20120285_Other Agency Comments_20110222

J�\tE� TFS
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
�� yw REGION 4
o�`�� Q ATLANTA FEDERAL CENTER
Z3 r�f/ r
�iTq< p pSEG�\o ATLANTA, GEORGIA 0303-8960
�'ebruary 22, 201 1
Ms. Jennifer Harris, P.E.
North Carolina Turnpike Authority
North Carolina Department of Transportation
5400 Glenwood Avenue, Suite 400
Raleigh, Nortll Carolina 27612
SUBJECT: Gaston East-West Connector, I-85 to I-485 and NC 160, Gaston and
Mecl<lenburg Counties, Final Environmental Impact Statement (FEIS);
TIP No.: U-3321; FHW-E40827-NC; CEQ No.: 20110011
Dear Ms. Harris:
The U.S. Environnlental Protection Agency (EPA) Region 4 NEPA Program
Office has reviewed the subject document for in accordance with Section 309 of tlle
Clean Air Act and Section 102(C) of the National Environmental Policy Act (1�1EPA).
The Narth Carolina Turnpil<e Authority (NCTA) and the Federal highway Administration
(FHWA) are proposin� to construct an approximate 22-mile, multi-lane, median-divided
toll facility from I-85 �vest of Gastonia to I-485/NC 160 in Gaston a��d Mecl<lenburg
Counties, North Carolina.
EPA provided detailed comments on the Draft Environmental Impact Statement
(DEIS) on July 17, 2009. EPA rated the twelve (12) detailed st�idy alternatives (DSAs)
as "EO-2", En��ironnlental Objections with additional information being req��ested in the
final document. Subsequent to this letter, EPA staff has continued with �vorl< with the
transportation a�encies and other NEPA/Section 404 Merger process agencies on
environmental issues, including air quality and transportation conforn�ity, avoidance and
�ninin�ization meas�ires to jurisdictional waters of the U.S., and conceptua] �l�itigation
plans.
NCTA and FHWA provided responses to EPA's DEIS coinment letter in Volume
2 of the FEIS, pages B1-39 to B1-63. NCTA and FHWA provided a Conceptual
Mitigatio�� Plan by reference to a project webpage and a general sunlmary of the plan in
the FEIS. EPA's detailed teclulical comments on the FEIS and the referenced reports are
incliided in Aitachment `A' (See attached).
EPA recognizes that additional avoidance and miniinization measures are
currently being proposed by the transportation agencies. However, the initial preliminary
designs were atypical for most new location, multi-lane, median-divided hi;hway
projects in Nortl� Carolina that resulted in much greater DEIS impacts to jurisdictional
waters of tl�e United States than other similarly scoped projects. Furthern�ore, EPA
understands that thc transportation agencies are now proposing to phase the project and
Intemet Address (URL) • http://www.epa.gov
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change the typical section. The section in western Gaston County from I-85 to US 321 or
approximately half the project length will be initially constructed as a two-lane facility.
Although many oi the DEIS comments were addressed, EPA has remaining
environmental concerns regarding direct impacts to jurisdictional streams and wetlands
includi»g 303(d) listed impaired waters, indirect and cumulative impacts to jurisdictional
resources, potential Environn�ental Justice impacts to minority and low-income
populations, long-teim impacts from Mobile Source Air Toxics to nearby neighborhoods
and communities, impacts to Voluntary Agricultural Districts, and impacts to terrestrial
forests and wildlife habitat. EPA also maintains its concerns regarding the ability of the
transpol-tation agencies to provide reasonable and functionally equivalent mitigation for
water resources in�pacts within the project study area.
To address these remaining issues, EPA recon�mends that the transportation
agencies provide additional information to the review agencies and the pLiblic prior to the
issuance of a Record of Decision (ROD). The supplemental inforniation should furtller
address the key issues in the attachment, incll�ding compensatory mitigation to direct
impacts to jw�isdictional streams and wetlands including 303(d) listed in�paired waters,
potential environmental enhancements to address indirect and cumLilative ii�lpacts to
jurisdictional resources, potential Environmental Justice impacts to minority and low-
income popLilations and provide for a thorough analysis, and long-tern� impacts fi-om
Mobile Source Air Toxics to nearby neighborhoods and commuuities and a site-specific
quantitative analysis. The supplemental information might also inclLide specific project
commitir�ents co»ceining impacts to Voluntary Agricultural Districts and opportunities
for safe wildlife passage to minimize fragmentation effects from the new multi-lane
facility.
Sl�ould yo�� have any questions concerning these comine»ts or recon�mendations,
please contact Mr. Christopher Militscher of my staff at 919-856-4206.
Si rgly, �
. ��,�;�_.
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1
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; ,� i > ; 1;�---__�
Heinz J. Mueller, Chief
NEPA Program Office
Cc: G. Conti, NCDOT
J. Sullivan, FHWA
S. Mcle��don, USACE
C. Sullins, NCDWC

Attachment A
FEIS Detailed Review Comments
Gaston East-West Connector Toll Facility
Mecklenburg and Gaston Counties
U-3321
General Comments to the FEIS
Cl�apter l of the FEIS includes the Draft EIS Summary and Upoltes, from pages
1-1 to 1-55. Based upon EPA's review, there is no mention of the petition signed by
more than 7,000 citizens opposed to the project in this s�immary chapter. One of the main
purposes of preparing an Environmental Impact Statement is to potentially address public
controversy. Considering this petition and the hundreds of written responses following
the public l�earings, the NCTA and FHWA l�ave chosen not to fully address the
controversial issues identified during the NEPA process. The exclusion o1 specifically
addressing this citizens' petition and other letters of opposition i» the sun�mary chapter of
the FEIS appears to be inconsistent with other large scope toll projects currently being
advanced by tl�e transportation agencies (e.g., Raleigh Southern Outer Loop or Triangle
Southeast Extei�sion Connector and the "Red Alternative" and the To���n of Garner).
Chapter 3, Section 3.3, includes more infornlation regarding the comiz�ents from
the general public. In addition to the approximate 7,000-person petition, NCTA and
FHWA also received 275 signatures slibmitted by the Harrison faniily opposed to the
project ai�d 109 signatures submitted by Barbara Hart opposed to one segment of the
project. OC the other l 5 public comment letters received, 14 are opposed to the project
and one is `i�eutral'.
The �cneralized concerns expressed by the public and other a�ei�cies are included
on pages 3-8 to 3-10. EPA does not believe that the generalized respoi�ses that NCTA
provided to most of these key concerns from the public help to address the controversial
issues associated �vitl� this proposed toll project.
As a�enera] conlme�lt regarding tl�e format of the DEIS and now the FEIS, EPA
strongly encourages co�lsistency. FHWA and NCDOT have produced c�oz.ens of EISs in
the last ten years. Based upon the professional judgment of the pri��ciple NEPA reviewer,
most all of thei�� are very readable and infornlation is easy to loeate within the sta�ldard
format specif��ed in the CEQ regulations. NCTA and FHWA have developed their
specific focmat th�t is less readable and more difficult to find information. For example,
under Farmland impacts Section 1.3.2.3, the discussion does not specitical ly identify
what the di rect i mpacts to agricultural lands are from the Preferred Alte»�ative, DSA 9.
Furthermore, tl�e comments concerning ]and use plans: "....whicl� clesign«1e soz�tl�ern
Gustori Cou�r1�� us �in urea turgeted for n�ore suburban development" and lhe "a��ea
surrouncl«2o 1/ze proposed ��roject is slated for suburban develop�ne��t" appear to be

provided as a rationalization for sprawl and justification for impacting farmlands,
including designated Voluntary Agriculiural District (VAD) properties. These
projections do not appear to be consistent with the finding and fiiture development trends
identified in the Indirect and Cumulative Effects section. All NCDOT EISs reviewed by
EPA in the lasr ten years or more contain a summary table of key impacts at the end of
Chapter I. The Gaston East-West Connector FEIS does not contain a summary table but
gives much �reater narrative discussions that often reiterate what was already addressed
in the DEIS or frequently refer the reader back to the DEIS. Direct impacts to key h�iman
and natural resource impacts for DSA 9 need to be gleaned from nun�erous pages of
written text in tl�e FEIS. See also htt :/p /ceq.hss.doe.�ov/nepa/re�s/ceq/1500.htm#1500.4 .
The NC`I�A is now part of tlle 1VCDOT which utilizes the NEPA/Section 404
Merger process. From EPA's understanding, NCTA has Ueen requested by both FHWA
a�1d the USACE to utilize the Merger process for turnpilce projects. The NCTA, with tlle
exception of the Gaston East-West Connector, utilizes the `Section 6002 TEAC' process
for its proposed turnpike projects. NCDOT and other participating a�encies refer to
interagency coordination meetings as `Merger concurrence meetings'. The FEIS on page
1-42 under Terrestrial Wildlife refers to a`TEAC meeting' held on April 8, 2008.
Similarly, i:l�e FEIS on page 1-35 refers to `TEAC meetings' conducted on February 5,
March 4, and again April 8, 2008. From EPA's understanding these were Merger team
meetings. EPA is unaware of a TEAC plan that was provided by NCTA for this
NEPA/Section 404 Merger project. More importantly, the tentative commitment with
NCWRC, USFWS and EPA for providing wildlife passages to address habitat
fragmentation issues during final design is not included on Table PC-1, Special Project
Commitments. The cost of additional wildlife passages can be substantial. The camment
on page 1-43 concerning the NCTA commitment for bridge desigi� to be `wildlife
friendly', when fcasible, is left technically undefined.
FE1S Resi�onses to EPA DEIS Comments
Commcnt #2: Re�arding EPA's past concurrences durin; the NEPA/Section 404
Merger process, EPA refers NCTA and FHWA to the 2005 Memorand�un of
Understandin� (MOU) under Applicability, Section B aild Concept of Conc�u-rence. EPA
is both a regulatory or resource agency depending upon the specific statute. Prior to the
issuance of the DEIS, the regulatory issues associated with the revoc�ition of the N.C.
State lmplcmentation Plan (SIP) were generally unknown to NCTA, FHWA and the EPA
Merger project team member. Regarding Clean Water Act requirements �ind the
subsiantial impacts to jurisdictions waters of the U.S., EPA requested inforination on a
conceptual miti�ation plan prior to the issuance of the DEIS. The DEIS did not contain a
concephial mitigation plan for the unavoidable impacts to jurisdictional streams and
wetlands, including potentially 48,995 linear feet of streams. Miles of tl�ese impacted
streams werc: incl�lded on the Section 303(d) list of impaired waters.
EPn believes that there is a si�nificant difference between thc Mer�er team
process and tl�e Section 6002 `TEAC process'. The Merger teanz process includes a
defined MOU, distinct agency roles and responsibilities, a dispute resolutio�l and

elevation process, a glossary of terms and environnlental statutes, and very detailed steps
and milestones to reach concurrence points. More inlportantly, the Merger process was
developed as a collaborative, problem-solving team process with the pern�itting a��d
participating agencies. Tl�e Section 6002 TEAC process is primarily based on the
coordination plan and the concept of agencies `raising objections' within 30 days of a
NCTA proposal. This differei�ce is evident for the Gaston East-West Connector project
as lnost of the meetings were not iruly conducted and held as typical Merger conctin�ence
point ineetings but as Section 6002 TEAC meetings. Under the Section 6002 TEAC
process, written concurreuce from other agencies except the USACE for the selection of
the LEDPA is ��ot requested nor required.
An exan�ple of the difference is evidenced by the cllanged nature of the proposed
project. �l��his iie�v toll faciliry was initially advanced in 2001 by the NCDOT as a
freeway under tl�e Merger process. In 2005, it was then promoted as a candidate toll
facility. How�ver, it was still being described as a multi-lane, Strategic Highway
Corridor (SHC) `freeway' ineant to divei-t traffic off of Interstate 85 and to facilitate t��ucl<
traffic fi-om/to the Charlotte Douglas Airport. Following the issuance of the DEIS, the
transportation a�encies are now describing this regional connector `fi•ee��ay' in the FEIS
as a phased project with approximately half of the length build as t���o lanes �vith right of
way for possibly more lai�es iii the future. EPA refers the transportation a�encies to page
2 of the MOU (Concept of concurrence: Exatnples of� r-eevaluation on concurrence
nii�ht i»clircle n cl7ange i�l tl�e assumptions on which the pro�ect purpose und need wcrs
based). Tl�e need to constrL�ct a inulti-lane freeway facility west of US 321 to I-85 is a
potential change to the ociginal assumptions on the purpose and �leed for tl�e project.
EPA was ��ot contacted by NCTA or FHWA between the DEIS and FEIS tor a discussion
as to whether a reevaluation of concurrence was potentially needed by proposing to b�iild
just two lanes initially for approximately half the project length.
Regardi��� Responses to EPA's comments on the DEIS, some of the NCTA and
FHWA responses included fro�n pages B1-46 to B1-63 are not fiill}� responsive or defer
to the DElS ini�ormatioi�. The responses to EPA's cominents #27, # 28 �ind #29 on
Mobile Source Air Toxics (MSATs) are not considered by EPA to be fully responsive.
NCTA and FH WA continue to rely on interi�n guidance and updated interim guidance.
The statement on page B1-58, "Monitoring ofMSAT emissions reniuin.s p�roblerrzutic for
federally fi,n�decl Iiighway pYOjects, and FHWA has only agreed to »lonrtvr-ii�g in a very
limited ��a�� on past projects", does not disclose the technical rationale For mo��itoring on
past selectecl projects. The MSAT infarmation contained in Appendix D�oes provide a
f�irther rationale ���hy FHWA does not conduct quantitative MSAT analyses. The closing
statement in this appendix states: "Consequently, the results of such crssessmer�ts would
not be itsefirl to clecisio��-mcalcer-s, who would need to weigl� tl�is i��for�niution agaii��st
project be��efits, sz�ch us reclucij�ag traffic congestion, accident r-ates, u�id futulities plus
improved uccess fo�° emergency response, that are better sa�ited fo�� yi.�cmtitc�tive afrufysis."
The project's ��urpose and need does not include documentation of problems with
accident r�it�s, safcty, or the need for improved access for emergency response on
existing 1-S� or parallel routes between Gastoilia and Charlotte. F�irthermore, based upon
the Travel Demand Model for the design year, the level of service (LOS) is actually

�vorse on I-8� �vitl� the proposed Gaston East-West Connector than �vithout Building
21.9 mile, new mtilti-lai�e facility will not provide the `benefits' identified i�� tl�is
statement. Consid�ri��g tl�e location of this project and its rural ai�d suburban setti��g, and
tl�at ove��all air quality is already compromised from ozone and 2.5 microns of particulate
matter (PM2.5), EPA's request to perform a more robust analysis of MSATs, especially
��ith i-espect to near roadway sensitive receptors, is not inconsistei�t with current FHWA
i��terim gui�iance.
FEIS Envii-onmental Commitments
Under Special Project Commitments ("Green Sheets"), EPA does not understand
Items 1, 5, ��nd 7, including Community Resources and Services (sharing infoi7��alion
with Re��ional ��ublic schools), Community Safety (bridge over the Catawba River and
Future desi��n accoi��modatioils for pedestrian/bicycle) , and Farnlland (NCTA �vill worlc
witl� Gaston County reg�rding public hearii�gs related to land condemnalion proceedin�s
a�ainst the VAD parcels prior to right of way acquisition). The eilvironmental
commitment made to FWS, NCWRC and EPA concerning adequate �vildlife passage
where there is substantial habitat fragmentation is not included i�l "Table PC-1. There is
no referencc to an enviroi�mei�tal commitment to contiilue to worlc �� ith impacted
Ei���ironmental Justice neighborhoods and communities. There is no refcrence to continue
coordination e�forts �vith the EEP and perniitting agencies to obtain acce��table
compensatory mitigation for direct impacts to jurisdictional stre�lills and �vetlands. Item
#18, Water Resources, developii�g a soil erosion and sedimentation plan and worl<ing
with peinlitting agencies on BMPs does not include an specific environmental
commitments.
Direct Im�acts to Streams and Wetlands
EPA continues to 11ave environi��ental concen�s for the magnitude of impacts to
jurisdiction��l stre��ms and wetlands resulting from the preferred alternativc (and Least
Environ���cnt��l ly Damaging Preferred Alten�ative — LEDPA). EPA's represcntative to
the Mer��r team abstained fi-om concurrence on the LEDPA. Reco�i�izin� the efforts to
provide design retinements to tlle Preferred Alternative DSA 9, the direct impacts to
jurisdictional strcams for a 21.9-mile facility are one of the highest in the past ten years
of the NEPA/Section 404 Merger process. DSA 9 currently includes 36,4] 6 linear feet of
total impact to streams (approximately 6.9 miles), 7.02 acres of impact to �vet�lands, 4.5
acres of imp��cts to ponds, and 91 individual stream crossings.
The FC1S states on page 1-43 that EPA also participates in the per���itting process
collceini�lg �vaters of the U.S. and jurisdictional issues. Under Section 404(1�)(1) of the
Clean Water Act, tlle U.S. Fish and Wildlife Service also directly participates in the
pennitting process tl�rough its direct authorities under the Fish and \-Vildlifc Coo�-dination
Act of ] 934. The NEPA/Section 404 Merger O1 Guidance manual includes a glossary of
laws related to lhe process tllat could be helpful to the NCTA and I;l-1 WA in identifyii��
the agencics that have �� participating role i» the pernlitting processes (See also
http://water.�i�a.��o��!lawsi�e;s/Quidance/wetla�lds/sec404.cfm.

EPA recognizes that avoidance and minimization measures were addressed by
NCTA and TH WA durin� Merger Concurrence Point 4A. Even wilh avoidance and
minimizalion measures accepted by the Merger tean� agencies, the 36,41 G linear feet oF
totaJ stream impact is the sin�le largest project impact since the inception oCthe
NEPA/Section 404 Mer�er process. For this reason and the general lack of miti�ation
opportunities in tl�e watersheds around Charlotte for Piedmont strean�s, EPA staff began
requestin� a Conceptual Mitigation Plan several years before the issuance of the DEIS.
ConceJ�tu�l ��iti�ation Plan
Thc \C�TA's Conceph�al Mitigation Plan dated June 29, 2010, was included as a
reference�] ciocument in the FEIS. A generalized sununary is included in Section 2.5.4.4
and page 1-�3 of the FEIS. Sections 1.0 to 6.0 contain bacicgroln�d information and the
�eneral inforn�ation that was presented at the multi-agency meetin� on Marcl� l6, 2010.
Appendix A oCthe reporl includes impacts to jurisdictional resolirces and Appeildix C
provides a �.�rojcct atl�s for potential on-site, adjacent and nearby mitigation
opportunitics.
Bas�d upon ti�e assessment provided in the report, EPA concurs thal the three (3)
potential mitigation sites (Sites l, 2 and 3) comprising sevei� (7) parcels are viable
opportunities for con�pensatory mitigation. EPA also generally concurs that tl�ere is
potei�tial op��ortunity for sonle stream mitigation credit at the exisling Beaverdam Creelc
mitigation site whicll is located in Mecklenburg County southwest of thc future
iilterchan�e connection at I-485. However, of the 14.0 Wetland Miti�ation Units
(WMUs) anci �8,066 Strea�n Mitigatioll Units (SMUs) of perennial sll-eams, 4,039 SMUs
for intern�it�cnt important streams and 1,672 SMUs for intermittent unimportant slreams
rec�uired for DSA 9, a majority of the impacts are located in sol�thern Gaston Co�u�ty and
Catawba O1 (HUC 03050101). All of the Environmental Enl�ancement Program (EEP)
assets sho���n in Exhibit l, Page 8 of the report with the exception of tl�� E3�averdam
Creek miti��uion site are located substantially far from the Catawba Ol and in other
counties. According to NCDWQ representatives, these EEP assets ma_y also be
functionally difl�erent kinds of streains than those beii�g iinpacted in the project study
area. Based upon EPA's estimation, some of these EEP asset sites are localed niore than
forty (40) miles from the project study area.
Re�ardinb the potential storm water control locations and oppoi-tw�ities for
mitigalion credits, EPA does not concur that these locations and possible activities shown
in Table 8, page 20 of tl�e report should be for direct Section 404 mitigation credits. D��e
to the existin� de�raded conditions of several main water courses in the project shidy
area, including Abernathy Creel<, Crowder's Creek and Catawba Crcek (per tl�e Final
2006 30 �(d) listj, and the projected Indirect and Cumulative Effects (ICE) from
develo}�ment resullin� Ci-om the project, these protective �neasures fi-on� increased
storn�water should be investigated and made regardless ofpotential n�itivation credits. Of
the 6 BMP sites listed on page 20 of the report, no existing storinti�aler controls are
present at t�vo of tlze sites (i.e., #1 and #6). Regarding BMP site #3, EPA c�u�not identify

from the description provided what the existing stormwater control is. The storn�water
flow off tl�e roof and parl<ing lot is directed into an outflow pipe alon� thc property line
ending at a headwater stream. Mitigation credit (SMUs) for stonnwater controls and
BMPS shoulcl be considered as additional protective �neasures and en�-iroi�i��ental
enhancemcnts to E�revent further degradation to impaired waters bein� directly and
indirectly al�fecte�i by the proposed project. As stated in the March 1 G, 2010, meeting
minutes, it is NCTA and FHWA policy not to mitigate for indirect and cumulative effects
fi-om their proposed projects. EPA believes tl�at these stormwater initiatives a»d BMPs
should be instituted as enhanceinents under Section 401 requirements,
Of the =�3 sites �vhere there is potential on-site, adjacent and i�earb�� mitigation
opportunitics includcd in Appendix C of the report, only three (3) stre<u�� sites have been
identified ��s l�avin� potential for nlore than preservation credits (i.e., C�estoration
potential). EPA prcfers restoratioi� and enhancement activities to strict ��reservation for
coil�pensatory mitigat�ion credit. Preservation (43 out of 43 identitied sitcs) of these
streain sites could very possibly end up being a`patchwork' of mitigation sites that do
little to protect or enhance the watershed's overall quality.
w'itl� the cxceptio�� o�the Beaverdam Creek mitigation site ai�d tllc 3 on-site
mitigation opportunities previously identified (Docicery, Harrison, and Falls properties
shown in Table 5, page 13), EPA does not concur with the report conclusions that there
has been adcquately identified conlpensatory mitigation for jurisdictional impacts to
strea�ns. EPA ���i]1 continue to address this outstanding issue of the lacl: ol� adeqtiate
compensatory mitigation of the project's impacts tlu�ough the USACE's Section 404
pennittin� E�rocess.
Direct Impacts �o the H�u»an Environment
The I'referrcd Alternative DSA 9 includes 344 residential reloca�ions. 3�
businesses, 1 larm, and � non-profit facilities. The proposed Monroc E3ypass/Connector
toll facility located oil tl�e other side of Charlotte which is also approxin�ately 20 miles in
length with numerous interchanges ]las 107 residential relocations. Th� Gaston East-
West Connccto�� has a magnitude (3 times) or more reside»tial relocations than a simil�rly
designed toll Faciliry. Table l-3 of the FEIS indicates that 25 neighborhoods and rtn-al
comn�uilities �vill be i»�pacted by DSA 9.
Rc�arding Environi��ental Justice issues, EPA's commet�ts on the DEIS remain
unaddressed in the FEIS. EPA considers that tlle construction of a toll [�acility in are�s
where there ��re n�any blocic groups characterized as minority and low-inco�ne is a
pote»tial en��iroi�mental justice issue that could be expected to liave a disproportion�tely
11igh and adverse in�pact. The FEIS did not provide further analysis to this issue b��t
defers to its comn�cnts and detennination in Section 3.2.5 of the DEIS. Tl�� discussion
ii�cluded in ihis section of the DEIS was and remains inadequate for the purposes of
idei�tifyin� or c�uantifyi��g tl�e actual direct ii�lpacts of the ne�v toll road to minority or
�OW-ll1COIl�C �)O��U��ICIOIIS.

Tabl� >-7 of the DEIS is titled "General Environmental Justice Evaluation for
Toll Facility". This table contains mostly unsupported opinions a��d lacl<s a quantifiable
analysis. Tl�c comment that, "All conafnuters, includifig low-inconie coninri��cr-s, �,o<<lcl
l�cive t/�e o/�troir ro �ise a��or�-toll altern�ative route, such as I-85", is coi�U�ary to tl�e
claimed `benelits' that tl�e public will obtain as a result of �the new, uncon�ested route to
Charlotte. Further statements in this section of the DEIS are also based u��oi� opiiiions and
��ot factual clata and analysis (e.g., Page 3-27; Neighborhoods in tl�e Pr�oject .Strady Area
could coilturi� special gror�ps, perrticularly low-inconze a�id minorit�'1�o��irlutions; ai1d,
All DSAs �,�ould ulso drrectli� mobile home parks, which could represent lo�v-inconie
I�ol�ulations). Ot�the 344 residential relocatio»s for DSA 9, Table 3-2 indic�tes th�lt 97
are ���inoritics. Ot�the 344 residential relocations for DSA 9, Table �- � inclicates as many
as 88 houscholds are below tl�e poverty level and represe�it `low-incon�c'. The evaluation
oFthis dat�� ���ith respect to the project study area, the County orother de[ined population
areas is not m��cle in a coinparative fashion. The `raw demographic data' provided in
these tablcs is not explored or fiilly discussed in Section 3.2.5 under Tnvironme�ltal
Justice. Th� FC[S (or DEIS) did not include the potential thresholds 10�- cletern�ini��g if
the impacts �vere disproportionately high compared to area de�nographic �l�lta. EPA notes
the responsc on page B 1-59 of the FEIS concerning 21 % of the Dei��o�raphic Study Area
being com��risecl ot minorities and that DSA 9 has 28% of the 344 resid�ntial relocations.
There is i�o ���ccilic reference to low-income population relocations in this response and
how combined with mii�ority populations this compares to deinographic study data.
Of the 2�5 noise impacted receptors identified in Table 4.4 for DSA 9, tl�ere is no
discussion as to ho�� illany of these impacted receptors ai°e minority or lo���-incon�e.
Highway noise is ��Iso potentially a direct impact to low-income and i»inorit_y
populations.
EPA continues to i��aii�tain its concer�ls for the lacic of a con�pi�ehensive,
objective, ancl detailed Ei�viro�unental Justice analysis for the proposed project. EPA
requests that a more comprel�ensive and detailed Environinental Justice analysis bc
perfonned usin�, u�dated U.S. Census data for the proposed project ��nci that it be
included in the supplemental information.
Other Proicct Direct ln�nacts and ICE
EPA conlinues to have environmental conceilis regarding tl�e impacts to
farmla��ds including 1�6 acres of conversion from active agricultural lands and 1,084
acres of prime and import�nt farmland soils (Table 1-5 of the FEIS). EPA is conce�7�ed
about the loss of�terrestrial forests (882 acres) and other greenspacc (G81 acres).
EPA continues to have envirotlmental concerns regarding ICl:. T��ble 1-8 of tl�e
FEIS includes the sum»���y of pote�ltial for ICE by county. For DSA 9, the potential for
accelerated �ro���th and otl�er indirect effects as a result of the project are characterized by
NCTA anci l�El WA �ls "high". The proposed Gaston East-West Connector is c�pected to
increase s��r�l����l in the project study area and beyond, including parts of�Yorl< Coui�ty,

S.C. (Page 1-49). CPA requests a copy of the ICE Q�lantitative Analysis re}�ort when it
becomes available.