20120285 Ver 1_More Info Requested_20120530

N®NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild P E Dee Freeman
Governor Director Secretary
May 30 2012
CERTIFIED MAIL RETURN RECEIPT REQUESTED
Jennifer Harris PE
NC Turnpike Authority
North Carolina Department of Transportation
1578 Mail Service Center
Raleigh North Carolina 27699 1578
Subject Proposed Gaston East West Connector (Garden Parkway) in Gaston and Mecklenburg Counties
Federal Aid Project No STP 1213(6) State Project No 8 2812501 TIP U 3321
NCDWQ Project No 20120285
Dear Ms Hams
On March 20 2012 the North Carolina Division of Water Quality (NCDWQ) received your application
dated March 6 2012 to construct the proposed Gaston East West Connector also known as the Garden
Parkway On April 4 2012 the point NCDWQ/U S Army Corps of Engineers Public Notice was
published for your project in order to notify and accept comments from interested parties The NCDWQ
received numerous comments during the public comment period including a request for the NCDWQ to
hold a public hearing The purpose of this correspondence is to inform you that the Director of the
NCDWQ has determined it is in the public interest that a hearing to assist in the review of public
comments and additional information be held per 15A NCAC 2H 504 prior to granting or denying a 401
Water Quality Certification for this project As such your application has been placed on hold At this
time we are coordinating administrative details in order to hold a hearing within 90 calendar days (no
later than August 28 2012) of the date of this letter We will keep you informed as the details regarding
the public hearing develop Comments will be accepted for 30 days beginning the day of the hearing after
which time the Director will have 30 days to issue deny or request more information regarding your
request for certification Please note that no action is necessary on your part at this time in regards to the
public hearing
Also the NCDWQ requests the following additional information be supplied as part of the application
review
• The resource agencies including NCDWQ have raised concerns in the past regarding the
assumptions and methodologies used to predict future land development and associated traffic
forecasts for the Gaston East West Connector As a result the North Carolina Turnpike
Authority (NCTA) has been questioned by the environmental agencies as well as others regarding
the methodology and assumptions used to determine future development and traffic volumes for
this project The recent U S 4`h Circuit Court of Appeals ruling on May 3 2012 regarding the
Indirect and Cumulative Effects Analysis (ICE) and Indirect and Cumulative Impacts Analysis
Transportation and Permitting Unit
1650 Mad Service Center Raleigh North Carolina 27699 1650 One
Location 512 N Salisbury St Raleigh North Carolina 27604 NorthCarohna
Phone [phone] \ FAX [phone] a f p/ y+
Internet www ncwaterquality org [`-KKLL L [y
An Equal opportunity \ Affirmative Action Employer

(ICI) for the proposed Monroe Bypass project has further raised questions regarding the
assumptions used in the model for the Gaston East West Connector In past responses the NCTA
has indicated that the methodology used for the Gaston East West Connector is different than that
used for the Monroe Bypass However the last sentence of Section 2 4 1 on page 18 of the
Gaston East West Connector Quantitative Indirect and Cumulative Effects Analysis (August 3
2010) states the forecasts represent the build condition and it was reasonable to use the
gravity model approach to redistribute households and employment for the No Build condition
Additionally in documents supplied as comments by the Southern Environmental Law Center
(SELC) it was stated by PBS &J /Atkins North America staff on May 13 2010 with respect to the
aforementioned document that overall growth does not change with or without the project — it
dust redistributes This is the same assumption used to the Monroe Connector project [emphasis
added] but was presented somewhat differently Please take a look and see what your thoughts
are regarding modifying this similar discussion in the Gaston report It appears to the NCDWQ
that the same assumptions were used in both the Gaston East West Connector and the Monroe
Bypass projects If this is the case the NCDWQ has significant concerns regarding the
methodology as well as the future No Build results
As stated earlier as well as in past discussions with the NCTA the NCDWQ has concerns with
the assumptions The NCDWQ is requesting that the NCTA provide a clear detailed explanation
of how the Gravity Model assumptions used for the Gaston east West Connector are different
than those used for the Monroe Bypass as the NCTA has contended in the past with respect to
the use of the demographic projection dataset Please provide clarity if indeed only one set of data
were used for both the future build and no build scenarios
Please note that your project has been placed on hold and a final decision will not be made by the Director
until after the public hearing administrative record period has closed and the additional information
requested has been received
This letter only addresses the application review and does not authorize any impacts to wetlands waters or
protected buffers Please be aware that any impacts requested within your application are not authorized at
this time by the NCDWQ Please contact me at 919 807 6380 or Cyndi Karoly @ncdenr gov or David
Wainwright at 919 807 6405 or David Wainwright @ncdenr gov if you have any questions regarding this
matter
Sincerely
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Cyndi Karoly Branch Chief
Wetlands and Stormwater Branch
CB K/daw
cc Liz Hair US Army Corps of Engineers Asheville Field Office
Chris Militscher Environmental Protection Agency
Marla Chambers NC Wildlife Resources Commission (electronic copy only)
Rob Krebs DWQ Mooresville Regional Office
Ron Ferrell Atkins North America Inc 1616 East Millbrook Road Suite 310 Raleigh NC 27609
File Copy
Transportation and Permitting Unit
1650 Mail Service Center Raleigh North Carolina 27699 1617 One
Location 512 N Salisbury St Raleigh North Carolina 27604 NorthCarollna
Phone [phone] FAX [phone] pr
Internet www ncwaterauality org Naturally
An Equal Opportunity 1 Affirmative Action Employer