20120285_Alternatives Report_20050915

1
1
REVIEW BOARD SUMMARY
OF
THE EVALUATION OF
IMPROVE EXISTING ROADWAYS
ALTERNATIVES
GASTON COUNTY EAST -WEST
CONNECTOR STUDY
T.I.P. PROJECT NO. U -3321
Prepared For
w%, uEPT OP FNViRotl [,,�_ t
AND NATPRAP AES©URRU S
MOORESV11- 'CL
WA Tr
North Carolina Department of Transportation
Protect Development and Environmental Analysis Branch
Prepared By
a
1616 East Nhllbrook Road
Raleigh, NC 27609
[phone]
June 10, 2005
SEP 1 5 200

TABLE OF CONTENTS
Review Board Summary of the Evaluation of Improve Existing
Roadways Alternatives
Gaston County East -West Connector Study
TIP Protect Number U -3321
10 Introduction
1 1 Background
12 Purpose of Report
13 Purpose and Need for the Project
14 Basic Types of Alternatives
3
3
3
3
3
2 0 Memo from FHWA and FTA General Councils on Planning Process Integration 4
3 0 NEPA/404 Merger Process Summary
El
3 1 Concurrence Point 1 (Purpose and Need) — Achieved July 24 2002 4
32 Concurrence Point 2 (Alternatives for Detailed Study) — In process 4
33 Review Board 5
4 0 Travel Demand and Traffic Operations Modeling
5
4 1 Travel Demand Model Scenarios 5
4 2 Traffic Operations Analyses 8
4 3 Conclusions from the Travel Demand Modeling and Traffic Operations Analyses 8
5 0 Potential Impacts
5 1 Potential Environmental Impacts
5 2 Potential Engineering Issues
0
10
12
6 0 Inconsistency with Local Thoroughfare Plans and Comprehensive Land Use Plans 14
6 1 Thoroughfare Planning Process
6 2 Comprehensive Land Use Plans
14
14
7 0 Inability of Improve Existing Roadways to Meet the Project s Purposes and Needs 14
8 0 Summary 15

10 Introduction
11 Background
The North Carolina Department of Transportation ( NCDOT) proposes to improve east west
travel between 185 west of Gastonia in Gaston County and I 485/NC 160 in Mecklenburg
County The Gaston County East West Connector Study is designated as TIP Project No U 3321
in the NCDOT s 2004 2010 Transportation Improvement Program (TIP) The TIP shows Project
U 3321 as a multi lane highway on new location from 185 west of Gastonia to NC 160 in
Mecklenburg County
The project study area consists of the following general boundaries in Gaston and Mecklenburg
Counties
* 185 to the north
* the South Carolina State line to the south
* the Charlotte Douglas International Airport to the east and
* the 185 and US 29 74 junction to the west
12 Purpose of Report
The purpose of this report is to explain why the studies and analyses that have been completed to
date sufficiently demonstrate that the Improve Existing Roadways (IER) alternatives should be
eliminated from further study These alternatives do not meet the critical elements of the purpose
and need for the proposed project and they are not consistent with the local thoroughfare plans
and comprehensive land use plans
13 Purpose and Need for the Protect
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 in general
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County This project purpose is based on the following needs
* Need to improve mobility access and connectivity within southern Gaston County and
between southern Gaston County and Mecklenburg County
Need to reduce congestion and improve traffic flow on the sections of 185 US 29 74 and
US 321 in the project study area improve high speed safe regional travel service along
the US 29 74 intrastate corridor and generally improve safety and reduce above average
accident rates in the study area
14 Basic Types of Alternatives
The NCDOT considered the following basic types of alternatives in accordance with FHWA
Guidelines (Technical Advisory T6640 8A)
3

1 No Action
2 Transportation System Management (TSM) and Transportation Demand Management
(TDM) Measures
3 Mass Transit
4 Improve Existing Roadways (Improve 185 Improve US 29 74 or Improve Both 185 and
US 29 74)
5 New Location
2 0 Memo from FHWA and FTA General Councils on Planning Process Integration
A recent draft memorandum from the General Councils of FHWA and FTA dated September 20
2004 discusses the integration of the transportation planning process which includes
Thoroughfare Plan development and the NEPA process
The transportation planning process required by 23 USC 134 and 135 and 49
USC 5303 5306 is designed to set the parameters for the project development
process Projects must come from the transportation improvement program
(TIP or STEP) established to implement the plan As a result much of the
data and decision making undertaken by state and local officials during the
planning process carry forward into the project development activities that
follow the TIP or STIP This means that the planning process and the
environmental assessment required during project development by the
National Environmental Policy Act of 1969 (NEPA) (42 U S C 4231 et seq )
must work in tandem with the results of the transportation planning process
feeding into the NEPA process To a much greater degree than other Federal
programs Congress has put great emphasis on the transportation planning
process for shaping transportation decisions and has retained and refined that
emphasis in surface transportation law over decades
3 0 NEPA/404 Merger Process Summary
31 Concurrence Point 1 (Purpose and Need) — Achieved July 24, 2002
32 Concurrence Point 2 (Alternatives for Detailed Study) — In process
Because of the project scope and size of the project study area the merger team leaders
decided to break Concurrence Point 2 into sections to make the process more
manageable
February 17, 2004 Pre Concurrence Point 2 meeting
Identified which new location alternatives NCDOT should prepare functional designs
prior to the new location Concurrence Point 2 meeting
H

August 17, 2004 Partial Concurrence Point 2 meeting
The purpose of this merger meeting was to achieve concurrence on the non new location
alternatives to be carried forward for detailed study Agreement on the Improve 185 and
US 29 74 Alternative could not be reached and the decision was made to elevate to the
Review Board
33 Review Board
September 14, 2004 — Elevation Meeting #1
Merger Team members attended Concurrence was not achieved
September 29, 2004 — Elevation Meeting #2
The supervisors of the Merger Team members attended Concurrence was not achieved
Agencies not concurring with NCDOT agreed to prepare a list of items they would need
to enable them to come to a decision
Week Ending, October 8, 2004
The following agencies provided lists of information and questions to NCDOT USACE
USFWS USEPA NCDWQ and NCWRC
Week Ending October 15, 2004
NCDOT provides a response to the information requested by USACE USFWS USEPA
NCDWQ and NCWRC
October 27, 2004 — Elevation Meeting #3
On October 27 2004 the Review Board met to discuss the project and the issues that the
Merger Team had not reached consensus on
February 8, 2005 Elevation Meeting #4
The Review Board met to continue discussion of the protect issues
4 0 Travel Demand and Traffic Operations Modelin
41 Travel Demand Model Scenarios
As described below a variety of scenarios were modeled in the regional travel demand model to
estimate traffic volumes and changes in travel patterns that would occur The results from the
travel demand model also were used to evaluate traffic operations along 185 and US 29 74
5

A No Build Alternative (Scenario 1) was modeled as a basis for comparison Scenario 5 and
Scenario 5a are the New Location Alternatives scenarios Scenarios 2 3 4 4+ 4a and 8 are
various combinations of improving existing roadways Scenarios 6 and 7 not reported here were
various runs to support the development of functional designs for the preliminary new location
alternatives
Scenario 1— No Build Alternative
No capacity improvements to 185 or to US 29 74 The addition of traffic signals
at six (6) currently unsignalized intersections
Scenario 2 — Improve 185 to 8 lanes
Widen 185 to eight lanes in each direction (addition of one through lane in each
direction) from the existing 8 lane area at Exit 26 (Belmont) west through
Gastonia to the interchange of US 29 74 and 185 This scenario does not include
any improvements to ramps or overpasses in the 185 corridor
Scenario 3 — Improve US 29 74 to 6 lanes
Widen the bridges over the Catawba River and the South Fork Catawba River to
six lanes Widen the four lane section that exists west of Gastonia from Myrtle
School Road west to 185 to six lanes This scenario does not include any turn
lane improvements on US 29 74 or on any other arterials in the project study
area
Scenario 4 — Improve 185 to 8 lanes and US 29 74 to 6 lanes
Scenario 4 is a combination of Scenarios 2 and 3
Scenario 4+ Improve 185 to 8 lanes and US 29 74 to 6 lanes with TSM type measures
(See Figure 1)
Based on the results of the corridor level traffic operations analysis (CORSIM)
for Scenario 4 a list was developed of additional improvements that would be
needed along and in the direct vicinity of the 185 and US 29 74 corridors that
would help maximize the efficiency of traffic operations along the corridor This
list included approximately 70 TSM type measures such as adding turn lanes or
additional lanes in interchange ramps The scenario that included these TSM
type measures was called Scenario 4+
Scenario 4a Improve Existing 185 to 10 lanes (See Figure 1)
Scenario 4a is Scenario 4+ with the following modifications
• 10 lanes on 185 from Exit 21 east to Exit at I-485 (widen 185 to 8 lanes from
Exit 14 east to Exit 21 and widen to 6 lanes on US 29 74)
• Capacity increases on the following road segments that connect 185 and US 29
74
• NC 279 (New Hope Rd) Widen to 6 lanes from dust north of 185 to US
2974
• Cox Rd widen to 6 lanes from dust north of 185 to US 29 74
• Cox Rd widen to 4 lanes from US 29 74 south to Garrison
Blvd/Armstrong Park Drive /Gardner Park Ave (this rd has 3 names in
cox rd vicinity)
• Redbud Drive widen to 4 lanes from US 29 74 south to NC 279
• NC 7 at Exit 26 widen to 4 lanes from north of 185 to US 29 74
T

• Considerations were included in the model to account for intersection
improvements along US 29 74 and at interstate ramps that would result
from implementing the intersection improvements recommended in
Scenario 4+
Scenario 5 Build a 4 lane New Location Freeway
Build a new location freeway south of 185 from 185 west of Gastonia to 1 485
No improvements would be made to existing 185 or US 29 74
Scenario 5a Build a 6 lane New Location Freeway
Scenario 5a a 6 lane new location freeway is a modification of the Scenario 5
(4 -lane new location freeway) The PM peak hour traffic volume results for
Scenario 5 indicated a 6 lane freeway on new location would be needed so the
regional travel demand was rerun with a 6 lane new location freeway
Scenario 8 Scenario 4a plus capacity improvements to north/south feeder roads (See
Figure 2)
Scenario 8 started with Scenario 4a (Improve Existing 185 to 10 lanes) Added
to this were capacity improvements (one lane in each direction) to north/south
roads that connect southern Gaston County to US 29 74 and 185 as have been
suggested in a general way by some of the resource agencies Below is a list of
the roadways where capacity improvements were added in the regional model
The list was developed with input from the Gaston Urban Area MPO It does not
include all the feeder roads that have exits on 185 For future reference the list
was numbered from 1 through 10 based on the roadway section
Section
1
NC 273 south all the way to NC 279 at the Botanical Garden (4 lane divided)
2
NC 7 from Exit 27 south to NC 273 (4 lane divided)
3
NC 279 (New Hope Rd) from Exit 20 on 185 south all the way to NC 273 at the
Botamcal Garden (5 lanes)
4
Redbud Dr from Exit 22 at 185 south to NC 279 (4 lane divided)
5
NC 274 (Union New Hope Rd) Robmwood Rd south past the airport continuing
on Union/New Hope Rd swinging northwest to NC 279 (4 lane divided)
6
Robmwood Rd from NC 279 New Hope Rd south to NC 274 (4 lanes)
7
Robinson Rd from NC 274 south to US 321 (5 lanes)
8
NC 274 at Exit 14 south to Myrtle School Rd continuing south on Myrtle School
Rd all the way to US 321 This road changes names to David Rd then
Stagecoach Rd before meeting up with US 321 (4 lane divided or 5 lane)
9
NC 274 from State Line to Union/S New Hope (4 lane divided)
10
US 321 widened to 6 lanes from State Line to 185 (Note This project impacts
the City s Main Historic District but the widening is necessary to handle existing
and projecte d future traffic )
7

4 2 Traffic Operations Analyses
In order to evaluate Scenarios 1 5 corridor level traffic operations analysis was performed using
a traffic micro simulation model — CORSIM This operational analysis evaluated future 2025
peak hour operations of the Improve Existing Roadways Alternatives (Scenarios 2-4) as
compared to Scenario 5 (New Location) and Scenario 1 (No Build)
4 3 Conclusions from the Travel Demand Modeling and Traffic Operations Analyses
Latent demand for Interstate travel exists in the area
The regional travel demand model showed that as capacity was increased on 185 and US
29 74 (1 a more lanes added to 185 and US 29 74) more people would use it For
example if 185 was widened to eight lanes through the study area (Scenarios 4 4a and
4 +) this would attract up to 1 000 more vehicles during the PM peak hour over the
estimates for the No Build scenario If 185 was widened to 10 lanes (Scenario 8) this
would attract up to 1 600 more vehicles per hour during the PM peak
Substantial diversion of traffic off of 185 and US 29 74 projected to occur if a New Location
roadway were built
Up to 20 25 percent of the traffic on 185 would be diverted to a new location Gaston
Connector if one were constructed (Scenarios 5 and 5a) This means that 185 would
carry up to 1 400 less vehicles per PM peak hour compared to the No Build scenario and
up to 2 800 vehicles per PM peak hour less compared to widening 185 to 10 lanes
Regional network statistics demonstrate a reduction in congested travel for a New Location
roadway and for Scenario 8 (Widen 185 to 10 lanes and widen feeder routes)
Statistics for the entire modeled roadway network were generated from the regional travel
demand model These statistics are for AM and PM peak periods and include vehicle
miles traveled vehicle hours traveled congested vehicle miles and congested vehicle
hours
Building a new location roadway resulted in lower vehicle hours traveled lower
congested vehicle hours and lower congested vehicle miles on the roadway network than
widening 185 to 8 lanes (Scenario 4)
Building a new location roadway reduced congested vehicle miles traveled as effectively
as widening 185 to 10 lanes (Scenarios 4a and 4 +) Only when all the north/south feeder
roads were widened (Scenario 8) does the non new location alternative reduce congested
vehicle hours substantially more

Traffic operations would be generally better or as good on 185 with a new location freeway in
place
Building a new location roadway (Scenario 5a) generally resulted in better or equal
average levels of service on 185 and US 29 74 than improving these existing roadways
(Scenario 4a and 8) even to 10 lanes See Exhibit 1
EXHIBIT 1
Level
of
Service
5F
4 OF
3 D/E
2 C/D
1C
0
Levels of Service on 1 -85
Westbound PM Peak Hour in 2025
13 14 17 19 20 21 22 23 26 27 29 1485
Interchange West to East
5 0 Potential Impacts
Scenario 1
No Budd
Scenario 4a
1 85 to 10 lanes
Scenario 5a
New location
6 lane freeway
Scenario 8
1 85 to 10 lanes
With Y lme
Improvements
Several potential impacts were considered in the evaluation of the improve existing roadways
alternatives Impacts analyzed were for Scenario 8 since this scenario (which improved the
north/south feeder roads [or y lines]) provided the best opportunity to meet the purpose and need
out of all the Improve Existing Roadways Alternatives
Scenario 8 includes numerous improvements to north/south feeder roads in southern Gaston
County as shown in Figure 2 Most of these improvements would be widening existing US and
NC routes such as US 321 NC 7 NC 273 NC 274 and NC 279 to four or five lane roadways
Figure 2 also shows a representative index of the approximate location in the project study area
of Figures 3 -6
0

The estimates of potential impacts were based on information obtained from NCDOT and Gaston
County GIS databases aerial photography and preliminary field observations Potential impacts
for Scenario 8 have been organized into two categories environmental and engineering
Potential impacts from improving the existing east west roadways 185 and US 29 74 are
discussed for both categories along with impacts due to the feeder route improvements The
following table illustrates the potential impacts from the feeder route improvements for the 10
roadway sections described above in Section 41 Further discussion is provided below
51 Potential Environmental Impacts
Human Environment
In general improvements to existing 185 and US 29 74 likely would have an overall lesser
impact on the natural environment than a new location alternative However impacts to the
human environment may be equal to or greater than a new location alternative for Scenario 8
Potential impacts to the human environment would be greatest for improvements along US 321
NC 279 and NC 273 The following human environment impacts along the feeder routes would
be in addition to the human environment impacts associated with improvements along 185 and
US 29 74
Relocations Widening sections of the feeder routes would impact churches residences
businesses churches community facilities parks and historic districts along these roadways
NC 279 (Section 3) and NC 274 (Section 8) could potentially impact 20 churches along the
approximate 16 miles of improvements In general potential residential impacts are greatest
along existing two lane routes such as NC 273 NC 279 and NC 274 where single family homes
and their individual driveways are located on both sides of the roadway Potential business
impacts would be greatest near or between 185 and US 29 74 such as along US 321 (Section 10)
and NC 7 (Section 2) Figures 3 and 4 show the high density development along US 321 and
NC 7 where business impacts could occur respectively
Potential community facility impacts would be greatest along NC 279 (Section 3) and NC 274
(Section 5) Figure 5 shows a section of NC 279 (Section 3) with a high potential for impacts to
community facilities churches and potential historic properties
Parks Two roadway sections have the potential to impact parks based on additional roadway
widening Widening of NC 7 through Belmont could impact Crescent Park (Figure 4) and the
widening of NC 279 could impact the Daniel Stowe Botanical Garden
Historic Sites and Districts A Phase I survey of historic architectural resources was conducted
in May 2003 for the new location study area The study also identified known historic sites and
districts on or eligible for the National Register of Historic Places located in the 185 and US 29
74 corridors
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Historic sites are located along existing US 29 74 (Franklin Boulevard) and US 321 (York
Street) Where these two roadways intersect in Gastonia is the Downtown Historic District
(National Register of Historic Places) which could not be avoided by improvements Figure 3
shows the Downtown Historic District in Gastonia Improvements to US 29 74 (Wilkinson
Boulevard) through Belmont could impact the Belmont Historic District
There are six potential historic sites along NC 279 (Section 3) and US 321 (Section 10) that could
be impacted by improvements Figure 5 shows some of the potential historic sites along NC 279
Natural Environment
Potential impacts to the natural environment could be high along existing US 29 74 where
approximately 6 3 miles of improvements would be necessary to upgrade to six lanes along the
corridor Where improvements are necessary there are several stream and floodplain crossings
Six new bridge crossings would be required one over the Catawba River one over the South
Fork of the Catawba River and four west of Myrtle School Road
Potential impacts to the natural environment would be greatest for improvements along US 321
(Section 10) and NC 273 (Section 1) due to the stream crossings and bridge replacements
Improvement to US 321 would require crossing two streams (one crossing is an existing
potentially historic bridge) with three new bridges Also four floodplains would potentially be
crossed and two known hazardous material sites could be impacted The two hazardous material
sites are RCRA or CERCLA sites A B Carter Inc and Woody s Tire Fire The A B Carter
Inc site generated treated and land disposed of wastewater and sludge from a chroming and
nickel plating operations for the textile machinery The Woody s Tire Fire site was used to store
used tires with roughly 50 000 to 100 000 tires that caught on fire
Improvements to NC 273 would require crossing two streams with two new bridges one of which
will be over the South Fork of the Catawba River
Air Quality
The current NCDOT Transportation Planning TransCad model includes all current TIP projects
At this time a new location roadway such as the one represented on the Gaston Urban MVO
Thoroughfare Plan is modeled Without updating the model it is unknown what will happen to
air quality if the new location freeway represented in the model is replaced with improve
existing I 85/US 29 74 for TIP Project U 3321 the Gaston County East West Connector Study
5 2 Potential Engineering Issues
Constructability
185 would require widening to a minimum of eight to ten lanes throughout the study area under
Scenario 8 The total length of proposed improvements along 185 would be approximately 20 5
miles All interchanges along 185 in the project study area (a total of 11) would need to be
reconstructed in order to meet current AASHTO design standards In addition to work at the
eleven interchanges in the project study area there are fifteen (15) cross street bridges and six
railroad bridges that would need to be replaced because of inadequate horizontal clearances for
additional lanes Figure 6 shows an example of one of the substandard interchanges in the
12

project study area (I 85 at Ozark Avenue [Exit 19]) where an interchange and a railroad bridge
would have to be reconfigured if improvements were made to existing 185
Maintenance of Traffic(MOT) and Travel Delays
The re construction of interchanges and replacement of structures along 185 would result in
lengthy construction periods with significant driver delay through these construction zones and
would require complex maintenance of traffic plans to allow for the safety of the motorists and
the construction workers In order to maintain existing traffic patterns these new bridge
structures would need to be constructed on new alignments and where possible adjacent to the
existing structures These reconstructions and realignments would impact adjacent businesses
Safety Bridge Replacement and Construction Schedule
The construction of new bridge structures would result in increased driver delay and could impact
driver safety during the construction period In order to attempt to minimize these delays it
would be recommended to stagger the replacement of these bridges within the project study area
limits By staggering this construction there could be a delay of 10 years or more before
widening of 185 could be completed resulting in continued driver delays This estimate of
construction schedule was based on the local knowledge of the NCDOT Division Construction
Engineer
Diversion of Traffic Patterns
While structural issues of bridges would not be as prevalent along US 29 74 as compared to 185
there would likely be increased driver delays and potential economic impacts to local merchants
due to changes in travel patterns because of construction along a majority of this east west
corridor
Construction of feeder route improvements outside of the urban areas would be disruptive to
traffic patterns in southern Gaston County which currently suffers from the lack of east west
connectivity Improving the feeder routes while constructing or making improvements along
existing 185 and US 29 74 would reduce mobility and increase travel times between Gaston and
Mecklenburg County Waiting until the 185 and US 29 74 improvements were completed
would extend the already extremely lengthy construction period
Cost
Preliminary construction cost estimates were developed by NCDOT in September 2004 for
Scenario 4+ The estimated construction cost was $2919 million dollars However right of
way (r /w) and utility costs were excluded from the estimate Based on the additional length of
improvements along existing 185 (approximately 4 9 miles) and feeder route improvements for
Scenario 8 it is anticipated that the cost estimate (exclusive of r/w and utility costs) would be
higher and could come close to or exceed the costs of the New Location route
13

6 0 Inconsistency with Local Thoroughfare Plans and Comprehensive Land Use
Plans
61 Thoroughfare Planning Process
The Gaston Urban Area Metropolitan Planning Organization (WO) recommends a new location
highway to improve east west mobility in southern Gaston County This new highway is shown
on the Gaston Urban Area Thoroughfare Plan and is locally known as the US 321/74 Bypass
and the Garden Parkway The Garden Parkway is the number one priority on the MPO s
Unmet Needs List which is a subset of the Gaston Urban Area Thoroughfare Plan
The Mecklenburg Union WO Thoroughfare Plan also identifies a transportation need for an
additional crossing of the Catawba River
6 2 Comprehensive Land Use Plans
The comprehensive land use plans of both Gaston County and Mecklenburg County show
southeast Gaston County and western Mecklenburg County as high growth areas Both
comprehensive plans show a new roadway connection across the Catawba River between these
two high growth areas Western Mecklenburg County and the Charlotte Douglas Airport are
expected to be or already area mayor employment centers The Charlotte Douglas International
Airport is proposing a new mtermodal facility in the southwest portion of their property
7 0 Inability of Improve Existing Roadways to Meet the Project's Purposes and
Needs
The project s purpose and need has two critical basic elements 1) improve east west mobility and
connectivity within southern Gaston County and between southern Gaston County and west
Mecklenburg County and 2) improve traffic flow on 185 and US 29 74 (the only existing east
west corridors in the study area)
The following summarizes the inability of the Improve Existing Roadways Alternatives
(Renanos 4 4+ 4a and 8) to meet the project s purposes and needs J
Q-7 South of US 29 74 there are no continuous east west roadways in the southern half of
Gaston County Improvements to 185 US 29 74 and north/south feeder roads proposed
under Scenario 8 would not improve east west mobility in southern Gaston County
[2 1 Geographically southern Gaston County and western Mecklenburg County are
completely isolated from each other by the Catawba River JThere are no crossings,-of the)
Catawba River south of -US 29 74 until the dge
NC 49 Buster Boyd Bri m York South
Carolina -about 11 miles downstream from US 29 74 - Improvements to 185 US 29 74
and north/south feeder roads would not provide the needed connectivity between
southeastern Gaston County and western Mecklenburg County
14

3 The regional travel demand model runs show that improvements Made to US 29 74 ands
existing I 85_continue to attract more traffic due to the latent travel demand in the area
resulting-in a _build it and they-will c6ntinue to come_ situation
4 The regional travel demand modeling and corridor level operations analyses (described in
Section 3) demonstrate that the diversion of- traffic achieved by 9--new location roadwayD
(Scenario S) is more effective or as effective at improving traffic flow-on I-85 and US 29D
74 than providing direct improvements to these roadways
Improving existing 185 and US 29 74 would not meet the need for connectivity and)
would only minimally-improve traffic flow on existing 185 and US 29_7_4 People would
still have to travel north on two lane roadways many through downtown areas and some
through historic districts to go east and west Even when improvements to north/south
feeder roads were added to create Scenario 8 additional traffic is attracted to 185 during
the peak hour because of the latent demand As a result the levels of service along 185
cdegrade for Scenario 8 as compared to Scenario 4a- ,
6 While improving existing 185 would improve traffic capacity and operations along 185
in the study area it is not a reasonable alternative due to travel delays during
construction long construction duration and community disruption caused by the
required improvements to existing 185 and the north south feeder routes in the study area
to improve access to the interstate Scenario 8 would require construction at 11--)
interchanges and 15 cross street bridges along I 85= replacing six (6) bridges along US)
29 74 and replacing -10 bridges along the y lmes'--1
7 Scenario 8 (Improve 185 to 10 lanes US 29 74 to 6 lanes and improve feeder roads) will
significantly impact the human environment within the entire project study for
businesses residences community facilities safety travel patterns and historic sites
Potential impacts to the human environment would be greatest for improvements along
US 321 NC 279 and NC 273 Potential impacts to the natural environment would be
greatest for improvements along US 321 and NC 273 due to the stream crossings and
bridge replacements Potential impacts to the natural environment could be high along
existing US 29 74 where six new bridge crossing would be required
8 Scenario 5 (Build a New Location Freeway) satisfies the critical elements of the purpose
and need statement because it 1) improves east west mobility and connectivity within
southern Gaston County and between southern Gaston County and west Mecklenburg
County and 2) Improves traffic flow along 185 and US 29 74
8 0 Summary
As described above the NCDOT believes the studies and analyses that have been completed to
date sufficiently demonstrate that the Improve Existing Roadways (IER) alternatives should be
eliminated from further study These alternatives do not meet the critical elements of the purpose
and need for the proposed project and they are not consistent with the local thoroughfare plans
and comprehensive land use plans
15

LEGEND
40.V 6 LOVEMENTS TO 1 -85 - SCENARIO 4A
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v 40V 8 La NO U 3321 GASTON and MECKLENBURG
X11
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LEGEND A& 6 ROVEMENTS TO 1 -85 - SCENARIO 8
8 ECT NO U 3321 GASTON and MECKLENBURG
WI COUNTIES EAST WEST CONNECTOR STUDY
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SCENARIO DESCRIPTIONS
GASTON COUNTY EAST -WEST CONNECTOR STUDY
TIP PROJECT NO U -3321
GASTON AND MECKLENBURG COUNTIES
FEDERAL PROJECT NUMBER STP- 1213(6)
STATE PROJECT NUMBER 8 2812501
Below is a summary of the scenarios discussed at the August 17 2004 Merger Team Meeting
Scenario 1— No Build Alternative
No capacity improvements to I 85 or to US 29 74
Scenario 2 — Improve I -85
Widen I 85 to eight lanes in each direction (addition of one through lane in each
direction) from the existing 8 lane area at Exit 26 (Belmont) west through Gastonia to the
interchange of US 29 74 and 185 This scenario does not include any improvements to
ramps or overpasses in the I 85 corridor
Scenario 3 — Improve US 29 -74
Widen the bridges over the Catawba River and the South Fork Catawba River to six
lanes Widen the four lane section that exists west of Gastonia from Myrtle School Road
west to 185 to six lanes This scenario does not include any turn lane improvements on
US 29 74 or on any other arterials in the project study area
Scenario 4 — Improve both I -85 and US 29 -74
Scenario 4 is a combination of Scenarios 2 and 3
Scenario 4+ — Improve I -85 and US 29 -74 and include TSM Measures
Based on the results of the corridor level operations analysis for Scenario 4 a Scenario
4+ was developed
Scenario 4+ includes the improvements from Scenario 4 plus
• Additional through lane in each direction on I 85 (widen to 10 lanes)
from Exit 21 (Cox Road) to Exit 27 (NC 273)
• Intersection ramp and cross street improvements along entire length of
I 85 and US 29 74 in study area (the long list in the meeting packet)
Scenario 5 — Build a New Location Freeway
Build a new location freeway south of 185 from I 85 west of Gastonia to 1485 No
improvements would be made to existing I 85 or US 29 74

Merger Review Board Elevation Meeting
Gaston East -West Connector
TIP No U -3321
October 27 2004
AGENDA
10 00 am
Welcome
Roger Sheats
10 05 am
Introductions
Roger Sheats
10 10 am
Project History
Derrick Weaver
10 15 am
Member Brief's
Drew Joyner
(time keeper)
GUMPO
MUMPO
NCDOT
FHWA
NCWRC
NCDWQ
USFWS
USEPA
USACE
10 45 am Review Board Questions
1145 am Summary / Closing Remarks Roger Sheats
12 00 am Adjourn

Section 4041 EPA .merger Project Team Meeting Agreement
Concurrence Point No I - Purpose .cud N'
eed
Proieet No ITIP'No Vame/bescrtptton
Federal Project Nurnber STP 12 13'(6) State P'rotect'rumber S 2812501
TIP Number U 3321
Dcscriptsort Gaston Edyt- 'West Cofndar 5tudv 3n brtston and Mceltlenburg Counties
Purpose and Need +ofPrapo5edProject
1 he purpose of the proposed action is to Improve east West trart�portatton nwblllt� rn the
area around the City of Gastonia. betweell stoma and the Charlotte metropolitan area
In general, and pa4 muLarly to establish dirLct access between'the rapidly growing area of
southeast Gaston Count} and'west iMecklenburg County' ThL-. project purpose Is based
on the foLlovying
Need to impro -ve 1110btitty access and connectivity wtthm'southem Gaston
County and betwecn southern Gaston Counq and Mecklenburg County
on A
Need to reduce congest= and improve traffic tIo%V the sections of I -85 US
29 -74 and QS 321 in the project studv area improve high -s eed safe regional
travel service along the GS 29 -74 tntmiate corridor and generally improve sarety
and reduce abo�rr aNera,2e accident rates to the Study area
The -project stud) area consists of the"lollowing generAJ boundaries- 1-85 to the north the
SOL'th CVohna State lime to the south, the Charlotte -C uglas International Airport to the
east and the 1 -85 ,anA US 29 -74 junction to the'west
Me Project Team concurred an this date of � � O,� Z with the purpose of
grid geed for the prpposed project as stated abo -ve
USACEAi
DO
% X
NCDWQ (Vb"J 'L

Notes for Presentation
Two fundamental concerns with a premature elimination of
alternatives
1) Circumvents Avoidance and Minimization Process
2) Delays in Permitting 404/401 (3rd Party intervention)
Purpose & Need
• Broad versus Strict interpretation
• Recollection of DWQ staff
• Written meeting minutes
Impacts & Modeling
• Modeling for 4+ not performed
• Assessment of impacts for New Location done, Non - Location not
done
Threatened and Endangered Species
• Protection of Existing Uses
• Wildlife listed specifically as an existing use
• Defer to WRC, DMF, and USFWS
• All have expressed concerns at this time
• If don't eliminate non -New Location properly Dead in the water if
T &E issue arises
LOS
• Even new location alternative need upgrades to I -85
• Not assessed at this time
Conclusion
• Not necessarily opposed to a new location alternative
• However, need to do full and fair assessment of alternatives to
eliminate

SCENARIO DESCRIPTIONS
GASTON COUNTY EAST -WEST CONNECTOR STUDY
TIP PROJECT NO U -3321
GASTON AND MECKLENBURG COUNTIES
FEDERAL PROJECT NUMBER STP- 1213(6)
STATE PROJECT NUMBER 8 2812501
Below is a summary of the scenarios discussed at the August 17 2004 Merger Team Meeting
Scenario I — No Build Alternative
No capacity improvements to 185 or to US 29 74
Scenario 2 — Improve I -85
Widen I 85 to eight lanes in each direction (addition of one through lane in each
direction) from the existing 8 lane area at Exit 26 (Belmont) west through Gastonia to the
interchange of US 29 74 and I 85 This scenario does not include any improvements to
ramps or overpasses in the I 85 corridor
Scenario 3 — Improve US 29 -74
Widen the bridges over the Catawba River and the South Fork Catawba River to six
lanes Widen the four lane section that exists west of Gastonia from Myrtle School Road
west to I 85 to six lanes This scenario does not include any turn lane improvements on
US 29 74 or on any other arterials in the project study area
Scenario 4 — Improve both I -85 and US 29 -74
Scenario 4 is a combination of Scenarios 2 and 3
Scenario 4+ — Improve I -85 and US 29 -74 and include TSM Measures
Based on the results of the corridor level operations analysis for Scenario 4 a Scenario
4+ was developed
Scenario 4+ includes the improvements from Scenario 4 plus
• Additional through lane in each direction on I 85 (widen to 10 lanes)
from Exit 21 (Cox Road) to Exit 27 (NC 273)
• Intersection ramp and cross street improvements along entire length of
I 85 and US 29 74 in study area (the long list in the meeting packet)
Scenario 5 — Build a New Location Freeway
Build a new location freeway south of 185 from I 85 west of Gastonia to 1485 No
improvements would be made to existing 1 85 or US 29 74

Merger Review Board Elevation Meeting
Gaston East -West Connector
TIP No U -3321
October 27, 2004
AGENDA
10 00 am
Welcome
Roger Sheats
10 05 am
Introductions
Roger Sheats
10 10 am
Project History
Derrick Weaver
10 15 am
Member Brief s
Drew Joyner
(time keeper)
GUMPO
MUMPO
NCDOT
FHWA
NCWRC
NCDWQ
USFWS
USEPA
USACE
10 45 am Review Board Questions
1145 am Summary / Closing Remarks Roger Sheats
12 00 am Adjourn

Section 404INEPA Merger Project Teams. Meeting Agreement
Concurrence Point No I - Purpose and Need
Prot Na ITIF No /farrne/ escrtpoon
Federal Project Number S`I'P- 1213 {6} Slate Project Ni umber 8 2912501
TIP Number U 3321 R
Description Gaston East -West Corridor Studv in Or'ston and Mecklenburg Counties
PuZpose and Need of Proposed'.Project
the purpose of the proposed action is to improve cast `%cst traq► portat►on mobility in the
area around the City of Gastania. betwe -en ChWonia and the Charlotte metropolitan area
in genera), and par vaitarly to establish dirLct access bete °een'the rapidly grawtnWarea of
southeast Gaston Courit.3 and w= Mecklenbuq� County This project pilrpose is based
on the following
Need 10 tmprave Mobiltty access and connectivity %kithin southem Gaston.
County and between wvthem Gaston Count) and 1\4Cd Lnburg CoUMV
Need�to reduce congest= and improve tr -ifc flow �
f the sections of I -85 ILJS
29 -74 and DS 321 in the project studv area Improve high - speed, safe regional
travel service-along the US 29 -74 intraslate corridor and generally improc,sarety
and reduce above ai emge accident rate in the study area
The project study area consists of the tollowing general bowi€laries I -85 to the north the
South Carolina State line to the south, the Charlotte- Douelas International Airport to the
east and thL I -8.) an'd US 29'74 function to the -,Nest
the Prnjeet "foam concurred on this date of I � q ,� � with Ibe purpose of
and need for the proposed pkgeet a- stated above
Ir

�1
Notes for Presentation
Two fundamental concerns with a premature elimination of
alternatives
1) Circumvents Avoidance and Minimization Process
2) Delays in Permitting 404/401 (3rd Party intervention)
Purpose & Need
• Broad versus Strict interpretation
• Recollection of DWQ staff
• Written meeting minutes
Impacts & Modeling
• Modeling for 4+ not performed
• Assessment of impacts for New Location done, Non - Location not
done
Threatened and Endangered Species
• Protection of Existing Uses
• Wildlife listed specifically as an existing use
• Defer to WRC, DMF, and USFWS
• All have expressed concerns at this time
• If don't eliminate non -New Location properly Dead in the water if
T &E issue arises
LOS
• Even new location alternative need upgrades to I -85
• Not assessed at this time
Conclusion
• Not necessarily opposed to a new location alternative
• However, need to do full and fair assessment of alternatives to
eliminate ate pa" k / -.('
:1 i1�fi(rA dn

Michael F Easley Gov OR
William G Ross Jr Secretary
North Carolina Department of Environment and Natural Resources
Alan W Klimek P E Director
Division of Water Quality
Briefing Paper for Review Board
October 27, 2004
Primary Issues — The DWQ has two fundamental concerns associated With the premature
elimination of alternatives
Circumvents the Avoidance and Minimization Process
Delays in 404/401 permitting due to incomplete alternative analysis
Purpose and Need
Approved 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 in general
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County The project purpose is based on the following
• Improve mobility access and connectivity in southern Gaston County and between southern
Gaston County and Mecklenburg County
• Reduce congestion and improve traffic flow on the sections of 185 US 29174 and US 321 in
the project study area improve high speed safe regional travel service along the US 29 74
intrastate corridor and generally improve safety and reduce above average accident rates in
the project study area
Prior to agreeing to the Purpose and Need statement, the DWQ asked if the statement as
written would preclude a fair assessment of non new location alternatives DWQ was
assured both orally and in writing that a broad interpretation of the Purpose and Need
would be employed during the planning of the protect, and that a full and fair assessn
of all alternatives would be considered /
The following statement is taken from the official May 15 2002 meeting minutes
The Statement of Purpose and Need repeatedly uses the term southern Gaston
the area we re talking about south of 185
Southern Gaston County is expected to receive the most growth based on the
Land Use Plan but we are referring to east west transportation needs and no
Gaston County It was not the intent to pre suppose any alternatives at a sp/
as ruling out alternatives for improved connectivity north of 185 The docu/
in this light and revised accordingly
Transportation Permitting Unit
1650 Mail Service Center Raleigh North Carolina 27699 1650
2321 Crabtree Boulevard Suite 250 Raleigh North Carolina 27604
Phone [phone]/ FAX [phone]/ Internet htto //h2o enr state nc us /ncwetlands
An Equal Opportunity /Affirmative Action Employer -50/ Recycled /10/ Post Consumer Paper

Impacts and Alts Developed
At this time we do not believe that the non -new location alternatives have received a full and
fair assessment when compared to the new location alternatives
• In the position paper submitted by the DOT it was stated that traffic modeling on 4+
alternative was not developed It was assumed that the alternative would not work See
statement below
Because of operational deficiencies Identified in Scenario 4, numerous TSM type
Improvements along US 29 74 were incorporated into Scenario 4, resulting In Scenario
4+
The corridor level model was not rerun for these improvements It is likes that makin
these improvements would simply shift the con estion f y g
demand model runs W oul d g archer downstream The regional
already completed show that improvenents made to US 29 74 and
existing 185 continue to attract
resulting in a more traffic due to the lat, i travel
recommended imprlovemen s Will continue to come demand In the area
making those Improvements thunning the model Identi sitiatzon The cycle o
P running the,riodela �g new areas of congeSQ °n g
adequately evaluate the ability
project u of the Im rove gait was not necessary to
P rpose and need It would si, p Existing h'oad
Scenario 4+ I?� addmore1 waYsAlternatives to meet the
mprovements to the listfor
• In the
position paper submitted b
for Potential thdOT
location alternatives as for othe 94 n� n alter W as stated that
See statement below l emativ at the sa
arson Segments s not Performed level of analy is
s
or
Only a curso were assess d o the not] -neW
These impacts level impact anal)4r do e y the team
pacts are not at the sam /o nefOy'the
alternative Impacts Therefore Inc 'Yetail4s�he Improve exlstl
'r�,,._ _ . trnctive t� �orrldOr levP� ng alteynat

I
l�
Level of Service (LOS)
• According to the documentation presented the LOS would be improved if a new location
alternative is built and would not be improved if a non new location alternative is built
However for both new location and non new location alternatives certain sections of I
85 and US 29/74 would have failing LOS in the design year 2025
• Improvements would need to be made to 185 and US 29/74 regardless of the alternative
chosen
• Most of the deficiencies in LOS on 185 are a result of poor service on surface streets
adjacent to 185 interchanges Thus it appears that much of the congestion on 185 could
be reduced by improvements to secondary roads rather than by improvements to 185
(DOT Information Package for U 3321 July 14 2004)
• Given this information it is not clear that alternative 4+ would not meet the east west
transportation needs of the area In our opinion additional information is needed to
demonstrate the effectiveness of the 4+ alternative
Conclusion
The DWQ is not necessarily opposed to the construction of a new location alternative In fact it
is likely that a new location alternative will ultimately be chosen and built However issuance of
the 401 Water Quality Certification and the Catawba Buffer Authorization requires the
avoidance and minimization of impacts that can only be accomplished through a full and
equitable assessment of all

�G
Michael F Easley Governor
William G Ross Jr Secretary
North Carolina Department of Environment and Natural Resources
Alan W Klimek P E Director
Division of Water Quality
Primary Issues — The DWQ
elimination of alternatives
Briefing Paper for Review Board 4
October 27, 2004 �� ,
has two fundamental concerns associated kith the premature
Circumvents the Avoidance and Minimization Process
Delays in 404/401 permitting due to incomplete alternative analysis
Purpose and Need
Approved 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 in general
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County The project purpose is based on the following
• Improve mobility access and connectivity in southern Gaston County and between southern
Gaston County and Mecklenburg County
• Reduce congestion and improve traffic flow on the sections of 185 US 29174 and US 321 in
the project study area improve high speed safe regional travel service along the US 29 74
intrastate corridor and generally improve safety and reduce above average accident rates in
the project study area
Prior to agreeing to the Purpose and Need statement, the DWQ asked if the statement as
written would preclude a fair assessment of non new location alternatives DWQ was
assured both orally and in writing that a broad interpretation of the Purpose and Need
would be employed during the planning of the protect, and that a full and fair assessment
of all alternatives would be considered
The following statement is taken from the official May 15 2002 meeting minutes
The Statement of Purpose and Need repeatedly uses the term southern Gaston County is that
the area we re talking about south of 185 9
Southern Gaston County is expected to receive the most growth based on the Comprehensive
Land Use Plan but we are referring to east west transportation needs and notjust southern
Gaston County It was not the intent to pre suppose any alternatives at a specific location such
as ruling out alternatives for improved connectivity north of 185 The document will be reviewed
in this light and revised accordingly
No e hCarolhna
Transportation Permitting Unit Naturally
1650 Mail Service Center Raleigh North Carolina 27699 1650
2321 Crabtree Boulevard Suite 250 Raleigh North Carolina 27604
Phone [phone] / FAX [phone] / Internet http / /h2o enr state nc us /ncwetlands
An Equal Opportunity/Affirmative Action Employer —50/ Recycled /10/ Post Consumer Paper

Impacts and Alts Developed
At this time we do not believe that the non new location alternatives have received a full and
fair assessment when compared to the new location alternatives
In the position paper submitted by the DOT it was stated that traffic modeling on 4+
alternative was not developed It was assumed that the alternative would not work See
statement below
Because of operational deficiencies identified in Scenario 4 numerous TSM type
improvements along US 29 74 were incorporated into Scenario 4 resulting an Scenario
4+
The corridor level model was not rerun for these improvements It is likely that making
these improvements would simply shaft the congestion farther downstream The regional
demand model runs already completed show that improvements made to US 29 74 and
existing 185 continue to attract more traffic due to the latent travel demand to the area,
resulting an a build at and they will continue tocome sittaatzon The cycle of making
recommended improvements running the mode tdent0tttg new areas of congestion
making those improvements then running theaodel agaaaz was not necessary to
adequately evaluate the ability of the ImproveExtsttng Roadways Alternatives to meet the ad protect purpose and need It would simply more improvements to the lost for
Scenario 4+
In the position paper submitted by th)?OT it was stated
for potential impacts on non new locon alternatives the same level of analysis
location alternatives as foi the 94 nfocatlo rnatr was not Performed n Segments that were assessed for the non new
See statement below
y the team
Only a cursory level impact analyzS done
These impacts are not at the same o for the improve These
� ,fdetaal
alternative imnacty Thorofnro ,t �„--, as the corr,a v ng alternan„on

Level of Service (LOS)
• According to the documentation presented the LOS would be improved if a new location
alternative is built and would not be improved if a non new location alternative is built
However for both new location and non new location alternatives certain sections of I
85 and US 29/74 would have failing LOS in the design year 2025
• Improvements would need to be made to 185 and US 29/74 regardless of the alternative
chosen
• Most of the deficiencies in LOS on 185 are a result of poor service on surface streets
adjacent to I 85 interchanges Thus it appears that much of the congestion on 185 could
be reduced by improvements to secondary roads rather than by improvements to 185
(DOT Information Package for U 3321 July 14 2004)
• Given this information it is not clear that alternative 4+ would not meet the east west
transportation needs of the area In our opinion additional information is needed to
demonstrate the effectiveness of the 4+ alternative
Conclusion
The DWQ is not necessarily opposed to the construction of a new location alternative In fact it
is likely that a new location alternative will ultimately be chosen and built However issuance of
the 401 Water Quality Certification and the Catawba Buffer Authorization requires the
avoidance and minimization of impacts that can only be accomplished through a full and
equitable assessment of all

O�0F W A TF9QG
Michael F Easley Governor
WilliamG Ross Jr Secretary
North Carolina Department of Environment and Natural Resources
Briefing Paper for Review Board
October 27, 2004
Alan W Klimek P E Director
Division of Water Quality
Primary Issues — The DWQ has two fundamental concerns associated with the premature
elimination of alternatives
Circumvents the Avoidance and Minimization Process
Delays in 404/401 permitting due to incomplete alternative analysis
Purpose and Need
Approved 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 in general
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County The project purpose is based on the following
• Improve mobility access and connectivity in southern Gaston County and between southern
Gaston County and Mecklenburg County
• Reduce congestion and improve traffic flow on the sections of 185 US 29174 and US 321 in
the project study area improve high speed safe regional travel service along the US 29 74
intrastate corridor and generally improve safety and reduce above average accident rates in
the project study area
Prior to agreeing to the Purpose and Need statement, the DWQ asked if the statement as
written would preclude a fair assessment of non new location alternatives DWQ was
assured both orally and in writing that a broad interpretation of the Purpose and Need
would be employed during the planning of the protect, and that a full and fair assessment
of all alternatives would be considered
The following statement is taken from the official May 15 2002 meeting minutes
The Statement of Purpose and Need repeatedly uses the term southern Gaston County is that
the area we re talking about south of 185
Southern Gaston County is expected to receive the most growth based on the Comprehensive
Land Use Plan but we are referring to east west transportation needs and not just southern
Gaston County It was not the intent to pre suppose any alternatives at a specific location such
as ruling out alternatives for improved connectivity north of 185 The document will be reviewed
in this light and revised accordingly
No e hCarohna
Transportation Permitting Unit Na%urallly
1650 Mail Service Center Raleigh North Carolina 27699 1650
2321 Crabtree Boulevard Suite 250 Raleigh North Carolina 27604
Phone [phone] / FAX [phone] / Internet http //h2o enr state nc us /ncvvetlands
An Equal Opportunity /Aff irmative Action Employer — 50 / Recycled /10 / Post Consumer Paper

Impacts and Alts Developed
At this time we do not believe that the non new location alternatives have received a full and
fair assessment when compared to the new location alternatives
• In the position paper submitted by the DOT it was stated that traffic modeling on 4+
alternative was not developed It was assumed that the alternative would not work See
statement below
Because of operational deficiencies identified to Scenario 4 numerous TSM type
improvements along US 29 74 were incorporated into Scenario 4 resulting an Scenario
4+
The corridor level model was not rerun for these improvements It is likely that making
these improvements would simply shaft the congestion farther downstream The regional
demand model runs already completed show that improvements made to US 29 74 and
existing 185 continue to attract more traffic due to the latent travel demand an the area
resulting an a build at and they will continue to come situation The cycle of making
recommended improvements running the model identifying new areas of congestion
making those improvements then running the model again was not necessary to
adequately evaluate the ability of the Improve Existing Roadways Alternatives to meet the
project purpose and need It would simply add more improvements to the last for
Scenario 4+
• In the position paper subnutted by the DOT it was stated that the same level of analysis
for potential impacts on non new location alternatives was not performed for the non new
location alternatives as for the 94 new location segments that were assessed by the team
See statement below
Only a cursory level impact analysis was done for the improve existing alternatives
These impacts are not at the same level of detail as the corridor level new location
alternative impacts Therefore at as not constructive to draw a comparison
Threatened and Endangered Species
• EMC Rules require protection of existing uses with the issuance of the 401 WQC
• Wildlife is explicitly listed as an existing use to be protected
• We typically rely on the expertise of WRC and USFWS to fulfill this requirement
• At present the WRC has concerns about the full and fair assessment of alternatives
• Failure to due an assessment of a full range of alternatives can result in failure to do
avoidance and minimization Thus causing permit delays at best and denial at worst
• Potential for impacts to federally listed endangered species with new location alternatives

Level of Service (LOS)
• According to the documentation presented the LOS would be improved if a new location
alternative is built and would not be improved if a non new location alternative is built
However for both new location and non new location alternatives certain sections of I
85 and US 29/74 would have failing LOS in the design year 2025
• Improvements would need to be made to 185 and US 29/74 regardless of the alternative
chosen
• Most of the deficiencies in LOS on 185 are a result of poor service on surface streets
adjacent to 185 interchanges Thus it appears that much of the congestion on 185 could
be reduced by improvements to secondary roads rather than by improvements to 185
(DOT Information Package for U 3321 July 14 2004)
• Given this information it is not clear that alternative 4+ would not meet the east west
transportation needs of the area In our opinion additional information is needed to
demonstrate the effectiveness of the 4+ alternative
Conclusion
The DWQ is not necessarily opposed to the construction of a new location alternative In fact it
is likely that a new location alternative will ultimately be chosen and built However issuance of
the 401 Water Quality Certification and the Catawba Buffer Authorization requires the
avoidance and minimization of impacts that can only be accomplished through a full and
equitable assessment of all

September 27 2004
Ms Knstma Solberg P E
NCDOT Project Manager PDEA
North Carolina Department of Transportation
1584 Mail Service Center
Raleigh North Carolina 27699 1584
RE Written Brief to Merger 01 Process Review Board NCDOT Elevation Process for
TIP Number U 3321, Gaston East West Corridor Study (Proposed "Gaston
Freeway" or "Garden Parkway "), Gaston and Mecklenburg Counties, Federal
Protect Number STP 1213(6), State Protect Number 8 2812501
Dear Ms Solberg
This letter and attachment represents the U S Environmental Protection Agency s (EPA)
formal response and written brief to the North Carolina Department of Transportation s
( NCDOT) notice of potential elevation for the above referenced Merger 01 project By copy of
this letter EPA is providing the same information to the Merger 01 Process Review Board
members consistent with the Implementation Guidance for Conflict or Dispute Resolution
executed on October 20 2003
It is my understanding that this is the first formal elevation of a NCDOT Merger 01
project While EPA has not yet been offered the opportunity to be a formal signatory agency to
the Merger 01 Implementation Guidance EPA believes that the Conflict or Dispute Resolution
agreement is a reasonable method of trying to resolve issues when the Merger team agency
representatives can not agree or reach consensus However EPA and NCDOT are bound to the
Inter Agency Agreement (IAG #RW NC- 94591501 0) provisions regarding disputes contained at
Item VI 4 a Mutually Understood Conditions It is recognized in the IAG that the NEPA/404
merger process was being updated and may include specific dispute resolution guidelines that
could include EPA EPA management officials were not invited to review the Merger 01
Conflict or Dispute Resolution Implementation Guidance prior to its execution by NCDOT the
North Carolina Department of Natural Resources (DENR) the U S Army Corps of Engineers
(ACE) and the Federal Highway Administration (FHWA)
As stated in the IAG resolution of the issue will require mutual cooperation by both
parties After the Interim Concurrence Point 2 meeting on September 9 2004 and the notice of
potential elevation by the NCDOT Mr Militscher of my staff went to your office on September
10`h to request that another Merger meeting be scheduled the week September 13`h to try to reach
a compromise amongst the Merger team agencies Mr Mihtscher also requested the same of Mr
Derrick Weaver PDEA Unit Head With the exception of the Division of Water Quality (DWQ)
representative who was not able to attend the September 14'h meeting due to late notice that pre
elevation Merger meeting ended without the interim concurrence which NCDOT (and FHWA) is

seeking
The attachment to this letter outlines EPA s specific concerns and rationale for its
position The scope and magnitude of the proposed project will result in irreversible changes to
the nature and character to half of Gaston County and the regional planning area The proposed
Draft Environmental Impact Statement (DEIS) should rigorously explore and objectively
evaluate all reasonable alternatives [CEQ 43 FR 55994 Section 1502 14(a)] EPA is
convinced that a combination of potential improvements to the existing failing facilities (I -85 and
US 29/74) along with other possible system improvements is a feasible alternative worthy of
further consideration
EPA has in the past supported the elimmation of alternatives for numerous Merger
projects where the detailed transportation and environmental analysis conducted by NCDOT
clearly shows that these alternatives do not justify further consideration under NEPA and clearly
do not meet the purpose and need However NCDOT has not conducted even a cursory
environmental analysis for the other No build Alternatives There are over 70 potential
Transportation System Management (TSM) measures which have not been discussed by the
Merger team representatives in any detail Furthermore EPA disagrees with some of the key
assumptions in the preliminary transportation analysis and some of the necessary analyses have
not been conducted (e g Mass Transit Alternative Future Transit Ridership Assumptions in
MPO s Travel Models Gaston N/A - Not specifically included in models)
In summary and conclusion EPA would encourage NCDOT and FHWA to consider a
compronuse position to dropping all of the alternatives except for the No -build and Build a
New Location Freeway at this stage of the NEPA process EPA believes that some of the No
build Alternatives (e g Scenario 4+ and Mass Transit with TSM for I -85 and US 29/74) do
meet the stated purpose and need in total or in part Thus all reasonable and feasible alternatives
should be carried forward for detailed study to the DEIS stage in order to allow the public and
decision makers the opportunity to comparatively evaluate a full range of alternatives
Furthermore performing detailed environmental studies for a full range of alternatives by
NCDOT is consistent with past efforts for proposed new location highway projects under the
Merger process EPA would be willing to sign a Partial Concurrence Point 2 form which
includes at least some No build Alternatives
We appreciate your consideration in this matter Thank you
Sincerely
Heinz J Mueller Chief
NEPA Program Office
Office of Policy and Management
Attachment

Review Board Members
S Kenneth Jolly Chief Regulatory Division
U S Army Corps of Engineers Wilmington District
Dempsey E Benton Chief Deputy Secretary
North Carolina Department of Natural Resources
Roger E Sheats Jr Deputy Secretary
North Carolina Department of Transportation
Don Voekler Assistant Division Administrator
Federal Highway Administration
cc A Stanley Meiburg EPA Deputy Regional Administrator
Russell L Wright EPA Assistant Regional Administrator
Gregory J Thorpe Ph D NCDOT PDEA Director

ATTACHMENT
Clarification on Concurrence
NCDOT has provided a misstatement of fact in its September 9 2004 e mail regarding
the Notice of Potential Elevation following the August 17 2004 Partial Concurrence Point 2
meeting EPA has not agreed that Mass Transit or combinations of other No build Alternatives
do not meet the purpose and need (P /N) for the project and should not be carried forward as
Detailed Study Alternatives (DSA) At no time during the August 17th meeting or subsequent to
that meeting has EPA s Merger team representative stated verbally (or provided in writing) that
Mass Transit or a potential combination of the No build Alternatives do not meet the purpose
and need statement Mr Militscher left the meeting in order not to be late for the scheduled 100
pm Merger meeting (R -2597) NCDOT did not allow sufficient time for the August 17th meeting
for agency comments on the No build Alternatives and a large part of the 3 -hour meeting was
consumed by the several PBS &J consultants
Subsequent to the August 17th meeting NCDOT did provide a copy of the Gaston County
Air Conformity Analysis as requested However NCDOT has not addressed the specific issue
raised by Mr Militscher during the August 17th meeting regarding induced travel from a New
Location facility This information and the underlying assumptions involving promoting
increased traffic within the project study area are critical in understanding and analyzing future
air pollutant emissions The responses EPA received regarding potential air quality issues for
the New Location Alternative within the Charlotte- Gastonia Rock Hill Subpart 2 Moderate 8-
hour Ozone Non attainment Area were curt and non - responsive
Project History
EPA is concerned that some of the verbal commitments to the resource agencies
including EPA by the former NCDOT Project Manager (Ms Jennifer Hams P E ) for this
project are not being taken seriously by the current NCDOT Project Manager Ms Hams
assured Mr Militscher and other agency representatives during the P/N meetings that all No
build Alternatives including Mass Transit would be given full consideration during the
development of alternatives EPA understood this prior commitment to mean an equitable
environmental analysis of these alternatives as well This comnutment has not been met in
EPA s view of NCDOT s refusal to provide detailed study for one or two of the No build
Alternatives (Scenarios described as 2 3 4 and 4+ in the August 17th handout and the
TSM/TDM Alternative and the Mass Transit Alternative)
The No Build Alternatives
NCDOT has not provided an equitable environmental analysis of the No build
Alternatives For example for the Mass Transit Alternative the Pros and Cons are cursory
not supported by coordinated planning studies and generally inaccurate In addition to providing

increased mobility and connectivity Mass Transit would also provide potentially less capacity
demand at peak hours on current failing roadways Mass Transit is generally more
environmentally friendly and would potentially result in less impacts to the human and natural
environment (e g Less business and residential relocations less wetland and stream impacts
etc ) Mass Transit is potentially safer than a New Location Freeway Mass Transit if designed
properly is a more efficient means of transportation Connection of a Light Rail system to the
Charlotte International Airport at the eastern termini with bus connections to other points around
Charlotte would be an ideal commuter station None of these Pros made it into the meeting
materials Ridership studies were not performed by Gaston County in their model and NCDOT
has very possibly underestimated future ridership interest between the commuting areas of
Gastonia and Charlotte To the contrary of NCDOT s post meeting e mail comments EPA
believes that a Mass Transit Alternative combined with specific Traffic System Management
(TSM) measures and some Improve Existing options fully meets the P/N and is a reasonable
and feasible alternative which should be given full and equitable consideration in the DEIS
Similarly the analysis provided for the Scenario 4+ Alternative (r e Improve Existing
Roadways Alternative with TSM measures) also understates the benefits derived from this
alternative compared to a New Location Facility In addition to maintaining level of service
(LOS) and reducing accident rates after the construction period this alternative would also
potentially improve connectivity between Gaston and Mecklenburg Counties by widening
existing bridges over the South Fork of the Catawba River and the main stem of the Catawba
River With TSM measures there would also be improved mobility within the project study
area This alternative may also be more environmentally friendly and result in less induced
travel and air pollution less wetland and stream impacts etc This alternative may be more cost
effective than a New Location Freeway NCDOT points to the Con of not providing
connectivity to southern Gaston County The P/N does not state that this is where the
connectivity must occur and that the existing facilities are located in the agreed to project study
area However without a full NEPA analysis NCDOT proposes to eliminate this alternative
from further detailed study by rhetorically stating it does not meet the P/N EPA believes that an
Improve Existing Alternative combined with specific TSM measures fully meets the P/N and is a
reasonable and feasible alternative which should be given full and equitable consideration in the
DEIS
Another issue of concern for EPA is the idea that even with the construction of a $600
million New Location Freeway the LOS for critical segments along 185 and US 29/74 in the
2030 design year will continue to be LOS F (F+ as qualified by FHWA) Thus the New
Location Freeway does not completely improve conditions along the failing roadways in the
design year and NCDOT acknowledges that additional TSM and other improvements will be
necessary even after the New Location Freeway is constructed Because of the full scope and
intent of the P/N can not be met even with the New Location Alternative in the design year of
2030 NCDOT needs to fully consider and evaluate additional reasonable and feasible
alternatives
The Merger Process

EPA is very disappointed that consensus could not be reached at the Partial Concurrence
Point 2 meeting EPA is equally disappointed that NCDOT and its consultant have not
efficiently used resource agency time during the Merger Process Most significantly EPA was
very troubled by the method in which NCDOT developed the New Location Freeway corridors at
the February 17 2004 Partial Concurrence Point 2 meeting for the New Location corridors
EPA and other resource agencies were asked to review and eliminate corridor segments from
over 90 individual roadway segments EPA s representative to the Merger team is not a highway
design engineer It was not an efficient use of his time to painstakingly go over more than 90
permutations of roadway segments to develop the New Location Corridors The NCDOT
consultant also had last minute revisions which were not provided ahead of time to the resource
agency representatives who tele conferenced into the meeting (e g FWS WRC) This further
confused and delayed this process An indeterminate number of segments were eliminated
based upon highway esign criteria and not environmental constraints This multi agency /multi
discipline method of developing NCDOT highway corridors is not consistent with current
Merger 01 Implementation Guidance or TEA 21 streamlining initiatives On other large scale
proposed new location Merger projects NCDOT develops a dozen or so viable transportation
corridors based upon highway design criteria identifies the environmental constraints and the
Merger agencies work together to modify delete add or adjust these NCDOT proposed corridors
based upon the environmental constraints EPA s representative cooperated fully with NCDOT
during this highway corridor development meeting but found it to be a very inefficient method
EPA understands that other resource agency representatives shared similar concerns
The current Merger 01 Implementation Guidance does not specifically address Partial
Concurrence Points EPA acknowledges the potential scope and magnitude of the proposed
project and the complexity of issues However EPA does not prefer this piecemeal concurrence
approach EPA would prefer that several days (if needed) be scheduled in advance (e g In May
of 2005 when NCDOT has identified another Partial Concurrence Point 2 meeting to further
eliminate New Location Corridors) to identify all reasonable and feasible alternatives needed to
be evaluated in detail in the DEIS The U -3321 project is listed as an NCDOT priority project
for Division 12 and is assigned to a TIP Program Manager EPA has not seen any difference in
PDEA/NCDOT resource commitment or priority of scheduling from that of any other Merger
project
There are 3 pages of identified TSM locations provided in the August 17th Merger team
meeting handout (Pages 7 10 from July 14`h Partial concurrence Point 2 meeting package) The
Merger team has not discussed any specifics of these potential improvement CORSIM analysis
targets Unlike the efforts to identify New Location Corridors NCDOT has not allowed
sufficient time nor emphasized the approximate 70 TSM improvement options included in the
handouts
NEPA/CEQ Regulations
Under Section 1502 14 of the CEQ regulations Alternatives including the Proposed
Action the first sentence stresses This section is the heart of the environmental impact
statement EPA believes that a true comparative form for the alternatives can not be obtained as

addressed in this section of the CEQ regulations by eliminating all but a No Action and Build
a new Freeway alternatives without providing a detailed environmental analysis for all
reasonable and feasible alternatives Furthermore NCDOT and FHWA have verbally identified
that even with a new Freeway alternative an undisclosed number of TSM measures and other
improvements will eventually be required for the existing roadways (I 85 and US 29/74)
although this issue has not been confirmed in writing
Under EPA s NEPA regulations under 40 CFR Part 6 Section 6 506(5) it further
addresses the issue of alternatives covered in the NEPA document including the reasons for
rejecting an alternative and disclose any significant environmental benefits precluded by such
refection The decision makers and the public will be unaware of any potential environmental
benefits from other No build alternatives if they are eliminated at this stage of NEPA planning
Public Disclosure
EPA is concerned that a full public disclosure of the reasonable and feasible alternatives
will not be included in the DEIS The proposed new Freeway represents a potential $600 mullion
investment in public dollars which will irreversibly and permanently alter the character and
quality of life in half a county and the Gastonia region For NCDOT and FHWA to dismiss Mass
Transit and other reasonable and feasible alternatives without providing a detailed environmental
analysis and without first obtaining public feedback from the DEIS is premature and contrary to
the spirit and intent of NEPA
Air Quality
Gaston County is located in the Gastonia Charlotte Rockhill Subpart Moderate 8 hour
Ozone non attainment area under the Clean Air Act EPA requested during the August 17th
meeting some indication from FHWA and NCDOT on the potential for induced travel with the
New Location Freeway alternative It is understood by EPA that there will be offsetting
gains /losses in air pollutant emissions To date EPA has not seen a specific traffic analysis
showing induced travel from the New Location Freeway Alternative
Threatened & Endangered Species
EPA has learned from FWS and WRC that there may be a potential for threatened and
endangered mussels to exist within the project study area including the streams and tributaries to
the South Fork of the Catawaba River and the main stem to the Catawba River FWS has
indicated during past meetings that biological surveys need to be conducted and a true
avoidance alternative should be developed consistent with Section 7 of the Endangered Species
Act The No -build or No Action alternative is not viewed by EPA as an avoidance
alternative (Contrary to statements from NCDOT and FHWA) The No Action does not satisfy
the P/N The No Action is not viewed by EPA as an avoidance alternative as it does not
commit any action to solve the identified transportation needs EPA and other agencies have
signed Concurrence Point 1 acknowledging that there is a demonstrated transportation problem
along the I -85 and US 29/74 corridors and the No Action does not address this need If the

threatened or endangered species are found within the New Location Freeway corridors (which
all cross the Catawba River South Fork & main stem) there will be no reasonable and feasible
avoidance alternative to evaluate
Other Issues (Funding, Toll Authority, and Economic Development)
Apparently this project has only funding for planning and environmental studies
Therefore it is unclear why this TIP project has taken on such a priority for Merger Process
Concurrence Point decision making when it is not programmed for funding through the 2004
2008 TIP
There have been newspaper accounts that the proposed Garden Parkway or Gaston
Freeway is to be the top priority for the NCDOT to create a toll road This issue was not
addressed during the August 17th Partial Concurrence Point 2 meeting or other Merger meetings
EPA was not aware that the NC Legislature created a toll authority ( Turnpike Authority ) in
October of 2002 which would seek funding from the NC Legislature and administer the proposed
New Location Freeway NCDOT needs to discuss and explore this issue with the resource
agencies and other interested parties Any foreseeable actions regarding a possible toll facility
should be fully disclosed in the NEPA process and should be considered in the traffic and
environmental analyses for the alternatives
During the August 17"' and September 14`h meetings it became apparent to EPA and
other agencies that the Gaston MPO representative stressed that a fairly good part of the need
for the proposed New Location Freeway is for economic development in southern Gaston
County Economic development was not substantiated during the P/N concurrence process and
has not been documented by neither NCDOT /FHWA nor local planning officials This
underlying desire to accommodate additional development and sprawl by providing the access
and right of -way would require that a full Indirect and Cumulative Impact analysis be performed
by NCDOT

Briefing Paper for Dempsey
October 25, 2004
Primary Issues — The DWQ has two fundamental concerns associated with the
premature elimination of alternatives
Circumvents the Avoidance and Minimization Process
Delays in 404/401 permitting due to incomplete alternative analysis
4, a, C2J
The Statement of Purpose and Need repeatedly uses the term southern Gaston County
as that the area we re talking about south of 185
Southern Gaston County as expected to receive the most growth based on the
Comprehensive Land Use Plan but we are referring to east west transportation needs
and not just southern Gaston County It was not the intent to pre suppose any
alternatives at a specific location such as ruling out alternatives for improved
connectivity north of 185 The document will be reviewed an this light and revised
accordingly
Purpose and Need
3
Approved Purpose and Need
rThe
purpose of the proposed action as to improve east west transportation mobility an the
area around the City of Gastonia between Gastonia and the Charlotte metropolitan area
an general and particularly to establish direct access between the rapidly growing area
%
of southeast Gaston County and west Mecklenburg County The project purpose as based
on the following
j
■ Improve mobility access and connectivity an southern Gaston County and between
southern Gaston County and Mecklenburg County
F
■ Reduce congestion and improve traffic flow on the sections of 185 US 29174 and US
321 an the project study area improve high speed safe regional travel service along
the US 29 74 intrastate corridor and generally improve safety and reduce above
saverage
accident rates an the project study area
Prior to agreeing to the Purpose and Need statement, the DWQ asked if the
statement as written would preclude a fair assessment of non new location
alternatives DOT committed to a full and fair assessment of all alternatives
The following statement is taken from the official May 15 2002 meeting minutes
The Statement of Purpose and Need repeatedly uses the term southern Gaston County
as that the area we re talking about south of 185
Southern Gaston County as expected to receive the most growth based on the
Comprehensive Land Use Plan but we are referring to east west transportation needs
and not just southern Gaston County It was not the intent to pre suppose any
alternatives at a specific location such as ruling out alternatives for improved
connectivity north of 185 The document will be reviewed an this light and revised
accordingly

Only a cursory level impact analysis was done for the improve existing alternatives
These impacts are not at the same level of detail as the corridor level new location
alternative impacts Therefore it is not constructive to draw a comparison
Threatened and Endangered Species
EMC Rules require protection of existing uses
Wildlife is explicitly listed as an existing use
Failure to due an assessment of a full range of alternatives can result in failure to
do avoidance and minimization Thus causing permit delays at best and denial
at worst
Potential for impacts to federally listed endangered species with new location
alternatives
CEQ Guidance on P &N and Alternatives
ti
As importantly the project purpose and need drives the process for alternatives
consideration in depth analysis and ultimate selection The Council on Environmental
Quality (CEQ) regulations require that the EIS address the no action alternative and
rigorously explore and objectively evaluate all reasonable alternatives
---57c� g�s ­-7
Impacts and Alts Developed
,�'t
At this time we do not believe that the non -new location alternatives have received a full
and fair assessment when compared to the new location alternatives
�L
ti
• DOT admittedly did not run traffic modeling on 4+ alternative Assumed it
Z 4
would not work
Because of operational deficiencies identified in Scenario 4 numerous TSM type improvements
C i
along US 29 74 were incorporated into Scenario 4 resulting in Scenario 4+
�.
The corridor level model was not rerun for these improvements It is likely that making these
improvements would simply shaft the congestion farther downstream The regional demand
model runs already completed show that improvements made to US 29 74 and existing 185
continue to attract more traffic due to the latent travel demand in the area resulting in a build it
and they will continue to come situation The cycle of making recommended improvements
running the model identifying new areas of congestion making those improvements then
running the model again was not necessary to adequately evaluate the ability of the Improve
Existing Roadways Alternatives to meet the project purpose and need It would simply add more
improvements to the last for Scenario 4+
• DOT admittedly did not provide the same level of analysis for potential impacts
on non new location alternatives as they did for the 94 new location segments that
were assessed by the team
Only a cursory level impact analysis was done for the improve existing alternatives
These impacts are not at the same level of detail as the corridor level new location
alternative impacts Therefore it is not constructive to draw a comparison
Threatened and Endangered Species
EMC Rules require protection of existing uses
Wildlife is explicitly listed as an existing use
Failure to due an assessment of a full range of alternatives can result in failure to
do avoidance and minimization Thus causing permit delays at best and denial
at worst
Potential for impacts to federally listed endangered species with new location
alternatives

Level of Service (LOS)
• DOT contends that the LOS would be improved if a new location alternative is
built and would not be improved if a non new location alternative is built
However for both new location and non new location alternatives certain
sections of 185 and US 29/74 would have failing LOS in the design year 2025
• Improvements would need to be made to I -85 and US 29/74 regardless of the
alternative chosen
• Most of the deficiencies in LOS on I -85 are a result of poor service on surface
streets adjacent to 185 interchanges Thus it appears that much of the congestion
on 185 could be reduced by improvements to secondary roads rather than by
improvements to 185 (DOT Information Package for U -3321 July 14 2004)
Toll Road Issue
NCDWQ and other resource agencies understand that the East West Connector is
slated to be a toll road However DOT has not confirmed this fact
Typically toll road usage is less than public- funded free road usage Therefore
the traffic reduction to 185 US 29/74 due to a new location facility would be less
than anticipated DOT s current traffic models do not reflect the road usage as a
toll road This could affect the LOS ratings of 185 US 29/74 for the design year
Information Packages
• DOT Information Packages (July 14 2004) distributed to the Merger Team prior
to the August 17 2004 Partial Concurrence Point #2 meeting indicated that
pertinent information for developing alternatives (road lengths relocatees parks
and recreation areas historic sites stream and wetland impacts etc ) would be
provided This information was not provided at the Partial Concurrence meeting
or at any subsequent meetings
• In the September 29 2004 Elevation Process Meeting NC DWQ and the other
resource agencies requested a variety of information including the information
promised in the Information Package DOT s responses to the information
requests still did not include the data promised in the Information Package DOT
staff have stated that they do not think this information is necessary for
eliminating the non new location alternatives

I,
Additional Items to Consider from FHWA website & guidance
If an alternative does not satisfy the purpose and need for the project as a rule it
should not be included in the analysis as an apparent reasonable alternative There
are times when an alternative that is not reasonable is included based on the
request of another agency or due to public expectation In such cases it should be
clearly explained why the alternative is not reasonable (or prudent or practicable)
why it is being analyzed in detail and that because it is not reasonable that it will
not be selected
As importantly the project purpose and need drives the process for alternatives
consideration in depth analysis and ultimate selection The Council on
Environmental Quality (CEQ) regulations require that the EIS address the no-
action' alternative and ' rigorously explore and objectively evaluate all reasonable
alternatives
Other times the cost or level of environmental impact are not acceptable and an
alternative that only partially meets the purpose and need or the no build
alternative must be considered If the costs are .justified in relation to the
transportation benefits then a less than full build alternative may be acceptable
NRDC v Morton (458 F2d 827 (D C Cir 1972)) thusly It is also inappropriate to
disregard alternatives merely because they do not offer a complete solution to [the]
problem From this could one assume that an alternative that meets 5 of 6 project
needs merits analysis and discussion in the DEIS and that it would be premature to
preclude such a discussion from the DEIS?
GUIDANCE FOR PREPARING AND PROCESSING
ENVIRONMENTAL AND SECTION 4(F) DOCUMENTS
FHWA TECHNICAL ADVISORY
T 6640 8A
October 30 1987
All reasonable alternatives under consideration (including the no build) need to be
developed to a comparable level of detail in the draft EIS so that their
comparative merits may be evaluated (40 CFR 1502 14(b) and (d))

GASTON EAST WEST CONNECTOR
DRAFT Briefing Paper
October 19, 2004
Introduction
Through several meetings held since August 2004 the NEPA/404 Merger Team has been unable
to reach consensus on a portion of Concurrence Point 2 for TIP Project U 3321 the Gaston East
West Connector
This briefing paper is organized as follows
• Issue Being Elevated in the NEPA/404 Merger Process
• Project History in the Thoroughfare Planning Process
• Project History in the NEPA Process
• Purpose and Need Statement
• Summary of the Inability of Improve Existing Roadway Alternatives to Meet Purpose
and Need
• Summary of Traffic Analyses Results
• Other Considerations
Issue Being Elevated in the NEPA/404 Merger Process
The NCDOT considered the following basic types of alternatives in accordance with FHWA
Guidelines (Technical Advisory T6640 8A)
1 No Action
2 Transportation System Management (TSM) and Transportation Demand Management
(TDM) Measures
3 Mass Transit
4 Improve Existing Roadways (Improve 185 Improve US 29 74 or Improve Both 185 and
US 29 74)
5 New Location
The Merger Team could not agree on which non new location alternatives should be carried
forward as Detailed Study Alternatives
The NCDOT believes the studies and analyses that have been completed to date sufficiently
demonstrate that TSM/TDM measures mass transit and improvements to existing roadways do
not meet the critical elements of the purpose and need for the proposed project and should be
eliminated from further study
The NCDOT Federal Highway Adrmmstration (FHWA) Gaston Urban Metropolitan Planning
Organization (GUMPO) Mecklenburg Union Metropolitan Planning Organization (MUMPO)
and State Historic Preservation Office (SHPO) agree that no non new location alternative should
be carried forward as a Detailed Study Alternative

The US Fish and Wildlife Service (USFWS) NC Division of Water Quality (NCDWQ)
NC Wildlife Resources Commission (NCWRC) US Environmental Protection Agency (USEPA)
and US Army Corps of Engineers (USACE) support retaining some or all of the non new location
alternatives as Detailed Study Alternatives
In accordance with CEQ and FHWA regulations the No Action (or No Build) Alternative is
always carried forward as an alternative in the Draft Environmental Impact Statement
Summary of the Inability of Improve Existing Roadway Alternatives to Meet Purpose and
Need
The FHWA provides guidance relating to the role of the Purpose and Need Statement in the
alternatives development process (FHWA Memorandum titled The Importance of Purpose and
Need in Environmental Documents September 18 1990) Based on this guidance the following
points were considered in evaluating the ability of the Improve Existing Roadways Alternatives
to meet the project s purpose and need
1 The project purpose and need drives the process for alternatives consideration in depth
analysis and ultimate selection
2 If an alternative does not satisfy the purpose and need for the project as a rule it should
not be included in the analysis as an apparent reasonable alternative
The purpose and need should be as comprehensive and specific as possible This will
assist in pinpointing and refining the alternatives which should be analyzed Further it
will in a sense protect those viable alternatives from sniping by external interests and
capricious suggestions to study something else If the purpose of and need for the
proposed project are rigorously defined the number of solutions which will satisfy the
conditions can be more readily identified and narrowly lirruted
4 The purpose and need define what can be considered reasonable prudent and practicable
alternatives
5 At times it is possible that no alternative meets all aspects of the projects purpose and
need In such a case it must be determined if the alternatives are acceptable and
worthwhile pursuing in light of the cost environmental impact and less than optimal
transportation solution To properly assess this it is important to determine the elements
1 of the purpose and need which are critical to the project as opposed to those which may
be desirable or simply support it the critical elements are those which if not met at least
to some mammal level would lead to a no build decision
The project s purpose and need has two critical basic elements 1) improve east west mobility and
connectivity within southern Gaston County and between southern Gaston County and west
a Mecklenburg County and 2) improve traffic flow on 185 and US 29 74 (the only existing east
west corridors in the study area)
Improving existing 185 and US 29 74 (under Scenario 4 or Scenario 4 +) would not meet the
need for connectivity and would only minimally improve traffic flow on existing 185 and US 29
74 The travel demand modeling and corridor level operations analyses (described in a
subsequent section) show that the diversion of traffic achieved by a new location roadway is more
2

effective at improving traffic flow on 185 and US 29 74 than providing direct improvements to
these roadways
South of US 29 74 there are no continuous east west roadways in the southern half of Gaston
County Improving US 29 74 and 185 would not improve connectivity in this area Drivers
would still have to travel north on two lane roadways many through downtown areas to go east
and west
The need for a new connection between Gaston and Mecklenburg Counties is clearly
demonstrated in the purpose and need statement Geographically southern Gaston County and
western Mecklenburg County are completely isolated from each other by the Catawba River
There are no crossings of the Catawba River south of US 29 74 until the NC 49 Buster Boyd
Bridge to York South Carolina about 11 miles downstream from US 29 74
The comprehensive land use plans of both Gaston County and Mecklenburg County show
southeast Gaston County and western Mecklenburg County as high growth areas Both
comprehensive plans show a new roadway connection across the Catawba River between these
two high growth areas Western Mecklenburg County and the Charlotte Douglas Airport are
expected to be or already are mayor employment centers The Charlotte Douglas International
Airport is proposing a new mtermodal facility in the southwest portion of their property
The Gaston Urban Area Thoroughfare Plan identifies a new location roadway in southern Gaston
County with a new crossing of the Catawba River as their top priority in the MPO s unmet needs
list The Mecklenburg Union Thoroughfare Plan also identifies a transportation need for an
additional crossing of the Catawba River The current travel demand model shows a new location
freeway would attract about 55 000 vehicles per day in 2025
A recent draft memorandum from the General Councils of FHWA and FIFA dated September 20
2004 discusses the integration of the transportation planning process which includes
Thoroughfare Plan development and the NEPA process
The transportation planning process required by 23 USC 134 and 135 and 49
USC 5303 5306 is designed to set the parameters for the project development
process Projects must come from the transportation improvement program
(TIP or STIP) established to implement the plan As a result much of the
data and decisionmaking undertaken by state and local officials during the
planning process carry forward into the project development activities that
follow the TIP or STIP This means that the planning process and the
environmental assessment required during project development by the
National Environmental Policy Act of 1969 (NEPA) (42 U S C 4231 et seq )
must work in tandem with the results of the transportation planning process
feeding into the NEPA process To a much greater degree than other Federal
programs Congress has put great emphasis on the transportation planning
process for shaping transportation decisions and has retained and refined that
emphasis in surface transportation law over decades
3

Protect History in the Thoroughfare Planninu Process
The Gaston Urban Area Metropolitan Planning Organization (MPO) recommends a new location
highway to improve east west mobility in southern Gaston County This new highway is shown
on the Gaston Urban Area Thoroughfare Plan and is locally known as the The Garden
Parkway The Garden Parkway is the number one priority on GUMPO s Unmet Needs List
which is a subset of the Gaston Urban Area Thoroughfare Plan
The need for improved east west mobility and the bypass concept was first identified in 1989
during the citizen participation process associated with the update of the Gaston Urban Area
Thoroughfare Plan The Gaston Urban Area MPO held five citizen workshops six public
meetings and 13 formal public hearings before adopting the locally named Garden Parkway as
a part of their 1991 Plan
In 1994 the Mecklenburg Union MPO Transportation Advisory Committee (TAC) adopted a
conceptual regional thoroughfare plan that included the Garden Parkway
Protect History in the NEPA Process
Study Initiation
Studies for TIP Project U 3321 began in July 2001 using grant funds obtained by The
Honorable Sue Myrick (US House of Representatives)
Concurrence Point 1
May _15, 2002 Initial Concurrence Point 1 meetin g
Concurrence on the purpose of and need for the project was not reached at this meeting
and the Merger Team requested the following additional information
• economic data related to the agricultural industry in Gaston County
• the need for improved connectivity between Gaston and Mecklenburg Counties
July 24, 2002 Second Concurrence Point 1 meeting
The additional information requested by the Merger Team was presented and
Concurrence Point 1 was achieved
Concurrence Point 2
February 17, 2004 Pre Concurrence Point 2 meeting
The purpose of this meeting was to attain agreement for which new location alternatives
NCDOT should prepare functional designs prior to the new location Concurrent Point 2
meeting Approximately 92 miles of new location roadway segments were presented to
the team (1200 foot wide corridors) and on February 17 2004 the team identified 72
0

mules of new location roadway to carry forward for functional design These functional
designs are currently being worked on
An agreement on alternatives that were eliminated from further consideration was signed
by all Merger Team members at the August 17 2004 meeting
August 17, 2004 Partial Concurrence Point 2 meetme
The purpose of this merger meeting was to achieve concurrence on the non new location
alternatives to be tamed forward for detailed study Because of the project scope and
size of the project study area the merger team leaders decided to break Concurrence
Point 2 into sections to make the process more manageable The meetings were
scheduled as information became available
The alternatives presented at the August 17 2004 included No Build (Scenario 1) Maas
Transit 1 talIic 5tistc n Man tgetnent ("I SM) I r iv tJ Dc ill tnd Man tgc ment (TDM)
Improve existing 185 (Scenario 2) Improve existing US 29 74 (Scenario 3) and
Improve Both 185 and US 29 74 (Scenario 4) and Improve Both 185 and US 29 74
plus TSM Type Measures (Scenario 4 +) and a new location freeway (Scenario 5)
The NCDOT presented travel demand projections and traffic operations data on the No
Build Alternative Improve Existing 185 Improve Existing US 29 74 and Improve Both
Existing 185 and US 29 74 The travel demand information was from the regional travel
demand model prepared in TransCad The corridor level traffic operations data was
based on CORSIM
The NCDOT and FHWA proposed that none of the non new location alternatives be
carried forward because the data collected indicates these alternatives do not meet the
Purpose of and Need for the project These alternatives include Mass Transit Traffic
System Management (TSM) Traffic Demand Management (TDM) Improvements to I
85 Improvements to US 29 74 and Improvements to 185 and US 29 74
The Merger Team was not able to reach concurrence at the Partial Concurrence Point 2
meeting for the Gaston East West Connector Study Therefore the North Carolina
Department of Transportation ( NCDOT) and FHWA made a decision to elevate
Concurrence Point 2 to the Review Board for resolution
NCDOT Federal Highway Administration (FHWA) Gaston Urban Metropolitan
Planning Organization (GUMPO) and Mecklenburg Union Metropolitan Planning
Organization (MUMPO) and State Historic Preservation Office (SHPO) agree that none
of the non new location alternatives meet purpose and need and therefore should not be
carried forward as Detailed Study Alternatives (DSAs)
US Fish and Wildlife Service (USFWS) NC Division of Water Quality (NCDWQ)
NC Wildlife Resources Commission (NCWRC) US Environmental Protection Agency
(USEPA) NC Division of Cultural Resources (NCDCR) and US Army Corps of
Engineers (USACE) agree that some or all of the Scenarios presented meet purpose and
need and should be carried forward as Detailed Study Alternatives
Elevation Meetings for Concurrence Point 2
September 14, 2004 — Elevation Meeting #1
5

Merger Team members attended Concurrence was not achieved
September 29, 2004 — Elevation Meeting #2
The supervisors of the Merger Team members attended Concurrence was not achieved
Agencies not concurring with NCDOT agreed to prepare a list of items they would need
to enable them to come to a decision
Week Ending October 8, 2004
The following agencies provided requests for information and questions to NCDOT
USACE USFWS USEPA NCDWQ and NCWRC
Week Ending October 15, 2004
NCDOT provided a response to the information requested by USACE USFWS USEPA
NCDWQ and NCWRC
TIP Protect U 3321 Purpose and Need Statement
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 in general
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County This project purpose is based on the following needs
• Need to improve mobility access and connectivity within southern Gaston County and
between southern Gaston County and Mecklenburg County
• Need to reduce congestion and improve traffic flow on the sections of 185 US 29 74 and
US 321 in the project study area improve high speed safe regional travel service along
the US 29 74 intrastate corridor and generally improve safety and reduce above average
accident rates in the study area
The project study area consists of the following general boundaries 185 to the north the South
Carolina State line to the south the Charlotte Douglas International Airport to the east and the
185 and US 29 74 function to the west
R

Summary of Traffic Analyses Results
Regional travel demand modeling and corridor level traffic operations analyses for the year 2025
were performed for the following scenarios to evaluate traffic flow in the study area
Scenario 1 —No Build Alternative
No capacity improvements to 185 or to US 29 74
Scenario 2 — Improve 185
Widen 185 to eight lanes in each direction (addition of one through lane in each
direction) from the existing 8 lane area at Exit 26 (Belmont) west through Gastonia to the
interchange of US 29 74 and 185 This scenario does not include any improvements to
ramps or overpasses in the 185 corridor
Scenario 3 — Improve US 29 74
Widen the bridges over the Catawba River and the South Fork Catawba River to six
lanes Widen the four lane section that exists west of Gastonia from Myrtle School Road
west to 185 to six lanes This scenario does not include any turn lane improvements on
US 29 74 or on any other arterials in the project study area
Scenario 4 — Improve both 185 and US 29 74
Scenario 4 is a combination of Scenarios 2 and 3
Scenario 5 — Build a New Location Freeway
Build a new location freeway south of 185 from 185 west of Gastonia to I-485 No
improvements would be made to existing 185 or US 29 74
Regional Travel Demand Model
Scenarios 2 and 3 were run to provide an evaluation of the relative influence of
improvements on 185 versus improvements on US 29 74 Based on these two scenarios
improvements on 185 had the most influence on travel patterns and volumes although
improvements to US 29 74 did have some effect
The Merger Team agreed that improvements to one of these roadways alone (Scenarios 2
and 3) did not meet purpose and need Therefore the discussions that follow focus on
comparing Scenario 4 to Scenarios 1 and 5
The travel demand model provided the following information for each scenario
• Average daily traffic volumes for mayor roadways in the study area
• Peak hour traffic volumes for mayor roadways in the study area
• Volume to capacity ratios (a measure of congestion) on mayor roadways
• Regional Statistics
• Vehicle miles traveled (VMT) daily on roads in the region
• Congested vehicle miles traveled (Congested VMT) daily on roads in the
region
• Vehicle hours traveled (VHT) daily on roads in the region
• Congested vehicle hours traveled (Congested VHT) daily on roads in the
region
7

General Conclusions from the Regional Travel Demand Model
• Improving 185 and US 29 74 attracted three to four percent more traffic to the
existing corridor
• Building a new location roadway diverted 20 percent of the existing traffic volume
from 185 and 12 percent from US 29 74
• Building a new location roadway resulted in better volume to capacity ratios on 185
and US 29 74 than improving the existing roadways (Can you give the v/c ratio
Also a brief explanation of what v/c ratios are?
• Building a new location roadway is approximately twice as effective at reducing
regional vehicle hours traveled congested vehicle miles traveled and congested
vehicle hours traveled (Again do you think your audience will know what you are
talking about ?)
Corridor Level Traffic Operations Analysis
Using traffic volume information from the regional travel demand model the CORSIM
computer model was used to evaluate traffic operations along the 185 and US 29 74
corridors for the 2025 peak periods that would occur under each scenario
Results from the CORSIM analysis were consistent with the results from the travel
demand model The CORSIM model produced a series of corridor level statistics for
each modeled scenario These included vehicle hours traveled hours of delay and
average speed
General Conclusions from the Corridor Level Analysis
• Increasing capacity on 185 and US 29 74 result in only slight improvements in
vehicle hours traveled hours of delay and average travel speeds along the corridor
• Diverting traffic to a new location freeway results in substantial improvements in
vehicle hours traveled hours of delay and average travel speeds along the 185 US
29 74 US 321 and I-485 corridors due to the reductions in traffic volumes on these
roadways
Based on the results of the CORSIM analysis for Scenario 4 a list of additional
improvements that would be needed along and in the direct vicinity of the 185 and US
29 74 corridors to help maximize the efficiency of traffic operations along the corridor
was developed This TSM list included approximately 70 improvements such as adding
turn lanes or additional lanes in interchange ramps
Other Considerations
I IS 29 74
Because of operational deficiencies identified in Scenario 4 numerous TSM type improvements
along US 29 74 were incorporated into Scenario 4 resulting in Scenario 4+

The corridor level model was not rerun for these improvements It is likely that making these
improvements would simply shift the congestion farther downstream The regional demand
model runs already completed show that improvements made to US 29 74 and existing 185
continue to attract more traffic due to the latent travel demand in the area resulting in a build it
and they will continue to come situation The cycle of making recommended improvements
running the model identifying new areas of congestion making those improvements then
running the model again was not necessary to adequately evaluate the ability of the Improve
Existing Roadways Alternatives to meet the project purpose and need It would simply add more
improvements to the list for Scenario 4+
185
185 would require widening to a minimum of eight lanes throughout the study area under
Scenario 4 or 4+ All interchanges along 185 in the project study area would need to be
reconstructed in order to meet current design standards Also structures over 185 within the
project study area do not have sufficient horizontal clearances to allow for additional lanes
thereby requiring replacement of these structures The re construction of interchanges and
replacement of structures would result in lengthy construction periods and driver delays through
these construction zones and would require complex maintenance of traffic plans to allow for the
safety of the motorists and the construction workers
In addition to work at the eleven interchanges in the project study area there are fifteen cross
street bridges and six railroad bridges that would need to be replaced because of inadequate
horizontal clearances
In order to maintain existing traffic patterns these new bridge structures would need to be
constructed on new alignments and where possible adjacent to the existing structures The
construction of these bridges would result in increased driver delay and could impact driver safety
during the construction period In order to attempt to minimize these delays it would be
recommended to stagger the replacement of these bridges within the project study area limits By
staggering this construction there could be a delay of 10 years or more before widening of 185
could be completed While structural issues of bridges would not be as prevalent along US 29/74
there would be driver delays and potential economic impacts to local merchants due to changes in
travel patterns
There is an existing Freeway Management System (Intelligent Transportation System [ITS]
technology) in Mecklenburg County If a new location alternative were selected as the preferred
alternative this new location route would be used as an alternate route during incidents on 185
(I don t think the merger team cares if the project affects the equity formula or not
9

INFORMATION /QUESTIONS REQUESTED BY MERGER TEAM
GASTON COUNTY EAST WEST CONNECTOR STUDY
TIP PROJECT NO U 3321
GASTON AND MECKLENBURG COUNTIES
FEDERAL PROJECT NUMBER STP 1213(6)
STATE PROJECT NUMBER 8 2812501
WBS ELEMENT 34922 1 1
The following requests for information and questions were submitted by the non
concurring agencies (USACE USFWS NCWRC NCDWQ EPA) from the U -3321
Merger Team for Partial Concurrence Point #2 Information or questions have been
compiled by NCDOT and grouped by topics they are as follows
1 Mass Transit
2 Information on Other Road Projects
3 Tolls
4 Funding
5 NEPA Regulations
6 Scenario 4+ Impacts
7 Constructability and Facility Size
8 Expanded Alternatives
9 T &E Species
10 Other
Under each request or group of sinular requests is a response reference to where an
answer is located or why we could or could not provide responses The subsequent
responses will hopefully provide an opportunity for the Merger Team to achieve Partial
Concurrence Point #2
MASS TRANSIT
• Information on all existing mass transit in the study area and projections for future
mass transit improvements and ridership (WRC)
Existing mass transit consists of local bus service connecting Gaston and
Mecklenburg Counties Current Mass Transit ridership in Mecklenburg County is
2 6% and 0 3% in Gaston County Mecklenburg County assumes future transit
ridership to be between 2% and 5% of total trips Because of the low transit
ridership in Gaston County future ridership is not projected or included in the
Gaston MPO model Expansion of mass transit in the study area includes the West
Corridor which will be comprised of either Bus Rapid Transit (BRT) or Light Rail
Transit (LRT) The EIS for this corridor is expected to begin this month
• NCDOT should provide information on the following (a detailed explanation and
analysis on how these Mass Transit initiatives may effect predicted traffic volumes in
the design year for 185 and US 29/74 and how a New Location Freeway alternative
U 3321 Gaston East West Connector Study I Response to Merger Team Requests

might potentially reduce future ridership assumptions for Mecklenburg County)
(EPA)
- Gastonia Express or Route 85X express service from Gastonia to Charlotte
Current and future predicted ridership
June 03 thru May 04 — 28 453
CATS does not prepare future ridership projections for individual routes
- Future Transit Ridership Assumptions in MPO s Travel Models for Gaston
County
Gaston MPO does not include a transit component in their model because of
insignificant ridership numbers in the county There is no indication in the
county that these numbers will increase in the near future The ridership
assumptions for Mecklenburg County is 2 5%
- NC Passenger Rail Service (AMTRAK) between Charlotte and Gastonia
Current and predicted ridership number of stations between Gastonia and
Charlotte width of existing right of way and plans for any service expansion
Currently there is only one option to travel from Gastonia to Charlotte via
Amtrak The northbound Crescent Line leaves Gastonia at 12 41 PM and
arrives in Charlotte 1 23 PM The southbound Crescent Line leaves
Charlotte at 3 25 PM and arrives in Gastonia at 3 52 PM It is a professional
opinion that ridership between Charlotte and Gastonia via AMTRAK is very
low and should not be considered a valid transportation option Future
service expansion is unknown
- Proposed Airport People Mover between Charlotte Int Airport and 185
Current status
The West Corridor Major Investment Study (MIS) prepared Sept 25 2002 for
the Charlotte Area Transit System identified a January 1998 update to the
Charlotte /Douglas International Airport Master Plan This update identified
the construction of a new airport expressway connecting 185 to the existing
passenger terminal and also identified a people mover to connect the
terminal satellite parking and a relocated rental car facility north of
Wilkinson Boulevard There are no current plans to extend the people
mover further north
- LRT /BRT Alternatives 2A & 213 from Charlotte to Gaston County line
Current status and future ridership projections
The preparation of the Environmental Impact Statement for the West Corridor
is expected to begin this month The EIS will identify an alternative to move
forward into design with The West Corridor Major Investment Study (MIS)
U 3321 Gaston East West Connector Study 2 Response to Merger Team Requests

prepared Sept 25 2002 for the Charlotte Area Transit System identified
future ridership projections for Alternatives 2A and 2B as follows
Alternative
Bus
BRT
LRT
BRT - (Morehead St - Wilkinson Bv)
2000
7000-8000
N/A
LRT - (Morehead St - Wilkinson Bv)
2000
N/A
7000-8000
BRT - (Mint St - Wilkinson Bv)
2000
5000-6000
N/A
LRT (Mint St -Wilkinson Bv) 1
20001
N/A 1
5000-6000
- LRT/BRT Alternatives 3A & 3B from Charlotte to Dixie River Road Current
status and future ridership projections
The preparation of the Environmental Impact Statement for the West Corridor
is expected to begin this month The EIS will identify an alternative to move
forward into design with The West Corridor Mayor Investment Study (MIS)
prepared Sept 25 2002 for the Charlotte Area Transit System identified
future ridership projections for Alternatives 3A and 3B as follows
Alternative
Bus
BRT
LRT
W 3A BRT - (Mint St - West Bv)
2000
4000-5000
N/A
W 3A LRT - (Mint St - West Bv)
2000
N/A
4000-5000
W 3B BRT - (Morehead St - Clanton Rd -
West By - Tyvola Rd )
2 500
7000-8000
N/A
W 3B LRT (Morehead St - Clanton Rd -
West By - Tyvola Rd )
2 500
N/A
7000-8000
INFORMATION ON OTHER ROAD PROJECTS
• Other TIP projects in the area NCDOT should provide a status of the following
projects and provide detailed traffic information on how these improvements reflect
on increased mobility reduced congestion and improved safety in the Project Study
Area (EPA)
R -2608 4 lane new location route from 185 west of Gastonia to US 321
north of Gastonia for approximately 7 5 miles
U -2408 NC 274 widening to 4 lanes for approximately 2 8 miles
U 3405 NC 274 widening to 5 lane for approximately 14 miles
U 3321 Gaston East West Connector Study 3 Response to Merger Team Requests

TIP Project Number R 2608 is an unfunded project as lasted in the 2004 2010 TIP
Only a portion of this proposed project near 185 is within the U 3321 project study
area Projects U 3321 and R 2608 were developed from the thoroughfare plan
alignment for the Garden Parkway which is and has been the number one priority
project for the Gaston Urban Area MPO for several years This project is not
included in the regional model however it is anticipated that it will be included for
the 2030 model with the Detailed Study Alternatives Currently no traffic information
is available for this project anticipated benefits of this project such as increased
mobility or reduced congestion would be speculative See additional information
from Newsletter #2
TIP Projects U 2408 and U 3405 are funded projects in the TIP and were included in
the regional model for the Gaston Urban Area MPO The regional model accounts
for the effects of the traffic distribution
U 2408 Gastonia — From NC 274 (Bessemer City Rd) To
US 29 74 (Franklin Blvd)
R/W 12 /20 /02
LET 11 /16/ 04
U 3504 Bessemer City — NC 274 (Gastonia Hwy) From SR 1484 (Maine Ave) To
west of NC 275
R/W 08 /20 /04
LET 07 /18 /06
• Information on other road projects in the area and how they affect future traffic
conditions (WRC)
Provide information about other road projects in the study area (either currently in
planning or those funded) and how those improvements will influence future traffic
and congestion (FWS)
Programmed improvements in the TIP are accounted for in the regional models of the
Gaston and Mecklenburg MPOs These improvements are thereby included for the
No Build and Build Scenarios The No Build Alternative always assumes that
projects will move forward to completion
U 3321 Gaston East West Connector Study 4 Response to Merger Team Requests

TOLLS
• Evaluate the traffic and congestion improvements to I -85 and US 29/74 assuming the
new location alternative is a toll road (FWS)
• Scenario 5 as a toll road (WRC)
• The percentage for truck traffic on 185 is estimated at 20 percent (Pages 34 and 35)
What is the estimated truck traffic on a New Location Freeway that is a toll road?
(EPA)
• Analysis of the LOS and traffic volumes for 185 US 29/74 and the new location
with the assumption that the new location facility would be a toll road (DWQ)
• NCDOT should provide a revised traffic analysis for the New Location Freeway
alternative based upon the likelihood that the Gaston Freeway is proposed to be a
toll road by the N C Turnpike Authority (EPA)
It has not been determined that this project will be a toll facility A toll would be one
funding option Traditionally funding has not been an element of the alternative selection
process
FUNDING
• Given the limited resources available for planning projects please explain why an
unfunded project is receiving priority (DWQ)
NCDOT received a Congressional mandate to being planning and environmental studies
on this project
• This facility is presently not funded in the TIP Please identify the funding source for
the new location facility (DWQ)
It is anticipated that this project will be eligible for Highway Trust Funds and Federal
Aid funding Funding for construction has not been identified in the TIP at this time
NEPA REGULATIONS
• Why does the NCDOT believe that the widen existing alternatives do not meet the
purpose and need? What part of the purpose and need statement is not mete
Agencies feel that this has not been answered to their satisfaction (WRC)
U 3321 Gaston East West Connector Study 5 Response to Merger Team Requests

The widen existing alternatives do not meet the critical elements of the Purpose and
Need Statement
• Under NEPA and Section 404 does an alternative have to fully meet the exact letter
of the purpose and need statement to be considered reasonable and feasible9 Or is the
ability of an alternative to meet the project purpose subject to a broader
interpretations (USACE)
An alternative has to meet the critical elements of the Purpose and Need Statement as
identified by the lead agencies
• Document the need for an additional crossing of the Catawba River (USACE)
The need for an additional crossing has been documented through the Thoroughfare
Plan development process for both the Gaston and Mecklenburg MPOs Both
planning organizations show an alignment (based on transportation need) across the
Catawba Raver
SCENARIO 4+ IMPACTS
Has DOT evaluated the environmental and social impacts from improvements to 185
and US 29/74 on any lever If so will DOT share that information with the merger
team so it can be considered in concert with traffic modeling data? (USACE)
Per the July 14 2004 Partial Concurrence Point 2 meeting handout (Item 7 of the
agenda Page 26) EPA is requesting that NCDOT provide the impact information for
Scenario 4+ as shown in this pre meeting package Impacts for this alternative to
wetlands streams historic properties relocations etc are listed on Page 26 and were
to be reported to the agencies at the 8/17 Merger meeting (EPA)
• Impacts of Improve Existing Roadways as indicated in Section 7 (page 26) of the
meeting information packet for the August 17 2004 meeting that were to be
provided at the meeting (WRC)
• Potential impacts to streams (linear feet) wetlands (acres) and other water bodies
(acres) due to improvements to 185 and US 29/74 Landscape scale assessment is
acceptable (DWQ)
• Provide the impact data for improve existing scenario 4+ as described on pages 26 27
of the July 14 2004 handout (FWS)
• Potential impacts to park and recreation areas community facilities and historic sites
due to improvements to 185 and US 29/74 Also the number of residences and
businesses to be relocated by proposed improvements to 185 and US 29/74 (DWQ)
U 3321 Gaston East West Connector Study 6 Response to Merger Team Requests

Only a cursory level impact analysis was done for the improve existing alternatives
These impacts are not at the same level of detail as the corridor level new location
alternative impacts Therefore it is not constructive to draw a comparison
Additionally impacts are not used in determining whether alternatives meet Purpose
and Need or which alternatives should be carried forward
CONSTRUCTABILITY AND FACILITY SIZE
The size of the facility (no of lanes on and off -ramp lanes etc ) needed for an
improve existing alternative (I -85 and US 29/74) Include constructability issues and
estimated costs (DWQ)
• Bridge replacements (auto and railroad) due to improvements to 185 and US 29/74
Include constructability issues with parallel bridges (DWQ)
This information is not necessary in determining if a proposed alternative meets the
project s Purpose and Need This type of analysis would be done during the Detailed
Study Alternatives (DSAs) stage
EXPANDED ALTERNATIVES
• Document the issues /problems with improvements /widening of the main arterial
routes that currently serve southern Gaston County This would include US 321 NC
274 NC 279 NC 273 Look beyond just improving the intersections with I -85 and
US 29/74 DOT s consultant touched on this during the meeting on August 17
talking about congestion issues but did not provide any information (USACE)
• An additional multi modal scenano that would evaluate Scenario 4 Plus and
incorporate mass transit improvements TDM and any other TSM improvements that
together would provide a best case scenario for Non New Location alternatives
Assumptions and variables put into the model for the above analysis (WRC)
Further analysis of the multi -modal alternative that explores creative combinations of
improve existing TSM mass transit improvement of Y lines and build alternatives
to meet the Purpose and Need of the project (DWQ)
NCDOT should identify and specifically review with Merger team members the 70
TSM location improvements identified in the July 14th package (Pages 7 through 10)
(EPA)
U 3321 Gaston East West Connector Study 7 Response to Merger Team Requests

Evaluate Scenario 4+ with the TSM measures described on pages 7 10 of the July 14
2004 handout and any other TDM and/or mass transit measures to achieve a best case
scenario for an improve existing alternative (FWS)
• Scenario 4 Plus which includes the TSM improvements described in Section 5 1 of
the meeting information packet for the August 17 2004 meeting (WRC)
If connectivity is a failing of improvements to 185 and US 29/74 did the NCDOT
evaluate improvements to existing arterial routes beyond interchanges (such as US
321 NC 274 NC 7 and/or NC 273) that could serve to connect southern Gaston
County to 185 and US 749 If so what are the impacts from such improvements?
(USACE)
In order for a new location facility to carry an estimated 50 000 vehicles per day at
an acceptable level of service (LOS) a full control access freeway is needed Mass
transit is included in the model for all scenarios
ME SPECIES
• Does suitable habitat exist for the federally endangered Carolina heelsplitter within
any of the new location comdors9 Do ES populations exist in these same corridors
Is DOT prepared to revisit Concurrence Point 2 if an ES avoidance alternative is
prematurely elirmnated9 (USACE)
• Provide survey data for federally listed species in the project study area including
both the new location corridors and the improve existing scenarios (FWS)
The natural resources investigation will commence after Detailed Study Alternatives
are selected Therefore it is unknown at this time whether suitable habitat exists If
protected mussels are found within the project study area NCDOT will address any
impacts to project alternatives at that time Natural resource data is not necessary in
determining if a proposed alternative meets the project s Purpose and Need This
type of analysis would be done during the Detailed Study Alternatives (DSAs) stage
OTHER
• Scenario 1 - No Build as a true Do Nothing Alternative without the minor
improvements used in the original analysis that are considered TSM improvements
(WRC)
The Do Nothing Alternative does not include TSM improvements
U 3321 Gaston East West Connector Study 8 Response to Merger Team Requests

From the July 3 2002 Purpose and Need package Section 9 3 2 Design Year Traffic
Volumes for 2025 are shown on page 35 ADT volumes are expected to increase
from 19 to 64 percent on 185 31 to 329 percent on US 29/74 and 8 to 88 percent on
US 321 EPA would like to know why there is such an unpredictable wide range of
ADT volume percentages in the design year and which percentages were used in the
traffic models for the alternatives considered (EPA)
The project study area is 20 miles wade and there are variations that depend on
where you re looking For example a 329 percent increase on US 29 74 is attributed
to where 1 485 (a new highway) will intersect
U 3321 Gaston East West Connector Study 9 Response to Merger Team Requests

e
Gaston Urban Area Metropolitan Planning Organization
181 South Street P O Box 1748
Gastonia, NC 28052 Gastonia, North Carolina 28053
MEMORANDUM L
To Knstina Solberg PE
Project Development Engineer
NCDOT
From Hank Graham AICP
Senior Transportation Planner
Gaston MPO
Re Gaston Urban Area MPO Position Paper for Partial Concurrence Point #2 regarding
TIP Project U 3321
Date October 19 2004
TIP Pr_oiect U 3321 Purpose and Need Statement Position
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 in general
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County This project purpose is based on the following
• Need to improve mobility access and connectivity within southern Gaston County and
between southern Gaston County and Mecklenburg County
• Need to reduce congestion and improve traffic flow on the sections of I -85 US 29/74 and
US 321 in the project study area improve high speed safe regional travel service along
the US 29 74 intrastate corridor and generally improve safety and reduce above average
accident rates in the study area
FINDING The Gaston Urban Area MPO attest that the No Action and the proposed New
Location alternative are the only alternatives that satisfy the purpose and needs statements
referenced above for TIP Protect U 3321 The new location alternative is the only
alternative that provides direct access and connection between Southern Gaston and
Mecklenburg Counties Subsequently the new location alternative will improve mobility
for 185 and US 29/74 by providing an alternative route for the County's growth areas
Gaston County Project History and Summary
Future traffic congestion is the maJor reason for constructing this roadway The Gaston Urban
Area MPO held five citizen workshops six public meetings and 13 formal public hearings
1

before adopting the locally named US 321/74 Bypass on their 1991 Plan however the line on the
Map was conceptual and had not been subject to a feasibility study In 1997 the Transportation
Advisory Committee (TAC) of the Gaston Metropolitan Planning Organization (MPO) created
the US 321/74 Bypass Citizen s Committee The first step for the Committee was to establish an
alignment for the Parkway The preferred alignment recommendation was completed on August
1998 and adopted by the Gaston MPO TAC in January 1999 Second the Bypass Committee
staff examined the existing and potential land development issues within the corridor and
developed an evaluation report The Committee not staff wished to be educated on and
subsequently recommended and promoted SMART GROWTH land use and development
principals along the proposed corridor The Committee finally developed a land use
recommendations report for the corridor in 2001 The TAC changed the project s name from the
US 321/74 Bypass to the Garden Parkway in November 2001 because of its close proximity and
easy access to the Daniel Stowe Botanical Garden (DSBG)
Citizens US 321/74 Bypass Committee Composition
The committee was comprised of representatives from each of the affected planning jurisdictions
and other interest groups Gastonia 3 Belmont -2 Gaston County -2 Dallas -2 Bessemer City -1
Cramerton 1 and the Gaston County Quality Natural Resources Commission -1 the Gaston
County Economic Development Commission -1 and the Gaston County Historic Preservation
Commission 1 The Commmttee underwent an extensive educational process using visual
preference surveys and/or visioning exercises Two (2) public forums were held to give citizens
the chance to hear and voice ideas Organized educational symposiums were conducted for the
first two or three meetings to discuss land use topics related to sprawl retail in suburb areas
and traffic on minor arterial and collector streets transit oriented development conventional
suburban growth traditional neighborhood development smart growth etc The Comrruttee
conducted approximately 18 20 meetings workshops and public hearings over a two year and 6
month time period
The Gaston Urban Area Metropolitan Planning Organization (MPO) recommends a new four
lane divided roadway with fully controlled access to improve east -west mobility in southern
Gaston County This new highway is shown on the Gaston Urban Area Thoroughfare Plan and
is locally known as the US 321/74 Bypass and The Garden Parkway The Garden
Parkway is the number one priority on the MPO s Unmet Needs List which is a subset of the
Gaston Urban Area Thoroughfare Plan
Transportation Improvement Program (TIP) Status
Two segments of the bypass are currently listed in the Unfunded Projects section of the State
of North Carolinas Transportation Improvement Program (TIP) The first is the Gaston East
West Connector from the end of West Boulevard in Charlotte to Interstate 85 in Gaston County
The second segment is the US 321 Bypass from 185 to US 321 North There is no funding
associated with either of these roadway segments therefore the inclusion in the TIP is wishful
thinking
The East West Connector would provide an excellent connection to the Charlotte Douglas
International Airport The preferred alignment researched and established by the Gaston Bypass
Committee proposed nine (9) interchanges for the roadway segment currently known as the
Gaston East West Connector
2

The Gaston Urban Area traffic simulation model indicates that both 185 and US 29/74 will be at
or over capacity in 20 years even with the Connector in place Therefore improvements to either
of these two roadways will not be a feasible alternative for the East -West Connector as all
improvements will be necessary in the future
Summary
• The US 321 Bypass was first identified in 1989 during the process to update the
Thoroughfare Plan
• Updated Thoroughfare Plan adopted in 1991 included the bypass
• 1994 Committee of 100 includes the bypass as part of the Metropolitan Roadway Plan
• 1994 Mecklenburg -Union MPO revises its thoroughfare plan to include the bypass
• 1997 Bypass Committee formed by the MPOs Transportation Advisory Committee begins
meeting to refine the bypass alignment to provide an alternative travel corridor through
Southern Gaston County
• August 1998 - Bypass Committee completes its work and sends recommendation to the TAC
• January 1999 TAC takes final vote on alignment of the bypass
• March 1999 TAC votes to adopt revised Thoroughfare Plan which includes new bypass
alignment
• November 1999 local mutual adoption process of the Thoroughfare Plan is complete which
signifies support for the bypass
• 2001 Bypass Committee completes Land Use Study with recommendations for affected
municipalities
• Studies for TIP Project U -3321 which is a portion of the Garden Parkway began in July
2001 using grant funds obtained by Ms Sue Myrick (US House of Representatives)
FINDING In conjunction with the clearly defined "Purpose and need" statement, the
volume of data and work conducted by the Bypass Citizen's committee is a testament to the
amount of public, private and political support for the proposed project
Issue Being Elevated in the NEPA /404 Merger Process — Concurrence Point #2
The NCDOT considered the following basic types of alternatives in accordance with FHWA
Guidelines (Technical Advisory T6640 8A)
1 No Action — Gaston MPO concurs that this should remain as an alternative for the proposed
project
2 Transportation System Management (TSM) and Transportation Demand Management
(TDM) Measures — Gaston MPO does not concur that this alternative group is a feasible
alternative for the proposed project
3 Mass Transit Gaston MPO does not concur that this alternative group is a feasible
alternative for the proposed project
4 Improve Existing Roadways (Improve 185, Improve US 29/74 or Improve Both 185
and US 29/74) — Gaston MPO does not concur that this alternative group is a feasible
alternative for the proposed project
5 New Location Gaston MPO concurs that this should remain as an alternative for the
proposed project
3

FINDING The Gaston MPO believes that the studies and analyses that have been
completed to date sufficiently demonstrate that TSM/TDM measures, mass transit, and
improvements to existing roadways do not meet all critical elements of the purpose and
need for the proposed protect and should be eliminated from further study The Gaston
MPO agrees that Mass Transit, TSM, TDM, Improvements to 185, and Improvements to
US 29 74 do not meet purpose and need and should not be carried forward as Detailed
Study Alternatives for this proposed Protect U 3321
FINDING A different protect purpose and need for another geographic study area, a
different population base with different land use patterns should and would yield the need
to include 185 and /or US 29/74 as protect alternatives, but not for TIP Protect U 3321
E

F
Y��,
MEMORANDUM
TO Kristina Solberg PE
Project Development Engineer
North Carolina Department of Transportation
FROM Robert W Cook AICP
Transportation Program Manager
Charlotte Mecklenburg Planning Commission /MUMPO
SUBJECT Position Paper TIP Project U 3321
Further Study of Non New Location Alternatives
DATE October 18 2004
It is the position of the Mecklenburg Union Metropolitan Planning Organization
(MUMPO) that none of the non new location alternatives merit further analysis as part of
the evaluation of U 3321 and therefore should be eliminated from further study The text
that follows will elaborate on why this position is being taken
Purpose & Need
The mutually agreed upon Purpose and Need for this project states as follows
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
In general and particularly to establish direct access between the rapidly growing area
of southeast Gaston County and west Mecklenburg County This project purpose is
based on the following
Need to improve mobility access and connectivity within southern Gaston
County and between southern Gaston County and Mecklenburg County
Need to reduce congestion and improve traffic flow on the sections of l 85 US
29 74 and US 321 in the project study area improve high speed safe regional
travel service along the US 29 74 intrastate corridor and generally improve
safety and reduce above average accident rates in the study area
In determining whether to further study the identified non new location alternatives one
must focus on the established purpose of and need for the project None of the non
new location alternatives will succeed in providing direct access between southern
Gaston County and Mecklenburg County Any improvements associated with the non
new location alternatives will of course be limited to existing facilities 1 85 US 29 74
and the Norfolk Southern rail line These three facilities fixed to a narrow corridor
running through the middle of Gaston County Only a facility constructed on new
location as has been proposed by U 3321 will meet purpose and need by providing the
direct access explicitly mentioned in the Purpose and Need statement

iv rte.
One of the primary reasons for the need to provide direct access is the substantial
employment in southwestern Mecklenburg County combined with the steady population
increases in southern Gaston County Many of the people choosing to reside in Gaston
County are employed at or in the vicinity of Charlotte Douglas International Airport
The airport itself is the third largest employer in Mecklenburg County and employment in
the airport area is expected to grow significantly due to planned airport expansions and
the development of an intermodal facility Employment in the area will also be bolstered
by the strategies approved by the Charlotte City Council when it adopted the Dixie
Berryhill Strategic Plan Much of the land within the study area was zoned residential
but is now planned for employment/mixed use
The approved Purpose and Need statement further notes the need `to improve east
west transportation mobility in the area around the City of Gastonia With the
exception of the 185 /US 29 74 corridor east west routes in Gaston County are virtually
non existent and the problem is particularly acute in the southern part of the county
Project U 3321 will correct that situation and significantly improve mobility within the
county without affecting corridors that are projected to be highly congested in the future
I -85
The scope of improvements that would be required along 1 85 would have a tremendous
�3 negative impact on the physical and social environment Every interchange would have
to be reconstructed as would virtually all overpasses Much development has taken
7� place in close proximity to the corridor this is especially true near the interchanges The
required reconstruction of interchanges and overpasses would require a great deal of
oZ
Oadditional right of way which in turn would likely require the relocation of a significant
number of homes and businesses Moreover nearby homes not acquired for right of
way could be greatly impacted temporarily by construction and permanently by the
noise associated with the increased traffic volumes
\\�C
US 29 -74
This facility is becoming less a road for regional travel and more a road for local
�S
residents to use for shopping and other similar trips Evidence of this can be seen
clearly in Gastonia in the area of Franklin Square and Eastridge Mall but also in
Belmont where a large regional shopping center is to be built and on Gastonia s west
side where a Wal Mart Supercenter recently opened Introducing regional traffic that
could use U 3321 to US 29 74 will exacerbate worsening congestion
Feeder Roads
Relying upon 1 85 and US 29 74 to accommodate traffic that would use U 3321 will not
only affect those facilities but will also affect their feeder roads Unfortunately few of
them are designed for the increased volumes that would be realized by motorists
attempting to access them Most pass through existing neighborhoods that would be
negatively impacted by the increased traffic volumes and there is little room for
increasing capacity without causing great harm to the those neighborhoods For
example those wishing to reach Exit 23 would have to pass through the cores of Lowell
and McAdenville Those using Exit 17 would have to pass through two historic districts
I n Gastonia and a neighborhood that would potentially generate environmental justice
concerns

A- ri
The first milestone in the environmental analysis of this project was reaching
concurrence on Purpose and Need The agreed upon Purpose and Need definitively
states that the purpose of the project is to provide access between southeast Gaston
County and Mecklenburg County and to improve east west mobility around Gastonia
Since the non new location alternatives fail to meet these tests the only logical
conclusion to be reached is to eliminate them from further consideration

a]
US Army Corps
of Engineers
W Im ngton Distnct
� �x�
Gaston E -W Connector Study, U -3321
Gaston/Mecklenbug Counties, NC
• Elevation Procedure under Section 404 /NEPA
Merger Process
• Ability of Improvements to Existing Roads to
Meet Project Purpose and Need
1 The subject study concerns a proposal to improve east west transportation mobility in the area between the
Gastonia and Charlotte metropolitan areas in general and between southeast Gaston County and western
Mecklenburg County in particular The project study area is bounded by 185 on the north the South Carolina
State Line on the south the Charlotte Douglas Airport on the east and the 185 /US 29 74 intersection and
Crowder's Mountain State Park on the west A Purpose and Need Statement for the project was signed by the
Merger Team on July 24 2002
2 A Merger Team meeting was held on August 17 2004 to consider whether proposed improvements to the existing
east west routes of Interstate Highway 85 and US Highway 29 74 would meet the project purpose In summary
traffic modeling data was presented which showed that widening 185 and US 29 74 would nominally reduce
congestion improve traff ic flow and reduce vehicle travel times but would probably not address the regional needs
to improve mobility and connectivity It was NCDOT s opinion that if an alternative did not fully meet all aspects of
the purpose and need statement that it should not be carried forward for additional study Considering the multi
faceted P & N Statement the merger team members with the exception of FHWA and the MPOs rejected this
position stating that widening still met the overall purpose of the project and it would be premature to eliminate it at
this point in the process Connectivity was not fully addressed because NCDOT did not evaluate improvements to
existing arterial routes beyond interchanges that could serve to connect southern Gaston County to 185 /US 29 74
The meeting adjourned without agreement
3 On September 8 2004 NCDOT notified merger team members that it intended to elevate the issue of the ability of
a widened 185 and US 29 74 to meet the project purpose and need We believe that this is an issue oriented
elevation request and not a concurrence point elevation
4 On September 14 2004 the merger team reconvened as the first step in the elevation process The NCDOT
reiterated its position in Item #2 above No additional information was presented The merger team requested that
NCDOT provide the GIS level impact data for the widening alternative that was described in Item 7 of the August
17 2004 meeting handout so that it could be considered in concert with the traffic data NCDOT declined to
provide this information indicating that the decision must be made on purpose and need alone No agreement
was reached
5 On September 29 2004 a meeting of Merger Team Supervisors was held as the next step in the elevation
process No concurrence was reached on the issue of whether or not to carry forward any non new location
alternatives The NCDOT agreed to provide a written response to questions and requests for additional
information by non concurring merger team members This response was a mailed to agencies on October 15
2004 This response contained no new information sufficient to change our position
6 The NCDOT has not clearly demonstrated that improvements to existing east west routes of Interstate 85 and US
29 74 would not meet the basic purpose of the project NCDOT s data show that these improvements would meet
some but not all of the facets of the P &N Statement The issue of connectivity has not been fully addressed
There is insufficient information on record to demonstrate that improvements to existing routes is not a practicable
alternative or that these improvements would have unacceptable environmental impacts It is recommended that
Scenario 4+ (improve both 185 and US 29 74 and potentially include improvements to connecting routes) be
carried forward for additional study and documentation of transportation benefits as well as impacts
10/19/04 POC Steven Lund
[phone] extension 223

® North Carolina Wildlife Resources Commission KN
Richard B Hamilton Executive Director
TO Knstina Solberg P E Project Manager
Project Development & Environmental Analysis Branch NCDOT
FROM Marla Chambers Highway Projects Coordinator
Habitat Conservation Program NCWRC
THROUGH David Cox Supervisor
Habitat Conservation Program NCWRC
DATE October 19 2004
SUBJECT Partial Concurrence Point 2 on non -new location alternatives for the proposed
Gaston East West Connector Gaston and Mecklenburg Counties TIP No
U 3321
Staff biologists with the North Carolina Wildlife Resources Commission ( NCWRC) have
participated in the NEPA/404 Merger process and attended Merger Team meetings including
two meetings of Partial Concurrence Point 2 on non new location alternatives for the proposed
Gaston East West Connector We have the following comments regarding the subject
concurrence point These comments are provided in accordance with the provisions of the
National Environmental Policy Act (42 U S C 4332(2)(c)) and the Fish and Wildlife
Coordination Act (48 Stat 401 as amended 16 U S C 661 667d)
The NCDOT proposes to improve east west transportation mobility between Gaston
County and western Mecklenburg County During the alternatives development phase of this
project TIP Project No U 3321 both new location and non new location alternatives were
considered Due to the size of the project Concurrence Point 2 has been divided into two
Partial Concurrence or Pre Concurrence points New location corridor segments were
agreed upon at the first Partial Concurrence Point 2 meeting on February 17 2004 At issue in
the second Partial Concurrence Point 2 meetings held on August 17 2004 and September 14
2004 was whether any non new location alternatives meet the purpose and need of the project

Gaston East West Connector 2 October 19 2004
Gaston & Mecklenburg Counties
In the project area Gaston and Mecklenburg Counties are separated by the Lake Wylie
portion of the Catawba River The existing crossings of the waterway in the project study area
185 and US 29 74 cross approximately 1 mile apart and pass dust to the north of Charlotte
Douglas International Airport New location corridors would carry traffic through southern
Gaston County near the state line crossing both the South Fork Catawba River and Catawba
River arms of Lake Wylie terminating southwest of the airport Both the new location and non
new location preliminary alternatives would connect to 1485 currently under construction
which will run north and south between the airport and Lake Wylie Other crossings of the
main stem of the Catawba River lie within three miles of the project study area to the north NC
27 and approximately 3 miles to the south of the study area NC 49
Careful and serious consideration must be given to a full range of possible alternatives at
this stage of the project s development in order to arrive at the Least Environmentally Damaging
Practical Alternative at Concurrence Point 3 Highly valuable natural recreational and cultural
resources exist in the project study area and every effort should be made to avoid unnecessary
impacts Crowders Mountain State Park Daniel Stowe Botanical Garden and Lake Wylie are
found in the study area Lake Wylie is a very popular lake for fishing and boating and is also
used for water supply The internationally renowned Bass Masters Classic fishing tournament
was held at Lake Wylie this year
In addition many streams flow through the study area some of which have the potential
to be inhabited by the federal and state Endangered mussel the Carolina heelsplitter (Lasmigona
decorata) which was recently found in the Catawba River basin in the upstate of South Carolina
Non new location alternatives avoid many of the impacts to the area s valuable resources that
would occur with the new location alternatives and therefore should receive serious
consideration as project alternatives to be carried forward for detailed study New location
alternatives would have much greater direct impacts to aquatic and terrestrial wildlife habitats
and recreational resources and have the potential for much greater secondary and cumulative
impacts to those resources considering the proximity to Charlotte and Lake Wylie and therefore
should be regarded as a last resort As development in the area increases water quality will
likely decrease impacting the water supply quality of recreational experiences on Lake Wylie
and possibly further jeopardize the survival of the Carolina heelsplitter It would be premature to
eliminate alternatives that avoid potential impacts to this species without thorough mussel
surveys in areas likely impacted by a new location alternative directly or indirectly
Computer models were used to predict traffic characteristics in the year 2025 and
compare five scenarios including the No Build non new location Scenarios 2 3 and 4 and the
new location Scenario 5 The No Build or Do Nothing alternative Scenario 1 as described in
the meeting information packet that was received prior to the August 17 2004 meeting included
several minor improvements involving the addition of traffic signals at six currently unsignalized
intersections Scenario 2 improves 185 Scenario 3 improves US 29 74 and Scenario 4
improves both roadways but the analysis of these three scenarios did not include any
improvements to ramps or overpasses in the 185 corridor nor any turn lane improvements on
US 29 74 or any other arterials Scenario 5 locally known as the Garden Parkway was not
analyzed as a toll road although it has been reported that the proposed Garden Parkway is in the
lead for one of the three toll road projects being selected by the North Carolina Turnpike

Gaston East West Connector 3 October 19 2004
Gaston & Mecklenburg Counties
Authority A toll road would likely attract less traffic from 185 and US 29 74 than a non toll
alternative
Scenario 4 Plus which adds Transportation System Management (TSM)
improvements to Scenario 4 such as improvements to ramps turn lanes and adjoining roads was
mentioned but not included in the traffic analysis NCWRC believes that Scenario 4 meets the
purpose and need of the project Additional strategies could be added to Scenario 4 Plus that
may increase its potential to improve the Level of Service (LOS) and safety on the existing
highways which would provide a best case scenario for the non new location alternatives
These include Transportation Demand Management (TDM) strategies (some of which are
currently being implemented) Mass Transit strategies (which are currently being studied) and
possibly additional TSM improvements beyond those listed in the meeting packet A more
accurate and appropriate comparison of preliminary alternatives would include the analysis of
Scenario 4 Plus and Scenario 5 as a toll road however NCDOT is unwilling to provide this
additional analysis requested by NCWRC and other resource agencies
The traffic operations analyses predict that by constructing a new roadway traffic flow
on 185 and US 29 74 can be improved to a level similar to that achieved by widening 185 and
US 29 -74 That being the case it stands to reason that both new location and non new location
alternatives meet the project purpose and need similarly Differences in traffic characteristics
should not be used to select or eliminate alternatives on the basis of which is better at this stage
in the Merger Process but rather to answer the basic question of whether an alternative meets the
project purpose and need None of the scenarios presented for comparison including the new
location alternative fully eliminated failing (LOS F) road segments from the target roadways
however Scenario 4 provided considerable LOS improvement over the no -build scenario
(Scenario 1)
We believe with the additional strategies of Scenario 4 Plus this alternative adequately
meets the purpose and need of the project by improving east west transportation mobility in the
area around the City of Gastonia and between Gastonia and the Charlotte metropolitan area We
believe that Scenario 4 Plus will reduce congestion and improve traffic flow on the sections of I
85 and US 29 74 improve high speed safe regional travel service along the US 29 -74 intrastate
corridor and will generally improve safety and reduce the above average accident rates in the
project study area and will do so to an extent similar to Scenario 5
It is anticipated that additional improvements to I 85 and US 29 -74 corridors will be
necessary under Scenario 5 particularly as a toll road NCDOT indicated that improvements to
the existing east west corridors could be handled through a separate project however it is the
purpose and need of this project to address those deficiencies Making those additional
improvements under a separate project would basically be constructing both a new location
alternative and a non -new location alternative greatly increasing the impacts and the costs when
we feel that improving existing roadways will address the project needs
Portions of the project s purpose and need statement refer to the need to improve
mobility access and connectivity within southern Gaston County and between southern Gaston
County and Mecklenburg County and particularly to establish direct access between the

Gaston East West Connector 4 October 19 2004
Gaston & Mecklenburg Counties
rapidly growing area of southeast Gaston County and west Mecklenburg County The main
population centers in Gaston County generally surround the parallel east west corridor of 185
and US 29 74 Southern Gaston County is generally rural except the rapidly growing area
closest to Lake Wylie
While an additional crossing of the Catawba River would provide a convenient access to
Charlotte for those living close to the lake in southeast Gaston County the negative impacts to
the southern portion of the county Lake Wylie and the water supply in the form of increased
development and urban sprawl and associated habitat fragmentation and decreases in wildlife
habitat water quality and open space out weigh the benefit of convenience The closest existing
crossings of the Catawba River to the rapid growth area in southeast Gaston County are
approximately 10 miles apart US 29 -74 to the north and NC 49 to the south not far from the
Gaston County /South Carolina state line Access to these east west roadways that provide direct
access to Charlotte is currently provided via NC 273 and/or NC 279 As long as the connecting
roadways are maintained to adequately carry the area s traffic load the access connectivity and
mobility issues for the targeted areas of the two counties will be resolved
For the above mentioned reasons NCWRC therefore maintains that non new location
alternative Scenario 4 Plus meets the purpose and need of the subject project Thank you for
the opportunity to provide our agency s position on this matter If you have any questions
regarding these comments please contact me at [phone]
ec Brian Wrenn NCDWQ
Chris Militscher USEPA
Marella Buncick USFWS
Steve Lund USACE

October 19 2004
Ms Knstina Solberg Project Manager
North Carolina Department of Transportation PDEA
1548 Mail Service Center
Raleigh North Carolina 27699 -1548
Dear Ms Solberg
Subject Comments About Information /Questions Requested By Merger Team Document and
Position Briefing Paper for the Elevation to Resolve Nonconcurrence of the Merger
Team at Partial Concurrence Point 2 for TIP Project No U 3321 Gaston County
East West Connector Study Gaston and Mecklenburg Counties North Carolina
As a result of the September 29 2004 elevation meeting the NCDOT requested that the
U S Fish and Wildlife Service (Service) provide a list of questions or requests for further
information regarding Project U -3321 by October 7 2004 We provided our request for
information via a mail on that date (copy enclosed) On October 18 2004 we received the
NCDOT s responses We have reviewed the responses to our requests and the requests and
questions of the other resource agencies and are providing the following comments and an
overall briefing regarding our reasons for nonconcurrence
The information in your document does not provide the level of detail necessary for us to change
our position regarding concurrence with the NCDOT s selection of Detailed Study Alternatives
(DSAs) We continue to support an improve existing scenario as an important component for
evaluating avoiding and mininuzmg the environmental impacts of this project
COMMENTS REGARDING THE NCDOT'S OCTOBER 18, 2004, DOCUMENT
In the subject document there are references to certain alternatives meeting or not meeting
critical elements of the current purpose and need The purpose and need as written has no
critical elements defined and the merger team never discussed any part of the purpose and need
as being critical When determining DSAs there is flexibility in the National Environmental
Policy Act (NEPA) to add DSAs for a variety of reasons public input level of controversy
additional knowledge natural resource concerns and we believe the Service s input and that of

other resource agencies is adequate justification to maintain an improve existing scenario as a
DSA An improve existing scenario is part of a reasonable range of alternatives providing a
valuable basis for comparison and potentially environmentally positive attributes not found in
new location alternatives We believe at least one of the scenarios should be carried forward as a
DSA
Specific concerns include the following
1 Provide survey data for federally listed species in the project study area including both the
new location corridors and the improve existing scenario (FWS)
The natural resources investigation will commence after Detailed Study Alternatives are
selected Therefore it is unknown at this time whether suitable habitat exists If protected
mussels are found within the project study area NCDOT will address any impacts to project
alternatives at that time Natural resource data is not necessary in determining if a proposed
alternative meets the project s Purpose and Need This type of analysis would be done
during the Detailed Study Alternatives (DSAs) stage
As we have stated previously the Service has concerns regarding the possibility of impacts
to federally listed species for the new location alternatives At this early point in the process
elimmatmg all of the improve existing scenarios leaves only no build as a potential
avoidance alternative for impacts to federally listed species if such species are discovered in
the new location corridors
Our request was not intended to provide a purpose and need fitness test Rather it is a way
to help ensure that the process can continue past Concurrence Point 2 without having to stop
and pick up a new alternative for detailed study if there are significant impacts to listed
species associated with the other alternatives Analysis of a broad range of alternatives
including an alternative that avoids impacts may be a very important factor in ensuring
compliance with the Endangered Species Act of 1973 as amended (Act) We remind you
that section 7(d) of the Act prohibits any irreversible or irretrievable commitment of
resources with respect to the agency action which has the effect of foreclosing any reasonable
and prudent alternative measures which would not violate subsection 7(a)(2)
2 Provide the impact data for improve existing scenario 4+ as described on pages 26 -27 of the
July 14 2004 handout (FWS)
Only a cursory level impact analysis was done for the improve existing alternatives These
impacts are not at the same level of detail as the corridor level new location alternative
impacts Therefore it is not constructive to draw a comparison Additionally impacts are
not used in determining whether alternatives meet Purpose and Need or which alternatives
should be carried forward
We believe it is important to gather the data display these impacts and make a true
comparison Again the request for these data is not a fitness test for purpose and need
PA

3 Evaluate the traffic and congestion improvements to 185 and US 29/74 assuming the new
location alternative is a toll road (Service)
It has not been determined that this project will be atoll facility Atoll would be one funding
option Traditionally funding has not been an element of the alternative selection process
Regardless of the funding mechanism for this highway paying a toll to use a road versus
using a public non toll road will influence what and how much traffic uses the new road
versus existing 185 Given that there is a proposal for this road to be a toll road we believe
it could alter the traffic numbers enough to force improvements to I -85 and US 29/74 even
with the new highway In addition this is anything but a traditional situation the Turnpike
Authority is less than 2 years old and toll roads have not been analyzed as possible funding
sources for roads in North Carolina
POSITION BRIEFING PAPER
The following describes our reasons for not concurring with the request to eliminate all non new
location alternatives for the subject project prior to signing Concurrence Point Two
Merger Process History
May 15 2002 — First meeting to discuss Purpose and Need
July 24 2002 — Concurrence reached on Purpose and Need
February 17 2003 — A meeting to review and discuss the preliminary new location corridor
segments and identify those that should be carried forward for functional design as potential
candidates for Detailed Study (January 14 2004 memo)
August 17 2004 First Partial Concurrence meeting to evaluate scenarios involving non new
location alternatives
September 15 2004 — First elevation meeting regarding Partial Concurrence for the subject
project
Listed Species
At this time we believe there is the potential for federally listed species to occur within the
impact area of the new location corridors Our records indicate occurrences of the federally
endangered Schwemnitz s sunflower (Helaanthus schweanatzaa) and the federally threatened bald
eagle (Halaaeetus eucocephalus) within the defined study area in the vicinity of the new location
alternatives We are aware of no occurrences of listed species in the vicinity of the non -new
location alternative scenarios
3

The first obligation of the action agency is to avoid impacts to listed species Currently there is
no site specific biological data for the new location alternatives Without these data it would be
premature to eliminate alternatives that potentially provide the only opportunities to avoid and
minimize project impacts to listed species In addition as described in an a mail to the Merger
Team on August 31 2004 a new population of the federally endangered Carolina heelsplitter
(Lasmigona decorata) mussel was discovered in the Fishing Creek system in the upstate of South
Carolina in the Catawba River basin This is the first find of this species on the west side of the
Catawba in recent history The extent of stream miles occupied by the heelsplitter is unknown at
this time but it could be fairly extensive given the habitat and the lack of survey data None of
the streams in the general new location corridor proposed for this project have had recent mussel
surveys Given this new information the Service strongly recommends stream surveys to
determine the habitat suitability for and the presence of any sensitive aquatic species in the new
location corridor alternatives before the non -new location alternative scenarios are eliminated
Streams, Wetlands, and Wildlife Habitat
New location highway projects permanently alter streams wetlands and wildlife habitat
configuration and function directly through destruction or fragmentation and indirectly and
cumulatively by providing access to previously undeveloped or moderately developed land
With the rapid development occurring in this region we have concerns about putting forward a
set of alternatives that will only serve to facilitate development and sprawl Again the non new
location alternative scenarios present the most likely opportunity to avoid and minimize impacts
We acknowledge that southern Gaston County is growing without the new location Gaston
East West Connector Project However we believe that a new highway will induce a higher rate
of development in the area and further degrade the natural environment
Process Issues
Merger Process The Merger Team has been asked to concur and sign a concurrence form at a
point that is not part of the first Merger Process or the draft revised Merger 01 Process The
information presented thus far clearly outlines the complexity of the project and we agree that
looking at it in pieces may make the information easier to sort through However we do not
believe that another signatory concurrence point is appropriate without a formal revision of the
Merger 01 Process Is the NCDOT proposing to add the Partial Concurrence Point as a step la
to the Merger 01 process?
Purpose and Need In the August 2004 meeting the NCDOT presented the non new location
scenarios and reasons to eliminate each of them The primary reason for eliminating these
scenarios in the NCDOT s opinion is that they do not meet the purpose and need for the project
because they do not sufficiently improve traffic capacity and eliminate congestion However
traffic numbers presented at the same meeting indicate that even with the completion of the new
location facility a portion of existing 185 would still operate at a Level of Service F or failing
in the design year With that information it would appear that none of the alternatives fully meet
the purpose and need
in

When the team wrote the purpose and need statement and agreed to its language there were no
measures or thresholds (such as sufficiently ) in the statement Further there is no language in
the CEQ regulations for NEPA that measures how much an alternative meets the purpose and
need Conversely the regulations do require that the agencies shall Rigorously explore and
objectively evaluate all reasonable alternatives (40 CFR 1502 14(a)) In our opinion the
current treatment of the non new location scenarios is neither rigorous nor objective
In summary we are concerned about potential direct indirect and cumulative impacts to listed
species and fish and wildlife habitat Our comments on this and other projects have consistently
favored non -new location alternatives as a way to avoid and minimize impacts Given that
environmental impacts of the new location alternatives will be substantial we believe that at
least one non new location scenario needs to be evaluated in order to provide an appropriate
comparison of impacts and a reasonable range of alternatives We believe that the non new
location scenario 4+ likely provides less potential for impacts to our trust resources and meets
the stated purpose and need
If you have questions about these comments please contact Ms Marella Buncick of our staff at
828/258 3939 Ext 237 In any future correspondence concerning this project please reference
our Log No 4 -2 02 444
Sincerely
Brian P Cole
Field Supervisor
Enclosure
cc
Mr Steve Lund U S Army Corps of Engineers Asheville Regulatory Field Office 151 Patton
Avenue Room 208 Asheville NC 28801 5006
Mr Chris Militscher U S Environmental Protection Agency Terry Sanford Federal Courthouse
310 New Bern Avenue Room 206 Raleigh NC 27601
Mr Brian Wrenn North Carolina Department of Environment and Natural Resources Division
of Water Quality Wetlands Section 1621 Mail Service Center Raleigh NC 27699 1621
Ms Marla J Chambers Highway Projects Coordinator North Carolina Wildlife Resources
Commission 12275 Swift Road Oakboro NC 28129
5

USFWS Request for Additional Information Regarding Project U -3321
The US Fish and Wildlife Service requests the following
1 Provide the impact data for the improve existing scenario 4+ as described on pages
26 27 of the July 14 2004 handout
2 Provide information about other road projects in the study area (either currently in
planning or those funded) and how those improvements will influence future traffic and
congestion
3 Evaluate Scenario 4+ with the TSM measures described on pages 7 10 of the July 14
2004 handout and any other TDM and/or mass transit measures to achieve a best case
scenario for an improve existing alternative
4 Evaluate the traffic and congestion improvements to 185 and US 29/74 assuming the
new location alternative is a toll road
5 Provide survey data for federally listed species in the project study area Including
both the new location corridors and the improve existing scenarios

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C n r Michael F Easley Governor
William G Ross Secretary
'1 North Carolina Department of Environment and Natural Resources
1 J Alan W Klimek P E Director
�� I w/ Division of Water Quality
0,,4
Pd /' � ) S 1 October 22 200e4� G(lrw
�t ,)' � s
Ix To Knstma Solberg P E Project Manager
Project Development and Environmental Analysis NC DOT
Y%P °4f From Brian Wrenn y {it
o(la Transportation Permitting Unit DWQ
Through John Hennessy Supervisor I></
Transportation Permitting Unit DWQ
it Subject Position Briefing Paper for the Elevation Process to Resolve Non Concurrence at
Partial Concurrence Point #2 for TIP Project U 3321 Gaston County East West
Connector Study Gaston and Mecklenburg Counties
The purpose of this document is to provide the position of the North Carolina Division of Water
Quality (DWQ) on TIP Project No U 3321 East -West Gaston Connector in Gaston County
The project history is as follows 4V /a,/= ,
• May 15 2002 The 404 /NEPA Merger Project Team met to discuss the statement of,""
1 �
° Purpose and Need of the project
o Concurrence was not achieved
o Additional information was requested for the agricultural economy in Gaston ✓� `�'"
1 f c ` f44S1� County and for the need of improved connectivity between Gaston and �-•'�`
Q' Mecklenburg Counties
o NC DOT promised the Merger Team fair and equal analysis for all alternatives
• July 24 2002 The 404 /NEPA Merger Project Team signed Concurrence Point #1 for
Purpose and Need of the project �� S
o The purpose of the proposed action is to improve east west transportation
f4l �(r mobility in the area around the City of Gastonia between Gastonia and the &
Charlotte metropolitan area in general and particularly to establish direct access
' d between the rapidly growing area of southeast Gaston County and west
VA, Mecklenburg County The project purpose is based on the following
■ Improve mobility access and connectivity in southern Gaston County and G
Ioaf
n�o a t�f between southern Gaston County and Mecklenburg County f
■ Reduce congestion and improve traffic flow on the sections of 185 US
a� S `c✓ 29174 and US 321 in the project study area improve high speed safe [� /r/ °L
regional travel service along the US 29 74 intrastate corridor and
generally improve safety and reduce above average accident rates in the E�
project study area I"
I-rr ` t i 1- NJl 54111 ire' Y'Y _L J' I ��N �, dA(
T PJ P)64-
Gf ITS Pv-
NorthCarohna
Transportation Permitting Unit Naturally
1650 Mail Service Center Raleigh North Carolina 27699 1650 CB h C Sid N Ass All
2321 Crabtree Boulevard Suite 250 Raleigh North Carolina 27604
Phone [phone] / FAX [phone] / Internet hhtt //h2o enr state nc us /ncwetlands
An Equal Opportunity /Affirmative Action Employer-50/ Recycled /10 / Post Consumer Paper r/
rs i-sk r tmMicc

• February 17 2004 - A Pre Concurrence Point #2 Meeting was held to discuss new
alignment alternatives
• August 17 2004 - A Partial Concurrence Point #2 Meeting was held to discuss possible
elimination of non new location alternatives Several agencies voiced concerns about
eliminating all non new location alternatives Specifically DWQ felt that a full
assessment of the traffic and environmental analyses was not presented at the meeting
Concurrence was not reached
• September 14 2004 The first meeting in the elevation process took place to reopen
discussions on the non new location alternatives Concurrence was not reached DWQ
was not present at this meeting
• September 29 2004 - The second meeting in the elevation process took place This
meeting included the next level of supervisors for the resource agencies involved in the
Merger Process The end result of this meeting consisted of the resource agencies
submitting a list of information requests to DOT Information requested by the resource
agencies included impacts to streams wetlands historic and archaeological sites revised
traffic analyses based on the new location facility being a toll road potential
combinations of non new location alternatives to meet the purpose and need etc
Position Statement
DWQ feels that it is inappropriate to eliminate the non new location alternatives at this time
Early elimination of the non new location alternatives would not allow for an appropriate
assessment of the full range of alternatives DWQ has two fundamental concerns with early
elimination of the non new location alternatives
1 It would circumvent the avoidance and minimization process
2 It would provide the potential for delays during the 404/401 permitting process
This opinion is expressed in discussions of the following issues Purpose and Need Impacts
Information Threatened and Endangered Species and Partial Concurrence Points These issues
are discussed below
Purpose and Need
The Merger Team agreed to a purpose and need statement that is unduly narrow During the
team s discussions concern about the restrictive nature of the purpose and need was expressed
Concurrence on the statement was finally achieved through a commitment made by NC DOT
that the specific language would not limit the assessment of non new location alternatives nor
would it pre suppose any alternative at a specific location The following statement is taken
from the May 15 2002 Concurrence Point #1 Meeting Minutes

The Statement of Purpose and Need repeatedly uses the term southern Gaston County as that
the area we re talking about south of 185 �
Southern Gaston County is expected to receive the most growth based on the
Comprehensive Land Use Plan but we are referring to east west transportation needs
and not just southern Gaston County It was not the intent to presuppose any
alternatives at a specific location such as ruling out alternatives for improved
connectivity north of 185 the document will be reviewed an this light and revised
accordingly
In Merger Process meetings and Elevation Process meetings at which DWQ has been present
this commitment has not been fulfilled DWQ is of the opinion that an overly restrictive
interpretation is being used to judge each alternative s ability to meet the purpose and need
particularly in light of previous commitments made by NC DOT Using this narrow
interpretation NC DOT asserts that the non new location alternatives do not sufficiently meet
the purpose and need However this assertion is based on cursory analyses using a combination
of the non new location alternatives (known as the Multi Modal alternative) and is done so
without the benefit of environmental analyses to support this position By not fully exploring
Multi Modal combinations the spectrum of non new location alternatives is arbitrarily limited
thus making these alternatives appear inconsistent with the purpose and need DWQ feels that
this places qualifiers for meeting purpose and need that are not defined within the purpose and
need statement nor within the Merger Process Although DWQ agrees that the new location
alternatives better satisfy the purpose and need as written DWQ feels that this course of action
would circumvent the required avoidance and minimization analysis and potentially result in
difficulties during permitting
Impacts Information
The primary responsibility of DWQ is to protect the streams wetlands and other water bodies of
the State of North Carolina DWQ must consider a project s purpose and need and the
subsequent project alternatives in relation to the avoidance and minimization of impacts In
accordance with the Merger 01 agreement a preliminary assessment of natural and human
environments using landscape scale assessment practices is required prior to agreement on
Concurrence Point No 2 #-2—To date the Merger Team has not been provided with sufficient
data as promised (July 14 2004 Information Package) regarding impacts to streams wetlands
historic and archaeological sites parks and recreational areas residences businesses community
facilities etc Without estimates of these impacts to consider in conjunction with traffic analysis
data DWQ cannot make an informed decision regarding the elimination of the non new location
alternatives This has the potential to create a possible situation where the NEPA process may
conflict with the 404/401 permitting process a situation whie#that the Merger Process was
created to avoid

Threatened and Endangered Species
Issuance of the 401 Water Quality Certification in accordance with 15A NCAC 2H 0500
requires that DWQ ensure that the existing uses of waters of the State are protected
Consideration of wildlife resources is specifically required in the protection of existing uses US
Fish and Wildlife Service and NC Wildlife Resources Conumssion feel that the potential for the
federally endangered Carolina Heelsphtter (Lasmigona decorata) to be present in the NC
sections of the Catawba River Basin provides sufficient incentive to retain a non new location
alternative until a full biological assessment can be made of the study area Biological
assessments are underway but until final results of the studies are submitted it would be unwise
to eliminate the avoidance alternative available through the non new location alternatives In
addition retaining a non new location alternative would be in keeping with Section 7 of the
Endangered Species Act which requires an avoidance alternative when threatened or endangered
species are present within a project study area If the non new location alternatives are
eliminated prior to the biological assessment and the Carolina Heelsplitter is found within the
project study area and an avoidance strategy cannot be developed to properly mitigate the
impacts to this population then the only avoidance alternative would be a No Build
alternative This would severely delay the construction of any facility to meet the purpose and
need of the project
Partial Concurrence Points
DWQ does not agree with the proposal to achieve signed partial concurrence for Concurrence
Point #2 DWQ feels that this would short- circuit the Merger Process by elimnating alternatives
without proper evaluation and comparison to the full scope of the alternatives Although DWQ
agrees that this is an extremely complex project it feels that signed concurrence is not
appropriate for partial concurrence points By eliminating all non new location alternatives
through signed concurrence before the new location alternatives can be evaluated the Merger
Team is locked in to a new location regardless of the impacts resulting from the new location
alternative This does not meet the spirit of the Merger Process and can lead to conflicts with the
404/401 permitting process DWQ is willing to break concurrence points up into multiple
meetings to accommodate complexity but providing written concurrence on partial concurrence
points unnecessarily lirmts the alternatives and the avoidance and minimization strategies of the
Merger Team

PEFo'n E W Connector TIP U 3321
Subject Gaston E -W Connector, TIP U -3321
From Marella_Buncick @fws gov
Date Mon, 19 Dec 2005 16 21 57 -0500
To dweaver @dot state nc us, militscher chns @epamail epa gov, chambersmj@vnet net,
steven w lund @saw02 usace army mil, polly lespmasse @ncmail net sarah mcbnde @ncmail net
CC Brian Cole @fws gov, Gary_Jordan@fws gov
On December 8 2005, the USFWS abstained from signing Concurrence Point 2 for the Gaston East -West
Connector Project, Gaston and Mecklenburg Counties, NC, for the following reasons
1 According to discussions at the last Merger meeting for this project U -3321 is being "handed off' to
the NC Turnpike Authority Since this project is now an NC Turnpike Authority study project, we
believe it is no longer in the Merger Process Merger is a process for which decisions are made in a
building block fashion, each subsequent step dependent on the previous step Therefore, we believe it is
inappropriate for our Agency to sign off on alternatives when we will not be involved in selecting a
LEDPA (CP 3) or in Avoidance and Minimization considerations (CP4) We have provided input that a
deciding official can use to help determine an appropriate range of alternatives
2 Our understanding is that the study of potential turnpike projects will include an analysis of economic
considerations to determine a project's feasibility Thus far, economic considerations beyond the cost to
build a project have rarely been discussed relative to the feasibility of a project If econonuc viability is to
be considered a criterion used to determine feasibility for this particular protect, we believe that the
current Purpose and Need should be re- visited to include economic considerations
If, in the future the NC Turnpike Authority adopts the Merger Process and current merger team members
are tasked by NCDOT to participate in another dual, merger process we will revisit our abstention from
this concurrence point decision
Thank you
marella buncick
USFWS
160 Zillicoa St
Asheville, NC 28801
828 -258 -3939 ext 237
1 of 1 12/19/2005 4 40 PU

S
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F EASLEY LYNDO TIPPETT
GOVERNOR September 15 2005 SECRETARY
STATE PROJECT 34922 1 1 (U 3321)
F A PROJECT STP 1213 (6)
COUNTY Gaston Mecklenburg
DESCRIPTION Gaston County East West Connector from 185 West of Gastonia to NC
160 in Mecklenburg County
MEMORANDUM TO Mr Gregory J Thorpe PhD Director
Project Development and Environmental Analysis Branch
, 0.�
FROM John L Pilipchuk LG PE Western Regional Geotechnical Manager
Geotechmcal Engineering Unit
eer
& ` o'' "` G�"vv,—
Gregory A Smith LG PE GeoEnvironmental Supervisor
Geotechmcal Engineering Unit
SUBJECT
Allen Steam Plant Fly Ash Basins
The GeoEnvironmental Section performed a non intrusive investigation of two fly ash basins immediately
south of Duke Power s Allen Steam Plant property near Belmont Our findings are to partially assist in
determining the suitability of Segments K1B K1C KID for additional study The northern basin is
inactive and vegetated while the southern basin currently receives approximately 12 000 gallons of fly
ash slurry per day The above segment alignments cross a portion of the northern basin
Fly ash was placed in the basin via water slurry the solid material settled out and the water was
discharged from the basin into the Catawba River Typical of such operations Duke Power practiced no
engineering control over consolidation of the ash The resulting material has low strength and is
generally unsuitable as a structural foundation without modifications Roadway construction across the
basin must therefore include considerable in situ modifications to the ash s physical properties necessary
for improved constructability or its excavation and replacement with suitable embankment material
MAILING ADDRESS
NC DEPARTMENT OF TRANSPORTATION
GEOTECHNICAL ENGINEERING UNIT
GEOENVIRONMENTAL SECTION
1589 MAIL SERVICE CENTER
RALEIGH NC 27699 1589
TELEPHONE [phone]
FAX [phone]
WEBSITE WWW DOH DOT STATE NC US
LOCATION
CENTURY CENTER COMPLEX
BUILDING B
1020 BIRCH RIDGE DRIVE
RALEIGH NC 27610

Mr Gregory J Thorpe PhD
September 15 2005
Page 2
Fly ash usually exhibits physical properties suitable for embankment material when it has been properly
dried and compacted Environmental impacts regarding contaminant concentrations within fly ash
generally are not a mayor concern as with bottom ash but appropriate chemical analyses must be
performed prior to acceptance of the material
A geotechnical/geoenvironmental field investigation can be scheduled if more detailed information is
needed to make a final decision regarding the status of the segments in question Please contact Greg
Smith GeoEnvironmental Supervisor at [phone] for additional geoenvironmental information or
John Pilipchuk Western Regional Geotechnical Manager at [phone] for additional geotechnical
information

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COMPARISONS SECTION J
PROJECT NO
TIP NO
COUNTY
DESCRIPTION
DATE
PREPARED BY
82812501 FHWA STP 1213(6)
U 3321
GASTON AND MECKLENBURG COUNTIES
GASTON COUNTY EAST WEST CONNECTOR STUDY
8/19/2005
PBS&
R to dbyM g T m D taI dSt dy
BOTANICAL GARDEN AREA Elm t dbyM g T m( .13 t 1 d St dy
J SEGMENTS

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Section 404/NEPA Merger Team Meeting Agreement
Concurrence Point No 2 — Detailed Study Alternatives
Protect No /TIP No /Name/Description
Federal Project Number STP 1213(6) State Project Number 8 2812501
TIP Number U 3321
Description Gaston East West Connector Study in Gaston and Mecklenburg Counties
Alternatives Carried Forward for Detailed Study
Non New Location Alternatives None to be carried forward for detailed study in accordance with
NEPA/404 Merger Process Review Board Decision (see separate signed partial Concurrence Point #2
forms for non new location alternatives from July 2005)
New Location Alternatives
Alt #
H Segments
J Segments
K Segments
4
1-12A H3
J4a J4b J2c J2d J5a J5b
K2A KX I K313 K3C
5
1-12A H3
J4a J2b J2c J2d JX4 JIe J I f
KIA KIB KIC K4A
6
H2A H3
J4a J2b J2c J2d JX4 JIe J I f
KIA KIB KIC KID
9
H2A H3
J4a J2b J2c J2d JX4 J I e J l f
KIA K3A K313 K3C
22
H2A 1-1213 H2C
J3 J2c J2d JSa J5b
K2A KX I K313 K3C
23
H2A 1-1213 H2C
J3 J2c J2d JX4 JIe J If
KIA KIB KIC K4A
24
H2A 1-1213 H2C
J3 J2c J2d JX4 JIe JIf
KIA KIB KIC KID
27
H2A 1-1213 H2C
J3 J2c Rd JX4 JIe J If
KIA K3A K313 K3C
58
MIA HIB HIC
Jla JXI J2d JSa J5b
K2A KXI K313 K3C
64
MIA HIB HIC
Jla Jlb Jlc Jld Jle Jlf
KIA KIB KIC K4A
65
MIA HIB HIC
Jla Jlb Jlc Jld Jle Jlf
KIA KIB KIC KID
68
MIA HIB HIC
Pa J1b Jlc Jld Jle Jlf
KIA K3A K313 K3C
76
MIA HX2
J2a J2b J2c J2d JSa J5b
K2A KX 1 K313 K3C
77
MIA HX2
J2a J2b J2c J2d JX4 JIe J I f
KIA KIB KIC K4A
78
MIA HX2
J2a J2b J2c J2d JX4 JIe Jlf
KIA KIB KIC KID
81
MIA HX2
J2a J2b J2c J2d JX4 J I e J l f
KIA K3A K313 K3C
The Project Team concurred on this date of 9/20/05 with the Detailed Study Alternatives listed
above to be carried forward in the Draft EIS for the proposed project
USACE
USEPA
NCDOT
USFWS
NCDWQ NCWRC
NCDCR
FHWA
GUMPO MUMPO

FINAL
MINUTES
NEPA1404 MERGER TEAM MEETING — CONCURRENCE POINT 2
GASTON COUNTY EAST WEST CONNECTOR STUDY
TIP Protect U 3321
Gaston and Mecklenburg Counties, North Carolina
Date September 20 2005
Time 1 00 PM
Place Board Room — Transportation Building
I S Wilmington Street
Raleigh NC
Subject Concurrence Point #2 Meeting for TIP Project U 3321
Attendees Ron Lucas —
Aldie Whitmore
Dan Grissom —
Michael Holder —
Derrick Weaver —
Shannon Lasater —
Teresa Hart
Tony Houser —
Lee Moore —
Brian Hanks —
Chris Manley —
Ed Lewis
Mary Pope Furr
Michael Wray
Shannon Ransom
Mark Staley
Robert Memory
Sarah McBride
Chris Militscher
Brian Wrenn
Polly Lespinasse
John Hennessy
Marla Chambers
Steve Lund
Hank Graham
Robert Cook
Gail Grimes
Anne Redmond —
Jill Gurak —
David Bass —
Lou Raymond
Lauren Wolfe —
Mark Stephens
Glenda Gibson —
Mike Pekarek —
FHWA
NCDOT Division 10
NCDOT Division 12
NCDOT Division 12
NCDOT PDEA
NCDOT PDEA
NCDOT PDEA
NCDOT Roadway Design
NCDOT Roadway Design
NCDOT Structure Design
NCDOT Natural Environment Unit
NCDOT Human Environment Unit
NCDOT Human Environment Unit
NCDOT Transportation Planning
NCDOT Transportation Planning
NCDOT Roadside Environmental
NCDOT Utilities Coordination Unit
SHPO
EPA
NCDWQ
NCDWQ
NCDWQ
WRC
USACE
Gaston Urban Area MPO
Mecklenburg Union MPO
NCTA
HNTB
PBS &J
PBS &J
PBS &J
PBS &J
PBS &J
Gibson Engineers
Gibson Engineers

September 20 2005 TIP Protect U 3321
NEPA1404 Merger Team Meeting Gaston County East West Connector Study
Attendees via Videoconference
Marella Buncick USFWS
Introduction
Mr Weaver began the meeting with the introduction of everyone in attendance and participating via
videoconference The purpose of this meeting was to decide which of the 90 preliminary new location
alternatives should be carried forward for detailed study The packet distributed to the Merger Team prior
to the meeting included the initial recommendations of the FHWA NCDOT Gaston MPO and
Mecklenburg Union MPO Those recommendations narrowed down the 90 preliminary alternatives to
16 Detailed Study Alternatives
Ms Gurak noted that the elevation process for the non new location alternatives was completed in July
2005 in accordance with the NEPA/404 Merger Memorandum of Agreement (MOA) The decision by
the elevation process Review Board (consisting of executive management representatives from FHWA
NCDOT USACE and NC DENR) was to eliminate non new location alternatives from detailed study as
part of Concurrence Point #2 (signed concurrence forms were included in the packet in Appendix A)
Meeting Displays
The following items were displayed during the meeting to facilitate decision making
• A map (included in the packet as Figure 2) showing the critical nodes and alternatives
A map with the functional design segments overlaid with environmental features (included in the
packet as Appendix C)
A map provided by the Gaston Urban Area MPO showing planned and platted development in
the area that had not yet been included in the County s downloadable GIS database Also shown
on the map were the functional design alternatives and the original Gaston MPO preferred
alignment
Background Issues
Some background issues were brought up at the start of this meeting by Merger Team members and are
documented below
1 Ms Chambers expressed concern about decisions made for this project at the elevation Review Board
meetings held prior to this meeting She stated she had received no minutes to these meetings and knew
nothing about why or how the Review Board decisions were made She stated she would like a Review
Board meeting summary to aid in making decisions about this project Several other Merger Team
members stated they also had not received any information about the Review Board meetings or the
Board s decision Mr Militscher noted that the Merger Process MOA requires the Merger Team to be
immediately notified of Review Board decisions Both Mr Militscher and Mr Hennessy stated that
something needed to be done about the lack of communication
Some Merger Team members had copies of a summary prepared by PBS &J for the Review Board There
was some misunderstanding that this document was meeting minutes to the final Review Board meeting
where the Board made its decision The Review Board meeting at which the decision was made was not
attended by staff and meeting minutes are not available The summary document was provided to the
Review Board at its request prior to their final meeting At their request the attendees from the resource
14

September 20 2005
NEPA1404 Merger Team Meeting
TIP Project U 3321
Gaston County East West Connector Study
agencies (EPA USFWS USACE NC DWQ SHPO NC WRC) will be emailed a copy of this summary
document
NCDOT apologized about the miscommunication noting this project was the first to be elevated to the
Review Board level Mr Weaver stated a copy of the Review Board summary document would be sent
to them by PBS &J
Mr Militscher stated that since US EPA was not included in the elevation process he does not feel his
agency is bound by this decision He indicated he will be commenting on the Draft EIS with this in mind
2 Ms Buncick brought up the fact that since this project is now a NC Turnpike Authority (NCTA)
project she wanted to know how this would affect the merger process and the decisions made by the
Merger Team She and Mr Militscher wanted to know if decisions (including past decisions) would be
made based on different criteria now that this project is a NCTA project Ms Buncick expressed concern
that the Detailed Study Alternatives decided on at this meeting may not be carried forward due to the
economic component of a toll road project Mr Militscher wanted to know why this project was still
going through the merger process if it was being turned over to NCTA
The North Carolina Turnpike Authority (NCTA) explained that toll projects do not pay for themselves
initially and that they are all candidate projects at this time subject to traffic revenue studies to
determine their economic feasibility If the project is deternuned to be infeasible as a toll project it will
then be turned back over to the NCDOT to be planned and constructed as a free (non toll) facility Mr
Weaver stated that a NEPA document must be done whether this is a toll project or not The NCTA and
NCDOT will carry forward the alternatives recommended for Detailed Study decided on at today s
meeting through the DEIS and the project will continue to follow an interagency process NCTA stated
that an agency coordination process will be implemented for NCTA projects but that the process has not
been finalized NCTA currently is working with the executive management of other resource agencies on
a process
Review of Decision Making Methodology
Ms Gurak explained the decision making methodology for identifying alternatives for detailed study
She referred to the large maps showing the segments of the alternatives as well as the environmental
features maps displayed The decision making methodology requires eight key decisions between pairs
of nodes (options) along the functional designs segments There are seven (7) nodes 185 (85E and
85W) US 321 (321N and 3215) a point west of the South Fork Catawba River (CTR N and CTR S) and
at 1485 (485)
The basic premise of this comparison/decision making methodology is that if possible at least one
connection between critical pairs of nodes should be maintained and redundant connections should be
eliminated There are enough planning and design data available to be able to narrow choices but still
keep all or most basic options open (in case a fatal flaw is later found along a corridor segment)
The eight key decisions under this methodology are listed below
Key Decision # Node to Node Decision Needed
85E to 321N Choose from two options
3

September 20 2005
TIP Project U 3321
NEPA1404 Merger Team Meeting
Gaston County East West Connector Study
2
321N to CTR N
Choose from two options
3
321N to CTR S
Choose from two options
4
321S to CTR N
Choose from two options
5
321S to CTR S
Choose from two options
6
CTR N to 485
Choose from four options
7
CTR S to 485
Choose from three northern options
8
CTR S to 485
Choose from two southern options
Mr Hennessy asked if the impacts were based on GIS data Ms Gurak stated that impacts were based on
GIS data and functional roadway designs and that this is the same level of data that is usually available at
this stage in the planning process
Discussion of Key Decisions
The Merger Team discussed the eight key decisions to identify the alternatives to carry forward as
Detailed Study Alternatives In some cases decision points were combined or added onto The decisions
are listed below
AREA WEST OF US 321 Decision Point 1(Nodes 85E and W to Nodes US 321N and S)
The Merger Team compared all the H segment combinations and for the 85E 321N routes decided to
keep both the western option (H2A +H3B +H2C +J3) and the eastern option (H2A +H3 +J4a) as Detailed
Study Alternatives for the following reasons
The eastern option has higher human environment impacts but the western has higher natural
environment impacts Keeping both options allows the Merger Team to make a decision when
more detailed information about impacts is available
Both options have potential environmental justice (EJ) issues Keeping both options available
allows for more design options later to avoid the EJ areas
The Merger Team also decided to eliminate the segment combination from 85E to 321 S
(H2A +H2B +HX1 +H1C +Jla) This option was not originally included as part of Decision Point 1
because it is the only option to get from 85E to 3215 The Merger Team elirmnated it because this
alternative has substantially more stream impacts than other H segment combinations reaching from 185
to US 321 (about 4 080 linear feet more than the next highest impacts) and would be substantially more
expensive (about $41 million more in construction costs than the next highest costs)
Summary of Decision Point I (Nodes 85E and W to Nodes US 321 N and S)
The Merger Team decided to retain the following segment
combinations for detailed study
• H2A H3 J4a
• H2A H2B 1-12C J3
• H1A H1B H1C Jla
• H1A HX2 J2a

September 20 2005 TIP Project U 3321
NEPA1404 Merger Team Meeting Gaston County East West Connector Study
CENTRAL AREA Decision Points 2 (Nodes 321N to CTR N), 3 (Nodes 321N to CTR S), 4 (Nodes 321S
to CTR N), and 5 (Nodes 321S to CTR S)
The Merger Team decided to keep the options recommended in the packet for Decision Points 2 through
5 as combinations to include in the Detailed Study Alternatives which are
• Decision Point 2 —
northern alternative (J4b J2c J2d J5a J5b K2A)
• Decision Point 3 —
northern alternative (J4b J2c J2d JX4 Jle Jlf K1A)
• Decision Point 4 —
northern alternative (JX1 J2d J5a J5b K2A)
• Decision Point 5 —
southern alternative (JIb Jlc Jld Jle J I f K1A)
For Decision Points 2 and 3 (which begin at Node 321N) the segment combinations that include JX7
(JX2 for alignments using J2a) have a functional design that is not desirable to NCDOT The design in
this area involves a half clover interchange at US 321 as a result of a railroad crossing Segment JX7
would cause back to back horizontal curves in this interchange area and super elevations of the ramps
and the mainline would be in opposite directions which make it difficult to tie the ramps into the
mainline This combination of design issues makes the design potentially unsafe These design problems
were not apparent until the functional designs had been completed
r � ;�2
8X1--
J J/ti
s \ J3a -''Ky` b
J�
Mr Hennessy asked if the functional design for segment JX7 meets AASHTO standards Mr Houser
stated that although it does it is not a preferable design Mr Houser stated the AASHTO standards are
guidelines and that meeting the minimum AASHTO requirements may not result in good designs in
individual cases such as segment JX7 Mr Houser noted that at this stage in the planning process he
would like to elirrunate poorer designs where possible Mr Weaver stated that it was important to narrow
down the number of alternatives carried forward for detailed study in order for this project to move
forward quickly and be easier to present to the public Mr Weaver also noted that the impacts were
similar for the segment combination options between 321N CTRN and 321N CTRS The Merger Team
agreed to eliminate those alternatives using segment JX7 As a consequence of eliminating segment JX7
segments JX2 and JX5 would consequently be eliminated since they follow the same alignment as JX7
(Note that segment JX5 is an outdated segment not used by any of the alternatives )
The group reviewed the impacts for the segment combinations included in Decision Point 4 (3215
CTRN) and Decision Point 5 (321S CTRS) and agreed with the original recommendations to retain
segment combinations JX1 J2d J5a J5b K2A and Jlb Jlc Jld Jle Jlf K1A for detailed study

September 20 2005
NEPA1404 Merger Team Meeting
TIP Project U 3321
Gaston County East West Connector Study
For Decision Point 4 JX1 J2d J5a J5b K2A was retained for detailed study and Jlb Jlc JX6 J5b K2A
was eliminated because JX1 J2d J5a J5b K2A was less expensive ($194 million vs $212 million) and
more direct Other impacts were very similar
For Decision Point 5 Jlb Jlc Jld Jle Jlf K1A was retained for detailed study and JX1 J2d JX4 Jle Jlf
K1A was eliminated because Jlb Jlc Jld Jle Jlf K1A has about 855 less linear feet of stream impact
and less floodplain impact Other impacts and the costs were similar Also retaining segment
combination Jlb Jlc Jld Jle Jlf K I A provided an alternate route
Summary of Decision Points 2, 3, 4, and 5 (Between Nodes 321N and S
and Nodes CTR N and S)
The Merger Team decided to retain the following segment
combinations for detailed study
• J4b J2c J2d J5a J5b K2A
• J4b J2c J2d JX4 Jle Jlf K1A
• JX1 J2d J5a J5b K2A
• Jlb Jlc Jld Jle Jlf K1A
Decision Point 6 (Node CTR N to Node 1485)
The Merger Team decided to retain segment combination KX 1 K3B K3C for detailed study and
eliminate segment combinations K2B K2C K2D and K2B KX4 K3C and KX1 KX3 K2D
Segment combinations using K2D were eliminated for the following reasons
Designs that use segment K3C are better than designs that use segment K2D Segment K2D has
a less desirable design due to a curve immediately east of the Catawba River bridge and just west
of 1485 This curve cannot be flattened due to space constraints related to tying into I-485
Segment combinations using K2D had about 2 500 to 3 100 more linear feet of stream impact
than the segment combinations that use K3C
Segment combination K2B KX4 K3C was eliminated from further consideration in comparison to
segment combination KX1 K3B K3C because it had more residential relocations (155 vs 107) with most
of these additional relocations in one subdivision on the west side of Southpomt Road
Summary of Decision Point 6 (Between Node CTR N and Node 1485)
The Merger Team decided to retain the following segment
combination for detailed study
• KX1 K3B K3C
in

September 20 2005
NEPA1404 Merger Team Meeting
TIP Project U 3321
Gaston County East West Connector Study
Decision Point 7 (Node CTR S to Node 1 485 (northern options])
The Merger Team decided to retain segment combination K3A K313 K3C for detailed study and
eliminate segment combinations K3A KX3 K213 and K1B KX2 K21) for the following reasons
• Designs that use segment K3C are better than designs that use segment K21) Segment K21) has
a less desirable design due to a curve immediately east of the Catawba River bridge and just west
of 1485 This curve cannot be flattened due to space constraints related to tying into 1485
• K3A K313 K3C has 2 100 to 2 200 fewer linear feet of stream impacts
During these last discussions (Decision Points 7 and 8) the videoconference connection with the USFWS
was lost
Although K3A K313 K3C has a better design at 1485 (does not use segment K2D) it does impact a
potential historic site located at the NC 279 interchange area (Segment K3A) The impact to the potential
historic site is unavoidable with this option If this option needs to be eliminated later due to the potential
historic site other alternatives to get from Node CTR S to Node I-485 will be available through the
segment combinations retained under Decision Point 8 The potential historic site will be evaluated in a
Phase II historic architectural survey that will be prepared for the Detailed Study Alternatives in the Draft
EIS
Mr Hennessy stated that most of the options for Decision Points 6 and 7 were very close to one another
location wise and likely would have similar impacts /issues associated with water quality Therefore it is
a good idea to eliminate any alternatives that are not preferable based on other issues (less desirable
design relocations etc )
Summary of Decision Point 7 (Between Node CTR S and Node 1485)
The Merger Team decided to retain the following segment
combination for detailed study
• K3A K313 K3C
Decision Point 8 (Node CTR S to Node 1 485 [southern options))
The Merger Team decided to retain both the northern option (segment combination K1B K1C KID) and
the southern option (segment combination K1B K1C K4A) for detailed study Segment combination
K1B K1C KID has a straighter alignment and fewer stream impacts but it has more residential
relocations (141 vs 91) and is dependent on the ability to construct a roadway over or through the Allen
Steam Station s retired (dormant) fly ash basin Mr Raymond stated that based on the geotechmcal
report prepared by NCDOT s Geotechmcal Unit (attached) and discussions with the Steam Station plant
manager constructing a roadway through the fly ash basin may have constructability issues and may
interfere with the Steam Station operations The plant manager Mr Immel stated in a telephone
conversation that a roadway through the fly ash basin would be a fatal flaw to the operation of the Steam
Station Mr Militscher noted that a fly ash basin is not ajurisdictional resource and the Merger Team
should not be avoiding or minimizing impacts to it at this point
Summary of Decision Point 8 (Between Node CTR S and Node 1485)
The Merger Team decided to retain the following segments
combination for detailed study
• KIB KIC KID
• K1B K1C K4A

September 20 2005
NEPA 1404 Merger Team Meeting
TIP Project U 3321
Gaston County East West Connector Study
Conclusion
At the end of the meeting with the elimination of segment combinations described above the Merger
Team had narrowed down the 90 preliminary new location alternatives to 16 recommended Detailed
Study Alternatives The Merger Team did not sign a Concurrence Point 2 form but agreed to sign it once
the form was updated to list the 16 Detailed Study Alternatives that the team agreed upon The form has
been updated with the recommended Detailed Study Alternatives and is attached for reference
NCDOT will call the USFWS for comment/concurrence on the last few decisions made at the meeting
The 16 Detailed Study Alternatives recommended by the Merger Team to be carried forward for detailed
study are
Alt #
H Segments
J Segments
K Segments
4
H2A H3
J4a J4b J2c J2d J5a J5b
K2A KX1 K3B K3C
5
H2A H3
J4a J2b J2c J2d JX4 Jle JIf
K1A K1B K1C K4A
6
H2A H3
J4a J2b J2c J2d JX4 Ae Af
KI A K1B K1C KID
9
H2A H3
J4a J2b J2c J2d JX4 Ae Af
K1 K3A K3B K3C
22
H2A H2B H2C
J3 J2c J2d J5a J5b
K2A KX1 K3B K3C
23
H2A H2B H2C
J3 J2c J2d JX4 Jle Af
K1A K1B KIC K4A
24
H2A H2B H2C
J3 J2c J2d JX4 Jle Af
K1A K1B K1C KID
27
H2A H2B H2C
J3 J2c J2d JX4 Jle Af
K1 K3A K3B K3C
58
H1A H1B H1C
A JX1 J2d J5a J5b
K2A KX1 K3B K3C
64
H1A H1B HIC
J1a Jib Jic Ad Ae Af
KIA K1B K1C K4A
65
H1A H1B H1C
Jia Jib Ac Jid Ae Af
K1A K1B K1C KID
68
H1A HIB H1C
Jia Ab Ac Ad Ae Af
K1A K3A K3B K3C
76
H1A HX2
J2a J2b J2c J2d J5a J5b
K2A KX1 K3B K3C
77
H1A HX2
J2a J2b J2c J2d JX4 Ae Af
KIA K1B K1C K4A
78
H1A HX2
J2a J2b J2c J2d JX4 Ae Af
K1A K1B K1C KID
81
H1A HX2
J2a J2b J2c J2d JX4 Ae Af
K1 K3A K3B K3C
Attachments
1 Table showing the total estimated impacts for each of the 16 recommended Detailed Study
Alternatives
2 Excel spreadsheets showing the segment combinations retained/eliminated for each area of the
project (H segments J segments and K segments) and their estimated impacts
3 Figure 3 — showing the recommended Detailed Study Alternatives
CC Meeting Attendees
Minutes Prepared by PBS &J

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