimated
Cost per
Year
$ 112,587.54
$ 295,936.88
$ 5,126,941.95 eact
Bridae #2AA (Extensi
6150.00 ft Area =
42.6 ft
Average
Cost per
Sq Ft per
Year
$ 0.428
$ 1.125
$ 19.49
261,990.0 sq ft
Total
Estimated
Cost per
Year
$ 112,131.72
$ 294,738.75
$ 5,106,185.10 eact
Length
Out-to-Out Deck Width
Segmental
Item
Inspection Estimated Cost per year
Estimated Maintenance Cost Per Year
Estimated Cost For 1 Rehabilitation
If costs are carried through 2060, would not need to include a rehabilitation.
Above estimated costs are in addition to costs from Phase II and III
All Cost Estimates are in today's dollars.
A-24
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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY LYNDO TIPPETT
GOVERNOR SECRETARY
AGENDA
Eastern Concurrence Meeting
ednesdav. Au us 15, 2007
Board Room, Transportation Building
Raleigh, North Carolina
2:00 PM to 4:00 PM, Beth Smyre, Project Planning Engineer, PDEA Branch
TIP No. B-2500 Bonner Bridge Replacement, Highway 12 Over Oregon Inlet
Dare County, Division 1
Team Members:
Bill Biddlecome, USACE
Beth Smyre, PDEA
Clarence Coleman, FHWA
Chris Militscher, USEPA
Ron Sechler, NMF
Mike Murray, NPS
Pete Benjamin, USFWS
Mike Bryant, USFWS - PI NWR
Renee Gledhill-Earley, SHPO
John Hennessy, DWQ
David Cox, WRC
Jim Gregson, DCM
Mike Street, DMF
NCDOT Technical Technical Support Staff and Other Agency Staff-Staff and Other Agency Staff-
Scott McLendon, USACE
Ron Lucas, FHWA
Kathy Matthews, USEPA
Gary Jordan, USFWS
Dennis Stewart USFWS
Thayer Broili, NPS
Clay Willis, Division 1
Travis Wilson WRC
David Wainwright, DWQ
Sara Winslow, DMF
Cathy Brittingham, DCM
Doug Hugget, DCM
Jim Hoadley, DCM
Anne Deaton, DMF
Sarah McBride, SHPO
Brian Yamamoto, PDEA
Rob Hanson, PDEA
Adrian Cox, Albemarle RPO
Consultants:
John Page, PB
Bill Rice, PB
Bobby Norburn, PB
Margery Overton, FDH
Sam Cooper, CZR
* The purpose of this meeting is to continue discussions on Concurrence Point 3.
NOTE: Please bring the packet that was mailed to you for the May 23`d meeting.
MAILING ADDRESS: TELEPHONE: [phone] LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: [phone] TRANSPORTATION BUILDING
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WEBSITE: WWW.DOH.DOT.STATE.NC.US RALEIGH NC
RALEIGH NC 27699-1548
North Carolina Department of Transportation
NEPA/Section 404 Merger Meeting
May 23, 2007
NC 12 Replacement of Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet
Federal-Aid Project No. BRS-2358(15)
WBS No. 32635
TIP Project No. B-2500
Dare County
NEPA/Section 404 Merger Meeting - May 23, 2007
NC 12 Replacement of Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet
AGENDA
1. Introduction and Purpose of this Meeting
II. Project History and Current Status
A. Project History
B. Current Status
2007 Supplement to the 2005 SDEIS
• Merger Team Meetings during Preparation of Supplement
- June 2006 Merger Team Meeting
- September 2006 Merger Team Meeting
- December 2006 Merger Team Meeting
March 2007 Public Hearings
III. Review Alternatives and Impacts
A. Pamlico Sound Bridge Corridor
• with Curved Rodanthe Terminus
• with Intersection Rodanthe Terminus
B. Parallel Bridge Corridor
• with Nourishment
• with Road North/Bridge South
• with All Bridge
• with Phased Approach/Rodanthe Bridge
• with Phased Approach/Rodanthe Nourishment
IV. NCDOT Preferred Alternative
V. Current Schedule
NEPA/Section 404 Merger Meeting
May 23, 2007
NC 12 Replacement of Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet
Federal-Aid Project No. BRS-2358(15)
WBS No. 32635 (TIP Project No. B-2500)
1. Introduction
The NCDOT proposes to replace the Herbert C. Bonner Bridge across Oregon Inlet in Dare
County. Bonner Bridge, built across Oregon Inlet in 1962, is approaching the end of its
reasonable service life. Bonner Bridge is part of NC 12 and provides the only highway
connection between Hatteras Island and Bodie Island. The replacement structure would serve the
same function. Two replacement bridge corridors are being considered: the Pamlico Sound
Bridge Corridor and the Parallel Bridge Corridor with NC 12 Maintenance. This project is
identified in the 2007 to 2013 Transportation Improvement Program (TIP) as TIP Project No.
B-2500.
The purpose of this meeting is to review the detailed study alternatives and their potential impacts
and to identify the Least Environmentally Damaging Practicable Alternative (Concurrence
Point 3).
II. Project History and Current Status
A. Project History
1. 1993 Draft Environmental Impact Statement
In 1990, NCDOT began studying replacement alternatives for Bonner Bridge (TIP No. B-2500).
The coordination for the project, including agency scoping, was initiated with a scoping letter to
government agencies in May 1990 at the start of a Bonner Bridge replacement feasibility study.
The feasibility study was undertaken to examine promising Oregon Inlet crossing replacement
alternatives. A Citizens Informational Workshop also was held in 1990. Agency input from the
scoping letter and public input from the workshop helped to formulate the range of alternatives
examined in the feasibility study that was completed in April 1991.
Citizens Informational Workshops were held in early 1991, at which the alternatives and
preliminary feasibility study findings were presented for public review. In May 1991, a second
scoping letter-along with copies of the final feasibility study report-was distributed to state
and federal environmental resource and regulatory agencies. On May 29, 1991, a formal scoping
meeting was held for local, state, and federal agencies. Input from the scoping letter, the scoping
meeting, and the workshops was used to finalize the alternatives and issues to be considered in
the 1993 DEIS.
In addition to agency coordination conducted as part of the scoping process and data gathering,
additional coordination meetings were held with agencies during preparation of the 1993 DEIS to
discuss permitting and mitigations issues. In April 1993, the four cooperating agencies (US Coast
Guard, USACE, NPS, and USFWS) were asked to examine a review copy of the DEIS.
Revisions were made to the DEIS based on their comments. The DEIS assessed a single
preferred alternative, the Parallel Bridge Corridor across Oregon Inlet. After the release of the
DEIS in November 1993, two combined (corridor and design) Public Hearings were held in early
1994. Comments were received regarding the DEIS from the public and from federal, state, and
local agencies.
2. 1996 Preliminary Final Environmental Impact Statement
A preliminary Final Environmental Impact Statement (FEIS) was prepared in 1996; however, it
was never signed because formal consultation with the USFWS under Section 7 of the
Endangered Species Act was not completed. Because it had been more than seven years since
completion of the DEIS, a re-evaluation was conducted in 2001 to determine if the preliminary
FEIS remained a valid assessment of project impacts. Copies of the preliminary FEIS were
distributed to state and federal environmental resource and regulatory agencies in May 2001. In
June 2001, a meeting was held with the FHWA, the NCDOT, and other state and federal
environmental resource and regulatory agencies to discuss the project. Based on the discussions
at this meeting, the decision was made in 2001 to prepare a Supplemental DEIS.
3. 2005 Supplemental Draft Environmental Impact Statement
Work on the SDEIS began in 2002 with a new study of potential Bonner Bridge replacement
alternatives. The project's first NEPA/Section 404 Merger Team meeting was held in July 2002.
The purpose of this meeting was to discuss the purpose and need of the project to replace Bonner
Bridge, the relation of the Bonner Bridge replacement project to NC 12 hot spot projects, and the
project study area. Concurrence was reached on the project's Statement of Purpose and Need
(Concurrence Point 1) as presented in the SDEIS. The team agreed that three needs relate to the
replacement of Bonner Bridge:
1. Continued demand for convenient daily and emergency access across Oregon Inlet is
expected.
2. The natural channel or gorge through Oregon Inlet migrates. A replacement bridge needs to
provide spans of sufficient height and width for navigation through the anticipated area of
future natural channel migration, helping to reduce future dredging needs, dredging impacts,
and the cost of dredging.
3. The southern terminus of Bonner Bridge is north of portions of NC 12 threatened by
shoreline erosion and overwash. Placing the southern terminus of a replacement bridge or a
long-term NC 12 maintenance and protection project south of these areas will reduce the
frequency of maintenance of these threatened segments of NC 12.
The project's second Merger Team meeting was held in February 2003. The purpose of the
second meeting was to identify the Bonner Bridge replacement corridor(s) to assess in detail in
the SDEIS. Concurrence was reached on two corridors for detailed assessment in the SDEIS
(Concurrence Point 2): Corridor Alternative 1 wide and Corridor Alternative 4.
The NCDOT also met with local officials in June 2003. This meeting was held at the request of
the Dare County Board of Commissioners. In addition to the Dare County Commissioners, a
commissioner from the Town of Duck and a commissioner from the Town of Nags Head
2
attended. The focus of local government comments was on the importance of maintaining
highway access to the recreational activities within the Refuge. Three Citizens Informational
Workshops also were held in mid-2003 in the project area. At these meetings, 173 persons
registered their presence. Representatives from the Refuge were present at all three workshops,
and a representative from the Seashore attended one of the workshops.
The Concurrence Point 2 decision was revisited at a July 2003 Merger Team meeting, at which
the main objectives were to discuss revising the alternatives for detailed assessment in the SDEIS,
as well as to identify alignment locations to evaluate within the corridor and to discuss bridge
lengths (i.e., Concurrence Point 2A). Revisiting the Concurrence Point 2 decision was necessary
because subsequent to the February 2003 meeting the Refuge had concluded that it was unlikely
that Corridor Alternative 1 could be determined compatible with the purpose and mission of the
Refuge and, therefore, was unlikely to be permittable for a replacement bridge landing in the
Refuge. After further discussions, the Merger Team agreed to revise the Concurrence Point 2
agreement by dropping Corridor Alternative 1 wide from further consideration and focusing the
attention of the SDEIS on Corridor Alternative 4 (i.e., the Pamlico Sound Bridge Corridor). The
Merger Team also concurred on the following at the July 2003 meeting: that the bridge should be
placed approximately 1 mile (1.6 kilometers) farther west than agreed to at the February 2003
meeting in order to reduce the need for dredging during construction; and that two termini options
at Rodanthe should be evaluated in the SDEIS, Segment A (Curved Rodanthe Terminus) and
Segment C (Intersection Rodanthe Terminus). The Merger Team also concurred on the
alignment and approximate bridge length of each alternative (i.e., Concurrence Point 2A) at the
July 2003 meeting.
The NEPA/Section 404 Merger Team Co-Chairs met in July 2004 to discuss the addition of the
Parallel Bridge Corridor with NC 12 Maintenance to the alternatives to be evaluated in detail in
the SDEIS. The attendees included members of the following agencies: the NCDOT, the
USFWS, the USACE, the FHWA, and the NCDENR - Division of Water Quality. It was agreed
that a variety of means for the maintenance of NC 12 should be assessed in the SDEIS, including
combinations of: road relocation; dune reconstruction; beach nourishment; elevated roadway;
and bridging of hot spots or island breaches. It was also discussed that if NC 12 leaves the
existing right--of-way, the Refuge's compatibility process would be triggered. The NCDOT
representative indicated that based on conversations with the remaining members of the Merger
Team there was a consensus that the Parallel Bridge Corridor should be evaluated in detail in the
SDEIS. The Co-Chairs agreed to circulate a concurrence form to the other Merger Team
members without calling a meeting, and the signing of the final revised Concurrence Point 2 form
was completed in October 2004.
In May 2005, the study team briefed the Merger Team on its definition of the Parallel Bridge
Corridor Alternatives to be evaluated in detail: Nourishment, Road North/Bridge South, and All
Bridge. Several environmental resource and regulatory agency representatives who also are part
of the Merger Team participated in the alternatives definition at meetings in January and April
2005.
In addition to the Merger Team meetings, between November 2002 and June 2005 the NCDOT
met with representatives of various environmental resource and regulatory agencies to discuss
specific issues related to natural and cultural resources within and near the project corridor,
including representatives of. the Refuge; Cape Hatteras National Seashore; NCDENR - DCM;
NCDENR - DMF; National Marine Fisheries Service; FHWA; USACE; NC Aquarium Society;
and SHPO.
The SDEIS was completed and signed in September 2005. Two Public Hearings were held in
November 2005. Approximately 207 people attended the two Public Hearings and written and
oral comments were received from 150 different individuals and organizations. Both hearings
were preceded by open house workshops. Summaries of both agency and public comments on
the 2005 SDEIS can be found in Appendix A of this packet.
B. Current Status
A proposal made during the comment period following the release of the SDEIS led to the
development of the Parallel Bridge Corridor with Phased Approach Alternative. This alternative
is evaluated in the Supplement to the 2005 SDEIS.
The first Merger Team meeting for the Supplement to the SDEIS was held on June 15, 2006. The
purpose of this meeting was to update the Merger Team on the additional alternative being
considered (the Phased Approach Alternative), as well as to update the Merger Team on revised
and augmented public cost estimates for each of the alternatives assessed in the SDEIS and the
additional alternative. The NCDOT also indicated that an engineering study to examine the
technical feasibility of the Phased Approach Alternative would be conducted and that the results
of this study would determine whether or not it would be presented to the Merger Team for
concurrence as a detailed study alternative.
The second Merger Team meeting for the Supplement to the SDEIS was held on September 21,
2006. The purpose of this meeting was to discuss the Final Report of the Bonner Bridge
Constructability Workshop (i.e., the engineering study of the Phased Approach Alternative that
was discussed at the June 2006 meeting), which took place in August 2006 in Kill Devil Hills, as
well as to decide whether or not a revised Concurrence Point 2 agreement should be signed to
include the Phased Approach Alternative so it could be evaluated in the Supplement to the
SDEIS. The Merger Team agreed that the Phased Approach Alternative fit within the definition
of the Parallel Bridge Corridor approved for detailed study in 2004. The NCDOT agreed to meet
again with the Merger Team to brief them on details related to its characteristics and impacts at a
future date.
A third Merger Team meeting for the Supplement to the SDEIS was held on December 14, 2006.
The purpose of this meeting was to present for discussion the functional designs of the two
Parallel Bridge Corridor with Phased Approach alternatives, as well as to discuss potential
impacts with the Merger Team in advance of the release of the Supplement.
The Supplement to the SDEIS evaluating the Phased Approach Alternative was completed and
signed on February 14, 2007. Following completion of the Supplement, a newsletter comparing
the impacts of the two replacement bridge corridor alternatives and announcing the two upcoming
Public Hearings was mailed in February 2007. The first Public Hearing was held in Manteo on
March 28, 2007 and the second Public Hearing was held in Rodanthe on March 29, 2007. Both
hearings were preceded by open house workshops. Approximately 244 people attended the two
Public Hearings. A total of 146 people provided comments on the project through April 25, 2007
(the comment period end date was April 23, 2007, as published in the March 9, 2007 Federal
Register). This included 39 people who spoke at the hearings (including 3 people who spoke at
both hearings) and 115 written comments (including 5 people who also spoke at the hearings).
A total of 115 of the commenters indicated a favored alternative, with 73 favoring one of the
Parallel Bridge Corridor alternatives (50 percent of the total 146 commenters) and 42 favoring
one of the Pamlico Sound Bridge Corridor alternatives (29 percent). The other 31 commenters
did not express a corridor preference, including 8 whose only concern was that a replacement
4
bridge needs to be built immediately (5 percent) and 23 who made general project-related
comments (16 percent). Summaries of both agency and public comments received on the
Supplement to the SDEIS can be found in Appendix B of this packet.
NCDOT has received resolutions and other official letters of support for the Parallel Bridge
Corridor alternatives from various elected officials representing the citizens of North Carolina. In
April 2007, the Town Manager of the Town of Nags Head provided NCDOT with a copy of a
resolution passed by the Nags Head Board of Commissioners in January 2006 which stated that
the Bonner Bridge should be replaced immediately with a parallel bridge. Secondly, during its
2005 Session, the NC General Assembly passed legislation (House Bill 747) recommending that
the replacement bridge be located with north and south termini in general proximity to the termini
at the existing Herbert C. Bonner Bridge. However, the legislation also recognized that the
preferred alternative for the bridge location cannot be determined prior to compliance with all
Federal and State laws and regulations. Finally, the NCDOT received a letter from USDOI
Secretary Kempthorne which indicated that the Secretary thought the best way to proceed with
the project would be to separate the replacement of the Bonner Bridge from the more difficult and
less urgent issues of the realignment of NC 12. The letter indicated that DOI believes the
replacement of the bridge itself could be accomplished in a way which is compatible with the
National Wildlife Refuge System Improvement Act of 1997, and other laws, if it is constructed
within the same easement or with minor changes to the current easement. With this
understanding, the letter said that NCDOT could quickly conclude their planning and begin
construction of a bridge to replace the existing bridge that Senator Burr stated is an imminent
threat to public safety. Governor Mike Easley, Senator Richard Burr, Congressman Walter Jones,
and State Senator Marc Basnight have all expressed their support of this position to NCDOT.
III. Summary of Alternatives and Impacts
The alternatives under consideration at this time are listed and briefly described below. These
alternatives are also shown in Figures 1 to 6 in this packet. A summary of the impacts associated
with each alternative is included in Tables I to 7 in this packet.
A. Pamlico Sound Bridge Corridor with Curved Rodanthe Terminus - contains
a proposed Pamlico Sound bridge that would be approximately 17.5 miles (28.2
kilometers) in length. The total project length would be 18 miles (29.0
kilometers), including the bridge and the approach roads at the northern and
southern ends. The southern terminus of the project would be within the
community of Rodanthe on Hatteras Island, where the proposed bridge would
end in a curve that would connect the bridge directly to NC 12. The bridge
would extend north from Rodanthe into Pamlico Sound up to approximately 5
miles (8 kilometers) west of Hatteras Island. The project would end at the
northern terminus of the Bonner Bridge on Bodie Island within the Seashore.
B. Pamlico Sound Bridge Corridor with Intersection Rodanthe Terminus - this
alternative is identical to the Curved Rodanthe Terminus, with the exception that
the southern terminus of the project in Rodanthe would end with a signalized
intersection at NC 12.
C. Parallel Bridge Corridor with Nourishment - contains the proposed Oregon
Inlet bridge that would be up to 2.7 miles (4.3 kilometers) in length, and uses
beach nourishment and dune enhancement to maintain a minimally adequate
beach and dune system to protect NC 12 in its current location through the
project area. The total length of beach requiring regular nourishment would be
approximately 6.3 miles (10.1 kilometers). Nourishment would occur in four
locations, likely repeated at four-year intervals.
D. Parallel Bridge Corridor with Road North/Bridge South - contains the
proposed Oregon Inlet bridge. However, starting at the project's southern
terminus in Rodanthe, NC 12 would be placed on a bridge west of Hatteras
Island beginning at a new intersection in Rodanthe and continuing to a point
approximately 2 miles (3.2 kilometers) north of the Refuge's southern boundary
where the project would meet existing NC 12. NC 12 would then remain
unchanged for 2.6 miles (4.2 kilometers). Beginning at a point approximately 1.3
miles (2.1 kilometers) south of the Refuge's ponds, NC 12 would be relocated to
a point 230 feet (70.1 meters) west of the forecast worst-case 2060 shoreline.
This relocation would continue 7.1 miles (11.4 kilometers) north until the
relocated NC 12 would meet the Oregon Inlet bridge. Three 10-foot-high (3-
meter-high) dunes, totaling 2,100 feet (640 meters) in length would be built, but
not immediately. They would be built when needed as the shoreline erodes
towards the relocated road. The first one is not expected to be needed until 2030.
E. Parallel Bridge Corridor with All Bridge - includes the proposed Oregon Inlet
bridge, as well as the same bridge in the Rodanthe area as the Road North/Bridge
South Alternative. In the central and northern part of the Refuge, NC 12 would
be constructed on a bridge to the west of the existing road. Two road segments
would be included in this relocation, one near Oregon Inlet and one just north of
the Refuge's ponds where access from NC 12 to the Refuge would be provided.
Access to the Refuge also would be available in a 1.8-mile (2.9-kilometer)
section of NC 12 that would be left unchanged between the Rodanthe area bridge
and the beginning of the next bridge section south of the ponds. The bridges
associated with this alternative would span the five potential storm-related island
breach locations.
F. Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge - this
alternative assumes an Oregon Inlet bridge and elevating portions of NC 12
through the Refuge and northern Rodanthe on new bridges within the existing
NC 12 easement. It would be built in four phases, with the first phase being the
bridge across Oregon Inlet. Additional phases would be built as necessitated by
shoreline erosion. With this alternative, the bridge in the existing NC 12
easement would begin in Rodanthe just north of Sudie Payne Road and extend
north to Oregon Inlet except for the 2.1 mile (3.4-kilometer) length of NC 12 in
the southern half of the Refuge that would not be threatened by erosion prior to
2060. Access to properties adjacent to the bridge in Rodanthe would be provided
by a one-lane, one-way frontage road on each side of the NC 12 bridge.
G. Parallel Bridge Corridor with Phased Approach/Rodanthe Nourishment -
this alternative would be similar except the southern end of the NC 12 bridge
would begin 0.3 mile (0.5 kilometer) south of the Refuge/Rodanthe border and
beach nourishment would be used to protect NC 12 in Rodanthe.
6
IV. NCDOT Preferred Alternative
NCDOT recommends the Parallel Bridge Corridor with Phased Approach/Rodanthe Bridge
Alternative as the project's LEDPA. NCDOT acknowledges the positions expressed by state and
federal environmental resource and regulatory agencies in their comments on the SDEIS and the
Supplement to the SDEIS that the Pamlico Sound Bridge Corridor is the least environmentally
damaging alternative. However, because of the high cost of the Pamlico Sound Bridge Corridor
and the lack of available funds to build a project at a cost of $1 billion or more in a single TIP
period, the Pamlico Sound Bridge Corridor is not practicable.
NCDOT acknowledges the concerns regarding Parallel Bridge Corridor with Phased
Approach/R.odanthe Bridge Alternative expressed by the US Department of Interior in the
comment letters on the SDEIS and the Supplement to the SDEIS. Therefore, it is the NCDOT's
intent to enter into discussions with US Department of Interior to accomplish the following:
• Clarify the comments and the concerns expressed and
• Identify and conduct additional analyses and/or studies needed to provide additional data
needed to address those concerns and to mitigate associated impacts.
V. Current Schedule
The following schedule is contingent upon a May 2007 LEDPA selection for this project:
• February 2008 Concurrence Point 4A - Avoidance and Minimization
• April 2008 Final Environmental Impact Statement
• August 2008 Record of Decision
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Section 404/NEPA Merger Project Team Agreement
Concurrence Point No. 3 - Least Environmentally Damaging
Practicable Alternative
Project No./TIP No./Name/Description:
Federal Project Number: BRS-2358(15)
WBS No. 32635
TIP Project Number: B-2500
Description: Replacement of the Herbert C. Bonner Bridge (Bridge No. 11) over Oregon
Inlet in Dare County
Least Environmentally Damaging Practicable Alternative:
The Bonner Bridge Project Team has concurred on this date of
with the Least Environmentally Damaging Practicable Alternative as the:
USACE
USEPA
NCD
SHPO
NMFS
NPS
NCDOT
USFWS
NCWRC
FHW.
NCDMF
NCDCM
USFWS-P1NWR
Appendix A
Summary of 2005 WEIS Agency and
Public and Comments
Bonner Bridge SDEIS
Agency Comments Summary
prepared by Parsons Brinckerhoff Quade & Douglas, Inc.
February 22, 2006
1. US Department of the Army, Corps of Engineers
Several of the Corps' comments were minor critiques or requests for clarification.
More detail in the impact assessment was requested regarding:
a. Impacts and mitigation for jetting and driving piles.
b. Removal and disposal of NC 12, if requested by the USFWS, with the Pamlico
Sound Bridge Corridor.
c. How the terminal groin issue would be handled with the USFWS (SDEIS
discussions are "ambiguous").
d. Methods, disposal areas, and impacts of construction dredging associated with
the Pamlico Sound Bridge Corridor.
2. US Environmental Protection Agency
Several of the EPA's comments were minor critiques or requests for clarification
related to shoulder widths on the Oregon Inlet bridge (which are narrower than the
other bridges), the chance for a storm-related breach of Hatteras Island, and the
breach economic impact assessment. The comments also include the EPA's thoughts
on how decision-making trade-offs should be handled related to storm-related
breaches, natural resource impacts, wetland impacts (fill and bridging), the past
position of Refuge officials on Refuge compatibility, the need for road access to the
Refuge, and community impacts. Regarding the Draft Section 4(f) Evaluation, the
EPA disagrees with the statement that the potential exists for the loss of paved road
access with the Pamlico Sound Bridge Corridor to cause an equal degree of harm to
the Refuge as the natural resource impacts associated with the Parallel Bridge
Corridor. Regarding mitigation, they offer observations related to the use of
temporary haul roads (Oregon Inlet bridge only) and request further consideration
of top-down construction with the Pamlico Sound Bridge Corridor.
In general, the EPA feels that additional information is needed regarding specific
avoidance and minimization measures with the Parallel Bridge Corridor alternatives.
They have "environmental objections" to all three alternatives. They would like
additional information on water quality impacts with the Pamlico Sound Bridge
Corridor. They feel, however, that the Pamlico Sound Bridge Corridor would
achieve the greatest long-term environmental benefits for the Refuge, while
Bonner Bridge Replacement Project TIP No. B-2500
A-1
providing reliable transportation access. Specifically, more detail in the impact
assessment was requested regarding:
a. Parallel Bridge Corridor with Nourishment Alternative
• Sand availability and suitability;
• Protected species impacts from dredging, construction, and nourishment and
dune maintenance;
• Essential fish habitat and benthic impacts from dredging; and
• The challenge of minimizing impacts during potential emergency repairs,
given that minimizing impacts is more difficult in an emergency situation
than for scheduled programs of coastal maintenance.
b. Parallel Bridge Corridor with Road North/Bridge South and All Bridge
alternatives: impacts to wildlife in the Refuge as a result of wetlands loss
(shading and fill), habitat fragmentation, and waterfowl collisions with vehicles
(All Bridge).
c. Pamlico Sound Bridge Corridor
• Functional impact of shading of the Sound in non-SAV areas (which the
commenters believe would not be great); and
• Water quality impacts from construction and operation (contaminant runoff).
Regarding the Nourishment Alternative, they also observe that although wetland
impacts are low, this alternative would have other significant environmental and
cost impacts, as opposed to the Pamlico Sound Bridge Corridor.
3. US Department of the Interior
The DOI supports the Pamlico Sound Bridge Corridor and believes it is prudent
from a Section 4(f) perspective. The DOI believes that the deficiencies they identified
in the SDEIS should be rectified in a revised SDEIS/Section 4(f) Evaluation. If the
document is not revised, the DOI may recommend referral of this project to the CEQ.
Almost all of the deficiencies identified are associated with the Parallel Bridge
Corridor.
Regarding the use and management of Refuge lands, the DOI states that fish and
wildlife must be considered first and foremost. They feel that the presence and
maintenance of NC 12 in the Refuge fragments habitat and disrupts coastal processes
in the Refuge. Furthermore, the increased maintenance that would be required with
the Parallel Bridge Corridor alternatives would be a source of continued and
expanded degradation.
Bonner Bridge Replacement Project
TIP No. B-
A-2
From a procedural perspective, as it relates to impacts on the Cape Hatteras National
Seashore, the DOI states that the National Park Service (NPS) determines the level of
environmental analysis required for all projects, including NCDOT projects, within
the boundary of its units. All NPS NEPA documents must contain a definition of
impact thresholds (minor, major, and moderate), state whether the impact is
beneficial or adverse, and state the duration of the impact. All of the replacement
bridge corridor alternatives are within the Cape Hatteras National Seashore.
The primary topics for which the DOI requests more information or more detailed
analysis are:
a. All alternatives
• Take into account the cost savings of not having to build the short-term hot
spot projects in the Refuge.
• Address how construction of any alternative would affect the gross sales at
the Oregon Inlet Marina and Fishing Center.
b. Parallel Bridge Corridor in general
• If NC 12 remains on Hatteras Island, overwash-related activities would
continue; take into account their impact and cost.
• A,dd a discussion of the effects of habitat loss, degradation, and
fragmentation on the diversity, biological integrity, and ecological integrity
of the barrier island system.
• Address the impacts of traffic and roadway maintenance noise on habitat
quality.
• Address road kills.
• Address the potential impacts to threatened and endangered species of
maintenance, dune reconstruction, sand fencing, sprigging, removing sand
and water, closing a new inlet, and repairing breaches.
• Mitigation proposals described in the SDEIS within the Refuge are likely not
possible, but mitigation is required to be on or adjacent to the Refuge.
• Additional threatened turtles are present in the study area beyond those
discussed in the SDEIS and the impact needs to be assessed.
• New information regarding the requirements of federally-listed species,
current policy/new legal requirements may affect what is found compatible
over the next 50 years.
Bonner Bridge Replacement Project TIP No. B-2500
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• Why are 6-foot shoulders assumed on the Oregon Inlet Bridge instead of
eight.
c. Parallel Bridge with Nourishment Alternative
• The need for and the availability of suitable sand appears to be substantially
understated given the amount of sand that has been placed at the north end
of Hatteras Island in the recent past.
• Information provided does not demonstrate that there is enough suitable
sand for nourishment through 2060. Also, over time source dynamics could
change.
• The biological suitability of the sand to be used needs to be assessed.
• The indirect and cumulative effects of repeated beach stabilization and
disruption of normal coastal processes is not adequately addressed.
d. Parallel Bridge with Road North/Bridge South and All Bridge Alternatives
Consider the impacts to the full zone or area between the relocated road and
the ocean.
Consider the impact of additional groins or revetments needed to protect the
road.
e. Pamlico Sound Bridge Corridor
• The Pamlico Sound Bridge Corridor would not only have no adverse impact
on the Refuge, but it would benefit the Refuge by removing the NC 12
pavement and the disruption associated with its maintenance. Removal of
utility lines also would benefit the Refuge. These benefits need to be
discussed.
• Some potential visitors to the Refuge might prefer the new form of access and
replace those who stop coming because of a lack of paved road access.
• Why dredge to 8 feet when 6 feet of water depth is acceptable in areas where
no dredging is needed?
• Provide more information on the species and numbers of wintering
waterfowl in Pamlico Sound.
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f. Other
The inclusion of a small-scale ferry service with the No-Action Alternative is
confusing because it does not meet the purpose and need of the project. An
adequately planned ferry service could serve Refuge visitors.
• Coastal modeling assumes the groin remains in place, what if it does not?
No NEPA studies are needed for groin removal since groin construction was
the result of a binding agreement between the NCDOT and the USFWS.
Conditions requiring removal of the groin should have been considered in
the Environmental Assessment for construction of the groin. Further NEPA
studies would be required in order to keep the groin once Bonner Bridge is.
demolished.
4. North Carolina Department of Environment and Natural Resources-Division of
Coastal Management
The Parallel Bridge Corridor with All Bridge and Road North/Bridge South are the
least preferred because of their significant impacts to CAMA wetlands. The
comments focus on the Pamlico Sound Bridge Corridor and Parallel Bridge Corridor
with Nourishment alternatives.
a. The project will require a CAMA major permit, with a preferred submission one
year prior to the construction let date.
b. All alternatives are consistent with the Dare County CAMA Land Use Plan.
c. The Outer Banks area should be considered for off-site wetland mitigation.
Converting one wetland type to a higher type is not acceptable. Mitigation
options presented in the SDEIS all seem to be reasonable mitigation options.
d. Pamlico Sound Bridge Corridor Alternative
• The bridge should include some sections higher than 10 feet above mean high
water outside the navigation zone to allow for the passage of traditional
commercial and recreational vessels.
More information is needed on the 8 miles of dredging in terms of impacts
and disposal.
e. Parallel Bridge Corridor with Nourishment Alternative
Assurance is needed that adequate amounts of sand would be available over
50 years.
• Nourishment can have significant negative impacts in terms of recovery of
flora and fauna, compatibility with sea turtle nesting, and the secondary and
Bonner Bridge Replacement Project TIP No. B-2500
A-5
cumulative impacts of other nourishment projects in the vicinity. These
impacts need to be avoided.
5. North Carolina Department of Environment and Natural Resources-Division of
Marine Fisheries
a. Pamlico Sound Bridge Corridor
• Need a current submerged aquatic vegetation (SAV) map to fully assess
construction dredging impacts.
• Why dredge to 8 feet when a 6-foot depth is adequate for barges?
• 'What sites would be used for dredging spoil?
• The proposed 10-foot vertical clearance outside the navigation zone would be
a hazard to navigation.
• Consider top down construction to reduce impacts to the sound bottom.
b. Parallel Bridge Corridor with Road North/Bridge South or All Bridge-Cannot
support these alternatives because of the extent of wetland loss.
c. Parallel Bridge Corridor with Nourishment-An adequate analysis is needed on
sand availability and compatibility for 50 years of beach nourishment.
d. The issue of future recreational fishing access (i.e., after the demolition of Bonner
Bridge and the catwalks) at the north end of Hatteras Island needs to be
adequately addressed.
e. The Division requests that Bonner Bridge debris be made available for use as an
offshore reef.
6. North Carolina Department of Environment and Natural Resources-Division of
Water Quality
a. Parallel Bridge Corridor
• The maintenance costs for NC 12 clean-up from minor storms needs to be
included.
• There is not a clear indication that the USFWS would issue a new permit for
the terminal groin.
• "Issuance of a 401 Water Quality Certification for the All Bridge and Road
North/Bridge South alternatives would be extremely problematic, at best,
and likely unpermittable, at worst."
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With the Parallel Bridge Corridor with Nourishment Alternative, more
information is needed on the sources, availability, and quality of sand for
nourishment.
b. Pamlico Sound Bridge Corridor- Why dredge to 8 feet when a 6-foot depth is
adequate for barges?
c. Include a discussion of potential wetland mitigation strategies.
d. It is suggested that storm water not be permitted to discharge directly into
streams or other surface waters.
7. North Carolina Department of Environment and Natural Resources-
Environmental Review
The focus of the letter was on the Pamlico Sound Bridge Corridor and the Parallel
Bridge Corridor with Nourishment.
a. Pamlico Sound Bridge Corridor
• Need more complete SAV surveys.
• Need more detail on construction dredging.
• Use top down construction in wetland and SAV areas.
b. Parallel Bridge Corridor with Nourishment
• Long-term affects of replacement bridge construction and long-term
maintenance and repair of NC 12 would create notable, not minimal,
secondary and cumulative impacts.
• The uncertainty of beach erosion and coastal storms are not fully considered
in the impact assessment.
• More details on sand availability for nourishment are needed.
• Is the cost of inflation considered?
8. North Carolina Department of Environment and Natural Resources-Natural
Heritage Program
a. The Pamlico Sound Bridge Corridor would cause the least impact to significant
natural resources and the Pea Island National Wildlife Refuge Registered
Natural Heritage Area.
b. The NCDOT should coordinate with the Wildlife Resources Commission on the
most recent locations and populations of nesting waterbirds in the vicinity of
Bonner Bridge Replacement Project TIP No. B-2500
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Oregon Inlet in order to make certain that the Pamlico Sound bridge does not
pass over areas where birds have recently nested. Otherwise the impacts to
colonial waterbird nesting islands and other natural areas because of the Pamlico
Sound bridge appear to be minimal.
c. All of the Parallel Bridge Corridor alternatives would impact a Registered
Natural Heritage Area to some degree.
d. The USFWS provision of some form of future access to the Refuge will have
some form of negative impact to important Refuge sites.
9. North Carolina Wildlife Resources Commission
a. Parallel Bridge Corridor with Road North/Bridge South and All Bridge
alternatives would both have substantial impacts to a federally-owned natural
area (i.e., the Refuge).
b. "Impacts associated with the Parallel Bridge Corridor are unacceptable." The
Pamlico Sound Bridge Corridor is believed to be the LEDPA.
c. Parallel Bridge Corridor with Nourishment Alternative
• The road would be susceptible to overwash and potential breach and would
not meet the purpose of providing a replacement crossing that is not
endangered by shoreline movement.
• Overwash provides important habitat, which is lost when overwash is
removed from the road.
• Nourishment does not allow for the natural migration of sand on barrier
islands.
• The analysis of impacts on beach and near shore invertebrate populations
and their recovery time needs to be completed in order to further consider
this alternative.
• Cumulative sand needs for the entire Outer Banks for beach nourishment
projects needs to be considered.
• A sand compatibility analysis needs to be done.
• Nourishment activity from April 1 to November 15 would impact nesting
shorebirds and sea turtles.
• The unpredictability of the lifespan of beach nourishment and inflation will
increase the cost of nourishment.
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Memorandum
To: B-2500 September 12, 2005 Supplemental Draft Environmental Impact
Statement Post Hearing Meeting Attendees
From: John Page
Date: March 10, 2006
Subject: Project: 8.1051205 (B-2500) Dare County
FA Project No. BRS-2358(15)
Bonner Bridge Replacement
Summary of Public Hearing Comments
Public Hearings were held on Wednesday, November 9, 2005 at the Dare County Justice
Center in Manteo, NC and Thursday, November 10, 2005 at the Rodanthe-Waves-Salvo
Community Center in Rodanthe, NC. Written and oral comments were received from 150
different individuals and organizations (multiple comments were received from several
individuals). The table below summarizes the comments received based on the alternative
favored.
Pamlico Sound Bridge Corridor
- Non-specific 36
- Curved Rodanthe Terminus 3
- Intersection Rodanthe Terminus 2
Total 41

Parallel Bridge Corridor
- Non-specific 81
- Non-specific from 2003 petition submitted with Senator Basnight's
comments; including 347 in state and 372 out-of-state (719)
- All Bride 3
- Road North/Bridge South 3
- Nourishment 6
- Compromise Solutions (Parallel Bridge with modifications to impact
Refuge as little as possible) 1
-
Total 94(813)

No Corridor Preference Specified
- Just build the bridge (which can be done faster/human environment
should take priority over natural environment 3
- General project-related comments 12
Total 15

Total Written and Oral Comments Received 150 (869)
Fifty-two of these comments were a form letter.
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Post Hearing Meeting Attendees
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page 2
Following is a summary of the oral and written comments that were submitted at
and following the Public Hearing:
• Concerns about Pamlico Sound Bridge Corridor
- Loss of public access to Refuge, including some comments that access details
should be worked out before decision is made to implement this corridor but
access emphasis is on full paved road access (76)
- Adverse impacts to Oregon Inlet navigation because groin would be removed (60)
- Too expensive, primarily in contrast to the Oregon Inlet bridge component of the
Parallel Bridge Corridor (60)
- Adverse impact on economy, primarily from non-road access to the Refuge (15)
- Bridge could be closed by high winds, crash, etc. (e.g., trucks, RVs, and cars with
car-top carriers are sometimes restricted on Chesapeake Bay Bridge-Tunnel
during windy conditions); of particular concern during hurricane evacuation (12)
- Potential traffic/safety problems, e.g., need passing/break-down lanes, provide for
u-turns, way to prevent head-on collisions (7)
- Adverse impact on wildlife/vegetation in Pamlico Sound because of dredging for
construction and bridge runoff (5)
- Would lead to northern end of Hatteras Island being left unprotected (2)
- High future Oregon Inlet dredging costs and inlet movement unpredictability if the
terminal groin is removed (2)
- Adverse impact to views of Pamlico Sound from Refuge (2)
- Bridge would not be a tourist attraction as some say (2)
• Concerns about Parallel Bridge Corridor
- Long-term beach erosion/migration of Refuge will continue and potential for a
breach to occur in the Refuge (22)
- Long-term maintenance of NC 12 through Refuge too expensive and
environmentally damaging (17)
- Moving NC 12 within Refuge will not be federally permittable; will take too long to
go through permit process and get various federal approvals, e.g., groin must be
re-permitted (11)
- Oregon Inlet is too dynamic for a bridge (3)
- Refuge is too susceptible to hurricane damage (2)
- Economic impacts of breach in NC 12 through Refuge would be substantial (1)
• Pamlico Sound Bridge Corridor Positives
- Best option for long term dependable/safe access (19)
- Preserves character/natural environment/wildlife of Seashore/Refuge and lets
nature take it's course (17)
- More cost effective over the long-term, gets the road away from an ever-changing
Hatteras Island (12)
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page 3
- Provides more reliable hurricane evacuation (7)
- Provides adequate access while reducing impacts on wildlife (4)
- Limits access to Refuge (preserving nature good for economy) (2)
• Parallel Bridge Corridor Positives
- Maintains current location of navigation channel and inlet (58)
- Maintains Refuge access, with a paved road (14)
- Practical, expedient, economical in that it spreads the costs out over a longer
period of time than the Pamlico Sound Bridge, which would need to be built all at
once (13)
- Less cost impact on power supply to Hatteras Island, i.e., it would be very
expensive to relocate the power supply on or parallel to a Pamlico Sound Bridge
(11)
- All Bridge Alternative would allow natural processes (e.g., overwash) to resume (3)
- Would help to reduce erosion in Refuge and allow groin to remain (3)
- Maintains full access to Oregon Inlet Coast Guard Station (2)
- Parallel Bridge Corridor is best option because of threat of Bonner Bridge collapse
(i.e., it can be built quicker and all other concerns related to Parallel Bridge are
less important than public safety, access, and the economy of Hatteras Island) (2)
• Other Comments
- Legal
1. Pamlico Sound Bridge does not require a USFWS compatibility determination.
2. Nourishment is the only alternative that would hold up in court since there is
precedence for the maintenance of NC 12, also it does not impact any
properties in Rodanthe.
- Navigation of Oregon Inlet
1. Primary concern is safe navigation through Oregon Inlet; need to make safer
and protect Inlet, including a groin on northern side of inlet.
2. Concerned with livelihoods of Oregon Inlet users.
3. Keep the groin in place no matter which alternative is selected.
- Bridge Design, Cost, and Timing
1. Time is getting short - need to get on with the project soon. Safety of existing
bridge and keeping NC 12 open until project finished is a concern. Funds for
that are needed, too.
2. Cost and impact of various alternatives on Cape Hatteras Electric Cooperative
must be considered (Pamlico Sound Bridge Corridor would have substantial
impacts).
3. Selected alternative should accommodate bicycles.
4. Build four-lane Pamlico Sound Bridge to address safety and congestion.
5. Icing on a Pamlico Sound Bridge is a concern.
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6. Extend the Pamlico Sound Bridge (possibly as a toll road) to bypass Rodanthe,
Waves, and Salvo, or just go with the Oregon Inlet bridge and improve NC 12.
7. Unless NCDOT abandons its right-of-way in the Refuge, the cost of ongoing
maintenance of NC 12 should be included in Pamlico Sound Bridge Corridor
costs. Also, USFWS cost for continued public access and environmental
impacts of access should be included.
8. Planning timeframe for the replacement bridge project is unclear in the SDEIS
(i.e., is the design life 50 years or 100 years?).
- Use of Demolished Bonner Bridge
1. Keep part of old bridge for recreational uses, i.e., fishing.
2. Use demolished bridge as part of artificial reef (for fish) near Oregon Inlet.
3. Use Bonner Bridge as a reef to help control erosion when it is torn down.
- Community Impact
1. If Bonner Bridge is closed before it is replaced, the economic impact on Dare
County would be substantial, so would the economic impact on the State.
Dare County is a donor county.
2. Oppose any alternatives that would adversely impact Mirlo Beach subdivision
at the north end of Rodanthe (support Nourishment to maintain community - it
is only alternative with no impact on people and their properties).
3. Most locals are for the Pamlico Sound Bridge, but not wanting to lose land in
Rodanthe to accommodate it.
4. Pamlico Sound Bridge would be a tourist attraction.
5. Pamlico Sound Bridge will help economy because dependable hurricane
evacuation will reduce time needed to evacuate people (i.e., allow tourists to
stay longer).
6. Use of Refuge is seasonal, so impact on economy of losing Refuge access will
not be that severe - most tourists go to areas north of Refuge for most of the
year.
7. Nourishment preserves what tourists come to Hatteras Island for, other
alternatives are unknowns in terms of economic impacts.
- Recreation Impact
1. Fishing catwalks should be built on the new bridge, whichever bridge is built.
2. Loss of access to Refuge beaches will put strain on other beaches on Hatteras
Island (e.g., overcrowding, too many vehicles to handle).
3. The Pamlico Sound Bridge and Rodanthe bypass bridge could have a
negative impact on recreation in Pamlico Sound.
4. Parallel Bridge Corridor supporters love the Refuge.
- Natural Resource Impact
1. NC 12 has been in the Refuge for a long time, yet the Refuge has still
appeared to thrive.
2. Wildlife will adapt to elevated road in Refuge.
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- Human Use of Refuge and Hatteras Island.
1. Human interests should take precedence over wildlife.
2. All necessary measures need to be taken to save Hatteras Island from erosion
(levies, beach nourishment, etc.); place human environment concerns ahead
of natural environment.
3. Many people who support the Pamlico Sound Bridge are still concerned about
access to the Refuge and keeping the groin to protect navigation of the
channel.
- Access Maintenance and Evacuation
1. Pamlico Sound Bridge will provide dependable hurricane evacuation that will
reduce time needed to evacuate people.
2. Oregon Inlet bridge provides better back-up access to Hatteras Island (i.e.,
with a maintained road on both sides of Oregon Inlet, it would be easier to
provide emergency access to island if the bridge were ever out for some
reason).
3. Parallel Bridge Corridor would leave residents to still deal with horrible road
conditions through Refuge in bad weather.
4. Opinions differ on which corridor is safer for evacuation. Road blocking
accidents are a concern with the Pamlico Sound Bridge.
5. Whichever alternative is chosen must maintain access to the entire Refuge.
Politics
1. In 2003, over 700 petitions from the Pea Island Coalition were gathered in
opposition to the Pamlico Sound Bridge. However, some commenters felt that
petitions from non-residents of Hatteras Island favoring the Parallel Bridge
Corridor should not carry any weight in the decision.
2. Politicians that are for the Parallel Bridge Corridor do not have to be
inconvenienced by road problems in the Refuge. Also, many people in the
tourism industry that are for the Parallel Bridge Corridor do not live on Hatteras
Island.
3. The real estate community seems to be firmly behind the Parallel Bridge
Corridor.
4. Senator Basnight's summary in support of the Parallel Bridge was that: it is the
only reasonable and feasible alternative which provides necessary
transportation linkage to Hatteras Island; it provides the least overall
environmental damage to the Seashore and the Pamlico Sound Outstanding
Resource Waters; and it protects public health and safety while ensuring good
stewardship of limited fiscal resources.
- Non-governmental organization (NGO) specific comments
1. Sierra Club: Believes groin should be removed in order to allow semi-natural
migration of inlet (would allow channel maintenance dredging). They also
believe that continued access should be allowed to the Refuge to the extent
possible, consistent with the natural characteristics of the Refuge, applicable
Over a Century of
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Post Hearing Meeting Attendees
March 10, 2006
page 6
law, and Refuge policy (begin access planning now to address public
concerns, which some of their members share).
2. North Carolina Coastal Federation: In favor of Pamlico Sound Bridge, but also
suggest the possibility of a compromise alternative that would provide access
to the Refuge through bridging any locations in the Refuge where the road has
to be moved from its existing location into wetlands. They would also support
leaving the groin in place as long as any new road in the Refuge allows
breaches to form and the island to migrate naturally. Also, no dune building or
beach nourishment is acceptable. They also suggest another possible
compromise solution of the Pamlico Sound Bridge with a spur bridge to the
northern end of the Refuge for public access.
3. Environmental Defense: Believes that the Pamlico Sound Bridge presents the
best solution for all issues, except access, which the USFWS has committed to
address. (They request that the USFWS establish a working group to
determine the most feasible means of maintaining access.)
4. Southern Environmental Law Center (SELC): Believes that Section 4(f) requires
that the Parallel Bridge alternatives cannot be considered because the Pamlico
Sound Bridge is feasible and prudent, and the Parallel Bridge alternatives do
not minimize harm to the Refuge. They maintain that the primary purpose of
the Refuge is to protect wildlife, and that impacts to Refuge recreational use
should not be considered as a harm to the Refuge. They believe that if the full
100-year life of the Pamlico Sound Bridge is considered, then nourishment
becomes much more expensive than presented in the SDEIS. SELC provides
extensive case law examples that they believe show that the Parallel Bridge is
not compatible with the purposes of the Refuge and that only the Pamlico
Sound Bridge complies with the National Wildlife Refuge System Improvement
Act. SELC believes that the SDEIS inadequately analyzes the environmental
impacts of the Parallel Bridge related to: shoreline erosion, new inlet formation,
and ocean overwash; beach nourishment (related to biological, geological,
and economic impacts); endangered and threatened species (particularly
related to beach nourishment); and wetlands. They support continued public
access to the Refuge and believe it can be accommodated within a
reasonable Refuge management plan (the USFWS has shown itself capable of
managing a reasonable access plan for other Refuges). However, this issue is
not related to Federal permitting requirements and access is not contingent
upon maintenance of NC 12.
5. NC Sea Grant: Three university coastal experts that support a possible
compromise solution (i.e., the Parallel Bridge Corridor with modifications) that
would impact the Refuge as little as possible.
- Other
1. Resume ferry service (one person said that all bridges are unrealistic and
doomed to failure, expenses are excessive, and ferry does not interfere with
the environment).
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Post Hearing Meeting Attendees
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page 7
2. Discounting should be shown in all materials presented to the public or costs
are misleading (especially for the Nourishment Alternative, whose cost drops
the most when discounted).
3. Some people have a fear of crossing long bridges.
4. Pamlico Sound Bridge reduces future unknowns - once it is built, it is done
(e.g., funding, nourishment, interaction with USFWS, etc.).
5. Road North/Bridge South Alternative is the best alternative and nourishment
money could be spent elsewhere.
6. Nags Head is currently not getting funding for beach nourishment so how
would NCDOT pay for nourishment.
7. It is reasonable to assume that beach nourishment will continue no matter
which alternative is selected because of pressure from various groups.
e-mail: [e-mail]
direct line: 919-468-2130
Enclosure
file no.: 3301 2.7.1
JAPLANNING\Bonner SDEIS\.Stakeholder InvolvementTublic Hearing\Post-Hearing Meeting\Bonner Public
Hearing Comments Summary Memo (final for client 3-13-06).doc
Over a Century of
Engineering Excellence A-15
Appendix B
Summary of 2007 Supplement to the SDEIS
Agency and Public and Comments
Bonner Bridge Supplement to the 2005 SDEIS
Agency Comments Summary
prepared by Parsons Brinckerhoff Quade & Douglas, Inc.
May 2, 2007
1. US Department of Agriculture-Natural Resources Conservation Service
The NRCS did not have any comments at this time.
2. US Department of the Army, Corps of Engineers
The COE had the following comments on the Supplement:
a. Further, more in-depth documentation is needed as to why the original cost
estimates were so grossly underestimated in the original document.
b. Further information/data/analysis needs to be presented pertaining to the
projected life-spans of the two bridge corridors and their relative costs projected
over time to reflect the true costs of the project.
c. The Phased Approach alternatives put a structure in a location that was deemed
not warranted for study in the 1991 feasibility study. The concerns reflected in
the study are still concerns today.
d. Further explanation is needed describing what "technically feasible" means in
terms of the Phased Approach alternatives. It should be documented in the EIS
that the Constructability Workshop document states, "It should be emphasized
that this approach, although feasible, is still quite technically challenging."
e. A major concern expressed for the inclusion of the Phased Approach alternatives
was to continue to have access to the ten plus miles of shoreline along the
Refuge. An original constraint (Constructability Workshop document) for the
Phased Approach alternatives was to maintain accessibility to NC 12 and all
access points on NC 12. This alternative does not meet this constraint.
f. The Supplement is unclear whether or not a compatibility determination would
be needed to construct the Phased Approach Alternative beyond Phase I.
g. The Supplement states that the Secretary of the USDOI response to US Senator
Burr "indicates that USDOI believes the replacement of the bridge itself could be
accomplished in a way which is compatible with the National Wildlife Refuge
System Improvement Act of 1997, and other laws, if it is constructed within the
same easement." While COE agrees that is the position stated in the letter in
regard to the replacement of the bridge itself, they are unclear if that means that
USDOI considers Phases II, III, and IV to be compatible as well.
Bonner Bridge Replacement Project TIP No. B-2500
B-1
h. Although COE is unsure of when the compatibility determination must be made
in the context of NEPA planning, it appears that it may be premature to select a
LEDPA for the project until the compatibility determination has been completed.
The wetland impacts are incorrectly stated in numerous places in the document.
The numbers presented are in most cases the total fill which is occurring in COE
jurisdictional areas, which includes open water impacts. The correct temporary
wetland impacts need to be included in the final document.
Further in-depth analysis needs to be presented pertaining to the indirect and
cumulative impacts of the Phased Approach Alternative associated with its
extended construction time-frame. COE does not agree with the statement in the
Supplement that, "Because the proposed project would consist of the
replacement of an existing bridge, as well as an existing road in the case of the
Parallel Bridge Corridor, indirect and cumulative impacts would be minimal."
COE feels that the Supplement does not adequately address indirect and
cumulative impacts. A more in-depth analysis is warranted as it relates to the
purpose of the Refuge and the impacts of long-term construction on its operation
and purpose.
k. Available and suitable sand sources should be identified for the life of the project
and alternatives should be provided in case adequate future sand sources are not
available.
1. It would be beneficial prior to the selection of the LEDPA for this project to have
accurate cost estimates for each alternative based on the most current design
standards.
m. Right-of-way costs for the Phased Approach/Rodanthe Bridge and Rodanthe
Nourishment alternatives appear to be switched.
n. Can it be assumed by the Capital Funding Section (page 2-24) that all the
alternatives currently being studied could be funded and constructed if selected?
o. Jurisdictional wetland impact numbers need to be corrected.
p. It should be documented that wetland impacts as well as jurisdictional impacts
could increase also as a result of sand movement.
q. It appears "Mitigation of Permanent Wetland Impacts" (page 4-41) is incorrectly
labeled. It appears that it should be labeled "Mitigation of Temporary Wetland
Impacts for the Hatteras Island Temporary Traffic Maintenance Road."
r. NCDOT is preparing to expend approximately 42 million dollars to conduct
repairs to Bonner Bridge, thus extending its usable life by approximately ten
years. It is COE's assumption that this will have no effect on implementation of
Bonner Bridge Replacement Project TIP No. B-2500
B-2
the selected alternative. However, if this is not the case, such changes should be
identified in the FEIS.
3. US Department of Commerce-National Oceanic and Atmospheric Administration
- National Marine Fisheries Service
The NMFS had the following comments:
a. The impact analysis provided in the Supplement does not adequately address
the significant environmental consequences of the alternatives in NOAA trust
resources.
b. The value of surf zone habitat and the impacts to it are not addressed nor are the
impacts of dredging in offshore borrow sites for beach fill. The feasibility and
potential long-term impacts of dredging offshore and deposition of sand on the
ocean beach within the Refuge are not adequately addressed.
c. In view of the potential impacts of beach nourishment on NOAA trust resources,
NMFS does not view beach nourishment as an acceptable long-term alternative
for maintaining NC 12.
d. Compatibility of the borrow sands with those at the natural beach is a key issue
and is insufficiently addressed.
e. The volume of sand needed appears to substantially underestimate what would
be needed for beach and dune construction.
f. Sand availability is not adequately described.
g. The Parallel Bridge Corridor has a shoulder width of six feet, whereas the
Pamlico Sound Bridge Corridor has a shoulder width of eight feet, which
increases the cost of the long bridge vs. the cost of the short bridge. This
provides for an unequal cost comparison and should be explained.
h. The Supplement states that the indirect and cumulative effects of the Parallel
Bridge Corridor would be minimal. Information provided in the Supplement
does not support this conclusion.
i. The Fish and Shellfish Section does not identify marine surf zone species that
could be affected by beach nourishment under the Phased Approach
alternatives.
j. No information is provided on the benthic invertebrate communities in the surf
zone.
k. The eventual degradation of the fish habitat along approximately ten miles of
beach should be addressed in greater detail.
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1. NMFS is concerned that bridge replacement alternatives that require long-term
beach nourishment and construction and maintenance of bridge structures in the
beach surf zone would result in long-term adverse impacts to NOAA trust
resources.
m. NMFS believes that the Pamlico Sound Bridge Corridor alternatives best support
the purpose and need for this project with the least impact to important estuarine
and marine resources in the project area.
n. The cumulative and/or additive effects of the "mixed and matched" approach are
not adequately explained. If additional alternatives that are the result of the
"mix and match" approach are proposed, the impacts to NOAA trust resources
must be fully evaluated for comparison with other alternatives.
4. US Department of Interior
DOI indicated that their February 13, 2006 comments on the SDEIS alternatives were
still valid. Those comments related to fish and wildlife resources apply to the new
Phased Approach Alternatives. Other comments are:
a. The SDEIS should describe the Outer Banks Task Force (OBTF) and its role in the
overall planning process. The alternatives, including mix and match options,
should be discussed in terms of how they meet the OBTF's goals.
b. It is not clear if the August 2006 NCDOT Constructability Workshop addressed
the practicality of the Phased Approach Alternatives; add additional detail on the
feasibility of constructing these alternatives within the existing NC 12 right-of-
way.
c. Add to the summary that the Pamlico Sound Bridge Corridor Alternatives avoid
breach problems near the groin.
d. DOI is concerned that NCDOT would build Phase I and not the later phases and
continue the status quo of only reacting to storm damage to NC 12.
e. The terms of the NC 12 easement agreement between NCDOT and DOI indicate
what can and cannot be done in the easement. A bridge might not be considered
a minor modification to NCDOT's use of the easement and require an
amendment to the easement agreement. A compatibility determination would
have to be made for an amendment to that agreement. The DOI feels that the
Phased Approach Alternatives would not receive a favorable compatibility
determination.
f. If the discussion of the potential for an OBTF short-term project at the "S" curve
Hot Spots prior to the implementation of Phase II in that area indicates an intent
on the part of NCDOT to relocate the NC 12 right-of-way on an as-needed basis,
then those impacts need to be addressed in the SDEIS.
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g. With the Nourishment Alternative, if sand is used from Corps of Engineers'
dredging as a part of a cost-sharing arrangement, the sand may not be suitable
for placing on the beach. Also funding for future Corps of Engineers pipeline
dredging is uncertain.
h. On page 4-4 of the Supplement to the SDEIS, clarify the difference between the
National Wildlife Refuge Comprehensive Plan and a compatibility
determination.
The DOI agrees a bridge in the Refuge would adversely affect the character of the
Refuge.
j. The ecological impacts of scour around NC 12 bridge piles once in the ocean
need to be addressed in more detail, including the impacts of maintenance and
repairs associated with scour, such as revetments or other stabilizing structures.
k. Even though they are in the existing easement, the Phased Approach
Alternatives would have direct effects on the Refuge, including construction
noise and the presence of construction equipment. The nourishment component
of one of the Phased Approach alternatives would have a direct impact. The
impact of road relocations and maintenance on NC 12 prior to the completion of
each Phase should be addressed.
1. The Phased Approach would turn the Refuge into a construction zone for 28
years with actual construction occurring over 13 of the 28 years. More
assessment is needed on the effect to birds from construction, the eventual
presence of the NC 12 bridges over the beach, and the eventual presence of the
NC 12 bridges in the ocean. Piping plover are unlikely to use habitat under
bridges.
m. More discussion is needed on the effect on sea turtles of night time lights on the
bridges in the NC 12 easement.
n. If one does not nourish the beaches at locations where the threatened seabeach
amaranth exists, will not this affect the integrity of the nourishment? Clarify.
o. It is unlikely that species displaced by project-related impacts would be able to
locate to suitable alternative habitat.
p. More emphasis should be placed on the importance of sand overwash to coastal
ecosystems.
q. There is no guarantee that DOI would issue a new permit to retain the terminal
groin.
The Section 4(f) evaluation adds little information on how the Phased Approach
Alternatives would affect the Refuge as a Section 4(f) resource.
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s. A construction staging area will need to be identified and the Cape Hatteras
National Seashore is willing to cooperate on this issue with NCDOT.
t. DOI requests that access to adjoining uses not be disrupted to the extent possible
at the Bodie Island end of any replacement bridge alternative.
u. The SDEIS is inadequate and does not meet the intended purpose of CEQ's
NEPA regulations or adequately address concerns of DOI and the public. DOI
may refer the project to CEQ and wishes to coordinate with NCDOT at the
earliest possible time to reach a solution and preclude the necessity for referral.
5. US Environmental Protection Agency
EPA's environmental review comments and ratings for the SDEIS Parallel Bridge
Corridor and Pamlico Sound Bridge Corridor alternatives remain unchanged from
the letter dated December 30, 2005. Following are their additional comments:
a. Purpose and Need Comments - with regards to the Parallel Bridge Corridor-
Phased Approach alternatives, EPA is not convinced that these additional
alternatives can reasonably meet the NCDOT's defined purpose and need for the
project to provide a facility that will not be endangered by shoreline dynamics
long-term.
b. 1991 Feasibility Study Alternatives
EPA is concerned that the transportation agencies may not be giving
previously rejected alternatives an equal comparison to the current
alternatives under full consideration. As the cost of the bridge replacement
options currently under detailed study has increased exponentially within
the last few years to more than $1 billion, the rehabilitation of the existing
bridge alternative discussed on page ix of the Supplement should be
reconsidered.
Increasing the length of Bonner Bridge, either through the selection of one of
the SDEIS Parallel Bridge Corridor alternatives or the Phased Approach
alternatives, by miles of new bridges will only increase the future risk and
public investment to keep NC 12 open by additional bridging.
• EPA believes that the Ferry alternative should also be reconsidered.
At a minimum, "emergency ferry service" should be considered between
Bodie Island and Hatteras Island as a contingency for any of the Parallel
Bridge Corridor alternatives and realistic costs projected for these
contingencies. The extended construction time-frames for new bridges as
well as executing emergency roadway repairs for the Parallel Bridge Corridor
alternatives should require that very specific contingency plans be made part
of this overall EIS analysis.
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c. Parallel Bridge Corridor with Phased Approach Alternatives
• EPA is uncertain as to why there are two different designs for the
replacement bridge structure and the NC 12 bridges, especially considering
safety issues for bicycles and pedestrians.
• The Parallel Bridge Corridor with Phased Approach alternatives are designed
and planned for addressing the "historic" hot spots, not their accelerated
formation or the increased size of new inlets along Hatteras Island.
• The Supplement states on page xxiii that telephone and electrical lines along
existing NC 12 will likely need to be moved one or more times between now
and year 2060. However, it is not clear whether these costs were included in
the costs of the Parallel Bridge Corridor alternatives.
• The discussion concerning the proposed 25-foot vertical clearance of the
bridges associated with the Phased Approach alternatives needs to be
included for all of the Parallel Bridge Corridor alternatives and reflected in
the costs for the different alternatives.
d. Jurisdictional Wetland Impacts
• One significant environmental concern that EPA has with the Phased
Approach alternatives is the potential for leakage and spillage of oil and
accidental releases to waters of the U.S.
• EPA does not prescribe to the use of "dilution as an acceptable solution to
water pollution."
• Biotic communities that are "0" acres impact should be de-emphasized or
removed from the tables in order to make the actual impacts for the
particular alternatives clearer.
• EPA does not understand why the costs presented in Table 2-1 for wetland
mitigation (excluding SAVs) for the Pamlico Sound Bridge Corridor with
Curved Rodanthe Terminus are substantially higher than for the Intersection
Rodanthe Terminus or the Phased Approach alternatives. NCDOT and
FHWA should explain this difference and the assumptions used in
developing these cost estimates. NCDOT and FHWA should begin
consulting with the resource agencies concerning compensatory mitigation
opportunities.
e. Refuge Impacts
The Pamlico Sound Bridge Corridor will not result in permanent disturbance
to Significant Natural Heritage Areas as identified by the North Carolina
Natural Heritage Program.
Bonner Bridge Replacement Project TIP No. B-2500
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EPA cannot find any literature references to piping plovers nesting under a
highway bridge. This statement should be corrected in the FEIS, or provided
with a supporting, relevant literature source.
• EPA believes that another method to ensure that piping plover would not be
negatively impacted by construction of the proposed project would include
intensive surveying efforts prior to construction to identify existing and
historic breeding sites, and providing and strictly enforcing a substantial
buffer to these areas.
The Supplement states that the Phased Approach alternatives could
permanently disrupt feeding and migrating birds within the near shore area
once shoreline erosion places the bridges south of Oregon Inlet in the ocean
(page 4-35). This permanent impact to migratory birds would appear to EPA
to be inconsistent with the Refuge's Comprehensive Conservation Plan and
overall mission.
• EPA believes that scour modeling for the Phased Approach alternatives
needs to be conducted prior to the selection of the preferred alternative.
• EPA is not concerned if the normal sand and sediment transport processes
will be affected by the Parallel Bridge Corridor alternatives, but to what
degree and what are the likely indirect and cumulative impacts associated
with these potentially drastic changes to the coastal landscape.
• EPA is uncertain as to under what conditions there would be visitors at the
Refuge following a storm event strong enough to cause a breach in the island.
• EPA requests that the detailed assumptions used in developing the operation
and maintenance costs be provided to the Merger Team agencies at the
upcoming scheduled Concurrence Point 3 meeting.
• EPA believes that the weather conditions and other storm events are not as
severe in the Pamlico Sound as they are on the near beach alternatives and
there should be less drastic repairs required for the Pamlico Sound Bridge
Corridor alternatives.
• EPA requests that NCDOT and FHWA provide more detailed information on
capital funding issues and commitments for the LEDPA meeting.
f. Sea Level Rise
• The Supplement does not discuss the potential cumulative and secondary
impacts from Sea Level Rise (SLR). This emerging yet documented issue
needs to be evaluated fully for the different alternatives in the FEIS.
Bonner Bridge Replacement Project TIP No. B-2500
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On page xii of the Supplement, historic beach erosion trends were used for
the development of the worst-case 2060 shoreline. However, this analysis
does not appear to take into account likely future trends because of SLR. The
predicted shoreline may not be at the locations that are presented in the
Supplement.
• The amount and estimated schedule of beach nourishment should be re-
evaluated based upon SLR projections within the project study area.
One of the recommendations to the NC Climate Change Commission in a
recent report was to prohibit new public and publicly licensed or permitted
infrastructure in flood prone and storm-surge prone areas. The construction
of new and extended bridges along the existing NC 12 corridor (i.e., Parallel
;Bridge Corridor alternatives) would appear to be inconsistent with this
technical recommendation.
g. Other Impacts from the Phased Approach alternatives
• EPA was unable to find an analysis or discussion within the Supplement that
addressed the increased safety concerns for vehicle-avian species collisions.
The near shore wind currents can be very strong and highly variable and the
potential frequency of collisions is more likely with the Phased Approach
alternatives than with the Pamlico Sound Bridge Corridor alternatives.
• EPA has previously stated its concerns about the use of a qualitative type
MSAT assessment being offered under FHWA's interim guidance.
• The air quality analysis does not address the potential near road exposures of
fishermen and other users of the Refuge from existing and future MSAT
pollutants for the Parallel Bridge Corridor alternatives.
6. North Carolina Department of Environment and Natural Resources-Division of
Coastal Management
NCDENR-DCM continues to recommend that the Parallel Bridge Corridor with
Road North/Bridge South and All Bridge alternatives be dropped from further
consideration (because of significant impacts to CAMA Coastal Wetlands AEC).
They also had the following additional comments:
a. NCDOT is urged to submit the CAMA major permit application for this project
to DCM a minimum of one year prior to the anticipated construction let date.
b. All of the alternatives under consideration impact CAMA AECs, and any
alternative selected would require a CAMA major permit. However, it is
possible that none of the alternatives would comply completely with the rules of
the NC Coastal Resources Commission (CRC), so DCM would have to deny a
CAMA permit application based on procedural reasons. DCM will work closely
Bonner Bridge Replacement Project TIP No. B-2500
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with the Merger Team to assure that the LEDPA complies with the CRC rules to
the maximum extent practicable, and DCM's concurrence on the LEDPA will
indicate that DCM will support that alternative if the CAMA permit application
needs to go before the CRC for a variance.
c. DCM is very concerned about public trust usage of the lands and waters within
the project area. As much as possible, public trust usage should be
accommodated in the alternative designs before a LEDPA is selected.
d. The SDEIS and the Supplement do not provide a concise summary and
comparison of all temporary and permanent impacts to biotic communities
between all of the alternatives under consideration in a format that allows the
reviewer to readily make comparisons between the alternatives.
Developing suitable compensatory mitigation for the impacts to wetlands and
waters of the State, including SAVs, will likely be a challenging undertaking for
the mitigation provider. Close coordination between the mitigation provider
and the state and federal agencies with regulatory control over these resources is
strongly encouraged.
f. The Supplement does not demonstrate that there are adequate and compatible
sand resources close by to accomplish the proposed beach nourishment for the
Phased Approach/Rodanthe Nourishment Alternative over the life of the project.
The viability of this alternative is also limited by the potential for significant
adverse impacts to ocean resources.
g. DCM is concerned that the successful implementation of the Phased Approach
alternatives may be too dependent upon the estimated position of the ocean
shoreline through 2060. Short-tem erosion events should be considered when
looking at the worst-case scenario shorelines, in addition to long-term erosion
rates.
h. A permanent bridge that is constructed in a location that is projected to be in the
ocean in the future will be exposed to significant wave energy. While this design
may be technically feasible, it does not appear to be practicable.
i. Prior to selecting a LEDPA, DCM would like to know how the bridges for all of
the alternatives under consideration will be disposed of when they have reached
the end of their service life, as well as the expected life spans for all of the bridges
under consideration.
j. When the Merger Team meets to select a LEDPA, the participants should be
reasonably sure that the design features (e.g., vertical clearance of bridges;
implementation of Joint Wave Task Force interim guidance related to wave
forces on bridges; bridge foundation assumptions; construction methodologies;
and design features for mitigating the risk of erosion and inlet formation based
on modeling of the hydraulics of the Oregon Inlet area) necessary to successfully
Bonner Bridge Replacement Project TIP No. B-2500
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implement all of the alternatives under consideration have been incorporated
into each of the alternative designs to the same level of detail. If information on
these design features is not available prior to the LEDPA meeting, the
participants should make an informed decision whether to wait until more
information is available, or whether to proceed with the selection of the LEDPA
with the best available information at the time.
7. North Carolina Department of Environment and Natural Resources-Division of
Marine Fisheries
As the Division indicated in previous comments (January 13, 2006), all of the
alternatives have environmental issues/consequences. Issues and concerns
expressed by the Division in the January 13, 2006 memo would also apply to the new
alternatives.
8. North Carolina Department of Environment and Natural Resources-Division of
Water Quality
DWQ had the following comments:
a. While the arguments that design-build will cost more because of the fact that
NCDOT will be paying consultants to design the road and that contractors will
build-in a ten percent increase in the profit margins to offset risk associated with
the project seems reasonable, it is diametrically opposed to every other NCDOT
(and NC Turnpike) project where DWQ has been told that design-build will save
both time and money. Please explain this apparent discrepancy.
b. While DWQ agrees that a recent worldwide cyclical boom in commodities has
resulted in a significant increase in construction costs, it seems unreasonable to
assume that trend will continue indefinitely.
c. The document fails to discuss what economies of scale (page 2-19) for previous
cost estimates specifically were anticipated and why they were no longer valid.
Please provide this additional information.
d. Please describe in greater detail the site-specific issues that are creating the
apparent ambiguity in developing more specific costs for this project and present
a single cost estimate for each alternative as has been done in other projects.
9. North Carolina Department of Environment and Natural Resources-
Environmental Review
Agency comments provided on the SDEIS and the Supplement should be fully
evaluated in the FEIS. The Phased Approach raises both short- and long-term
environmental concerns. Of particular interest is the potential to cause permanent
damage to the natural ecological conditions within the Refuge and surrounding area.
Bonner Bridge Replacement Project TIP No. B-2500
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10. North Carolina Department of Environment and Natural Resources-Natural
Heritage Program
The Natural Heritage Program (NHP) had the following comments:
a. NHP notes that the SNHAs identified on page xx of the Supplement are also
included on the Registry of Natural Heritage Areas under the Nature Preserves
Act.
b. The Supplement does not make it clear if NC 12 would pass over the
impoundments or run along the eastern edges.
c. From a purely ecologicalihabitat impacts perspective, the NHP favors the
Pamlico Sound Bridge Corridor.
11. North Carolina Wildlife Resources Commission
The NCWRC states that their previous comments are still valid. They also had the
following additional comments.
a. NCWRC has consistently maintained the need to select an alternative that will
allow the natural processes to return to the barrier islands. Essentially elevating
NC 12 will allow the shoreline to naturally evolve and progress inland, however
the habitat created will be severely impacted by the presence of the bridge
structure.
b. Coastal waterbird habitat such as overwash zones, inlets, and sand flats created
in the vicinity of the Phased Approach bridges will not provide approximate
habitat while in close proximity to the bridge structures.
c. The structure will impact the ability of sea turtle habitat to properly function.
d. Any elevated structure located in the vicinity of sea turtle nesting habitat will
need to be designed to eliminate artificial lighting, such as street lights or head
lights, from reaching the beach or nesting areas. Artificial lights near the nesting
areas can disorient hatchlings.
e. Impacts associated with the cumulative effects of prolonged construction were
not adequately discussed in the Supplement. NCDOT should provide this
information prior to selecting an alternative.
12. Town of Nags Head, North Carolina
The Town of Nags Head Board of Commissioners passed a resolution on January 4,
2006 indicating that the aging Herbert C. Bonner Bridge over the Oregon Inlet
should be replaced immediately with a parallel bridge.
Bonner Bridge Replacement Project TIP No. B-2500
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Memorandum
SO
RS
YEA
S
To: B-2500 February 14, 2007 Supplement to the 2005 Supplemental Draft
Environmental Impact Statement Post Hearing Meeting Attendees
From: John Page
Date: April 27, 2007
Subject: Project: 8.1051205 (B-2500) Dare County
FA Project No. BRS-2358(15)
Bonner Bridge Replacement
Summary of Public Hearing Comments
Public Hearings were held on Wednesday, March 28, 2007 at the Dare County Justice
Center in Manteo, NC and Thursday, March 29, 2007 at the Rodanthe-Waves-Salvo
Community Center in Rodanthe, NC. The official public comment period ended on April
17, 2007. As of April 27, 2007, a total of 146 citizens made comments (oral, written, or
both) at and following the Public Hearings. A summary of these comments is provided
below. In addition, four non-government organizations (NGOs) provided written comments
following the public hearings - these comments are also summarized below. The attached
table presents the comments made by person making the comment (along with the
organization the individual commenter represents, if appropriate). It should be noted that
the comments received during the 2007 comment period will be added to those received
during and after the November 2005 public hearings (see final "Summary of Public Hearing
Comments" memorandum, dated March 10, 2006).
Alternative Favored (Citizen Comments Only)
- Pamlico Sound - non-specific 15
- Pamlico Sound with Curved Rodanthe Terminus 2
- Pamlico Sound with Intersection Rodanthe Terminus 25
TOTAL PAMLICO SOUND BRIDGE CORRIDOR 42
- Parallel - non-specific 40
- Parallel with All Bridge 0
- Parallel with Road North/Bridge South 2
- Parallel with Nourishment 21
- Parallel with Phased Approach - Rodanthe Bridge 1
- Parallel with Phased Approach - Rodanthe Nourishment 6
- Compromise Solutions (Parallel Bridge with modifications to impact 3
Refuge as little as possible) -
TOTAL PARALLEL BRIDGE CORRIDOR 73
Just Build the Bridge 8
- General Project-Related Comment with No Corridor Preference 23
Specified
TOTAL NO CORRIDOR PREFERENCE SPECIFIED 31
TOTAL CITIZEN COMMENTS 146
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The following is a summary of the oral and written comments that were submitted at
and following the Public Hearings:
• Concerns about Pamlico Sound Bridge Corridor
- Adverse impact on the environment. (6)
- Too expensive, primarily in contrast to the Oregon Inlet Bridge component of the
Parallel Bridge Corridor. (5)
- Loss of public access to refuge, including some comments that access details
should be worked out before decision is made to implement this corridor but
access emphasis is on full paved road access. (5)
- Concern about increased utilities/electric bills. (4)
- Adverse impact on wildlife/vegetation in Pamlico Sound because of dredging for
construction and bridge runoff. (4)
- Concern about emergency response time. (3)
- Adverse impact on economy, primarily from non-road access to the Refuge. (1)
- Adverse impact to views of Pamlico Sound from Refuge. (1)
- Adverse impact on Rodanthe residents. (1)
- Concern about cars colliding with birds on long bridge. (1)
- Safety concerns. (1)
- Concern about runoff and trash thrown into Pamlico Sound. (1)
- Would create new problems (evacuation safety, noise, pollution, etc.). (1)
• Concerns About Parallel Bridge Corridor
- Long-term maintenance of NC 12 through Refuge too expensive and
environmentally damaging. (7)
- Long-term beach erosion/migration of refuge will continue and potential for a
breach to occur in the Refuge. (4)
- Oregon Inlet is too dynamic for a bridge. (1)
- Economic impacts of breach in NC 12 through Refuge would be substantial. (1)
- Impacts to wetlands degrade the Refuge. (1)
• Pamlico Sound Bridge Corridor Positives
- Preserves character/natural environment/wildlife of Seashore/Refuge (allowing
nature to take its course). (5)
- Less expensive (more cost effective over the long-term). (3)
- Best option for long term dependable/safe access. (2)
- Provides more reliable hurricane evacuation. (2)
- Provides adequate access while reducing impacts on wildlife. (2)
- Limits access to refuge (preserving nature good for economy). (2)
- Why should we deal with the NC 12 maintenance problems in the Refuge (i.e.,
beach erosion, breach threat, etc.) until 2060 when they can be solved in
considerably less time by building the long bridge? (1)
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- Allows for future economic development. (1)
- Addresses all "hot spots" at one time. (1)
• Parallel Bridge Corridor Positives
- Practical, expedient, economical in that it spreads the costs out over a longer
period of time than the Pamlico Sound Bridge, which would need to be built all at
once. (11)
- Better for environment. (3)
- Parallel Bridge is the best option because of the threat of Bonner Bridge collapse
(i.e., it can be built quicker and all other concerns related to Parallel Bridge are
less important than public safety/access/economy of Hatteras Island). (2)
- Maintains Refuge access with a paved road. (1)
• Other
Bridge Design, Cost, and Timing
1. Build the bridge now. (22)
2. Concerned about safety of existing bridge. (10)
3. Opposed to long bridge. (7)
4. Selected alternative should include design features to accommodate bicycles
safely. (4)
5. Resume ferry service. (2)
6. Keep the old bridge and charge a toll. (1)
7. New bridge needs 4-lanes and shoulders (hurricane evacuation and safety
concerns). (1)
8. Any solution that keeps existing NC 12 through the Refuge is a waste of
money. (1)
9. Low lying NC 12 through the Refuge is a bigger concern than Bonner Bridge.
(1)
10. Concern about the safety of children using the current bridge to get to school.
(1)
11. Opposed to any bridge. (1)
12. Create artificial reef instead of using beach nourishment. (1)
13. Build a two-tower suspension bridge. (1)
- Community/Economic Impacts
1. Concern about economic impact to Dare County - stated that Dare County is
one of four donor counties in NC. (4)
2. Alternative chosen should preserve integrity and ambiance/way of life of the
island and Rodanthe/other small villages. (3)
3. Residents' opinions should be favored. (1)
4. Personal home negatively affected by some alternatives. (1)
5. Mini-bridges would negatively impact residents with increased noise. (1)
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6. Concern that it will be difficult to attract visitors if they cannot just pull off of the
highway to stop at destinations in the Refuge. (1)
7. Bridge in Rodanthe will create "visual pollution." (1)
8. Bridge in Rodanthe will destroy any businesses in the vicinity. (1)
9. The community is completely dependent on a new bridge being constructed
and NC 12 being maintained. (1)
10. Evacuation is a major concern. (1)
11. The elevated road and bridges in the sound around Mirlo Beach would impair
views of the ocean and sound for residents. (1)
12. Concern with promoting increased bicycling in off-season to help economy.
(1)
- Natural Resource Impact
1. Let nature take its course. (2)
2. Habitat fragmentation caused by new right-of-way or bridge structure in
Refuge is incompatible with the purpose of the Refuge as a sanctuary for
migratory birds. (1)
- Access Maintenance
1. Alternative chosen must maintain access to entire Refuge. (12)
2. In favor of maintaining/repairing current NC 12 access to the Refuge. (2)
3. Concern with loss of access rights for general public to Refuge. (1)
- Other general comments
1. Document should be more reader friendly. (1)
2. The State needs to work with the County and private property owners to insure
local property protection from the ravages of nature. (1)
- Non-governmental organization comments:
1. Audubon North Carolina: Audubon NC continues to support the Pamlico
Sound Bridge Corridor, as it is "the only alternative that will provide reliable
transportation while protecting the considerable environmental values of Pea
Island National Wildlife Refuge." Audubon's comments include:
- The Phased Approach alternatives are "almost as expensive, entail
considerable adverse environmental impacts, introduce additional new
recreational impacts, and fail to provide reliable transportation through the
refuge." They believe that the Phased Approach alternatives are "an
expensive, massive gamble that could end up being a bridge to nowhere."
- They request that NCDOT include in the FEIS a discussion of similar bridges
located in ocean locations with comparable wave energy; the reliability of such
bridges; and the construction and maintenance costs associated with such
bridges. In addition, do the projected costs of the Phased Approach
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alternatives include the higher design standards of the AASHTO/FHWA Joint
Wave Task Force?
- They are also very concerned with the adverse recreational impacts (e.g.,
surfing, swimming, ocean kayaking, windsurfing, and birding) of having a
bridge on the beach or just offshore and feels that the document downplays
these significant adverse impacts.
- The Supplement also does not acknowledge the positive geological and
biological impacts from dynamic beaches (i.e., ocean overwash and inlet
formation, migration, and closure), and is unclear as to what action will be
taken if an inlet opens up in the Refuge. The FEIS should clearly indicate when
an inlet will be allowed to remain open and when it will be closed, as well as
when and how artificial dunes will be maintained. In addition the FEIS should
discuss the full direct, indirect, and cumulative environmental impacts of
closing an inlet and maintaining an artificial dune system.
- The Supplement also does not adequately disclose impacts on beach nesting
birds. It does not acknowledge the extensive benefits to birds from the
hundreds of acres of nesting, feeding, and resting habitats that would be
created naturally by removing the road from the Refuge and restoring natural
overwash patterns. Audubon NC is concerned that as the shoreline erodes,
piping plover habitat may be created under the Phased Approach alternatives'
bridges and the document does not address the negative impacts of this
possibility. They request that NCDOT provide examples of piping plover using
habitat under similar bridges, or withdraw the statement that there would be
minimal disturbance to piping plover habitat. The Endangered Species Act
would define it as a "take" if there is the possibility that plovers living under the
bridge in the future could be struck by vehicles. The document also fails to
address the likely scenario that nourished beaches will not be suitable for
nesting because of the steep profile, lack of feeding habitat, and planting of
dune grasses.
- They are concerned that the NCDOT will declare an "emergency" and extend
the western end of the terminal groin to the south if the future sound side
shoreline gets too close to the road or bridge in the area to the south of the
terminal groin. Unless the NCDOT will guarantee as an irrevocable permit
condition that the groin will not be extended, the FEIS should include a
discussion of the environmental impacts and economic costs of extending the
groin.
- Audubon NC strongly objects to the "mix and match" approach, as it raises
serious concerns with compliance to the mandates of NEPA. Depending on
which alternative is chosen, there are a range of direct and indirect
environmental impacts. Failing to disclose the impacts of an alternative that
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may be implemented deprives the public of information regarding the impacts
of that alternative and prevents the public from having an opportunity to submit
comments.
- They continue to have concerns about the cost analysis. The full life of the
bridge is 100 years, but the cost analysis is only through 2060, which seriously
skews the cost/benefit analysis in favor of any options that involve beach
nourishment and against the Pamlico Sound Bridge Corridor. They are also
amazed that with the passing of just two years the costs for the Pamlico Sound
Bridge Corridor increased by such a dramatic amount, which raises concerns
regarding the objectivity of the analysis.
- They state that NCDOT must comply with all applicable environmental statutes
despite the letter from USDOI Secretary Kempthorne.
North Carolina Coastal Federation (NCCF): NCCF's new comments are
intended to supplement their previous comments on the SDEIS. They continue
to object to maintaining the Refuge as a staging ground for a highway, and
believe that the island must be allowed to retreat in a natural fashion and the
road must retreat with it. They believe, however, that it is possible to provide a
travel corridor while at the same time allowing the barrier island to function as a
natural system and allowing public access. They re-emphasize that the
Refuge is a "wild, undeveloped barrier system and must remain so." They
restate their idea that NCDOT consider moving NC 12 to the west side of the
Refuge, possibly along the dikes that form the west walls of the impoundments.
The dikes could be replaced by bridges that would restore the natural tidal
flushing of the ponds while allowing public access. They continue to believe
that this alignment, or one like it, would provide a reasonable compromise to
the impasse over the Bonner Bridge replacement. They also re-iterate the
following points for the current public comment period on the Supplement:
- Large scale beach nourishment is not acceptable within a wildlife Refuge -the
island must be allowed to function as a natural barrier island - so the Parallel
Bridge Corridor with Nourishment Alternative should be removed from
consideration.
- Pea Island is becoming more and more unstable from the constant
construction of high dunes on the east side of NC 12 (i.e., natural island
migration is being thwarted and sand is being washed out to sea), so
alternatives with dune building should be removed from consideration.
- A bridge constructed in the Canal Zone area would encroach on the beach in
a few years because of the unusually high erosion rate in this area. Does
NCDOT really want visitors to lie on a beach beneath a highway?
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- Relocating NC 12 slightly to the west along the ponds will not likely be found
compatible with the 1997 Refuge Act. If this option is feasible, why not move
the road to the far west side of the island?
In choosing an option, it is vital to recognize the true cost of maintaining NC 12
through 2060. However, even the least expensive options far exceed the
funding that NCDOT currently has available.
- Although the Pamlico Sound Bridge Corridor is more expensive than the other
options, it should be recognized that its 100-year life expectancy is twice as
long as the Parallel Bridge Corridor alternatives.
Based on the above considerations, NCCF does not believe that the options in the
Supplement are suitable for the landscape of the Refuge or the political climate in
Dare County, or that NCDOT can realistically expect to maintain NC 12 through the
Refuge as designed and described. Therefore, they suggest the following
possible amendments to the designs of both bridge corridors in order to make
them work:
1. If the Pamlico Sound Bridge Corridor is selected, then access ramps
should be provided to allow public access to Pea Island.
2. If the Parallel Bridge Corridor is selected, then NCDOT should work with
USFWS to find a route for NC 12 on the west side of the Refuge that will
meet three goals - natural island migration, reliable transportation, and
public access - while also meeting the management needs of the Refuge.
Environmental Defense (ED): ED incorporates their previous comments on the
SDEIS by reference into their new comments. As stated in their previous
comments, they believe that none of the alternatives presented meets all needs
regarding safety, reliability, economic feasibility, public access, and avoidance
of environmental impacts. However, based on the information presented in the
Supplement, ED maintains that the Pamlico Sound Bridge Corridor still
presents the best solution when all of the factors are considered and balanced.
Their new comments include the following questions and general concerns
regarding both Phased Approach Alternatives:
- Construction timing - they are concerned that if specific decision-making
criteria are not established for exactly when and under what conditions
construction of the bridges in Phases II - IV would occur, then actual
construction of the Phased Approach could be delayed indefinitely resulting in
a de facto Nourishment Alternative. In addition, would beach fill be used as an
interim measure if erosion occurs faster than expected (i.e., before a certain
phase is scheduled) or if a breach occurs? As detailed in their previous
comments, they are strongly against the Nourishment Alternative as it results in
unacceptable long-term and cumulative impacts to natural resources and fails
to meet the needs of providing safe and reliable transportation.
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- Economics - they strongly believe that a true accounting of the costs
associated with the various alternatives should be calculated on a timeframe
comparable to the life expectancy of the replacement bridge (i.e., 100 years)
rather than to the artificial project endpoint of 2060.
- Natural resources - while the direct wetland impacts for the Phased Approach
alternatives has been evaluated to be relatively small, the total temporary and
permanent biotic community impacts from construction of either of the Phased
Approach alternatives are not insignificant. While much of the impact might be
temporary, the magnitude of that effect on the biota and general ecology of the
Refuge can be exacerbated by the timing of such temporary impacts - the
Supplement does not adequately evaluate this. Also, they disagree with the
biological conclusion of "Unresolved" with respect to impacts to piping plovers
and green sea turtles - the Phased Approach alternatives present a likely
adverse impact to these species. The conclusion that the Phased Approach
alternatives would not likely adversely affect loggerhead sea turtles based on
observations from 2003 and 2004 is also erroneous - the area should be re-
evaluated before making such a conclusion because this species also would
likely be adversely affected.
- Cumulative and long-term impacts - they believe that the analysis of the
cumulative and long-term impacts of having bridges along the shoreline in the
ocean on nearshore fish species and habitats, as well as on nearshore benthic
communities, is not adequate. This is a serious omission based on the
discussion of the potential impacts of scour from the bridges on local
bathymetry, wave climate, and potentially longshore sediment transport.
Alteration of habitat at the base of the food change can have cascading
ecological impacts that should be recognized, particularly given the
importance of fishing and birding on the local economy.
- Aesthetics, recreation, and access - The Phased Approach alternatives would
be a substantial visual impact to the Refuge that would permanently alter the
undeveloped and protected character that makes it a unique national treasure.
These alternatives also provide the most restricted public access to the Refuge
of any of the Parallel Bridge Corridor alternatives - this restricted public access
would adversely affect Refuge resources and recreational activities. They
strongly support continued public access to the Refuge and note that access
to other public trust areas in the state is maintained without a paved road.
These impacts alone make the Phased Approach alternatives incompatible
with the purpose and mission of the Refuge.
- Safety and reliability - The Phased Approach alternatives do not appear to
provide a safe and reliable means of transportation, which is of paramount
importance. Overwash and flooding will continue to be an issue with these
alternatives. The eventual bridges in the ocean will not provide safe
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transportation during the frequent storm events that impact the area. In
addition, based on data provided in the Long Bridge Operations and Safety
Study Report, they maintain that the Pamlico Sound Bridge will provide the
safest and most reliable transportation to and from Hatteras Island.
4. Southern Environmental Law Center (SELC): SELC's new comments are also
signed by the following agencies: Defenders of Wildlife, Pamlico-Tar River
Foundation, North Carolina Wildlife Federation, and the North Carolina Chapter
of the Sierra Club. The comments are intended to supplement their previous
comments on the SIDES and they incorporate the previous comments by
reference. They continue to support the Pamlico Sound Bridge Alternative and
do not agree that any of the Parallel Bridge Corridor alternatives, including the
Phased Approach alternatives, are viable alternatives. They have "numerous
concerns about the adequacy of review of the environmental impacts
associated with the Parallel Bridge alternatives, including the new Phased
Approach and related compliance with the National Wildlife Refuge System
Improvement Act and Section 4(f) of the Department of Transportation Act of
1966." Their concerns include:
- The Phased Approach cannot comply with the Refuge Act - "because the
Phased Approach, and the associated direct and indirect impacts, is a use
of the Refuge that 'materially interfere[s] with' and 'detract[s] from the
fulfillment of the mission of the System or the purposes of the refuge,' it
cannot be found to be compatible. 16 U.S.C. § 668ee."
SELC believes that the Supplement incorrectly states that a Compatibility
Determination is only necessary for alternatives that use land outside of the
existing easement. They state that a Compatibility Determination applies
for projects that have direct, indirect, or cumulative impacts on Refuge
land or adjacent land that affects the Refuge. They also state (with
examples) that work within easements may be limited by the Refuge
Manager and may be subject to a Compatibility Determination. In addition,
they state that the two NEPA documents are inadequate because the
information presented is not sufficient to prove that any of the Parallel
Bridge Corridor alternatives could be found compatible.
The Phased Approach Alternative does not comply with Section 4(f) - the
NEPA documents recognize that the Pamlico Sound Bridge Corridor is the
only "avoidance" alternative, and no other alternatives can be considered
for implementation when there is an alternative that avoids impacts to the
Section 4(f) resource.
- The Phased Approach Alternative will have significant adverse impacts on
the Refuge that the Supplement fails to adequately evaluate, including: the
building (along with the scheduling of phases) of a transportation corridor
within such a dynamic system (e.g., shoreline erosion, inlet formation, etc.)
as exists in the Refuge; the effects of building a bridge that will ultimately
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be in the Atlantic Ocean; and a "mix and match" approach that cannot be
supported by the NEPA analysis.
The Phased Approach Alternative's NEPA analysis does not adequately
address natural resource impacts, including: using assumptions related to
construction phasing that underestimate wetland impacts; an incorrect
conclusion that the Phased Approach Alternative would not likely adversely
affect loggerhead sea turtles (i.e., the eventual presence of bridge pilings
in the surf or on the beach would impact nesting habitat for this species);
and the impacts of a long-term construction schedule and "mix and match"
alternatives on piping plover, sea turtles, and fisheries.
The Phased Approach Alternative fails to provide long-term access to the
Refuge because the access is not compatible to the Refuge mission and
would severely limit or eliminate certain Refuge activities (e.g., fishing,
surfing, etc.).
The cost estimates for the replacement bridge corridor alternatives are
inconsistent with the project life span, which unfairly discounts alternatives
that require beach nourishment and dune building, as well as costs of
maintaining a bridge in the Atlantic Ocean over the long-term. The public
should be informed of the maximum costs that could be incurred over the
long-term. In addition, the supporting documentation is inadequate to
support the revised cost analyses that increased the Pamlico Sound
Bridge Corridor costs by approximately 2.25 times vs. 1.3 times for the
other alternatives and revising the costs is recommended.
- Secretary Kempthorne's letter fails to recognize the USDOI's legal
obligations pursuant to the Refuge Act and to NEPA.
e-mail: page]@pbworld.com
direct line: 919-468-2130
Enclosure
file no.: 3301 2.7.1
JAPLANNING\Bonner SDEIS\.Stakeholder Involvement\Public Hearin g\Post-Hearing Meeting (2007 Public
Hearings)\Bonner Bridge - March 2007 Public Hearing Comments Summary Memo - final draft.doc
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a4w. STATF o
aw.
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY LYNDo TIPPE rr
GOVERNOR SECRETARY
AGENDA
Wednesday, May 23, 2007
Eastern Concurrence Meeting
Board Room, Transportation Building
Raleigh, North Carolina
1:30 PM to 4:30 PM, Beth Smyre, Project Planning Engineer, PDEA Branch
TIP No. B-2500 Bonner Bridge Replacement, Highway 12 Over Oregon Inlet
Dare County, Division 1
Team Members:
Bill Biddlecome, USACE
Beth Smyre, PDEA
Clarence Coleman, FHWA
Chris Militscher, USEPA
Ron Sechler, NMF
Mike Murray, NPS
Pete Benjamin, USFWS
Mike Bryant, USFWS - PINWR
Renee Gledhill-Earley, SHPO
John Hennessy, DWQ
David Cox, WRC
Charles Jones, DCM
Mike Street, DMF
NCDOT Technical Support Staff and Other Agency Staff:
Scott McLendon, USACE
Ron Lucas, FHWA
Kathy Matthews, USEPA
Gary Jordan, USFWS
Dennis Steward USFWS
Thayer Broili, NPS
Travis Wilson WRC
David Wainwright, DWQ
Sara Winslow, DMF
Cathy Brittingham, DCM
Sarah McBride, SHPO
* The purpose of this meeting is to achieve concurrence on CP3.
MAILING ADDRESS: TELEPHONE: [phone] LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: [phone] TRANSPORTATION BUILDING
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WEBSITE. WWW.DOH.DOT.STATE.NC.US RALEIGH NC
RALEIGH NC 27699-1548
NEPA/Section 404 Merger Meeting - August 15, 2007
NC 12 Replacement of Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet, Dare County
WBS No. 32635
TIP No. B-2500
Purposes of Meeting
Review activities since May 23 Merger Team Meeting
Determine whether concurrence on NCDOT Preferred Alternative can be achieved. If
concurrence is not achieved, move the project into the Merger 01 Conflict/ Dispute
Resolution (Elevation) process
AGENDA
1. Introduction and Purpose of this Meeting
II. Determine LEDPA concurrence
-4?.
III. Next Steps