20000847 Ver _Complete File_19910715

n pc AA7E ' l'v
State of North Carolina
Department of Environment, Health, and Natural Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor Douglas G. Lewis
William W. Cobey, Jr., Secretary Director
Planning and Assessment
MEMORANDUM
TO: Chrys Baggett
State Clearinghouse
FROM: Melba McGee wj?
Project Review Coordinator
RE: 92-0138 - DEIS - US 220, Montgomery
& Richmond Counties
DATE: October 16, 1991
The Department of Environment, Health, and Natural Resources
(DEHNR) has reviewed the Draft Environmental Impact Statement for
proposed construction of US 220 to a four lane divided facility
in Montgomery and Richmond counties. The attached comments
identify substantial concerns from divisions within this
Department. In reviewing our comments, it is evident that the
majority of the alternatives discussed by the Department of
Transportation (DOT) would have major impacts to wetlands, fish
and wildlife habitat, forest lands and possibly rare plants and
animals. There is a consensus, however, that the middle
alignment would be more acceptable and would be environmentally
less damaging to the area.
There are a number of concerns which should be dealt with in
order to produce an acceptable final document. While the
"improve existing" option is addressed in part on pp. 2-9, there
needs to be more detailed discussion as to why the rural portions
of the existing alignment cannot be utilized, particularly from
the crossing at Jobs Creek and going on toward Norman (where M3
parallels the existing alignment). This discussion is important
in the context of minimization efforts as well as avoidance,
especially concerning the wetland impacts at Jobs Creek.
The Natural Heritage Program has raised a number of concerns
that need to be clearly answered in the final document. The
Biotics report and any other technical documents concerning

natural resources should be submitted along with the final
document in order to clarify the nature of the survey work which
was performed. If these documents show deficiencies, it could
cause delays in the review process. It would be more
advantageous for DOT to work with key agencies (such as the
Wildlife Resources Commission and the Natural Heritage Program)
to review and comment on the technical documents in their draft
form prior to the completion of the environmental document. This
would allow for better decisions and avoid unnecessary delays.
In conclusion, concurrence with the project will be
conditional upon our divisions' comments being satisfactorily
addressed in the Final Environmental Impact Statement. Thorough
documentation will also help avoid delays at the permit level.
Thank you for the opportunity to comment.
MM: bb
Attachments
cc: John Dorney
David Foster
0 North Carolina Wildlife Resources Commission
512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391
Charles R. Fullwood, Executive Director
MEMORANDUM
TO: Melba McGee, Division of Planning and Assessment
Dept. of Environment, Health & Natural Resources
FROM: Dennis L. Stewart, Manager _,t.,rruc- .??
Habitat Conservation Program
DATE: October 3, 1991
SUBJECT: Administrative Action Draft Environmental Impact
Statement for Proposed Construction of US 220 to a
Four-lane Divided Facility, Montgomery and Richmond
Counties. Federal Aid Project F-45-1(42), State Project
No. 8.1550801, T.I.P. No. R-2231.
The subject document has been reviewed by professional
biologists on the Wildlife Resources Commission staff and a field
investigation was conducted on 17 September 1991. Our comments
are provided in accordance with certain provisions of the
National Environmental Policy Act (42 U.S.C. 4321-4347).
The purpose of the proposed project is to construct a 4-lane
section of US 220, on a new location, from Emery to the existing
4-lane just south of Ellerbe. This new section will be
approximately 15 miles in length. Four construction alternatives
are described in the document: western, middle, eastern, and east
alternate alignments. Neither adding 2 lanes to the existing
highway nor utilizing portions of the existing road were
apparently given serious consideration.
This project will result in major impacts to fish & wildlife
habitat and wetlands, both during and after construction. There
is no "best" alternative, from a natural resources standpoint,
because all alignments destroy over 700 acres of forest and
agricultural lands, fragment large blocks of forest lands, impact
over 20 acres of wetlands, and cross at least 31 drainageways or
streams. Each alignment transects at least one roadless (state-
maintained) tract of 2000 to 3000 acres. These large tracts are
particularly important for the survival of certain non-game
birds, as well as game species which require areas secluded from
human contact, for example wild turkeys, bobcats, and the
occasional transient black bears that pass through this area.
The assertion (p. 4-58) that ..."no effect on long-term
' Memo Page 2 October 3, 1991
(wildlife) productivity is expected" cannot be supported. This
statement should be altered or deleted in future revisions.
The Middle Alignment would be more acceptable if it were /
shifted to the east several hundred feet, particularly if
portions of the existing highway were used. There are a few c(
relatively sharp curves along the existing highway as well as the J
need to bypass the towns of Norman and Ellerbe, but there are
major sections of the existing highway corridor which could be
used. Advantages of this alternative are that it would primarily
follow a ridge, thereby avoiding many stream and wetland impacts,
and it would greatly reduce the loss of upland habitat and forest
fragmentation.
As proposed, the Middle Alignment crosses Jobs Creek and
would require 260 linear feet of fill along the 300-350 ft. wide
crossing, coupled with a 300 ft. long bridge. Wetland and
floodplain impacts could be minimized by crossing Jobs Creek at
the existing US 220 site, decreasing the width of the median
through the crossing, and by increasing the bridge length with a
corresponding reduction of fill. In addition to wetland impacts
at the Jobs Creek crossing, losses over one acre each are
expected at 8 other locations along the Middle Alignment and
losses of less than one acre each will occur at another 11 sites.
The Western and both Eastern alignments are entirely
unacceptable to this agency due to expected impacts to Little &
Big Mountain Creeks and Silver Creek (Western) and Rocky Ford
Branch, a WS-III-ORW classified tributary of Naked Creek (Eastern
and Eastern Alternate) and other wetlands along each of the
alignments. It is our observation that "best management
practices" to avoid stream and wetland impacts are rarely a
concern of heavy equipment operators.
If conducted at a much earlier stage than at the DEIS level,
coordination between DOT and NCWRC of this and most other highway
projects could be accomplished with far fewer impacts to natural
resources. At this point, we are asked to consider alignments
which are unacceptable to this agency. This is particularly
frustrating when better alignments appear to exist but apparently
have not been considered.
Due to significant, irreversible impacts to fish and
wildlife resources, stream quality, floodplains and wetlands,
NCWRC recommends that a revised DEIS/EIS give consideration to an
alignment which will greatly reduce degradation of these
resources. Unless major revisions are made, this agency will be
unable to concur with the Final EIS or a Finding of No
Significant Impact.
Thank you for the opportunity to review and comment on this
document. We look forward to receiving a revised project plan
from DOT.
DLS/lp
cc: Ken Knight, District 6 Wildlife Biologist
Steve A. Pozzanghera, Piedmont Region Habitat Biologist

State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor October 7, 1991 George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
MEMORANDUM
Regional Offices To: Melba McGee
Asheville
704/251-6208 From: Alan ClarkA__
Fayetteville Subject: Draft EIS - US 220 relocation from Emery
919/486-1541 to south of Ellerbee, EHNR # 92-0138
Mooresville Montgomery and Richmond Counties
704/663-1699
Raleigh The subject document has been reviewed by this
919/733-2314 office. The Division of Environmental Management is
Washington responsible for the issuance of the Section 401 Water
919/946-6481 Quality Certification for activities which may impact
waters of the state including wetlands. The following
Wilmington
comments are offered in response to the DEIS prepared
919/395-3900 for this project.
Winston-Salem
919/896-7007 1. NCDOT should require that the contractor not
impact additional wetland areas due to the disposal
of excavated spoil material, as a source of borrow
material or other construction related activities.
2. As stated above, a 401 Water Quality Certifica-
tion will be required for this project.
3. Endorsement of the DEIS by DEM does not preclude
the denial of the 401 Certification upon applica-
tion if wetland impacts have not been avoided and
minimized to the maximum extent practicable.
4. In general, we prefer the middle alignment
since it impacts fewer acres of wetlands, avoids
the ORW areas of the Drowning Creek watershed and
the WS III areas of Bells and Rocky Ford Creeks,
avoids the Sandhills Gamelands,_and impacts the
smallest individual wetland sites.
affects less valuable wetlands cannot be accepted
5. DOT should apply for one individual permit for
all wetland impacts including those less than one
acre. Appropriate mitigation should be developed
at that time.
PO. Box 29535, Rnh°igh, North Carolina 27(+21;-0535 ICItpho>nr 9i') _73;7015 Pollution Prc%cntion Pays
An Equal Op[-Lin4n Afar mau v? V m?:: i e?i, „vrr
6. Although fills of less than one acre of wet-
lands may be eligible for nationwide 26 permits
from the Corps of Engineers, they may still require
a 401 Certification from DEM if they are in a WS
watershed or if significant existing uses would be
removed.
Questions regarding the 401 Certification should be
directed to Ron Ferrell in DEM's Water Quality Planning
Branch.
USIFRVAN.927/REF1
cc: Ron Ferrell
Nay o
v
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Land Resources
James G. Martin, Governor PROJECT REVIEW COMMENTS Charles H. Gardner
Wiillam W. Cobey, Jr., secretary Director
Project Number: ? -a_ laq County: ??Qy? jc?'1rcW v?ot
Project Name: c) 'p --p V,
S vR- Proj - mod. l? ??501, itP -aa?l, ?cdQ=a \ R, - F-145-i
Geodetic Survey
_ geodetic survey markers. N.C. Geodetic
This project will impact (Qa
Survey should be contacted prior to construction at P.O. Box 27687,
Raleigh, N.C. 27611 [phone]. Intentional destruction of a
geodetic monument is a violation of N.C. General Statute 102-4.
/ This project will have no impact on geodetic survey markers.
other (comments attached) 0_/3 C
Fo more in ion contact the Geodetic Survey office at [phone].
(, / 9l
'nL
eviewer) Dat /
Erosion and Sedimentation Control
No comment
This project will require approval of an erosion and sedimentation
control plan prior to beginning any land-disturbing activity if more
than one (1) acre will be disturbed.
If an environmental document is required to satisfy Environmental
Policy Act (SEPA) requirements, the document must be submitted as part
of a erosion and sedimentation control plan.
If any portion of the project is located within a High Quality Water
Zone (HQW), as classified by the Division of Environmental Management,
increased design standards for sediment and erosion control will apply.
The erosion and sedimentation control plan required for this project
should be prepared by the Department of Transportation under the
erosion control program delegation to the Division of Highways from the
North Carolina Sedimentation Control Commission.
Other (comments attached)
For more information contact the Land Quality Section at [phone].
- /7-5
Reviewer Date
P.O. Box 27687 • Raleigh, N.C. 27611-7687 • Telephone [phone]
An Equal Opportunity Affirmative Action Employer
STATED
?l t s
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Forest Resources
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor Stanford M. Adams
Griffiths Forestry Center
William W Cobg6 Jr., Secretary 2411 Garner Road Director
Clayton, North Carolina 27520
September 24, 1991
MEMORANDUM
TO: Melba McGee, Planning & Assessment
FROM: Don H. Robbins, Staff Forester ,/ Xf
SUBJECT: Draft EIS on US 220 Bypass of Norman and Ellerbe (on new location)
in Montgomery and Richmond Counties, North Carolina
PROJECT: 492-0138
DUE DATE: 10-1-91
We have reviewed the above subject document and have the following comments:
1. We prefer the middle alignment alternative for the following
reasons-
a. Less wetland affected.
b. Distance is shorter.
C. Woodland acreage involved is not the greatest impact. There is
also less impact to managed timber lands.
d. Smallest right-of-way acreage.
e. Least amount of displacements.
2. We would not favor the western alignment because of the number of
woodland acres that would be involved.
3. We also would not favor the eastern or the east alternative
alignments for the following reasons-
a. Naked Creek Headwaters would be involved.
b. The land counted as agriculture is actually in CRP pine
plantations from SR 1524 to SR 1526 and not agriculture.
DHR/la
pc: Warren Boyette - CO
Bob Harrington - D3
File
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer
State of North Carolina Reviewing Office:
Department of Environment, Health, and Natural Resources
INTERGOVERNMENTAL REVIEW - PROJECT COMMENTS Project Number: Due Date:
/p- / - g
After review of this project it has been determined that the EHNR permit(s) indicated must be obtained in order for this project to
comply with North Carolina Law.
Guestions regarding these permits should be -addressed to the Regional Office indicated on the reverse of the form.
Ali applications, information and guidelines relative to these plans and permits are available from the same Normal Process
Regional Office. Time

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PERMITS SPECIAL APPLICATION PROCEDURES or REQUIREMENTS (statutory time
limit)
Permit to construct & operate wastewater treatment Application 90 days before begin construction or award of 30 days
facilities, sewer system extensions, & sewer construction contracts On-site Inspection. Post-application
systems not discharging Into state surface waters. technical conference usual {90 days)
NPDES - permit to discharge Into surface water and/or Application 180 days before begin activity. On-site inspection. 90.120 days
permit to operate and construct wastewater facilities Pre-application conference usual. Additionally, obtain permit to
discharging Into state surface waters. construct wastewater treatment facility-granted after NPDES. Reply (NIA
time, 30 days after receipt of plans or Issue of NPDES
permit-whichever Is later.
30 days
Water Use Permit Pre-application technical conference usually necessary
(NIA)
7 days
Well Construction Permit N/A
(15 days)
Application copy must be served on each riparian property owner. 55 days
Dredge and Fill Permit On-site Inspection. Pre-application conference usual. Filling
may require Easement to Fill from N.C. Department of (90 days)
Administration and Federal Dredge and Fill Permit.
Permit to construct & operate Air Pollution Abatement 60 days
facilities and/or Emission Sources N/A (90 days)
Any open burning associated with subject proposal
must be In compliance with 15 NCAC 2D.0520.
See comments reference asbestos 60 days
on back of form. N/A
(90 days)
Complex Source Permit required under 15 NCAC 2D.0800.
The Sedimentation Pollution Control Act of 1973 must be properly addressed for any land disturbing activity. An erosion & sedimentation control plan
will be required If one or more acres to be disturbed. Plan filed with proper Regional Office (Land Quality Sect.) at least 30 days before begin activity.
The Sedimentation Pollution Control Act of 1973 must be addressed with respect to the referrenced Local Ordinance:
On-site Inspection usual. Surety bond filed with EHNR as shown:
Any area mined greater than one acre must be permited.
AFFECTED LAND AREA AMOUNT OF BOND 30 days
Mining Permit Less than 5 acres $ 2,500
5 but less than 10 acres 5,000
10 but less than 25 acres 12,500 (60 days)
25 or more acres 5,000
North Carolina Burning permit On-site inspection by N.C. Division Forest Resources If permit 1 day
exceeds 4 days (NIA)
Special Ground Clearance Burning Permit - 22 On-site Inspection by N.D. Division Forest Resources required more 1 day
counties in coastal N.C. with organic soils than five acres of ground clearing activities are involved. Inspections (N/A)
should be requested at least ten days before actual burn is planned."
90-120 days
ON Refining Facilities N/A (N/A)
If permit required, application 60 days before begin construction.
Applicant must hire N.C. qualified engineer to: prepare plans, 30 days
Dam Safety Permit inspect construction, certify construction is according to EHNR approv-
ed plans. May also require permit under mosquito control program. An a (N/A)
404 permit from Corps of Engineers.

Normal Process
Time
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(statutory time
PERMITS SPECIAL APPLICATION PROCEDURES or REQUIREMENTS limit)
File surety bond of $5,000 with EHNR running to State of N.C. 10 days
Permit to drill exploratory oil or gas well conditional that any well opened by drill operator shall, upon (NIA)
abandonment, be plugged according to EHNR rules and regulations.
Geophysical Exploration Permit Application filed with EHNR at least 10 days prior to issue of permit 10 days
Application by letter. No standard application form. (NIA)
State Lakes Construction Permit Application fee based on structure size is charged. Must Include 15-20 days
descriptions 8 drawings of structure 8 proof of ownership (NIA)
of riparian property.
60 days
401 Water Quality Certification NIA (130 days)
55 days
CAMA Permit for MAJOR development $10.00 fee must accompany application (180 days)
22 days
CAMA Permit for MINOR development $10.00 fee must accompany application (60 days)
Several geodetic monuments are located in or near the project area. If any monuments need to be moved or destroyed, please notify:
N.C. Geodetic Survey, Box 27687, Raleigh, N.C. 27611
Abandonment of any wells, if required, must be in accordance with Title 15, Subchapter 2C.0100.
Other comments (attach additional pages as necessary, being certain to cite comment authority):
Renovations of structures containing asbestos material and demolitions of both
non-asbestos containing structures and asbestos containing structures must be
in accordance with NCAC 2D.0525 which requires notifications and removal prior to
demolition.
If "orphan" UST's are discovered during excavation, please call the Fayetteville
Regional Office Groundwater Section immediately.
Jim Bales
Groundwater Section
reviewer signature agency date
REGIONAL OFFICES
? Asheville Regional Office
59 Woodfin Place
Asheville, NC 28801
[phone]
? Mooreeville Regional Office
919 North Main Street
Mooresville, NC 28115
[phone]
? Washington Regional Office
1424 Carolina Avenue
Washington, INC 27889
[phone]
? Fayetteville Regional Office
Suite 714 Wachovia Building
Fayetteville, NC 28301
[phone]
? Raleigh Regional Office
Box 27687
Raleigh, NC 27611-7687
[phone]
? Wilmington Regional Office
7225 Wrightsville Avenue
Wilmington, NC 28403
[phone]
? Winston-Salem Regional Office
8003 Silas Creek Parkway Extension
Winston-Salem, NC 27106

Comments (page 2)
Project Review Form
Project Number 92-0138
Montgomery County
9/12/91
- Existing water mains and public water supply wells may be affected
depending upon the location of the road widening and possible changes
in drainage features. Appropriate water system officals should be
contacted.
- Debra B. Benoy, P.E.
Regional Engineer
Public Water Supply Section
Division of Environmental Health
DIVISION OF PARKS AND RECREATION
September 23, 1991
Memorandum
TO: Melba McGee
THROUGH: Carol Tingley C
e k
FROM: Stephen Hall, Natural Heritage Program
SUBJECT: DEIS -- US 220 on New Alignment, Montgomery and Richmond
Counties
REFERENCE: 91-0138
As cited in the report, the Natural Heritage Program database
contains records for a number of rare species occurring within the
vicinity of the project's study area. These include the federally
endangered red-cockaded woodpecker (Picoides borealis) and
Michaux's sumac (Rhus michauxii), as well as five other species
that are included on the state's list of protected species as well
being candidates for federal listing.
This concentration of rare plants and animals, and particularly
the presence of federally-endangered species, requires a careful
survey along the proposed corridors in order to fully evaluate the
potential environmental impacts of the project. This report,
however, appears to rely primarily on Natural Heritage Program
records and some questionable assumptions about habitat
preferences for its evaluations. The only mention of a vegetation
survey refers to a reconnaissance trip made in January 1990, a
time of year when the majority of the herbaceous species, as well
as many woody species, are not identifiable, if even detectable.
With regard to animals, only areas potentially supporting red-
cockaded woodpeckers appear to-have been examined. Furthermore,
for neither of these surveys are any indications given of the
qualifications of the biologists, the number of man-hours
involved, or other details that would allow us to evaluate the
thoroughness of the inventories.
From what little information is presented, we
an adequate survey was done, particularly for
species known to occur in the vicinity of the
question the assumption that no ground-survey
Michaux's sumac. The investigators appear to
description of this species given in Radford,
(1964) as including a definite preference for
In fact there is only a slight hint of such a
only for a few sites in the Piedmont. Radfori
do not believe that
the rare plant
project. We
need be done for
misread the habitat
Ahles, and Bell
soils with basic pH.
preference, and that
i, et al. also
w ?
clearly state that this species occurs in xeric sandy habitats.
In fact, this species is found primarily in such habitats in the
sandhills, none of which are basic in pH or even neutral. There
is thus plenty of potential habitat for this species to be found
along the proposed highway corridors, none of which apparently
received any scrutiny close enough to determine its presence.
The potential for the occurrence of other species was apparently
dismissed partly on the basis that no Natural Heritage Program
records existed within the project site itself. While our data
represent the most detailed site information for the state's rare
species, they are usually not based on complete and systematic
surveys of particular areas. The fact that our database does
contain a number of site records within a mile or two of the
project should only be used to suggest a strong need for more
intensive inventories along the routes of the proposed corridors.
Before we can evaluate this project any further, we will need a
more substantial survey, conducted by qualified biologists working
during the appropriate seasons of the year. Any surveys that are
conducted should be documented sufficiently to allow us to
evaluate their adequacy. A set of draft guidelines for this
purpose, created by the Natural Heritage Program in conjuntion
with the Plant Protection Program of the NC Dept. of Agriculture
and the Non-game Program of the NC Wildlife Resources Commission,
is available upon request.

3193
t
Department of Environment, Health, and Natural Resources
? Project located in 7th floor library
Office of Legislative and Intergovernmental Affairs I'
Project Review Form
Project Number: County: Date: Date Response Due (firm deadline):

This project is being reviewed as indicated below:
Regional Office/Phone Regional Office Area In-House Review
? Asheville ? All R/O Areas ? Soil and Water ? Marine Fisheries
ill
? F
tt ? Air ? Coastal Management ? Water Planning
ev
aye
e ? Water ? Water Resources ? Environmental Health
?Mooresville ?Groundwater Wildlife ?Solid waste management
? Raleigh ? Land Quality Engineer T Forest Resources ? Radiation Protection
hi
? W
t ? Recreational Consultant ? Land Resources ? David Foster
on
as
ng ? Coastal Management Consultant Parks and Recreation El Other (specify)
ED Wilmington
? Others
Environmental Management
? Winston-Salem PWS Monica Swihart
L
Manager Sign-Off/Region: Date: In-House Reviewer/Agency:
Response (check all applicable)
Regional Office response to be compiled and completed by Regional Manager
? No objection to project as proposed
? No Comment
'? Insufficient information to complete review
? Approve
? Permit(s) needed (permit files have been checked)
? Recommended for further development with recommendations for
strengthening (comments attached)
? Recommended for further development if specific & substantive
changes incorporated by funding agency (comments
attachedlauthority(ies) cited)
In-House Reviewer complete individual response.
? Not recommended for further development for reasons
stated in attached comments (authority(ies) cited)
? Applicant has been contacted
? Applicant has not been contacted
? Project Controversial (comments attached)
? Consistency Statement needed (comments attached)
? Consistency Statement not needed
? Full EIS must be required under the provisions of
NEPA and SEPA
? Other (specify and attach comments)
RETURN TO:
Melba McGee Office of Legislative and Intergovernmental Affairs
P5 104

?.; STAY,,
` ?.-7'
State of North Carolina
Department of Environment, Health, and Natural Resources
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27604
James G. Martin, Governor October 7, 1991
George T. Everett, Ph.D.
William W. Cobey, Jr., Secretary Director
I
MEMORANDUM
Regional Offices To: Melba McGee
Asheville
704251-6208 From: Alan Clark
Fayetteville Subject: Draft EIS - US 220 relocation from Emery
to south of Ellerbee, EHNR # 92-0138
Mooresville Montgomery and Richmond Counties
704/663-1699
Raleigh The subject document has been reviewed by this
919/733-2314 office. The Division of Environmental Management is
Washington responsible for the issuance of the Section 401 Water
919/946-6481 Quality Certification for activities which may impact
waters of the state including wetlands. The following

Wi395-39n3900
919//395-
comments are offered in response to the DEIS prepared
for this project.
Winston-Salem
919/896.7007 1. NCDOT should require that the contractor not
impact additional wetland areas due to the disposal
of excavated spoil material, as a source of borrow
material or other construction related activities.
2. As stated above, a 401 Water Quality Certifica-
tion will be required for this project.
3. Endorsement of the DEIS by DEM does not preclude
the denial of the 401 Certification upon applica-
tion if wetland impacts have not been avoided and
minimized to the maximum extent practicable.
4. In general, we prefer the middle alignment
since it impacts fewer acres of wetlands, avoids
the ORW areas of the Drowning Creek watershed and
the WS III areas of Bells and Rocky Ford Creeks,
avoids the Sandhills Gamelands, and impacts the
smallest individual wetland sites.
affects less valuable wetlands cannot be accepted
5. DOT should apply for one individual permit for
all wetland impacts including those less than one
acre. Appropriate mitigation should be developed
at that time.
P() Its„ 291 [,U6_h. North ( an dina ( ?3: 10rhh,mc919-?3701I 1U]Mi-1 I'lew"t'-, Pa-
\n fm:.d t iii;,.,u r.,.'.n \n,..,..?i .o \, i.n,a 1'"1111-1,

6. Although fills of less than one acre of wet-
lands may be eligible for nationwide 26 permits
from the Corps of Engineers, they may still require
a 401 Certification from DEM if they are in a WS
watershed or if significant existing uses would be
removed.
Questions regarding the 401 Certification should be
directed to Ron Ferrell in DEM's Water Quality Planning
Branch.
USIFRVAN.927/REF1
cc: Ron Ferrell
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
March 15, 1994
MEMORANDUM
A AT:,0WMA1
[4 le
ID EHNR
To: Phillip Edwards
NC DOT - P&E
Through: John T)
From: Eric Galamb??
Subject: US 220, Emery to Ellerbe; R-2231
Montgomery and Richmond Counties
DOT presented the subject project during the Cooperating
Agencies Coordination Meeting in November 1993. DEM requests
that DOT determine the wetland impacts (acreage) to various
wetland types for 60 and 46 foot medians. This information
should be included in the Final EIS. If it is too late to
include this information in the FEIS, DEM requests that this
information be included in the 401 Certification application.
Thank-you for this consideration. Should you have any
questions, I can be reached at 733-1786.
cc: Scott McLendon, COE
Jeff Richter, COE
us220r_om.eis
,.0 Box 29535, Raleigh, North Carolina 27626-0535
An ;,caport.unityAfirmafive Action Employer
Telephone [phone] FAX [phone]
50% recycled/ 10% post-consumer paper

1 . .f
7 i
COOPERATING AGENCIES COORDINATION MEETING
NOVEMBER 18, 1993
US 220 EMERY TO ELLERBE; R-2231 .
MONTGOMERY AND RICHMOND COUNTIES
FEDERAL FEIS
AGENDA / (handouts)
PROJECT DESCRIPTION
(location map; E 12-1)
(design criteria; T 2.4-1)
PURPOSE AND NEED
US 220 Intrastate Corridor
I-73 Designation
(text DEIS S-2/S-4)
(typical section; E 2.4-8)
(intrastate corridor map; E 1.2-2)
(text 1-1 / 1-2; DEIS)
(news release)
REASONABLE AND FEASIBLE ALTERNATIVES
(map showing routes; E 2.4-3) (map showing interchanges; E 2.4-4)
- (alternatives summary; 3/92) (advantages and disadvantages; 3/92)
(cost revision memo; 7/93) (alternatives summary table update; 6/93)
PREFERRED ALTERNATIVE
Eastern Alternative (selection memo; 8/26/93)
(letters of support [2])
MAJOR ISSUES
- Wetlands (wetlands map; E 3.7-2)
(wetlands text 4-43/4-48; T 4.7-2)
- Naked Creek Outstanding Resource Waters Watershed
(drainage map; E 3.6-1)
(text 3-31 / 3-33, 4-24 / 4-25)
- Sandhills Gamelands (map of Corridor; E 4.2-1)
(text 3-13, 4-8/4-10)
- Protected Species (text 4-51 / 4-53)
COORDINATION AND PUBLIC INVOLVEMENT
9/89
2/90
7/91
10/91
1/06/92
1/29/92
8/93
Citizens Information Workshops
Citizens Information Workshops
Draft EIS
Public Hearing
Post-DEIS Agency Coordination Meeting
Post-DEIS Agency Coordination Meeting
Selection of a Preferred Alternative
(mtg minutes)
11/17/93 ... rsh... 2451117a.adg

HWA-NC-EIS-91-02-D
ederal Highway Administration
eaion 4
US 220
PROPOSED CONSTRUCTION OF US 220 TO A FOUR-LANE
DIVIDED FACILITY ON NEW LOCATION THAT EXTENDS
APPROXIMATELY 15.3 MILES FROM
EMERY TO SOUTH OF ELLERBE IN
MONTGOMERY AND RICHMOND COUNTIES, NORTH CAROLINA
Federal Aid Project F-45-1(42)
State Project No. 8.1550801
T.I.P. No. R-2231
ADMINISTRATIVE ACTION
DRAFT
ENVIRONMENTAL IMPACT STATEMENT
SUBMITTED PURSUANT TO THE NATIONAL ENVIRONMENTAL
POLICY ACT 42 U.S.C. 4332(2)(c) BY THE
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
AND
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
COOPERATING AGENCY
DEPARTMENT OF THE ARMY, CORPS OF ENGINEERS
This reports presents the documented needs for the planning process leading to the selection ofa corridor location. The existing conditions
of the study area are described and the alternatives are assessed in terms of environmental impacts, com atibility with loc a ggoals,
relative cost-effectiveness, and public opinion. 01
S 1
D'fite rv L.J. Ward, P.E. - NCDOT
Manager of Planning and Environmental Branch
Date Fo1C Nicho L. Graf, 15. E. - HWA
Division Administrator
For additional information contact:
Mr. Nicholas L. Graf, P.E. Mr. L. J. Ward, P.E.
Division Administrator Manager of Planning and Environmental Branch
Federal Highway Administration N.C. Department of Transportation
Post Office Box 26806 Post Office Box 25201
Raleigh, North Carolina 27611 Raleigh, North Carolina 27611
Telephone: [phone] Telephone: [phone]
Comments must be received by Mr. L.J. Ward, Manager of Planning and Environmental
Branch, NCDOT, P.O. Box 25201, Raleigh, NC 27611 By:

PROJECT DESCRIPTION
US 220 EMERY TO ELLERBE; R-2231
MONTGOMERY & RICHMOND COUNTIES
FEDERAL HIS
November 18, 1993
C
va
Richmond
Roanoke
NC
C

SC
US 220 EIS; R-2231
EXHIBIT 1.2-1
PROJECT LOCATION MAP
MO TGOM Y j
0
1
r
A
I? Q
.
1
EMERY

220
RICHMOND
ELLERBE .` CO. 74 1
Rocking m l?
j 1
?• 74 i
/ i '
S.3 DESCRIPTION OF ACTION
General Description - US 220 is a major traffic route between the Greensboro, Winston-
Salem, High Point Triad urban area and the coastal areas of North and South Carolina. It is located
approximately 60 miles east of, and generally parallel to, Interstate Highway 77 (I-77) and provides
connection between I-40/I-85, US 64 and US 74, which are all east-west routes through the Piedmont and
Coastal Plain regions of North Carolina. In terms of influence, it directly serves a corridor that extends
from Roanoke, Virginia, and traverses North Carolina to its border with South Carolina. It provides a vital
transportation link between the communities in and along the corridor and provides access to other routes
serving the entire southeastern seaboard.
Project Status - The route is classified as a rural principal arterial in the North Carolina
Functional Classification System, is a part of the North Carolina Intrastate Corridor System as identified
in the November 1990 Transportation Improvement Program (TIP), and is also a Federal Aid Primary
route. The project is included in the 1990-1996 North Carolina Transportation Improvement Program as
Identification Number R-2231. It is scheduled for the start of design in Fiscal Year (FY) 1991, with right-
of-way (ROW) acquisition beginning in FY 1993 and construction starting in FY 1996.
Description of Studied Improvements - The proposed action is to construct a four-lane
divided roadway on new location, replacing the existing two-lane road from the south end of the
Star/Biscoe/Candor Bypass to the existing four-lane roadway south of the town of Ellerbe. Four alterna-
tives were considered, in addition to the No-Build alternative.
The proposed project begins at the existing four-lane roadway near the intersection of
US 220 and US 220A, just south of Candor, and runs southward. The existing roadway is approximately
15.3 miles in length and the four alternative alignments vary in length from 15.1 to 16.4 miles. The project
ends at the existing four-lane south of Ellerbe.
Traffic Volumes - Traffic volume estimates for the existing alignment, as well,,as the
alternate routes, have been prepared for the current year 1990 and the design year 2010. See exhibits 1.5-
1 and 2.4-5 through 2.4-7. The four alternatives on new location, each a four-lane divided roadway with
full control of access, would all operate at an overall Level-Of-Service (LOS) A, with some short sections
on the borderline of LOS-B. This is in contrast to the No-Build alternative (i.e., the existing two-lane
highway), which currently operates at LOS-C (north of Norman) to E (south of Ellerbe) and would
operate at LOS-E under year 2010 conditions. The signalized intersection in Ellerbe currently operates
at an intersection LOS-B, and would reach LOS-F prior to the year 2010.
The estimated 1990 average daily traffic volumes (ADT) on the existing two-lane highway
range from a low of approximately 5,000 to a high of approximately 9,000 vehicles per day at different
points along the length of the project. The design year 2010 ADT on existing alignment is projected to
range from a low of approximately 9,000 to a high of 16,000 vehicles per day.
New alignments are projected to have ADTs of approximately 10,000 vehicles per day for
design year 2010.
S-2

Proposed Design Criteria - The proposed facility is a four-lane divided roadway with full
control of access. Design speed is 70 mph. Right-of-way for the build alternatives is defined as a
minimum 350 feet (ft), with 25 ft offset beyond construction limits where 350-ft is exceeded. This extra
width right-of-way occurs in areas of deep cut or fill and at interchanges where the right-of-way is located
beyond the on and off ramps.
S.4 ENVIRONMENTAL IMPACTS
Urban and Community Impacts - Construction of any of the alternative alignments would
increase the overall public safety in the towns of Ellerbe and Norman. There will be a change in local
business opportunities as a result of the road relocation and improvement. Increased traffic and improved
connections to the state and regional urban centers are expected to stimulate economic development in
the area. Some businesses along the existing route may be affected by the diversion of traffic.
Displacement of people and businesses would occur with the construction of any of the
alternative alignments; however, the alignments differ in the magnitude of displaced structures
(Residential, Commercial, Farm and Storage, etc.). The Eastern Alignment requires the most structures
to be displaced at 45. The Middle Alignment requires the least at 16. The East Alternate and Western
alignments require 42 and 20, respectively.
None of the construction alternatives require land from schools, recreation areas, parks,
wildlife refuges, historic sites, or churches. One abandoned cemetery may need to be relocated prior to
construction of the proposed Middle Alignment.
Historical and Archaeological Sites - An historical and archaeological inventory and survey
of the study area was completed as part of this study. Eleven potentially significant archaeological sites
are located within the alternative alignments. The Western Alignment contains three sites, the Eastern
and East Alternate alignments together contain four sites, and the Middle Alignment contains four sites.
Two historical structures, one on and one eligible for the National Register of Historic Places, were also
identified by the study noted above. No adverse impacts are expected to the historic sites.
Biotic Communities -Biotic communities, including wetland communities, and the associated
wildlife would be impacted by the construction of any of the alternative alignments. The East Alternate
Alignment contains more urban development, but due to its increased length, it poses the greatest impact
to wetlands. The Western Alignment has the second highest level of impact with the Eastern and Middle
alignments coming in third and fourth, respectively. The Western and Middle alignments contain a more
diverse biotic community and would have the greatest impact on the natural systems.
Air Ouality - Air quality in the area is not expected to change considerably with the
construction of any of the alignments. None of the sites considered in the air quality analysis were
projected to exceed either the one-hour or eight-hour carbon monoxide concentrations set forth by the
National Ambient Air Quality Standards.
S-3
r
Noise Impacts - Noise impacts would be limited in the study area, due to the small
concentration of development which occurs in the immediate area. The Eastern Alignment has the,
greatest number of total impacted structures at 17. The East Alternate and Western alignments have 16
and 13, respectively. The Middle Alignment has the least number of impacted units at 7.
Water Ouality - Construction of adequately sized bridges and culverts would yield
correspondingly minimal increases in floodplain areas. Temporary water quality impacts are expected
from increased sediment loading associated with construction. Drainageway crossings are very close in
number for all alignments. The Western and Eastern alignments have 31 crossings. The Middle has 34
and the East Alternate Alignment has the most, at 36.
Visual Impact - Visual impacts of the Western and Middle alignments are expected to be
limited due to the small number of affected population. The Eastern and East Alternate alignments are
projected to have more visual impact due to increased development in that area.
Summary of Impacts - See Table S-1.
Environmental Commitments - The State makes the following commitments with respect
to the avoidance or minimization of major environmental impacts during design, construction, and
maintenance of this project.
• Avoidance or mitigation of wetlands, as described in Section 4.7.2.4, "Wetland
Mitigation Planning."
• Avoidance of the Sandhills Gamelands properties by the Eastern and East Alternate
Alignments.
• Use of best erosion control practices for all construction activities.
In the Naked Creek and Rocky Ford Branch Watershed (outstanding resource waters)
crossed by the Eastern and East Alternate Alignments, the more stringent erosion control measures
required by Rule 0.0201(d)(2)(A) and (B) of 15 NCAC 213.0201, described in Section 3.6.2, will be
followed.
S-4
TABLE 2.4-1
DESIGN CRITERIA FOR NEW CONSTRUCTION
Traffic:
ADT
ADT
DHV
1990
5,100 to 5,900 vpd
9,300 to 10,600 vpd
DUAL
TTST
V (design speed)
Functional Classification: Principal Arterial
Terrain: Rolling
Design Speed: 70 MPH, Rolling Terrain
Typical Section: See Exhibit 2.4-8
Lane widths 12-ft with 12-ft shoulders (2-ft paved)
Ali ng ment:
Spirals - required
Superelevation - 0.10 ft/ft
Maximum grades - 4% (freeway)
Minimum vertical clearance -
Over freeways - 16 ft-6 inches to 17 ft-0 inches
Over others - 15 ft-0 inches to 15 ft-6 inches
2010
10%
6%
10%
70 MPH
Diamond Interchanaes
Ramp widths 14 ft lane with left-side shoulder 12-ft (2-ft paved) and right-side shoulder 14-ft (2-ft paved)
Design Speed - Middle range to 50 mph
Grades - 6% max.
Control of Access - Full Control of Access
Right-of-Way - Minimum 350-ft width, 25-ft beyond construction limits where 350 ft is exceeded.
2-17
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PURPOSE AND NEED
US 220 EMERY TO ELLERBE; R-2231
MONTGOMERY & RICHMOND COUNTIES
FEDERAL FEIS
November 18, 1993

c
VA
Richmond
Roanoke
NC

SC
US 220 EIS; R-2231
EXHIBIT 1.2-1
PROJECT LOCATION MAP
ELLERBE -` -\
L
Rocking
MO TGOM Y
i 09
s?
1
00
1 r /'
`• 1
?J
L
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1
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-EMERY
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220
RICHMOND
CO. ?•?"
l ?3
1
1.0 PURPOSE OF AND NEED FOR ACTION
Section 1.0 of this report describes the factors which document the need for improvements
to the two-lane segment of US 220 connecting the Star/Biscoe/Candor Bypass in Montgomery County
with the existing four-lane highway south of Ellerbe. Those factors are summarized below.
The NCDOT has the goal of improving the entire US 220 corridor in the state. It is
designated as part of the Intrastate Corridor System and serves as a major north-south route in the area
between I-77 to the west and I-95/ US 1 to the east. Recent improvements to US 220 in the Greensboro
to Rockingham corridor have been to a four-lane, divided, controlled-access roadway. It is the goal of
NCDOT to provide the highest feasible level of traffic service on all future improvements to the US220
corridor. This is acheived with a multi-lane, divided, full control of access facility. Anything less than full
control of access allows for the degradation of traffic service and safety over time as the increase in access
points increases traffic conflict.
This study addresses a missing link in the US 220 Intrastate Corridor between Emery
(Candor) and Ellerbe in Montgomery and Richmond Counties, North Carolina. This portion of the
corridor between Greensboro and Rockingham is the last to be studied for improvement from its current
two lanes. US220 to the north and south of the project termini is a 4-lane divided facility, with full control
of access to the north and partial control of access to the south. The existing road with sharp curves,
roller-coaster grades, reduced speed zones through towns, and traffic signal in downtown Ellerbe reduces
travel efficiency and creates safety problems which are increasing as the traffic volumes increase over time.
Accident statistics show a reduction in accidents by a factor of 3 can be expected by upgrading from the
existing 2-lane roadway to a four-lane, divided, controlled access facility. With the traffic volumes
projected for 2010, this amounts to a reduction from approximately 105 accidents to 35 per year along this
stretch of US 220.
Portions of the existing roadway currently operate at a level of service (LOS) below the
NCDOT's goal for rural roadways. This goal is LOS C, the beginning of the range where the operation
of individual users becomes significantly affected by interactions with others in the traffic stream. In
coming years, traffic service along the entire route will degrade below LOS C. Over-capacity conditions
are now experienced on a seasonal basis when the mix of local, regional, commercial truck and
recreational traffic all use the facility in the summer months. By the design year 2010, the entire 2-lane
roadway will be experiencing LOS E during peak hours. LOS E indicates reduced speeds, lack of freedom
to maneuver, and high driver frustration. The improved roadway will provide LOS A conditions for 2010
traffic. LOS A represents a free flow of traffic.
The purpose of this Draft Environmental Impact Statement (DEIS) is to evaluate and
document the various build and no-build alternatives to support the decision whether to construct the
project as proposed, to construct with modifications or new alternatives, or not to build. This DEIS serves
as a planning document to communicate with the public and agencies in compliance with the National
Environmental Policy Act (NEPA), and to evaluate the potential impacts or effects on man's environment
1-1
REASONABLE AND FEASIBLE ALTERNATIVES
US 220 EMERY TO ELLERBE; R-2231
MONTGOMERY & RICHMOND COUNTIES
FEDERAL FEIS
November 18, 1993
=s ;:C'_WZ*l FI:.E : - i 'ii Viu_, _.:,ii,.?? :,• , 1,:r,;:.J?'?
AK' 0_5 1993
•'?0 ?" 4i:' 4 1993-'
'0
made-
'•R" ! oke .4pproprtatc Action [? D ry ? - ? _ "
STR P _ ;ere reply Using
DES D ' -- r
,,Iy "Signature
GEO-/ 'reper P..,,ly usirlg =
LoC OCT7g? RTH CAc20LI
MY Signature NA
PHO _1} e S D aly Using TRANSPORTATION- Fri, ;;1, ? ; ;:
HYD
a Pro
NLG-?` - 'r%4?Y&%k1sing 1FFAIRS DIVISION 5us?Vn?E _ $A?+~Hut•lT
_ 25201.
i Signature
BO, RALEIGH. N.C27611-5201Ct1il?rtY
SMT/ /? t 1, formation
VDC
diate?
Cor.ta.ct: Bill Jones, (919) 733'-2522 Date: May 14, 1993
Release No: 145 R DistributionN.C. -
(2'his is a revised version of release-number 145 mailed May 11 1993
ROUT) SELECTED FOR I=73 THROUGH N.C
?,=t RALEIGH Gov. James B. Hunt Jr.' and state Transportation Secretaryy. Sam,--'-
Hunt today announced. the selection of a route in North Carolina for
Interstate. 73, a new north/south interstate highway-between Charleston
South Carolina and Detroit, Michigan.
' :1t° route was included in the Intermodal Surface Transportatio
Ef` Lciency Act (ISTEA a p n yy?
pproved by the U.S. Congress in 1991.
"T:Ze highway will provide welcome economic development in the counties
along and. near this corridor, as well as saving travel time for
czarists-" Gov. Hunt said.
Secretary Hunt promised that members of the N.C. Board of Transportati'o'n-"..' ?•
and .st=. f of-the N.C. Department of Transportation will "do allthey 'can
to brirg.the entire route to interstate standards as soon as possible."
Interstate 73.will enter the state on Interstate 77 at the Virginia sa
line in Surry County. It will use I-77 to the U-S. 52 Connector north of
Pi
ne Ridge and•then use U.S. 52 through Stokes and Forsyth ounties to
c
Interstate 40 in Winston-Salem. From there, it will use I-40 to U.S. 311
ar.d then use U.S. 311 through Guilford and Randolph counties to U-.S. 220
noz.It
h of Asheboro. From there, the interstate will use U.S. 220, throwgh
Randolph, Montgomery and Richmond counties to U.S. .1 in Rockingham and
;...then exit the state on U.S. Z at the South Carolina state line.
A
I Except for the-I-77 segment in Surry County, none of highways to be used
for I-73 are built to interstate standards. Although those"are scheduled
in the NCDOT's Transportation Improvement Program (TIP) to-_9-1" kn1111 .
multi-lane highways, additional funds will be required to br ??°m T..^ .
j interstate standards.
Exi si -ng state and federal
since. no additional funding
fcr 1-7; in North?Carolina.
funds will have to be used for
was-designated in the federF,.L-
i 0 4993
the upgrade
legisl??Lon
;;•?0i•?!iSOV
-y ;:.i: hJ41R
***NCDOT***
1
1114C DOTUNE
as a result of the US 220 project, including an evaluation of the transportation system, social and
economic development, and current and projected traffic demand in the study area. A description of
preliminary alternatives, analysis of those alternatives and selection of detailed study alternatives are
described in Section 2.0. The environmental analysis follows with a description of the existing
environment (social, economic, physical, cultural and natural resources) in Section 3.0 and the effects or
environmental consequences of each of the alternatives in Section 4.0.
1.1 PROJECT SETTING
The project is located in south-central North Carolina, in southern Montgomery and
northern Richmond Counties. Exhibit 1.2-1 is a project location map showing the study area in relation
to the two county road systems as well as the North Carolina, South Carolina and Virginia road systems.
The northern project terminus in Montgomery County is at the transition of US 220 from 4-lanes to 2-
lanes just south of Candor (an area known on some mapping as Emery, and on others as Belle Acres).
The southern project terminus in Richmond County is at the transition of US 220 from 2-lanes to 4-lanes
south of Ellerbe.
The US 220 study area is located within Richmond and Montgomery counties in an area of
transition from the Piedmont region into the Sandhills region of North Carolina. Wooded hills and
stream bottoms rise and fall from the Piedmont eastward into the more gently rolling open woodlands
and fields of the Sandhills area. Existing 2-lane US 220 follows the predominent ridge line from Emery
south to Plain View (in Richmond County) where it leaves the ridgetop and travels southwest to Ellerbe.
Richmond and Montgomery counties share common socioeconomic characteristics in
predominantly rural populations mixed with small communities such as Candor, Ellerbe and Norman in
the study area. The study area includes a broad range of residential, commercial, industrial and
agricultural land uses. The socioeconomic resources of the study area relate to and tie in closely with the
recreation opportunities, physical resources, cultural resources and natural resources of the area.
Section 3.0 presents a more-detailed review of the area's affected environment.
1.2 SYSTEM LINKAGE
This project is part of the North Carolina Intrastate Corridor System, a program to provide
high-speed, safe travel service throughout the state. It connects major population centers both inside and
outside the state and provides safe, convenient, through-travel for motorists. It is designed to support
statewide growth and development objectives and to connect to major highways of adjoining states. This
project, Transportation Improvement Program project number R-2231, is part of the US 220 - NC 68
Intrastate Corridor extending from the Virginia border south to US 1 in Rockingham (Richmond County).
Exhibit 1.2-2 shows the US 220 and NC68 Intrastate Corridor, with the November 1990 status of the
corridor improvement projects.
This project is the final improvement to US 220 south of I-40/I-85, with construction
scheduled to begin in Federal Fiscal Year (FFY) 1996. Project R-523 in Randolph and Montgomery
1-2

SR-131 SR-1310
SR-1309 fj a B NETT OAD 73 o w SR-1319
(y RICHMOND COUNTY I MONTGOMERY COUNTY
•„•...' { ....?» »»» ° . ?•?° ?• •-»"••. U?SIInrt SR-1535 0 2840 5280
f. a G ° '?.?u?1u1h 51? SR-1321
D CHAPPELL a SCALE : I"=5280'
c SR-1325 I I" = I MILE)
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n v WALLACE ROAD p ? ?' .,? c
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1317 SR-13 SR-1524
IGHAM p Q
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2 a ,•?, SR-1317 "? ,'`•? CHU.
8R-1448 ! E ELLERBE: °??,,' '`•.
FLINTY a tip,
°, SR 11153 SR 1533 h?
SR-1453 CHU
smoDy
0 CRAWFORD ROAD
CHU SR-1575 ter.
?• a o wM?SR-1321 ?qy .?•
o e l5 p ?',•..? h.
SR-1450 Sa-152 o L ?i ?
LEDBETTER ROAD p ??. ?'•• t' ""• `h'`
o VS2 / 73 r »???,e D P
~ • SR-1456 SR-1458 ? ? '' ?
o ••
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C 6
SR-1452 0 ..+. i /. $mNCs MILLSTONE ROAD ??• `• CHURCH NO,RfiiAN r? tr+""""°...'.•.•..»»?I ?7y
sail up ?, q [fib l? 8 N CANDOR
a SR-1453 i i $R-1526 \ -?
SR-1455
t
SR-1441 [EAST, R p? PLAIN EMERY
0 '
VIEW n 0
"AM °REM SR-1524 SR-1521
SR-1457 SR-1458 l7zl SR-1321 WINDBLOW AD
LEGEND
-•-• APPROAMATE PRELIMINARY ROUTES _
WUTIM r" PRELIMINARY ROUTE DESIGNATIONS
US 220 EIS; R-2231
EXHIBIT 2.4-3
REASONABLE AND FEASIBLE
ALTERNATIVES
_1
March 27, 1992
ALTERNATIVE SUMMARY
US220 - MONTGOMERY AND RICHMOND COUNTIES
Alternative Alignments
East
Units Western Middle Eastern Alternate
Length Miles 15.32 15.02 16.17 16.44
Right-of-Way
r Total Cost
Construction
Right-of-Way
Benefit/Cost Ratio
Grade-Separated
Interchanges Number 5 5 6 6
Relocations Residences 11 10 31 29
'j - Businesses 1 1 2 2
Cemeteries 0 1 0 0
Land Uses Acres of Managed Timber 354 231 202 231
Acres of Forest Lands 225 255 155 204
Acres of Agricultural Fields 165 229 395 332
Acres of Disturbed Areas 7 22 23 24
Acres of Open Water 2 0 1 1
Cultural Resources Archaeological Resources(H.R.) 3 4 4 4
Historic Sites (N.R.) 0 0 0 0
Air Quality 1 hr CO Concentration (ppm) 1.5 1.5 1.5 1.5
Water Quality and Drainageway Crossings 31 34 31 36
and Aquatic Ecology Acres of Wetland Inpact 23.6 20.9 21.3 24.2
Noise Residences Impacted 13 7 17 16
Terrestrial Ecology Acres of Forest 504 405 287 364
and Agricultural Acres of Clear-cut Forest 75 81 70 71
Acres of Agricultural Fields 165 229 395 332
Acres of Disturbed Areas 7 22 23 24
Acres of Open Water 2 0 1 1
Potential Hazardous
Waste Sites Number 0 0 1 1
Prime and Unique
Farmland Acres 15 12 0 0
Statewide or Locally
Important Farmland Acres 97 162 222 260
Acres 753 737 776 792
$M 63.7 62.4 54.6 58.7
$M 59.9 58.4 49.7 54.0
$M 3.8 4.0 4.9 4.7
(at 100/,) 1.16 1.17 1.13 1.11
' r
i =r
US-220 FROM EMERY TO ELLERBE,AONTGOMERY AND RICHMOND
COUNTIES, TIP No. R-2231, PROJECT No. 8.1550801
ADVANTAGES AND DISADVANTAGES OF ALTERNATIVES
EASTERN ALTERNATIVE
ADVANTAGES:
o Lowest total cost -,$54.6 Million versus $62.4 million for
Middle Alternative.
o Better serves Norman and NC-73.east of Ellerbe.
o Least impact on Bottomland and Mixed Hardwood Forest.
Takes 100 acres less hardwood forest than Middle
Alternative.
o Improves access to speedway via SR 1450.
o Has development potential around southern end of project.
o Low wetland impact
•D I SADVANTAG E<S '
o Impacts_Out.s"tanding Resource Waters watershed feeding Naked
Creek and Drowning Creek
o Divides outlying parcels of protected Sandhiils Gameiands
and could encourage development in vicinity of Gamelands
o Longest and most indirect route between-project termini
o Greatest number of relocations. Number of relocations is
three times higher than other alternatives.
o Greatest impact on agricultural lands and farm operations
o Potential access problem to homes and farms adjacent to
existing US-220. Additional right of way acquisition and
construction could be involved. These costs were not
included in cost estimates.
o Potential hazardous waste site, An abandoned landfill is
located within proposed right of way.
o Need to relocate more than one mile of SR-1453 to avoid
Sandhill Gameland and continue to provide local access.
o Closest to residential areas in Norman -
MIDDLE ALTERNATIVE
ADVANTAGES:
o Best service for town of Ellerbe
o Lowest number of relocations
o Low wetland impact
o Highest Benefit/Cost Ratio
o Shortest length - 15.02 miles versus 16.17 miles for
Eastern Alternative
o least acreage required for right of way - 737 acres
versus 776 acres for Eastern Alternative
* Revised cost estimates
• i
iZ„i:- t+?? f X Y
J?
-' ,•o pens area for potential development along existing
-- US-220 and 58-1453 in southern Montgomery and northern
Richmond Counties
DISADVANTAGES:
o Greatest acreage of Hardwood and Mixed Hardwood Forest land
required for right of way,
o Closest to Rankin Lake Subdivision ;.
o Divides wildlife habitat area in Little Mountain Creek
drainage basin. However, most habitat area is privately
owned and not-protected from development, timbering, or
other use.
o Potential impacts to three to five graves in unmarked
family cemetery
WESTERN ALTERNATIVE
ADVANTAGES
o Least impact on agricultural fields and farm operations
o Low number of relocations
o Lowest right of way cost
DISADVANTAGES:
o Potential construction problems and highest construction
cost due to rough terrain
o Greatest wetland impact
o Greatest number of acres of forest land required for
right of way
o Poorest traffic service to towns and existing population
o Greatest habitat fragmentation impacts
o Least potential for economic development
r_
NOV-17-193 WED 09:16 ID: TEL NO: #117 P05
O
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
JAMES B. HUNT. JR DIVISION OF HIGHWAYS
GOVERNOR PO. BOX 25201. RALEIGH. N.C 27611-5201
July 9, 1993
MEMORANDUM TO: L. J. Ward, P. E., Manager
Planning and Environmenal Br nc _
FROM: H. Frank Vick, P. E. ;?
Consultant Engineering i
S
AM HUNT
SECRETARY
SUBJECT: CS-220 from Emery to Ellerbe, TIP No. R-2231
Montgomery and Richmond Counties
U»date 12 Pro.iect Costs
We•have received revised construction and right-of-way costs
for the middle and eastern alternatives for this project.
Alter nativ e Alignments

Middle Easte rn
Total Costs (July 1993) $74.4 Mil $72.5 Mil
Construction $70.4 Mil $67.5 Mil
Right-of-Way $ 4.0 Mil $ 5.0 Mil
Total Costs (March 1992) $62:2 Mil $54.4 Mil
Construction $58.2 Mil $49.5 Mil
Right-of-Way $ 4,0 Mil $ 4.9 Mil
Total Costs (DEIS July 1991) $66.4 Mil $56.6 Mil
Construction $62.4 Mil $51.7 Mil
Right-of-Way $ 4.0 Mil $ 4.9 Mil
These construction cost increases are due to the addition of
interchange grading and drainage costs, the addition of
service roads, revised subgrade stabilization, RCBC's and
paved shoulders.
If you have questions or need additional information, please
contact me.
cc: Ms. Gail Grimes, P. E.
. Mr. Philip D. Edwards

June 10, 1993
R-2231
ALTERNATIVE SUMMARY
US220 - MONTGOMERY AND RICHMOND COUNTIES
Alternative Alignments
East
Units Western Middle Eastern Alternate
Length Miles 15.32 15.02 16.17 16.44
Right-of-Way Acres 753 737 776 792
Total Cost $M 74.4 72.4
Construction $M 70.4 67.5
Right-of-Way $M 4.0 4.9
Benefit/Cost Ratio (at 10%)
Grade-Separated
Interchanges Number 5 5 6 6
Relocations Residences 11 10 31 29
Businesses 1 1 2 2
Cemeteries 0 1 0 0
Land Uses Acres of Managed Timber 354 231 202 231
Acres of Forest Lands 225 255 155 204
Acres of Agricultural Fields 165 229 395 332
Acres of Disturbed Areas 7 22 23 24
Acres of Open Water 2 0 1 1
Cultural Resources Archaeological Resources(H.R.) 3 4 4 4
Historic Sites (N.R.) 0 0 0 0
Air Quality 1 hr CO Concentration (ppm) 1.5 1.5 1.5 1.5
Water Quality and Drainageway Crossings 31 34 31 36
and Aquatic Ecology Acres of Wetland Inpact 23.6 20.9 21.3 24.2
Noise Residences Impacted 13 7 17 16
Terrestrial Ecology Acres of Forest 504 405 287 364
and Agricultural Acres of Clear-cut Forest 75 81 70 71
Acres of Agricultural Fields 165 229 395 332
Acres of Disturbed Areas 7 22 23 24
Acres of Open Water 2 0 1 1
Potential Hazardous
Waste Sites Number 0 0 1 1
Prime and Unique
Farmland Acres 15 12 0 0
Statewide or Locally
Important Farmland Acres 97 162 222 260
PREFERRED ALTERNATIVE
US 220 EMERY TO ELLERBE; R-2231
MONTGOMERY & RICHMOND COUNTIES
FEDERAL FEIS
November 18, 1993
7
1.• •
STATE OF NORTH CAROLINA
DEPARTMENT OF TPANSPORTATION
JAMES B. HUNT. JR. DIVISION OF HIGHWAYS R. SAMUEL HUNT II I
Gowmo;L P.O. BOX 25201. RALEIGH. N.C 27611-5201 SECRETARY
August 25, 1993
MEMORANDUM TO: Mr. J. T. Peacock, Jr., P. E.
Chief Engineer - Preconstruction
FROM: L. J. Ward, P. E., Manager9-?
Planning and Environmental. Branch
SUBJECT: Project R-22310 Richmond and Montgomery Counties, US 220
From Emery to Ellerbe
As requested in your memorandum of October 12, 1992 the Planning and
Environmental Branch contacted the County Commissioners for Richmond and
Montgomery Counties as well as the local officials of the towns of Emery and
Ellerbe to solicit responses regarding the selection of a preferred
alternative. Mr. G. R. Kindley, Jr., Board of Transportation member, also
requested the County Commissioners and Town Officials provide the Department
of Transportation with an endorsement for a preferred alternative. Recently
the Richmond County Commissioners and Town of Ellerbe adopted resolutions
endorsing the Eastern Alternative (Attached). Mr. Kindley also endorses the
Eastern Alternative.
The Eastern Alternative contains several advantages which include:
Lowest total cost - $72.5 million versus'
'Better traffic service for Norman and NC 73 east of Ellerbe
Least impact on Bottomland and Mixed Hardwood Forest
Improves access to speedway via SR 1540
Has development potential around southern end of project
Low wetland impact
Endorsement by Richmond County Commissioners and Town of Ellerbe
Officials.
If you concur with the selection of the Eastern Alternative as the
preferred alternative, please notify Public Affairs and request a press
release.
If you have questions or need additional information, please contact me.
PE/rfm
Attachments
c: H. Franklin Vick, P. E.

r
RICHMOND COUNTY BOARD OF COMMISSIONERS
125 SOUTH HANCOCK STREET i P.O. ©OX 504
ROCKINGHAM, NORTH CAROLINA 20379,
TELEPHONE: [phone]
FAX: [phone]
JIMMY !.. Maske
Chelrman
Vntnon W. McDonald
Vice Chairman S'
•letbett C. Diggs
I. Lynn MCCaskiil
Bill Mcoua9a
1. ClY04 Walklns
N.T. "Felt" Ussery
June 9, 1993
Mr. 134. R. Kindley, Jr,
Board'
oard Member
North Carolina department of Transportation
P.O. Box 280
Rockinghamo NC 28379
REe
Beer Mr. Klndleys
Richard O. Tlllis
County Maneper
John T. Pape. Jr,
County Attorney
Aulh 0. 61111ard
finance 0111ear
Matian S: savage
Clerk to the 80erd
Johnny C. Sullon
Industrial Dereldper
This is to advise that In the
the Soard of Commissioners Regular Meeting of June 7
route of the by tonsensus, endorsed the eastern
Concurrence With PthedoFflclal action~teken b t
Council In endorain the The Board I9 In
Y he EIlert,e Town
g eastern route.
The Board appreclates your conslderatlon of this matter, an
If we might offer any assists d
rice, please let ue know.
Sincerely,
?i?uetr-/
Harlan S. SaVa9e
Clerk to the Board
Proposed Route - Highway 220 By-pass
CCi• Ellerbe Mayor Joe Comer
! .. ,. -rrry1? .: sT,SY•?J7 usra??r.+vf ? .
t.' . .
rk"_12atu',itill of I;he To.3tm u•f EJ„?•tj•(-qu, -{bo bf,1, NorF:h C 'APO1?11?d
"Ievr$ u'i . T'r ar)r.,"acrY`i..ab1 an Pero-krdirrn the r©jcwafion..bf 1?crGi';a-
'r•vt•trrd ,-he Town of r'1 Lk?Y`bc?.. ? ? :; '' ',. :. • ..
WHEREAS. Lho new uip 220 Will ,bft tin ''i ,• .;r
nrei?rtteted Eas•bwr11 F'rot.t'lO' All cnt•t11bL`><b?ili `fin.. :.
? ?tirt?txtad 'i?iG, ?:aFay fcitf,i+J 10su to bLti.i d --than
?tia•r: p•r.gpt??od ... .
WHEREAS., -blit•,• ic'rAf'fic 1-3rab10ITI ? e:slJarciall -ctrl.:µl:apu. -
4eed,ir<:.Ayy wouId baIIeviaErjd'itunt:.4Ft?,1= u?L?rn ;
Routa and
WHEREAS, the TiDwn of Ell+#'riaw would iic)t be 'eet) ro(tlit-aIL•ffcto tod
advarvaiy mor a 4y tam.? 'r.au iav o'r' -bhca u#;ht3r. ' :,; .:' %:'; :•: .
The Town Board ctoes orw •ro-co-rd as rrrrantmatnciinrt •tc.)-ttle 140 -1,tII Caro- .
.Li.rla Derj-.%'o•'tirll?+i-d-. 11 `' T'(` 111 fa?7t7'rl?a9??5311 'tihe Selection of t ho.
??'!•<7!:f(33k7f3
E"asta•ryi R-outer for •l:1he new US EE0 bypjAas a;rc7Ulid. !`lIO,rbQj War'bh
.fd'1'tiJlli7tlr - ,'
iiul:aurr uy Commissioner ser.rahded by Cc+mmfra
?irJllwr •,.?vS7PAr.....? ._ g' AFlla'rr Yed 'by.LI114rrimGll.ttn' voL-e a'I"Thn :Town.
warn s?i E: 15a'rt.xt,,. 'tsi'ria •thea 3•(•d daly of aY, :I9
911A,-* 4,-,j
t y j
l
MAJOR ISSUES
US 220 EMERY TO ELLERBE; R-2231
MONTGOMERY & RICHMOND COUNTIES
FEDERAL FEIS
November 18, 1993

SR-1309 SR-1314 B NE 1310
WW3 e
•? a
WW2 WW4
I , '• a WM2 WM3, • _
..1313 .....
•' WM .1 .... ........ ALLACE RO
.......... ;
i "6
4M WFh^? 0
WE2 cz
8R-1448 ; ELLERBE:
SP,-1453
0 CRAWFORD ROAD
SR-1450 `, • °
LEDBETTER ROAD 0
WE3 °
-•1458
4 D D`'`'am. WE5
SR-1452
MILL STONE ROAD wj:s COO
SR-1455 _
SR-1441
LEGEND
POTENTIAL WETLANDS
WWI WETLAND SITE DESIGNATION
FOR TABLE 4.7-2
US 220 EIS; R-2231
EXHIBIT 3,7-2
POTENTIAL WETLANDS
SITES
73 O CHUP" S'-1319
RICHMOND COUNTY MONTGOMERY COUNTY
0
`_, ° :.. .? •- -•. p(??m SR-1535 0 2640 5280
WWS W6 a SR-1321
0 CxJ SP,-1325 SCALE : 1"=5280'
WW9 11" : 1 MILE I
`'•.?, SP.-1533
4 v o o W 10 WWI 2
-1J ,? ''•,? SR-1524
1317
to,
43 '`•. WM6 A'?T ? ? •'''•.
C SR-1317 ?aa ''••.,? WWI 3
, W 7
ruWr WM8 WWI 4
a n ?i4_ SR-t`1153 SP, 1533
`'••: WM9 SR-1575 W 15
0 0° ?0©© WMI W 17 ••.,• W I
Q WM 3 14
c2 / 73 .?.. ...._..?.?,., , '' •i. - ??? / s WM 6. WC I P
, ?yo
a "SR-JA WM I I WMI 2. 18
0 2
WMI 9 ?'`•.
CUM &bFM,3S i ?..........«.-...-.-.-.-«..•
NORMAN f ••
• • WE6 o CHU401 i ?Q??CIr I1 0 CANDOR
,??'• ? SP,-1453 SP,-1528 -?
WE? EMERY
s ? .... WE 7 ,.?,•.
MEW
1 ?'( MN;D Cif O
` SP.-1524 SP.-1003 SR-1521
SR-1457 SR-1458 73 SR-1321 WINDBLOW ROAD

safety hazard. Areas of bare soil will be expeditiously re-seeded with fast-growing grass species so as to
minimize erosion, yet ultimately revegetated with native species. Long-term impacts to vegetation from
pollution contained in highway runoff water will be managed by utilizing retention basins and grassed
swales in the construction design.
A No-Build alternative would not be expected to affect vegetation within the study area.
Continual disturbances to vegetation communities from logging and agricultural activities will change the
landscape.
4.7.2 Impacts to Wetlands
4.7.2.1 Nature of Potential Impacts and Control Measures - Examples of common highway construction
impacts to waters of the U.S. including wetlands are: increased turbidity and sedimentation; modification
of water chemistry due to sediments, nutrients and pollutants; increased soil erosion and soil compaction;
destruction of vegetative cover and topsoil; and alteration of water flow and circulation patterns. The,
effects of construction will primarily fall into two categories: 1) the immediate results which will occur
during the construction phase, and 2) the long-term effects or permanent changes caused by the
constuction itself or through management related to the structure (Darnell et al.,1976).
The degree of impacts which these construction activities will have on the environment depends
largely on the highway and bridge structures and construction techniques. Conservative construction
techniques can reduce the effects on the physical environment, yet the effects of man-made landforms
on ecosystems are not as predictable as are the immediate impacts on the specific sites they occupy.
Modifications of ecosystems transpire over a longer period of time than do site-specific alterations (Fore
and Peterson, 1980), thus long-term impact effects are not easily quantified.
The initial clearing of the land during construction will remove the vegetative cover and
underlying topsoil layer. These activities, whether taking place in grassland or marsh communities, will
increase the surface runoff and lead to erosion. Runoff and erosion will add soil solids to drainage areas
and tributaries and eventually into wetland areas in the form of increased water turbidity and
sedimentation. High turbidity to the waters is one of the primary construction site impacts (Shuldiner et
al., 1979). Turbidity of the water, due to the presence of suspended solids, diminish the suitability of
water as habitat for supporting aquatic vertebrates, invertebrates, phytoplankton, and rooted vegetation
(EQL, 1977; Darnell et al., 1976).
Impacts from erosion and sedimentation may be minimized by implementing control measures
at the beginning, during and after construction, with monitoring conducted throughout the construction
activity. Various means to limit erosion include use of berms; sediment basins and traps, and
revegetation. Placement of such structures should precede the actual construction activities, minimizing
erosion impacts from the beginning. Revegetation along the right-of-way should be performed with native
plant species.
4-43
4.7.2.2 Determination of Potential Wetland Impact Areas - Using information obtained during baseline
investigations, the approximate extent of potential wetlands crossed by the alternative alignments was
drawn on topographic maps. The functional design construction limits were then transferred to the
preliminary wetlands maps. An electronic planimeter was used to determine the areal extent of impacts
to potential wetlands for each of the four alignments. Results reflect the "worst case", as it is possible that
some areas within the construction limits would not be impacted. Types of impact would also vary and
results do not discriminate these variations. For example, small drainages with culverted fill may
accommodate the roadway, whereas larger floodplains may be spanned with bridge structures. The fill
would permanently destroy wetlands within its footprint whereas the bridge would accommodate wetlands
beneath the roadway. Although flood waters might be detained to a greater degree by culverted fill than
by bridges, the difference may be measured in hours and the effect on other wetland functions might be
minimal (Adamus and Stockwell, 1983).
The largest extent of potential wetlands are found in association with the wider floodplains.
The approximate areal extent of several of the wetlands is of maximum inclusion within these floodplains.
The bottomland areas are highly interspersed with ridges, swales, depressions and tributary channels.
While much of these areas may not be strictly jurisdictional according to the Federal multiple-parameter
wetland delineation method, the jurisdictional swales, depressions and channels are sufficiently dispersed
and blended within the higher ridges to make preliminary delineation mapping difficult. For mapping
purposes the potential wetland areas were determined with the aid of USGS topographic maps and color
infrared photography along with field investigations, thus areas which may not be considered jurisdictional
have been included in the wetland category.
Wetland sites are located and identified in Exhibit 3.7-2. Acreage totals for direct impacts to
wetlands are quite similar for all four alignments as shown in Table 4.7-2, ranging from a total of
24.2 acres for the East Alternate Alignment to 20.9 acres for the Middle Alignment. Any activity that will
cause loss or substantial adverse modification of waters of the U.S., including wetlands, that is less than
one acre in size is considered for coverage under a nationwide permit issued by the Corps of Engineers.
When permitted by a nationwide, no further Corps of Engineers action is required. For those impacts
to wetlands that exceed one acre in size, written coordination with the Corps of Engineers is required.
Eleven sites on the Western Alignment, 11 sites on the Middle Alignment, 7 sites on the Eastern
Alignment, and 8 sites on the East Alternate Alignment qualify by size for inclusion under a nationwide
permit. None of these partial-acre sites are of a quality that would warrant their individual coordination
with the Corps of Engineers. Potential wetland sites with areal extent exceeding one acre are discussed
in more detail below. The extent of open water potentially affected by the preliminary routes is relatively
minor in coverage and approximate acreages are presented in Table 4.7-2.
4.7.2.3 Potential Wetland Site Descriptions -
Western Alin ment - As shown in Table 4.7-2, six sites of more than one acre of wetlands are
listed as being impacted by the Western Alignment. All of these sites are characterized as bottomland
hardwood forest community types. Those sites that include additional community types are noted below.
The quality and function of these sites are as follows:
4-44
TABLE 4.7-2
POTENTIAL WETLANDS IMPACTS (ACRES) k 1
Western Middle Eastern East
Alignment Alignment Alignment Alternate
Site Acres Site Acres

WW2 2.3 WMl 1.5
WW3 2.3 WM2 1.2
WW5 5.5 WM3 1.7
WW12 4.0 WM4 2.0
WW14 2.5 WM6 3.0
WC1 2.8 WM10 1.7
WM11 1.9
WM12 1.7
WC1 2.8
Site
WE2
WE4
WE6
WE8 1.9
WC1 2.8
Acres
2.5
1.6
1.6
Site Acres
WE2 2.5
WE4 1.6
WE6 1.6
WE7 5.3
1.9
WE9 2.0
WA1 3.1
WC1 2.8
TOTAL OF SITES
> THAN 1 AC.
EACH 19.4 17.5 17.7 20.8
11 Other Sites 11 Other Sites' 7 Other Sites 8 Other Sites
Range in Size from Range in Size from Range in Size from Range in Size from
0.1 to 0.9 acre 0.1 to 0.9 acre 0.1 to 0.9 acre 0.1 to 0.9 acre
Open Water 1.6 0 0.7 0.7
TOTAL OF ALL
WETLAND &
OPEN WATER 23.6 20.9 21.3 24.2
4-45
Sites WW2, WW3 and WW14 - These sites are located within narrow upper tributaries. The
major role of these sites is of a flood-control nature. The sites support a minute diversity of
wetland vegetation and are of low value. These narrow upper tributary wetlands are in
abundance within the project area. Sites WW2 and WW3 also contain open-water areas (stock
ponds).
Sites WW5 and WW12 - These sites are included within larger expanses of floodplains. They
support a more diverse wetland vegetation community that is of less frequency in the area and
thus of higher value. These communities also provide greater flood storage and velocity
reduction. Portions of these areas have been disturbed by logging and are revegetating as
marsh wetland communities.
Site WC1 - This site is located on a narrow upper tributary and a portion of the area has been
cleared due to logging. The cleared area is revegetating as a marsh wetland community and
is in an early stage of development. This wetland site serves in a flood control capacity.
Other potential wetland sites (each less than one acre in areal extent) are primarily associated
with upper tributaries of Big Mountain Creek, Little Mountain Creek, and Beaverdam Creek. These
tributary crossings are predominately narrow drainages with widths of potential wetlands ranging from
10 ft to 60 ft. Sites WW1 and WW4 support bottomland communities that have not been disturbed or
logged as of January 1990. The majority of the other communities where these tributaries occur have
been subject to logging activities. Sites WW1 and WW4 would provide the highest value when considering
wildlife habitat and wetland vegetation. All of these sites would be active in some extent of flood control,
although to a minor degree.
Middle Ali nment - The Middle Alignment impacts nine potential wetland sites with an areal
extent larger than one acre. These sites consist of bottomland hardwood forest community types. Those
sites that include additional community types are listed below. The quality and function of these sites are
as follows: '
Sites WM1, WM2, WM3, WM4, WM10, and WM11 - (These sites contain the same type,
quality and function of wetlands as previously mentioned for site WW2)
Site WM6 - This lowland forest community occurs within a relatively wide floodplain of Jobs
Creek. Due to the maturity of this woodland community the importance of this site when
considering quality is greater than the six previous sites.
Site WM12 - This site has been severely disturbed by logging and supports little wildlife habitat.
Quality of this site is low and flood control is its primary function.
Site WC1 - (Previously discussed under Western Alignment)
4-46
Eastern Alignment - A total of seven sites exist on this alignment that are over one acre in size.
The type, quality and function of these sites are as follows:
Sites WE2, WE6, WE7, WE8, and WE9 - These sites are of the marsh wetland community
type. All sites, except WE2, are on upper tributaries of creeks that are classified as WS-III or
WS-III-ORW (see Section 3.6.2). Due to this classification, these wetland sites have a
uniqueness of participating in filtration of sediments to these waterways, even though the small
size of each site may not considerably alter the quality of water downstream. These wetland
sites maintain a low level of productivity and species diversity. Site WE6 contains a portion of
open-water (stock pond).
Site WE4 - This site includes a shrub wetland community type. These communities are on an
upper tributary of a creek classified as WS-III. It also shares the same properties as of the
aforementioned (WE6, WE7, WE8, and WE9) wetland sites.
Site WC1 - (Previously discussed under Western Alignment)
East Alternate Ali nmment - The East Alternate Alignment impacts eight wetland sites that are
over one acre in size. The type, quality and function of these sites are as follows:
Sites WE2, WE4, WE6, WE7, WE8, WE9 and WC1 - (Previously discussed under the Eastern
Alignment)
Site WA1 - This marsh wetland community occurs in a severely disturbed upper tributary. As
a result of recent logging, the natural flow through the area has been altered. The area is of
low productivity and species diversity.
Potential indirect construction impacts to wetlands may occur due to 1) soil erosion and
subsequent sedimentation, and 2) off-site pollution resulting from oil and grease runoff. These impacts
represent potential temporary adverse effects to wetlands downstream of construction areas. Such impacts
may be minimized by implementing proper runoff and erosion-control measures during construction,
control and removal of accidental spills of fuel or waste oil, and by revegetating exposed soils as soon as
possible after construction is complete.
4.7.2.4 Wetland Mitigation Planning - Mitigation includes measures which avoid, minimize, eliminate
or compensate for the losses. Initial mitigation measures in the planning or alignment of highway projects
is to minimize the probable occurrence of wetland impacts through route location (avoidance), design (use
of bridge crossings instead of filled embankment), and construction practices. Activities to minimize the
impacts to wetland habitat from highway construction include: minimizing devegetation of the construction
area, and decreasing the amount of fill placement; implementation of best management practices,
including an erosion and sedimentation control plan, and use of retention basins and revegetated swales
to minimize runoff, sedimentation, turbidity, leaching of soil nutrients, and leaching of chemicals from
4-47
petroleum products, pavement, and waste material; and alleviating flow alterations, due to stuctures, which
change established wetland drainage or flooding patterns.
The fact that some degree of impact is often unavoidable, regardless of the care applied during
the planning, design, and construction of a highway, necessitates a plan for compensatory mitigation to
reconstruct the features or habitat that were disturbed. This is required for unavoidable impacts which
remain after appropriate and practicable minimization has been achieved. Actions may involve on-site
restoration of degraded wetland habitat or creation of manmade wetland habitat within the highway right-
of-way through creative use of swales, borrow pit areas, and drainage runoff channels.
If on-site mitigation measures are not practicable then off-site mitigation measures will be developed.
These off-site mitigation projects must be designed to reestablish, to the extent reasonable, similar
conditions as the pre-existing vegetation. Off-site mitigation should be conducted in the same geographic
vicinity or in close proximity, and possibly within the same watershed as the project. Action may include
expanding existing wetlands, revegetating with hydrophytic species or regulating water levels in
impoundments or streams. Construction or improvement of the mitigation wetland habitat should not
be considered unless postproject monitoring and viability of the sites can be arranged.
Another form of compensatory mitigation which occasionally is used includes mitigation banking
through an approved bank by the Corps of Engineers and the U.S. Environmental Protection Agency
(EPA). The payment of a fee to a "mitigation bank" by the permitholder for purchase (withdrawal) of
a productive wetland may potentially meet the objectives for mitigation of impacts created during the
project. However, preservation of existing wetlands through a purchase may not always be accepted as
compensatory mitigation. The EPA and the Corps of Engineers will provide specific guidance in the
mitigation process.
A detailed mitigation plan for wetland impacts will be developed when a preferred alignment
is selected and a jurisdictional wetlands delineation is conducted. Any mitigation proposed will provide
functional and acreage replacement based on impacts (i.e., no net loss of values), and the expected degree
of success would need to be reflected in this plan.
A No-Build alternative would not be expected to affect wetlands within the study area.
There would be continued disturbance to wetlands from logging and agricultural activities.
4.7.3 Impacts to Wildlife and Fisheries
4.7.3.1 Wildlife - Table 4.7-1 gives impacts to vegetation, thus wildlife habitat, for each alignment. The
major direct, adverse impact to wildlife by any of the alternative alignments would stem from clearing
activities during construction. Clearing activities would result in the direct destruction of certain forms
of wildlife not mobile enough to avoid construction operations. These include several species of
amphibians, reptiles, mammals and some age classes of birds (e.g., nestlings and fledglings). Also
included are species which burrow underground, such as the woodland vole. Some of the larger, more
mobile species of wildlife, such as deer and adult birds, may be warned by the noise associated with initial
4-48
SR-1309 SR-1310 BNETf 10
........
p •, -*IR-1313
2 ALLACE P,0
R INGHAM p
2
2
L
BR-1448 ; ELLERBN,:
....... ..................... ;
a
SP,-1453\
0 CP,AWORD ROAD
e
SR-1450 °
LEDBETTER ROAD Q •? n
•. R-•1as8
SR-1452 0 `•`"•?..
MILLSTONE P,O.AD tal:s
SP,-1455
SR-1441
SR-•1457
LEGEND
F.E.MA 100-YEAR FLOODPLAINS
11 / ` RIDCE LINE
SARON
1 RI SR-1319
73 0 1
RICHMOND COUNTY MONTGOMERY COUNTY
?_4. -i5 0 2640 5280
• `•.,? w SR-1321 °
0 ? SCALE : I"=5280'
•\•?• SR-1325 I I" = I MILE 1
SP,-1533
0 ?.
n v `•.
P,- SR-13 !Y •?,? SR-1524
1317
a SR-1317 wrap ,•, `'•.
y
FLOM au ' ?• a ?i? SR41153 SP, 1533
° yr t SR-1575
o M`'`•. SR-1321 i ?'•,
0/73
0 p '? .•'J5'
sR-1458 o 44 ' ? ?S" ?''C i i•'
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US 220 EIS; R-2231
EXHIBIT 3.6-1
STUDY AREA
DRAINAGE AND FLOODPLAINS
and separation of directional travel via a median, will improve safety for users of US 220. This will, in
turn, decrease the probability of a hazardous material spill on the roadway.
Most of the study area's water supply comes from wells. The two sources of water supplied
to distribution systems in Ellerbe (Richmond County) and Belle Acres Subdivision (Emery, Montgomery
County) are on the Pee Dee River, west of Rockingham and Mt. Gilead, respectively. Hazardous spills
in the study area will have no impact on these water supplies.
Montgomery and Richmond County Emergency Management response teams consist of
volunteer fire department and emergency medical system personnel. They respond to all reported
hazardous material spills, but are limited to handling only fuel, asphalt, and hydrocarbons. For other dry
and liquid chemical spills, their response would be to effect area isolation and containment. The North
Carolina Division of Emergency Management would be contacted for all chemical spills and for any spill
in excess of 25 gallons.
3.6.3 Floodways and Flood lp ains
Exhibit 3.6-1 shows regulatory floodplain boundaries for creeks within the study area.
Delineated floodplain boundaries were taken from maps developed according to the requirements of the
Federal Emergency Management Agency (FEMA). FEMA usually specifies that floodplain delineation
is required for channels draining approximately one square mile or greater, however policy regarding
where to end designation of regulated floodplain boundaries can vary depending upon the degree of
development in the subject area. Consequently, Exhibit 3.6-1 does not necessarily show all areas in the
study area subject to periodic inundation of significant overbank area.
All delineated floodplain areas shown in Exhibit 3.6-1 are designated Zone A by FEMA. The
Zone A designation denotes the 100-year floodplain area as estimated by approximate methods. In other
words, no detailed hydrologic/hydraulic analyses were performed to establish base flood elevations or
flood hazard factors along these drainageways. Though approximate, Zone A areas have the same legal
requirements as Regulatory Floodways based upon formal hydraulic studies.
Creeks with designated 100-year floodplains within the project area include Little Mountain,
Jobs, Big Mountain, Silver and Naked.
3.6.4 Hydrology and Drainage
Surface drainage patterns from the study area are presented in Exhibit 3.6-1. Generally,
stream channels in the area are well-defined, intermittent with respect to flow, and often crossed by
existing roadways.
The pro' crams primarily westward toward Big and Little Mountain creeks, which
are tributaries t the Pee Dee Riv ' . Depending upon the alternative selected, some portion of the
project site area m am to the east into Drowning Creek and its tributaries, Naked Creek and Rocky
3-31
Ford Branch. These waters ultimately join the Pee Dee River about 90 miles downstream of the project
site in South Carolina.
. The approximate length of road draining westward toward the Pee Dee River and eastward
to Drowning Creek for each alignment is summarized below.
Total Approximate Approximate
Number of Length of Roadway Length of Roadway
Drainageway Draining Westward Draining Eastward
Crossings to Pee Dee River to Drowning Creek
Alignment Each miles miles
Middle 34 15.1 0.0
Western 31 15.2 0.0
Eastern 31 5.2 10.6
East Alternate 36 6.6 9.6
Naked Creek and Rocky Ford Branch (tributaries of Drowning Creek) are classified Class
WS-III-ORW (Outstanding Resource Water). The ORW classification applies to waters representing the
upper tier of the EPA's "antidegradation policy". Once designated as an ORW watershed, no new treated
wastewater discharges or expansions of existing discharges will be permitted in the basin and stormwater
controls will be required for all development activities in which more than one contiguous acre of land
is disturbed. Specific requirements is presented in Rule 0.0201(d)(2)(A) and (B) of 15 NCAC 213.0201.
More detail on stormwater controls are provided in Section 3.6.2.1.
The Eastern Alignment provides the greatest length of roadway normally draining to the
Naked Creek/ Rocky Ford Branch watershed: 5.0 miles. The East Alternate Alignment provides for 4.0
miles of roadway draining to Naked Creek/ Rocky Ford Branch. The Middle and Western alignments
are not located in the Naked Creek/ Rocky Ford Branch watershed.
Notably, the alignments within the ORW watershed are situated over much of their lengths
very near the natural ridgeline (Exhibit 3.6-1). At the north end of the affected watershed, the distance
from the project Build Alternatives to Naked Creek is approximately one mile, with a difference in
elevation of 100-ft. At the south end of the affected watershed near SR-1459, the distance to Naked
Creek is approximately 3-1/2 miles, with a difference in elevation of 200-ft. Near the ridgeline, slopes
are flat to gradual and the alignments are in the vicinity of or cross the headwaters of 8 tributary streams
feeding Naked Creek. Numerous impoundments (farm ponds) are located downstream of the alignments
along the margins of the ridge top. Below these impoundments, stream gradients increase rapidly. The
existence of the numerous, small headwaters, shallow gradients, and impoundments downstream of the
alignments provides filter-settling potential for sediment and pollutant loadings, and hazardous material
spills from the new roadway prior to reaching the waters of Naked Creek itself.
3-33
The residential community surrounding Rankin Lake would be affected most directly by
hazardous spills from the Middle Build Alternative, and less severely by the No-Build Alternative, both
of which are located in the Little Mountain Creek drainage basin upstream of the lake (see Exhibit 3.6-1).
Rankin Lake is not a drinking water source but does provide recreation in the form of fishing and boating
for residents. The Western, East and East Alternate routes each have short sections of alignment along
the headwaters of streams draining towards Rankin Lake.
Montgomery and Richmond County Emergency Management response teams consist of
volunteer fire department and emergency medical system personnel. They respond to all reported
hazardous material spills, but are limited to handling only fuel, asphalt, and hydrocarbons. For other dry
and liquid chemical spills, their response would be to effect area isolation and containment. The North
Carolina Division of Emergency Management would be contacted for all chemical spills and for any spill
in excess of 25 gallons.
4.6.2.4 Water Supply - The town of Ellerbe and the Belle Acres subdivision are the only
communities within the study area with water distribution systems. Ellerbe's water comes from the Pee
Dee River, west of Rockingham, well outside of the study area and Belle Acres is served by the town of
Candor with a source from the Pee Dee River west of Mt. Gilead, well outside the study area. The rest
of the study area is served by local wells. None of the study alternatives would impact these municipal
drinking water supplies.
4.6.2.5 Outstanding Resource Waters - The Naked Creek and Rocky Ford Branch watersheds,
located east of existing US220 and north of SR 1459 are designated WS-III Outstanding Resource Waters
(ORW). The ORW classification applies to waters representing the upper tier of the EPA's
"antidegradation policy". Once designated as an ORW watershed, no new treated wastewater discharges
or expansions of existing discharges will be permitted in the basin and stormwater controls will be
required for all development activities in which more than one contiguous acre of land is disturbed.
Specific requirements are presented in Rule 0.0201(d)(2)(A) and (B) of 15 NCAC 213.0201 for any land-
disturbing activities within 1 mile of the ORW stream or its direct tributaries (a High Quality Water with
special ecological, state, national, or recreational significance) that result in the exposure of at least 1 acre
of contiguous lands to erosion. Sedimentation control provisions,. designed to protect this resource,
include:
1. Limitation to uncovering more than 20 contiguous acres at any time
2. Sediment basins to capture 700 of all particles 40 microns in diameter, to meet 2-
year storm criteria
3. Conformance to all other measures to meet 25-year storm criteria
4. All ditches must have 2:1 or flatter side slopes
5. Ground cover must be reestablished within 15 working days (or 60 calendar days) for
any phase of work reaching completion, or for which work will be suspended
4-24
In addition to the No-Build option (existing US 220), the Eastern and. East Alternate
alignments are located along the ridgeline, approximately one mile upslope from Naked Creek at the
north end of the project and 3-1/2 miles upslope at SR-1459. Approximately eight tributaries to Naked
Creek have headwaters along these project alternatives. Shallow slopes and numerous impoundments
(farm ponds) along these streams will assist in minimizing sediment, nonpoint source pollutants and
hazardous waste spills from directly entering and affecting Naked Creek. Below the impoundments, stream
gradient rapidly increases to between 1 and 1-1/2 percent. Storm runoff in the steeper portions of these
tributaries is likely to exceed 5 feet per second, with travel times to Naked Creek of less than one hour.
One major tributary of Naked Creek just north NC 73 is crossed by both the Eastern and
East Alternate Alignments below it's impoundments in an area of steep gradient. All other tributary
crossings north of Rocky Ford Branch are made above the impoundments in areas of minimal slope.
Rocky Ford Branch has headwaters just south of Plain View, between SR 1459 and NC 73. The Eastern
and East Alternate alignments cross directly over the main headwater of this ORW stream, at the
upstream end of a large pond. Existing US 220 has no drainage into Rocky Ford Branch.
Channel erosion, with associated increases in turbidity and sedimentation, is of concern along
the Eastern and East Alternate alignments due to passage through the Naked Creek and Rocky Ford
Branch drainages. Due to the location of the subject alternatives along the ridgeline, the shallow slopes
along the ridge, the many small streams and drainage areas associated with the tributary headwaters, and
the numerous farm ponds which serve to slow the flow and trap sediment, adverse impact to the ORW
waters of Naked Creek and Rocky Ford Branch due to construction related erosion is expected to be
minimal with the exception of the one tributary crossing just north of NC 73. Since the ORW watershed
crossings of the Eastern and East Alternate Alignments are all within one mile of direct tributaries to
Naked Creek and Rocky Ford Branch, the special stormwater control measures described above will be
required if construction is begun. Extra vigilance in the implementation of the stormwater and erosion
control practices will be needed to adequately protect these sensitive waters.
4.6.3 Floodplains and Floodways
Increased impervious cover associated with highway construction will have a minimal impact
with respect to increasing runoff volumes and peak flow rates in the overall study area. Large changes
may be experienced within small drainage areas crossed by the alignment where the roadway storm
drainage system discharges into existing drainages. Due to the rural nature of the project area, these local
changes in runoff will not adversely impact property downstream of the road.
Construction of new roadway embankment across drainages brings the potential for increases
in floodplain area and property damage upstream of the roadway. To ensure that floodwater property
damages due to roadway construction are minimized, drainage structures are designed with upstream
(headwater) elevation in mind. All bridges and culverts on this project will be designed and constructed
in accordance with Federal Highway Administration (FHWA) floodplain impact requirements. FHWA
requires the minimization of upstream headwater elevations due to the construction of roadway across
4-25
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SANDHILLS
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US 220 EIS; R-2231
EXHIBIT 4.2-1
EASTERN ALIGNMENT/SANDHILLS
GAMELANDS MAP
v ?
LEGEND
1200-ft CORRIDOR WIDTH
- - SANDHILLS GAMELANDS BOUNDARY
3.2.3 Recreation
The major recreation resources within Montgomery and Richmond counties include
dispersed recreation opportunities in the Uwharrie National Forest in northern Montgomery County,
hunting and field trial opportunities within the Sandhills, Uwharrie and Richmond gamelands, and fishing
opportunities at McKinney Lake, Blewett Falls Lake and along the Pee Dee River.
Recreational areas actually falling within the vicinity of the proposed project, however,
consist of a small state picnic area located at the intersection of the existing US 220 and NC 73; the Lions'
Club recreation facility, located off SR 1452 and used primarily for bi-monthly meetings and seasonal
gatherings such as group picnics (Comer, 1990); and western portions of the Sandhills Gamelands, which
are along the eastern edge of the study area in Richmond County, near the area known as McLeod. The
Sandhills Gamelands, totaling over 60,000 acres, are managed by the NC Wildlife Resources Commission
for wildlife-oriented recreation. The western portions of the Gamelands near the project area are also
used for passive military maneuvers by the U.S. Army at Fort Bragg. A small detached parcel is located
west of SR 1453 and north of SR 1458, another detached parcel on the east side of SR 1453 at SR 1457,
and the main body of the properties east of SR 1453 at SR 1458. -
Several area landowners also lease their land for hunting purposes.
3.2.4 Schools
Ellerbe and Norman students attend Mineral Springs Kindergarten, Ellerbe Primary, and
Ellerbe Junior High schools. From grades 10 through 12, all students attend Richmond Senior High
School. The Richmond Community College is located in the City of Rockingham and offers a two-year
program. The Gardner Webb College of Boiling Springs, NC, offers a four-year extension program
through the Richmond Community College.
3.3 CULTURAL RESOURCES
3.3.1 Cultural Setting
3.3.1.1 Prehistoric Period - The four proposed alignments cross an area characterized by a relatively
high density of archaeological sites spanning a lengthy prehistoric period. The major prehistoric stages
recognized in the cultural sequence of the North Carolina Piedmont are Paleo-Indian (ca. 10,000 to 8000
years B.C.), Archaic (8000 to 500 B.C.) and Woodland (500 B.C. to A.D. 1500). Sites from all of these
cultural stages occur in the combined Montgomery/Richmond county area. With the exception of a
Mississippian intrusion into western Montgomery County during the fourteenth and fifteenth centuries
A.D., Woodland subsistence patterns persisted in the region until historic times. The Historic period
began around A.D. 1625 with the advent of European traders from coastal areas.
Paleo-Indian - The Paleo-Indian stage coincided with the end of the Wisconsin glaciation.
Although the ice sheets did not extend into the southeast, the climate was significantly cooler than today.
As the climate began to warm around 10,000 B.C., the spruce/pine boreal forests covering much of North
Carolina were gradually replaced by temperate deciduous forests, and Pleistocene megafauna rapidly
3-13
r
offered or provided for each displacee within a reasonable period of time prior to displacement.
Relocation payment received would not be considered as income for the purposes of the Internal Revenue
Code of 1954 or for the purposes of determining eligibility or the extent of eligibility of any person for
assistance under the Social Security Act or any other Federal law.
Last Resort Housing is a program used when comparable replacement housing is not
available or when it is unavailable within the displacee's financial means, and the replacement payment
exceeds the Federal and state legal limitation. The purpose of the program is to allow broad latitudes
in methods of implementation by the state so that decent, safe, and sanitary replacement housing can be
provided.
Low-income relocations for each alternative ($0-15k income level from Appendix C) are:
Western - 5, Middle - 7, Eastern - 12, and East Alternate - 10. Due to the apparent low value of many
of the mobile homes, last resort housing would undoubtedly be necessary.
4.2.3 Considerations Relating to Pedestrians and Bicycles
No existing or proposed pedestrian or bicycle facilities would be directly impacted by any
of the four alternative alignments. An approved bike route, SR 1524, which is part of the Sandhills Sector
Bicycling Highway, is located at the northern end of the study area. All alternative alignments propose
to bridge SR 1524 and not interchange traffic.
It would be expected that the proposed action would have a beneficial impact on public
safety associated with pedestrian and bicycle circulation within the communities of Ellerbe and Norman.
Because of the anticipated control of access associated with all of the proposed alignments, no adverse
pedestrian- or bicycle-related impacts would be expected for rural residents.
4.2.4 Parks and Recreation
In the maps accompanying the project scoping letter, showing 700-ft wide corridors, and
Newsletter #2 showing 1200-ft wide corridors, alternative E7 shows incursions by the study corridor
boundaries on properties managed as part of the Sandhills Gamelands. These are lands managed by the
North Carolina Wildlife Resources Commission for wildlife-oriented recreation. The Corps of Engineers,
in a scoping response, recommended against an Eastern Alignment due to impacts on the Sandhills
Gamelands.
During the selection of an Eastern Alignment for detailed analysis, efforts were made to
specifically avoid the taking of any Gamelands property. As a result of this effort, alternative E7 was
modified in the vicinity of the Gamelands. This modified route was chosen as a reasonable and feasible
alternative and is the basis for the Eastern Alignment discussed in this DEIS.
Exhibit 4.2-1 is an enlarged map of the area showing the three Gamelands properties in the
vicinity, and the 1200-ft wide Eastern Alignment corridor. Within the corridor, functional designs for a
roadway, with an approximate 350-ft right-of-way, have been prepared that avoid the taking of any
4-8
i
properties managed as a part of the Sandhills Gamelands. This design includes the realignment of a two-
mile section of SR 1453 to the west of the new roadway.
Though the exact route through the Eastern Alignment corridor would not be developed
until the preliminary/detailed design phases of this roadway project, if chosen as the preferred alternative,
the final designs for this section would miss all Sandhills Gamelands properties and avoid direct impacts
on said lands. The fenced right-of-way afforded by the full control of access design will provide safety
to hunters passing between separate gamelands properties and vehicles passing through the area.
The Lions Club facility would not be impacted by the proposed Eastern Alignment. The
closest point of the proposed alignment is over 1000 ft from the southeast corner of the property and
intervening foliage makes for a visual barrier. Noise levels can be expected to increase approximately five
decibels over the existing levels. The five-decibel increase would not be considered as an impact (See
Section 4.6.7, Noise).
4.2.5 Schools
The proposed action would not impact any existing public or private schools within the study
area. Beneficial impacts would result from increased public safety along the entire length of the existing
US 220, with school buses experiencing far fewer conflicts with truck and auto traffic.
4.2.6 Section 4(0 and Section 6(0 Lands
Based on land use information assembled for this study, no known existing publicly owned
parks, recreation areas, refuges, or historic sites are located within the study area that would be directly
impacted by any of the proposed US 220 relocation alternatives. Therefore, provisions of Section 4(f) of
the Department of Transportation Act and Section 6(f) of the Land and Water Conservation Fund Act
of 1965 are not applicable at this time.
4.3 CULTURAL RESOURCES
4.3.1 Archaeoloev
In accordance with 36CFR, Part 800.4, an intensive archaeological survey was conducted
along the alternate alignments. As a result of this survey, 57 archaeological sites were found to lie
partially or totally within the area of potential effect along the proposed new alignments, including
proposed interchanges, grade separations and detour roads, considered in this DEIS. Twelve of the
57 sites were found outside of the alignments during the Phase I survey. These sites are listed in
Table 4.3-1 and will not be affected by the proposed alignments.
A listing by alignment of potentially affected archaeological sites is included in Table 4.3-2.
The locations of these sites with respect to the proposed alignments are illustrated in Exhibit 4.3-1.
Table 4.3-2 summarizes the type and temporal affiliation of each site. The table also presents
recommendations regarding potential for NRHP eligibility and additional work required in order to assess
NRHP eligibility. SHPO concurrence on these recommendations was given in January and March 1991
4-10

bottoms, adherence to cleanup procedures and minimizing fill to streams, intermittent drainages and
wetlands.
4.7.4 Impacts to Protected Species
4.7.4.1 Flora - Potential impacts of the proposed project to rare, threatened or endangered plant
species is dependent on the occurrence and abundance of these species within the study area. Although
no occurrences of rare species have been recorded in the study area, that possibility exists for two species:
nestronia and Carolina triodia. As discussed in Section 3.7.4.1, nestronia is listed by the FWS as a
Category 2 species and by the State as Threatened, while Carolina triodia is a State candidate for listing
as threatened or endangered status. Each of these rare plant species is associated with woodland areas;
nestronia primarily occurs within the Piedmont and Carolina triodia chiefly occurs within the inner Coastal
Plain (Radford et al., 1973). Potential for occurrence within the study area of the other five rare plant
species described in Section 3.7.4 is extremely low. Suitable habitat for these other species is associated
either with basic soils or with pine pocosins. Within the study area, the soils are predominantly strongly
acidic and pine pocosins were not observed within the corridor alignments.
As previously mentioned in Section 3.7.4.1, the Federally-listed endangered Michaux's poison-
sumac is not expected to occur in the study area due to its preference for basic soils which do not occur
in the study area. Suitable habitat for the Federally-listed endangered rough-leaved loosestrife includes
pine pocosins and ectones with savannahs. This species is often associated with pond pine woodlands (i.e.
pine pocosins) and longleaf pine savannahs in a rich, mesic transition zone. Appropriate potential habitat
was not observed within the corridor alignments during field investigations, thus potential for occurrence
is considered to be low.
Suitable habitat exists within the study area for nestronia, listed as a North Carolina Threatened
and Federal C2 species and for Carolina triodia, a State candidate for listing as Endangered or
Threatened. No occurrences of these plants have been recorded in the study area, and none were
identified during field surveys for this project. In order to determine whether populations of nestronia
and Carolina triodia occur in the alternative corridors, it would be necessary to conduct field surveys
during the time of flowering to allow for their positive identification. The alignments which cross the
greatest amount of woodlands (excluding pine plantations) are the Western and Middle alignments, thus
these corridor alignments would have the greatest possibility of occurrence of these two species. As no
legal- protection is offered this plant with respect to highway construction, no further fieldwork or
biological assessment for these two species is planned.
No unique natural plant communities have been recorded within the study area by NCNHP and,
although there is some potential for such communities to exist, it is unlikely that these would occur to any
large extent due to the highly managed nature of the area. Therefore, it is improbable that any
unrecorded, unique natural communities will be impacted by the proposed US 220 project.
4-51

A No-Build alternative is not expected to affect any threatened or endangered plant species
within the study area. There would be continued disturbance to woodlands from agricultural and logging
activities.
4.7.4.2 Fauna - The red-cockaded woodpecker is the only Federally listed endangered species known
to occur near the study area. As mentioned in Section 3.7.4, red-cockaded woodpeckers nest in mature
stands of pines with an open understory. The nearest red-cockaded woodpecker colony on record with
the FWS is an experimental one, approximately one mile east of SR 1453 and south of SR 1459 (Carter,
1989). The experimental colony is approximately one mile from the proposed Eastern or East Alternate
alignment and no impacts to the colony or its foraging habitat are expected. Acceptable boundaries of
individual populations of red-cockaded woodpeckers are felt to be 18 miles (so long as there is no
discontinuity of habitat larger than 5 miles ) (SSN, 1990) and individual birds have been known to disperse
over 50 miles (Moser, 1988). However, normal foraging habitat for individual colonies is within .6 mile
of the colony, although individual birds have been observed to forage slightly farther (.7 mile) away from
the colony (Hooper, 1986).
The existence of suitable nesting and/or foraging habitat along the study corridors was
determined through interpretation of aerial photos for appropriate species composition. Subsequent
personal visits were conducted to determine species composition and age of trees within each potential
patch of forest. The composition of most pinelands in the study area has too much hardwood mid-story
growth for good red-cockaded woodpecker habitat. Nine potential woodpecker habitat patches within the
study corridors were visited after being identified from aerial photography. After appropriate examination,
all but one were dismissed due to species composition or age.
The patch with the best species composition is provided further description. It is within the
Sandhills Gamelands property between SR 1453, SR 1459 and SR 1458. The age of this stand was suspect
for being too young, and the basal area was high, but it is continuous with foraging habitat to the
previously described experimental colony one-mile distant. An examination of the area did not reveal any
active or inactive colonies in the stand or within a half mile. It should be noted that this stand of trees,
though within the 1200-ft wide Eastern and East Alternate study corridors, will not be affected by
construction of the project due to it's location in the Sandhills Gamelands. The alignment will be kept
west of SR 1453 at this location and no property from the Gamelands will be taken for the project,
therefor no trees from this stand will be removed.
In conclusion, no impacts are expected to red-cockaded woodpeckers with any of the project
alternatives due to the lack of suitable nesting and foraging habitat in all but the one location described
above. For the one stand of potential foraging habitat along the Eastern and East Alternate corridors,
no trees will be taken by the project. Further, as this potential foraging habitat and experimental colony
(one-mile distant) are both on the east side of the corridor, no disruption in the movement of foraging
birds is likely to occur.
4-52

As discussed in Section 3.7.4, no habitat suitable for bald eagle nesting occur,proximate to the
study area. Migrant bald eagles may occur in the study area, but are not expected to be impacted by the
proposed project.
Also discussed in Section 3.7.4, the eastern cougar is extremely rare in North Carolina with the
most recent occurrence in Tyrell County in 1987. In addition to its extreme rarity, the eastern cougar is
known to show a preference for remote, little disturbed areas and avoid areas of possible human contact
(Van Dyke, 1986). The existing residential and agricultural disturbance in the area surrounding the
existing US 220 corridor combined with the species rarity make the occurrence of the species in the
project area unlikely.
The short-nosed sturgeon (Acipenser hng ' is Federally listed as endangered and has
been reported in Richmond County, in or ne the Pee Dee Rive,. This species occurs in fresh, estuarine
and salt water; however, it is usually found in tal waters. D Ito the upland nature of the terrain,
this species is not expected to occur in the headwater and intermittent streams which characterize the
study area. With the lack of suitable habitat, no impact to this species is expected.
The Bachman's sparrow, listed as a Category 2 species by the FWS, also prefers open pine
stands. Any efforts to lessen the impact to pine forests would also be beneficial for this species.
Naked Creek and its tributaries shelter the Category 2 sandhills chub and pinewoods darter fish
species listed in Section 3.7.4. The nearest location of either of these species recorded in the NCNHP
data banks is for the sandhills chub. The site location is in Naked Creek along the
Montgomery/Richmond county line, approximately 1.5 miles northeast of Norman (NCNHP, 1989).
There is also a recorded location of the pinewoods darter further downstream in Naked Creek, south of
SR 1458. The sandhills chub occupies medium-sized, slow-flowing creeks with sand and gravel bottoms
and sparse vegetation. The pinewoods darter is moderately common in shallow streams with moderate
current, usually over gravel riffles (Lee et al., 1980). These two species are only found in the Lumber
River drainage system and are candidates for Federal listing due to their specialized range. Special care
taken in the design and implementation of all creek-crossing structures, as discussed in Section 4.7.3,
should make impacts to these species negligible.
4.7.5 Prime and Important Farmlands
The potential impacts to farmland from this project are being evaluated according to the
guidelines set forth in the Farmland Protection Policy Act (FPPA). For purposes of the Act, "farmland"
is either "prime farmland," "unique farmland," or other farmland "that is of statewide or local importance."
All three of these types of "farmland" are defined by section 1540(c)(1) of the Act. Further, this
evaluation provides for the ranking of project alternatives according to their impact on prime or important
farmlands.
In consultation with SCS representatives in Montgomery County, it has been determined that
no prime or unique farmlands are located within that part of the county that would be impacted by any
4-53
COORDINATION AND PUBLIC INVOLVEMENT
US 220 EMERY TO ELLERBE; R-2231
MONTGOMERY & RICHMOND COUNTIES
FEDERAL FEIS
November 18, 1993

ESPEY, HUSTON & ASSOCIATES, INC.
February 7, 1992
MEMORANDUM 16
FROM: - Roy Highberg, Espey, Huston and Associates
TO: Cindy Sharer; NCDOT Planning and Environmental
SUBJECT: US 220 (R-2231)
Montgomery and Richmond Counties
Minutes from post-DEIS Agency Meetings
Meeting #1
DATE: January 06, 1992
TIME: 2:00pm
PLACE: NCDOT Raleigh; Room 470
PARTICIPANTS:
Frank Vick
Gail Grimes
Cindy Sharer
Susan Corda
Janet Shipley
John Maddox
Sue Flowers
Steven Kroeger
Brent Dather
Susan Mooney
John Dorney
Dennis Stewart
Steve Pozzanghera
David Foster
Tracy Hill
Roy Highberg
Cliff Ladd
NCDOT Planning and Environmental
NCDOT Planning and Environmental
NCDOT Planning and Environmental
NCDOT Planning and Environmental
NCDOT Planning and Environmental
NCDOT Roadway Design
NCDOT Roadway Design
NCDOT
FHWA
FHWA
NC Div. Environmental Management
NC Wildlife Resources Commission
NC Wildlife Resources Commission
NC Dept Environment, Health and Natural Resources
EHA
EHA
EHA
Meeting #2
DATE: January 29, 1992
TIME: 10:30am
PLACE: NCDOT Raleigh
PARTICIPANTS: Gail Grimes
Cindy Sharer
Brent Dather
Steve Chapin
Mike Crocker
Roy Highberg
NCDOT Planning and Environmental
NCDOT Planning and Environmental
FHWA
US Army Corps of Engineers
US Fish and Wildlife
EHA
ESPEY, HUSTON & ASSOCIATES, INC.
1. See attached agenda and exhibits 2.42 (Preliminary Route Alternatives) and 3.7-2 (Potential Wetland
Sites) from the Draft EIS.
2. EHA (Roy Highberg) presented an overview of the alternative corridors described in the DEIS using the
800-scale Public Hearing Map. Acetate overlays on the map highlighted farmland, developed areas, and
vegetation communities in the area of the corridors. The selection of the reasonable and feasible corridors
in October 1989 was discussed.
3. EHA (Cliff Ladd) described the procedures utilized for the biologic analysis reported in the DEIS.
(Meeting #1).
4. Specific areas of concern were discussed. The highlights are listed below:
Outstanding Resource Waters (ORW). John Dorney (DEM) felt that only two specific stream
crossings were of concern along the eastern corridor. One is located just northeast of Norman (WE9) where
the tributary stream crossing was well below the ridge and water velocities are expected to be high. Stringent
adherence to Best Management Practices will be neccessary. The second crossing is just southeast of Plain
View (WE7) where the Rocky Ford Branch crossing involves both a large wetland area and a farm pond. It
would be much better to shift the alignment slightly east and take out the farm pond than to impact the
wetlands above the pond which run parallel to the project at that point. All of the rest of the eastern
corridor within the ORW watershed is located along the ridgetop where little construction erosion is
anticipated.
Two potential hazardous materials locations along the Eastern Corridor should receive additional
study if this corridor is to be selected as the preferred alternative. One is near the Dewitt Trucking facility
(the location 50-gallon drums containing unidentified substances and a potentially polluting washrack draining
into Rocky Ford Branch). The other is an unregulated landfill site located between Plain View and Norman,
within the east edge of the eastern corridor.
The criteria presented in the DEIS for protected species habitat received critical comment.
Red Cockaded Woodpecker (RCW0. Concern was expressed with respect to the DEIS describing/
dismissing potential foraging habitat on the basis of criteria which cites the presence of hardwood
understory. RCW foraging habitat can include midstory hardwood. Thirty year old pine could be
foraging habitat for nests within 1/2 mile. Sixty year old pine is required for nesting habitat. Mike
Crocker will provide a copy of the Guidelines for Preparation of Biologic Assessment for RCW by
Gary Henry, S.E. Region, FWS.
Protected plant species. Concern was expressed with respect to the use of broad soil preferences to
define habitat. Too little is known about the target species to make such sweeping statements.
Concern was expressed over the lack of seasonal field survey for individual flowering plants.
Michaux's Sumac was mentioned as being found along roadway right of way. There is no known
habitat preference for Michaux's Sumac. One must walk along and look for it.
ESPEY, HUSTON & ASSOCIATES, INC.
There will need to be further seasonal fieldwork along the preferred alternative and clarification/rework of
the protected species section to address the habitat concerns prior to the FEIS.
Animal movement in the vicinity of, and between outlying parcels of the Sandhills Gamelands was a
concern with respect to the Eastern and East Alt. Alternatives. Because these areas are "protected" due to
their public ownership/management, they are considered more sensitive than habitat on privately owned land
which is not protected from development over the long term.
Habitat fragmentation resulting from cutting across currently roadless areas received a great deal of
attention. The Middle Corridor fragments a large track along Little Mountain Creek north of Rankin Lake.
Because of more extensive farming, the Eastern Corridor causes less severe fragmentation. Mitigation
options for fragmentation of large tracts can be obtained through bridges rather than box culverts at stream
crossings. These bridges should be one bay longer than the stream channel on one side to allow the passage
of land animals. Culverts don't offer the same opportunity for passage due to their resemblance to dark
caves. Many species won't enter them to cross under the highway. The proposal was made to state a
preference in the FEIS for bridges rather than culverts in specific locations for the purpose of riparian
movement.
Hardwood and mixed pine-hardwood forest areas support a more diverse wildlife population than
pine forest. The Middle Corridor impacts more hardwood/mixed forest than the Eastern Corridor.
Wetland impacts cannot be avoided by the project due to their location along streams and drainages
running perpendicular to the north-south alignment of the project. Efforts to minimize the impact to
wetlands should first involve realignment to minimize impacts where feasible. The following locations were
specifically identified for design changes on the preferred alternative.
WM4.... The fill from the current functional design extends to the edge of the eastern arm of Rankin
Lake. The alignment should be shifted east to lessen the impact on wetlands at the entrance of the
tributary stream and the lake.
WM6 ... The Job's Creek crossing involves a large wetland area in a location that is already targeted
for a bridge for hydraulics reasons. Further lengthening of the bridge, a lowering of the profile so
that the same length of bridge will have lesser wetland impact, or an alignment shift up or
downstream to a narrower wetland area should be evaluated for minimization of impacts.
WM19 ... Look at an alignment shift to the east to get further away from the confluence of the
tributary streams and associated wetlands.
WC1 ... The current alignment runs along the tributary streams and includes their confluence. Look
at avoidance either to the west or the east. An alignment shift to the east may require the use of
back-to-back curves in the interchange with US-220A.
WE7 ... Shift the alignment either east (through farm pond) or west to avoid the linear wetland
parallel to the project.

ESPEY, HUSTON & ASSOCIATES, INC.
5. The Purpose and Need for a freeway on new location received extensive discussion at both meetings.
None of the agencies were happy with the dismissal of the two preliminary alignments (MOD and Improve
Existing [IE]) which utilize part or all of the current US220 alignment. The big question which will be raised
in the review of the FEIS is why a lesser facility (expressway) is not sufficient for the project. The MOD and
IE alternatives were not studied in detail beyond October 1989 because an expressway option was not
considered to be reasonable and feasible.
6. No clear preference was expressed by the State agencies for the preferred alternative. The Western
Corridor was clearly in disfavor. The FWS state biologist expressed concerns with the Eastern Alternatives
due to; ORW impacts, the WS-III water classification for Bell's Creek east of Ellerbe, and the proximity of
the Sandhills Gamelands. The general impression left by the agencies was that no alternative was preferred,
but the Middle Alternative was the lesser of the existing evils.
7. Dennis Stewart (WRC) asked to be involved in design review for culverts/bridges in the areas where
large tracts of habitat are fragmented. Mitigation through bridging is his goal where such incursions cannot
be avoided. Sensitivity towards habitat fragmentation in the early stages of project development prior to the
establishment of preliminary routes is needed. The agencies should meet and provide input-as early in the
process as possible so they can assist in the development of potential routes.
cc: file 12100-A1
Cindy Sharer; NCDOT P&E
Rob Reid; EHA Aus
Cliff Ladd; EHA Aus
Tom Stierhoff; EHA Wbg
RSH
TLH '
(wp51 1000128a.min)
4.
US 220 from Emery to Ellerbe
TIP No. R-2231
AGENCY MEETING - JANUARY 29, 1992
AGENDA
I. INTRODUCTIONS
II. BACKGROUND
1. Project Scope
2. Purpose and Need for Project
3. Reasonable and Feasible Alternatives
III. IMPACTS
1. Habitat/ Threatened and Endangered Species Survey
Methodology and Findings
2. Presentation of Land Use/ Habitat/ Wetlands Mapping
3. Comparison of Alternatives
a. Habitat
b. Wetlands
c. Sandhills Gamelands
d. Outstanding Resource Waters
e. Managed forest land
f. Agricultural fields
g. Relocations
h. Hazardous waste sites
IV. AGENCY COMMENTS AND DISCUSSION
1. Discussion
2. Potential Mitigation
3. Discussion of Alternative Preferred by Agencies
4. Issues to be Addressed in Final Environmental Impact
Statement
V. CONCLUSION
?? ??frs
Fes,
US 220 EIS ... Montgomery and Richmond Counties, R-2231
WETLANDS ... Preliminary Design Impacts Along the Preferred Corridor
Subsequent to the selection of the preferred alternative, wetlands delineations were conducted in 1994 and 1995 within
the 1,200-foot wide corridor in accordance with the procedures described in the 1987 Corps of Engineers' Wetland
Delineation Manual (TR Y-87-1). The wetlands flagging was informally coordinated with the U. S. Army Corps of
Engineers (USCOE) during a field visit on January 19, 1995, and extent of the delineated wetlands were surveyed by
NCDOT using Global Positioning System techniques. The Wetlands Delineation Report (dated March 1995) is available
for reference. The development of the current Preliminary Designs for the preferred alternative have been laid out to
avoid, or minimize to the extent possible, the jurisdictional wetlands delineated within the preferred corridor.
In general, three vegetated wetland community types and two types of waters of the U.S. were identified within the
corridor. The wetland types are forested wetlands, marshes and wet meadows, and regenerative shrub wetlands.
Streams and open-water areas, which were commonly represented by stock ponds, constituted the waters of the U.S.
Forested wetlands were the most frequently encountered wetland areas. The remaining community types are of
relatively limited aerial extent.
Table 4.7-2 in the DEIS identifies the specific wetlands impacted by all project alternatives based upon the 1991
information and functional designs. Wetland impacts were estimated at 21.3 acres for the Eastern Alternative
(subsequently selected as preferred).
In 1994 and 1995, thirty-three wetland sites were delineated within the 1,200 foot wide preferred corridor and southern
alternate, identified as sites 'A' through 'GG', as shown in Exhibit 4-1 and Table 4-1. The total areal extent of wetlands
within the 1,200-ft wide corridor is approximately 272 acres, with approximately 34 miles of perimeter. 'Waters of the
U.S.' (ponds and streams) were not included in this delineations or the subsequent analyses.
After alignment adjustments during development of the preliminary designs, the potential impacts to the jurisdictional
wetlands total 25.76 acres. Table 4-2 lists the impacted wetlands along the preferred alternative. These are based upon
the 1994-1995 wetlands delineations and the probable impacts from the current preliminary designs. Impacts were
measured using the standard median (70 feet), with no special embankment slopes in the vicinity of the wetlands. The
standard design template varied the foreslope from 6:1 to 2:1 to tie in with existing ground within 9 meters of the hinge
point. 2:1 slopes were used if the tie-in point exceeds the 9-meter distance. Impacted wetland sites total 30, ranging
in size from 0.04 to 2.14 acres. Eleven of the impacted areas identified were in excess of one acre, with one of these
05-16-95 ... coehnd3x.att
exceeding two acres. All of the impacted areas are located in "headwater" tributary areas or are isolated and could,
therefore, qualify under the Nationwide Permit Program, as would the majority of stream crossings.
The preliminary design alignment has avoided and minimized wetland impacts to the extent that approximately 26 acres
of wetlands are impacted among thirty discrete impact sites. Approximately 10-percent of the wetlands within the
preferred corridor are impacted by the current preliminary design. This in spite of the fact that the nominal 300-foot
wide footprint, plus interchange areas, make up more than 25-percent of the corridor width. More details on the results
of the wetlands effort are found in Wetlands Delineation Report, March 1995, (Appendix A of the FEIS).
All thirty of the impacted wetlands are of a size and location to meet the requirements for the Nationwide program.
Eleven sites may exceed one acre. Each of these, Site EE1 (1.63 acres), Site GG1 (1.59 acres), Site GG2 (1.77 acres),
Site Cb (1.71 acres), Site F (1.55 acres), Site G (1.07 acres), Site Gb (1.36 acres), Site H (1.04 acres), Site I (2.14 acres),
Site S (1.63 acres), and Site Wa (1.34 acres) would meet the headwater and size criteria for N:irionwide Permit #26, with
pre-discharge notification submitted to the COE. The total acreage of impacted wetlands is 5.76 acres. «itli 5.93 acres
among 19 sites qualifying under Nationwide #26 and 16.53 acres among eleven sites qualifying under Nationwide #26
with pre-discharge notification.
The wetland impacts resulting from the current preliminary designs exceed those estimated for the functional designs
by 4.46 acres, or 21-percent. This increase, despite the attempts to avoid and minimize impacts through alignment shifts
in the preliminary design, stems from the greater extent of the wetland sites as identified through the formal delineations
in 1994 and 1995. The increase in size of the wetlands within the preferred corridor is in large part associated with the
prevalence of hillside seep areas which were not previously recognized through the photo interpretation and field checks
used for the impact estimates in the Draft EIS. It is felt that a similar increase would have occurred in the limits of
wetlands within each of the other Reasonable and Feasible Alternative corridors, had they also been formally delineated.
05-16-95 ... coehnd3x.att 2
Table 4-2
US-220; WETLAND IMPACTS
05/16/95
Preliminary Drainage
Wetland Design Impact Area Basin Location Permit Wetland
Site Stationing Size Type
(ha) (acres) (acres)
PREFERRED ALTERNATIVE
CC 2+00/ Y-Line 0.1353 0.33 10 South Prong Tributary NW #26 PDN PSSB
EE1 9+00/ Y-Line 0.6598 1.63 20 South Prong Tributary NW #26 PDN PSSB
EE2 SB Off Ramp 0.2748 0.68 20 South Prong Tributary NW #26 PSSB
EE3 11+00 0.0991 0.24 10 South Prong Tributary NW #26 PSSB
EE4 NB On Ramp 0.0978 0.24 10 South Prong Tributary NW #26 PSSB
DD Y-Line 0.3194 0.79 10 South Prong Tributary NW #26 PSSB
FF 12+65 0.0782 0,19 10 South Prong Tributary NW #26 PFO1B
GG1 17+00 to 18+00 0.6416 1.59 600 South Prong Tributary NW #26 PDN PFO1B
GG2 20+00 0.7143 1.77 275 South Prong Tributary NW #26 PDN PFO1B
Ca 24+50 0.1860 0.46 40 South Prong Tributary NW #26 PFOIA
Cb 28+50 0.6905 1.71 40 South Prong Tributary NW #26 PDN PFOIA
D 36+00 0.3220 0.80 70 Bells Creek Tributary NW #26 PFO1B
E 46+80 0.0000 0.00 500 Bells Creek Tributary NW #26 PWMHh
F 58+00 0.6281 1.55 1210 Bells Creek Tributary NW #26 PDN PFOIA
G 75+60 0.4315 1.07 145 Bells Creek Tributary NW #26 PDN PF01B
Ga 80+20 0.0752 0.19 50 Bells Creek Tributary NW #26 PF01B
Gb 83+50 0.5495 1.36 50 Bells Creek Tributary NW #26 PDN PF01B
Gc 85+40 / Ramp 0.0752 0.19 50 Bells Creek Tributary NW #26 PFO1B
H 95+00 / Y-line 0.4210 1.04 35 Job's Creek Tributary NW #26 PDN PFOIB
I 97+00 to 100+00 0.8653 2.14 43 Job's Creek Tributary NW #26 PDN PFO1B
and Y-line
J 105+00 0.0000 0.00 28 Job's Creek Tributary NW #26 PF01B
K 118+50 0.0000 0.00 67 Job's Creek Tributary NW #26
L 120+80 0.0000 0.00 40 Job's Creek Tributary NW #26
M 122+60 0.0000 0.00 40 Job's Creek Tributary NW #26
N 64+00 0.0000 0.00 Bells Creek Tributary NW #26 PFOIA
O 126+00 0.0000 0.00 25 Rocky Ford Branch Tributary NW #26 PEMHxh
P 126+00 0.0000 0.00 30 Rocky Ford Branch Tributary NW #26 PFOIB
Za 130+80 0.0000 0.00 30 Rocky Ford Branch Tributary NW #26 PFO1B
Z 133+00 to 139+0 0.0000 0.00 5 Rocky Ford Branch Tributary NW #26 PFOIB
Q 163+60 0.3334 0.82 g5 Naked Creek Tributary NW #26 PFO1B
R 167+40 /Ramp 0.0165 0.04 0 Naked Creek Tributary NW #26 PFO1B
Sa 179+00 0.2604 0.64 ' 30 Naked Creek Tributary
NW #26
PFOIA
S 181+30 0.6582 1.63 '\ u 435 Naked Creek Tributary NW #26 PDN PF01B
AA 200+00 0.0000 0.00 20 Naked Creek Tributary NW #26
T 226+00 0.0000 0.00 65 ed Creek Tributary NW #26
U 235+00 / Ramps 0.2608 0.64 90 Big Mountain Creek Tributary NW #26 PFOIA
Va 240+00 0.0000 0.00 20 Big Mountain Creek Tributary NW #26 PFO1B
Vb 244+00 0.1321 0.33 30 Big Mountain Creek Tributary NW #26 PFO1B
V 245+40 0.3063 0.76 265 Big Mountain Creek Tributary NW #26 PFO1B
X 247+00 0.0000 0.00 40 Big Mountain Creek Tributary NW #26 PSSB
W 249+00 0.2329 0.58 20 Big Mountain Creek Tributary NW #26 PFO1B
Wa 251+20 0.5431 1.34 100 Big Mountain Creek Tributary NW #26 PDN PFOIB
Y 258+60 0.3170 0.78 150 Big Mountain Creek Tributary NW #26 PFO1B
Ya 261+80 0.1004 0.25 40 Big Mountain Creek Tributary NW #26 PFOIA
TOTALS 10.4257 25.76 PREFERRED ALTERNATIVE
ha acres
Individual Permit may be required below headwaters (5 sq mi or 3,200 acres)
Nationwide Permit for headwater wetland impacts of less than 1 acre
Nationwide Permit with Pre-Discharge Notification for headwater wetland impacts between 1 and 10 acres.
EASTERN ALTERNATIVE
EE4 Ramp 0.2741 0.68 10 South Prong Tributary NW #26 PSSB
A 13+20 1.2656 3.13 20 South Prong Tributary NW #26 PDN PF01B
B 18+00 0.4343 1.07 120 South Prong Tributary NW #26 PDN PFO1B
Cc 21+50 0.2754 0.68 105 South Prong Tributary NW #26 PFO1B
Cd 26+00 to 29+00 1.5974 3.95 170 South Prong Tributary NW #26 PDN PF01B
Ce 0.0000 0.00 20 South Prong Tributary NW #26 PFO1B
Cf 0.0000 0.00 20 South Prong Tributary NW #26 PDN PFO1B
D thru Ya (from above) 6.5289 16.13
TOTALS 10.3757 25.64
(delta) -0.05 -0.12
Open Water
1 106+00 0.00 0.00
O 126+00 0.90 2.23
Z 130+80 to 132+2 0.85 2.09
TOTALS 1.7497 4.32

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US 220 EIS ... Montgomery and Richmond Counties, R-2231
WETLANDS ... Preliminary Design Impacts Along the Preferred Corridor
Subsequent to the selection of the preferred alternative, wetlands delineations were conducted in 1994 and 1995 within
the 1,200-foot wide corridor in accordance with the procedures described in the 1987 Corps of Engineers' Wetland
Delineation Manual (TR Y-87-1). The wetlands flagging was informally coordinated with the U. S. Army Corps of
Engineers (USCOE) during a field visit on January 19, 1995, and extent of the delineated wetlands were surveyed by
NCDOT using Global Positioning System techniques. The Wetlands Delineation Report (dated March 1995) is available
for reference. The development of the current Preliminary Designs for the preferred alternative have been laid out to
avoid, or minimize to the extent possible, the jurisdictional wetlands delineated within the preferred corridor.
In general, three vegetated wetland community types and two types of waters of the U.S. were identified within the
corridor. The wetland types are forested wetlands, marshes and wet meadows, and regenerative shrub wetlands.
Streams and open-water areas, which were commonly represented by stock ponds, constituted the waters of the U.S.
Fotested`wetlands w6e'the most frequently encountered wetland areas.{ The remaining community types are of
relatively limited aerial extent.
Table 4.7-2 in the DEIS identifies the specific wetlands impacted by all project alternatives based upon the 1991
information and functional designs. Wetland impacts were estimated at 21.3 acres for the Eastern Alternative
(subsequently, selected as preferred).
In 1994 and 1995, thirty-three wetland sites were delineated within the 1,200 foot wide preferred corridor and southern
alternate, identified as sites 'A' through 'GG', as shown in Exhibit 4-1 and Table 4-1. The total areal extent of wetlands
within the 1,200-ft wide corridor is approximately 272 acres, with approximately 34 miles of perimeter. 'Waters of the
U.S.' (ponds and streams) were not included in this delineations or the subsequent analyses.
After alignment adjustments during development of the preliminary designs, the potential impacts to the jurisdictional
wetlands total 28.17 acres. Table 4-2 lists the impacted wetlands along the preferred alternative. These are based upon
the 1994-1995 wetlands delineations and the probable impacts from the current preliminary designs. Ifta'cts''were
measured using the standard median (70 feetkwith no special embankment slopes in the vicinity of the wetlands. The
standard°'design template varied the foreslope from 6:1 to 2: l to tie in with,exsting ground<within 9 meters of the hinge
point. 2:1 slopes were used if the tie-in point exceeds the 9-meter distance. Impaeted"wetland sites total 29, ranging
,in size from 0.0.4xo 4 50 acres. 'Eleven of the impacted areas identified were in excess of one acre, with-one of these
04-27-95 ... coehnd3x.att

I?re4 All of the impacted areas are located in "headwater" tributary areas or are isolated and could,
therefore, qualify under the Nationwide Permit Program, as would the majority of stream crossings.
The preliminary design alignment has avoided and minimized wetland impacts to the extent that approximately 28 acres
of wetlands are impacted among twenty-nine discrete impact sites. Approximately 10-percent of the wetlands within
the preferred corridor are impacted by the current preliminary design. This in spite of the fact that the nominal 300-foot
wide footprint, plus interchange areas, make up more than 25-percent of the corridor width. More details on the results
of the wetlands effort are found in Wetlands Delineation Report, March 1995, (Appendix A of the FEIS).
All twenty-nine of the impacted wetlands are of a size and location to meet the requirements for the Nationwide
program. Eleven sites may exceed one acre. Each of these, Site EE1 (1.63 acres), Site GG1 (1.59 acres), Site GG2 (1.77
acres), Site Cb (1.71 acres), Site F (1.55 acres), Site G (1.07 acres), Site Gb (1.36 acres), Site H (1.43 acres), Site I (4.50
acres), Site S (1.63 acres), and Site Wa (1.34 acres) would meet the headwater and size criteria for Nationwide Permit
#26, with pre-discharge notification submitted to the COE. The total acreage of impacted wetlands is 28.17 acres, with
8.59 acres among 18 sites qualifying under Nationwide #26 and 19.58 acres among eleven sites qualifying under
Nationwide #26 with pre-discharge notification.
The wetland impacts resulting from the current preliminary designs exceed those estimated for the functional designs
by 6.87 acres, or 32-percent. This increase, despite the attempts to avoid and minimize impacts through alignment shifts
in the preliminary design, stems from the greater extent of the wetland sites as identified through the formal delineations
in 1994 and 1995. The increase in size of the wetlands within the preferred corridor is in large part associated with the
prevalence of hillside seep areas which were not previously recognized through the photo interpretation and field checks
used for the impact estimates in the Draft EIS. It is felt that a similar increase would have occurred in the limits of
wetlands within each of the other Reasonable and Feasible Alternative corridors, had they also been formally delineated.
04-27-95 ... coehnd3x.att 2
a
Table 4-1
US 220; Delineated Wetlands Within the Preferred Corridor
file l 00tab41.wb 1
R-2231 04/27/95 WETLAND AREA WETLAND
rsh Length PERIMETER
Delineated Stream Areas Total
Wetland Wetland Channel Perimeter Length
Site Area Wetland Flagged Flagged
(ha) (acres) (m) (m) (ft)
A 1.4409 3.90 956 3,136
B 3.0557 8.28 1,910 6,266
C 10.2193 27.69 4,708 15,446
D 4.8046 13.02 2,257 7,405
E 1.1900 3.22 918 3,012
F 3.4654 9.39 1,911 6,270
G 11.6460 31.56 5,907 19,380
H 1.0612 2.88 575 1,886
I 5.4107 14.66 1,968 6,457
J 1.4921 4.04 958 3,143
K 0.0286 0.08 89 292
L 0.0420 0.11 101 331
M 0.2584 0.70 255 837
N 0.8105 2.20 953 3,127
O 0.1497 0.41 175 574
P 0.2991 0.81 287 942
Q 2.2936 6.22 1,284 4,213
R 1.2478 3.38 878 2,881
S 7.3554 19.93 3,849 12,628
T 1.3622 3.69 769 2,523
U 1.6057 4.35 1,374 4,508
V 3.6588 9.92 2,954 9,691
W 2.7036 7.33 2,069 6,788
X 0.6857 1.86 941 3,087
Y 7.4259 20.12 4,005 13,140
Z 3.8252 10.37 2,053 6,735
AA 0.1022 0.28 71 233
BB 0.7709 2.09 534 1,752
CC 0.6231 1.69 465 1,526
DD 1.9504 5.29 1,243 4,078
EE 3.4777 9.42 2,781 9,124
FF 0.9026 2.45 813 2,667
GG 14.8633 40.28 5,446 17,867
Totals 100.2283 271.62 0 55,457 181,943
ha. acres m m feet
55.46 34.46
km miles
Table 4-2
US-220; WETLAND IMPACTS
04/27/95
Preliminary Drainage
Wetland Design Impact Area Basin Location Permit Wetland
Site Stationing Size Type
(ha) (acres) (acres)
EE1 9+00/ Y-Line 0.6598 1.63 20 South Prong Tributary NW #26 PDN PSSB
EE2 SB Off Ramp 0.2748 0.68 20 South Prong Tributary NW #26 PSSB
EE3 11+00 0.0991 0.24 10 South Prong Tributary NW #26 PSSB
EE4 NB On Ramp 0.0978 0.24 10 South Prong Tributary NW #26 PSSB
DD Y-Line 0.3194 0.79 10 South Prong Tributary NW #26 PSSB
FF 12+65 0.0782 0.19 10 South Prong Tributary NW #26 PFO1B
GGI 17+00 to 18+00 0.6416 1.59 600 South Prong Tributary NW #26 PDN PFO1B
GG2 20+00 0.7143 1.77 275 South Prong Tributary NW #26 PDN PFOIB
Ca 24+50 0.1860 0.46 40 South Prong Tributary NW #26 PFOIA
Cb 28+50 0.6905 1.71 40 South Prong Tributary NW #26 PDN PFOIA
D 36+00 0.3220 0.80 70 Bells Creek Tributary NW #26 PFOIB
E 46+80 0.0000 0.00 500 Bells Creek Tributary NW #26 PWMHh
F 58+00 0.6281 1.55 1210 Bells Creek Tributary NW #26 PDN PFOIA
G 75+60 0.4315 1.07 145 Bells Creek Tributary NW #26 PDN PFO1B
Ga 80+20 0.0752 0.19 50 Bells Creek Tributary NW #26 PFO1B
Gb 83+50 0.5495 1.36 50 Bells Creek Tributary NW #26 PDN PFOIB
Ge 85+40 / Ramp 0.0752 0.19 50 Bells Creek Tributary NW #26 PFOIB
H 95+00 / Y-line 0.5777 1.43 35 Job's Creek Tributary NW #26 PDN PFOIB
I 97+00 to 100+00 1.8195 4.50 43 Job's Creek Tributary NW #26 PDN PFOIB
and Y-line
J 105+00 0.0000 0.00 28 Job's Creek Tributary NW #26 PFOIB
K 118+50 0.0000 0.00 67 Job's Creek Tributary NW #26
L 120+80 0.0000 0.00 40 Job's Creek Tributary NW #26
M 122+60 0.0000 0.00 40 Job's Creek Tributary NW #26
N 64+00 0.0000 0.00 Bells Creek Tributary NW #26 PFOIA
O 126+00 0.0000 0.00 25 Rocky Ford Branch Tributary NW #26 PEMHxh
P 126+00 0.0000 0.00 30 Rocky Ford Branch Tributary NW #26 PFOIB
Za 130+80 0.0000 0.00 30 Rocky Ford Branch Tributary NW #26 PFO1B
Z 133+00 to 139+0 0.0000 0.00 85 Rocky Ford Branch Tributary NW #26 PFOIB
Q 163+60 0.3334 0.82 55 Naked Creek Tributary NW #26 PFO1B
R 167+40 / Ramp 0.0165 0.04 40 Naked Creek Tributary NW #26 PFOIB
Sa 179+00 0.2604 0.64 30 Naked Creek Tributary NW #26 PFOIA
S 181+30 0.6582 1.63 435 Naked Creek Tributary NW #26 PDN PFOIB
AA 200+00 0.0000 0.00 20 Naked Creek Tributary NW #26
T 226+00 0.0000 0.00 65 Naked Creek Tributary NW #26
U 235+00 / Ramps 0.2608 0.64 90 Big Mountain Creek Tributary NW #26 PFOIA
Va 240+00 0.0000 0.00 20 Big Mountain Creek Tributary NW #26 PFO1B
Vb 244+00 0.1321 0.33 30 Big Mountain Creek Tributary NW #26 PFOIB
V 245+40 0.3063 0.76 265 Big Mountain Creek Tributary NW #26 PFO1B
X 247+00 0.0000 0.00 40 Big Mountain Creek Tributary NW #26 PSSB
W 249+00 0.2329 0.58 20 Big Mountain Creek Tributary NW #26 PFO1B
Wa 251+20 0.5431 1.34 100 Big Mountain Creek Tributary NW #26 PDN PFO1B
Y 258+60 0.3170 0.78 150 Big Mountain Creek Tributary NW #26 PFOIB
Ya 261+80 0.1004 0.25 40 Big Mountain Creek Tributary NW #26 PFOIA
TOTALS 11.4013 28.17
ha acres
Individual Permit may be required below headwaters (5 sq mi or 3,200 acres)
Nationwide Permit for headwater wetland impacts of less than 1 acre
Nationwide Permit with Pre-Discharge Notification for headwater wetland impacts between 1 and 10 acres.
Alternate "A"
EE4 Ramp 0.2741 0.68 10 South Prong Tributary NW #26 PSSB
A 13+20 1.2656 3.13 20 South Prong Tributary NW #26 PDN PFO1B
B 18+00 0.4343 1.07 120 South Prong Tributary NW #26 PDN PFOIB
Cc 21+50 0.2754 0.68 105 South Prong Tributary NW #26 PFO1B
Cd 26+00 to 29+00 1.5974 3.95 170 South Prong Tributary NW #26 PDN PFO1B
Ce 0.0000 0.00 20 South Prong Tributary NW #26 PFOIB
Cf 0.0000 0.00 20 South Prong Tributary NW #26 PDN PFO1B
D thru Ya (from above) 7.6398 18.88
TOTALS 11.4866 28.38
(delta) 0.0853 0.21
Open Water
J 106+00 0.00 0.00
O 126+00 0.90 2.23
Z 130+80 to 132+2 0.85 2.09
TOTALS 1.7497 4.32

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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
JAMES B. HUNT JR. DIVISION OF HIGHWAYS
GOVERNOR P.O. BOX 25201, RALEIGH, N.C. 27611-5201
June 17, 1997
Mr. John Dorney
DEHNR - Division of Water Quality
Environmental Sciences Branch
4401 Reedy Creek Road
Raleigh, North Carolina 27607
ATTN: Ms. Cyndi Bell
Dear Mr..Dorney:
GARLAND B. GARRETT JR.
SECRETARY
CA)
SUBJECT: US 220 from Emery to Ellerbe, Montgomery and Richmond Counties,
FHWA-NC-EIS-91-02-F, Federal Aid Project No. F-45-1(42), State
Project No. 8.155080 1, TIP No. R-2231: Record of Decision
Thank you for your comments on the Final Environmental Impact Statement for the
subject proposed highway project. Your comments are addressed in the Record of
Decision (ROD), which was signed by the Federal Highway Administration on May 30,
1997. A copy of the ROD is enclosed for your information.
If you have questions or need additional information, please contact Cindy Sharer, P. E.,
project planning engineer.
Sincerely,
H. Franklin Vick, . E., Manager
Planning and Environmental Branch
Attachments
cc: Mr. Roy Shelton, FHWA
Ms. Melba McGee, DEHNR
o' ?P
O
404 347 2125 1997.05-30 14:26 ;1770 P.02/02
11dU1'ri
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Aidnitlsf?af?vn
Subject Record of Decision bate: May 30, 1997
FHWA-NC-EIS-91-02-F
US 220 Montgomery and
Richmond Counties, North Carolina Fleplyto
From: Ann. of
Director, Office of Planning and HPP-04
Program Development
To: Atlanta, Georgia
Mr. Nicholas L. Graf
Division Administrator (HDA-NC)
Raleigh, North Carolina
This documents the Record of Decision (ROD) (as required by 40
CFR 1505.2) for the subject project, This record incorporates
the Federal and State project files and the attached preliminary
ROD. Based upon the Environmental Impact Statement and public
input, the Federal Highway Administration (FHWA) and the North
Carolina Department of Transportation (NCDOT) have selected the
Eastern Alternative. FHWA has determined that the Eastern
Alternative is the environmentally preferable alternative. The
preliminary ROD contains a description of the alternatives
considered, measures to minimize harm, and all necessary
monitoring requirements.,
The correspondence received between the FEI9 and the date this
ROD was signed is as follows: A. February 26, 1997 letter from
the U.S. Department of the Interior, a February 7, 1997 letter
from the Division of Environmental Management of the Department
of Environment, Health and Natural Resources (DEHNR), a February
14, 1997 letter from the North Carolina Wildlife Resources
Commission of the DEHNR, and a January 31, 1997 letter from the
Division of Forest Resources of the DEHNR_ Copies of these
letters are attached. The preliminary ROD provides NCDOT's
responses to the letters and we find the responses adequately
address all concerns expressed. Based on a review of
correspondence received, we find that there have been no new,
substantive issues or impacts identified. Therefore, the FEIS
and the attached ROD remain valid:
hn S. Humeston
.Y ? ?? a/yam
Date
Attachments
RECORD OF DECISION
U. S. Department of Transportation
Federal Highway Administration
US 220 from Emery to South of Ellerbe
Montgomery and Richmond Counties, N. C.
FHWA-NC-EIS-91-02-F
Federal Aid Project No. F-45-1(42)
State Project No. 8.1550801
TIP No. R-2231
A. Decision
The proposed action is the construction of a four-lane divided, full-control of access roadway
on new location from south of Ellerbe (Richmond County) to Emery, south of Candor
(Montgomery County). The project is approximately 16 miles in length. Since the publication
of the DEIS in 1991, the NCDOT has designated US 220 in Montgomery and Richmond
Counties as part of the North Carolina route for the proposed Interstate 73, which will extend
from Charleston, South Carolina to Detroit, Michigan.
The Preferred Alternative is the Eastern Alternative as presented in the Final Environmental
Impact Statement. Interchanges are proposed at US 220 south of Ellerbe, SR 1452 (Millstone
Road), SR 1458, NC 73, SR 1321, SR 1524, and US 220 north of Emery.
The main purpose of the project is to provide a full control of access facility along the US 220
corridor as part of the North Carolina Intrastate System and as a portion of I-73.
B. Alternatives Considered
Alternatives considered for the proposed improvements to US 220 from Emery to Ellerbe
included the No-Build alternative, the Widen Existing Alternative, and four construction
alternatives. The No-Build Alternative and Widen Existing Alternative were found not to
provide a satisfactory solution for the project purpose and need. The four reasonable and
feasible construction alternatives identified were the Western, Middle, Eastern, and East
Alternate alternatives.
Basis for Selection of Preferred Alternative
The Eastern Alternative was selected as the Preferred Alternative in 1993 based upon the
detailed information and analyses presented in the DEIS, verbal and written comments from
the public received during the Corridor Public Hearing and the comments from various
federal, state, and local agencies and officials during post-DEIS meetings. The Western
Alternative received little or no support due to its cost, impacts to forested wetlands and large
tracts of unfragmented natural habitat, and remoteness from the existing development along
US 220. The Middle and Eastern alternatives received fairly equal support from the public
and the regulatory agencies. The Middle alternative avoided impacts to the Naked Creek
watershed and the Sandhills Gamelands and had fewer impacts to the human environment,
while the Eastern alternative was the least expensive, provided better traffic service to Ellerbe
and Norman, and had fewer impacts to high quality wildlife habitat (hardwood and pine-
hardwood forest) and to high quality wetlands. The East Alternate alternative shared the
impacts of the Eastern alternative but did not share its cost advantages, and received less
support than either the Middle or Eastern alternatives.
The Eastern Alternative was selected as the Preferred Alternative based on better traffic
service provided to Ellerbe and Norman, on lesser impacts to botto,mland and upland
hardwood and pine-hardwood forests, on lesser impacts to high quality wetlands, and on
lower cost. The Eastern Alternative is therefore the environmentally preferred alternative.
The selection of the Eastern Alternative was endorsed by the Richmond County
Commissioners, the Ellerbe Town Board; and the U. S. Army Corps of Engineers.
Description of the Preferred Alternative
US 220 is a major traffic route Greensboro, Winston-Salem, High Point Triad urban area
travelers bound for the coastal areas of South Carolina. It is located approximately 60 miles
east of and generally parallel to Interstate 77 (I-77) and provides connection between I-
40/I-85, US 64 and US 74, east-west routes through the Piedmont and Coastal Plain regions of
North Carolina. US 220 directly serves as a corridor that extends from Roanoke, Virginia,
through North Carolina to the South Carolina border.
From south to north, the Preferred Alternative begins at the intersection of four-lane US 220
and SR 1448, south of Ellerbe, in Richmond County and travels east of existing US 220 for
approximately 14 miles before crossing to the west of US 220 north of Norman, in
Montgomery County. The Preferred Alternative rejoins US 220 at the existing four-lane
roadway near the intersection of US 220 and US 220A, dust South of Candor. The existing
two-lane US 220 is approximately 15.3 miles in length and the Preferred Alternative measures
approximately 16.2 miles in length.
After selection of the Eastern Alternative as the Preferred Alternative, the relocation of the
southern terminus of the project was evaluated in response to suggestions received from the
public during the Corridor Public I-fearing process and from the regulatory agencies during the
2
Draft Environmental Impact Statement (DEIS) comment period. The relocated southern
terminus is approximately 0.25 miles south of the original terminus for the Eastern
Alternative, at the US 220 intersection with SR 1448. An alternate corridor was developed to
connect the relocated southern terminus to the Eastern Alternative at the crossing of SR 1450,
a distance of approximately 1.5 miles. The alternate corridor improved the design and
function of the interchange at existing US 220 and reduced the impacts to a mobile home park
and residences along Dogwood Drive just south of the Richmond Yarns Mill. The alternate
corridor and the relocated southern terminus were chosen as the Preferred Alternative based
upon reduced residential impacts and better short term and long term traffic service than the
Eastern Alternative.
Grade separated interchanges are proposed for each project terminus with existing US 220, as
well as at SR 1452, SR 1441, NC 73, SR 1321, and SR 1524. Bridges, service roads, and
realignments of existing roads are proposed to reconnect public and private roads bisected by
the project including: a service road along the west side of the project north of SR 1455, the
realignment of SR 1457 in the northeast quadrant of the interchange at SR 1441, the
realignment of SR 1453 along the west side of the project north of the SR 1441 interchange, a
service road along the east side of the project north of SR 1459, a service road along the east
side of the project north of the NC 73 interchange, a grade separation at SR 1526, and a
service road running north along the east side of the project connecting SR 1526 with US 220.
These service roads, realignments, and bridges will provide for the continuation of existing
access to roads and farms cut by the project, and minimize the disruption to the existing land
uses adjacent to the project.
Impacts
Urban and Community Impacts: Construction of the Preferred Alternative would increase the
overall public safety in the towns of Ellerbe and Norman by removing through traffic from the
Central Business Districts and removing the conflicts between local turning traffic and the
higher speed through traffic, especially commercial trucks. School buses using existing US
220 will benefit from the diversion of the through traffic. The decreased delays to through
traffic will result in cost savings in labor and fuel consumption. Improved connections to the
state and regional urban centers are expected to stimulate economic development in the area,
particularly in the vicinity of interchanges. However, some businesses along the existing
route may be adversely affected by the loss of drive-by traffic.
Displacement of approximately twenty-seven residences, four business buildings (from two
businesses), and three poultry barns would occur with the construction of the Preferred
Alternative.
The Preferred Alternative does not require land from schools, recreation areas, parks, wildlife
refuges or churches.
Historic Architectural Properties: There are no historical structures listed in or eligible for
listing in the National Register of Historic Places impacted by the Preferred Alternative.
Archaeological Sites: There are no archaeological sites listed in or eligible for listing in the
National Register of Historic Places impacted by the Preferred Alternative.
Biotic Communities: Biotic communities, including wetland communities, and the associated
wildlife would be impacted by the construction of the Preferred Alternative. The Preferred
Alternative right-of-way includes approximately 26-percent managed timber, 50-percent
agricultural land, 20-percent forest, three-percent previously disturbed (developed) areas, and
one-percent open water.
The Preferred Alternative will result in impacts to 30 jurisdictional wetland sites with a total
impacted area of approximately 24.7 acres. Wetland impacts range in size from 0.04 acre to
1.85 acres, with eleven sites exceeding one acre. All of the potentially affected jurisdictional
wetlands are located along headwater streams.
The Preferred Alternative separates one 75-acre out-parcel of the Sandhills Gamelands from
the remainder of the 60,000-acre Gamelands. No land is taken from the Gamelands and the
project does not affect forested areas contiguous with the Gamelands along SR 1458.
Air Quality: Air quality in the area is not expected to change substantially with the
construction of the Preferred Alternative. None of the sites considered in the air quality
analysis were projected to exceed either the one-hour or eight-hour carbon monoxide
concentrations set forth by the National Ambient Air Quality Standards. The project area is
classified as an air quality attainment area in the State Implementation Plan (SIP).
Noise Impacts: Noise impacts would be limited due to the rural nature of the study area.
Thirty-three homes and businesses will experience noise impacts as a result of construction.of
the Preferred Alternative.
Water Quality: Temporary water quality impacts are expected from increased sediment
loading associated with construction. The Preferred Alternative will cross 31 drainageways.
Seven of these are in the Big Mountain Creek watershed, eight in the Naked Creek watershed,
two in the Rocky Ford Branch watershed, four in the Job's Creek watershed, seven in the
Bells Creek watershed and three in the South Prong Creek watershed. No long term negative
impacts to water quality are anticipated.
Flood plains: There are no regulatory floodplains or floodways identified along the drainages
crossed by the Preferred Alternative. Therefore, there will be no impacts to FEMA floodways
or 100-year floodplains resulting from this project.
C. Section 4(f)
The proposed action will not take land from a publicly owned park, historic site, wildlife or
waterfowl refuge, or recreation area of local, state or federal importance as determined by the
officials having jurisdiction. Therefore, provisions of 49 USC 1653(f) are fulfilled. The
applicable provisions of 36 CFR 800 have been fulfilled.
4
D. Measures to Minimize Harm
Avoidance of the Rocky Ford Branch Wetlands: As recommended by the Department of
Environment, Health and Natural Resources, Division of Environmental Management, the
preliminary design was shifted approximately 400 to 600 feet to the east to avoid impacting
the 5.3 acres of wetlands located along Rocky Ford Branch. A large farm pond will be
bisected by this shift in the alignment. Enough of the pond may remain both downstream and
upstream of the project to create two or three smaller ponds, or the area may be used to
mitigate wetlands unavoidably impacted by the project.
Alternate Corridor at the South End of the Project: The Eastern Alternative at the south end
of the project was severely constrained by the Richmond Yarns Mill, by a lakeside residential
development along Dogwood Drive and by a trailer park east of US 220. Following the
Corridor Public Hearing, an alternate corridor was proposed between US 220 and SR 1450,
southeast of the existing corridor, between the Eastern Alternative and SR 1448. Based on
environmental evaluations and a relocation study conducted along the alternate corridor,
residential relocations were reduced by 24 residences, noise impacts were reduced by seven
impacted receptors, and wetland impacts were slightly reduced by selection of this alternate
corridor as the Preferred Alternative.
Mitigation of Noise Impacts: With the Preferred Alternative, 33 receptors are predicted to be
impacted by noise. Of those 33 receptors, 27 receptors are predicted to experience a
substantial exterior noise level increase and six are predicted to approach or exceed the
FHWA noise abatement criteria.
Due to the rural nature of the study area, impacted receptors along US 220 are generally
isolated. Physical abatement measures for isolated receptors are deemed to be neither
reasonable nor feasible. Landscaping and vegetated berms could provide some aesthetic and
psychological relief for these properties and will be considered by NCDOT during final
design. Any landscaping berm would not be of a height sufficient to provide noise abatement.
Based on these preliminary studies, no traffic noise abatement is considered reasonable or
feasible along this project and none is proposed. This evaluation completes the highway
traffic noise requirements of 23 CFR, Part 772 and, unless a major project change develops,
no additional reports are required for this project.
Wetland Mitigation: Wetland impacts were avoided and minimized to the extent practicable
through the selection of the Preferred Alternative and the development of the alignment
during preliminary design. Mitigation of unavoidable impacts will be provided for this project
as coordinated with the U. S. Army Corps of Engineers, the U. S. Fish and Wildlife Service,
the Division of Environmental Management and the Wildlife Resources Commission.
Wetlands within the project construction limits (toe-of-slope) were calculated using a standard
median (70 feet), with no special embankment slopes in the vicinity of the wetlands. The
5

potential impacts to the jurisdictional wetlands total 24.72 acres. Impacted wetland sites total
30, ranging in size from 0.04 to 1.85 acres. Eleven of the impacted areas identified are in
excess of one acre, with no sites exceeding two acres. All of the impacted areas are located in
"headwater" tributary areas or are isolated.
Construction Impacts: Construction related impacts associated with the proposed project will
be minimized through erosion and sediment control measures as described in the Federal Aid
Policy Guide (FAPG) part 650B and the North Carolina Administrative Codes, Chapter 4
Sedimentation Control. NCDOT's Best Management Practices for the Protection of Surface
Waters will be incorporated in the design and construction of the project.
E. Monitoring and Enforcement Program
The construction staff of NCDOT and FHWA will enforce all pertinent specifications and
contract provisions which are in accordance with the intent of this EIS and the welfare of the
public.
F. Environmental Commitments
The North Carolina Department of Transportation makes the following commitments with
respect to the avoidance or minimization of major environmental impacts during design,
construction, and maintenance of this project:
• NCDOT will minimize long-term water quality impacts through the use of the NCDOT
"Best Management Practices for Protection of Surface Waters".
• The more stringent erosion control measures required by Rule 0.0201(d)(2)(A) and (B) of
15 NCAC 213.0201 will be followed within the Naked Creek Watershed (outstanding
resource waters) crossed by the Preferred Alternative.
• The Preferred Alternative will be designed to avoid or minimize the extent practicable the
jurisdictional wetlands delineated within the corridor. The wetland mitigation plan will be
developed in consultation with the appropriate regulatory agencies.
• NCDOT will construct a hazardous spill catch basin at the crossing of the Naked Creek
unnamed tributary northeast of Norman.
• Underground storage tank sites will be avoided to the extent practicable. Where sites can
not be avoided, testing and removal will be accomplished in accordance with 40 CFR Part
280 and I SA NCAC 2.2(n). Any required site remediation will be accomplished in
6
accordance with NC Department of Environment, Health, and Natural Resources
"Guidelines for Remediation of Soil Contaminated by Petroleum".
• Impacts to the Sandhills Gamelands will be avoided by the Preferred Alternative.
• All structures will be designed so as not to exceed a maximum of 1-foot increase in the
base 100-year flood elevation.
• NCDOT commits to funding the relocation of geodetic control monuments affected by the
project.
• NCDOT will consider the use of landscaping as a noise abatement measure.
• NCDOT will implement the last resort housing program, if necessary, as mandated by
state law.
• NCDOT will coordinate with WRC, as required under the Streambank Stabilization and
Planting Guidelines for Stream Restoration and Relocation, January 27, 1997, and with
US Fish and Wildlife Service, in accordance with the Fish and Wildlife Coordination Act,
in the determination of the specific requirements for each stream relocation.
• Sediment and erosion control measures will be placed within construction areas to
minimize impacts on streams and wetlands. This commitment will be included in the
construction contract awarded for this project.
• All borrow material will be taken from upland sources. This commitment will be included
in the construction contract awarded for this project.
G. Comments on the Final EIS
The final statement is in accordance with the applicable provisions of 23 CFR 771 and it
satisfactorily covers the anticipated environmental impacts, including physiographic and
cultural effects.
The following correspondence has been received from agencies following completion of the
FEIS. Comments contained therein are addressed below:
7
United States Department of the Interior
Office of the Secretary
Director, Office of Environmental Policy and Compliance
February 26, 1997
1) Comment: Table 4-2 of the FEIS shows that wetland losses for 70-, 60-, and 46-foot
medians would be 24.72, 23.85, and 22.7 acres, respectively. The FEIS proceeds to the
determination (p.4-7) that the preferred alternative includes all practical measures to minimize
harm to wetlands. We question these conclusions and believe that neither the DEIS nor FEIS
adequately considers the use of 46-foot medians through wetland areas.
Response: The preferred alternative impacts 30 small wetland pockets along the 16.2 mile
length of the project. The frequency and spacing of the wetland pockets do not provide
adequate distance for a transition from a 70-foot median to a 46-foot median and back to a 70-
foot median. Therefore, the median width for the entire project would have to be reduced to
46 feet. This section of proposed US 220 will be designated I-73 and a 70-foot median width
is safer for a high speed Interstate highway. The reduction of the median width from 70-feet to
46-feet would save a total of three acres of wetlands. The NCDOT does not recommend
reducing the median width below 70 feet to achieve such a small reduction in wetland
impacts.
2) Comment: All wetland losses for this project should be considered together and evaluated
with a single permit.
Response: The NCDOT agreed to submit to a single permit application at the May 18, 1995
Permit Review Agency Meeting.
3) Comment: The true extent of wetland impacts cannot be assessed until a complete plan of
compensatory mitigation is developed. While the conceptual wetlands mitigation plan is an
excellent planning document, the FWS believes that the NCDOT has had sufficient time to
develop a complete plan and provide commitments for its implementation.
Response: The NCDOT is developing a wetland mitigation plan for this project, and this plan
will be submitted with the permit application. An environmental commitment was added to
this document committing the NCDOT to implement a complete plan of compensatory
wetland mitigation.
Department of Environment Health and Natural Resources
Division of Water Quality
Environmental Sciences Branch
February 7, 1997
4) Comment: The FEIS states that 31 new stream crossings will be required to construct the
Eastern Alternative. The document does not include the linear feet or area of streams to be
placed in culverts or diverted by channel changes. This information must be included with the
permit application and drawings.
Response: The exact linear distance of streams to be placed in culverts or diverted by channel
changes will be determined during final design. It is anticipated, however, most of the 31
stream crossings will be over 100 feet in length and will be categorized as "standard"
relocations. This information will be included in the permit application.
.i) Comment: NCDOT is reminded that stream mitigation may be required in accordance with
current DWQ Wetland Rules (I 5A NCAC 2H.0506(b)(6)) which were not in effect at the
time the EIS was prepared.
Response: It is anticipated stream mitigation will be required in accordance with DQW
Wetland Rules. NCDOT will coordinate with WRC, as required under the Streambank
Stabilization and Planting Guidelines for Stream, Restoration and Relocation, January 27,
1997, and US Fish and Wildlife, in accordance with the Fish and Wildlife Coordination Act,
in the determination of the specific requirements for each stream relocation. An environmental
commitment to the coordination is included in this ROD.
6) Comment: In a Permit Review Agency Meeting held May 18, 1995, NCDOT agreed to
submit a single application for the entire project, as included in this EIS. At that time,
NCDOT also committed to including a comprehensive wetland mitigation proposal with the
permit application.
Response: See Responses 2) and 3), above.
7) Comment: Please ensure that each of the 31 proposed stream crossings has been examined
with respect to these guidelines (NCDOT's Guidelines for the Location and Design of
Hazardous Spill Basins).... The Environmental Commitments section includes plans to
provide spill basins at Rocky Ford Branch (Wetland Z) and at a single Naked Creek unnamed
tributary crossing. However, the Preferred Alternative discussion states that the Rocky Ford
Branch crossing will not even be required. We ask that NCDOT determine whether or not any
of the 31 stream crossings will require placement of hazardous spill catch basins in
accordance with NCDOT's guidelines.
Response: The water quality classifications for each of the stream crossings in the project
area were reviewed. Naked Creek and its tributaries, including Rocky Ford Branch, are
9
designated Outstanding Resource Waters (ORW). An unnamed tributary of Naked Creek is
crossed by the Preferred Alternative. No WS-1 designated streams are crossed by the
proposed project. The original preliminary design impacted a 5.3 acre headwater wetland
along Rocky Ford Branch and a hazardous spill catch basin was proposed at this location.
Based on a recommendation by DEHNR, the design was shifted eastward to avoid the
wetland. A hazardous spill catch basin is no longer needed at this location. The environmental
commitment in the FEIS regarding the construction of hazardous spill catch basins was,
therefore, in error and has been corrected in this ROD. A basin is proposed at the Naked
Creek tributary crossing just north of SR 1321.
8) Comment: In the FEIS, DOT stated that the final design will likely incorporate a 70-foot
median throughout most of the 16.2 mile project..... NCDOT is reminded that the 70-foot
median will necessarily involve more mitigation for stream and wetland impacts, and may
even cause some crossings to exceed the 150-foot minimum threshold at which stream
mitigation will be required.
Response: See Response 1) and 5), above.
9) Comment: DWQ requests that NCDOT ensure that the sediment and erosion control
measures are not placed in wetlands.
Response: Sediment and erosion control measures will be placed within construction areas to
minimize the impact on streams and wetlands. An environmental commitment was added to
address this concern.
10) Comment: DWQ asks that NCDOT stipulate that borrow material will be taken from
upland sources in the construction contract awarded for this project.
Response: An environmental commitment was added to address this concern.
11) Comment: In the future, NCDOT is strongly encouraged to utilize DWQ's Wetland
Rating System to discuss the comparative qualities of wetlands. Without a quantitative system
with repeatable results, there will be no consistency in comparing project alternatives or
discussing appropriate mitigation.
Response: NCDOT often uses the DWQ system for evaluating wetland functions and values
for projects. However, the DWQ system is not widely accepted by all agencies since it puts
more emphasis on water quality issues than some other rating systems. A different rating
system was used to evaluate the wetlands impacted by this project.
10
Department of Environment, Health and Natural Resources
North Carolina Wildlife Resources Commission
February 14,1997
12) Comment: We found no mention of stream channel impacts. The document did state that
there would be 31 new stream crossings on the preferred alternative. This indicates that stream
channel modifications will likely be necessary. We anticipate that with the new COE and
DQW regulations, stream mitigation will be required and may add significant costs to the
project. Stream channel modifications are of particular concern on tributaries of Naked Creek.
Response: See Response 5), above.
Department of Environment, Health and Natural Resources
Division of Forest Resources
January 31, 1997
13) Comment: Page P-2 and P-3 under Environmental Commitments does = indicate that
the ROW Contractor will attempt to salvage all forest wood products for pulpwood, chips,
poles and sawtimber if at all possible. We highly recommend that salvage be attempted.
Response: NCDOT standard construction specifications state the timber cut for highway
construction becomes the property of the contractor. The contractor is responsible for salvage
or disposal of the wood forest products.
Date of Approval Leon N. Larson, Regional Administrator
Federal Highway Administration
APPENDIX
Comments on Final Environmental Impact Statement

EHT of lh
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ER 91/838
United States Department of the Interior
OFFICE OF THE SECRETARY
Washin;ton. D.C. 20240
Mr. Leon N. Larson
Regional Administrator
Federal Highway Administration
100 Alabama Street, 17th Floor
Atlantic, Georgia 30303
Dear Mr. Larson:
E !
FE 9, 2 6 1997 Q,t F?
4 MAR u j 1997 r
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We have reviewed the Final Environmental Impact Statement for US 220, from Emery to
South of Ellerbe, Montgomery and Richmond Counties, North Carolina, and have the
following comments.
GENERAL COMMENTS
The Draft Environmental Impact Statement (DEIS) addresses the proposal by the North
Carolina Department of Transportation (NCDOT) to construct a four-lane, median-divided
highway. The DEIS considered three build alternatives on new location, the upgrading of the
existing roadway, and the no-build alternative. The preferred alternative has been determined
to be a modification of the original alternative on new location east of the existing highway.
The preferred alternative would be approximately 16.4 miles long.
Our comments on the DEIS recommended the maximum use of the existing alignment in order
to avoid adverse impacts associated with construction at a new location. The FEIS notes
(p. 2-1) that since the DEIS the proposed project has been incorporated into the proposed
route of Interstate 73. The document presents additional justifications (p. 6-6) for construction
at the new location.
We raised several issues regarding project impacts to federally endangered and threatened
species. By letter dated August 18, 1995, the Fish and Wildlife Service (FWS) informed the
NCDOT that the requirements of Section 7 of the Endangered Species Act had been fulfilled.
However, the letter stated that Section 7 issues would 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; (2) this action is subsequently modified in a manner that
was not considered in this review; and/or, (3) a new species is listed or critical habitat
determined that may be affected by the identified action.
Mr. Leon N. Larson 2
SPECIFIC COMMENTS
Median Widths and Wetland Impacts
The reduction of highway median width through wetlands can reduce the loss of these areas.
The original design indicated a 70-foot median. Comments from the Corps of Engineers (p.
6-9) on the DEIS requested that the NCDOT evaluate wetland impacts associated with smaller
medians. Table 4-2 of the FEIS shows that wetland losses for 70-, 60-, and 46-foot medians
would be 24.72, 23.85, and 22.7 acres, respectively. The FEIS proceeds to the determination
(p. 4-7) that the preferred alternative includes all practical measures to minimize harm to
wetlands. We question these conclusions and believe that neither the DEIS nor FEIS
adequately considers the use of 46-foot medians through wetland areas.
Permits for Wetland Impacts
The FEIS addresses the issue of permitting the fill of wetlands. The document notes (p. 4-6)
that all thirty of the impacted wetland sites are of a size and location to meet the requirements
for nationwide permits, primarily nationwide permit 26. As noted above, the project will
probably impact over 20 acres of wetlands, and we believe that losses from individual wetland
sites along the project corridor should not be considered individually. Furthermore, the
nationwide permits which will be reissued soon will reduce the areas which qualify for the use
of nationwide permit 26. All wetland losses for this project should be considered together and :j O
evaluated with a single individual permit.
Compensatory Wetland Mitigation
The DEIS stated (p. 4-48) that "A detailed mitigation plan for wetland impacts will be
developed when a preferred alignment is selected and a jurisdictional wetland delineation is
conducted." The FEIS presents a preferred alternative and notes (p. 3-8) that wetlands were
delineated in late 1994 and early 1995, and these delineations have been verbally accepted by
the Corps of Engineers. Construction of the preferred alternative would impact approximately
25 acres of wetlands.
Appendix E of the FEIS presents an excellent draft of a conceptual plan. The draft plan
provides details of measures which the NCDOT should do, could do, and/or may do. It does
not present a plan of the compensatory measures which will be done. The FWS strongly
supports many of the opinions and goals expressed in Appendix E, especially ones such as
"NCDOT will try to achieve in-kind, on-site replacement, replacing the vegetation wetlands
classes which have been lost on the project." However, the true extent of wetland impacts
cannot be assessed until a complete plan of compensatory mitigation is developed. While the
conceptual wetlands mitigation plan is an excellent planning document, the FWS believes
Mr. Leon N. Laeson
that the NCDOT has had sufficient time to develop a complete compensation plan and provide
commitments for its implementation.
We appreciate the opportunity to provide our comments,
Sincerely,
Willie R. Taylor
Director, Office of Environmental
Policy and Compliance
cc: H. Franklin Vick, P.E.
Manager, Planning and Environmental Branch
North Carolina Department of Transportation
Division of Highway
P.O. Box 25201
Raleigh, North Carolina 27611-5201
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
Ja mes B. Hunt, Jr., G ove mor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
February 7, 1997
MEMORANDUM
To: Melba McGee
Through: John Dorn*-)
From: 'Cyndi Bell GLe
AT4
ID FE F=1
Subject: Final Environmental Impact Statement for US 220 from Emery to South of Ellerbe
Montgomery and Richmond Counties
State Project DOT No. 8.1550801, T.I.P. No. R-2231
EHNR # 97-0454, DWQ # 11496
The subject document has been reviewed by this office. The Division of Water Quality (DWQ) is
responsible for the issuance of the Section 401 Water Quality Certification for activities which impact
waters of the state including wetlands. The project will impact up to 25.76 acres of jurisdictional
wetlands. Impacts to surface waters at stream crossings and a farm pond were not quantified. DWQ
offers the following comments based on the document review:
A) In the Draft Environmental Impact Statement (DEIS) submitted July 15, 1991, NCDOT
described three study corridors (Western, Middle, and Eastern) in addition to the No-Build
Alternative. DWQ had substantial objections to NCDOT's preferred (Eastern) alternative, and
expressed our preference for the Middle Alternative in our October 7, 1991 written response to
the DEIS. Subsequently, NCDOT has made significant efforts to modify the Eastern Alternative
to reduce its potential wetland impacts. NCDOT states that the preferred alternative now has
"lesser impacts to bottomland and upland hardwood and pine-hardwood forests, lesser impacts to
high quality wetlands, and lower cost." Wetlands within the Eastern Alignment study area were
delineated so that NCDOT could develop a preliminary design specifically addressing avoidance
and minimization of wetland impacts within the footprint of the study corridor. The stated
purpose of this methodology was to obtain concurrence from the U.S. Army Corps of Engineers
that the selected alternative would meet the Step-Down Procedure. Based on this information,
DWQ can also agree that the preferred alternative is the most practical alternative considering
the various environmental, socioeconomic and design constraints involved with this project. We
appreciate NCDOT's efforts to conduct extensive up-front studies and modify the alignment,
where necessary. However, NCDOT is reminded that issuance of a 401 Water Quality
Certification will be contingent upon avoidance, minimization, and mitigation of all wetland and
surface water impacts, including stream crossings and channel changes. During the permitting
process, the document will need to be supplemented with information pertaining to surface water
impacts in order for DWQ to fully endorse the selected alternative. This information is outlined
below:
Environmental Sciences Branch • 4401 Reedy Creek Road Raleigh, North Carolina 27607.
Telephone [phone] FAX At 733-9959
An Equal Opportunity Affirmative Action Employer 50% recycle&10 % post consumer paper
Ms. Melba McGee Memo
February 7, 1997
Page 2
1) The FEIS states that 31 new stream crossings will be required to construct the Eastern
Alternative. The document does not include the linear feet or area of streams to be
placed in culverts or diverted by channel changes. This information must be included
with the permit application and drawings. During the detailed design process, we
encourage NCDOT to place stream crossings (bridges or culverts) perpendicular to
stream channels to minimize impacts, if at all possible. DWQ will be happy to consult
with NCDOT throughout this process to help ensure protection of these streams.
NCDOT is reminded that stream mitigation may be required in accordance with current
DWQ Wetland Rules (15A NCAC 2H.0506(b)(6)) which were not in effect at the time
the EIS was prepared. We recommend that NCDOT coordinate with DWQ prior to
application for 404/401 Permits in order to discuss the potential need for a stream
mitigation plan.
2) A "large" farm pond will also be drained and partially filled. NCDOT should consult
with DWQ prior to application for 401 Water Quality Certification to discuss
applicability of our Pond Policy (in accordance with 15A NCAC 2H.0506(b)) to this
project. This policy is currently undergoing internal review within DWQ and may be in
effect prior to the construction date of the US 220 Relocation.
3) The preferred alignment will impact approximately 25.76 acres of jurisdictional
wetlands at 30 locations along the project corridor. In the EIS, it is stated that the
proposed work will likely qualify for Nationwide Permits 14 and/or 26, based on the fact
that all impact sites will occur above headwaters, and no single impact site exceeds two
acres. NCDOT should note that restrictions on "stacking", or repeated use of a
particular Nationwide permit for a single project, may apply under the revised 1997
Nationwide Permits. In such a case, the Corps may require application for an Individual
Permit. Furthermore, in a Permit Review Agency Meeting held May 18, 1995, NCDOT
agreed to submit a single application for the entire project, as included in this EIS. At
that time, NCDOT also committed to including a comprehensive wetland mitigation
proposal with the permit application. The FEIS includes a Draft Conceptual Wetland
Mitigation Plan with general guidelines for the types of mitigation which may be
proposed for this project. NCDOT is reminded that the new DWQ Wetland Rules (15A
NCAC 2H.0506 (h)(2)) include specific requirements for mitigation plans and ratios
based upon the distance of impact areas from surface waters. NCDOT is advised to
consult with the COE and DWQ prior to submittal of the 404/401 permit application in
order to develop a comprehensive application, including all wetland and stream impacts,
with corresponding mitigation. The mitigation plan will need to include a specific
property(ies), with plans for said property(ies), and monitoring/remediation
methodologies.
Ms. Melba McGee Memo
February 7, 1997
Page 2
1) The FEIS states that 31 new stream crossings will be required to construct the Eastern
Alternative. The document does not include the linear feet or area of streams to be O
placed in culverts or diverted by channel changes. This information must be included
with the permit application and drawings. During the detailed design process, we
encourage NCDOT to place stream crossings (bridges or culverts) perpendicular to
stream channels to minimize impacts, if at all possible. DWQ will be happy to consult
with NCDOT throughout this process to help ensure protection of these streams.
NCDOT is reminded that stream mitigation may be required in accordance with current
DWQ Wetland Rules (15A NCAC 2H.0506(b)(6)) which were not in effect at the time
the EIS was prepared. We recommend that NCDOT coordinate with DWQ prior to
application for 404/401 Permits in order to discuss the potential need for a stream
mitigation plan.
2) A "large" farm pond will also be drained and partially filled. NCDOT should consult
with DWQ prior to application for 401 Water Quality Certification to discuss
applicability of our Pond Policy (in accordance with 15A NCAC 2H.0506(b)) to this
project. This policy is currently undergoing internal review within DWQ and may be in
effect prior to the construction date of the US 220 Relocation.
3) The preferred alignment will impact approximately 25.76 acres of jurisdictional
wetlands at 30 locations along the project corridor. In the EIS, it is stated that the
proposed work will likely qualify for Nationwide Permits 14 and/or 26, based on the fact
that all impact sites will occur above headwaters, and no single impact site exceeds two
acres. NCDOT should note that restrictions on "stacking or repeated use of a
particular Nationwide permit for a single project, may apply under the revised 1997
Nationwide Permits. In such a case, the Corps may require application for an Individual
Permit. Furthermore, in a Permit Review Agency Meeting held May 18, 1995, NCDOT
agreed to submit a single application for the entire project, as included in this EIS. At
that time, NCDOT also committed to including a comprehensive wetland mitigation
proposal with the permit application. The FEIS includes a Draft Conceptual Wetland
Mitigation Plan with general guidelines for the types of mitigation which may be
proposed for this project NCDOT is reminded that the new DWQ Wetland Rules (15A
NCAC 2H.0506 (h)(2)) include specific requirements for mitigation plans and ratios
based upon the distance of impact areas from surface waters. NCDOT is advised to
consult with the COE and DWQ prior to submittal of the 404/401 permit application in
order to develop a comprehensive application, including all wetland and stream impacts,
with corresponding mitigation. The mitigation plan will need to include a specific
property(ies), with plans for said property(ies), and monitoring/remediation
methodologies.

Ms. Melba McGee Memo
February 7, 1997
Page 3
4) Reference NCDOT's Guidelines for the Location and Design of Hazardous Spill Basins
(May 2, 1996), which state that these basins will be provided at stream crossings located
within one half mile of the Critical Area of a water supply source and on all streams
designated as ORW or WS-I. Please ensure that each of the 31 proposed stream
crossings has been examined with respect to these guidelines. It is unclear from the EIS
whether or not this was done. For example, the Environmental Commitments section O
includes plans to provide spill basins at Rocky Ford Branch (Wetland Z) and at a single
Naked Creek unnamed tributary crossing. However, the Preferred Alternative
discussion states that the Rocky Ford Branch crossing will not even be required. We
ask that NCDOT determine whether or not any of the 31 stream crossings will require
placement of hazardous spill catch basins in accordance with NCDOT's guidelines.
The number of catch basins installed at any given crossing should be determined by the
design of the crossing, so that runoff water would enter said basin(s) rather than directly
flowing into the stream.
B) We wish to thank NCDOT for providing a comparison of impacts for the preferred alternative
based upon median widths of 70 feet, 60 feet, and 46 feet. In the FEIS, DOT stated that the final
design will likely incorporate a 70 foot median throughout most of the 16.2 mile project. The
suggested 60-foot and 46-foot median widths would result in reduced wetland impacts of 23.85
and 22.70 acres, respectively. NCDOT is reminded that the 70-foot median will necessarily
involve more mitigation for stream and wetland impacts, and may even cause some crossings to
exceed the 150-foot minimum threshold at which stream mitigation will be required.
C) We wish to thank NCDOT for shifting the alignment of the Eastern Alternative so that the Rocky
Ford Branch wetlands could be avoided. This has reduced the overall wetland impact of the
project by approximately 5.3 acres.
D) DWQ requests that NCDOT ensure that the sediment and erosion control measures are not
placed in wetlands. This commitment should be incorporated into the construction contract
awarded for this project.
E) DWQ asks that NCDOT stipulate that borrow material will be taken from upland sources in the
construction contract awarded for this project.
F) The EIS refers to the comparison of "relative quality" among the studied wetlands as a valid
criterion in evaluating design alternatives. It is stated that qualitative determinations were based
on subjective ratings determined by NCDOT's consultant, and that no formal evaluation system
was used to determine "low, medium and high" quality wetlands. Specifically, it appears that
"lower quality wetlands" were defined as headwater wetlands (page 6-11). This statement is
particularly disturbing, given that headwater wetlands are among the most critical in terms of
water quality (DWQ Report No. 93-01, May, 1993). In the future, NCDOT is strongly
encouraged to utilize DWQ's Wetland Rating System to discuss the comparative qualities of I
wetlands. Without a quantitative system with repeatable results, there will be no consistency in
comparing project alternatives or discussing appropriate mitigation.
Ms. Melba McGee Memo
February 7, 1997
Page 4
Based upon the wetland impacts described in the EA, General Certifications 3103 and 3108 will likely be
applicable to this project. Final permit authorization will require formal application by NCDOT and
written concurrence from DWQ. Please be aware that this approval will be contingent upon evidence of
avoidance and minimization of wetland and stream impacts to the extent practical, and provision of
wetland and/or stream mitigation where necessary.
DWQ appreciates the opportunity to provide comments on the Final EIS. DOT is reminded that issuance
of a 401 Water Quality Certification requires satisfaction of water quality concerns, to ensure that water
quality standards are met and no uses are lost. Questions regarding the 401 Certification should be
directed to Cyndi Bell at [phone] in DWQ's Water Quality Environmental Sciences Branch.
cc: Scott McLendon, COE, Wilmington
Cynthia D. Sharer, P.E., NCDOT, P&E
Michelle Suverkrubbe, DWQ
R2231EIS.DOC
Ms. Melba McGee Memo
February 7, 1997
Page 4
Based upon the wetland impacts described in the EA, General Certifications 3103 and 3108 will likely be
applicable to this project. Final permit authorization will require formal application by NCDOT and
written concurrence from DWQ. Please be aware that this approval will be contingent upon evidence of
avoidance and minimization of wetland and stream impacts to the extent practical, and provision of
wetland and/or stream mitigation where necessary.
DWQ appreciates the opportunity to provide comments on the Final EIS. DOT is reminded that issuance
of a 401 Water Quality Certification requires satisfaction of water quality concerns, to ensure that water
quality standards are met and no uses are lost. Questions regarding the 401 Certification should be
directed to Cyndi Bell at [phone] in DWQ's Water Quality Environmental Sciences Branch.
cc: Scott McLendon, COE, Wilmington
Cynthia D. Sharer, P.E., NCDOT, P&E
Michelle Suverkrubbe, DWQ
R2231EIS.DOC
NCWRC,HCP,FALLS LAKE TEL:[phone] Feb 14'97 13:46 ido.004 P.03
th Carolina Wildlife Resources Commission 0
Nor
512 N. Salisbury Streer, Raleigh, North Carolina 27604-1188, 919-733-3391
Charles R. Fullwood, Executive Director
10.11 IURANULIM
TO: Melba McGee
Office of Intergovernmental and Legislative Affairs, DE-HNR
F1<0M: David Cox, Highway Project Co tna r
Habitat Conservation Program
DATE: February 14, 1997
SUBJECT: Final Environmental Impact Statement (FEIS) for the US 220
improvements, from Emery to south of Ellerbe, Motltgosnery and
Riclunond counties, North Carolina. TIP No. R-2231, SCH Project No.
97-0454.
Staffbiologists with the N. C. Wildlife Resources Commission (NC;WRC) have
reviewed the subject FEIS and are familiar with habitat values in the project area. Tile
purpose of this review was to assess project impacts to fish and wildlife resources. Our
comments are provided in accordance with certain provisions of the National
Environmental Policy Act (42 U.S.C. 4332(2)(c)) and the Fish and Wildlife Coordination
Act (48 Sta(. 401, as amended; 16 U.S.C. 661-6674).
The proposed project involves the construction of a four-lane divided highway on
new location from the intersection of four-lane US 220 and SR 1445, south of EIlerbe,
and travels cast of existing US 220 for approximately 14 miles before crossing w the west
of US 220 north of Norman. The preferred alternative is approximately 16.2 miles in
length.
The subject document adequately discusses benefits, social impacts, and traffic
analysis of the final build alternatives. Tile document also adequately describes
anticipated impacts to natural resources from construction of the eastern alternative.
We appreciate that slight alignment shifts were made that reduced wetland
impacts by approximately 5 acres. The comparison of wetland impacts ]or different
median widths was also helpful. Since total wetland impacts are projected to be 24.72
acres we will recommend that this project be authorized under a single individual '404'
permit. We are concerned about the subjective rating system used to judge the relative
values of the wetland sites crossed by the alternatives. We request that in future
documents a more objective system be used such as the DWQ wetland rating system.
NCWRC.HCP,FALLS LAKE TEL:[phone] Feb 14'97 13:46 No.004 P.04
Memorandum 2 February 14, 1996
We found no mention of strcam channel impacts. The dOCument did state that
there would be 31 new strcam crossings on the preferred alternative. This indicates that 2
strcam channel modifications will likely be necessary. We anticipate that with tite new
COE and DWQ regulations, stream mitigation will be required and tray add significant
casts to the project. Stream channel modifications are of particular concern on tributaries
of Naked Freak.
At this time, we concur with the FEIS for this project. We anticipate an
opportunity to comment on the `404' permit for this project. In final design, NC:DOT
should avoid and minimize wetland impacts where possible. This should he documented
and supplied with the permit application.
Thanl< you ('or the opportunity to review and comment on this FETS. If we can
further assist your office, please contact, David Cox, Highway Project Coordinator, at
[phone].
cc: t1SFV+iS, Raleigh
Scott fcT.endon, USACOF., Wilmington
State of North Carolina
Department of Environment,
Health and Natural Resources •
Division of Forest Resources
mom
James B. Hunt, Governor p E
Jonathan B. Howes, Secretary
H N FZ
Stanford M. Adams, Director
Griffiths Forestry Center
2411 Old US 70 West
Clayton, North Carolina 27520
January 31, 1997
MEMORANDUM
TO: Melba McGee, Office of Legislative Affairs'
FROM: Don H. Robbins, Staff Foresterw1pe
SUBJECT: DOT FEIS for US220 Bypass on New location from Emery to south of Ellerbe in
Montgomery'and Richmond Counties
PROJECT #: 97-0454 and TIP# R-2231
DUE DATE: 2-12-97
We have reviewed the above subject document of October 1996 and have the following
comments :
1. The Eastern Alternative (Preferred Alternative) is a revision of the East Alternative and will
impact a total of 357 acres of woodland plus 24.7 acres of wetlands of which some are
woodland.
2. Even though the impact to woodland has been reduced by 78 to 222 acres depending upon
other non-selected alternatives, we are still concerned due to the fact that 357 acres of
woodland will be lost to highway construction. The situation would have been worse, if the
other alternatives had been selected.
3. Page 6-15, DOT's response to our comment #29 indicates, " ...Though some of the areas
classified as agricultural in the DEIS are in fact devoted to silviculture, these stands are at
present very immature and the conversion to highway ROW through these stands would
result in minimal loss of timber."
Our response to this - We highly value these young pine plantations as the future supply
of timber and we hate to lose them to highway construction. DOT should regard these
young immature stands according and should attempt to avoid them if at all possible.
4. Page P-2 and P-3 under Environmental Commitments does = indicate that the ROW 13
Contractor will attempt to salvage all forest wood products for pulpwood, chips, poles and
sawtimber if at all possible. We highly recommend that salvage be attempted.
PC: Mike Thompson and Warren Boyette - CO
Ken Jeffries - R2
Dave Andres - D-3 and staff
File
P. O. Box 29581, Raleigh, North Carolina 27626-0581 N f C An Equal Opportunity Affirmative Action Employer
Voice 919-733-2162 FAX [phone]. recycled/ 10% post-consumer paper
x
State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
Kerr T. Stevens, Director
May 18, 1999
MEMORANDUM
To: Melba McGee
Through: John Dorne
From: John Hennes ??--
Subject: Comments on the EA for the I-73/I-74 improvements from US74 in Rockingham (R-512)
to US 220 Ellerbe Bypass (R-2231), Richmond County, Federal Aid Project # NHF-220
(4), State Project # 8.1580802, TIP Project # R-3421, DENR Project Number 99E-0668
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. Since the preferred alternative has not been selected, the proposed impacts to
jurisdictional wetlands and streams have not been finalized. However, the range of anticipated impacts is
2.3 acres and 1.8 acres of impacts to wetlands for Alternative C and A-C, respectively. Moreover, the
anticipated impacts to streams is 12,160 LF and 11,900 LF for Alternatives C and A-C, respectively. The
DWQ offers the following comments based on review of the aforementioned document:
A) 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) 1.
B) In accordance with the NCDWQ Wetlands Rules 115A NCAC 2H.0506(b)(6) 1, 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 NCDWQ Wetlands Rules 115A NCAC 211.0506 (h)(3) ), the
Wetland Restoration Program may be available for use as stream mitigation.
Q 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.
D) Sediment and erosion control measures should not be placed in wetlands.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
Mr. William D. Gilmore memo
05/18/99
Page 2
E) Borrow/waste areas should avoid wetlands to the maximum extent practicable. Impacts to
wetlands in borrow/waste areas could precipitate compensatory mitigation.
F) 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 the creek. Instead, stormwater should be designed to drain to a properly
designed stormwater detention facility/apparatus.
G) There should be a discussion on mitigation plans for unavoidable impacts. If mitigation is
required, it is preferable to present a conceptual (if not finalized) mitigation plan with the
environmental documentation. While the NCDWQ realizes that this may not always be practical,
it should be noted that for projects requiring mitigation, appropriate mitigation plans will be
required prior to issuance of a 401 Water Quality Certification.
H) Future documentation should include an itemized listing of the proposed wetland and stream
impacts with corresponding mapping.
1) Based on the information presented in the document, the magnitude of impacts to wetlands and
streams will 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 and inclusion of appropriate mitigation where necessary.
The NCDWQ appreciates the opportunity to provide comments on your project. Should you have any
questions or require any additional information, please contact John Hennessy at [phone].
cc: Dave Timpy, Corps of Engineers
Tom McCartney, USFWS
David Cox, NCWRC
Ken Averitte, NCDWQ Regional Office
C:\ncdot\TIP R-3421\comments\ R-3421 comments.doc
r
Fax:[phone]

Aug 25 '99 1302 P.01
STATE -OF NORTH CAROLINA
DEPART[VIENT OF TRANSPORTATION
JAMES B. HUNT JR. P.O. BOX 25201, RALEIGH, N.C. 27611-5201 DAVID MCCOY
GOVERNOR SECRETARY
PROJECT DEVELOPMENT &'ENTVIRON MENTAL ANALYSIS BRANCH
FAX COVER SHEET
DATE: Z<'?' Ig??
NCDOT/P&E BRANCH
s
Please deliver the following pages to:
Name-
Name: t-Mess
Name: Dggu; r _.-
Pax: 91C> W 7.5-1 L407,5-
Fax: 9 [Cl - x133 1196-11
Fax: III - 57_4b.._., g4W3
Name: or• A a ` Fax:-11'9 - `` i4ET&
This Telecopy is being sent by:
Name: ?? ?'-??+r•se T`
Phone Number:
Remarks:
Number of Pages (Including Cover'.Sheet):
If you do not receive all.pages clearly; cail:(,920) 733-3141 as soon as possible_
Project Development & Environmental Analysis Branch Fax Number: [phone]
PHONE [phone] FAX(919)733A150
NCDOT/P&E BRANCH Fax:[phone] Aug 25 '99 13:03
ti
?•M w s \
STATE OF NORTH CAROLINA,
DEPARTMENT OF TRANSPORTATION
JAMES B. HUNT JR. P.O. BOX 25201, RALEIGH; N.C. 27611-5201
GOYMNOR
August 25, 1999.
MEMORANDUM TO: Dave Timpy, USACE
John Hennessy, NCDWQ
David Cox, NCWRC
Tom McCartney, US.FWS
PROM: Jim HausetZ:5?.
Natural Systems Unit
P. 02
DAVID MCCOY
SBCRETARY
SUBJECT: Concurrence on avoidance and minir zation for proposed
US 220 Ellerbe bypass, Richmond County; TIP R-2231;
State Project No. 8.T550803.
The North Carolina Department of Transportation (NCDOT) would like to seek
concurrence from the agencies listed above concernimg our avoidance and minimization
efforts for the proposed US 220 Ellerbe bypass in Richmond County, TIP R-2231. Based
on comments made during the site visA on July 20-21,1999, NCDOT's Hydraulics
Design Unit and Roadway Design Unit are evaluating recommended avoidance and
minimization options. We will forward the results of these evaluations to you when they
are completed, and at that time would request final concurrence on avoidance and
minimization efforts so that we may proceed to the.purchase of right of way. If you have
any questions or need additional information, -please contact me at 733-7844 Extension
279,
cc: Charles Bruton, NCDOT
PHONE [phone] FAX[phone]
2 - 2z3 / , 14s Z20

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State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
JamesB. Hunt, Jr., Govemor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
MEMORANDUM
To: Melba McGee
Through: John Dorn
From: Cyndi Bell G [f
February 7, 1997
A14 411 0
?EHNR
FAXED
FES 0 61997,
Subject: Final Environmental Impact Statement for US 220 from Emery to South of Ellerbe
Montgomery and Richmond Counties
State Project DOT No. 8.1550801, T.I.P. No. R-2231
EHNR # 97-0454, DWQ # 11496
The subject document has been reviewed by this office. The Division of Water Quality (DWQ) is
responsible for the issuance of the Section 401 Water Quality Certification for activities which impact
waters of the state including wetlands. The project will impact up to 25.76 acres of jurisdictional
wetlands. Impacts to surface waters at stream crossings and a farm pond were not quantified. DWQ
offers the following comments based on the document review:
A) In the Draft Environmental Impact Statement (DEIS) submitted July 15, 1991, NCDOT
described three study corridors (Western, Middle, and Eastern) in addition to the No-Build
Alternative. DWQ had substantial objections to NCDOT's preferred (Eastern) alternative, and
expressed our preference for the Middle Alternative in our October 7, 1991 written response to
the DEIS. Subsequently, NCDOT has made significant efforts to modify the Eastern Alternative
to reduce its potential wetland impacts. NCDOT states that the preferred alternative now has
"lesser impacts to bottomland and upland hardwood and pine-hardwood forests, lesser impacts to
high quality wetlands, and lower cost." Wetlands within the Eastern Alignment study area were
delineated so that NCDOT could develop a preliminary design specifically addressing avoidance
and minimization of wetland impacts within the footprint of the study corridor. The stated
purpose of this methodology was to obtain concurrence from the U.S. Army Corps of Engineers
that the selected alternative would meet the Step-Down Procedure. Based on this information,
DWQ can also agree that the preferred alternative is the most practical alternative considering
the various environmental, socioeconomic and design constraints involved with this project. We
appreciate NCDOT's efforts to conduct extensive up-front studies and modify the alignment,
where necessary. However, NCDOT is reminded that issuance of a 401 Water Quality
Certification will be contingent upon avoidance, minimization, and mitigation of all wetland and
surface water impacts, including stream crossings and channel changes. During the permitting
process, the document will need to be supplemented with information pertaining to surface water
impacts in order for DWQ to fully endorse the selected alternative. This'information is outlined
below:
Environmental Sciences Branch • 4401 Reedy Creek Road Raleigh, North Carolina 27607
Telephone [phone] FAX # [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10 % post consumer paper
Ms. Melba McGee Memo
February 7, 1997
Page 2
1) The FEIS states that 31 new stream crossings will be required to construct the Eastern
Alternative. The document does not include the linear feet or area of streams to be
placed in culverts or diverted by channel changes. This information must be included
with the permit application and drawings. During the detailed design process, we
encourage NCDOT to place stream crossings (bridges or culverts) perpendicular to
stream channels to minimize impacts, if at all possible. DWQ will be happy to consult
with NCDOT throughout this process to help ensure protection of these streams.
NCDOT is reminded that stream mitigation may be required in accordance with current
DWQ Wetland Rules 115A NCAC 2H.0506(b)(6)) which were not in effect at the time
the EIS was prepared. We recommend that NCDOT coordinate with DWQ prior to
application for 404/401 Permits in order to discuss the potential need for a stream
mitigation plan.
2) A "large" farm pond will also be drained and partially filled. NCDOT should consult
with DWQ prior to application for 401 Water Quality Certification to discuss
applicability of our Pond Policy (in accordance with 15A NCAC 2H.0506(b)) to this
project. This policy is currently undergoing internal review within DWQ and may be in
effect prior to the construction date of the US 220 Relocation.
3) The preferred alignment will impact approximately 25.76 acres of jurisdictional
wetlands at 30 locations along the project corridor. In the EIS, it is stated that the
proposed work will likely qualify for Nationwide Permits 14 and/or 26, based on the fact
that all impact sites will occur above headwaters, and no single impact site exceeds two
acres. NCDOT should note that restrictions on "stacking", or repeated use of a
particular Nationwide permit for a single project, may apply under the revised 1997
Nationwide Permits. In such a case, the Corps may require application for an Individual
Permit. Furthermore, in a Permit Review Agency Meeting held May 18, 1995, NCDOT
agreed to submit a single application for the entire project, as included in this EIS. At
that time, NCDOT also committed to including a comprehensive wetland mitigation
proposal with the permit application. The FEIS includes a Draft Conceptual Wetland
Mitigation Plan with general guidelines for the types of mitigation which may be
proposed for this project. NCDOT is reminded that the new DWQ Wetland Rules 115A
NCAC 21-1.0506 (h)(2)} include specific requirements for mitigation plans and ratios
based upon the distance of impact areas from surface waters. NCDOT is advised to
consult with the COE and DWQ prior to submittal of the 404/401 permit application in
order to develop a comprehensive application, including all wetland and stream impacts,
with corresponding mitigation. The mitigation plan will need to include a specific
property(ies), with plans for said property(ies), and monitoring/remediation
methodologies.
Ms. Melba McGee Memo
February 7, 1997
Page 3
4) Reference NCDOT's Guidelines for the Location and Design of Hazardous Spill Basins
(May 2, 1996), which state that these basins will be provided at stream crossings located
within one half mile of the Critical Area of a water supply source and on all streams
designated as ORW or WS-I. Please ensure that each of the 31 proposed stream
crossings has been examined with respect to these guidelines. It is unclear from the EIS
whether or not this was done. For example, the Environmental Commitments section
includes plans to provide spill basins at Rocky Ford Branch (Wetland Z) and at a single
Naked Creek unnamed tributary crossing. However, the Preferred Alternative
discussion states that the Rocky Ford Branch crossing will not even be required. We
ask that NCDOT determine whether or not any of the 31 stream crossings will require
placement of hazardous spill catch basins in accordance with NCDOT's guidelines.
The number of catch basins installed at any given crossing should be determined by the
design of the crossing, so that runoff water would enter said basin(s) rather than directly
flowing into the stream.
B) We wish to thank NCDOT for providing a comparison of impacts for the preferred alternative
based upon median widths of 70 feet, 60 feet, and 46 feet. In the FEIS, DOT stated that the final
design will likely incorporate a 70 foot median throughout most of the 16.2 mile project. The
suggested 60-foot and 46-foot median widths would result in reduced wetland impacts of 23.85
and 22.70 acres, respectively. NCDOT is reminded that the 70-foot median will necessarily
involve more mitigation for stream and wetland impacts, and may even cause some crossings to
exceed the 150-foot minimum threshold at which stream mitigation will be required.
C) We wish to thank NCDOT for shifting the alignment of the Eastern Alternative so that the Rocky
Ford Branch wetlands could be avoided. This has reduced the overall wetland impact of the
project by approximately 5.3 acres.
D) DWQ requests that NCDOT ensure that the sediment and erosion control measures are not
placed in wetlands. This commitment should be incorporated into the construction contract
awarded for this project.
E) DWQ asks that NCDOT stipulate that borrow material will be taken from upland sources in the
construction contract awarded for this project.
F) The EIS refers to the comparison of "relative quality" among the studied wetlands as a valid
criterion in evaluating design alternatives. It is stated that qualitative determinations were based
on subjective ratings determined by NCDOT's consultant, and that no formal evaluation system
was used to determine "low, medium and high" quality wetlands. Specifically, it appears that
"lower quality wetlands" were defined as headwater wetlands (page 6-11). This statement is
particularly disturbing, given that headwater wetlands are among the most critical in terms of
water quality (DWQ Report No. 93-01, May, 1993). In the future, NCDOT is strongly
encouraged to utilize DWQ's Wetland Rating System to discuss the comparative qualities of
wetlands. Without a quantitative system with repeatable results, there will be no consistency in
comparing project alternatives or discussing appropriate mitigation.
Ms. Melba McGee Memo
February 7, 1997
Page 4
Based upon the wetland impacts described in the EA, General Certifications 3103 and 3108 will likely be
applicable to this project. Final permit authorization will require formal application by NCDOT and
written concurrence from DWQ. Please be aware that this approval will be contingent upon evidence of
avoidance and minimization of wetland and stream impacts to the extent practical, and provision of
wetland and/or stream mitigation where necessary.
DWQ appreciates the opportunity to provide comments on the Final EIS. DOT is reminded that issuance
of a 401 Water Quality Certification requires satisfaction of water quality concerns, to ensure that water
quality standards are met and no uses are lost. Questions regarding the 401 Certification should be
directed to Cyndi Bell at [phone] in DWQ's Water Quality Environmental Sciences Branch.
cc: Scott McLendon, COE, Wilmington
Cynthia D. Sharer, P.E., NCDOT, P&E
Michelle Suverkrubbe, DWQ
R2231EIS.DOC
R-2231, US 220 in Richmond and Montgomery Counties
and
R-1030, US 117 in Wayne and Wilson Counties
AGENDA
March 31, 1998
Purpose
As we all know, the NEPA process has changed. These two projects are caught between the old
process and the new. The planning documents for these two projects were done regarding the old
regulations but must be permitted under the new regulations. One reason for today's meeting is to
aid in the transition of these projects. We are providing an update on the two projects as relates to
wetland and stream impacts. We would like your advice regarding what is needed or must be done
to obtain concurrence.
Another reason for this meeting is to implement as standard practice an additional environmental
coordination step. Today's meeting will serve as a pilot to this new step. We envision this step as
the ideal time to discuss and resolve project changes that would cause major design revisions such
as alignment shifts or change in interchange configurations. It would be far more efficient to
implement these major changes prior to the purchase of R/W.
We would also welcome your comments relative to this pilot environmental coordination step.
Project Background and status.
Fortunately, a lot of effort and work has gone into minimization of wetland impacts during the
early stages. The wetland boundaries have been located, verified and GPSed during the Planning
Document phase. The alignments were shifted and modified to minimize impacts based on these
limits. These same wetland limits are on the current design plans. We only have updated plans on
portions of the project and not the complete project and it is these updated portions that will be
primarily discussed. We would like to explore the available permit options, phased permit
perhaps.
R-2231
A. Project Breakdown map
B. Environmental commitments
C. Wetland impacts; per Planning Document and current information
D. Stream impacts
E. Current Mitigation plan
F. Discussion
BREAK
R-1030
A. Project Breakdown map
B. Environmental commitments
C. Wetland impacts; per Planning Document and current information
D. Stream impacts
E. Current Mitigation plan
F. Discussion
6. Summary
What do you like and dislike about today's meeting?
What improvements should be made?
What do you like and dislike about the projects?
What must be done to make the projects pemittable, etc.?

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R-2231 RICHMOND & MONTGOMERY COUNTIES ,,jkiR?;=J ?6??N
US 220 Bypass MAI'
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Section 2.0 of the FEIS identifies the Preferred Alternative for the proposed project. This section includes the
justification for the selection of the Preferred Alternative along with reasons for elimination of the other alternatives.
The Section 3.0 details intensive environmental evaluations conducted along the Preferred Alternative. These include
revised air quality and traffic noise evaluations based upon design year 2020 traffic forecasts, wetlands delineations,
and protected species surveys. The Wetlands Delineation Report is contained in Appendix A, the protected species
Biological Evaluation is contained in Appendix B, the air quality modeling input and results are contained in
Appendix C, and the draft Conceptual Wetlands Mitigation Plan is contained in Appendix E of this report. Sections
4.0 and 5.0 detail the wetlands and floodplain findings, respectively, for the Preferred Alternative.
Mitigation measures for impacts and environmental commitments associated with the Preferred Alternative are
addressed in Section 6.0 of the FEIS. These mitigation measures are compiled from Section 4.10 of the DEIS and
from agency correspondence received and coordination conducted throughout the study process.
Public and agency involvement is addressed in the Section 7.0 of the FEIS. Information concerning the Corridor
Public Hearing is presented along with summaries of verbal and written public comments regarding the DEIS. In
addition, substantive comments made by the various federal, state, and local agencies and officials concerning the
DEIS are provided with specific responses. Copies of all agency correspondence are provided in Appendix D to this
document.
A reevaluation of the DEIS was prepared due to the extended time between the DEIS and the FEIS. A copy of the
reevaluation is included in Appendix F.
ENVIRONMENTAL COMMITMENTS
The North Carolina Department of Transportation makes the following commitments with respect to the avoidance
or minimization of major environmental impacts during design, construction, and maintenance of this project:
NCDOT will minimize long-term water quality impacts through the use of the NCDOT "Best Management
Practices for Protection of Surface Waters".
The more stringent erosion control measures required by Rule 0.0201(d)(2)(A) and (B) of 15 NCAC
213.0201 will be followed within the Naked Creek and Rocky Ford Branch Watershed (outstanding resource
waters) crossed by the Preferred Alternative.
The Preferred Alternative will be designed to avoid or minimize to the extent practicable the jurisdictional
. wetlands delineated within the corridor. The wetland mitigation plan will be developed in consultation with
the appropriate regulatory agencies.
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NCDOT will construct a hazardous spill catch basin at. the Rocky Ford Branch crossing (Wetland 'Z') and
at the crossing of the Naked Creek Tributary northeast of Norman (Wetland 'S').
• Underground storage tank sites will be avoided to the extent practicable. Where sites can not be avoided,
testing and removal will be accomplishPa' in accordance with 40 CFR Part 280 and I SA NCAC 12(n). Am
required site remediation will be accomplished in accordance with NC Department of Environment, Health,
and Natural Resources "Guidelines for Remediation of Soil Contaminated by Petroleum".
• Impacts to the Sandhills Gamelands will be avoided by the Preferred Alternative.
• All structures will be designed so as not to cause a significant increase in the upstream 100-year flood
elevation.
• NCDOT commits to funding the relocation of geodetic control monuments affected by the project.
• NCDOT will consider the use of landscaping as a noise abatement measure.
• NCDOT will implement the last resort housing program, if necessary, as mandated by state law.
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From: Scott C McLendon [Scott.C.Mclendon*SAW02.usace.army.milj
Sent: Friday, February 13,1998 1:02 PM
To: Return requested; Return requested; Return requested; Return requested
Subject: R-2231, Relocation of US 220, Montgomery and Richmond County
Dear Colleague,
Pursuant to the interagency agreement to integrate Section 404 with the NEPA process, I
have been requested by Ms. Cindy Sharer of the North Carolina Department of
Transportation to concurr and/or comment regarding the minimization of impacts to waters
and wetlands relative to the above referenced project.
It is my understanding that on May 18, 1995, at the monthly agency coordination meeting,
information was provided by NCDOT and their consultant regarding the minimization of
wetland impacts along the preferred alternative for this project. It may be helpful to refer to
your notes and meeting minutes. If you do not have these minutes, please let me know and I
will provide them to you.
As the last agency involvement was nearly three years ago, it may be appropriate to convene
the review team with NCDOT to review minimization of impacts. If you feel that this is
necessary, please let me know by March 13, 1998. If you feel that your minimization
requirements have been met, you concurence should be provided by the above date as well.
Responses may be sent by fax [phone]), e-mail (scoff c
[e-mail]), ortelephone (910-251-4725)
Sincerely,
Scott McLendon
N-CW`'kC, HCP, FALLS
TEL:[phone] Feb 14'97 1355 No.005 P.02
LAK
F!ai Noah Car(
TO;
FRAM:
512 N. Salisbury
Melba M
Office; of
Wildfe Resources commission n
Raleigh, North C=11na 27"4185, 919-7333391
!& R.Mwood, Executive Director
and Legislative Affairs, DEHNR
David COX, 'Highway Project Co rna r
Habitat Conservation Program i- . -01
DATE: February 14, 1997
SUBJECT: Final Envircynmental Impact Statement (FEIS) for the US 220
improvemegts, from Emery to south ofElIerbe, Montgomery and
Richmond counties, North Carolina. TIP No. R-2231, SCH Project No.
97-0454.
Staff biologists with the N. C. Wildlife Resources Commission (NCWRC:) have
reviewed the subject FEIS and are familiar with habitat values in the project area. The
purpose of this review wasp assess project impacts to fish and wildlife resources. Our
comments are provided in abcordance with certain provisions of the National
Environmental Policy Act (42 U.S.+C. 4332(2)(e)) and the Fish and Wildlife Coordination
Act (48 Stat. 401, as amended; 16 U.S.C. 661-6674).
'1'hc proposed project involves the construction of a four-lane divided highway on
new location from the intersection of four-lade US 220 and SR 1448, south of Ellerbe,
and travels eust of existing i7S 220 for approximately 14 miles before crossing to the west
of US 220 north ot'Norinan. The preferred alternative is approximately 16.2 miles in
length.
The subject document adequately discusses benefits, social impacts, and traffic
anal sis of the 11nal build alternatives. The document also adequately describes
anti ipated impacts to natural resources from construction of the eastern alternative.
We appreciate that slight alignment shifts were made that reduced wetland
impacts by approximately 5 acres. 1110 comparison of wetland impacts for different
median widths was also helpful. Since total wetland impacts are projected to be 24.72
acres we will recommend that this project be authorized under a single individual `404'
permit. We are concerned about the subjective rating system used to judge the relative
values of the wetland sites crossed by the alternatives. We request that in fi,ture
documents a more objective; system be used such as the DWQ wetland rating system.
.NC@RC,HCP,FALLS LAKE TEL:[phone] Feb 14'97 13:56 No.005 P.03
Memorandum 2 February 14, 1996
We found no mention of stream channel impacts. The document. did state that
there would be 31 new stream crossings on the preferred alte=rnative. This indicates that
stream channel modifications will likely be necessary. We anticipate that with the new
CUE and DWQ reg-ulations, stream mitigation will be required and may add significant
costs to the project. Stream channel modifications are of particular concern on tributaries
of Naked Crock.
At this time, we concur with the FEIS for this project. We anticipate an
opportunity to connnent orb the `404' permit for this project. In final design, NCDOT
should avoid and minimizd wetland impacts where passible, This should be documented
and supplied with the pcrm"tt application.
Thank you for the o portunity to review and comment on this FE, is. If we can
further assist your office, p
(919) 528-9$$6?ase contact, David Cox, Highway Project Coordinator, at
.
cc: LlSFWS, Raleigh
Scott Mc f,endon, UtS11COE, Wilmington
I
..tea
JAMES B. HUNT JR.
GOVERNOR
MEMO TO: Mr.
Mr.
Mr.
Mr.
Ms.
Mr.
Mr.
Ms.
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
P.O. BOX 25201. RALEIGH. N.C. 27611-5201 E. NORRIS TOLSON
SECRETARY
Mike Bell (COE)
Roy Shelton, PE(FHWA)
Scott McClendon (COE)
Marshall Clawson, PE
Cindy Bell (DWQ)
David Cox (WRC)
Howard Hall (Fish & Wildlife)
Robin Little
Ms. Cindy Sharer, PE(
FROM: Dewayne L. Sykes, PE -(?.?,,?
Project Engineer
DATE: March 4, 1998
SUBJECT: Project 8.1550802 (R-2231) Montgomery-Richmond Counties
Project 8.1330502 (R-1030) Wayne-Wilson Counties
In accordance with the new Project Development Process, we have
scheduled a meeting on March 31, 1998, with the Corps of
Engineers and.other agencies in reference to coordination of
wetland mitigation. The purpose of this meeting is to discuss
the minimization of wetland impacts and to determine the status
of the wetland mitigation study. The meeting will be at the
Highway Design Conference Room.
The meeting is scheduled as follows:
• 9:00am -10:30am TIP Project R-2231- US 220 Bypass from Emery
to Ellerbe
• 10:30am-12:30pm TIP Project R-1030- US 13.7 from S of NC 581
at Goldboro to Proposed US 264 Bypass
I request that each of you attend this meeting or have a lease
representative attend for you. If you have any question, please
call me at [phone].
DLS/ear
cc: Frank Vick, PE
Tom Shearin, PE
Harry Thompson, PE
David Snyder, PE(FHWA)
Felix Davila, PE(FHWA)
Steve Chapin (COE)
Gail Grimes, PE

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