R4440 (12)

412 Thunder Creek
Franklin, NC 28734
September 27, 2010
.lamille A. Robbins
NCDOT-Human Environment Unit
1548 Mail Service Center
Raleigh, North Carolina
27699-1598
Dear Mr. Robbins,
Our family has lived for nearly 30 years in very close proximity to the Needmore Tract and
proposed Needmore Road Project ( SR 1364 and SR 1369)(T,I, P. R 4440). We have paddled,
hiked and bicycled this area and use it almost weekly because of its untouched natural beauty. I
think it is very important that this area be protected and encourage NCDOT to drop their plans
for paving improvements to this area, and consider only Alternative A or B. As you know most
all of the road is in a permanent conservation easement as part of the Needmore Tract. Clearing
nearly 20 acres within this permanently conserved 300' buffer is not keeping with the intent of
the establishment of this conservation area.
The stated need and purpose lacks sufficient documentation. You state that one of your main
goals is to improve the quality of travel, but then never define what you mean by quality of
travel. Who are you trying to improve quality of travel for? 1 feel that you need to collect better
data to document who is using this road, for I believe many of the people using this road are
recreationists who have come to this area for its natural beauty and the quality of travel that
exists now with the dirt road closely following this unusual stretch of river. If NCDOT
accomplishes its statewide mission every road in NC will eventually be paved over, and the rural
character which a dirt road like this provides will be extinct.
Based on your traffic safety analysis it appears that the accident rate for this road is very low. It
seems likely with a paved and straighter road that the volume of cars using this stretch will
increase, with a resulting higher incident of crashes. Why didn't you include any data with
projected increase in crashes as a result of paling improvements? In the NC Wildlife Resources
Commission comments they state that "we are concerned that any improvements that increase
travel speed or increase traffic on this roadway will decrease roadway safety and the safety of
recreational users of the Game Land."
I just finished a bicycle trip through the Great Smokies and that area also has beautiful creeks
and rivers, but the experience is so diminished because of the constant volume of traffic. Paving
this road will certainly bring a new flock of tourists to this relatively untouched area and with
time it will be become just another overused river' corridor.

You mention a project need of reducing existing sedimentation from the Needmore Road.
However, little factual data is presented to support this goal. Many of the agencies, such as US
Fish and Wildlife, contend that the majority of the sedimentation is coming from above Franklin
and only a minimum amount as a result of the dirt road. The fish population is very healthy in
this area and wouldn't be such if sedimentation was a huge problem in this area. In Fish and
Wildlife's Comments on the EA they state that "part of the justification for paving the road is to
reduce sediment inputs to the river. However,-there are no data to support the idea that paving
will eliminate sediment from the river. No specific sources of sediment from the road have been
identified nor are there river reaches ill the project area where sediment has been demonstrated to
have significantly negatively altered habitat."
In EPA's review comments they state that "Paving the existing roadway will do little or nothing
to improve the existing flooding and sedimentation problem." According to NC Wildlife
Resources comments submitted on May 25, 2010 "paving alternatives may exchange
sedimentation impacts for pollutant impacts from other sources."
So far as improving system linkage we already have HWY 28 which connects off of four lane
19/74. I use and travel both of these roads and feel there is no need to spend 13 million dollars to
possibly save 5 minutes in travel time!! Based on system linkage I wonder whether NCDOTS's
real intent is to create a super highway through this area connecting Knoxville, Graham County,
and Franklin to Atlanta. I certainly hope not.
Your last stated purpose and need "to avoid or minimize adverse impacts to the existing high
quality natural resources including but not limited to water quality, habitat and vegetation," is
confusing to say the least. This high natural resource area will be best protected by leaving in its
existing protected state.
You mention reducing existing maintenance costs associated with the Needmore Road ($207,000
per year), but don't give an estimate of the annual cost associated with maintenance of a paved
road, especially one that will continue to flood and have extensive annual damages. It would
seem that the expense of repairing a flooded paved roadway would be very high and that such
data would need to once again be studied more thoroughly.
I was very disappointed to read your basis for state environmental assessment in your EA report
on pages 66 and 67, "The proposed project will cause no significant changes in route
classification or land use and is not controversial in nature. The project has been reviewed by
federal, state, and local agencies and no major objections have been raised. No major objections
to the project were voiced at the citizen informational workshop held on Dec. 2, 199. For these
reasons, it is concluded that an Envirdim ental'Assessment is applicable to this project." You
know that there is much opposition from the public and agencies concerning Alternatives C, D
and E. When you write such a dishonest statement concerning objections, it only continues to
erode public trust. How can I feel that other data in the EA report is truly accurate when you
make such a blatantly inaccurate statement?
Do you realize that you contradict yourself on public objections on page 1 of the EA, where you
state that 120 people attended the Citizen Information Workshop in 1999 and comments and
petitions were split evenly between favoring and opposing the project? This clearly contradicts
the assertion that no major objections were raised.
I have read the merger agencies comments on.the,EA and there are major objections to the
proposed project. In EPA's April 23 comment letter they state that "Considering the limited
scope of the proposed project, it has been relatively controversial with resource agencies
considering the context sensitive location of the project, the very high quality of the natural
resources that will be impacted and the very low traffic volumes associated with existing
Needmore Road." EPA, U. S. Fish and Wildlife, NC Wildlife Resource, and NCDENR all have
very serious concerns with Alternative E and express more interest in Alternative A or B.
Many of the agencies have submitted comments requesting additional data be supplied, tables
revised, etc in the EA. After NCDOT has completed this additional documented work. I am
formally requesting that the public cornment period be reopened. The current EA has significant
inconsistencies, inaccuracies and failures to provide sufficient depth of research, and the public
should have the right to comment on a fully updated and researched environmental document.
.
Alternative B should be explored in much more depth as the preferred alternative. Pennsylvania
Dirt and Gravel Roads has done extensive research into maintaining dirt and gravel roads and it
appears that there are several affordable, environmentally viable dust suppressants & road
stabilization methods that would protect the natural beauty of this river corridor at a very low
cost in comparison to the proposed $13 million project.
I have been attending Comprehensive Transportation meetings in Macon County and the goal is
supposedly to have the public more involved in selecting needed transportation improvements. If
this is the overall goal of NCDOT to increase public input then why have both public hearings
been in Swain County? Why is there a continual refusal to come to Macon County for a public
hearing? If NCDOT can spend a possible $13'inillion on paving 3.3 miles of dirt road, then I
would think you could afford a public hearing in both counties. I feel that you know there is
much greater opposition in Macon County,to.this road project and are attempting to diminish the
publicity of opposition. 'r
. ., , .
In concluding I encourage NCDOT to drop this project which has no factual documented need,
lacks the support of many local and recreational users of the road, and will have major negative
impact to the protected riparian buffer, as well as the river itself'. Quality of travel may actually
decrease with a more congested roadway,,higher probability of accidents, and the loss of the
natural beauty of this existing corridor due to the massive cuts and paving. I encourage NCDOT
to do more research into options A andB which seem to have the least impact on the quality of
natural resources. I hope that NCDOT will be fair and hold public hearings in both counties that
will be affected by this road project. If NCDOT truly wants to earn the trust of local communities
they need to be more accurate in their statements, such as in the EA, and do more reliable
research. Please reopen the public comment period, once the EA has been updated based on
agency requests.
Sincerely,

Trish Severin