20120285_Other Agency Comments_20090612

June 12, 2009
Ms Jennifer H Harris, P E
Staff Engineer
North Carolina Turnpike Authority
1578 Mail Service Center
Raleigh North Carolina 27699 1578
Dear Ms Harris
Subject Comments on the Draft Environmental Impact Statement for the Proposed Gaston
East West Connector, Gaston and Mecklenburg Counties, North Carolina
(TIP No U 3321)
This letter responds to a request for our review and comments on the Draft Environmental
Impact Statement (DEIS) for the subject project Our comments are provided in accordance with
the Fish and Wildlife Coordination Act, as amended (16 U S C 661 -667e) and section 7 of the
Endangered Species Act of 1973 as amended (16 U S C 1531 1543)
The North Carolina Turnpike Authority (NCTA) proposes to provide a new location freeway
from 185 west of Gastonia to 1 485 near the Charlotte Douglas International Airport As part of
the North Carolina Department of Transportation s ( NCDOT) merger process we participated as
a merger team member and provided comments and recommendations to the NCDOT regarding
the project through concurrence point (CP) 2 alternatives to be carried forward We abstained
from signing at CP 2 A copy of our abstention is included in the DEIS Appendix A
Subsequently the NCTA chose to follow the merger process for this project and in 2008 we
signed a combined CP 1 2 and 2a form and have attended agency coordination meetings and
provided comments and recommendations at those meetings
The majority of our concerns for the environmental impacts of this project are the extent of
impacts to streams and wetlands and the fragmentation of terrestrial habitat The recommended
alternative will impact a total of 9 3 miles of streams, including 7 4 miles of perennial streams
and almost 2 miles of intermittent streams Wetland impacts are estimated at 7 5 acres

Conservatively this project will require about 20 miles of stream and 15 acres of wetland
compensatory mitigation We are concerned that this amount of mitigation will not be available
particularly in this area Every effort should be made to further avoid and minimize impacts to
streams and wetlands and to provide on site mitigation
In addition to direct effects, the indirect and cumulative effects on streams and wetlands from
this project and the development that it has the potential to induce will permanently alter the
streams in the area and further degrade water quality and habitat Although the municipalities in
the study area are under the National Pollutant Discharge Elimination System s Phase I1
storm water rules these rules do not address the preservation of intact riparian buffers limits on
impervious surface amounts in a given watershed or other factors critical to maintaining stable
properly functioning streams and aquatic habitat Measures to mitigate secondary and
cumulative impacts can be found in the North Carolina Wildlife Resources Commission s
Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to Aquatic
and Terrestrial Wildlife Resources and Water Quality We strongly encourage the NCTA to
work with local governments to adopt protective measures for streams and wetlands in the study
area to reduce these impacts
The fragmentation of terrestrial habitat is also a concern for this project This new location
freeway will bisect a number of farms and other working land and forests that provide habitat
and movement corridors for wildlife and migratory birds There is a brief discussion on
page 6 18 regarding impacts to terrestrial wildlife but there is no analysis specific to the
alternatives proposed or the recommended alternative This discussion also states that the NCTA
will consider wildlife passage structures along the corridor but there is no map to display where
these structures may be located or in what habitats Page 7 9 of the DEIS references a map
showing the distribution of habitat in the study area and possible indirect and cumulative impacts
to terrestrial wildlife but this map is in another document that is not provided in the DEIS or its
appendices If large patches of habitat are being fragmented by the various alternatives,
measures to avoid or minimize those impacts should be investigated particularly if habitat or
travel corridors for large mammals or migratory birds will be affected
The only federally listed species known to occur in the project study area is the Schwemrtz's
sunflower (Helianthus schweinitzii) According to the DEIS, there is a population of this
sunflower along the western side of Union New Hope Road, and the majority of the alternatives
(including the recommended alternative) would have no impact on this population The DEIS
further states that four of the proposed alternatives (Alternatives 4 22 58, and 76) are near this
population but would have no direct impacts If one of these latter alternatives is chosen further
consultation will be required to determine whether this population will be impacted
We appreciate the opportunity to provide these comments and will continue to participate in the
planning process for this project If you have questions about our 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 Number 4 2 02 444
Sincerely,
Brian P Cole
Field Supervisor
Electronic copy to
Ms Marla J Chambers Western NCDOT Permit Coordinator North Carolina Wildlife
Resources Commission 12275 Swift Road Oakboro, NC 28129
Mr Chris Milrtscher U S Environmental Protection Agency, 1313 Alderman Circle,
Raleigh NC 27603
Ms Polly Lespmasse Mooresville Regional Office North Carolina Division of Water Quality
610 East Center Avenue Suite 301 Mooresville, NC 28115
Regional Director FWS, Southeast Regional Office Atlanta GA (ES, Attention Mr Richard
Warner)