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Attendees:
March 26, 2009 Bonner Bridge Merger Team Meeting Attendees
John Page. Parsons Brinckerhoff
April 15, 2009
Meeting Minutes - Nlarch 26, 2009 NEPA/Section 404 Merger Team
Informational Meeting for the Bonner Bridge Replacement Project (TIP No.
13-2500)
Gary Jordan
Pete Ben.jamin
Mike Bryant
Dennis Stewart
Bill Biddlecome
Scott McLendon
Stacie Craddock
Christopher A. Militscher
Kathy Matthews
Ron Sechler
Mike Murray
"Thayer Broili
Clarence Coleman
Ron Lucas
Michael Dawson
Rob Avers
Amy Simes
Jim Iloadley
Cathy Brittingham
Sara Winslow
Brian Wrenn
David Wainwright
Travis Wilson
Renee Gledhill-Earley
Greg Thorpe
Beth Smyre
Brian Yamamoto
Rob I-lanson
Kristine O'Connor
Missy Pair
Michael Till chy
Chris Rivenbark
Elizabeth Lusk
Kathy I Icrring
Byron Kyle
USFWS - Raleigh Field Off-ice
USFWS - Raleigh Field OlTicc
USFWS - NC Coastal Plain Refuge Complex
USFWS - Pea Island National Wildlife Refuge
US Army Corps of Ingineers
US Army Corps of C?ngineers
US Army Cotes of Engineers
USE13A
USFPA
National Marine Fisheries Service
National Park Service - Cape Hatteras National Seashore
National Park Service- Outer Banks Goup
FHWA - NC Division
FHWA - NC Division
FH WA - NC Division
Fl-JWA- NC Division
NCDFNR
NCDFNR - DCM
NCDFNR - DCM
NCDENR - DMF
NCDENR - DWQ
NCDENR - DWQ
NCDl,NR - Wildlife
NCDCR - SHPO
NCDOT- PDEA
NCDOT - PDFA
NCDOT - PDF.A
NCDOT- PDEA
NCDOT - PDEA
Resources Commission
NCDOT - PDFA
NCDOT-Natural Environment Unit
NCDOT- Natural Environment Unit
NC_'DOT - Nattral Environment Unit
NCDOT-Natural Environment Unit
NCDOT- Roadwav Desicn
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Minutes: March 26, 2009 Merger Team Informational Meeting for Bonner Bridge
Zak Hamidi NCDOT - Roadwav Design
Dave Henderson NCDOT- Fydraulics Unit
Jerry Lindsey NCDOT- Hydraulics Unit
.lent' .lennings NCDOT - Division 1
Clay Willis - NCDO'I'-Division 1
Ray McIntyre NCDOT-TIP Development Unit
Thomas Stoddard NCDOT -TIP Development Unit
Debbie Barbour NCDOT- PI'ecoflStRIC6011
Victor Barbour NCDOT -Technical Services
Mai kStaley NCDOT- RoadsideEnvironmentalUnit
Rodger Rochelle NCDO'I'-'I ransportatiou Program Management Unit
Nilesh Surti NCDOf-Transportation Program Management Unit
Virginia Mabry NCDOT-Transportation Program Management Unit
Lonnie Brooks NCDOT- Sit ucture Design Unit
K. J. Kim NCDOT - Geotechnical Engineering Unit
Sam Cooper CZR
John Page Parsons Brinckerhoff
Bobby NotbLll'n Parsons Brinckerhoff
The mectin, started at 10:30 a.m. in the Board Room of the NCDOT'T ransportation Buildill"
Bill Biddlecomc opened the meeting and asked the attendees to introduce themselves. tic then
turned the meeting over to Beth Smyre.
Introduction and Purpose of this Nleetin_
Beth said that today's meeting was an informational meeting and asked if everyone had a
meeting packet. She said the purpose of the meeting was to discuss the possibility of revisiting
the project's LEDPA decision; however, before NCDOT formally asks for concurrence, it
wants to inform the Merger Team mcmhers on the reasons behind this possibility and get
agency feedback. In addition NCDOT wants each agency to have an opportunity to take
information from today's meeting back to discuss further with their management before any
decision to change the LEDPA is made.
Proiect Hislorr and Current Status
Beth went through a brief summary of the LEDPA concurrence agreement (including the
elevation process that occurred), the hEIS, and the Concurrence Point 2A/4A agreement for
Phase I of the LEDPA, including the dates for each event. She also defined the LEDPA - the
Parallel Bridge Corridor with Phased Approach/Rodauthe Bridge Alternative.
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Summan of Comments on the 2008 Final Environmental Impact Statement/Section 4(11
Evaluation
Beth turned the meeting over to Clarence Coleman to discuss the agency comments received
on the FEIS, noting Ihat a copy of all agency and NGO comments received were included in
the merger packet. Clarence said that substantive agency and NGO comments were received
on the FEIS, so NCDO'f/FI-I WA started to review and respond to these comments. I le said
that the Record ol* Decision will include responses to all comments, but today's meeting will
focus on several issues that FI IWA believes need further discussion with the Merger 'I'can)
based on the FE IS comments.
Clarence said that the firs) issue he wanted to discuss was the FEIS' Section 4(f) analysis. The
Department of Cultural Resources (DCI2) commented that there would be a substantial
impairment to the Rodanthe Historic District as a result of the LEDPA. FH WA interpreted this
comment to mean that DCR disagreed with the conclusion in the FEIS that there would not be
a constructive use of the historic district with the LEDPA. DCR also commented that they
disagreed with the FEIS determination that there would be no constrictive use of the Refuge.
DCR's comment indicates that, based on the LEDPA's impacts on the Refuge as documented
in the FEIS, they believe that there would be a constructive use of the Refuge. In addition, the
DOI commented that any of the Parallel Bridge Corridors would violate Section 4(f), and they
also believed that there Would be a constructive use of the Refuge Finally. Southern
Environmental Law Center (SELC) also commented that they disagreed with the constructive
use analvsis in the FE IS.
Clarence said the second issue that he wanted to discuss was Refuge access with the LEDPA.
"I'hc DOI and several other agencies commented that they were concerned over the public's
loss of access to the RelLgc with the LEDPA.
The third issue that Clarence wanted to discuss evas the Ilnurc disposition of the terminal groin.
SE LC commented That the FEIS did not adequately assess the impacts of rcnwving the groin
with the LEDPA, and that this issue had a direct relationship to the project.
Certification ofNC 12 Right-of-Wav.
Clarence discussed that FHAV'A requires NCDO"f to ccrtily that the right-of-way/easement is
legal for federally-funded projects under FHWAjurisdiction to (i.e., to make sure the state.has
rights to the easement). He said that this process typically occurs once the NEPA process is
completed, but based on the FEIS comments FHWA thought it should occur now. 'I'herelbrc.
NCDOT conducted a substantial amount of additional research into the history of the INC 12
casement through the Refuge and NCDOT's rights to this casement. Clarence also said that
basal on the property deeds and other Icgal dOCLnllcuts discovered during the additional
research, FH WA decided to reevaluate the applicability of Section 4(t) with respect to The
Refuge for the proposed projecT. 'fhe reason for this decision is that FI IWA believes that the
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Minutes- March 26, 2009 Merger Team hiformational Meeting for Bonner Bridge
research revealed an evolutionarv relationship between NC 12 and the Refuge that could alter
the Section 4(f) analysis for the Refuge in the FEIS. Clarence reiterated that despite rumors to
the contrary. the genesis for this effort was the right-of way certification process.
Renee Gledhill-Early asked if the re-evaluation of Section 4(f) was related only to the 4(1) use
of the Refuge as refuge (i.e., the re-evaluation does not relate to other possible uses of the
Refuge that qualify it lot Section 4(0 protection). Clarence indicated that the Refuge is being
re-evaluated as a refuge and as a historic resource under Section 4(f).
Clarence discussed that the Road Notch/Bridge South Alternative is being re-examined as the
potential Prefened Alternative for several reasons. lie discussed that the cost is less and that
DCR preferred the Road North/Bridge South over the LEDPA because keeping NC 12 at-grade
would be preferable for maintaining the integrity ofthc historic landscape of the Refuge.
Terminal Cruin
Clarence discussed that FHWA and NCDO"f want to keep the terminal groin with any Parallel
Bridge Corridor alternative to protect the southern end of the replacement Oregon Inlet bridge
on Hatteras Island. However, SELC is concerned with what they believed to be the FI IS' lack
of analysis related to the impact of removing the terminal groin. Clarence said that the FEIS
includes discussion of this issue, but if further analysis of removing the groin is needed, the
analysis would need to consider all pertinent related issues for all of the detailed study
alternatives, including the Pamlico Sound Bridge Corridor. Two such issues are Section 106
and Section 7 with respect to threatened and endangered species impacts (critical habitat for
the endangered piping plover has been federally-designated behind the groin since the LEIS
%vas published). Based on the current groin permit, it appears that the groin would have to be
removed with the Panilico Sound Bridge Corridor, but h'hl WA is currently coordinating with
USFWS on whether rn' not this would be the case. It needs to be determined if it is possible to
gel a new permit to retain the groin. if needed, with any of the detailed study alternatives.
Clarence said that further coordination With USFA4?S is nccdcd in the next few weeks on NF,PA
and other related issues related to retaining the groin with tile LEDPA.
Section 106 Cuordinaliun
Clarence said that there was a Section 106 coordination meeting between FH\VA. NCDOT.
and the Section 106 consulting parties last'Iliesday (3/24/09). '1 he reason for the meeting was
to discuss DC'R's comments on the FEIS related to impacts to the Rodanthe l fistoric District.
DCR's comments led 1:1-IbVA and NCDOT to take a closer look at the inconsistencies in the
locations of the NC 12 termini in Rodanthe between the parallel Bridge Corridor alternatives
and the Punlico Sound Bridge Corridor alternatives (i.e., the Pamlico Sound Corridor
alternatives were designed to avoid the historic district as deftied in the Supplement to the
SDEIS, whereas- the Parallel Bridge Comdor uhcrnatives were defined based on an earlier
district boundary and while avoiding the district's old boundary, they did encroach on the
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revised boun(tary). Clarence said that in order to address this inconsistency, the NC 12 termini
in Rodanthe for the Phased Approach/Rodanthe Bridge, Road North/Btidge South, and All
Bridge alternatives have been redesigned to slay out of the historic district. He said that as a
result of these design changes, it was agreed at the Section 106 meeting that now there would
be "No Adverse Effect" on the historic district with the phased Approach/Rodanthe Bridge.
Road North/Bridge South, and All 131 idge alternatives. Beth discussed the design changes in
more detail, and copies of the new designs were also included in the meeting packet. Clarence
noted that these new designs are an outcome of the Section 106 coordination process and will
apply no matter which alternative is chosen as the LEDPA.
Clarence said that the proposed project's effects on the Refuge were also revisited at the
Section 106 meeting, but no revised concurrence was made related to impacts on the Refuge.
He said that it is a fact that NC 12 has been moved four times within the Refuge with no
documented significant environmental impacts. He also said that a FONSI was completed on
the last road relocation in the Refuge in the 1990s. However, additional Section 106
coordination will continue since no revised concurrence was reached. FHWA agreed to gather
some additional information, including drawings, and then get back with DCR to further
discuss impacts on the Refuge. At the Section 106 meeting, it was agreed that the adverse
effects determination in the FEIS for the Coast Guard Station still applies for all alternatives.
In addition, an agreemeiWwas reached on the use of a temporary staging area at the Coast
Guard Station for Phase 1.
Next Steps
• Preparation of draft revised Section 4(t) analysis by F11WA - FHWA is revising the
FEIS' Section 4(f) analysis based on the new right-of-way data generated by NCDOT's
additional research on the NC 12 easement. Mike Murray asked if the Merger Teanh
would have a chance to review and comment on the revised Section 4(f) analysis once it is
completed since it includes new information- Clarence responded that they would.
Review of new right-of-way data and draft timeline by FHNVA, NCDOT and D01,
followed by distribution of data to Merger Team- FH WA has sent information on the
right-of way agreements to USFWS and DOI. who will vcrifv the validity of the data
before it is distributed to the other Merger Team members. FI-1 WA and NCDOT also have
prepared a draft timeline of the history of the NC 12 casement through the Refuge and past
agreements (i.e., the evolutionary relationship between NC; 12 and the Refuge discussed
previously), which also has been sent to USFWS and DOI for their concurrence and/or
feedback before it is distributed to the rest of the ,Merger Tcam. Ultimately, the NC
Attorney General and agcucy lakvyer:s may have to meet to discuss the official tinhclinc
before the issue can be finalized. Clarence said that the additional data and the timeline are
factors in.dctermining the applicability of Section 4(I) with respect to the Refuge. Bill
Biddlecome asked if this issue only related to the applicability of Section 4(f) and not
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compatibility. Clarence responded that the issue only relates to Section 4(t) (i.e.,
compatibility is a separate issue).
• Continuation of Section 106 coordination.
• NCDOT and FHWA will continue to examine the Road North/Bridge South
Alternative as a potential Preferred Alternative.
Next Bonner Bridge Nlerger'Feant Meeting will he held on iVlay 21, 2009- Clarence
said that the next proposed Merger Team Meeting has been pushed back four April 16 to
May 21 (i.e., to the next regularly scheduled meeting on May 21, 2009) in part becanse of
the outcome of the Section 106 meeting, but also4o allow the timeline to be 1711alized and
then subsequently to allow all oI'tlie Merger Team agencies to have time to review the
timeline before the nieetimu.
Question and Answer
Pete Benjamin said that lie doesn't understand the timeline argument with respect to Refuge
Section 4(f) applicability- it doesn't seen relevant. He would like something in writing from
FHWA related to where they are going with this issue. Mike Bryant asked who within his
agency has the information that Clarence referenced because lie has not seen it. Mike said he
has only seen the map that was being used as a display at today's meeting which shows the
year in which various parcels were transferred fioni the slate to the Refuge. Clarence said that
he had been told that the DOI solicitor has the new right-of-way information cold is reviewing
it. In addition. he thought that tabular information listing resources for the new data was e-
mailed last Monday to Mike, and possibly to Pete, but Clarence will confirm that DOI has
received the intended information. He also said that he wanted to make it clear that FHWA's
research and conclusions are not the final word. rather FFIWA is looking for DOI to agree with
FH WA's findings and/or provide missing elements. He re-iterated that ultimately lawyers
front the stale. PH WA, and the DOI would likely be involved in dctcrmining a final
conclusion.
In response to a continent, Clarence said that no one with F-I IWA has claimed that N'CDO'I' has
the 62ht to move NC 12 wherever they want within the Refuge. At this point. h1IWA and
N'CDOT arc simply speculating that the extensive collaboration between the state and the DOI
that has occurred over the years, as exhibited in the documents gathered in NCDOT's research
back to the early 1900s. may indicate that Section 4(1) does not apply for moving NC 12 within
he Refuge due to
joint planning. hlowcvcr, it was discussed that it has yet to be determined
whether or not the passing ol'the National Wildlife Rel'uge System Improvement Act in 1997,
which brought about the requirement for Refuge compatibility determinations, would impact
the historic process that has been followed lot- relocatin.- NC 12 within the Refuge (i.e.. the
process prior to 1997 that became evident based on the new right-of-wav data gathered).
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Travis Wilson asked for clarification as to whether or not the tiered EIS that had been planned
for implementing the multiple phases of the current LEDPA (the Phased Approach/Rodanthe
Bridgc Alternative), for which it had been assumed that all alternatives for maintaining NC 12
through the Refuge (i.e., nourishment, relocation on road, and relocation on bridge) would be
kept available for Phases 11 to IV, would still keep these additional options for future phases if
the Road North/Bridge South is selected as the LEDPA. Clarence responded that the other
options would remain available. He said that Phase I (the new Oregon Inlet bridge) would be
basically the same for any alternative at this point. including extending the bridge to the south
across the northern-most hot spot on Hatteras Island, but beyond that the best option (based on
future impact analyses) at the time the project is ready for implementation could still be chosen
for future phases. FHWA regulations allow the ROD to he revised as lone as all alternatives
being considered for the revised ROD were carried forward for detailed study in the FFAS.
Beth added that based on the estimated costs fix the project, any alternative will now have to
be phased. For example, the Road NorthBridge South Alternative is anticipated to be two to
three phases. with the new Oregon Inlet bridge as he first phase. She added that later phases
could change to other alternatives based on future conditions in the Refuge. Mike asked if
there would be a Supplemental EIS for changes to future phases of the LEDPA. Clarence said
that a Reevaluation would be done of the ROD to determine if there were any new significant
impacts and that would be the catalyst for possibly doing a Supplemental BIS.
Chris Militscher asked if the Section 404 permit would be phased. Scott McLendon responded
that the permit would be phased, but the impacts for all phases would be considered in issuing
the initial permit so that hopefully the maximum impacts for all phases are known in advance.
Scott asked why the Road North/Bridge South Alternative would be chosen because it has
much greater wetlands impacts. Clarence responded that part of the reason was related to the
access issues comments from the DOL as well as concerns over elevated structures (because of
aesthetics) through the Refuge from other commenters. 7n addition, as lie discussed
previously, NC 12 has been relocated al-grade several limes through the Refuge with no
identified significant impacts. Dennis Stewart commented that we need to keep in perspective
that this relocation would be much longer than previous relocations. Clarence said that it was
still a fact that all previous relocations had been handled with FONSIs (or possibly lesser
environmental documents).
Scott asked for clarification on whelher*or not Section 4(f) and the new casement data were the
primary reasons behind the Merger Team being asked to possibly consider changing the
LEDPA to the Road North/Bridge South Alternative. Clarence responded that based on the
new data 171 i WA is rc-analyzing the applicability of Section 4(f) to the Refuge because it may
not appIv to the Refuge as a refuge, but it may still apply to the Refuge as a historic site. He
also noted that the Road North/Bridgc South Alternative would cost substantially less to build
than the Phased Approach/Rodanthe Bridge Alternative (approximately 5500 million less
based on the most recent cost estimates).
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Clarence said that the DO] commented that the Pamlico Sound Bridge Corridor may be
feasible and prudent to build, so the LEDPA would violate Section 4(f). Based on this
comment, Phi WA is looking at the issue ol'prudence again and this will be part of the new
Section 4(t) analysis. He added that FhI WA believes that it has already been proven that the
long bridge is not practicable and USACF. had agreed with this conclusion by signing the
Review Board agreement. Scott commented that if PHWA determines again that the long
bridge is not prudent, that means that it cannot be built under Section 4(I), but that
determination would not apply to Section 404. (Note: Prudence is an PHWA decision tinder
Section 4(f)). The Corps has already agreed that the Pamlico Sound Alternative is not
practicable, consistent with Section 404 b(1) Guidelines. Clarence agreed but added that he
hoped USACF would consider PH W A's Section 4(t) determination that the alternative could
not be built in their Section 404 decision.
Brian Wrenn asked if there would be any other design changes with the redesigned Road
North/Bridge South Alternative that would affect the impact numbers in the FEIS. Beth said
that two additional design cham,es that are being considered with the Road North/Bridge South
Alternative are extending the new Oregon Inlet bridge approximately 2,000 feet to the south
(as with the Phased Approach) and possibly shifting the Road North pail of the project to try
and reduce wetland impacts. Any possible shifts to the alignment to reduce wetland impacts
would be discussed further with USACF and NCDENR, including bridging opportunities. She
said that these other potential design changes had not been finalized yet, but any additional
changes would be included in the information packet sent out prior to the nest meeting so that
the Merger Team would have an opportunity to discuss the changes at the meeting. Brian
asked if design changes would also be considered for the other Parallel Bridge Corridor
alternatives. Beth said that further design changes would probably only be looked at for the
Road North/Bridge South Alternative because the Phased Approach had already been
improved as much as possible at this point and the focus is now on possibly pursuing the Road
North/Bridge South as the new LEDPA.
Brian commented that he hasn't heard suflicientjustification tir pursuing the Road
North/Bridge South Alternative when the wetlands impacts are so significantly higher. lie
added that he thought the other alternatives should also be looked at further for reclucirw
impacts rather than focusing on customizing one alternative. lie said that it would be difficult
for DENR to permit one alternative when there are other alternatives on the table that have
tower impacts. Scott agreed that it would be difficult for the USACF to justify changing the
LEDPA based on just looking at changes to one alternative without also looking at improving
the other ahernatives.
Pete asked if the May 21 meeting would he a concurrence meeting. Clarence responded that it
possibly would be a concurrence meeting. Pete said that he wants to be provided information
that fully "connects the dots" as to how the decision was made to consider moving away from
the Phased Approach as the LEDPA. Clarence said that a package would be put together to
more fully explain to the Merger Team members why the Road North/Bi idge South
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Alternative is under consideration as the new LEDPA. and that this information would be
provided before the next meeting. Pete requested a one month advance notice with the
informational packet for the next meeting.
Bill said that he is still confused as to how compatibility tits into the current decision-making
process to pursue the Road North/Bridge South Alternative. Clarence said compatibility is not
PHWA's decision. Mike responded that compatibility is still a major issue that would apply
unless something takes away DOI's rights to part of the property within the Refuge. Bill asked
if compatibility was being considered in parallel with the other issues that were discussed
today. Clarence responded that the attorneys are considering this issue. Scott asked if a
decision on compatibility would be made prior to the next Merger "(earn meeting. Mike
responded that he was not sure. I-lejust knows that theDO1 solicitors had asked for all ol'the
relevant project information, including the new data, so that they can have an informed
discussion. Bill said that he thought the attorneys should make a decision on compatibility
before the next meeting. Mike said that he cannot make a compatibility determination now,
but he could render a new opinion once he has more information or new direction from DOI.
Clarence again summarized the action items that need to occur prior to the next Merger Team
meeting:
• All documentation related to the new data and timelines need to be reviewed by the
PI-IWA, NCDOT, and DOI attorneys and finalized, and then provided to the Merger Team
members prior to the meeting.
• Refuge management needs to provide an indication on their jurisdiction related to
compatibility once the agency attorneys have reviewed and provided comments on the new
data and timeline.
Scott asked if the compatibility action item was appropriate. Mike responded that
compatibility determinations usually take place after the NEPA process has been completed,
but in the past draft cicterminat ions have been made to help explain USPWS' position. As far
as he knows, USPWS still considers the NC 12 easement through the Refuge to be the
easement shown in the PHIS, bill we will have to wait and see if the new data changes
anything.
Cathy Brittinghant asked if the learn members would be provided a sunttnar_v ol'today's
meeting. Beth responded that meeting minutes would be prepared.
Bill Biddlecome then adjourned the meeting.
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