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HomeMy WebLinkAbout20150955 Ver 1_EPA Comments_20120413 (2)U.S. Environmental Protection Agency Region 4 Raleigh Office Terry Sanford Federal Courthouse 310 New Bern Avenue Raleigh, North Carolina 27601 April 13, 2012 Dr. Gregory J. Thorpe, Ph.D. Manager, Project Development and Environmental Analysis Unit North Carolina Department of Transportation 1548 Mail Service Center Raleigh, North Carolina 27699 -1548 SUBJECT: Federal Environmental Assessment, Topsail Island Bridge Replacement, Surf City, Pender County, TIP No: B -4929 Dear Dr. Thorpe: The U.S. Environmental Protection Agency (EPA) has reviewed the subject document and is providing comments in accordance with Section 309 of the Clean Air Act and Section 102(2)(C) of the National Environmental Policy Act (NEPA). The North Carolina Department of Transportation (NCDOT) and the Federal Highway Administration (FHWA) are proposing to replace Bridge No. 16 over the Intercoastal Waterway, in Surf City, Pender County. The proposed project is included in the NEPA/Section 404 Merger process. EPA has been an active participant and concurred with the purpose and need, Concurrence Point 1, on August 20, 2009. Detailed study alternatives (DSAs) to be carried forward, Concurrence Point 2, was agreed to on December 14, 2010. EPA's detailed technical review comments on the Federal Environmental Assessment (EA) are attached to this letter (See Attachment A). EPA has not identified environmentally preferred alternative at this time from the seven (7) Detailed Study Alternatives (DSAs) under consideration and will work with the other Merger team agencies on the selection of the Least Environmentally Damaging Preferred Alternative (LEDPA) at the Concurrence Point 3 meeting. We appreciate the opportunity to review this document and request a copy of the Finding of No Significant Impact (FONSI) when it becomes available. Please feel free to call me should you have any questions concerning these comments at 919 - 856 -4206 or 404 -562 -9512. Thank you. Sincerely, Christopher A. Militscher, REM, CHMM Merger Team Representative FOR: Heinz J. Mueller, Chief NEPA Program Office USEPA Region 4 Cc: C. Coleman, FHWA B. Shaver, USACE D. Wainwright, NCDWQ S. Sollod, NCDCM w /Attachment Attachment A Detailed Technical Comments Topsail Island Bridge Replacement Federal EA for TIP No: B -4929 Pender County, N.C. Evaluation of the Environmental Impacts from the Detailed Study Alternatives Seven (7) Detailed Study Alternatives (DSAs) were carried forward for study in the Environmental Assessment (EA), including Alternatives 44, 45, 45R, 46, 47, 411, and 417. All of the DSAs include a new bridge over the Intercoastal Waterway. DSA 45R has substantially higher impacts to residences and businesses than the other DSAs (i.e., 413 and 47, respectively). DSA 46 has the least impact to existing residences and businesses at 0 residential relocation and 1 business relocation. Table 5 -13 of the EA also includes total property impacts for each DSA. Vacant property `impacts' are a routine cost - related effect of the transportation agencies building new roadways and bridges. However, the DSAs with the least number of vacant property impacts (i.e., DSA 46 and 47), actually have the greatest estimated costs (i.e., $93,719,530 and $101,319,530, respectively). Conversely, the DSA with the greatest number of vacant property impacts (i.e., DSA 417 — 43) has the least total project costs (i.e., $57,372,278). The information on vacant property impacts are not typically included in NEPA document summary impact tables. EPA is unsure as to the relevance of providing this information in the summary impact table. Potential impacts to jurisdictional wetland resources for the seven (7) DSAs as referenced above are 1. 1, 1. 1, 1. 1, 0, 0, 1.0 and 0.8 acres, respectively. DSA 46, 47 and 417 have potential impacts to 03, 0. 1, and 0.4 acres, respectively to CAMA regulated wetlands. With the exception of DSA 46 and 47, all of the other DSAs have jurisdictional impacts of a similar magnitude (approximately 1 acres or less). All of the DSAs have a Section 4(f) adverse effect to the existing historic Topsail Bridge No. 16. DSA 46 and 47 also have a potential Section 4(f) effect to the Soundside Park (i.e., 0.03/0.4 acres and 0.01/0.4 acres; permanent /temporary impacts). All of the DSAs have a `May Affect — Not Likely to Adversely Affect' (MA -NLAA) determination for two Federally - protected species. Impacts to Terrestrial Forest communities are identified in Table 5 -2 of the EA. The estimated impacts from the DSAs range between 0.1 acres for DSA 47 to 3.6 acres for DSA 411. DSA 411 has 1.5 acres of impact to mesic mixed hardwood forests. Considering the past substantial loss of these types of coastal terrestrial communities from development, and in consideration of other jurisdictional and human resources impacts, DSA 411 is EPA's least preferred alternative. DSA 411 also includes 4 residential relocations and 1 business relocation and impacts the Faith Harbor United Methodist Church property.