20120285 Ver 1_Alternatives Report_20090909

�J Turnpike Authority
Gaston East-West Connector
Gaston and Mecklenburg Counties
STIP No. U-3321
Preferred A/ternative Report
September Q 2009

TABLE OF CONTENTS
�
PAGE
1.0 Project Description ............................................................................................1
1.1 Proposed Action ........................................................................................1
1.2 Project Purpose and Need ..........................................................................1
1.3 Project Status ..........................................................................................2
1.4 Detailed Study Alternatives ........................................................................2
1.5 Summary of Impacts .................................................................................3
1.6 Recommended Alternative .........................................................................3
2.0
3.0
.�
Overview of Open Houses and Public Hearings ......................................................5
Summary of Previous Agency Coordination Meetings ..............................................7
Minimization Efforts and Impact Reductions ........................................................11
5.0 Summary of Comments Received Related to the Draft EIS and Selection of the
Preferred Alternative .......................................................................................
5.1 Responses to Generalized Comments on Purpose and Need ........................
5.2 Responses to Generalized Comments on Travel Times and Traffic Forecasts..
5.3 Responses to Generalized Comments on Range of Alternatives ....................
5.4 Responses to Generalized Comments on Air Quality ...................................
5.5 Responses to Generalized Comments on Water Quality and Jurisdictional
Resources.............................................................................................
5.6 Responses to Generalized Comments on Indirect and Cumulative Effects and
Wildlife.................................................................................................
5J Responses to Generalized Comments on Cultural Resources, Community
Characteristics, and Farmland .................................................................
12
14
16
17
20
22
23
25
6.0 Summary of Design Comments ......................................................................... 26
6.1 Design Comments Received from the Public and Interest Groups ..................26
Matthews Acres Access Road ..................................................................27
Pam Drive and Saddlewood Drive ...........................................................27
Land North of Interchange at Robinson Road ............................................27
Wilson Farm Road just South of Union Road .............................................27
Carolina Speedway on NC 274 ................................................................28
Interchange at NC 273 ..........................................................................28
Sunderland Road/Allison Street at NC 273 ............................................... 28
Boat Club Road and Access to Optimist Club Fields ...................................28
I-485 Interchange Area ......................................................................... 29
General Pedestrian and Bicycle Access Comments .....................................29
Access to South End of Bay Shore Drive ..................................................29
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TABLE OF CONTENTS
PAG E
6.2 Design Comments Received from Agencies and Local Governments .............. 30
US 29-74 Interchange ........................................................................... 30
Interchanges at Robinson Rd, Bud Wilson Rd, NC 274, NC 273, and I-485... 30
Interchange at Bud Wilson Road .............................................................30
Future Belmont-Mt. Holly Loop ...............................................................30
Access to Charlotte-Douglas International Airport Area .............................. 30
Mainline Typical Section ......................................................................... 31
7.0 Traffic Forecasts ..................................................................................... 31
LIST OF TABLES
Table 1. Public Participation Summary for Pre-Hearing Open Houses and Public Hearings...6
Table 2. Summary of Agency Coordination Meetings ......................................................8
Table 3. Impact Reductions Associated with Bridge Crossings ....................................... 11
Table 4. Summary of Comments Received Related to the Draft EIS and Selection of the
Preferred Alternative .................................................................................... 12
Table 5. Year 2030 Traffic Volumes Along the Detailed Study ....................................... 31
APPENDICES
Appendix A.
Appendix B.
Appendix C.
Appendix D.
Appendix E.
Appendix F.
Figures S-la and S-lb from Draft EIS - Map of Detailed Study Alternatives
Summary of Environmental Impacts
Comments from State and Federal Agencies
Comments from Local Governments
Comments from Interest Groups and Organizations
Comments Responding to USACE Public Notice
iii
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1.0 PROJECT DESCRIPTION
1.1 Proposed Action
The North Carolina Turnpike Authority (NCTA) proposes to construct a project known as the Gaston
East-West Connector, which would be a controlled-access toll road extending from I-85 west of
Gastonia in Gaston County to I-485 near the Charlotte-Douglas International Airport in
Mecklenburg County.
The project is included in the North Carolina Department of Transportation (NCDOT) 2009-2015
State Transportation Improuement Program (STIP) as STIP Project U-3321. The project is known as
the "Gaston East-West Connecto�' and as the "Garden Parkway." This study refers to the project as
the Gaston East-West Connector.
1.2 Project Purpose and Need
The purpose of the proposed action is to improve east-west transportation mobility in the area
around the City of Gastonia, between Gastonia and the Charlotte metropolitan area, and
particularly to establish direct access between the rapidly growing areas of southeast Gaston County
and western Mecklenburg County. The primary needs for the project are summarized below:
• There is poor transportation connectivity between Gaston County and
Mecklenburg County and within southern Graston County.
• Limited crossings of the Catawba River constrain travel between Gaston and
Mecklenburg Counties. No crossings are located in southern Gaston County.
• Projected growth in southern Gaston County and western Mecklenburg County will
continue to increase demands for accessibility and connectivity between the two
counties.
• Within southern Gaston County, south of I-85, a lack of connecting east-west
roadways makes travel circuitous and limits mobility.
• The GUAMPO and the MUMPO include a new location roadway running through
southern Gaston County and connecting over the Catawba River to Mecklenburg
County in their long range transportation plans.
• The Gaston East-West Connector is a state-designated Strategic Highway Corridor,
envisioned as a new freeway facility on the Strategic Highway Corridors Vision Plan.
• There are existing and projected poor levels of service on the Project Study Area's
major roadways.
• Traffic volumes are projected to increase on I-85, I-485, US 29-74 and US 321 in the
Project Study Area through 2030.
• There are existing poor levels of service on segments of I-85 in Gaston County; from
Exit 19 (NC 7[Ozark Avenue]) through Exit 27 (NC 273 [Park Street]).
• Levels of service on I-85, US 29-74 and US 321 are projected to worsen in the future.
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• Congestion and frequent incidents on I-85 inhibit regional travel and diminish the
ability of I-85 to function as a Strategic Highway Corridor and Intrastate Corridor.
Several performance measures were used in the first screening of various alternative concepts to
evaluate their ability to meet the project's purpose, including the east-west mobility and direct
access components as stated above. To evaluate their ability to meet the purpose and need,
alternative concepts were evaluated to determine whether they would:
• Reduce travel distances and/or travel times between representative origin/destination
points within southern Gaston County andbetween southern Gaston County and
Mecklenburg County.
• Provide a transportation facility with a mainline that would operate at acceptable levels
of service (generally LOS D or better on the mainline) in the design year (2030) for
travel between Gaston County and Mecklenburg County.
• Reduce congested vehicle miles traveled and/or congested vehicle hours traveled in
Gaston County compared to the No-Build Alternative in 2030.
1.3 Project Status
The Draft Environmental Impact Statement for the Gaston East-West Connector (STIP Project U-
3321) was signed on Apri124, 2009 and made available for public and agency review on NCTA s
website on May 1, 2009. A notice of availability was published in the Federal Register on May 22,
2009 (Vol. 74, No. 98, pg. 24006). The public comment period for the project ended on July 21, 2009.
The remainder of the project schedule is as follows:
4rh Quarter 2009 Selection of Preferred Alternative
2�d Quarter 2010 Final EIS published
4rh Quarter 2010 Record of Decision (ROD) published
lst Quarter 2011 Construction begins
4rh Quarter 2014 Project open to traffic
The Gaston East-West Connector project is located in the Charlotte-Gastonia-Rock Hill air quality
region (Metrolina region). The Metrolina region continues to face challenges in meeting the
requirements of federal air quality laws. These requirements do not prevent ongoing studies from
continuing, but they have the potential to delay federal approval of transportation projects in the
region, including the Gaston East-West Connector. To prevent such delays, federal and state air
quality and transportation agencies are continuing to work together to resolve the air quality issues
so that planned transportation projects can move forward. FHWA and NCTA will provide an
updated summary of the region's conformity status in the Final EIS (See also May 20, 2003 FHWA
memorandum regarding clarification of conformity requirements).
1.4 Detailed Study Alternatives
There are twelve Detailed Study Alternatives (DSAs) considered in the Draft EIS: DSAs 4, 5, 9, 22,
23, 27, 58, 64, 68, 76, 77, and 81. These DSAs are controlled-access toll facilities on new location.
Figure S-la and S-lb from the Draft EIS shows the DSAs in detail, and are included in
Appendix A.
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The mainline design speed is 70 miles per hour (mph), with a planned posted speed limit of 65 mph.
Each DSA currently is proposed to have ll to 12 interchanges (depending upon the DSA), as listed
below from west to east.
• I-85
• US 29-74
• Linwood Rd (�R 1133)
• Lewis Rd ��R 1126� �D�Ad
58, 64, and 68 only)
• US 321
• Robinson Rd (SR 2416)
• Bud Wilson Rd (SR 2423)
• NC 274 (Union Rd)
• NO 249 (�outh New Hope Rd)
• NO 243 (�outhpoint Rd)
• Dixie River Rd (SR 1155)
• I-485
In addition to the twelve new location build DSAs, the No-Build Alternative was retained to provide
a baseline for comparison with the DSAs, in accordance with National Environmental Policy Act
(NEPA) regulations (40 CFR Part 1502.14(d)) and FHWA guidelines (Technical Advisory T 6640.SA;
Section V.E.l). The No-Build Alternative assumes that the transportation systems for Gaston and
Mecklenburg counties would evolve as currently planned in their respective Long Range
Transportation Plans, but without the Gaston East-West Connector or major capacity improvements
to I-85 or to US 29-74. However, the No-Build Alternative would not meet the project's purpose and
need.
Each of the build DSAs are toll alternatives and tolls would be collected by an electronic toll
collection (ETC) system. There would be no cash toll booths.
1.5 Summary of Impacts
The Draft EIS provides detailed discussions of the project's anticipated impacts to the human,
physical, cultural, and natural environments. The comprehensive impact summary table from the
Draft EIS is included in Appendix B.
1.6 Recommended Alternative
Based on the information available to date, including the Draft EIS, the FHWA, NCTA, and NCDOT
have identified DSA 9 as the Recommended Alternative in the Draft EIS. This alternative is
comprised of Corridor Segments H2A-H3-J4a-J4b-J2o-J2d-JX4-Jle-Jlf-KlA-K3A-K3B-K3C, as
shown in Figure S-la-b in Appendix A.
DSA 9 has been identified as the Recommended Alternative based on the following considerations.
Please note this list is not in order of importance, but is organized by issues as they are presented in
the Draft EIS. Also, this list does not represent all benefits or impacts of DSA 9, just those elements
that differentiated DSA 9 when compared to the other DSAs.
Cost and Design Considerations
• DSA 9 is one of the shortest alternatives at 21.9 miles (all alternatives range from 21.4 to 23.7
miles).
• DSA 9 has the second-lowest median total cost ($1,282 million) (all alternatives range from
$1,281 million to $1,378.4 million).
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Human Environment Considerations
• DSA 9 is one of the four DSAs with the fewest numbers of residential relocations at 348
residential relocations (the range being 326 to 384 residential relocations).
• Although DSA 9 is higher in the range of business relocations at 37 (the range being 24 to 40
business relocations), it would avoid impacts to Carolina Specialty Transport (provides
transportations services to special needs groups) that would occur under DSAs 58, 64, 68, 76,
77 and 81.
• DSA 9 is in the middle of the range of total neighborhood impacts at 25 impacted
neighborhoods (the range being 21 to 31 impacted neighborhoods).
• DSA 9 would have no direct impacts to schools. (DSAs 5, 23, and 27 also avoid direct impacts
to schools.)
• DSA 9 would not require relocation of known cemeteries (DSAs 27, 68, and 81 also would not
require relocation of known cemeteries.)
• At Linwood Road, DSA 9 is one of three alternatives (DSAs 4, 5, and 9) that would avoid
impacting either the Karyae Park YMCA Outdoor Family Center or the Pisgah Associate
Reformed Presbyterian Church (part of the church property is also an historic site eligible for
listing on the National Register of Historic Places).
• DSA 9 is one of the three alternatives (DSAs 4, 5, and 9) farthest from Crowders Mountain
State Park.
• DSA 9 would avoid right-of-way requirements from Daniel Stowe Botanical Garden. (DSAs 4,
22, 27, 58, 68, 76, and 81 also avoid these right-of-way requirements.)
• DSA 9 would avoid the relocation of Ramoth ANIE Zion Church and cemetery, which is part of
the Garrison Road/Dixie River Road community. (DSAs 4, 22, 27, 58, 68, 76, and 81 also
avoid this church.)
• DSA 9 is one of the eight alternatives (DSAs 4, 9, 22, 27, 58, 68, 76, and 81) with the least
amount of right of way required from future Berewick District Park in Mecklenburg County.
Phvsical Environment Considerations
• DSA 9 is in the middle range of estimated numbers of receptors impacted by traffic noise at
245 receptors (the range being 204 to 309 impacted receptors).
• DSA 9 is one of the alternatives (DSAs 4, 5, 9, 22, 23, and 27) that would impact the least
acreage of land in Voluntary Agricultural Districts. DSA 9 also is one that is expected to
have the least indirect and cumulative effects to farmlands.
• DSA 9 is one of the alternatives with the fewest power transmission line crossings at 14
crossings (the range being 13 to 18).
Cultural Resources Considerations
• DSA 9 is one of six alternatives (DSAs 4, 5, 9, 22, 23, and 27) that would not require right of
way from the Wolfe Family Dairy Farm historic site. Selection of DSA 9 makes it more likely
that, if the US 321 Bypass is constructed at some future time, the project would also avoid
the Wo1fe Family Dairy Farm historic site.
• DSA 9 is one of four alternatives (DSAs 5, 9, 23, and 27) with low to moderate potential to
contain archaeological sites requiring preservation in place or complex/costly mitigation.
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Natural Resources Considerations
• DSA 9 is one of eight alternatives (DSAs 4, 9, 22, 27, 58, 68, 76, and 81) that would cross the
South Fork Catawba River and the Catawba River where the rivers have been more affected
by siltation and they are less navigable, and water-based recreation would be affected less
than with DSAs that cross farther south.
• DSA 9 would impact the least amount of upland forested natural communities at 882 acres
(all alternatives rangefrom 882 to 1042 acres).
• DSA 9 is one of the alternatives (DSAs 4, 9, 22, and 76) having the lowest potential to
indirectly affect upland wildlife species due to habitat fragmentation.
• DSA 9 is lower in the range of impacts to ponds at 41 acres (all alternatives range from 21 to
6.3 acres).
• DSA 9 is lower in the range of impacts to wetlands at 7.5 acres (all alternatives range from
6.9 to 13.2 acres).
• DSA 9 is lower in the range of impacts to perennial streams at 38,894 linear feet (all
alternatives range from 36, 771 to 50, 739 linear feet).
• DSA 9 would have the fewest number of stream crossings at 91 (all alternatives range from 91
to 120 crossings).
• DSA 9 is one of eight alternatives (DSAs 5, 9, 23, 27, 64, 68, 77, and 81) that have a biological
conclusion of No Effect relating to the federally endangered Schweinitz's sunflower.
2.0 Overview of Open Houses and Public Hearings
Four Pre-Hearing Open Houses and two Corridor Design Public Hearings were held in June 2009.
Formal presentations were made at the two Public Hearings by Steve DeWitt of the NCTA (June 23
and June 25) and David Bass of PBS&J (June 23) and Clint Morgan of PBS&J (June 25). Comment
sheets were made available at all Pre-Hearing Open Houses and Public Hearings and through the
project website. Table 1 summarizes the public participation for each meeting.
In addition to the activities above, a Local Officials Meeting was held from 1:00 PM to 2:30 PM on
June 22, 2009, at the Gaston County Police Department. All Pre-Hearing Open House materials
were available for their review and a presentation was made by Steve DeWitt. This meeting was
attended by 271oca1 officials.
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Table 1. Public Participation Summary for Pre-Hearing Open Houses and Public Hearings
Date June 22, 2009 June 23, 2009 lune 24, �une 25, 2009
2009
Type of Meeting Pre-Hearing Pre-Hearing Public Pre-Hearing Pre-Hearing Public
Open House Open House Hearing Open House Open House Hearing
Presentation Presentation
Workshop Workshop Workshop Workshopand
Components and slide and slide and formal and slide slide and formal
comment comment
presentation presentation period Presentation presentation period
Gastonia Southpoint
Adult Forestview Forestview High �lympic High Olympic
Location Recreation High School, High School, School, High School,
Center, Gastonia Gastonia School, Charlotte Charlotte
Gastonia
Belmont
2:30 — 2:30 — 7:00 — 2:30 — 2:30 — 7:00 —
Time
6:30 PM 6:30 PM 10:15 PM 7:30 PM 6:30 PM 8:30 PM
Numberof Zg� 352 �700 191 57 85
Attendees**
Numberofspeakers N/A N/A 53 N/A N/A 29
(verbal comments)
Number of written Included Included
comments received at 25 59 with open 28 5 with open
workshop/hea ring house tota I house tota I
" Not inclutling NCTA, NCDOT, FHWA antl Consulting Statt in attentlance. Number ot attentlees estimatetl basetl on those who registeretl on
attendance sheets forthe Pre-Hearing Open House and an approximate head munt forthe Public Hearings.
The Draft EIS comment period was from May l, 2009 to July 21, 2009. As of midnight, July 22,
2009, a total of 256 written comment forms/letters/emails have been received, along with 7
resolutions and 3 petitions. There were 82 speakers at the Public Hearings (please note that there
were seven people who spoke at both Public Hearings). They were counted as individual speakers at
each meeting because they provided different comments at each Hearing). Comments are
categorized asfollows:
• 153 comment forms
• 63 emails
• 141etters from citizens
• 7 comment letters from interest groups/organizations
o Catawba Riverkeeper
o Connect Gaston
o Gaston Together
o Ed Eason (citizen with strong interest in air quality)
o Southeast Connector Coalition
o Stopthetollroad.com (Mr. Bill Toole)
o Southern Environmental Law Center
• 19 comment letters from federal, state, and local agencies
• 82 speakers from the two formal Public Hearings.
• 7 resolutions (all supporting the Garden Parkway)
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3 petitions (note: the petitions were not reuiewed for duplicates or ualidity of signatures)
o Over 7,000 Signatures (Approximate) —Opposed to the Garden Parkway —submitted
by Bill Toole of stopthetollroad.com
0 275 Signatures — Opposed to the Garden Parkway —submitted by the Harrison
Family.
0 109 Signatures — Oppose Segment KXl due to potential impact to Mt. Pleasant
Baptist Church Cemetery—submittedby Barbara Hart. (SegmentKX1 not apart of
DSA 9, the Recommended Alternatiue. Howeuer, Segment K3A, which is a part of
DSA 9 has the same preliminary design footprint in the area of the Mt. Pleasant
Baptist Church cemetery. A memo dated August 15, 2008, was sent to Ms. Hart
describing impacts to the Mt. Pleasant Church property. The preliminary engineering
designs would not impact the area of the cemetery where there are e�isting marked
grauesites.)
While selection of a Preferred Alternative is not by popular vote, it is noted that of the 153 comment
forms and 63 emails received, 58 were specifically in favor of the project and/or selection of Detailed
Study Alternative (DSA) 9, and 129 were specifically opposed to the project overall and/or selection of
DSA 9. Please note that most comments received did not state a DSA preference, but the majority
was against the project. Generally, of the public comments received, there were twice as many
commenters who stated they opposed the project compared to those who supported the project.
Based on a review of the comments, listed below, in no specific order, are general issues that were
found to be frequently stated in the comments received.
• A new connection across the river is needed.
• DSA 9 is a reasonable choice.
• The road will encourage needed economic development.
• The project should provide sidewalks at cross streets.
• Ending the project at US 321 will adversely impact traffic on this overcrowded roadway and
will bring trucks through the historic York-Chester neighborhood.
• The Garden Parkway will only benefit developers and land owners, especially David Hoyle
and Robert Pittenger.
• The Garden Parkway costs too much, and this money should be spent on education.
• The Garden Parkway is not the best use of taxpayer dollars.
• Air quality is bad in the region and this project will not help.
• The Garden Parkway will spur more development and urban sprawl. There will not be
enough money to build schools and other facilities associated with development.
• This project will change the rural character of Gaston County that the residents have chosen.
• This road will be another Greenville, South Carolina, Toll Road.
3.0 SUMMARY OF PREVIOUS AGENCY COORDINATION MEETINGS
Agency coordination meetings have been held throughout the project development process to receive
comments on project studies, achieve concurrence points, and solicit issues and concerns from the
Agency Coordination Team. The North Carolina Department of Transportation (NCDOT) held
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meetings with the NEPA/404 Merger Team from 2002 through 2005 to achieve Concurrence Points 1
and 2.
The NCTA initiated regularly scheduled monthly meetings, referred to as Turnpike Environmental
Agency Coordination (TEAC) meetings, to review the status of the current NCTA projects,
environmental concerns, and permitting requirements. TEAC meetings regarding the Gaston East-
West Connector have been held from 2006 through 2008. In addition, NCTA held two meetings to
discuss the scope of the indirect and cumulative effects analysis (June 29, 2007, with US Fish and
Wildlife Service (USFWS) and NC Wildlife Resources Commission (NCWRC), and July 26, 2007,
with NC Division of Water Quality (NCDWQ)).
The first and second screenings of alternatives were originally discussed with the environmental
resource and regulatory agencies through the NEPA/404 Merger Ol Process under the
administration of the NCDOT. A series of eight meetings regarding project alternatives were held
from February 2004 through September 2005, resulting in concurrence on the DSAs on September
20, 2005. At that time, three agencies (US Environmental Protection Agency [USEPA], [USFWS],
and [NCWRC]) elected to abstain, rather than expressing concurrence or non-concurrence in the
DSAs.
After the initial concurrence was achieved on the DSAs in September 2005, the FHWA and NCTA
reevaluated the alternatives screening process in light of the project being determined a candidate
toll facility and the receipt of updated travel demand forecasts. The FHWA and NCTA coordinated
with the environmental resource and regulatory agencies on this reevaluation at several TEAC
meetings held in January, June, and September 2007, and February, July, September and October
2008. The environmental resource and regulatory agencies confirmed concurrence on the DSAs at
the October 2008 TEAC meeting, and the concurrence form is included in Appendix A-1 of the Draft
EIS. The three agencies that previously had abstained, the USEPA, USFWS and NCWRC,
concurred at this stage along with all the other cooperating and participating agencies.
Table 2 is from Section 9.2 of the Draft EIS and provides summaries of the TEAC meetings held for
the Gaston East-West Connector project.
Table 2: Summary of Agency Coordination Meetings
Meeting Main Topic Summary of Meeting
Date
NEPA/404 Merger Team Meetings held by NCDOT
OS/15/02 CP 1 Purpose The preliminary Purpose and Need Statement was presented for discussion.
and Need Additional information was requested.
07/24/02 CP 1 Purpose and Need The revised Purpose and Need Statement was presented and concurrence was
achieved.
02/17/04 Pre-CP 2 Identified new location alternativesfor which NCDOT should prepare
functional designs priortothe new location CP 2 meeting.
The purpose ofthis meeting wasto achieve concurrence on the non-new
locationalternativestobecarriedforwardfordetailedstudy. Agreementon
08/17/04 Partial CP 2 eliminating the Improve Existing Roadways Alternatives could not be reached,
and the decision was made to follow the process outlined in the NEPA/404
Merger Ol Memorandum of Agreement (MOA) for elevating the decision.
09/14/04 Elevation Meeting ril The MergerTeam members attended. Concurrence was not achieved.
The supervisors ofthe MergerTeam members attended. Concurrence was not
09/29/04 ElevationMeetingri2 achieved.
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Table 2: Summary of Agency Coordination Meetings
Meeting Main Topic Summary of Meeting
Date
In accordance with the MOA, the Review Board met to discuss the project and
10/27/04 Elevation Meeting ri3 the issues thatthe MergerTeam had not reached consensus on. The Review
(Review Board) Board consists of designated senior managementfrom FHWA, NCDOT, USACE,
andNCDENR.
Elevation Meeting ri4
02/08/OS (Review Board) The Review Board metto continue discussion of project issues.
Late Elevation Meeting ri5 The Review Board met and signed the Partial CP 2 form eliminating all non-new
June/Early (Review Board) location alternativesfrom further study.
July 2005
The purpose ofthe meeting wasto decide which of the 90 preliminary new
location alternatives should be carried forward forfurther study. The
preliminary new location corridors were narrowed to 16 DSAs (later reduced to
12 DSAs). The FHWA, NCDOT, USACE, NCDWQ, SHPO, GUAMPO, and MUMPO
signed the CP 2 form. The USEPA, USFWS, and NCWRC chose to abstain from
signing. An abstention in the NEPA/404 Ol Merger process meansan agency
09/20/OS CP 2 Meeting does not actively object to a concurrence milestone, but does not wish to sign
the concurrence form. The agency agrees notto revisitthe concurrence point
subject to guidance on revisiting concurrence points contained in the
NEPA/404MergerOlMemorandumofAgreement. Representativesofthese
agencies provided emails with their reasons for abstaining. These are included
in Appendix A-1.
TEAC Meetings and Indirect and Cumulative Effects (ICE) Scoping Meetings held by NCTA
12/15/06 TEAC - Project Status Update This meeting was held to discuss Section 6002 Coordination Plans and to
Meeting provide an update on the status of project-related studies.
The following topics were discussed: Section 6002 Coordination Plans, historic
architecture resources, archaeological resources, bald eagle surveys, mussel
TEAC-ProjectStatusUpdate surveys,wetlandandstreamsurveysandmitigation,preliminaryengineering
Ol/25/07 designs, hydraulic studies,traffic operations analysis, geotechnical studies of
Meeting the Allen Steam Station fly ash basin, schedule for design tasks, status of the
project in the NEPA process, DSAs, traffic and revenue study, Charlotte-Douglas
International Airport expansion, and mobile source airtoxics (MSATs).
The purpose ofthis meeting wasto provide updates on recently
completed/ongoing environmental and technical studies, field verification
TEAC- Project Status Update meetings, and next stepstoward Draft EIS. Completed surveys discussed were:
03/22/07 bald eagles, wetlands and streams, biotic communities, historic architectural
Meeting resources, and archaeological resources. The NCTA requested comments,
issues, and concerns from the agencies regarding environmental issues related
to the recently completed studies and ongoing studies.
Issues covered in this meeting included the decision to studytoll-only
alternatives in the Draft EIS, the completed Phase II historic resource surveys
TEAC- Project Status and the archaeological resource surveys, field verification meetings for
06/20/07 wetlands, streams, and ponds, and other updates on special technical studies,
Meeting indirectandcumulativeeffectsassessment,engineeringdesigns,community
characteristics,andtolltrafficforecasts. NCrAreviewedtheGUAMPO's
resolution to change the name of STIP Project U-3321 to the Garden Parkway.
06/29/07 Indirect and Cumulative This meeting was held with the USFWS and NCWRCto discussthe scope ofthe
Effects Scoping Meeting indirect and cumulative effects study.
07/26/07 IndirectandCumulative ThismeetingwasheldwiththeNCDWQtodiscussthescopeoftheindirect
Effects Scoping Meeting and cumulative effects study.
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Table 2: Summary of Agency Coordination Meetings
Meeting Main Topic Summary of Meeting
Date
This meeting provided updates on recentlycompleted and ongoing
environmental technical studies, recent correspondence with Duke Energy
Corporation supporting elimination of detailed study corridor segment K1D,
and next steps toward the Draft EIS. The NCTA requested comments, issues
and concernsfrom the agencies. Topics covered in the meeting included a
summary of draft versions of the Noturol Resources Technicol Report (NRTR), a
09/27/07 TEAC-ProjectStatusUpdate summaryoffindingsfromtheDroftCommunityChoroderisticsReport(CCR),
toll traffic forecasting studies, and information related to the Duke Power Allen
Steam Station flyash basin. The attendees agreed that DSAs containing
Corridor Segment K1D (DSAs 6, 24, 65, and 78) should be eliminated from
further study due to interference with critical operations at Allen Steam
Station. Attendees included representativesfrom FHWA, USACE, USEPA,
NCDWQ, NCWRC, USFWS, NCDOT, and NCTA.
The purpose ofthe site visit was to reviewthe various natural communities
12/17/07 TEAC - Project Site Visit represented in the study area at locations requested by the resource agencies.
12/18/07 Representativesfrom FHWA, NCDOT, USACE, USEPA, NCDWQ, and NCWRC
attended the field tour over the two-day period.
The primary purpose of this meeting was to discuss the approach to be taken
to discuss CP 2a. The attendees agreed that it was acceptable to move forward
02/OS/08 TEAC-Approach to with bridging decision discussions. Other items discussed were the Section
Discussing CP 2a 6002 Project Coordination Plan, updatestothe draftversions of the Purpose
ond Need Stotement and the Alternotives Developmentond Anolysis Report
Addendum, and planned Citizens Informational Workshops.
The purpose ofthe meeting wasto discuss information to achieve
03/04/08 TEAC-CP2aDiscussion agreement/concurrenceonthebridgingdecisionsforstreamsandwetlands
crossed by the DSAs (CP 2a).
Agreement on bridging and alignment decisionsforthe DSAs was reached at
04/08/08 TEAC- CP 2a Agreement this meeting. Attendees included representativesfrom FHWA, USACE, USEPA,
USFWS, NCWRC, NCDOT, and NCTA.
This meeting covered the analysis and results in the Droftlndirectond
CumulativeEffectsAssessment(ICEJ,luly2008. Alsopresentedwerethe
TEAC - Indirect and Updoted Purpose ond Need Stotement, lune 2008 a discussion of items
07/07/08 Cumulative Effect updated and added in the Addendum to the Finol Alternotives Development
Assessment and Other Issues ond Evoluotion Report, luly 2008, an update on the status of the Section 6002
Coordination Plan forthe project, and an announcement of upcoming Citizens
Informational Workshops scheduled for August 2008.
TEAC - Section 6002 This meeting was held to provide the attendees a summary of the August 2008
Coordination Plan, Citizens Informational Workshop Seriesri3 and to discussthe updated Purpose
09/23/08 Comments on Reports, and ond Need Stotement, lune 2008, the Addendum to the Finol Alternotives
SummaryofWorkshop DevelopmentondEvoluotionReport,luly2008andthelndirectondCumulotive
Seriesri3Comments EffectsAssessment,luly2008.
TEAC - Section 6002 The Agency Coordination Team agreed to sign (or resign) CPs 1, 2, and 2a.
Coordination Plan, There were no abstentions. The Section 6002 Coordination Plan was approved.
There were no substantive comments on the Purpose ond Need Stotement,
10/07/08 Comments on Reports, and �une 2008, or the Addendum to the Finol Alternotives Development ond
SignaturesforCPl,2,and EvoluotionReport,luly2008The1ndirectondCumulotiveEffectsAnolysis,luly
Za 2008 was discussed, with additional review time requested bythe team.
Notes CP-ConcurrencePoint
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4.0 MINIMIZATION EFFORTS AND IMPACT REDUCTIONS
The DSAs incorporate measures to avoid and minimize impacts to Waters of the United States and
the Catawba River buffers. The horizontal alignment of the preliminary engineering designs was
adjusted where possible to minimize or avoid impacts to streams, wetlands, and ponds.
The presence of wetlands and streams, and minimizing or avoiding impacts to these resources, was a
factor in considering interchange configurations. Bridge lengths that were extended to maintain
roadway and railway access adjacent to the Catawba River and South Fork Catawba River also
avoided or minimized encroachment into Catawba River buffer areas.
To further address avoidance and minimization, the NCTA met with the environmental resource and
regulatory agencies at TEAC Meetings on February 5, March 4, and Apri18, 2008, to discuss
bridging and alignment decisions for the DSAs' preliminary engineering designs (Concurrence
Point 2a).
As a result of those meetings, there were no changes to the alignments of any of the DSAs. However,
the NCTA agreed to include several bridges in the preliminary engineering designs, beyond those
required to convey floodwaters, to avoid or minimize stream and wetland impacts. Table 3 shows
locations where bridges are recommended to avoid or minimize stream and wetland impacts, along
with the estimated impact reduction associated with each bridge.
Based on the information in the table, the additional bridging along DSA 9(Recommended
Alternative) reduced stream impacts by 940 linear feet and wetland impacts by 1.5 acres.
Table 3: Impact Reductions Associated with Bridge Crossings
DSASegmentand Previously ImpactAcreage�ac)/
Crossing Proposed Proposed Structure Linear Feet (If) as
DSAs Structure Previously Proposed
HD27—Bessemer H2A Triple7x10ft
Branch DSAs 4, 5, 9, 22, 23, 27 Box Culvert Bridge 340 If
HD32 H2C Bridgeover LengthenBridgetospan 3741f
Stream S70 DSAs 22, 23, 27 Chapel Grove Rd stream
HD17 HX2 Bridgeover LengthenBridgetospan 3501f
Stream S79 DSAs 76, 77, 81 Camp Rotary Rd stream
HD48 H3 Triple11x10ft 3041f—S135
Blackwood Creek DSAs 4, 5, 9 Box Culvert Bridge Z961f—S134
(5135)
1B2 13 and 12a Lengthen Bridge to span 1.7 ac (DSAs 22,23, 27)
Crowders Creek (S14) DSAs 22, 23, 27, 76, Bridge Vdetland 103 1.9 ac (DSAs 76, 77, 81)
and Wetland 103 77, 81
1D9 Jlc Triple 7x10 Box gridge 4781f
Stream 5178 DSAs 64, 68 Culvert
KD3 Lengthen Bridge to span
Catawba Creek K3A wetland W248 (also avoids
(5259) and its buffers 9, 27, 68, 81 Bridge buffers on east side of 1.5 ac
and Wetland W248 creek)
KD17 Lengthen Bridge to span
Catawba Creek K1B wetland W248 (also avoids
(5259) and its buffers 5, 23, 64, 77 Bridge buffers on east side of 1.2 ac
and Wetland W248 creek)
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5.0 SUMMARY OF COMMENTS RECEIVED RELATED TO THE DRAFT EIS AND
SELECTION OF THE PREFERRED ALTERNATIVE
This section discusses substantial as well as other comments relative to the Draft EIS and/or
selection of the Preferred Alternative. Comments received from state and federal agencies, local
governments, and interest groups and organizations during the comment period for the Draft EIS
are included in Appendices C, D, and E, respectively. Substantive comments received are grouped
under ten categories as listed in Table 4.
As of August 5, 2009, no written comments were received from the USACE, a cooperating agency.
USACE received four comment letters in response to their Section 404 public notice. Letters were
receivedby the USACE from Mr. John Medlin, Ms. Heather Pierce, Mr. Bill Toole, and the Southern
Environmental Law Center (SELC). Comments from these letters are summarized in Appendix F.
These four commenters also sent letters to the NCTA. The letter from SELC was the same as the
letter sent to the NCTA. The letters from Mr. Medlin, Ms. Pierce, and Mr. Toole were slightly
different. All relevant comments from these letters are included in Table 4 below.
Table 4. Summary of Comments Related to the Draft EIS and Selection of the Preferred
Alternative
Topic Comments
Purpose and Need • The project will not improve traffic flow on I-85, US 321, US 29 and US 74, and it may increase
(commentsreceived congestioninthefuture.
only from the public • The stated need to connect southern Gaston County and western Mecklenburg County is not
onthistopic) supportedbyquantifiabledata.
• The Draft EIS fails to show that an additional bridge over the Catawba River would respond to any
existing mobility need south ofthe existing bridges.
• NCrA cannot reconcile its mandate to build specific toll road projects with federal law.
• Ratherthan identifying an underlying purpose thatthe project mightfulfill,the Draft EIS restates
the specific project design that meets the NCTA's mandate to build the Garden Parkway toll road.
The resulting project purpose is too narrowto support consideration ofthe reasonable range of
alternatives required by NEPA.
TravelTimesand • TheDraftElStrafficprojectionspredictthatthenewtollhighwaywouldcausefurthertraffic
Traffic Forecasts congestion on much of I-85 and US 29/74.
• The Draft EIS presents inflated estimates of traffic volumes in the project area which make the
need for the connector seem greater than it is.
• There appears to be little to no change in travel time savings from most of Gaston County and the
project study area.
Range of • The Draft ElSdisregards the TSM and MassTransitAlternatives and did not provide a full range of
Alternatives reasonable alternatives.
• Objectives could be reached by improvements to I-85 (including widening and HOT lanes), interim
TSM approaches to US 29 and US 74, and other combinations of transportation improvements.
• The Draft ElSdid not consider improvements to the area's transit and freight rail facilities as an
alternative.
• The Draft EIS does not address how a combination of alternatives might be able to meet purpose
and need.
• The Draft ElSshould have studied endingthe project at US 321 if that is an interim phase.
• The decision to study only toll alternatives in the EIS is not consistent with the CEQ regulations at
40 CFR 1502.14(a) and (c). The EIS might have also considered a comparison with a freeway.
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Table 4. Summary of Comments Related to the Draft EIS and Selection of the Preferred
Alternative
Topic Comments
Air Quality • Prior to issuance ofthe FEIS and ROD, NCTA should demonstrate thatthe new location project will
be included in an approved SIP and will be in conformity.
• The Draft ElSdoes not address quantitative air quality impacts as they relate to Mobile Source Air
Toxics.
• TheDraftElSdoesnotofferanymitigationmeasurestoaddresstheproject'simpactonairquality,
specifically concerning MSAT emissions exposure at schools, hospitals, parks, etc.
• The EIS should address greenhouse gas emissions.
WaterQuality and • Concerns about sediment and erosion impacts that could resultfrom this project. Erosion control
Jurisdictional measures should adhere to the Design Standards in Sensitive Watersheds.
Resources • The possible effects of storm water runoff associated with this project could negatively affect the
project area.
• Concerns aboutthe amount of mitigation needed and that it will not be available in the area; every
effort should be made to further avoid and minimize impactsto streams and wetlands and to
provide on-site mitigation. Mitigation should focus on improving degraded streams in the area.
• Direct impactsto existing 303(d) listed impaired streams and other waters at riskfrom further
degradation have not been fullyaddressed from the standpoint ofavoidance and minimization
(e.g. right of way and median widths, shoulder widths, etc.).
• A conceptual mitigation plan should be provided in the Final EIS, with information about on-site
mitigation opportunities.
Indirect and • The Draft EIS has no specific discussion of mitigation for indirect and cumulative impacts.
Cumulative Effects • There are no quantitative data presented in the Draft EIS concerning potential ICE to wetlands,
streams, water quality and wildlife habitat.
• AquantitativelCEanalysisshouldbepreparedforthePreferredAlternative.
• TheGuidanceMemorandumtoAddressandMitigateSecondaryandCumulativelmpactsto
Aquatic and Terrestrial Wildlife Resources and Water Quality should be consulted when developing
mitigation measures.
Wildlife • Negative impactsto terrestrial resources and wildlife, includingfragmentation of terrestrial habitat,
are a significant concern.
Cultural Resources • The Draft EIS missed the subject of historic Stowesville, Stowes Factory, Gaither Mill, Stowesville
Cemetery, and the old Methodist church.
Community • EJ populations would receive a higher percent of impactfrom the newfacility in terms of air quality
Characteristics and noise impacts, but would not necessarily receive a proportionate benefitfrom the project due
to potential toll costs.
Farmland • The Draft EIS does not offer any potential avoidance and minimization measures to potentially
reduce impactstofarmlands.
• Concernsabouttheavailabilityofreplacementpropertyforfarmsthatneedtoberelocated.
The following additional studies will be completed and discussed with agencies prior to completing
the Final EIS:
• Updated traffic forecasts.
• Findings of detailed archaeological field surveys.
• Mainline and crossroad design refinements and associated changes in right of way and
impacts in response to comments on the Draft EIS, as well as addition and modification of
service roads.
• Additional indirect and cumulative effects analysis, including quantitative land use study for
the Preferred Alternative.
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• Conceptual mitigation plan, including options for onsite mitigation.
• Update on GUAMPO LRTP and MUMPO LRTP updates and Metrolina region air quality
conformity.
5.1 Responses to Generalized Comments on Purpose and Need
Comment: The project will not improue traffic fGow onI-85, US 321, US 29 and US 74, and it may
increase congestion in the future.
Response: Traffic forecasts and operations and regional travel demand statistics are described in
detail in Appendix C of the Draft EIS and in Section 2.2.6.3 (Improve Existing Roadways
Alternatives) and Section 2.2.7.2 (New Location Alternatives) of the Draft EIS. Appendix C includes
forecasts and operations analyses for I-85, US 321, and US 29-74.
As discussed in these sections, the Improve Existing Roadways Alternatives that include widening
I-85 would achieve only minimal improvements to traffic flow on I-85. A widened I-85 (widened to 8-
10 lanes) would continue to operate at LOS E and F in 2030. Most improvements to traffic flow
achieved by increasing capacity would be offset by the increase in traffic volumes attracted to the
facility. As shown in Table C-2 of Appendix C of the Draft EIS, an improved I-85 would attract an
additional 17 percent more vehicles per hour than the No-Build scenario. On the other hand, a New
Location Alternative would reduce traffic volumes on I-85 primarily from NC 279 eastward
compared to the No-Build Alternative, although levels of service would remain at LOS E or F in
2030. More importantly, however, the New Location Alternative provides an additional east-west
route between Gaston and Mecklenburg Counties that would operate at LOS C or better, which is a
traffic flow benefit that cannot be achieved under either the Improve Existing Roadways
Alternatives or the No-Build Alternative.
Levels of service along US 29-74 west of McAdenville would primarily be a LOS D or better and fall
to LOS F east of McAdenville. This would be true for both the No-Build and New Location
Alternatives. Along US 321, levels of service will be similar for all options; however, the New
Location Alternative may result in higher traffic volumes along US 321, south of the proposed
alignment, as vehicles use US 321 to access the New Location Alternative.
In considering regional statistics, comparisons of congested vehicle miles traveled (VMT) and
congested vehicle hours traveled (VHT) between the No-Build Alternative, Improve Existing
Roadway Scenario 4, and New Location Alternative (Toll Scenario) are made in Table C-1 of
Appendix C of the Draft EIS. The year 2030 congested VMT and congested VHT are highest for the
Improve Existing Roadways Alternative. The New Location Alternative (Toll Scenario) and the No-
Build Alternative result in about the same congested VMT and VHT, with the New Location
Alternative Toll Scenario performing slightly better, even with the expanded mobility and additional
roadway capacity provided by the project.
In conclusion, while existing and future deficiencies of I-85 and US 29-74 are acknowledged in the
Draft EIS, improving these specific roadways are not identified as purposes for this project. The
project purpose is to improve east-west transportation mobility in the area around the City of
Gastonia, between Gastonia and the Charlotte metropolitan area, and particularly to establish direct
access between the rapidly growing area of southeast Gaston County and western Mecklenburg
County. The Draft EIS adequately demonstrates that improving I-85 or other area roadways cannot
effectively meet this project purpose.
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Comments: 1) The stated need to connect southern Gaston County and western Mecklenburg County
is not supported by quantifiable data. 2) The Draft EIS fails to show that an additional bridge ouer
the CatawbaRiuer would respond to any existing mobility need south of the existing bridges.
Response: The need to connect southern Gaston County and western Mecklenburg County is
supported by the local land use plans and long range transportation plans and demonstrated by
travel demand modeling. Appendix B of the Draft EIS shows the Gaston Urban Area Metropolitan
Planning Organization's (GUAMPds) population projections for 2010, 2020 and 2030 from the 2030
Long Range Transportation Plan (LRTP). These indicate substantial increases in population in the
southern half of Gaston County will occur. Mecklenburg County is projected to continue to be the
economic and employment center of the region. Residential growth projected in southern Gaston
County and residential and employment growth in western Mecklenburg County will continue to
increase demand for improved connectivity and east-west mobility since there is a lack of east-west
routes in southern Gaston County and a lack of connections to Mecklenburg County.
Comments: 1) NCTA cannot reconcile its mandate to build specific toll road projects with federal
law. 2) Rather than identifying an underlying purpose that the project might fulfill, the Draft EIS
restates the specific project design that meets the NCTA's mandate to build the Garden Parkway toll
road. The resulting project purpose is too narrow to support consideration of the reasonable range of
alternatiues required by NEPA.
Response: The project purpose is stated in Section 1.3 of the Draft EIS: "The purpose of the
proposed action is to improve east-west transportation mobility in the area around the City of
Gastonia, between Gastonia and the Charlotte metropolitan area, and particularly to establish direct
access between the rapidly growing area of southeast Gaston County and western Mecklenburg
County."
Criteria used in the alternatives evaluation to determine whether a particular alternative concept
would meet the project purpose are listed in Section 2.21 of the Draft EIS:
• Reduce travel distance and/or travel times between representative origin/destination
points within southern Gaston County and between southern Gaston County and
Mecklenburg County.
Provide a transportation facility that would operate at acceptable levels of service
(generally LOS D or better on the mainline) in the design year 2030 for travel between
Gaston and Mecklenburg County.
• Reduce congested vehicle miles traveled and/or congested vehicle hours traveled in
Gaston County compared to the No-Build Alternative in 2030.
This project purpose does not include any statements that the purpose of the project is to construct a
toll facility.
A variety of alternatives could meet the criteria stated above. In accordance with Council on
Environmental Quality (CEQ) regulations (40 CFR 150214) and FHWA guidance and regulations
(FHWA Technical Advisory T6640.SA, 1987 and 23 CFR 771123), a reasonable range of alternatives,
including non-toll alternatives, were evaluated in Chapter 2 of the Draft EIS as well as the
Addendum to the Final Alternatiues Deuelopment and Analysis Report (October 2008) and eliminated
for a variety of reasons, as documented in that chapter.
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5.2 Responses to Generalized Comments on Travel Times and Traffic
Forecasts
Comments: 1) The Draft EIS traffic projections predict that the new toll highway would cause
further traffic congestion on much of I-85 and US 29/74, 2) The Draft EIS presents inflated estimates
of traffic uolumes in the project area which make the need for the connector seemgreater than it is,
and 3) There appears to be little to no change in trauel time sauings from most of Gaston County and
the project study area.
Response: In response to the first comment, please refer to the first commentMesponse under
Responses to Generalized Comments on Purpose and Need.
The comment regarding inflated traffic volumes in the project area refers to volumes reported for the
existing year 2006 in the Draft EIS as compared to traffic counts prepared by the North Carolina
Department of Transportation Transportation Planning Branch's Traffic Survey Group. The
commenters point out that the traffic volumes reported for I-85, US 321, and US 29-74 in the Draft
EIS are sometimes different, usually greater, than actual counts for the years 2006 and 2007.
At the time traffic forecast efforts began, NCTA s consultants obtained the approved Metrolina
Travel Demand Model for the13-county region surrounding Charlotte which was used to develop the
traffic forecasts for the project. Traffic forecasting methodologies and results are documented in the
Traffic Forecasting for Toll Alternatiues (MAB —August 2008). The version of the model used to
perform the project forecasts was calibrated based on known traffic volumes for the base year 2000,
with the model providing forecasts for years 2010, 2020, and 2030. Volumes for the project's base
year of 2006 were obtained by interpolating between the calibrated base year 2000 and the forecast
year 2010. Since the travel demand model was calibrated to 2000 traffic volumes, it can be expected
that actual counts for any given subsequent year could vary at some locations. A comparison of the
modePs 2006 results (Existing Conditions scenario) with actual 2006 traffic counts along I-85 show
that there is reasonably good correlation between the modeled and measured values for most of the
study area. Measured volumes are lower by about 7 percent or less west of Exit 26 (Belmont Mount
Holly Road), and lower by about 10-11 percent east of Exit 26. The model may have projected more
robust growth rates for the period 2000-2010 than what has actually occurred up to 2006, resulting
in lower actual traffic counts compared to forecasted values.
In conclusion, it could be expected that variations in economic and other conditions and swings in
growth rates would normalize over the course of the 30-year forecast. The majority of the analyses
reported in the Draft EIS, in particular those used to compare alternatives, were based on the 2030
forecasts, not the 2006 forecasts, and are reasonable values to use in the planning process.
Regarding travel times, two types of travel times are reported in the Draft EIS. One is the origin
and destination travel time estimate, reported in the Draft EIS in Section C.2 of Appendix C. The
other type is an average change in travel time and this is discussed in Section 7.51 of the Draft EIS.
Both are different outputs from the approved Metrolina Regional Travel Demand Model that were
used to forecast traffic for the proposed project.
The origin/destination travel time savings estimates are comparisons between the No-Build
Alternative for the year 2030 and the New Location Alternative (Toll Scenario) for the year 2030.
These travel times would not necessarily correlate to travel times experienced today. As shown in
Table C-4 in Appendix C of the Draft EIS, travel time savings under the New Location Alternative
for trips within Gaston County are greatest (8-9 minutes) for trips starting and ending in southern
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Gaston County, reflecting the increased mobility the proposed project would provide within southern
Gaston County. For trips between southern Gaston County and western Mecklenburg County, the
travel time savings would be greater, ranging from 9-28 minutes depending on origin and
destination (Table C-5 in Appendix C of the Draft EIS). These time savings are representative of
these specific trips. Travel times of other trips within the project study area may vary.
The second type of travel time reported is described in Section 7.51 of the Draft EIS. This travel
time (an output from the Metrolina Regional Travel Demand Model) is an overall travel savings
experienced by ALL trips in a particular traffic analysis zone (TAZ), whether those trips actually use
the proposed project or not. (Note: A TAZ is a delineated area used for tabulating traffic-related
data often corresponding to US Census tract and block group boundaries. The boundaries typically
follow physical features such as streets, riuers, or canals and are updated as part of the decennial
census.) Since this reported value includes many types of trips (through trips, local trips, trips that
use the proposed project, trips that do not use the project, home-to-work trips, home-to-shopping
trips, etc.), it would not be expected to show such dramatic savings as specific origin/destination
pairs. These calculations of average travel time savings provide a basis for assessing the overall
effect of the project on travel times in each TAZ and help to show locations that would experience
increase mobility. They do not represent travel time savings for specific origin/destination pairs and
would be expected to be smaller values. Results from this type of analysis show that average travel
time savings would be greatest for areas immediately surrounding the project in Gaston and
Mecklenburg Counties, then areas extending south into York County, South Carolina.
In conclusion, the travel time savings in 2030 realized by constructing the proposed project compared
to the No-Build Alternative would be substantial for many specific origin/destination pairs, and the
project also would have an effect on overall average travel times for trips throughout the project
study area.
5.3 Responses to Generalized Comments on Range of Alternatives
Comments: 1) The Draft EIS disregards the TSM and Mass Transit Alternatiues and did not
prouide a full range of reasonable alternatiues, 2) Objectiues could be reached by improuements to
I-85 (including widening and HOT lanes), interim TSM approaches to US 29 and US 74, and other
combinations of transportation improuements, 3) The Draft EIS does not address how a combination
of alternatiues might be able to meet purpose and need, and 4) The Draft EIS did not consider
improuements to the area's transit and freight rail facilities as an alternatiue.
Response: In accordance with 40 CFR 150214(a), agencies are required to: "Rigorously explore and
objectiuely eualuate all reasonable alternatiues, and for alternatiues which were eliminated from
detailed study, briefly discuss the reasons for their hauing been eliminated". The Draft EIS (Section
2.2) evaluated the full range of alternatives as required by 23 CFR 771123(c) and as suggested by
FHWA Technical Advisory T66430.S.A (October 1987) when considering improvements to the
transportation system. The Draft EIS discusses TSM and Mass Transit Alternatives in Draft EIS
Sections 2.2.3 and 2.2.5, respectively. Combination alternatives also are addressed in Section 2.2.5.
None of these alternatives were determined to meet the project's purpose and need. TSM and TDM
alternatives were eliminated because they would not noticeably improve mobility, access, or
connectivity within southern Gaston County, nor between southern Gaston County and western
Mecklenburg County. The Mass Transit Alternative, using expanded bus service on existing
roadways or expanded rail service on the existing rail line near I-85, was eliminated from further
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study because it would not establish direct connectivity within southern Gaston County or between
southern Gaston County and western Mecklenburg County. The Mass Transit Alternative including
bus rapid transit or light rail on new alignment could provide connectivity within southern Gaston
County and between southern Gaston County and west Mecklenburg County and provide shorter
travel times or distances for the transit users. However, the Mass Transit Alternative on new
alignment would carry a much lower volume of trips than a new highway facility and would be ill-
suited to the dispersed low-density land uses in southern Gaston County (resulting in even less
trips). The resulting lower volume of trips accommodated would not noticeably reduce vehicle miles
traveled and/or congested vehicle hours traveled in Gaston County compared to the No-Build
Alternative.
The ability of Improve Existing Roadway Alternatives to meet the project purpose and need are
addressed in the Draft EIS Section 2.2.6. See also the first comment under Responses to Generalized
Comments on Purpose and Need.
The environmental resource and regulatory agencies and the public were afforded opportunities to
review and provide input throughout the alternatives development and screening analysis process.
All environmental resource and regulatory agencies participating in the Turnpike Environmental
Agency Coordination (TEAC) meetings signed a concurrence form in October 2008 concurring on
three points: the Purpose and Need (Concurrence Point 1), Bridging and Alignment Decisions
(Concurrence Point 2a) and the Detailed Study Alternatives to be carried forward in the Draft EIS
(Concurrence Point 2). This concurrenceform is included in Appendix A-1 in the Draft EIS.
Recent work by NCDOT on the Piedmont and Northern Railway corridor, which is a rail corridor
north of I-85, was mentioned in a comment. The Piedmont and Northern Railway corridor is located
in Gaston and Mecklenburg Counties. At this time, the corridor in Gaston County is inactive.
Portions of the corridor in Mecklenburg County are active, except for the Cedar Yard terminus near
uptown Charlotte, which is inactive. The corridor is approximately 16 miles long. It begins in
downtown Gastonia and runs north of I-85 through Ranlo, Lowell, and Mount Holly. It crosses the
Catawba River just south of the NC 27 crossing of the river. The corridor then swings south to end
at South Cedar Street, just east of I-77. There is a spur that runs south from the corridor and ties
into downtown Belmont. The NCDOT acquired the inactive Piedmont and Northern mainline
corridor in 1991.
There has been some interest in reactivating this line for short line freight service. Section 261 of
Session Law 2008-191 (House Bill 2431) directed NCDOT to study the Piedmont and Northern
Railway line in Gaston County to determine the cost to bring the full line into operation. The
resulting report to the Joint Legislative Transportation Oversight Committee: Cost to Reactivate
Piedmont and Northern Rail Line (January 15, 2009) (available for download at
www.bv�'�n.org/quicklinks/reports/P&N Report 15JanO8.pdf) describes the improvements that
would need to be made to the rail line and corridor in order to provide freight service and also
possible future passenger rail service. At this time, "freight service is anticipated only on the 11.6
mile segments from Mount Holly to Gastonia and the northernmost 1.5 miles of the Belmont Spu�'
as documented in Cost to Reactivate Piedmont and Northern Rail Line (January 15, 2009).
Following the report to the legislature, a federal Categorical Exclusion (CE) for reactivation of the
Piedmont and Northern Railroad Corridor for freight service was signed by FHWA on July 9, 2009.
The proposed action identified in the CE is reactivation of freight rail service between Mount Holly
and Gastonia and along the Belmont Spur to the north of Belmont/Mount Holly Road (SR 2093). The
CE states: "At the time of this document, there are no plans in the foreseeable future to implement
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passenger rail service on any portion of the corridor. Passenger service would be covered under a
separate document process if determine feasible."
Future passenger service on the Piedmont and Northern Rail corridor could provide additional
transportation options between Gaston County and Mecklenburg County and could benefit the
region's transportation network, but it would not meet the Gaston East-West Connector purpose and
need for the reasons listed for the Mass Transit Alternative in Section 2.2.51 of the Draft EIS. It
would not improve mobility within southern Gaston County because it is located north of I-85. It
would not improve connectivity between southern Gaston County and western Mecklenburg County
because the Piedmont and Northern Rail corridor crosses the Catawba River in Mount Holly, just
south of NC 27. It also would not reduce congested vehicle miles or congested vehicle hours traveled
in Gaston County because it is not anticipated to attract enough trips to make a noticeable difference
in traffic volumes on area roadways.
The Final EIS will include an update on the Mass Transit Alternative discussion as it relates to the
current status of the Piedmont and Northern Rail corridor studies.
Comment: The Draft EIS should haue studied ending the project at US 321 if that is an interim
phase.
Response: The proposed project is included in the 2030 LRTP for the GUAMPO area as starting at
I-85 and continuing eastward to the Mecklenburg County line. The GUAMPO plans to include the
entire proposed project as a toll facility in its next update to the LRTP. US 321 was announced by
the NCTA as a potential interim western project terminus during discussions with the public and
local officials about funding. I.ike many large roadway projects in North Carolina, the Gaston East-
West Connector would need to be constructed and funded in phases. US 321 was identified as a
potential terminus based on information available at the time regarding project costs, potential
available funding, and traffic forecasts. The highest travel demand is projected along the eastern
segments of the proposed project. The ultimate project extends from I-485 in Mecklenburg County to
I-85 west of Gastonia, and this is the project NCTA intends to eventually construct as soon as
financing can be obtained. This will be clarified in responses to comments included in the Final EIS.
Comment: The decision to study only toll alternatiues in the EIS is not consistent with the CEQ
regulations at 40 CFR 150214(a) and (c). The EIS might haue also considered a comparison with a
freeway.
Response: The regulations at 40 CFR 150214(a) and (c) are:
In this section agencies shall:
(a) Rigorously explore and objectively evaluate all reasonable alternatives, and for
alternatives which were eliminated from detailed study, briefly discuss the reasons for
their having been eliminated.
(c) Include reasonable alternatives not within the jurisdiction of the lead agency.
Alternatives for the project were rigorously explored and evaluated, as documented in the Addendum
to the Final Alternatiues Deuelopment and Eualuation Report for the Gaston East-West Connector
(October 2008) and summarized in Chapter 2 of the Draft EIS. A Mass Transit Alternative, which
would not be within the jurisdiction of the FHWA, NCDOT, nor NCTA, was included in the
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evaluation. Environmental resource and regulatory agencies signed a concurrence form in October
2008 concurring with the Detailed Study Alternatives identified for the project.
The current NCDOT 2009 — 2015 State Transportation Improvement Program (STIP) includes the
project as a toll facility, and traditional (non-toll) transportation funding for this project is not likely
in the foreseeable future. GUAMPO, as part of the metropolitan planning process, has decided to
allocate the limited available federal and state funds to other projects. In September of 2000, the
GUAMPO TAC passed a resolution stating that it supports the use of alternative funding methods,
including payment by toll.
Based on preliminary traffic and revenue forecasts, the NCTA determined that the Gaston East-
West Connector is financially feasible with the collection of tolls. Using tolls, the NCTA can provide
the funding and construct the project many years earlier than with traditional funding sources.
Using tolls as the funding mechanism for construction and maintenance allows needed capacity to be
added when budget shortfalls would otherwise prevent or delay completion of critical projects.
5.4 Responses to Generalized Comments on Air Quality
Comment: Prior to issuance of the Final EIS and ROD, NCTA should demonstrate that the new
location project will be included in an approued SIP and will be in conformity.
Response: On May 8, 2009, USEPA published a Finding of Failure to Submit State
Implementation Plans (SIP) for the Charlotte area in the Federal Register. The state has 24 months
from this finding to make a SIP submittal and obtain USEPA approval. The NC Department of
Environment and Natural Resources Division of Air Quality (NCDENR-DAQ) intends to submit a
SIP in November 2009.
Because the Mecklenburg-Union Metropolitan Planning Organization (MUMPO) and the Gaston
Urban Area Metropolitan Planning Organization (GUAMPO) did not complete an update to their
respective Long Range Transportation Plan (LRTPs) and conformity determinations by May 3, 2009,
and June 30, 2009, respectively, and because the region does not have an approved SIP, the
Metrolina region is currently in a Conformity Lapse Grace Period (CLGP). In discussions with
MUMPO and GUAMPO, it is anticipated that the Metrolina region will be able to avoid moving into
a conformity lapse status, which would begin one year after the start of the CLGP.
As explained in the FHWA/FTA memorandum —Clarification of Transportation Conformity
Requirements for FHWA/FTA Projects Requiring Enuironmentallmpact Statements (May 20, 2003),
an approved SIP and a modified LRTP and conformity determination that is consistent with the
project as proposed must be in place prior to the issuance of the Record of Decision (ROD) for this
project.
FHWA cannot issue a ROD for this project until the LRTPs are updated and there is an approved
SIP for the Metrolina region. The absence of either of these events will result in a project delay until
these approvals are obtained.
Comment: The Draft EIS does not address quantitatiue air quality impacts as they relate to Mobile
SourceAir Toxics (MSATs). The Draft EIS does not offer any mitigation measures to address the
project's impact on air quality, specifically concerning MSAT emissions exposures at schools,
hospitals, parks, etc.
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Response: The MSAT analysis was conducted in accordance with the Federal Highway
Administration Interim Guidance on Air Toxic Analysis in NEPA Documents dated February 3,
2006. The interim guidance establishes three levels of review:
• No analysis for projects with no potential for meaningful MSAT effects;
• Qualitative analysis for projects with low potential MSAT effects; or
• Quantitative analysis to differentiate alternatives for projects with higher potential
MSAT effects.
Projects requiring a quantitative analysis include projects that have the potential for meaningful
differences among project alternatives. To fall into this category, projects must:
• Create or significantly alter a major intermodal freight facility that has the potential to
concentrate high levels of diesel particulate matter in a single location; or
• Create new or add significant capacity to urban highways such as interstates, urban
arterials, or urban collector-distributor routes with traffic volumes where the annual
average daily traffic volumes (AADT) are projected to be in the range of 140,000 to
150,000, or greater, by the design year; and also
Be proposed to be located in proximity to populated areas, or in rural areas in proximity
to concentrations of vulnerable populations (i.e., schools, nursing homes, hospitals).
The project would not qualify as requiring a quantitative analysis because it would not significantly
alter a major intermodal facility, nor would the AADT be in the range of 140,000 to 150,000.
The overall approach applied in the MSAT guidance characterizes the trend in MSAT emissions and
the difference in MSAT emissions between alternatives, but does not attempt to characterize health
risks or microscale impacts, due to the uncertainty associated with available analysis tools. In late
2007, the US District Court in the Southern District of Maryland upheld this approach in ruling on a
challenge to the Inter-County Connector project, stating that "the Defendants' methodology was
reasonable and should be upheld ... Defendant's failure to consider Plaintiffs' approach to the health
effects analysis, which could be ascertained, if at all, only through uncertain modeling techniques,
did not preclude informed decision-making under NEPA."
Comment: The EIS should address greenhouse gas emissions.
Response: From a policy standpoint, FHWAs current approach on the issue of global warming is as
follows. On April 2, 2007, the Supreme Court issued a decision in Massachusetts et al v. USEPA
that the USEPA does have authority under the Clean Air Act to establish motor vehicle emissions
standards for COz emissions. However, the Court's decision did not have any direct implications on
requirements for developing transportation projects.
On April 24, 2009, in response to the Supreme Court's decision in Massachusetts et al v. USEPA, the
USEPA issued a proposed finding in the Federal Register (Volume 74, No. 78, page 18886) that
"atmospheric concentrations of greenhouse gases endanger public health and welfare within the
meaning of Section 202(a) of the Clean Air Act." This finding is proposed specifically for six
greenhouse gases that "together constitute the root of the climate change problem: carbon dioxide,
methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride." The USEPA
also proposed to find that the "combined emissions of carbon dioxide, methane, nitrous oxide, and
hydrofluorcarbons from new motor vehicles and new motor vehicle engines are contributing to this
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mix of greenhouse gases in the atmosphere." However, this finding, if finalized, would not include
standard-setting rulemaking to establish standards, criteria, or thresholds regarding greenhouse gas
emissions. As of August 25, 2009, the USEPA continues to accept public comment on this proposed
finding, even though the public comment period ended June 23, 2009.
FHWA does not believe it is informative at this point to consider greenhouse gas (GHG) emissions in
a Draft EIS for an individual road construction project, such as the Gaston East-West Connector.
The climate impacts of COz emissions are global in nature. Analyzing how alternatives evaluated in
a Draft EIS might vary in their relatively small contribution to a global problem will not better
inform decisions. Further, due to the interactions between elements of the transportation system as
a whole, emissions analyses would be less informative than ones conducted at regional, state, or
national levels. Because of these concerns, FHWA concludes that COz emissions cannot usefully be
evaluated in this Draft EIS in the same way that other vehicle emissions are addressed.
FHWA is actively engaged in many other activities with the DOT Center for Climate Change to
develop strategies to reduce transportation's contribution to GHGs—particularly COz emissions—
and to assess the risks to transportation systems and services from climate change. FHWA will
continue to pursue these efforts as productive steps to address this important issue. FHWA will
review and update its approach to climate change at both the project and policy level as more
information emerges and as policies and legal requirements evolve.
Lastly, it is important to note that while the Gaston East-West Connector project will provide new
road capacity, the new capacity will be priced (tolled), which serves as a demand management tool in
addition to providing needed project financing. The traffic forecasting for this project shows that the
Gaston East-West Connector project would result in some increases in both vehicle-miles traveled
(VMT) and vehicle-hours traveled (VHT) within the project study area. Because VMT and VHT are
correlated with GHG emissions, this data suggests that the Gaston East-West Connector project may
marginally increase GHG emissions in the project study area. This potential increase in GHG
emissions would be insignificant on a global scale, but is noted here for informational purposes in
connection with the comments concerning GHG emissions and climate change.
5.5 Responses to Generalized Comments on Water Quality and
Jurisdictional Resources
Comments: 1) Concerns about sediment and erosion impacts that could result from this project.
Erosion control measures should adhere to the Design Standards in Sensitiue Watersheds, 2) The
possible effects of storm water runoff associated with this project could negatiuely affect the project
area.
Response: As discussed in Draft EIS Section 62.4, an erosion and sedimentation plan will be
developed for the Preferred Alternative prior to construction in accordance with all applicable
regulations and guidance. The FHWA, NCTA, and NCDOT will work with the permitting agencies
to determine the appropriate best management practices to implement for the project.
A quantitative indirect and cumulative effects (ICE) analysis also will be prepared for the Preferred
Alternative and the land use analysis results will be reported in the Final EIS. The ICE analysis
also will address water quality issues for purposes of the required Section 401 Water Quality
Certification.
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Comments: 1) Concerns about the amount of mitigation needed and that it will not be auailable in
the area,� euery effort should be made to further auoid and minimize impacts to streams and wetlands
and to prouide on-site mitigation. Mitigation should focus on improuing degraded streams in the
area, 2) A conceptual mitigation plan should be prouided in the Final EIS, with information about
on-site mitigation opportunities.
Response: The FHWA, NCTA, and NCDOT intend to use the NC Ecosystem Enhancement
Program (EEP) for most project mitigation needs. Over the past several years, NCTA has been
coordinating with EEP regarding this project and projected mitigation needs. A conceptual
mitigation plan will be prepared and described in the Final EIS. The conceptual mitigation plan will
include an evaluation of on-site mitigation opportunities.
Comment: Direct impacts to existing 303(d) listed impaired streams and other waters at risk from
further degradation haue not been fully addressed from the standpoint of auoidance and
minimization (e.g. right of way and median widths, shoulder widths, etc.).
Response: As stated in the Section 6002 Coordination Plan for the Gaston East-West Connector
Project, this study, to the extent possible, will follow the environmental review process consistent
with the requirements for "Projects on New Location" as described in the Section 404/NEPA Merger
Ol Process Information. The Merger process requires Concurrence Point 4a (avoidance and
minimization) must be achieved after Concurrence Point 3(identification of LEDPA). The FHWA,
NCTA, and NCDOT will continue working with the environmental resource and regulatory agencies
to achieve these concurrence points. The NCTA held a design workshop on August 26, 2009, to
consider design changes that would reduce impacts and costs. The environmental resource and
regulatory agencies were invited to this meeting.
5.6 Responses to Generalized Comments on Indirect and Cumulative
Effects and Wildlife
Comments: 1) The Draft EIS has no specifac discussion of mitigation for indirect and cumulatiue
impacts, 2) There are no quantitatiue data presented in the Draft EIS concerning potentiallCE to
wetlands, streams, water quality and wildlife habitat, 3) A quantitatiue ICE analysis should be
prepared for the Preferred Alternatiue, 4) The Guidance Memorandum to Address and Mitigate
Secondary and Cumulatiue Impacts to Aquatic and Terrestrial Wildlife Resources and Water Quality
should be consulted when deueloping mitigation measures.
Response: In accordance with NCDOT procedure, a Qualitative Indirect and Cumulative Effects
(ICE) report was completed and included in the Draft EIS. Several comments on the Draft EIS
requested that a Quantitative ICE analysis be performed. NCTA intends to prepare a Quantitative
ICE report, consisting of two parts. The first will analyze potential changes in land use and the
second will analyze potential changes in water quality. The Quantitative ICE report currently is
planned to include analysis of two scenarios: no-build (for a baseline of comparison), and the
Preferred Alternative. Prior to commencement of this study, scoping with the agencies will be
conducted to ensure the study approach and scope will meet the expectations of the agencies. The
land use component of the Quantitative ICE will be included in the Final EIS. The water quality
component will be completed as part of the permitting phase of the project.
If the results of the quantitative ICE indicate mitigation measures for indirect and/or cumulative
effects should be evaluated, the FHWA, NCTA, and NCDOT will coordinate with the environmental
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resource and regulatory agencies on this issue. It should be noted that FHWA, NCTA, and NCDOT
would not have any authority over most types of mitigation measures that could be effective at
minimizing indirect/cumulative impacts, such as local land use controls and ordinances. However,
as stated in NEPA s Forty Most Asked Questions, prepared by CEQ:
Question 19b. How should an EIS treat the subject of auailable mitigation measures that are
(1) outside the jurisdiction of the lead or cooperating agencies, or (2) unlikely to be
adopted or enforced by the responsible agency?
A. All releuant, reasonable mitigation measures that could improue the project are to be
identified, euen if they are outside the jurisdiction of the lead agency or the cooperating
agencies, and thus would not be committed as part of the RODs of these agencies. Sections
150216(h), 15052(c). This will serue to [46 FR 18032) alert agencies or officials who can
implement these extra measures, and will encourage them to do so. Because the EIS is the
most comprehensiue enuironmental document, it is an ideal uehicle in which to lay out not
only the full range of enuironmental impacts but also the full spectrum of appropriate
mitigation.
Howeuer, to ensure that enuironmental effects of a proposed action are fairly assessed, the
probability of the mitigation measures being implemented must also be discussed. Thus the
EIS and the Record of Decision should indicate the likelihood that such measures will be
adopted or enforced by the responsible agencies. Sections 150216(h), 15052. If there is a
history of nonenforcement or opposition to such measures, the EIS and Record of Decision
should acknowledge such opposition or nonenforcement. If the necessary mitigation measures
will not be ready for a long period of time, this fact, of course, should also be recognized.
NCTA can encourage local governments to adopt regulations and land use plans that would help
protect significant natural resources, but FHWA, NCTA, and NCDOT lack any enforcement
authority to ensure their adoption or adherence.
Provisions regarding FHWA's legal responsibility and authority for mitigating project impacts are
found in FHWA's Environmental Impact and Related Procedures 23 CFR 771105(d):
"Measures necessary to mitigate aduerse impacts will be incorporated into the action and are
eligible for Federal funding when the Administration determines that:
1. The impacts for which the mitigation is proposed actually result from the Administratiue
action; and
2. The proposed mitigation represents a reasonable public expenditure after considering the
impacts of the action and the benefits of the proposed mitigation measures.In making this
determination, the Administration will consider, among other factors, the extent to which
the proposed measures would assist in complying with a Federal statute, Executiue Order,
orAdministration regulation orpolicy."
Furthermore, as stated in the FHWA Position Paper: Secondary and Cumulatiue Impact Assessment
in the Highway Project Deuelopment Process:
"After the analysis is complete a ualid question will remain: If a proposed highway
improuement is determined to cause potential secondary and cumulatiue effects, what can and
should be done to mitigate the aduerse impacts? This is a difficult question for which there
are no simple solutions. Consistent with existing FHWA regulations mitigation proposals
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must be both reasonable and related to project impacts. Howeuer, the opportunities for
enuironmental enhancement that are now auailable under the highway program may greatly
expand our traditional uiew of mitigation. Changing a proposed transportation improuement
to lessen its contribution of indirect impacts may likely result from a combination of
mitigation and enhancement measures that address area-wide concerns, not just the
immediate infGuence of the project. Unfortunately, measures that would be appropriate to
offset most future deuelopmental impacts in the area of a project often will be beyond the
control and funding authority of the highway program. In these situations, the best approach
would be to work with local agencies that can infGuence future growth and promote the
benefits of controls that incorporate enuironmental protection into all planned deuelopment."
Comment: Negatiue impacts to terrestrial resources and wildlife, including fragmentation of
terrestrial habitat, are a significant concern.
Response: The FHWA, NCTA, and NCDOT will include habitat fragmentation in the quantitative
ICE study to be prepared for the Preferred Alternative.
5.7 Responses to Generalized Comments on Cultural Resources,
Community Characteristics, and Farmland
Comment: The Draft EIS missed the subject of historic Stowesuille, Stowes Factory, Gaither Mill,
Stowesuille Cemetery, and the old Methodist church.
Response: Draft EIS Section 5.31.2 discusses the Stowesville site. Additional archaeological
research will be conducted for this site and related sites as part of the Phase II archaeological
surveys for the Preferred Alternative. The results will be reported in the Final EIS.
Comment: EJpopulations would receiue a higher percent of impact from the new facility in terms of
air quality and noise impacts, but would not necessarily receiue a proportionate benefit from the
project due to potential toll costs.
Response: Environmental justice issues are discussed in Section 3,2, 5 of the Draft EIS. As stated
in Section 3.2.5 of the Draft EIS, any of the Gaston East-West Connector DSAs would provide a new,
limited-access, east-west route in the region. A result of the project would be reduced traffic on the
existing non-toll route, I-85. Completing the project would benefit all motorists, including low-
income motorists who may choose not to use the toll facility or may tend to use it less frequently.
Neighborhoods with predominantly minority populations (Matthews Acres/Spring Valley and
Garrison Road) are located near I-85 and I-485 within Segments H2A and K3C of DSA 9(see Figure
3-3 and 3-4 in the Draft EIS). In these areas, there are approximately 40 residences (all assumed to
be minority) that are predicted to experience noise impacts under DSA 9 based on FHWA noise
abatement criteria.
With respect to low income populations, the specific areas where these populations occur within DSA
9 are not readily known. As such, the following method was used to estimate the approximate
percentage of low income populations that could be impacted by increases in noise levels with
implementation of DSA 9. The total numbers of noise-impacted receptors along all the DSA 9
corridor segments was multiplied by the percent of population in poverty of the area's corresponding
census block. For example: Segment H2A has 32 noise-impacted receptors and its corresponding
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Census Tract 318 Block Group 3 has approximately 42.8 percent living below the poverty level.
Applying this method to the entire length of DSA 9, it can be estimated that approximately 35-40
impacted receptors may be low income. Total numbers of potentially impacted residences are
estimated to be approximately 245. The estimated values for impacted minority and low-income
residences represent approximately 15 percent of the impacted receptors.
Preliminary analyses shows noise barriers would be reasonable at twelve locations along DSA 9,
including noise barriers for the Spring Valley and Garrison Road neighborhoods (see Figure 4-1 in
the Draft EIS). Both of these areas are predominantly minority and also have higher percentages of
their populations considered low-income than other areas along the project. Based on these values,
it is not expected that minority or low-income populations would have disproportionate high and
adverse noise impacts.
Similar to potential noise impacts, populations nearest to DSA 9 have the highest potential to be
affected by air quality impacts, and the above method for estimating potential noise impacts on
minority and low income populations can also be used in a general consideration of air quality
effects. Therefore, it is assumed that the percentage of minority and low income populations that
could be potentially impacted by decreased air quality would be similar to those populations
potentially impacted by noise. Therefore, it is not expected that minority or low-income populations
would have disproportionate high and adverse air quality impacts.
Comments: 1) The Draft EIS does not offer any potential auoidance and minimization measures to
potentially reduce impacts to farmlands, 2) Concerns about the auailability of replacement property
for farms that need to be relocated
Response: The locations of farms and voluntary agricultural districts (VADs) were incorporated
into the development of the preliminary new location corridors, and these areas were avoided where
possible, taking into consideration other resources in the area. No other mitigation is required.
The relocation reports prepared for the proposed project indicate replacement property for farms is
available and can be found in Appendix F of the Draft EIS.
At the request of USEPA, farmlands will be a resource evaluated in the quantitative ICE report to be
prepared for the Preferred Alternative.
6.0 SUMMARY OF DESIGN COMMENTS
As a result of the public involvement activities associated with the project, several issues were raised
regarding the preliminary designs for the DSAs. These issues, described below, were raised by
public, local municipalities, interest groups, and agencies. Unless otherwise noted, the comments
apply to DSA 9(Recommended Alternative).
6.1 Design Comments Received from the Public and Interest Groups
These comments and proposed actions were discussed at the Gaston East-West Connector Post-
Hearing Meeting held August 4, 2009.
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Matthews Acres Access Road
Matthews Acres residents appear to prefer different access to US 29-74 instead of the access to Oates
Road shown on the Public Hearing Maps. Some Pre-Hearing Open House attendees suggested
connecting to US 29-74 directly south.
NCTA will investigate alternative means of access to the Matthews Acres neighborhood and will
coordinate with residents.
Pam Drive and Saddlewood Drive (south of Robinson Road interchange�
Residents were concerned about closing Pam Drive and rerouting their access to Robinson Road via
the Saddlewood neighborhood. Concerns included additional driving distance and sight distance at
the Saddlewood Road/Robinson Road intersection. Some suggested keeping Pam Drive open and
connecting it directly across from the interchange ramp. Residents also were concerned about the
visual impacts of an access control fence in front of their neighborhood.
NCTA will review sight distances at the Saddlewood Road/Robinson Road intersection under the
proposed designs. Design changes will be made if necessary.
Land North of Interchan�'e at Robinson Road
Property owners on either side of Robinson Road directly north of the interchange commented on the
preliminary designs. The property owner on the west (D'Amore family) would have their horse farm
facilities impacted. The property owner on the east stated they would agree to moving the ramps to
their side of the road. The on-ramp north of the interchange and the proposed access control along
Robinson Road would directly impact the D'Amore horse farm riding ring and security entrance gate
as well as approaching close to their home.
NCTA will investigate interchange design changes to miminize impacts to the horse farm. These
include moving the ramp to a loop on the east side of Robinson Road or shifting the interchange
ramps closer to the mainline. Compressing the ramps would allow full movement at the D'Amore
driveway approximately 700 feet away.
As a separate issue, the railroad bridge over Robinson Road near US 321 was discussed at the Post-
Hearing Meeting (August 4, 2009). This bridge narrows Robinson Road to one lane, and it constrains
traffic movements along Robinson Road. The previous traffic forecasts did not account for this
condition, but new forecasts being prepared will. Mr. Grissom stated Division 12 would like to
replace this bridge, but it is owned by the railroad and costs are prohibitive at this time.
Wilson Farm Road iust south of Union Road (NC 274)
Property owners (Margaret and Bob Ferguson) own 140 acres (162 Wilson Farm Rd, Parcel ID
193024). Preliminary designs would result in a narrow strip of land on the north end of the parcel
being divided from the rest of the parcel. Owners wanted to know if mainline could be shifted north.
No action is proposed regarding this request. If the mainline is shifted north, it would impact a large
wetland area (Wetland 189, shown on Figure 2-9v of the Draft EIS).
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Carolina Speedwav on NC 274 iust south of Union-New Hope Road
The property owners (Charles Harrison and Harriet Harrison Armstrong) asked if DSA 9 could be
moved north to avoid the Carolina Speedway and homes. They are concerned with impacts to
racetrack parking and pit area.
The mainline alignment for DSA 9 cannot be moved north due to intersection spacing concerns with
Union New Hope Road. However, NCTA will investigate measures to minimize impacts to the
Carolina Speedway. Mr. Harrison and Ms. Armstrong own a 63-acre parcel to the east of the
Speedway. There is a possibility that this additional property could be used to relocate some of the
functions/uses that would be encroached on by the proposed designs for DSA 9.
Interchange at NC 273
The property at 2030 Southpoint Road (NC 273) (Rhonda Harmon) is adjacent to the eastbound off
ramp. The property owner was concerned about being landlocked. Another property owner in
Graystone Estates concerned about providing sidewalks on Southpoint Road for high school students
traveling to Southpoint High School.
The NCTA will be conducting a service road study for the Preferred Alternative which will review
land-locked properties. Sidewalks will be added to cross streets where appropriate and can be
funded. The traffic signals proposed at the interchange ramp termini will provide for gaps in traffic
to allow for turning movements onto Southpoint Road.
Sunderland Road/Allison Street off of NC 273 south of the proposed interchan�'e
A resident of Sunderland Road asked if the new access point for Sunderland Road onto NC 273 could
be moved north approximately 800 feet. Another resident was concerned that school buses traveling
into the neighborhood will not be able to turn around. Currently, school buses do not need to turn
around to exit the neighborhood.
The NCTA will investigate modifying the Sunderland Road access to NC 273 and will review the
designs to ensure school bus access is provided.
Boat Club Road and Access to the Optimist Club/Duke Enere'v Recreational Fields
The Optimist Club leases land on Boat Club Road from Duke Power for youth recreational fields.
The Optimist Club recently made improvements and expanded the fields. The preliminary
engineering designs shown on the Public Hearing Map encroach on the expanded fields. The
Optimist Club is concerned about impacts to the fields and provision of access to the fields.
The NCTA has modified the preliminary engineering designs to avoid direct encroachment on the
expanded recreational fields. These modified designs also avoided two electric power towers. A
letter dated June 18, 2009 was sent from NCTA to Mr. Kelvin Reagan, Optimist Club President,
describing the design changes. This memorandum also included a map of the new design. These
modifications will be included in the Final EIS. Access to the fields will be investigated as part of
the service road study and will include coordination with Duke Power. Duke Power owns the
recreational field land and adjacent land to the south. Issues to be explored with Duke Power
include moving a gate to allow the recreational field users to use Duke Power's access road that
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extends from Boat Club Road to NC 273. This road currently provides access to Duke Power's air
pollution control equipment area.
I-485 Interchan�'e Area
Piedmont Natural Gas recently purchased a 50-foot easement along the west side of I-485.
A utility study will be performed prior to construction and utilities will be accommodated in the
design of the project.
General Pedestrian and Bicvcle Access Comments
Connect Gaston and Gaston Together submitted comments regarding sidewalks and greenways
throughout the project.
• Bridges over streams should be constructed in a manner that allows future walking and
bike paths to pass beneath them.
• All bridges over roads, and interchanges with roads, be constructed with sidewalks
(north-south) that allow access from one side of the thoroughfare to the other.
• All sidewalks should be constructed sufficient in width to allow foot, bike, wheelchair,
and stroller traffic to travel in both directions simultaneously.
• Bridges over the South Fork and Catawba Rivers should be constructed with provisions
for pedestrians to cross the rivers.
• Bridges at Blackwood Creek, Brandon Creek, Catawba Creek, and an unnamed
perennial branch just south of the US 29/74 interchange should be designed to allow
greenway construction.
• There is a greenway planned to follow a section of Crowders Creek south of I.inwood
Road that should be taken into consideration.
During final design, the NCTA will work with local jurisdictions to provide sidewalks and other
crossings where appropriate and can be funded.
Access to South End of Bav Shore Drive (Corridor See'xnent K4A - not in the
Recommended Alternative DSA 9)
The access road proposed to provide access to remaining homes on the south end of Bayshore Drive
would connect Bayshore Drive to Magnolia W ay Lane in Woodland Bay, which would then allow
drivers to access South New Hope Road via Woodland Bay Drive. Woodland Bay is a gated
community, whose roads are privately owned. This proposed access to join Bayshore Drive to a
development that is not part of the Woodland Bay Homeowners Association.
If a Preferred Alternative is identified that includes Segment K4A (DSAs 5, 23, 64, or 77), the service
road study would consider this issue.
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6.2 Design Comments Received from Agencies and Local Governments
US 29-74 Interchan�'e
The US 29-74 Interchange should be eliminated to reduce impacts to wetlands and Crowders Creek
(a 303(d)-listed stream) and its tributaries.
The NCTA, NCDOT, and FHWA will make a decision regarding this interchange prior to the Final
EIS, after completing new traffic forecasts. Previous coordination with the GUAMPO had indicated
they could agree to the elimination of the US 29-74 interchange.
Interchanges at Robinson Road. Bud Wilson Road. NC 274 (Union Rd). NC 273 (Southpoint
Road), and I-485
Single Point Urban Interchanges (SPUIs) or other compressed interchange designs should be
considered at Robinson Road, Bud Wilson Road, NC 274 (Union Road), NC 273 (Southpoint Road).,
and I-485.
As part of final design, the NCTA will review updated traffic forecasts and work with the GUAMPO
and MUMPO to determine if any interchanges can be eliminated or deferred. Also during final
design, the NCTA will review the listed interchanges to determine if the interchange footprints can
be reduced.
Bud Wilson Road Interchan�'e
The GUAMPO has requested that the Bud Wilson Road interchange be removed or relocated to an
extension of Beaty Road.
The NCTA, NCDOT and FHWA will make a decision regarding deleting or relocating this
interchange prior to publication of the Final EIS
Future Belmont-Mt. Hollv Loop
The GUAMPO requests that a grade-separation be provided for the future proposed Belmont-Mt.
Holly Loop Road to be located west of Southpoint Road (NC 273).
Since the Belmont-Mt. Holly Loop is a proposed Road, its exact location is not known and its
construction would be a separate project. The NCTA would allow grade-separated crossings of the
mainline to be funded and constructed by others in the future.
Access to Charlotte-Dou�'las International Airport Area
The MUMPO and the Charlotte-Douglas International Airport have requested that access be
provided east of I-485 to the roadways north of relocated NC 160 (West Boulevard) to accommodate
the Airport's runway expansion project and future intermodal facility.
The NCTA will work with the Airport, Charlotte DOT, and MUMPO during final design to ensure
access is provided.
A T N EA T-WE T NNE T R
September 8, 2009 TEAC Meeting
30

Mainline Tvnical Section
Agency commenters suggested reviewing the proposed typical sections for ways to reduce the
construction footprint. Arecommendation was made to maintain the median width, but narrow the
footprint for a 4-lane facility to minimize impacts to area resources. A wider right of way could be
preserved for possible future widening, but additional impacts to streams and wetland should be
avoided until such widening occurs.
The NCTA will review the typical sections during final design. A workshop to discuss potential ways
to reduce the costs and impacts of the project is scheduled for August 26, 2009.
7.0 TRAFFIC FORECASTS
The April 13, 2006 version of the 2030 Metrolina travel demand model was used for all year 2030
project-related traffic forecasts because this was the current version when the updated forecasting
activities began. The 2030 Metrolina travel demand model covers a thirteen-county region
(including Gaston County and Mecklenburg County) within a single model. The 2030 Metrolina
travel demand model also uses population and land use forecasts that extend out to 2030. The
Metrolina travel demand model is updated on a continual basis.
Year 2030 Toll Scenario traffic volumes were developed by modeling three representative DSAs:
DSA 4(the northernmost DSA), DSA 64 (the southernmost), and DSA 77 (a crossover DSA). A
review of the Non-Toll Scenario forecasts showed that these three representative alternatives would
provide the full range of volumes forecasted along the DSAs, and all DSAs are represented by
various portions of these three DSAs. Table 6 shows the forecasted 2030 Toll Scenario traffic
volumes along the mainline for DSAs 4, 64, and 77. The Recommended Alternative, DSA 9, is most
closely represented by DSA 4 in the table below.
Table 5: Year 2030 Traffic Volumes Along the Detailed Study Alternatives
Modeled Detailed Study Alternative
Segment
4* 64 77*
I-85 to US 29-74 12,800 10,000 12,200
US 29-74 to Linwood Rd (SR 1133) 20,800 11,400 18,000
Linwood Rd to Lewis Rd (SR 1126) 15,400 9,600 17,400
Lewis Rd to US 321 15,400 14,200 17,400
US 321 to Robinson Rd (SR 2416) 20,000 18,800 21,400
Robinson Rd to Bud Wilson Rd (SR 2423) 29,200 29,400 30,400
Bud Wilson Rd to NC 274 (Union Rd) 28,000 28,600 28,200
NC 274 to NC 279 (S New Hope Rd) 31,600 35,000 34,800
NC 279 to NC 273 (Southpoint Rd) 42,200 44,200 43,400
NC 273 to Dixie River Rd (SR 1155) 58,400 61,800 60,600
Dixie River Rd to I-485 55,400 54,400 53,000
Source: GostonEost-WestConnectorv(U-3321/TrofficForemstforTollAlternotives�Martin/Alexiou/Bryson,
August 2008)
* Altematives 4 and 64 do not have an interchange at Lewis Rd, and therefore the vol umes in the 3�tl and 4`�
rowsarerepeated. DSA9ismostsimilartoD5A4.
A T N EA T-WE T NNE T R
September 8, 2009 TEAC Meeting
31

APPENDIX A
Figure S-1a and S-1b

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Parks
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and Attractions
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----County Lines
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Streets
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Source: Gaston County and
Mecklenburg County GIS
Map printed April 2009.
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STIP PROJECT
NO. U-3321
Gaston County and
Mecklenburg County
GASTON EAST-WEST
CONNECTOR
DETAILED STUDY
ALTERNATIVES
Figure S-1a

Alternative 4
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Alternative 68
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Map Pnnted Apnl 2009.
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STIP PROJECT
NO. U-3321
Gaston County and
Mecklenburg County
GASTON EAST-WEST
CONNECTOR
DETAILED STUDY
ALTERNATIVES
Figure S-1 b

APPENDIX B
Summary of Environmental Impacts

TABLE S-2: Summary of Environmental Impacts -Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
Length (miles) 21.4 21.5 21.9 21.9 22.0 22.4 23.1 23.3 23.7 21.8 21.9 22.2
Construction Costs 955.0- 980.2- 974.5- 999.5- 1,022.6- 1,019J- 978.2- 992.4- 986.2- 982.1- 1,007.4- 1,000.5-
(millions $)� 1,140.8 1,173.2 1,168.4 1,195.0 1,228.2 1,221.7 1,171.3 1,188.6 1,180.9 1,174.0 1,209.6 1,199.7
Right-of-Way Cost 186.7- 199.1- 173.9- 197.0- 208.8- 183.5- 197.3- 215.7- 190.8- 182.4- 194.6- 169.6-
(millions $)� 228.5 243.0 213.0 241.1 255.5 224.5 241.3 263.2 233.2 223.2 237.6 207.3
Environmental
Mitigation 38.9-41.1 34.8-36.7 32.2-34.0 40.4-42.6 36.4-38.4 33.8-35.7 41.5-43.7 34.3-36.1 31.8-33.5 37.7-39.8 33.2-35.0 31.1-32.8
Costs(millions $)�
Total Costs 1,180.6- 1,214.1- 1,180.6- 1,236.9- 1,267.9- 1,237.1- 1,217.0- 1,242.4- 1,208.7- 1,202.1- 1,235.2- 1,201.2-
(millions $)� 1,410.4 1,452.9 1,415.4 1,478.7 1,522.0 1,481.9 1,456.3 1,488.0 1,447.6 1,436.9 1,482.3 1,439.8
Median Total
Project Cost 1,280.5 1,316.9 1,282.0 1,342.2 1,378.4 1,342.9 1,321.2 1,348.2 1,312.6 1,304.3 1,341.9 1305.0
(millions $)�
LAND USE
Compatible with yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes
Land Use Plans
ICE : Potential for
Accelerated Growth High High High High High High High High High High High High
and Indirect Effects
in Gaston County
RELOCATIONSAND NEIGHBORHOOD IMPACTS
Residential 377 358 348 373 354 344 359 336 326 384 365 355
Relocations
Business
Relocations 38 33 37 40 35 39 30 26 30 29 24 28
Named Z1 24 18 19 22 16 17 21 15 18 21 15
Neighborhoods
Rural
Neighborhoods3 8 8 � 6 6 5 10 10 9 7 7 6
ICE : Potential for
indirecteffectsdue Most Most Most Most Moderate Most Most Least Moderate Most Least Moderate
to proximity to
neighborhoods
MITIGATION Conform to Uniform Relocation Act; continue public outreach efforts; meet with neighborhood organization and business community representatives; continue to
evaluate design improvementsto lessen impacts.

TABLE S-2: Summary of Environmental Impacts —Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
COMMUNIN SERVICES AND FAQLITIES IMPACTS
PublicParks 1 1 1 1 1 1 1 1 1 1 1 1
PrivateRecreational ba b�e b�a a a a a a a
Facilitiess �. 3" 3" 1 2ce Zc Za, 3a,ce 3a,c Za, 3a,ce 3a,�,
Schools6 1 0 0 1 0 0 2 1 1 2 1 1
Ch u rch es with
ImpactstoMain 2 3 2 1 2 1 1 2 1 0 1 0
Buildings
Ch u rch es with
Impactsto 3 3 1 4 4 2 2 2 0 2 2 0
Propertyand/or
Outbuildings Only
Cemeteries
Requiring 1 1 0 1 1 0 1 1 0 1 1 0
Relocation
MITIGATION Conform to Uniform Relocation Act; continue public outreach efforts; meet with school district representatives regarding site planning, bus routes and property
encroachments; coordinate with church leaders on property encroachments and relocation strategies; continue to evaluate design improvements to lessen impacts.
NOISE IMPACfS
Total ri of
Impacted 302 271 245 298 267 241 272 231 204 309 278 276
Receptors
ICE :Overall Weakto Weakto Weakto Weakto Weakto Weakto Weakto Weakto Weakto Weakto Weakto Weakto
ambient noise moderate moderate moderate moderate moderate moderate moderate moderate moderate moderate moderate moderate
increase effects effects effects effects effects effects effects effects effects effects effects effects
NOISE MITIGATION
Total Length of ZZ�162 19,220 20,562 19,922 16,980 18,322 13,926 10,335 11,677 17,967 15,025 16,367
Noise Barriers (ft)
Total ri of Noise
Barriers� 13 11 12 11 9 10 8 6 7 10 8 9
Number of
Benefitted 191 157 169 171 144 149 132 98 110 161 128 139
Receptors
AIR QUALIN IMPACTS

TABLE S-2: Summary of Environmental Impacts —Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
Transportation The LRTPs and air quality conformity determinationsforthe MUMPO and GUAMPO regions will need to be updated priortothe completion of the Record of Decision
Conformity so the project design concept and scope are consistent.
Mobile Source Air
Toxics (MSATs) 4ualitative assessment completed. Currenttools and science notadequate to quantifythe health impactsfrom MSATs.
FARMLAND IMPACTS
VAD Acreage
Impacted by right 44.7 49.2 49.2 44.7 49.2 49.2 68.8 138.4 138.4 64.0 68.5 68.5
of way
Farm Relocations 0 1 1 0 1 1 0 2 2 0 1 1
ICE : Potential for
indirecteffectson Least Least Least Least Least Least Moderate Most Most Moderate Moderate Moderate
agriculture and
farmland
MITIGATION None required.
UTILITIES IMPACTS
Power
Transmission Line 14 13 14 14 13 14 18 17 17 17 15 17
Crossings�o
Gas Transmission
Pipeline 4 4 4 4 4 4 4 4 4 4 4 4
Crossings��
Railroad Crossings 2 1 2 2 1 2 2 1 2 2 1 2
MITIGATION Coordinate temporary and permanent changes in utility lines with each ofthe utility providers.
VISUAL IMPACfS
Changesinthe Mostvisual Most Moderate Moderate Moderate Least Moderate Moderate Moderate Moderate Moderate Least
visual visual visual visual visual visual visual visual visual visual visual
Visual Landscape impacts
impacts impacts impacts impacts impacts impacts impacts impacts impacts impacts impacts
MITIGATION Implement a landscaping plan forthe project. Investigate the feasibility and reasonableness of cost-effective treatments forthe bridge sides, piers, and railings to
enhance aesthetics.
HAZARDOUS MATERIALS IMPACTS

TABLE S-2: Summary of Environmental Impacts —Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
Hazardous
Materials Sites Zq Z3 24 22 21 22 14 12 13 14 13 14
within DSA
Corridor
MITIGATION A more detailed field reconnaissance will be conducted forthe Preferred Alternative.
FLOODPLAINS/FLOODWAYS IMPACTS
Floodplain 12 13 13 12 13 13 11 12 12 10 11 11
Crossings
Longitudinal
Floodplain 1 1 1 0 0 0 0 0 0 0 0 0
Encroachment
FloodwayCrossings 10 10 10 9 9 9 7 7 7 7 7 7
Number of Major
Culverts/Pipes 47 43 45 45 41 43 47 42 44 42 39 40
(>72" diameter)��
MITIGATION The effect of all the DSAs can be mitigated through proper sizing and design of hydraulic structures (culverts, bridges, and channel stabilization). A detailed
hydrologic and hydraulic analysis will be conducted for the Preferred Alternative.
CULTURALRESOURCESIMPACTS
Historic Resources
withNoAdverse la 2e,° 2e,° la ye,° ye,° ya,e ge,ae 3e,ae Za,e 3e,ce 3e,ce
Effect13
Overall Potential Moderate Moderate
forArchaeological High Moderate Moderate High Low Low High to High to High High Moderate Moderate
Sites
MITIGATION Duringfinal design ofthe Preferred Alternative,the designs will be reviewed to ensure the applicable conditions are metto maintain the No Adverse Effect
determinations. The Preferred Alternative, once defined, will be surveyed to determine if archaeological sites eligible for listing on the NRHP are present.

TABLE S-2: Summary of Environmental Impacts —Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
SECfION 4�F)/6�F) RESOURCES IMPACTS
Section 4(f)
Resources with de 1 1 1 1 1 1 2 2 2 2 2 2
miminis Impact1°
Section 6(f) 0 0 0 0 0 0 0 0 0 0 0 0
Resources
MITIGATION All applicable conditions must be met in orderto maintain the NoAdverse Effects determination to cultural resources. The NCTA will continue coordination with
local agencies with jurisdiction over park and recreation resourcesto ensure that right-of-way and construction limits within the property boundaries are minimized
tothe extentfeasible.
NATURAL COMMUNITIES IMPACfS�s
Disturbed/Clearcut 552 561 567 544 553 560 513 535 542 514 523 529
(acres)
Agricultural(acres) 121 142 177 121 142 177 153 220 256 128 148 184
UplandForested g13 902 882 982 972 951 1042 1008 987 965 955 935
(acres)
Successional
(acres) 155 128 114 125 99 85 149 117 102 156 130 115
Open Water ZZ Z6 21 22 26 21 22 26 21 22 26 21
(acres)
ICE : Effects on
wildlifeand Weakto Weakto Weakto Weakto
Strong Strong Strong Strong Strong Strong Strong Strong
habitatthrough moderate moderate moderate moderate
habitat effects effects effects effects effects effects effects effects effects effects effects effects
fragmentation
An erosion and sedimentation plan will be developed forthe Preferred Alternative to prevent runoff, erosion and sedimentation impacts and to minimize impactsto
MITIGATION aquatic communities and wildlife in accordance with the NCDENRguidelines and Best Management Practices. The NCrA will coordinate with the USFWS, USEPA, and
the NCWRC on the feasibility and design of a wildlife passage at Stream 5156 for all DSAs, and on designing bridge crossings to be wildlife friendly when feasible for
all DSAs. Control measures will be implemented to reduce the potential for spreading non-native plant species.

TABLE S-2: Summary of Environmental Impacts -Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
JURISDICTIONAL RESOURCES IMPACTS16
Pond Impacts 6.3 5.1 4.1 5.1 3.9 2.9 5.5 3.1 2.1 5.5 6.1 3.3
(acres)
Wetland Impacts
(acres) 7.4 6.9 7.5 8.8 8.2 8.9 12.1 12.5 13.2 9.7 9.1 9.8
Perennial Stream 48 Z96 42,733 38,894 50,100 44,609 40,766 50,739 40,915 37,223 46,105 40,033 36,771
Impacts (linearft.)
Intermittent
Stream Impacts 9,048 9,501 10,101 8,953 9,406 10,006 9,505 9,537 9,986 9,364 9,678 10,417
(linearft.)
TotalStream 106 99 91 111 105 97 120 112 103 111 105 97
Crossings
Total Stream 57,344 52,234 48,995 59,053 54,015 50,772 60,244 50,452 47,209 55,469 49,711 47,188
Impacts (linearft.)
Total I m pacts to
Catawba River 4,145 22,590 20,615 4,145 22,590 20,615 4,145 22,590 20,615 4,145 22,590 20,615
Buffers (sq ft)�'
ICE : Effects on
waterquality, Very Very Very Very Very Very
wetlands, Strong Strong Strong Strong Strong Strong
impaired Strong Strong Strong Strong Strong Strong effects effects effects effects effects effects
waterways,and
effects effects effects effects effects effects
watersheds
The DSAs incorporate measuresto avoid and minimize impactsto Waters ofthe US and the Catawba River buffers. The NCTA agreed to include several bridges in the
MITIGATION Preliminary engineering designs, beyond those required to conveyfloodwaters. In addition,final design efforts will examine all appropriate and practical possibilities
of avoiding and minimizing impactsto Waters ofthe US and Catawba River riparian buffers. Strict adherence to Best Management Practices will assist in minimizing
project impacts.

TABLE S-2: Summary of Environmental Impacts —Gaston East-West Connector Detailed Study Alternatives
ISSUE DETAILED STUDY ALTERNATIVE
4 5 9 22 23 27 58 64 68 76 77 81
PROTECTED SPECIES IMPACTS
May May May May
Schweiniti s
Affect/Not Affect/Not Affect/Not Affect/Not
Sunflower�s Likelyto No Effect No Effect Likelyto No Effect No Effect Likelyto No Effect No Effect Likelyto No Effect No Effect
Adversely Adversely Adversely Adversely
Affect Affect Affect Affect
Michaux's Sumac No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect
Smooth Coneflower No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect
Carolina No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect No Effect
Heelsplitter
MITIGATION Concurrence needed from US Fish and Wildlife Service on the biological conclusion of MayAffect/Not LikelytoAdversely Effect. Once the Preferred Alternative is
selected, additional surveys will be conducted as needed.
Notes:
1. Source: Gaston Cost Estimate Support Memorandum, HNTB, December 2008
2. ICE = Indirect and/or cumulative effect
3. Neighborhoodsnotnamed/identifedinavailableGlSmapping,butareasmntainingdustersofhomesandmnsideredruralmmmunities
4. BerewickDistrictPark�ownedbyMecklenburgCounty)
5. a)KaryaeYMCAFacility—impacttostructures,entrance,andparking;b)Linwood5pringsGolfCourse-accesschangeonly;c)Carolina5peedway—right-of-wayencroachmentandimpacttoparking;d)
Duke Energy recreational fields — right-of-way encroachment, e) Daniel Stowe Botanical Garden — mi nor right-of -way encroachment
6. DSAs 4, 22, 58 and 76 encroach on ForesNiew High SchooPs property edge and mme parking areas. DSAs 58, 64, 68, 76, 77, and 81 encroach on Sadler Elementary School property with no impactsto
school use or access.
7. Undeveloped lots behind the barrier must have a building permit issued by the Date of Public Knowledge forthis barrier to be mst effective.
8. VAD—VoluntaryAgriculturalDistrict
9. AcreagesarecalculatedforthepreliminaryengineeringdesignrightofwayforeachDSA.Areasofprimeandstatewideimportantmilsalreadyinurbandevelopmentwerenotindudedinthetotals.
10. There may be one to three individual lines in a power transmission easement. This table reports the numbers of individual transmission line crossings.
11. The four gas transmission pipeline crossings are located in the two easements that cross US 321 near Crowders Creek Road.
12. Indudes all of the multiple pipes/culverts required at interchanges.
13. a)ThomasAllimn House; b) Harrimn Family Dairy Farm; c)1BF Riddle House; d) William Clarence Wilmn House; e) Wolfe Family Dairy Farm
14.Deminimisimpactsonpublidy-ownedparksaredefnedasthosethatdonotadverselyaffecttheactivities,featuresandattributesofthe5ection4�f)remurce. BerewickDistrictParkwouldbeminimally
impacted by all DSAs and it appears there are grounds for a de minimisfinding. De minimis impacts related to historic sites are defned asthe determination of either"NoAdverse EffecC' or "No Historic
PropertiesAffected" in mmpliance with Section 106 of the National Historic Preservation Act (NHPA). The Wolfe Family Dairy Farm would be impacted by DSAs 58, 64, 68, 76, 77, and 81. The State
Historic Preservation Office has mncurred that these impact would mnstitute a de minimis effect , a nd FH WA i ntends to use SHPO's mncurrence as a basis of a de minimis finding for this property if DSA
58, 64, 68, 76, 77, or 81 is selected as the Preferred Altemative.
15. Acreages calculated within the DSA right-of-way I imits.
16.Theseimpactswerecalculatedusingthepreliminaryengineeringdesigns mnstructionlimits,withanadditiona125-footbuffer.
17. This indudes impacts to buffer zones 1 and 2 for the Catawba River, South ForkCatawba River, and Catawba Creek. Mitigation is not required for impacts of less than one-third acre (14,505 square feet).
18. Dueto its location on the northem edge of the DSA mrridor, it is assumed all impacts to the observed Schweinitrs sunflower population will be avoided.

APPENDIX C
Comments from State and Federal Agencies

APPENDIX D
Comments from Local Governments

APPENDIX E
Comments from the Public and Interest Groups and Organizations

APPENDIX F
Comments Responding to USACE Public Notice

� N O R T H C A R O L I N A
; � Turnpike Authority
Gaston East-West Connector
Comments Responding to USACE Public Notice
.. �
.�
My family enjoys the couple of acres we have, especially watching the hawk family in the woods behind our home and seeing a deer or fox run through the
u01 1 letter 6/28/2009 Pierce Heather Protected Species yard. Being able to show these beautiful sites of nature to my children is rare in this day and time. This multi-million dollar road would do irreversible
and Wildlife damage environmentally to the peninsula. Instead of putting a toll road through Belmont, we all need to be concerned with protecting the delicate eco-
system of the peninsula.
Land Use and Sprawl is not good for Belmont or Gaston County. Belmont has seen enough growth, especially on the peninsula. We don't need strip malls and the
u01 2 letter 6/28/2009 Pierce Heather Transportation commercial growth that would come with the road, no matter what part of the county we are talking about. The small town of Belmont does not need
Planning another bridge crossing the Catawba River into our borders.
Personally, I do not believe enough thorough, and I do mean thorough, research has been done by the proper authorities regarding environmental research
u01 3 letter 6/28/2009 Pierce Heather Water Resources on and around the peninsula of Belmont. Catawba Riverkeeper David Merryman does not support the Garden Parkway, nor does the Lake Wylie
Lakekeeper, Ellen Goff.
Indirect and Water This toll road will make a huge impact on Gaston County environmentally, especially Belmont with the waters of the Catawba River, Lake Wylie, and South
u01 4 letter 6/28/2009 Pierce Heather Fork River surrounding the peninsula. Erosion of the banks of the waters, water table declining, displacing and killing of wildlife and runoff from road's
Cumulative Effects Resources surtaces will wash sediment downstream.
u01 5 letter 6/28/2009 Pierce Heather Air Qualit This re ion is alread in �eo ard of not meetin clean air standards
Alternatives Cultural We don't need 2 more bridges built across Belmont for a road that doesn't even connect I-85 and stops at HWY 321 right at the Historic York Chester
u01 6 letter 6/28/2009 Pierce Heather nei hborhood in Gastonia
Considered Resources 9
ApplicanPs stated purpose is to improve east-west transportation mobility. Specifically, they stat that traffc on I-85 is at critical levels. However, their own
u02 1 letter 7/17/2009 Medlin John Indirect and publications indicate that projected traffc counts will be worse with the project than without. Because the project does not accomplish iPs objective, the
Cumulative Effects impacts to the environment are not justified and it should not be allowed.
In stating the existing conditions and making predictions about the furture development of the region ("..much of the rural area shifting toward a more
Indirect and suburban environment."), the applicant fails to reveal that much of that future development is contingent on the construction of this project. Without the
u02 2 letter 7/17/2009 Medlin John Cumulative Effects project, the development will be significantly delayed. Much of the existing local population is against the project because of the expected growth, and iPs
affect on adjacent property values. These values will be influenced by the impacts of the project in the form of increased storm water runoff, erosion, and
siltation, as well as loss of forest and wetlands, noise pollution, and reduced aesthetic value.
As predicted by the applicant, total traffc count into and out of the county will increase because of the project. The additional traffc will affect already poor
u02 3 letter 7/17/2009 Medlin John Air Quality air quality in the region.
Purpose and Need The project fails to meet the stated purposes of reducing congestion and substantially improving east-west connectivity. Therefore, the Project has no
u03 1 letter 7/17/2009 Stop the Toll Road.com Toole William forAction merit.
Alternatives Because the Transportation Agencies have summarily rejected without meaningful analysis precticable alternatives (such as establishing High Occupancy
u03 2 letter 7/17/2009 Stop the Toll Road.com Toole William Considered Toll (HOT) lanes on I-85, improving existing transportation facilities, and transportation demand management, or mass transit) no 404 permit may be
issued.
Indirect and The expected adverse effects of uncontrolled suburban sprawl through agricultural lands that lack municpal water and sewer outweigh the marginal benefts
u03 3 letter 7/17/2009 Stop the Toll Road.com Toole William Cumulative Effects of the Project. For these reasons, the Corps must conclude that the Project cannot be approved for a permit under section 404 of the Clean Water Act.
u03 4 letter 7/17/2009 Stop the Toll Road.com Toole William Indirect and The DEIS provides no evaluation reflecting the type of development that would be stimulated by the Project, or the indirect and cumulative impacts of such
Cumulative Effects development upon the existing community.
u03 5 letter 7/17/2009 Stop the Toll Road.com Toole William Purpose and Need A primary purpose of the Project is to improve traffc flow and safe travel on I-85, US 29l74 and US 321 in the Project Study Area. The Project fails to meet
for Action the stated ur oses of decreasin con estion.
u03 6 letter 7/17/2009 Stop the Toll Road.com Toole William Purpose and Need The DEIS does not demonstrete the substantial improvement to treffc flow on I-85, US 29/74, or US 321 that is required to meet the stated Project purpose.
for Action
The DEIS contains no evaluation at all of the effect of terminating the Project at US 321, which the North Carolina Turnpike Authority states is the likely
u03 7 letter 7/17/2009 Stop the Toll Road.com Toole William Indirect and westem terminus. In response to a substantial number of questions from the community, the North Carolina Turnpike Authority ultimately presented a June
Cumulative Effects 2, 2009 study comparing various treffc scenarios at US 321, including that of terminating the Project there. The study shows the following daily traffc
counts in the year 2030 and demonstretes that constructing the Project increases traffic on I-85 at US 321. All scenarios
Purpose and Need The draft Environmental Impact Statement prepared by the the Turnpike Authority declares that the purpose of the toll road is "to improve treffc flow on the
u03 8 letter 7/17/2009 Stop the Toll Road.com Toole William sections of I-85, US 29-74 and US 321" in the study area, and to "reduce congested vehicle miles travelled" compared to traffic if the Project is not built.
for Action Because the toll road does not meet the basic purpose of relieving treffc congestion, this Project has no merit.
ppen ix
COmmen[5 KespOntling [O USHCt F'UbllC NO[ICe
Gaston Connector DEIS
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� N O R T H C A R O L I N A
; � Turnpike Authority
Gaston East-West Connector
Comments Responding to USACE Public Notice
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If DEIS estimates are to be believed, in 2030 residents on the Belmont Peninsula will save 23 minutes travelling to the Charlotte Douglas Airport by taking
u03 9 letter 7/17/2009 Stop the Toll Road.com Toole William Alternatives the toll bridge. This time savings occurs in part because the No-Build Alternative is estimated to take 57 minutes. Currently, MapQuest shows the trip
Considered taking 17 minutes. For the proposed travel savings to be correct, treffc on South Point Road and Wilkinson Boulevard must become so congested that the
trip increases by 40 minutes, a two hundred percent increase in 20 years. This simply is not credible.
Land Use and It is probable that from the US 321/Robinson Road interchange to the airport would see improved travel times over the toll road. The fact is, however, that
u03 10 letter 7/17/2009 Stop the Toll Road.com Toole William Transportation Google Maps shows there is no development at the US 321/Robinson Road interchange and it is not a travel destination. The Project provides no
Planning meaningful, credible improvement in east-west connectivity, and certainly is not worth the impacts it will cause to the environment and the community.
Alternatives The DEIS appers to have consistently overestimated the "existing" treffc volume along each of the major roadways in the project area. This leads to
u03 11 letter 7/17/2009 Stop the Toll Road.com Toole William Considered inflated treffc congestion projections. The failure to accuretely reconcile the 2006 estimates with the 2007 observed data further corrodes the credibility of
the long-term model projections.
The DEIS cursorily reviews, then summarily concludes, that a number of alternatives, including High Occupancy Toll (HOT)/High Occupancy Vehicle (HOV)
u03 12 letter 7/17/2009 Stop the Toll Road.com Toole William Alternatives on I-85, expanded mass transit, upgrading the existing road system, or some combination of these, fail to meet or exceed the defined purpose and need.
Considered Of course, the Tranportation Agencies then fail to apply the same standard of success to their preferred alternative of Project construction.
u03 13 letter 7/17/2009 Stop the Toll Road.com Toole William Alternatives The Transportation Agencies concluded that Mass Transit Improvements on Existing Locations (consisting of bus or rail service) would not attrect enough
Considered tri s to noticeabl reduce vehicle miles travelled or con estion. The DEIS does not contain an stud to su ort this conclusion. T
The DEIS analysis of the Improve Existing Roadways Alternative is particularly disheartening. For example, the April 24 DEIS failed to review and consider
the Charlotte Region Fast Lanes Study (draft Final Report March 2009) which concluded that a High Occupancy Toll (HOT) lane option was feasible, could
u03 14 letter 7/17/2009 Stop the Toll Road.com Toole William Alternatives be constructed in existing I-85 right-of-way, would save commuters 19 minutes, and unlike the Project would be fully self-supporting (construction and O&M)
Considered from toll revenues. The DEIS rejected the Improve Existing Roadways Alternative without the detailed study and for summary conclusions that are now
redundant (and at direct odds with other professional studies) — travel times would not improve compared to the No-Build alternative, failure to provide east-
west connectivity, and failure to improve level of service.
Alternatives The Transportation Agencies have not engaged in an objective evaluation of the alternatives using empirical data. Compared to their willingness to
u03 15 letter 7/17/2009 Stop the Toll Road.com Toole William Considered overlook the same defciencies with the Project, the Transportation Agencies have not conducted a good faith review of the precticable alternatives. For this
reason, the Corps must conclude that the Project is not eligible for a 404 permit.
Indirect and Cultural The Transportation Agencies have failed to evaluate the effects of the reasonably foreseeable - indeed probable - realtiy that the Project will daed-end into
u03 16 letter 7/17/2009 Stop the Toll Road.com Toole William Cumulative Effects Resources US 321 for decades, and perhape forever. This reality has the potential to have direct impacts upon two historic neighborhoods located along US 321.
Indirect and The DEIS has not adequately evaluated the indirect effects and cumulative impacts of constructing a transportation facility that is designed to promote
u03 17 letter 7/17/2009 Stop the Toll Road.com Toole William Cumulative Effects suburban sprawl in what is principally agricultural land and pastures. The area to be served by the Project does not muncipal water and sewer, and none is
planned for much of the area.
The DEIS fails to account for the fact that the withdrawal of the North Carolina State Implementation Plan means the MUMPO and GUAMPO transportation
plans have now lapsed into a one year conformity grece period. At no point does the DEIS address the fact that by promoting suburban sprawl, the Project
u03 18 letter 7/17/2009 Stop the Toll Road.com Toole William Air Quality will substantially increase vehicle emissions of ozone precursors and contribute to the region's ozone problem, currently designated "serious". Given the
fact that the region has been unable to reduce iPs baseline ozone levels, it is likely specifc enforceable actions and transportation control measures will
have to be adopted to control vehicle emissions.
u03 19 letter 7/17/2009 Stop the Toll Road.com Toole William Air Quality The DEIS fails to evaluate the impacts of the Project on an already serious regional ozone problem.
The DEIS fails to evaluate how the required wetlands compensatory mitigation will be implemented. In fact, the DEIS states that even a"conceptual
u03 20 letter 7/17/2009 Stop the Toll Road.com Toole William Water Resources mitigation plan" is one of the several "unresloved issues and areas of controversy". Securing suitable compensatory wetland mitigation sites within the
lower Catawba River watershed is a well-recognized problem, and both the Corps and the public have a need to understand hwo the Transportation
Agencies propose to address this issue.
u04 1 letter 7/21/2009 Southem Environmental Law Farren J. David Comments submitted to USACE are identical to comments submitted during DEIS public review period - control number i005
Center
Appendix F
Comments Responding to USACE Public Notice
Gaston Connector DEIS
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