20000874_More Info Received_20030214

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
U. S. Army Corps of Engine' ei'S
Regulatory Field Office
Post Office Box 1890
Wilmington, NC 28402 -1890
ATTN: Mr. Richard Spencer
NCDOT Coordinator
Dear Sir:
February 14, 2003
�C 0W
FB 1 4W
WE
LANDS
1'JAi rat tiALITY S£
LYMDo TEPPETT
SECRETARY
Subject: Application for Section 404 and 401 permits for the Ellerbe Bypass and
Ellerbe Connector (NC 73 Extension). Richmond and Montgomery Counties;,
US 220; Federal Aid No. NEF -45- 1(49); State Project No. 8.T550803; TIP Noss.
R -2231 (A, B, CA, and CB) and R -3303. COE Action ID 199400590; DWQ No.
©409711
The North Carolina Department of Transportation ( NCDOT) proposes to construct a
four -lane, full control of access highway on new location from south of Ellerbe (Richmond
County) to Emery, south of Candor (Montgomery County). Interchanges are proposed at US 220
south of Ellerbe, SR 1452, SR 1458, NC 73, SR 1321, SR 1524, and US 220 north of Emery.
The project will be approximately 19 miles in length. A connector road (R -3303) also known gas
the NC 73 Extension between the existing, intersection of US 220 and NC73, and the proposedl
Bypass will also be constructed. The connector will be a two-lane road with exclusive turning;
lanes at various intersections along the proposed roadway. This application addresses both
projects and consists of the cover letter, ENG Form 4345, 8'/2 x 11 inch permit drawings, andl
half size plan sheets.
Purpose and Need: The main purpose of the proposed Ellerbe Bypass is to improve the entire US
220 corridor in the state. US 220 is desigmted as part of the Interstate Corridor System and
serves as a major north -south route. The bypass is needed because the existing road in and new
Ellerbe has sharp curves, roller - coaster grades and reduced speed zones through towns that create
safety hazards, which are increasing in sev -erity as the traffic volumes increase. The purpose off
the Connector is to provide direct connection between existing NC73 and the proposed Bypass
without the need to travel to downtown Ellerbe.
I- "

Summary of Impacts: Tables 1- 4 illustrate the wetland and stream impacts by section for the
entire length of the project. The wetland tables give impacts by river basin, community type,
riverine /non - riverine status, and by project section. The surface water tables give impacts by river
basin, raw impact, natural channel design, and required mitigation. The project lies in two river
basins: the Yadkin River Basin (Hydrologic Catalog Units 03040104 and 03040201) and the
Lumber River Basin (Hydrologic Catalog Unit 03040203).
Table 1. Wetland Impacts by Community Type in Yadkin Diver Basin (acres)
A
0
4i28-,-
7.73
0.00
0.28
0.00
12.29
B
0.00
; ,.� .._
5.68
2.38
0.00
0.00
8.06
CA
0.00
0.00
0.00
0.00
0.00
0.00
0.00
CB
0.00
0. ...{
2
0.00
0.00
0.00
6.02
R -3303
1.32
1 0
4
0
0
0
1.32
Tot!LL
1.32
k�f k 1
19.43 1
2.38
0.28
0.00
27.69
Table 2. Wetland Impacts by Community Type in Lumber River Basin (acres).
u
g a r
- M m 1 "; -..
4670
A
2335
B
1854
0.00
3708
CA
0.00
0.00
0.00
CB
M
M."
4034
R -3303
367
0
734
Totals
49 i
�i
13,149
Table 3. Surface Water Impacts for the Yadkin River Basin (linear feet)
2
0.00
4670
A
2335
B
1854
0.00
3708
CA
0.00
0.00
0.00
CB
2693
676
4034
R -3303
367
0
734
Totals
7249
676
13,149
2

Table 4. Surface Water Impacts for the Lumber River Basin.
*Onsite Stream Mitigation yields 1:1
Summary of Mitigation: The project has been designed to avoid and minimize impacts to
jurisdictional areas throughout the NEPA and design processes. Detailed descriptions of these
actions are presented elsewhere in this application. Compensatory mitigation for the remaining
impacts consist of:
• 2.45 acres of on -site wetland restoration at the Myrick Pond Mitigation Site for the Lumber
Basin Wetland impacts;
• 5 5.3 8 acres of off -site wetland riverine restoration at the Key Branch Mitigation Site for the
Yadkin Basin wetland impacts;
• 702 feet of on -site stream relocation using natural channel design techniques at the Myrick
Pond Mitigation Site for the Lumber Basin Stream Imparts.
• 676 feet of on -site stream relocation using natural channel design techniques at Sites 3 and 6
- 2231CB for mitigation of stream impacts in the Yadkin Basin.
• '-6183 eet of stream mitigation from the Key Branch Mitigation Site for stream impacts in the
d n Basin.
• 6966 LF of stream mitigation from the following Full Delivery Stream Mitigation sites.
• Skelly & Loy Site 1 (Bennett) 10,540 LF (see Table 11 for details)
• Skelly & Loy Site 2 (Saron Church) 390 LF (see Table 12 for details)
• Skelly & Loy Site 6 (Poole Rd.) 722 LF (see Table 13 for details)
• Skelly & Loy Site 17= (Haithcock) 4568 LF (see Table 14 for details)
TOTAL 16,220 LF
The on -site mitigation sites are described in detail elsewhere in this application. The final
mitigation plans for the four stream mitigation sites were hand delivered to the USACE, the
NCDWQ, the NCWRC and the USFWS in January and February 2003 by Skelly and Loy.
Copies of the letters of transmittal of these plans can be found appended to this application.
PROJECT SCHEDULE
Schedule: All sections of R -2231, the Ellerbe Bypass, will be let to construction in July 2003.
The Connector, R -3303, is scheduled for letting in October 2004. Table 5 reflects the project
breakdown, section limits, and project let dates.
©
1 11
1 11
1 I r
I I I
1 11
1 11
©®
r 11
1 11
r rl
1 11
*Onsite Stream Mitigation yields 1:1
Summary of Mitigation: The project has been designed to avoid and minimize impacts to
jurisdictional areas throughout the NEPA and design processes. Detailed descriptions of these
actions are presented elsewhere in this application. Compensatory mitigation for the remaining
impacts consist of:
• 2.45 acres of on -site wetland restoration at the Myrick Pond Mitigation Site for the Lumber
Basin Wetland impacts;
• 5 5.3 8 acres of off -site wetland riverine restoration at the Key Branch Mitigation Site for the
Yadkin Basin wetland impacts;
• 702 feet of on -site stream relocation using natural channel design techniques at the Myrick
Pond Mitigation Site for the Lumber Basin Stream Imparts.
• 676 feet of on -site stream relocation using natural channel design techniques at Sites 3 and 6
- 2231CB for mitigation of stream impacts in the Yadkin Basin.
• '-6183 eet of stream mitigation from the Key Branch Mitigation Site for stream impacts in the
d n Basin.
• 6966 LF of stream mitigation from the following Full Delivery Stream Mitigation sites.
• Skelly & Loy Site 1 (Bennett) 10,540 LF (see Table 11 for details)
• Skelly & Loy Site 2 (Saron Church) 390 LF (see Table 12 for details)
• Skelly & Loy Site 6 (Poole Rd.) 722 LF (see Table 13 for details)
• Skelly & Loy Site 17= (Haithcock) 4568 LF (see Table 14 for details)
TOTAL 16,220 LF
The on -site mitigation sites are described in detail elsewhere in this application. The final
mitigation plans for the four stream mitigation sites were hand delivered to the USACE, the
NCDWQ, the NCWRC and the USFWS in January and February 2003 by Skelly and Loy.
Copies of the letters of transmittal of these plans can be found appended to this application.
PROJECT SCHEDULE
Schedule: All sections of R -2231, the Ellerbe Bypass, will be let to construction in July 2003.
The Connector, R -3303, is scheduled for letting in October 2004. Table 5 reflects the project
breakdown, section limits, and project let dates.

Table 5 Construction limits and schedule
Sections
Project Limits
Let Date
R -2231A
Us 220 bypass from SR 1448 to south of SR 1455
July 2003
R -223IB
US 220 bypass from south of SR 1455.(Fire Tower Rd) to north of
NC 73
July 2003
R -2231 CA
US 220 bypass from north of NC 73 to south of SR 1524
July 2003
R -2231 CB
US 220 bypass from south of SR 1524 to exist 4 lanes north of US
220 alt
July 2003
R -3303
NC 73 ext from existing NC 73/us220 to srl452 (Church St) near
Ellerbe
October 2004
PERMITTING HISTORY
Over the past few years several permit applications have been submitted for this project. An
application dated June 30, 2000 was submitted to the USACE and the NCDWQ. We received
responses from the USACE on September 14, 2000 and from the DWQ on July 25, 2000
requesting additional information on the mitigation as well as many design issues. A revised
application incorporating our responses to the agencies was submitted in December 2001.
Comments were received from the NCDWQ dated April 15, 2002 and from the USACE dated
March 7, 2002 requesting additional information. At that time the NCDWQ stated that the
application was deficient and returned the document to us. We subsequently withdrew the
application and informed the agencies that a new application would be submitted. This
document is the new application and incorporates substantial data to demonstrate our compliance
with the Clean Water Act and to show that we have complied with the requests in the comment
letter responses to their concerns.
On August 27, 2002 we held a pre - application meeting. Prior to that meeting we had transmitted
our revised responses to the April 15, 2002 and March 7, 2002 agency letters as well as revised
permit application drawings to the agencies. These responses were discussed with the WRC
(David Cox), the DWQ (John Hennessy) and the USACE (Richard Spencer) during the meeting
(USFWS representative was absent). We have repeated the bulk of these design and mitigation
responses in this application in the section entitled Minimization. Where the request was minor
(for instance asking that we include the name of the stream on the drawing) we did not make a
written response in the Minimization Section; but we did, of course, correct the items on the
drawings.
NEPA DOCUMENT STATUS
R -2231: A Draft Environmental Impact Statement (DEIS) was submitted by the NCDOT
in compliance with the National Environmental Policy Act. The DEIS for the Ellerbe Bypass, R-
2231, was approved on July 15, 1991. A Final Environmental Impact Statement (FEIS) was
approved on November 22, 1996. A Record of Decision (ROD) was approved on May 30, 1997.
Copies of the DEIS, FEIS and ROD for project R -2231 have been provided to regulatory review
agencies involved in the approval process. Additional copies will be provided upon request.
R -3303: The EA for the Connector was approved on March 25, 2000. We expect the
FONSI to be signed by December 2002. After the documents were approved they were

circulated to federal state and local agencies. Copies of the EA for R -3303 has been provided to
the agencies. Additional copies will be provided upon request.
The projects are in compliance with 23 CFR Part 771.111(f) which lists the Federal Highway
Administration (FHWA) characteristics of independent utility of a project:
(1) The project connects logical termini and is of sufficient length to address
environmental matters on a broad scope;
(2) The project is usable and a reasonable expenditure, even if no additional
transportation improvements are made in the area;
(3) The project does not restrict consideration of alternatives for other reasonably
foreseeable transportation improvements.
RESOURCE STATUS
Delineations: Delineations of Jurisdictional wetlands were completed by Espey, Huston, &
Associates, Inc. (EH &A) ecologists. Wetland sites were delineated in June 1994, September
1994, October 1994, and January 1995. Guidance provided in the 1987 Corps of Engineers
Wetland Delineation Manual (Environmental Laboratory, 1987) was used for determining
wetland boundaries. Wetland boundaries were verified in January 1995 by U. S. Army Corps of
Engineers (USACE) field personnel. On July 16, 2002 Mr. Richard Spencer of the Wilmington
District Corps of Engineers re- verified the wetland boundaries for R -2231. There were no
changes in the wetland boundaries.
Delineations of jurisdictional streams were completed by NCDOT biologists in
November 1998 (R- 223IA) and June 1999 for sections R-223.1 B, CA and CB. The streams were
verified by agency personnel during an on -site meeting July 20 -21, 1999.
Section A: There are a total of eleven jurisdictional sites in this section. These are labeled site I,
IIA, IIB, III, IV, V, VI, VII, VIII, IX, and X. The wetland and surface water impacts are
described in Table 6. All wetland and surface water impacts for this section are located in the
Yadkin River Basin.
The wetland systems in Section A, with one exception, are considered non - riverine,
because they primarily receive their wetland hydrology from sources other than overbank
flooding. All sites on Section A are headwater forests or bottomland forests, except site VIII,
which contains a freshwater marsh complex that receives wetland hydrology from an upstream
tributary flow and adjacent hillside seepage areas. Wetland impacts on jurisdictional areas in
this section total 12.29 acres. Impacts to this section are summarized in Table 6. Compensatory
wetland mitigation in the Yadkin River Basin will be required for all 12.29 acres of wetland
impacts for this section (4.28 non - riverine and 7.73 riverine).
The jurisdictional stream impacts, totaling 2,488.71 feet (existing channel lost) on
Section A, are in perennial streams. The stream impacts on section A result from culvert/pipe
installations. Compensatory mitigation in the Yadkin River Basin will be required for all
2,488.71 feet of stream impacts for this section.

Table 6. Wetland and Stream Impacts for Section A.
_
I
PSSB
headwater (NR)
0.43
0.00
0.00
0.00
IIA
PSSB
headwater (NR)
2.28
0.00
0,00
0.00
IIB
PSSB
headwater (NR)
1.40
630.44
0.00
630.44
IIC
PSSB
headwater (NR)
0.17
0.00
0.00
0.00
III
PFO1B
bottomland (R)
2.32
203.15
0.00
203.15
IV
PFOIB
bottomland (R)
1.71
319.95
0.00
319.95
V
PFO1 A
bottomland (R)
0.48
0.00
0.00
0.00
VI
PFOIA
bottomland (R)
1.94
0.00
0.00
0.00
VII
PF01B
bottomland (R)
1.28
233.50
0.00
233.50
VIII
PEMHh
emergent marsh
0.28
308.00
0.00
308.00
IX
perennial stream
0
265.20
0:00
265.20
X
perennial stream
0
374.28
0.00
374.28
. Total:
12.29
2334.52
0.00
2334.52
Section B. There are nine jurisdictional sites on Section B. These are labeled Sites 1A, 1B, 1C,
and 1 through 6. The wetland and surface water impacts are described in Table 4. Sines 1 A, 1 B,
1 C, 1, 2, and 3 are located in the Yadkin River Basin. Sites 4, 5, and 6 are located in the Lumber
River Basin.
Wetland impacts on jurisdictional areas of section B total 8.31 acres in bottomland
forests. Sites 1A, 2, 3, and 4 in Section B predominantly receives their wetland hydrology from
overbank flooding and are considered riverine wetlands. Sites I B, I C', and 1 are non-riverine
and receive their wetland hydrology from adjacent hillside seeps, groundwater intrusion, and
precipitation, Impacts to this section are summarized in Table 7. Compensatory mitigation will
be required for all 8.31 acres of wetland impacts for this section. The Yadkin River Basin
impacts are 2.38 acres non - riverine and 5.68 acres riverine. The Lumber River Basin impacts at
site 4 are 0.25 acres riverine.
The jurisdictional stream impacts, totaling 1,854 on section B, we in perennial streams.
The stream impacts on section B result from culvert/pipe installations..
Construction of this section will result in the discharge of fill into two farm ponds (Sites 5
and 6) that are located in the Lumber River Basin. Site 5 is an excavatted pond, hydraulically
driven by springs and precipitation. Site 5 (299 acres) will be drained and roadway fill will be
placed on the eastern region of the pond. Site 6 (9.37 acres) will be drained and has been
developed into a wetland and stream mitigation site for the Ellerbe Bypass. This pond and future
NCDCT Mitigation Site, named Myrick Pond, was historically created by damming and
impounding an unnamed tributary to Naked Creek. Ellerbe Bypass Lumber River Basin wetland
and stream impacts will be wholly mitigated from this site. Myrick pond will yield 2.45 acres of
wetland restoration mitigation and 1066 feet of stream mitigation. Fuirther mitigation details of
Myrick Pond can be found in the mitigation section of this applications and in the permit

drawings for R- 2231B. In section B, compensatory mitigation will be required off -site in the
Yadkin River Basin for 1,854 feet of stream impacts.
Table 7. Wetland and Stream Impacts for Section B.
1A
PFOIA
bottomland (R)
1.64
1 571
0.00
0.00
571
113
PFO1B
bottomland (NR)
0.28
292
0.00
0.00
292
1C
PF01B
bottomland (NR)
0.24
0.00
0.00
0.00
0.00
I
PFO1B
bottomland (NR)
1.86
663
0.00
0.00
663
2
PF01B
bottomland (R)
1.40
0.00
0.00
0.00
0.00
3
PF01B
bottomland (R)
2.64
328
0.00
0.00
328
Total
Yadkin R.B.
8.06
1854
0
0
1854
4
PF01B
bottomland (R)
0.25
0.00
0.00
0.00
0.00
5
stock pond
0.00
0.00
2.99
0.00
0.00
6
stock pond
0.00
0.00
9.37
(1066)*
0
Total
Lumber R.B.
0.25
1 0
12.36
(1066)*
0
*NCDOT Mvrick Pond wetland and stream mitigation site
Section CA: There are four jurisdictional sites on this section Iabeled Sites 1 through 4. The
wetland and surface water impacts are described in Table 8. Wetland and surface water impacts
are located in the Lumber River Basin.
There are 1.87 acres of jurisdictional wetland impacts on this section. All sites receive
their wetland hydrology from overbank flooding and are considered to be riverine wetlands.
Compensatory mitigation in the Lumber River Basin will be required for all 1.87 acres of
riverine wetland impacts for this section.
The jurisdictional stream impacts, totaling 351 feet (existing channel lost), are in perennial
streams in the Lumber River Basin and result from culvert/pipe installations. Compensatory
mitigation will be required for 351 feet of stream impacts for this section. Impacts to this section
are summarized in Table 8.
As a result of the avoidance and minimization agreement (signed April 19, 2000) by
NCDOT and the resource agencies, dual bridges will be constructed at station 190 +89 (Site IV)
over an unnamed tributary to Naked Creek, an outstanding resource water (ORW). Hand clearing
will be utilized in wetlands versus mechanized clearing.
7

Table 8. Wetland and Stream Impacts for Section CA.
Section CB: There are a total of seven jurisdictional sites on this section, labeled Sites 1 thirough
7. The wetland and surface water impacts are described in Table 9. All wetland and surface; water
impacts are located in the Yadkin River Basin.
Wetland impacts in jurisdictional areas of this section total 6.02 acres. All wetland
systems in Section CB predominantly receive their wetland hydrology from overbank floodling
and are considered to be riverine wetlands. However, several of the wetlands in Section CB may
receive additional saturation from adjacent hillside seeps. Compensatory mitigation will hte
required for all 6.02 acres of wetland impacts for this section.
The jurisdictional stream impacts, totaling 2693 feet on section CB, are in perenniail
streams. The stream impacts on section CB result from culvert/pipe installations. Natural
channel design was developed on sites 3 and 6. The NCDOT expects to receive 1:1 onsite
mitigation credit for the two relocations, yielding 676 feet (423 feet for site 3 and 253 feet for
site 6) of total onsite mitigation credit for section CB. Compensatory mitigation will be requuired
for the remaining 2016 feet of stream impacts for this section. Impacts to this section are
summarized in Table 9.
Table 9. Wetland and Stream Impacts for Section CB.
a
x
�'y(
'
�1
�
p
2CF ati
PFOIA
-
0.56
564
0.00
E .
I
PF01 B
bottomland (R)
1.0
351
0.00
J:) I
II
PFOIB
bottomland (R)
0.18
0.00
0.00
0.00
III
PFOIB
bottomland (R)
0.69
0.00
0.00
0.00
IV
PFOIB
bottomland (R)
0
0.00
0.00
0.00
6
PFOIB
Total:
1.87
351
0.00
351
Section CB: There are a total of seven jurisdictional sites on this section, labeled Sites 1 thirough
7. The wetland and surface water impacts are described in Table 9. All wetland and surface; water
impacts are located in the Yadkin River Basin.
Wetland impacts in jurisdictional areas of this section total 6.02 acres. All wetland
systems in Section CB predominantly receive their wetland hydrology from overbank floodling
and are considered to be riverine wetlands. However, several of the wetlands in Section CB may
receive additional saturation from adjacent hillside seeps. Compensatory mitigation will hte
required for all 6.02 acres of wetland impacts for this section.
The jurisdictional stream impacts, totaling 2693 feet on section CB, are in perenniail
streams. The stream impacts on section CB result from culvert/pipe installations. Natural
channel design was developed on sites 3 and 6. The NCDOT expects to receive 1:1 onsite
mitigation credit for the two relocations, yielding 676 feet (423 feet for site 3 and 253 feet for
site 6) of total onsite mitigation credit for section CB. Compensatory mitigation will be requuired
for the remaining 2016 feet of stream impacts for this section. Impacts to this section are
summarized in Table 9.
Table 9. Wetland and Stream Impacts for Section CB.
a
x
�'y(
'
�1
�
p
PFOIA
Bottomland (R)
0.56
564
0.00
564
2
PFOIB
Bottomland (R)
0.045
0.00
0.00
0.00
3
PFOIB
Bottomland (R)
2.13
755
423
331
4
PFOIB
Bottomland (R)
0.65
0.00
0.00
0.00
5
PF01 B
Bottomland (R)
1.36
479
0.00
479
6
PFOIB
Bottomland (R)
1.02
574
253
321
7
PFOIB
Bottomland (R)
0.25
321
0.00
321
Total:
6.02
2693
676
2016

PROTECTED SPECIES
Plants and animals with Federal classification of Endangered (E) or Threatened (T) are
protected under provisions of Section 7 and Section 9 of the Endangered Species Act of 1973, as
amended. As of January 31, 2003, the U.S. Fish and Wildlife Service (Service) lists nine
federally protected species for Richmond and Montgomery Counties County (Table 10).
Table 10. Federally Protected Species for Richmond and Montgomery Counties
SCIENTIFIC NAME
COMMON NAME
County
STATUS
Acipenser brevirostrum
Shortnose Sturgeon
Richmond
E
Rhus michauxii
Michaux's sumac
Richmond
E
Lasmigonia decorata
Carolina Heelsplitter
Richmond
E
Lysimachia asperulaefolia
Rough- leaved Loosestrife
Richmond
E
Haliaeetus leucocephalus
bald eagle
Montgomery
T
Felis concolor couguar
Eastern cougar
Montgomery
E
Helianthus schweinitzii
Schweinitz's sunflower
Montgomery
E
Echinacea laevigata
Smooth coneflower
Montgomery
E**
Picoides borealis
red - cockaded woodpecker
Both
E
"E" denotes Endangered (a species that is in danger of extinction throughout all or a significant portion of
its range).
"T" denotes Threatened "likely to become endangered within the foreseeable future throughout all or a
significant portion of its range."
" T *" denotes Threatened (proposed for delisting)
* *Obscure record - the date and/or location of observation is
uncertain (USFWS Web site data)
The following paragraphs summarize our fieldwork and the history of concurrence
documentation received from the Service. In addition to existing letters of concurrence
described below we have requested updated concurrence from the Service to confirm the most
recent findings.
Table 10a: USFWS Concurrence Letter Dates
USFWS
Species Specifically
Location
Concurrence Letter
addressed
Dates
November 4, 1991
Eastern cougar, bald eagle
FEIS, page D -4
August 18, 1995
Shortnose sturgeon,
FEIS , page D -6
Michaux's sumac, Rough -
leaved loosestrife, RCW,
Schweinitz's sunflower
January 22, 2002
Carolina heelsplitter
Copy attached
Pending
Smooth coneflower and
Sent to FWS
Michaux's sumac, Rough-
February 2003
leaved loosestrife, RCW,
Schweinitz's sunflower

Biological conclusions of "No Effect" or "Not Likely to Adversely Affect" were reached and
documented for R -2231 for all species as follows:
Bald eagle and eastern cougar: In a letter dated November 4, 1991 the Service
concurred with a finding of no effect for the eastern cougar and the bald eagle.
Further, the letter stated that the NCDOT had satisfied its obligations under Section 7
of the Endangered Species Act of 1973, as amended (16 USC 1531 - 1543). This letter
is on page D -4 of the FEIS. In addition, the nearest suitable foraging/nesting habitat
for the bald eagle is Bluet Falls Lake, which is more than five miles from any point in
the project area. USFWS guidelines specify that development activities should not
occur within distances of up to one mile.
Schweinitz's sunflower, rough - leaved loosestrife, Michaux's sumac, red -
cockaded woodpecker, and shortnose sturgeon: In a letter dated August 18, 1995
the Service concurred that the project is not likely to adversely affect the species or
their habitat or species proposed (in 1995) for Federal listing under the Endangered
Species Act. This letter is on page D -6 of the FEIS. Since 1995 new surveys were
performed to update the status of the species. This information is presented in the
following paragraphs.
Rough - leafed loosestrife and Michaux's sumac: New terrestrial surveys were
conducted on July 31- August 1, 2001 by NCDOT biologists, Jeff Burleson, Lindsey
Riddick, and Clay Willis. Previously identified habitat for rough - leafed loosestrife
and Michaux's sumac was again surveyed extensively. After a thorough search, no
individuals of rough- leafed loosestrife or Michaux's sumac were found.
Schweinitz's sunflower: In October and November 2002 new terrestrial surveys were
conducted for Schweinitz's sunflower. The plant by plant survey was conducted
throughout the entire project even though the species is listed only in the
Montgomery County portion of the project. The survey was completed on November
15, 2002. No individuals were found. In conclusion, project construction will not
affect this species. A copy of the November 2002 Survey is attached to this
application.
Red - cockaded woodpecker: All pine dominated forested tracts within the project
limits were evaluated for habitat suitability on August 2001. Tracts were either less
than 30 years old or had been clear cut.
Smooth coneflower: A letter dated July 7, 2000 from the NCDOT to the USACE
documents the "No Effect" status of the project on this species. A copy of the letter is
attached to this application. In June 1999, NCDOT biologist's, Dale Suiter and Jim
Hauser searched the project vicinity for suitable habitat and none was found. In June
2000 NCDOT biologists Jeffrey Burleson and Clay Willis searched the project
vicinity for suitable habitat and again, none was found.
10

In October and November 2002 a plant by plant survey was made by EcoScience
biologists in areas that had a landscape position corresponding too the landscape
needs of the smooth coneflower. The survey was completed November 15, 2002 and
no individuals were found. The NC Natural Heritage Program database of rare
species and unique habitats does not have any record of smooth coneflower within the
project vicinity. In conclusion, project construction will not affect this species. A
copy of the November 2002 Survey is attached to this application.
Carolina heelsplitter: In a letter dated January 22, 2002 the Service concurred that
construction activities carried out in conjunction with project R -2231 are "Not Likely
to Adversely Affect" the Carolina heelsplitter. A copy of the letter is attached to this
application.
CULTURAL RESOURCES
Arch: A memorandum dated October 8, 1996 documents that there are no archaeological
sites eligible for the National Register of Historic Places and that the archaeological portion of
the Section 106 compliance was complete for the project as proposed. A copy of that
memorandum is attached to this permit application. A letter dated March 6, 2000 documents that
an archaeological report was submitted to the SHPO for project R -3303. No comments were
received from the SHPO. A copy of that letter is attached to this application.
Historic: On September 30, 1996 the SHPO concurred that the properties under consideration
were not eligible for listing in the National Register of Historic Places. Further confirmation was
provided by the SHPO in a letter dated August 7, 2000 stating that they had no comment on the
permit application for R -2231 submitted at that time. A letter signed by the SHPO December 23,
1999 determined that there were no effects on National Register listed property within the area of
potential effect for project R -3303. Copies of these letters are attached to this application.
UTILITY IMPACTS
In addition to impacts from the construction of the road, impacts often result from the need to
move existing utilities. These impacts to jurisdictional areas result from activities that `but for"
the construction of the road would not have occurred. The following paragraphs describe and
quantify the "but for" impacts. Occasionally a utility company will decide to upgrade a line or
construct a new line near the proposed highway right of way. The impacts from these activities
would have occurred whether or not the road project was constructed. Therefore, they do not fall
under the "but for" scenario. In those cases the utility company is responsible for obtaining any
permits and the impacts are not addressed in the highway project application. However, if the
information is available to us we will attempt to identify these non - "but for" actions so that you
are kept informed about the actions that may occur near our right of way.
R -2231 A
1) Plan sheet 10 & 11: There is an existing overhead CP &L power line, angling across the -L-
line, at approximate station 37 + 10 that will have a pole installed on the right and left side of -
L- at the CIA fence, with one pole inside the proposed C/A fence being removed.

2) Plan sheet 24: Pee Dee EMC will be replacing an existing overhead power line that crosses
the wetlands on the right side of -Y4- on parcel 74.
3) Plan sheets 24, 25 & 26: Pee Dee EMC will be installing a new line, paralleling -Y] -, on the
right side within 10 feet of our easement as the easement crosses the wetlands. The hig1hway
contractor will be doing the clearing and it is expected that Pee Dee EMC will have trucks within
the wetlands area but should not be outside the footprint of the project
R -2231 B
1) Plan Sheets 12, 13 & 14 (ROW Plan Sheets 6, 7 & 8) CP &L will be installing an overhead
power line along the right side of -SRA -. This will be a joint use line for Pee Dee EMC &
CP &L. Clearing and grubbing, by the CP &L contractor, within the wetlands will be necessary
for this line. However, all work will be within the proposed right of way.
2) Plan Sheets 12, 13 & 14 (ROW Plan Sheets 6, 7 & 8) Ellerbe Telephone will be plac ling an
underground line on the left side of -SRA -. Clearing and grubbing by the Highway contractor in
the wetlands will be necessary. However, all work will be within the proposed right of %vay.
R -2231 CA
At the present time, there are no utility relocations, through wetlands. It is possible that Pee Dee
EMC will have to build an overhead line through the wetlands on the right of -L- ( outsfide the
proposed CIA) if Pee Dee EMC can not get the necessary easements on parcels 2, 4, 5 & 901 on
the left side of -L -. Pee Dee EMC presently has a line angling across -L- at station 176 -+ 80.
This line will have to be relocated due to the distance angling across the CIA. It is expected the
relocation will be accomplished by building an overhead line paralleling the CIA fence ((left side
of -L -) across parcels 2, 4, 5 and 901. The proposed line will then make a 90 degree turm and
cross the roadway at station 177 + 80 to tie back into their existing pole on the bottom kft corner
of sheet 5 thus avoiding the wetlands.
R -2231 CB At the present time, there are no utility relocations through wetlands.
FEMA COMPLIANCE
According to the NCDOT Hydraulics engineers there is no FEMA involvement Xwith this
project. A detailed description of the FEMA Zone A crossing involvement is located in tthe DEIS
on page 4 -26 and 4 -27 and supports the "No FEMA Involvement "status for this project.
MITIGATION OPTIONS
The Corps of Engineers had adopted, through the Council on Environmental Quaility
(CEQ), a wetland mitigation policy that embraces the concept of "no net loss of wetlancils" and
sequencing. The purpose of this policy is to restore and maintain the chemical, biologicml, and
physical integrity of the Waters of the United States. Mitigation of wetland and surface water
impacts has been defined by the CEQ to include: avoiding impacts, minimizing impacts,,
rectifying impacts, reducing impacts over time and compensating for impacts (40 CFR 11508.20).
Executive Order 11990 (Protection of Wetlands) and Department of Transportation Ordcer
5660.1 A (Preservation of the Nations Wetlands), emphasize protection of the functions sand
values provided by wetlands. These directives require that new construction in wetlands be
12

avoided as much as possible and that all practicable measures are taken to minimize or mitigate
impacts to wetlands.
The NCDOT is committed to incorporating all reasonable and practicable design features
to avoid and minimize wetland impacts, and to provide full compensatory mitigation of all
remaining wetland impacts. Avoidance measures were taken during the planning and
DEIS/FEIS, ROD phases; minimization measures were incorporated as part of the project design.
AVOIDANCE: All wetland areas not affected by the project will be protected from unnecessary
encroachment.
• No staging of construction equipment or storage of construction supplies will be allowed in
wetlands or near surface waters.
• Avoidance of Rocky Ford Branch Wetlands: The preliminary design was shifted
approximately 400 to 600 feet to the east to avoid impacting the 5.3 acres of wetlands along
Rocky Ford Branch. This shift resulted in the project bisecting Myrick's Pond (R -2231B Site
6), which will be used as on -site mitigation for wetland and stream impacts in the Lumber
River Basin.
MINIMIZATION: Minimization includes the examination of appropriate and practicable steps
to reduce the adverse impacts. Many of the following minimization commitments were originally
presented to the agencies during the August 27, 2002 pre - application meeting. Minimization
techniques were implemented as follows:
•
High Quality Waters BMP: NCDOT has committed (ROD) that "construction related
impacts associated with the proposed action will be minimized through the use of High
Quality Waters erosion and sediment control measures. All practical measures have been
taken to minimize environmental harm."
•
Slopes: Fill slopes in wetlands are at a 2:1 ratio.
• Ditching: It is the policy of the NCDOT to eliminate lateral ditching in wetlands as much as
possible, thus preserving the hydrology of adjacent wetlands.
Median Width: The project was designed using a 46 -foot median width.
•
R-223 1A, Site IIA: At the pre - application meeting held August 27, 2002 (minutes attached),
DWQ asked why 2:1 side slopes (w/ guardrail) could create more impact than flatter side
slopes (w /o guardrail). NCDOT explained that the use of guardrail requires an additional
shoulder width of three feet. This often produces more impact than if a flatter slope was
used, especially in shallow fill situations. It was also pointed out that the whole wetland area
was shown as impacted, regardless of slope. The agencies agreed that there was no further
opportunity for minimization at this site. .
• Section A Site III Station 26 +40 —L- (Rt): The 900 mm RCP at Station 26 +40 —L- (Rt) was
relocated to an energy dissipater basin that consists of a 2GI at Station -- L -27 +00 M which
minimized impacts to water quality.
13

• Section A Site IV Station 29 +60: A preformed scour hole (PSH) was added at the outlet of
the 375 mm rep at station 29 +60 Rt to minimize the impacts on water quality.
Section A Site V Station 34 +55 (Rt): The 400 mm CSP was realigned perpendicular to
centerline which resulted in the discharge being located away from the wetland thus
minimizing impacts to the wetland.
Section A Site VII Station 46 +35 to 46 +80: Impacts to the wetlands was minimized by
replacing the funnel drain at Station 46 +00 —L= (Rt) with a 2GI and taking the drainage to the
median inlet thus eliminating outlet into the wetland. In addition, the ditch from Station
46 +35 to 46 +60 —L- (Rt) was eliminated by adding another cross pipe to take flow from ditch
(Rt) to stream (Lt).
Adding a PSH at Station 46 +80 —L- (Lt) at the end of the lateral ditch, further
minimized impacts to water quality.
• Section A Site VIII Station 52 +60: adding a PSH at Station 52 +60 —L- (Lt) at the end of the
lateral ditch, further minimized Impacts to water quality.
• R -223 1B Site 1 from Station 92 +32 —L- (Lt) to Station 90 +80 —L- (Lt): The outlet at this site
was relocated and an energy dissipater installed to minimize the water quality impacts at this
site.
R -223 1B Site 6: The pond will be drained prior to construction of the road so the necessary
drainage structures for the Type A Sediment Basin can be constructed. The draining will be
accomplished by pumping, which would control the rate of pond drawdown. This would
minimize the impacts to the downstream water quality and the downstream wetlands by
controlling the velocity and sediment load from the pond release. The Type A Sediment
Basin will function during the construction of the road. The dam and basin structures will be
removed completely following construction of the road and a short portion of the channel
restored to a functioning stream. This stream restoration is described in greater detail in the
attached Myrick Pond Mitigation Plan.
R -2231 CA Site 1 Station 172 +75 to 174 +10: Impacts to wetlands and water quality at this
Outstanding Resource Water (ORW) site were minimized by redesigning the project in the
following manner. We redirected the outlet of the inlet at Sta. 172 +75 —L- M to flow into the
system at Sta. 174 +00 —L -. We also redirected the outlet at Sta. 174 +10 —L- Lt to flow to the
system at Sta. 174 +00 —L -. The system at Sta. 174 +00 ---L- was then discharged into a
Hazardous Spill Catch Basin along with the system at Sta. 173 +65 —L- Rt. Therefore, all the
storm water from the roadway at this site will flow through the Hazardous Spill Catch Basin
and across the Energy Dissipater at the end of the basin's outlet pipe before the water filters
down to the wetlands in a diffuse manner at a non - erosive velocity. In addition, a PSH will
be incorporated into the design at -Sta. 173 +00 —L- (Lt) as requested by the DWQ.
• R -223 l CA Site II Station 176 +80 to 179 +00: This system is picking up the drainage from a
gentle swell on the left side of the proposed project. This feature is not a stream. On the right
14

side at station 177 +00 is a wetland that drains into Naked Creek. We revised the system at
Station. 177 +10 —L- to outlet outside of the wetland and added an energy dissipater at the end
of the system so the discharge will flow into the wetland diffuse and at an non- erosive
velocity. This design change results in the minimization of impacts to both the wetland and to
the water quality.
• R- 2231CA Site III Station 188 +20 to 189 +40: This system includes a wetland that drains into
Naked /Creek (ORW). We have minimized the impacts on wetlands by revising the skew of
the 750mm pipe at this site to align with the wetlands. This change will ensure that the
wetland on the right side of the proposed road at Station 189 +25 (more or less) will have the
hydrology to remain a jurisdictional wetland. In addition, the v -ditch on the left side of the
road ends in a PSH at Station 188 +20 instead of the in the wetland as previously designed.
The other end of the v- ditch, which is actually located in Site IV, terminates in another PSH
located outside the wetland at about Station 190 +40. Thus the impacts on both water quality
and wetlands have been minimized.
R_2231CA Site IV, Station 191 +00: Temporary Work Bridge: The NCDOT will use a
temporary work bridge, versus a temporary causeway to construct the new dual bridges on
section CA over the tributary to Naked Creek. A PSH will be incorporated into the design at
Stationl73 +00 —L- (Lt) as requested by the DWQ.
The bridge was designed with no deck drainage. All water from the bridges flow to the
Hazardous Spill Catch Basin at Sta. 192 +30 —L- Right. An energy dissipater was added to the
end of the outlet pipe for the basin to diffuse the discharge at a non - erosive velocity.
• R- 2231CB Site 1: PSH were installed at left of 11 +65 ramp `IB' and right of 11 +70 ramp `IC
and an energy dissipater left of 11 +20 ramp `IB' to minimized water quality impacts.
R- 2231CB Site 2 Site 2: a PSH at 450 outlet was inserted and the base tail ditch removed. In
addition at Station 249 +60 —L- (Rt) in the ditch at the wetland the ditch was flattened and
stone added to reduce the velocity to less than 2 ft/sec for the 10 year event.
wetland.
R- 2231CB Site 5: the previous design had a 400 mm CSP, which provided roadway drainage
directly into the unnamed tributary of Big Mountain Creek. We relocated this 400 CSP
outlet to Station 260 +90 —L- (Rt) with a PSH about 15 m (49 feet) south of the wetland and
45 m (147 feet) south of the UT to Big Mountain Creek. The box and the lateral ditch now
end at the PSH thus minimizing water quality impacts.
• R- 2231CB Site 6: We relocated the 400 CSP outlet to Sta. 268 +50 —L- (Rt) and added a
PSH. This removed the end of the pipe from a wetland thus minimizing water quality impacts
from road runoff to the wetland. The 450 CSP outlet at Sta. 269 +10 —L- (Rt) now ends in a
PSH, which minimizes impacts to the wetland from road runoff.
R -2231 CB Site 6: The ditch at Station 271 +45 —L- (Lt) was removed. The 375 mm CSP
outlet at Station 271 +90 --L- (Rt) was eliminated and routed to the 750 mm CSP outlet. This
outlet has been relocated to empty into an existing sediment basin.
15

COMPENSATION: The primary emphasis of the compensatory mitigation is to reestablish a
condition similar to that that would have existed if the project were not built. As previously
stated, mitigation is limited to reasonable expenditures and practicable considerations related to
highway operation. Mitigation is generally accomplished through a combination of methods
designed to replace wetland functions and values lost as a result of construction of the project.
These methods consist of creation of new wetlands from uplands, borrow pits, and other non -
wetland areas; restoration of wetlands; and enhancement of existing wetlands.
FHWA STEP DOWN COMPLIANCE: All compensatory mitigation must be in
compliance with 23 CFR Part 777.9, "Mitigation of Impacts" that describes the actions that
should be followed to qualify for Federal -aid highway funding. This process is known as the
FHWA "Step Down" procedures:
1. Consideration must be given to mitigation within the right -of -way and should include
the enhancement of existing wetlands and the creation of new wetlands in the highway
median, borrow pit areas, interchange areas and along the roadside.
2. Where mitigation within the fight-of-way does not fully offset wetland losses,
compensatory mitigation may be conducted outside the right -of -way including
enhancement, creation, and preservation.
The project has been designed to avoid and minimize impacts to jurisdictional areas throughout
the NEPA and design processes. Detailed descriptions of these actions are presented elsewhere
in this application. Compensatory mitigation for the remaining impacts consist of:
2.45 acres of on -site wetland restoration at the Myrick Pond Mitigation Site for the
Lumber Basin Wetland impacts;
• 55.38 acres of off -site wetland riverine restoration at the Key Branch Mitigation Site for
the Yadkin Basin wetland impacts;
• 702 feet of on -site stream relocation using natural channel. design techniques ast the
Myrick Pond Mitigation Site for the Lumber Basin Stream Impacts.
• 675.85 feet of on -site stream relocation using natural channel design techniques at Site 3
and 6 of R -2231 CB for mitigation of stream impacts in the Yadkin Basin.
• 6183 feet of stream mitigation from the Key Branch Mitigation Site for strearm impacts in
the Yadkin Basin.
• 6966 LF of stream mitigation from the following Full Delivery Stream MitigaGuon sites.
• Skelly & Loy Site 1 (Bennett) 10,540 LF (see Table 11 for details)
• Skelly & Loy Site 2 (Saron Church) 390 LF (see Table 12 fmr details)
• Skelly & Loy Site 6 (Poole Rd.) 722 LF (see Table 13 fiDr details)
• Skelly & Loy Site 17 (Haithcock) 4,568 LF (see Table 14 fmr details)
TOTAL 16,220 LF
16

The project will impact 7249 feet of stream in the Yadkin River basin. We will provide 676 feet
of onrsite stream relocation (1:1) as noted above. We will mitigate for the rest of the impacts at a
ratio of 2:1. Therefore, we will need to'provide offsite stream mitigation for 6573 linear feet of
stream:
Based on the ratios described in the NCDENR -DWQ May 10, 2000 Interim Internal DW
Policies on Stream Mitigation Options and Associated_Macrobenthos Monitoring Manual, we
propose to provide 6573 feet of stream restoration [6183 linear feet. from Key Branch and 390
linear feet from the Poole Road Full Delivery site (Site 6)]. We will provide the remainder of the
mitigation as enhancement credits from the Bennett Road Site (Site 1), the Saron Church Road
(Site 2) and Haithcock Road.
The following enhancement credits were derived from the data in Tables 11 -14. Since we
already have proposed a 1:1 credit of restoration, the credit ratios in Tables 11 -14 have been
halved in order to obtain the correct number of linear feet/credits that will result in a true 2 :1
mitigation of impacts as established by the EPA directives for Mitigation Banks. We will
provide 6573 linear feet of stream enhancement [5637 from the Bennett Road site (Site 1) and
195 feet from Saran Church Road (Site 2) and 741 linear feet from Haithcock Road Site (Site
17)].
We will also commit the remainder of the stream mitigation available at the Poole Road Site and
Haithcock Road site to be held in as a reserve for impacts to the Ellerbe Bypass streams. These
sites will be used if the targeted sites do not provide success or if there are any other reasons
identified by the agencies or the NCDOT. Options have been purchased for all the Skelly & Loy
sites listed above.
STREAM MITIGATION SITE SUMMARIES
The final mitigation plans for the four stream mitigation sites were hand delivered to the
USAGE, the NCDWQ, the NCWRC and the USFWS in January and February 2003 by Skelly
and Loy. Copies of the letters of transmittal of these plans can be found appended to this
application.
Site #1 —Bennett Road
The stream restoration work at Bennett Road will stabilize three unnamed tributaries of
Little Mountain Creek. Livestock allowed to graze adjacent to the stream and removal of the
riparian corridor are jeopardizing the long -term stability of these tributaries. Grading and
excavation adjacent to the streams will provide the streams with much needed flood prone width,
and grade control structures will maintain the vertical and horizontal alignments of the
tributaries. Supplemental riparian vegetation will be added along the stream corridors, and
conservation easements will protect these valuable natural resources indefinitely.
17

Table 11: Potential Mitigation from Site 1
STREAMBANK STABILIZATION AND
STREAM
MITIGATION CREDIT
RIPARIAN PLANTINGS
ENHANCEMENT
CREDIT
LENGTH
Tributary 1
520 LF
Tributary 2
1,680 LF
Mitigation Credit Ratio
3 to 1
SUB -TOTAL
2,200 LF
734 LF
VEGETATION PLANTING PLUS LIVESTOCK
STREAM EN-
MITIGATION CREDIT
EXCLUSION
HANCEMENT
LENGTH
Tributary 1
820 LF
Tributary 2
1,480 LF
Tributary 3
1,140 LF
Little Mountain Creek
4,900 LF
Mitigation Credit Ratio
4 to 1
SUBTOTAL
8,340 LF
2,085 LF
TOTAL MITIGATION
12,819 LF
Site #2 — Saron Church Road
The unnamed tributary of Big Mountain Creek near Saron Church Road has been
impacted by livestock grazing adjacent to the stream and by the complete removal of the riparian
corridor. The riparian area of this stream will be re- planted with natural vegetation to provide
stability to the streambanks, fenced to prevent access by cattle and other livestock, and placed
into a conservation easement to protect the restoration work.
Table 12: Potential Mitigation from Site 2.
VEGETATION PLANTING PLUS
STREAM
MITIGATION
LIVESTOCK EXCLUSION
ENHANCEMENT
CREDIT
LENGTH
Stream Enhancement Length
390 LF
Mitigation Credit Ratio
4 to 1
TOTAL MITIGATION
390 LF
. 98 LF
Site #6 — Poole Road
The main stem of Steely Branch at Poole Road is an entrenched, or down -cut, stream
system (stream type G). This stream is also devoid of the sinuosity or meandering pattern
usually associated with natural streams due to historical human activities that moved and
straightened the stream. To correct these impairments, Steely Branch will be relocated,
reconstructed, and elevated to allow the stream to have access to the natural flood plain. Grade
control structures will be built to prevent the stream from down - cutting again. After the full
reconstruction, this reach of Steely Branch will be a stable C stream with a wide flood plain and
supplemented riparian vegetation, and will be protected in perpetuity through the establishment
of a conservation easement.
18

Table 13: Potential Mitigation from Site 6
STREAM RESTORATION
STREAM RESTORATION
MITIGATION
Segment 2
Mitigation Credit Ratio
LENGTH
CREDIT
Poole Road Project Site
722 LF
2,007 LF
Mitigation Credit Ratio
Stream Enhancement Length
1 to 1
TOTAL MITIGATION
722 LF
722 LF
Site #17 — Haithcock Road
Middle Prong Hamer Creek is an entrenched stream system (stream type G) that is
negatively impacted by cattle that are actively grazing on the stream banks and loafing within the
stream. The stream banks show evidence of mass wasting of sediment, and the profile of the
stream is unnaturally convex and lacking the natural sequence of riffles and pools. To restore
Middle Prong Hamer Creek, the stream will be reconstructed on the flood plain that surrounds its
existing location, thereby providing valuable sinuosity and flood prone area width. Grade
control structures will be built to prevent the stream from down cutting, riparian vegetation will
be planted, and a fenced conservation easement will protect the stream in perpetuity.
Table 14: Potential Mitigation at Site 17
Stream Restoration
Stream Restoration Length
Mitigation Credit
Segment 2
Mitigation Credit Ratio
2,007 LF
1 to 1
SUBTOTAL
2,007 LF
2,007 LF
Vegetation Planting
Plus Livestock Exclusion
Stream Enhancement Length
Mitigation Credit
Segment 1
Segment 3
Mitigation Credit Ratio
1,375 LF
1,186 LF
4 to 1
SUBTOTAL
2,561 LF
641 LF
[TOTAL MITIGATION
4,568 LF
2,648 LF
REGULATOR' APPROVALS
Application is hereby made for a Department of the Army Individual Section 404 Permit
as required for the above- described activities. We are also hereby requesting a 401 Water
Quality Certification from the Division of Water Quality. In compliance with Section
143- 215.3D(e) of the NCAC, we have enclosed a check for $475.00 to act as payment for
processing the Section 401 permit application. We are providing seven copies of this application
to the North Carolina Department of Environment and Natural Resources, Division of Water
Quality, for their review.
19

If you have any questions or need additional information please call Ms. Alice N. Gordon at
(919) 733 -7844 extension 288.
Sincerely,
M ' -T2"/
Gregory J. Thorpe, Ph.D.
Environmental Management Director, PDEA
cc: Mr. David Franklin, USACE, Wilmington (Cover Letter Only)
Mr. John Dorney, NCDWQ (7 copies)
Mr. David Cox, NCWRC
Mr. Ron Sechler, NMFS
Ms. Kathy Matthews, USEPA
Mr. Garland Pardue, Ph.D., USFWS
Mr_ N. L. Graf, P.E., FHWA
Mr. Jay Bennett, P.E., Roadway Design
Mr. Omar Sultan, Programming and TIP
Ms. Debbie Barbour, P.E., Highway Design
Mr. David Chang, P.E., Hydraulics
Mr. Greg Perfetti, P.E., Structure Design
Mr. Mark Staley, Roadside Environmental
Mr. W. F. Rosser, P.E. (Div. 8), Division Engineer
Mr. Art King (Div. 8), Division Environmental Officer
20