20100752_Other Agency Comments_20061109 (2)

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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Q ATLANTAFEDERAL CENTER
Z?F X02 611 FORSYTH STREET
ti,4 PR03EG? ATLANTA, GEORGIA 30303-8360
November, 9, 2006
Gregory J. Thorpe, Ph.D.
Environmental Management Director
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
SUBJECT: US 321 Improvements, Caldwell and Watauga Counties, North Carolina
State of North Carolina Final Environmental Impact Statement
TIP Project No. R-2237C
Dear Dr. Thorpe:
In accordance with Section 309 of the Clean Air Act, the U.S. Environmental
Protection Agency (EPA) is providing comments on the subject State Final
Environmental Impact Statement (FEIS). Improvements are proposed for this segment of
US 321 in the vicinity of the Town of Blowing Rock covering a distance of
approximately 4.3 miles. NCDOT has identified the Widening Alternative as its
preferred alternative, for the existing 2-lane US 321 Bypass of Blowing Rock. Planning
has been ongoing for well over a decade, and a 4-lane roadway is planned from
Blackberry Road northward to near Possum Hollow Road within the City of Blowing
Rock.
EPA's comments on the Draft EIS, that was prepared in accordance with the
federal National Environmental Policy Act (NEPA), are contained in a letter of
September 23, 2002, in which EPA rated the Widening Alternative Environmental
Concerns (EC) because of the potential impacts to historic resources (Green Park Historic
District) and the disruption to the commercial area, both within Blowing Rock. EPA
generally concurs with the selection of the preferred alternative in part because of the
detailed plans for extensive mitigation for identified adverse impacts to historic resources
and the affected community features along US 321. Unlike the other build alternatives
considered in the Draft EIS, the Widening Alternative would have no adverse impact on
the natural and scenic resources of the Blue Ridge Parkway, a "national rural parkway"
managed by the National Park Service.
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Response to Comments
In the comments on the Draft EIS, EPA identified several major impacts. Those
impacts to natural resources have been minimized by the selection of the Widening
Alternative. Aquatic impacts will be 1,440 linear feet of stream habitat and .07 acres of
wetland, but with complete avoidance of impact to the National Park resource. The other
major impact involves properties covered by the National Historic Preservation Act. The
"Project Commitments" identify a number of structural elements to maintain the
aesthetics of the mountain village setting. While there are no noise barriers proposed in
part because of the aesthetic requirements, the stipulations in the Memorandum of
Agreement (MOA) between the Corps of Engineers, NCDOT and the State historic
Preservation Officer include a 35 mph speed limit and sound abatement/buffering for
certain historic structures. The vehicle speed control would also be beneficial mitigation
for the 28 identified affected noise receptors and historic properties, if rigorously
enforced. The MOA and the Memorandum of Understanding (MOU) between NCDOT
and the City of Blowing Rock provide reasonable certainty for effecting the mitigation
for the visual changes and impacts to historic resources and the community brought about
by the widening project.
Invasive Species and Construction Activities
The Draft EIS did not directly address the issue of invasive plant species. The
document also does not address this NEPA cross-cutting issue under E.O. 13112. EPA
has environmental concerns regarding the potential spread of invasive plant species,
including very aggressive exotic (alien, foreign, introduced and non-indigenous) plants
such as Japanese knotweed (Fallopia japonica) and Kudzu (Pueraria montana) along the
proposed project. Further recommendations for appropriate use of best management
techniques are contained in the enclosure to this letter.
Surface Stream Impacts
The selection of the Widening Alternative involves substantial impacts to stream
both from culverting but mostly from placement of roadway fill parallel to the widened
roadway causing a lateral shift of the streams. The amount of direct impact to streams is
second highest of the 5 build alternatives considered. The Draft EIS indicated ample
availability of other sites for offsetting the impact, however, the Final EIS does not
address it in any detail. Further, this proximity of fill to the streams presents substantially
greater difficulties in managing stormwater runoff during construction. EPA would
appreciate having specific mitigation addressed during the Merger Process, and included
in the Record of Decision.
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In summary, EPA is supportive of this proposed project but suggests that NCDOT
take all reasonable steps to manage the construction phase of the project and subsequent
maintenance activities because of the project's mountain community setting, the impacts
to surface streams and the threat posed by invasive plant species. EPA will remain
engaged in the project as it proceeds through completion of the Merger Process. Please
contact Mr. Ted Bisterfeld (404/562-9621) or Mr. Chris Militscher (919/856-4206) on
my staff if you wish to discuss these comments. Thank you for the opportunity to
comment.
Sincerely,
J ' ?f
Heinz J. Mueller
Chief, NEPA Program Office
Office of Policy and Management
Enclosure
cc: John Hennessy, NCDWQ, Raleigh
Ken Jolly, USACE, Wilmington
Pete Benjamin, USFWS Raleigh Field Office
ENCLOSURE TO EPA COMMENTS ON FINAL EIS
Invasive Species and Construction Activities
One of the primary reasons for EPA highlighting this environmental concern
regarding invasive plants is the NCDOTs efforts to provide very specific (and potentially
expensive) landscaping along US 321 for the chosen widening alternative. Some of
these detailed environmental commitments will be difficult to meet if invasive species
impact NCDOTs viewscape plans within Blowing Rock. EPA will continue to
coordinate with NCDOT and provide any technical assistance as needed.
While there are other invasive exotic species that may be a general environmental
concern, such as Tree of Heaven (Ailanthus altissima), Mimosa or Silktree (Albizia
julibrissin), Asian bittersweet (Celastrus orbiculatus), Russian olive (Elaeagnus
angustifolia), Chinese privet (Ligustrum sinense), Japanese honeysuckle (Lonicera
japonica), Chinese wisteria (Wisteria sinensis), Lespedezas (Lespedeza bicolor and L. _
cuneata), etc., both Japanese knotweed and Kudzu can significantly and very quickly
alter viewscapes and out compete and threaten native vegetation. These two species
especially can be very expensive to control and even more difficult to completely
eradicate once they have become established along a disturbed right-of-way. The North
Carolina Native Plant Society and North Carolina Botanical Garden with input from other
groups and agencies list all of the aforementioned exotic plants as`Rank 1-Severe threat',
which means that these species have invasive characteristics, spread rapidly into native
plant communities and displace native vegetation. More detailed lists and technical
information can be found at: htip://www.ncwildflower.org/invasives/invasives.htm.
EPA, NCDOT, the National Park Service, the U.S. Fish and Wildlife Service and
other agencies have found that a number of these species may, already be present in the
project study area and along the existing US 321 right-of-way. The Blue Ridge Parkway,
which crosses US 321 just north of Blowing Rock, is a significant natural and cultural
resource that should be seriously considered in developing all relevant avoidance and
minimization measures. NPS has recently issued Environmental Assessments on the
control of invasive plants along the Blue Ridge Parkway. The spread of invasive species
from the proposed project could alter their future control and management plans.
Construction activities from the planned roadway improvements may result in the
further spread and expansion of undesirable non-native plants. Table S-1 in the State
FEIS indicates that the construction period is estimated to be 3 to 4 construction seasons
(years) for the preferred (Widening) alternative. NCDOT should consider the use of Best
Management Practices (BMPs) to reduce the spread of these invasive species. Disturbed
soils should be provided temporary seeding as soon as possible. Clearing and grubbing
and grading should be limited to the greatest extent practicable. Native plants should be
planted as soon as possible to reduce the establishment of the invasive exotic species.
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In addition to the aforementioned BMPs already used by NCDOTs Roadside
Environmental unit, EPA also suggests NCDOTs consideration for additional
minimization measures, such as early recognition of invasive plant seedlings and physical
removal and/or herbicide treatment should begin as soon as these young plants are
identified. Periodic inspection and frequent maintenance activities will also be critical to
keeping these damaging and undesirable plants under control. For Japanese knotweed,
fill dirt can be a source of rhizomes and future colonization. The State FEIS identifies
that approximately 797,000 cubic yards of fill dirt will be required for the project. The
source of the fill dirt could be inspected by NCDOT officials and/or their qualified.
consultants familiar with Japanese knotweed in order to insure that contractors are not
introducing the reproductive rhizomes to new areas.
If Japanese knotweed is already present along the existing right-of-way, efforts
should be made to limit its spread during construction. There are some recent examples
where mowing or cutting Japanese knotweed around Memorial Day and spraying it with
a glyphosate-based herbicide around Labor Day can significantly decrease the size and
viability of the colony*. Complete eradication may require several years of intensive
treatments once Japanese knotweed is allowed to become established. Both
mowing/cutting and herbicide spraying activities should be conducted when dry weather
is predicted for 2-3 days. Riparian areas should also be protected from cut plant parts and
from direct herbicides. Hand-spraying by a State-licensed applicator is also
recommended.
All of the aforementioned minimization activities are consistent with the general
recommendations from other resource agencies, other State DOT's, and other specialists
in weed control. Again, EPA's primary concern is that the cost of providing detailed
landscaping (viewscape mitigation) for the selected alternative is not `undone' or damaged
from the introduction and/or spread of invasive exotic plants.
* Source: The Japanese Knotweed Workshop, Boyce Thompson Institute, Cornell
University, October 11-12,2006; Daisley, K., Natural Biodiversity: Comparison of
Control Effectiveness and Financial Efficiency at Demonstration Project Sites Employing
Various Integrated Pest Management Tactics to Control Japanese and Giant Knotweed
Species; Grieser, J., NYC DEP Stream Management Program: Evaluation of Three
Japanese Knotweed Treatment Methods; Allen, D., Cornell University: Control of
Japanese Knotweed Using Herbicide; et al.