20181192_Staff Comments_20100907

Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
September 7, 2010
MEMORANDUM
To: Christy Shumate, NCTA
From: Brian Wrenn, NCDWQ, Transportation Permitting Unit
Subject: Comments on proposed Purpose and Need Statement for the Triangle Expressway Southeast
Extension in Wake and Johnston Counties, TIP Nos. R-2721, R-2828, R-2829.
NCDWQ has reviewed the Draft Purpose and Need Statement for the subject project. Below are our
comments regarding the Draft Purpose and Need statement:
1. In Section 2.2 summary of Need for Proposed Action, Need #3, contains the following language in
the last paragraph:
Dee Freeman
Secretary
"This type of congestion is not consistent with the purpose of the State's Strategic Highway Corridors
Initiative, which is to provide a safe, reliable, and high-speed network of highways."
Strategic Highway Corridor (SHC) initiatives are not appropriate problem statements for Purpose and
Need statements. The problem is previously identified in Needs #1, #2, and earlier sections of Need
#3. Any reference to SHC initiatives should be removed from the Purpose and Need Statement.
2. In Section 2.3 Purpose of Proposed Action, the opening paragraph details the purpose statement. It
includes language regarding improving mobility in the study area. It was explained in the August 10,
2010 that the study area (for traffic analysis purposes) is bigger than the project study area (for
alternatives analysis purposes). Use of such similar terminology is confusing. NCDWQ recommends
that a clearer distinction be made between the traffic study area and the project study area.
3. In Section 2.3.2 Measures of Effectiveness for Meeting the Project Purpose, NCTA provides four
measures for measuring the effectiveness of alternatives to meet the project purpose. NCDWQ is in
agreement with these metrics. In Handout #2, NCTA provides criteria for alternatives screening. The
screening criteria are different from the Measures of Effectiveness in Section 2.3.2, and include
references to the SHC initiative and system linkage, neither of which is included in the project
purpose. The screening criteria should not include language that references desired outcomes of the
project. Desired outcome criteria should only be considered when analyzing detailed study
altematives at later stages of the selection process. The alternatives screening criteria should mirror
the measures of effectiveness stated in the Draft Purpose and Need statement.
Transportation Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
Loca`:ion: 2321 Crabtree Blvd„ Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: http:llh2o emstate.nc.uslncwetlandsl
One
hCarolina
Nort
Naturally
An Equal Opponunity 1 Affirmative Action Employer
Thank you for requesting our input at this time. NCTA is reminded that issuance of a 401 Water Quality
met and designated uses are not degraded or lost. If you have any questions or require additional
information, please contact me at 919-733-5715 or 336-771-4952.
cc: Eric Alsmeyer, US Army Corps of Engineers, Raleigh Field Office
George Hoops, Federal Highway Administration
Chris Militscher, Environmental Protection Agency (electronic copy only)
Travis Wilson, NC Wildlife Resources Commission
File Copy