U-3831

er SIAIJ
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
August 24, 2004
WETLANDS/ 401 r,;Rc"Il)>?
SEP 0 3 2004
WATER QUALITY SEDTIONi
LYNDO TIPPETT
SECRETARY
MEMORANDUM TO: Mr. John Hennessy
Division of Water Quality/Wetlands
FROM: Gregory J. Thorpe, Ph.D., Director sL
Project Development and Environmental Analysis Branch
U
SUBJECT: Widening of SR 2048 (Gordon Road) from the NC 132 Interchange
Ramp to West of US 17 (Market Street), New Hanover County,
Division 3, Federal Aid Project No. STP-2048(1), WBS No. 34985.1.1,
TIP No. U-3831
The Project Development and Environmental Analysis Branch has begun studying the proposed
improvements to SR 2948 (Gordon Road). The project is included in the 2004-2010 North Carolina
Transportation Improvement Program and is scheduled for right of way in fiscal year 2009 and
construction in fiscal year 2012.
The Project consists of widening SR 2048 (Gordon Road) to a multi-lane facility, from the
NC 132 Interchange to west of US 17 (Market Street). The project is 2.4 miles in length.
We would appreciate any information you might have that would be helpful in evaluating
potential environmental impacts of the project. If applicable, please identify any permits or approvals
which may be required by your agency. Your comments will be used in the preparation of a federally
funded Environmental Assessment. This document will be prepared in accordance with the National
Environmental Policy Act. It is desirable that your agency respond by October 8, 2004 so that your
comments can be used in the preparation of this document.
If you have any questions concerning the project, please contact Michele James, Project
Development Engineer, of this Branch at [phone], Ext. 233. Please include the TIP Project
Number in all correspondence and comments.
GJT/plr
Attachment
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.NCDOT.ORG
LOCATION:
TRANSPORTATION BUILDING
1 SOUTH WILMINGTON STREET
RALEIGH NC
Iii! I'!i xa..
,.? t?'t ? ?? ? PROJECT ?.. un ? + L"•u ` L:1! L ? ? / ?1 S__l ?
u 1 LIMITS v°n.?a °1-:>%?? / ?/
+.+r\ / F~ ? VrY L I / ?? 2921 L ?=S
I
T )JJ ??11
1? „_ ?( nu\? OGDEN
xu ? ?o (UNINCJ
.o° ? m
_ is r zs ? e / ?,
°' ??? I KINGS GRANT u ? LeLe i ?7
J (UNINC.) ?u i j /
J- lflS " I i1¢ oga Prk y1' lS!
?,! PROJECT
u /? tLa ~ t u c.A 1 d? LIMITS a e ti ° . .
/ 4,c v.A, a9 c °
!/ 0, is i,..""
r" , , B WA ? ? Lx L u s L/,? ?' ? ` L2
y n 2a ri_! UU ? 712 u-
J?, Lu- ,f
t ix a \ u L e , ui` `its! Lv
_ _
Lu ? ..?,
NEW' :.,?
rr iriii Igton? ?I<:.:.. ,,.. ,.
?. a
C 1 NORTH CAROLINA DEPARTMENT OF TRANSPORTA TION
i PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS BRANCH
SR 2048 (GORDON ROAD)
FROM NC 132 INTERCHANGE RAMP
TO WEST OF US 17 (MARKET STREET)
WILMINGTON, NEW HANOVER COUNTY
TIP NO. U - 3831
°, "`E
cfw?E FIGURE 1
WtA-c BY' C-OkI3 STIMwvANT DATE: 01 / 2J / 01
DWQ appreciates the opportunity to provide comments on your project. Should you have any questions
or require any additional information, please contact Nicole Thomson at 919-715-3415.
cc: Dave Timpy, US Army Corps of Engineers, Wilmington Field Office
Travis Wilson, NC WRC
Gary Jordan, USFWS
Chris Militscher, USEPA
File Copy
p?0FINAT4R9
7
0 ? `C
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
February 3, 2005
MEMORANDUM
TO: Michelle James, NCDOT Project Development Engineer
FROM: Nicole Thomson, NC Division of Water Quality, Transportation Permitting Unit
SUBJECT: Scoping Review of NCDOT's Proposed Widening of SR 2048 (Gordon Road) from NC
132 Interchange Ramp to West of US 17 (Market Street), New Hanover County, Federal
Aid Project No. STP-2048(1), WBS 34985.1.1, TIP Project No. U-3831.
This office has reviewed the referenced document. The Division of Water Quality (DWQ) is responsible
for the issuance of the Section 401 Water Quality Certification for activities that impact Waters of the
U.S., including wetlands. It is our understanding that there are potential impacts to jurisdictional
wetlands and streams. The project will have impacts to wetlands, streams, and other surface waters
associated with:
Stream Name River Basin Stream Classification W Index No.
Smith Creek Cape Fear C; SW 18-74-63
DWQ offers the following comments on the referenced documents:
Project Specific Comments:
1. Smith Creek are class C; Sw waters of the State. Although class C; Sw waters of the State do not
have specific storm water requirements, New Hanover County is a coastal county. In accordance
with 15A NCAC 2H .1005, developments in coastal counties that require a sedimentation/erosion
control plan must have a storm water permit. Prior to land disturbing activities, a storm water permit
must be obtained for the above referenced project.
2. The environmental document should provide a detailed and itemized presentation of the proposed
impacts to wetlands and streams with corresponding mapping. If mitigation is necessary as required
by 15A NCAC 2H.0506(b)(6), it is preferable to present a conceptual (if not finalized) mitigation plan
with the environmental documentation. Appropriate mitigation plans will be required prior to
issuance of a 401 Water Quality Certification.
3. Environmental assessment alternatives should consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff. These alternatives should include road designs that
allow for treatment of the storm water runoff through best management practices as detailed in Best
Management Practices for the Protection of Surface Waters, such as grassed swales, buffer areas,
preformed scour holes, retention basins, etc.
One
Nip
nCarolina
Transportation Permitting Unit Naturally
1650 Mail Service Center, Raleigh, North Carolina 27699.1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone]/ Internet: http://h2o.enr.state.nc.us/ncwetlands
An Pni inI Onnnrhinif%dAHirmofn,e Arfinn P-Invar - rf)Ol Pnn AndIM01 Pnef rinnemmnr Ponar
General Comments Regarding Bridge Replacement Projects
4. After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the NCDOT is respectfully reminded that they will need to demonstrate the avoidance
and minimization of impacts to wetlands (and streams) to the maximum extent practical. Based on
the impacts described in the document, wetland mitigation will be required for this project in
accordance with Environmental Management Commission's Wetland Rules (15A NCAC 211.0506
(h)(2)}.
In accordance with the Environmental Management Commission's Rules 115A NCAC
2H.0506(b)(6) }, mitigation will be required for impacts of greater than 150 linear feet to any single
perennial stream. In the event that mitigation is required, the mitigation plan should be designed to
replace appropriate lost functions and values. In accordance with the Environmental Management
Commission's Rules { 15A NCAC 2H.0506 (h)(3) }, the NC Ecosystem Enhancement Program may
be available for use as stream mitigation.
6. The 401 Water Quality Certification application will need to specifically address the proposed
methods for storm water management. More specifically, storm water will not be permitted to
discharge directly into the creek. Instead, storm water should be designed to drain to a properly
designed storm water detention facility/apparatus to achieve diffuse flow and nutrient treatment.
7. For watersheds subject to riparian buffer rules, riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
8. If applicable, DOT should not install the bridge bents in the creek, to the maximum extent practicable.
9. Any new culverts must be countersunk to allow unimpeded fish and other aquatic organisms passage
through the crossing.
10. If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3027/Nationwide Permit No. 6 for Survey
Activities.
11. Sedimentation and erosion control measures sufficient to protect water resources must be
implemented prior to any ground disturbing activities. Structures should be maintained regularly,
especially following rainfall events.
12. Sediment and erosion control measures should not be placed in wetlands.
13. Borrow/waste areas should avoid wetlands to the maximum extent practicable. Impacts to wetlands
in borrow/waste areas could precipitate compensatory mitigation.
14. While the use of National Wetland Inventory (NWI) maps and soil surveys is a useful office tool,
their inherent inaccuracies require that qualified personnel perform onsite wetland delineations prior
to permit approval.
w
O? WAT ?Rp
O?G
O `W `C
February 9, 2005
MEMORANDUM
To: Melba McGee
,???
Through: John Hennessy
From: Nicole Thomson
Subject: Comments on the Proposed widening of SR 2048(Gordon Road) from the NC 132 Interchange
Ramp to West of US 17 (Market Street) in New Hanover County, Federal Aid Project No. STP-
2048(1), WBS Element No. 34985.1.1, TIP U-3831, DENR Project Number 05-0067.
This office has reviewed the referenced document. The Division of Water Quality (DWQ) is responsible for the
issuance of the Section 401 Water Quality Certification for activities that impact Waters of the U.S., including
wetlands. It is our understanding that the project as presented will result in impacts to jurisdictional wetlands and
streams. The DWQ offers the following comments based on review of the aforementioned document:
A) The document does not present any mapping that shows the location of wetlands and streams. In addition,
the document does not give any specified amount of anticipated impacts to wetlands and streams. Until the
DWQ has a map that clearly displays all the wetlands, streams, and other surface waters located in the
project, with the proposed project superimposed onto those resources, we cannot agree that appropriate
avoidance and minimization has occurred for this project. As such, issuance of the 401 Water Quality
Certification for this project could be delayed until the information is provided to the DWQ for review, and
we are convinced that all appropriate avoidance and minimization has occurred for this project.
B) After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the NCDOT is respectfully reminded that they will need to demonstrate the avoidance and
minimization of impacts to wetlands (and streams) to the maximum extent practical. Based on the impacts
described in the document, wetland mitigation may be required for this project. Should the impacts to
jurisdictional wetlands exceed 1.0 acres, mitigation may be required in accordance with NCDWQ Wetland
Rules (15A NCAC 2H.0506(h)(2)).
C) In accordance with the Environmental Management Commission's Rules (15A NCAC 211.0506(b)(6)),
mitigation will be required for impacts of greater than 150 linear feet to any single perennial stream. In the
event that mitigation is required, the mitigation plan should be designed to replace appropriate lost
functions and values. In accordance with the Environmental Management Commission's Rules 115A
NCAC 2H.0506 (h)(3) ), the NC Ecosystem Enhancement Program may be available for use as stream
mitigation.
D) As part of the 401 Water Quality Certification Application process, NC DOT is respectfully reminded to
include specifics for both onsite and offsite mitigation plans. If mitigation is required, it is preferable to
present a conceptual (if not finalized) mitigation plan with the environmental documentation. While
NCDWQ realizes that this may not always be practical, it should be noted that for projects requiring
mitigation, appropriate mitigation plans will be required in conjunction with the issuance of a 401 Water
Quality Certification. We understand that NC DOT will request compensatory mitigation through the NC
Ecosystem Enhancement Program for offsite mitigation.
Noce hCarolina
Transportation Permitting Unit Natfurali(f
1650 Mail Service Center, Raleigh, North Carolina 27699.1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone]/ Internet: http://h2o.enr.state.nc.us/ncwetlands
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
V
E) Future documentation, including the 401 Water Quality Certification Application, should include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
F) An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The
type and detail of analysis should conform to the NC Division of Water Quality Policy on the assessment of
secondary and cumulative impacts dated April 10, 2004. We understand that you have agreed to make this
study a part of your 401 Water Quality Certification Application.
G) NC DOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, to jurisdictional wetlands, streams, and riparian buffers need to be included in the final impact
calculations. These impacts, in addition to any construction impacts, temporary or otherwise, also need to
be included as part of the 401 Water Quality Certification Application.
H) Where streams must be crossed, the DWQ prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where
high quality wetlands or streams are impacted, a bridge may prove preferable. When applicable, DOT
should not install the bridge bents in the creek, to the maximum extent practicable.
I) Sediment and erosion control measures should not be placed in wetlands.
J) Borrow/waste areas should avoid wetlands to the maximum extent practicable. Impacts to wetlands in
borrow/waste areas could precipitate compensatory mitigation.
K) The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater should not be permitted to discharge directly into
streams or surface waters.
L) Based on the information presented in the document, the magnitude of impacts to wetlands and streams
may require an Individual Permit application to the Corps of Engineers and corresponding 401 Water
Quality Certification. Please be advised that a 401 Water Quality Certification requires satisfactory
protection of water quality to ensure that water quality standards are met and no wetland or stream uses are
lost. Final permit authorization will require the submittal of a formal application by the NCDOT and
written concurrence from the NCDWQ. Please be aware that any approval will be contingent on
appropriate avoidance and minimization of wetland and stream impacts to the maximum extent practical,
the development of an acceptable stormwater management plan, and the inclusion of appropriate mitigation
plans where appropriate.
The NCDWQ appreciates the opportunity to provide comments on your project. Should you have any questions or
require any additional information, please contact Nicole Thomson at [phone].
cc: Mr. Dave Timpy, US Army Corps of Engineers, Wilmington Field Office
Mr. Gary Jordan, USFWS
Mr. Travis Wilson, NCWRC
Mr. Ken Averitte, NCDWQ Wilmington Regional Office
Central Files
File Copy
CA2004 DOT Projects\U-383 REnvirontmental Study Feb 05
R Department of Environment and Natural Resources
Office of Legislative and Intergovernmental Affairs
Project Review Form
Project Number: County: Date Received: Date Rupassae Due (fsrm line):

This project is being reviewed as indicated below:
Regional Office Regional Office Area In-House Review
? Asheville )(Air foil & Water Marine Fisheries
? Fayetteville XWater Coastal Management
? Mooresville Groundwater Wildlif r*r ? Water Resources
V ?r
? Raleigh Land Quality Engineer Environmental Health
? Washington ? Recreational Consultant korest Resources ? Solid Waste Mgmt
Wilmington ? Land Resources ? Radiation Protection
? Winston-Salem Parks & Recreation ? Other
Watcf QbaliL. -- `
? Groundwater
? Air Quality
Manager Sign-WRegion: Date: la-House Resiewcr/Agency:
Response (check all applicable)
? No objection to project as proposed.
E3 No Comment
O Insufficient information to complete review
Other (specify or attach comments)
WETLANDS / 401 GROUP
SEP 14 2004
WATER QUALITY SECTION
KZ I u full l v:
Melba McGee
Environmental Coordinator -
Office of Legislative & Intergovernmental Affairs

e,.a STA7[ °?
4? F
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY LYNDO TIPPETT
GOVERNOR SECRETARY
August 24, 2004
C' s o
MEMORANDUM TO: Ms. Chrys Baggett, Director ?? Fp
State Clearinghouse
Department of Administration
FROM: Gregory J. "fhorpe, Ph.D., Director 4
Project Development and Environmental Analysis Branch
SUBJECT: Widening of SR 2048 (Gordon Road) from the NC 132 Interchange
Ramp to West of US 17 (Market Street), New Hanover County,
Division 3, Federal Aid Project No. STP-2048(1), WBS No. 34985.1.1,
TIP No. U-3831
The Project Development and Environmental Analysis Branch has begun studying the proposed
improvements to SR 2948 (Gordon Road). The project is included in the 2004-2010 North Carolina
Transportation Improvement Program and is scheduled for right of way in fiscal year 2009 and
construction in fiscal year 2012.
The Project consists of widening SR 2048 (Gordon Road) to a multi-lane facility, from the
NC 132 Lnterchange to west of US 17 (Market Street). The project is 2.4 miles in length.
We would appreciate any information you might have that would be helpful in evaluating
potential environmental impacts of the project. If applicable, please identify any permits or approvals
which may be required by your agency. Your comments will be used in the preparation of a federally
funded Environmental Assessment. This document will be prepared in accordance with the National
Environmental Policy Act. It is desirable that your agency respond by October 8, 2004 so that your
comments can be used in the preparation of this document.
If you have any questions concerning the project, please contact Michele James, Project
Development Engineer, of this Branch at [phone], Ext. 233. Please include the TIP Project
Number in all correspondence and comments.
GJT/plr
Attachment
MAILING ADDRESS:
NC DEPARTMENT Or TRANSPORTATION
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS
1548 MAIL SERVICE CENTER
RALEIGH NC 27699-1548
TELEPHONE: [phone]
FAX: [phone]
WEBSITE: WWW.NCDOT.ORG
LOCATION:
TRANSPORTATION BUILDING
1 SOUTH WILMINGTON STREET
RALEIGH NC
`K
?J
01
.? r

• jr
•r .. ?Mr•, .?r,
~ A, r-
a:?n
i
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS BRANCH
SR 2048 (GORDON ROAD)
FROM NC 132 INTERCHANGE RAMP
TO WEST OF US 17 (MARKET STREET)
WILMINGTON, NEW HANOVER COUNTY
TIP NO. U - 3831
°
SUtE FIGURE 1
GRAPPOC eY-CPWUJ ST,00 ANT OATS: 01123104

?PPS?ENT OF
N O
9
?4RcH ,ga
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
September 9, 2004
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 impacts of the proposed widening of SR 2048 (Gordon
Road) to a multi-lane facility from the NC 132 interchange ramp to west of US 17 (Market
Street) in New Hanover County, North Carolina (TIP No. U-3831). These comments provide
scoping 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).
Recent aerial photography reveals the predominantly developed, residential nature of the project
area. However, some isolated forest habitat may still remain. For road improvement projects
such as widening, realignment, bridge replacement and culvert replacement, the Service
recommends the following general conservation measures to avoid or minimize environmental
impacts to fish and wildlife resources:
Wetland and forest impacts should be avoided and minimized to the maximal extent
practical. Areas exhibiting high biodiversity or ecological value important to the
watershed or region should be avoided. Proposed highway projects should be aligned
along or adjacent to existing roadways, utility corridors or other previously disturbed
areas in order to minimize habitat loss and fragmentation. 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. If spanning the flood plain is
not feasible, culverts should be installed in the flood plain portion of the approach to
restore some of the hydrological functions of the flood plain and reduce high velocities of
flood waters within the affected area;
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. Off-site detours should be used rather than construction of temporary, on-site bridges.
For projects requiring an on-site detour in wetlands or open water, such detours should be
aligned along the side of the existing structure which has the least and/or least quality of
fish and wildlife habitat. At the completion of construction, the detour area should be
entirely removed and the impacted areas be planted with appropriate vegetation,
including trees if necessary;
6. 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. Opportunities to protect mitigation areas in perpetuity via conservation
easements, land trusts or by other means should be explored at the outset;
7. Wherever appropriate, construction in sensitive areas should occur outside fish spawning
and migratory bird nesting seasons. In waterways that may serve as travel corridors for
fish, in-water work should be avoided during moratorium periods associated with
migration, spawning and sensitive pre-adult life stages. The general moratorium period
for anadromous fish is February 15 - June 30;
Best Management Practices (BMP) for Protection of Surface Waters should be
implemented; and
9. Activities within designated riparian buffers should be avoided or minimized.
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.aov/es/countyfr.litm] .
Although the North Carolina Natural Heritage Program (NCNHP) database does not indicate any
known occurrences of listed species near the project vicinity, use of the NCNHP data should not
be substituted for actual field surveys if suitable habitat occurs near the project site. The
NCNHP database only indicates the presence of known occurrences of listed species and does
not necessarily mean that such species are not present. It may simply mean that the area has not
been surveyed. If suitable habitat occurs within the project vicinity for any 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 may be 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, supported by
tabular data, if available, and including a discussion of the project's independent utility;
2. A description of the proposed action with an analysis of all alternatives being considered,
including the upgrading of existing roads and a "no action" alternative;
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;
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 secondary impacts to
natural resources, and how this and similar projects contribute to cumulative adverse
effects;
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,
2omu s urger
Acting Ecological Services Supervisor
cc: Dave Timpy, USACE, Wilmington, NC
Nicole Thomson, NCDWQ, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
Chris Militscher, USEPA, Raleigh, NC