20120285_Gaston East-West Corridor Email_20110919

FW Gaston ICE comments
FW Gaston ICE comments
Lespinasse, Polly
Sent Tuesday May 08 2012 3 30 PM
To Carrillo Sonia
Attachments Water %20Qua1ity %2OAnalysis -1 doc (101 KB)
From Wrenn, Brian
Sent Monday, September 19, 20114 41 PM
To Harris, Jennifer, Marella Buncick, Militscher, Chris, Chambers, Marla J
Cc Lespinasse, Polly
Subject RE Gaston ICE comments
my bad
Page I of
From Wrenn, Brian
Sent Monday, September 19, 20114 20 PM
To Jennifer, Harris„ Marella Buncick, Militscher, Chris, Chambers, Marla (marla chambers @ncwildlife org)
Cc Lespinasse, Polly
Subject Gaston ICE comments
Jennifer,
Please find attached comments on the Gaston ICE a signed hard copy will follow thanks
Brian
0
/ /mail nc gov /owa/ ?ae= Item &t =IPM Note &id= RgAAAADMSzLcd9W2TJHI4 %2bm 5/17/2012

From Polly Lespinasse Division of Water Quality Mooresville Regional Office
Through Brian Wrenn Transportation Permitting Supervisor Division of Water Quality
Subject Comments on the Indirect and Cumulative Effects Water Quantitative Analysis Related to the
Proposed Gaston East West Connector Extending from 185 West of the City of Gastonia in
Gaston County to 1-485 near the Charlotte Douglas International Airport in Mecklenburg County
Mecklenburg and Gaston Counties, STIP No s U 3321
This office has reviewed the referenced document dated August 2011 The NC Division of Water Quality (NCDWQ) is
responsible for the issuance of the Section 401 Water Quality Certification for activities that impact Waters of the U S
including wetlands It is our understanding that the project as presented will result in impacts to jurisdictional wetlands
streams and other surface waters NCDWQ offers the following comments based on review of the aforementioned
document
Project Specific Comments
The analysis indicates notable increases between the 2035 No Build Analysis and the 2035 Build Analysis
Increases In the amount of total phosphorus (TP) are expected in the Catawba Creek (7 %) Lower Crowders
Creek (5 5 %) Lake Wylie Catawba River (5 3 %) and Beaverdam Creek Catawba River (5 3 %) hydrologic units
(HUs) Increases in total nitrogen (TN) are expected In the Catawba Creek (5 3 %) and Lake Wylie Catawba River
(5 3 %) HUs Additionally increases in annual runoff are expected in the Beaverdam Creek Catawba River
(8 73 %) Catawba Creek (7 97 %) and Lower Crowders Creek (7 28 %) HUs Catawba Creek Lower Crowders
Creek Lake Wylie and Beaverdam Creek are either on North or South Carolinas 2010 303(d) list or have
established TMDLs (total maximum daily loads) Catawba Creek and Lake Wylie are listed for impaired biological
integrity Lower Crowders Creek is listed for impaired biological integrity throughout the reach and fecal coliform
in some stream sections DWQ is very concerned with the potential indirect and cumulative impacts to both
303(d) listed streams and non 303(d) listed streams throughout the study area that may result from the
construction of this road While Beaverdam Creek Catawba River is not currently on the North Carolina 303(d)
list it is expected to see an increase in TP TN and annual runoff Increased pollutants in this HU as a result of
the construction of this project could result in impairment necessitating its listing on the 303(d) list The NCTA is
encouraged to investigate opportunities with local governments to address the indirect and cumulative impacts to
local jurisdictional resources that may be incurred as a result of this project
2 DWQ provided comments to the North Carolina Turnpike Authority (NCTA) on our review of the Final
Environmental Impact Statement (FEIS) on February 21 2011 One of the comments Is below
Chapter 2 Page 64 of the FEIS states that interviews were conducted with the MPOs and County Planning
Departments to determine whether the updated 2035 forecasts should serve as the No Build Scenario or the
Mooresville Regional Office
Location 610 East Center Ave Suite 301 Mooresville NC 28115
Phone [phone] Fax [phone] Customer Service 1877-623 6748
Internet www ncwaterquality org
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Build Scenario for ICE Study Area Based on these interviews the Gaston East West Connector was
assumed to be completed in the allocation of future growth to specific zones NCDWQ is unclear whether this
means the road was considered to be completed in the No Build Scenario Table 2 17 provides the Estimated
Change ►n Impervious Cover by Watershed using baseline data from 2007 and the 2035 No Budd and 2035
Build Scenarios Very little change In impervious cover ►s realized between the 2035 No Build and Build
Scenarios The total increase in impervious cover from No Budd to Budd is 0 5% with some watersheds
showing no increase in impervious cover and some showing a decrease in impervious cover This information
may support the fact that the Gaston East West Connector was included in the No Build Scenario If the Gaston
East West Connector was included in the No Build Scenario NCDWQ is concerned that this does not provide
an accurate evaluation of the indirect and cumulative impacts associated with this project If the Gaston East
West Connector was included in the models used to generate data for the No Build Scenario the NCTA will be
required to provide modeling data that does not Include the completion of the Gaston East West Connector as
part of the No Build Scenario
To our knowledge this comment has not been addressed It appears based on this analysis that the land use
data input for this model was provided by the Louis Berger Group Inc DWQ is concerned that if the land use
input data was generated using the amount of impervious cover from Louis Berger Group report the results of the
water quality analysis may be skewed Again DWQ is unclear whether the construction of the road or portions of
the road were included in the 2035 Build Scenario The Water Quality Analysis states on Page 2 that the No
Build Alternative by definition is the Forecasted land use for the year 2035 without the construction of the
project It is also important to note that in project discussions with other federal agencies DWQ was advised
that the construction of the road was included in the No Build analysis Therefore based on the potentially
conflicting information presented in the FEIS Water Quality Analysis and verbal discussions with other
agencies DWQ will not consider this analysis complete until we receive written confirmation from each
Metropolitan Planning Organization (MPO) that construction of the road or any portion of the road (i e
construction of the road was allocated for within specific TAZ units only in the `No Build" analysis) was
not included in the "No Build' analysis
3 Pages i and 33 of the Water Quality Analysis state that four of the five HUs with 303(d) listed stream show
decreases TSS under the Build Scenario Based on Table 20 the only 303(d) listed HU which shows a
decrease in TSS is the Mill Creek —Lake Wylie HU Decreases are seen in two other HUs (Fates Creek and Lake
Wylie Catawba River) but according to this document they are not 303(d) listed
General Comments
1 In accordance with the Environmental Management Commission s Rules {15A NCAC 2H 0506(h)) mitigation will
be required for impacts of greater than 150 linear feet to any single perennial stream In the event that mitigation
is required the mitigation plan shall be designed to replace appropriate lost functions and values The NC
Ecosystem Enhancement Program may be available for use as stream mitigation
2 Future documentation including the 401 Water Quality Certification Application shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping
3 NCDWQ is very concerned with sediment and erosion impacts that could result from this project The NCTA shall
address these concerns by describing the potential impacts that may occur to the aquatic environments and any
mitigating factors that would reduce the impacts
4 A final analysis of cumulative and secondary impacts anticipated as a result of this project is required The type
and detail of analysis shall conform to the NC Division of Water Quality Policy on the assessment of secondary
and cumulative impacts dated April 10 2004
5 The NCTA is respectfully reminded that all impacts including but not limited to bridging fill excavation and
clearing and rip rap to jurisdictional wetlands streams and riparian buffers need to be included in the final impact
calculations These impacts in addition to any construction impacts temporary or otherwise also need to be
included as part of the 401 Water Quality Certification Application
6 Where streams must be crossed NCDWQ prefers bridges be used in lieu of culverts However we realize that
economic considerations often require the use of culverts Please be advised that culverts should be countersunk
to allow unimpeded passage by fish and other aquatic organisms Moreover in areas where high quality

wetlands or streams are impacted a bridge may prove preferable When applicable the NCTA should not install
the bridge bents in the creek to the maximum extent practicable
7 Whenever possible NCDWQ prefers spanning structures Spanning structures usually do not require work within
the stream or grubbing of the streambanks and do not require stream channel realignment The horizontal and
vertical clearances provided by bridges shall allow for human and wildlife passage beneath the structure Fish
passage and navigation by canoeists and boaters shall not be blocked Bridge supports (bents) should not be
placed in the stream when possible
8 Bridge deck drains shall not discharge directly into the stream Stormwater shall be directed across the bridge
and pre treated through site appropriate means (grassed swales pre formed scour holes vegetated buffers etc )
before entering the stream Please refer to the most current version of NCDWQ s Stormwater Best Management
Practices
9 Sediment and erosion control measures should not be placed in wetlands or streams
10 Borrow /waste areas should avoid wetlands to the maximum extent practical Impacts to wetlands in borrow /waste
areas will need to be presented in the 401 Water Quality Certification and could precipitate compensatory
mitigation
11 The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management More specifically stormwater shall not be permitted to discharge directly into streams
or surface waters
12 Based on the information presented in the document the magnitude of impacts to wetlands and streams may
require an Individual Permit (IP) application to the Corps of Engineers and corresponding 401 Water Quality
Certification Please be advised that a 401 Water Quality Certification requires satisfactory protection of water
quality to ensure that water quality standards are met and no wetland or stream uses are lost Final permit
authorization will require the submittal of a formal application by the NCTA and written concurrence from
NCDWQ Please be aware that any approval will be contingent on appropriate avoidance and minimization of
wetland and stream impacts to the maximum extent practical the development of an acceptable stormwater
management plan and the inclusion of appropriate mitigation plans where appropriate
13 If concrete is used during construction a dry work area shall be maintained to prevent direct contact between
curing concrete and stream water Water that inadvertently contacts uncured concrete shall not be discharged to
surface waters due to the potential for elevated pH and possible aquatic life and fish kills
14 If temporary access roads or detours are constructed the site shall be graded to its preconstruction contours and
elevations Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted When using temporary structures the area shall be cleared but not grubbed Clearing
the area with chain saws mowers bush hogs or other mechanized equipment and leaving the stumps and root
mat intact allows the area to re vegetate naturally and minimizes soil disturbance
15 Placement of culverts and other structures in waters streams and wetlands shall be placed below the elevation
of the streambed by one foot for all culverts with a diameter greater than 48 inches and 20 percent of the culvert
diameter for culverts having a diameter less than 48 inches to allow low flow passage of water and aquatic life
Design and placement of culverts and other structures including temporary erosion control measures shall not be
conducted in a manner that may result in dis equilibrium of wetlands or streambeds or banks adjacent to or
upstream and down stream of the above structures The applicant is required to provide evidence that the
equilibrium is being maintained if requested in writing by NCDWQ If this condition is unable to be met due to
bedrock or other limiting features encountered during construction please contact NCDWQ for guidance on how
to proceed and to determine whether or not a permit modification will be required
16 If multiple pipes or barrels are required they shall be designed to mimic natural stream cross section as closely
as possible including pipes or barrels at flood plain elevation floodplain benches and /or sills may be required
where appropriate Widening the stream channel should be avoided Stream channel widening at the inlet or
outlet end of structures typically decreases water velocity causing sediment deposition that requires increased
maintenance and disrupts aquatic life passage

17 If foundation test borings are necessary it shall be noted in the document Geotechnical work is approved under
General 401 Certification Number 3687 /Nationwide Permit No 6 for Survey Activities
18 Sediment and erosion control measures sufficient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Control Planning
and Design Manual and the most recent version of NCS000523
19 All work in or adjacent to stream waters shall be conducted in a dry work area Approved BMP measures from
the most current version of NCDOT Construction and Maintenance Activities manual such as sandbags rock
berms cofferdams and other diversion structures shall be used to prevent excavation in flowing water
20 While the use of National Wetland Inventory (NWI) maps NC Coastal Region Evaluation of Wetland Significance
(NC CREWS) maps and soil survey maps are useful tools their inherent inaccuracies require that qualified
personnel perform onsite wetland delineations prior to permit approval
21 Heavy equipment should be operated from the bank rather than in stream channels in order to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams This equipment shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels lubricants hydraulic
fluids or other toxic materials
22 Riprap shall not be placed in the active thalweg channel or placed in the streambed in a manner that precludes
aquatic life passage Bioengineering boulders or structures should be properly designed sized and installed
23 Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
following completion of construction
NCDWQ appreciates the opportunity to provide comments on your project Should you have any questions or require any
additional information please contact Polly Lespinasse at [phone]
cc Liz Hair US Army Corps of Engineers Asheville Field Office (electronic copy)
Chris Militscher Environmental Protection Agency (electronic copy)
Marla Chambers NC Wildlife Resources Commission (electronic copy)
Marella Buncick US Fish and Wildlife Service (electronic copy)
Sonia Gregory NCDWQ Central Office (electronic copy)
File Copy