20201371 Ver 1_7_A-0009C_FONSI_final_Signed_20211216

FINDING OF NO SIGNIFICANT IMPACT
Corridor K, Appalachian Development Highway System
US 129 at Robbinsville to NC 28 at Stecoah
Graham County, North Carolina
STIP Project No. A-0009C
WBS Element No. 32572.1.FS10
FA No. APD-0074(178)
Photo Source: Graham County Travel & Tourism (2018)
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
FINDING OF NO SIGNIFICANT IMPACT
Submitted Pursuant to the National Environmental Policy Act
42 USC 4332(2)(c) and 49 USC 303
Corridor K, Appalachian Development Highway System
US 129 at Robbinsville to NC 28 at Stecoah
Graham County, North Carolina
STIP Project No. A-0009C
WBS Element No. 32572.1.FS1
FA No. APD-0074(178)
FEDERAL HIGHWAY ADMINISTRATION
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION, HIGHWAY DIVISION 14
_________________________________________________________________
Date For John F. Sullivan, III, PE
Division Administrator
Federal Highway Administration
_________________________________________________________________
Date Wanda H. Austin, PE, CPM
Division Engineer
NCDOT Division of Highways, Division 14
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
3/19/2021
3/19/2021
FINDING OF NO SIGNIFICANT IMPACT
Submitted Pursuant to the National Environmental Policy Act
42 USC 4332(2)(c) and 49 USC 303
Corridor K, Appalachian Development Highway System
US 129 at Robbinsville to NC 28 at Stecoah
Graham County, North Carolina
STIP Project No. A-0009C
WBS Element No. 32572.1.FS1
FA No. APD-0074(178)
PREPARED FOR
NCDOT HIGHWAY DIVISION 14
PREPARED BY
STANTEC CONSULTING SERVICES INC.
TGS ENGINEERS
_________________________________________________________________
Date Amy C. Sackaroff, AICP
Project Manager
Stantec Consulting Services, Inc.
_________________________________________________________________
Date Stacy B. Oberhausen, PE, CPM
Project Manager
NCDOT/TGS Engineers
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
3/19/2021
3/19/2021
Photo Source: Graham County Travel & Tourism (2018)
A NOTE TO THE READER
What is a Finding of No Significant Impact?
This Finding of No Significant Impact (FONSI) follows the approval of the Corridor K Improvements Environmental Assessment (EA), signed on
August 26, 2020, for NCDOT STIP Project No. A-0009C. The EA evaluated a two-lane design option with passing and climbing lanes with the goal
of finding a ‘right-size’ design that best addressed mobility and reliability needs while minimizing impacts. The primary purpose of an EA is to help
decision-makers determine whether a FONSI is appropriate for documentation of project impacts or if an Environmental Impact Statement (EIS) is
needed.
The Federal Highway Administration (FHWA) and the North Carolina Department of Transportation (NCDOT) have determined that the Improve
Existing Alternative (Alternative 1) will have no significant impact on the human or natural environment. The Finding of No Significant Impact
(FONSI) is based on the Environmental Assessment (EA) and contains the errata sheets to the EA, and public, environmental resource agencies,
and environmental advocacy groups comments on the EA, which have been independently evaluated by FHWA and determined to
adequately and accurately discuss the need, environmental issues, and impacts of the proposed project and appropriate mitigation measures.
The EA, together with the information contained in this FONSI, provides sufficient evidence and analysis for determining that an Environmental
Impact Statement (EIS) is not required. The FHWA takes full responsibility for the accuracy, scope and content of the referenced EA and Section
4(f) documentation.
This FONSI explains:
Changes in the proposed project,
impacts, or mitigation measures resulting
from comments received
Agency coordination that has occurred
since the approval of the EA
Documentation of pertinent comments
received on the EA and responses to the
comments
What’s in this document?
The FONSI includes: any changes in the proposed action, impacts, or
mitigation measures resulting from comments received during the public
hearing and thirty (30) day comment period; agency coordination that
has occurred since the approval of the EA, notably the identification of
the Least Environmentally Damaging Practicable Alternative; avoidance,
minimization, and mitigation measures; and,documentation of pertinent
comments received on the EA and responses to the comments.
What happens next?
This FONSI completes the NEPA environmental review process. The
project will now continue into final design, right-of-way acquisition, and
construction. Right-of-way acquisition is scheduled to begin in August
2021 with construction beginning in August 2022. Visit the Corridor K
project website for project updates and contact information.
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This Finding of No Significant Impact is available online at the project website:
https://www.ncdot.gov/projects/corridor-k
and can be viewed at the following locations:
NCDOT District 14 Office
191 Robbinsville Road
Andrews, NC 28901
NCDOT Graham County Maintenance Yard
2447 Tallulah Road
Robbinsville, NC 28771
If you have any comments about the proposed project, please send your comments to:
Corridor K Project Management Team
c/o TGS Engineers
706 Hillsborough Street, Suite 200
Raleigh, NC 27603
[e-mail]
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PROJECT COMMITMENTS

Corridor K, Appalachian Development Highway System
US 129 at Robbinsville to NC 28 at Stecoah
Graham County, North Carolina
STIP Project No. A-0009C
WBS Element No. 32572.1.FS10
FA No. APD-0074(178)

The following Project Commitments are either updated or newly-added since distribution of the
Environmental Assessment. Any clarifying or status comments are indicated by text in italics.

Division 14 Construction and Geotechnical Unit – Acidic Rock
Excavation in the ZWE unit is being studied under thin section microscopy and NNP (acid-base accounting) as part of
current geotechnical investigations that run through Summer 2021. Mitigation is determined by acid-producing-potential
levels. If needed, the North Carolina Department of Transportation (NCDOT) will develop a Project Special Provision to
deal with any necessary handling and treatment of acidic rock.

UPDATE: Based on testing completed in summer and fall 2020:
1. No specific treatment or material handling will be required for excavation of this project.
2. No specific water chemistry testing or monitoring is recommended with respect to this issue, outside of other
erosion control and water quality preservation items required for the project.
3. Durable excavated rock material, if approximating Class I or II rip rap, or Class VII in the NCDOT Standard
Specifications may be used to construct 1.5:1 rock embankments parallel to streams, if needed to reduce the
project footprint.

Division 14 Construction and Geotechnical Unit – Subsurface Investigations
If additional geotechnical investigations are needed, subsurface investigations, including borings, will be conducted in
accordance with the current NCDOT Geotechnical Unit Guidelines and Procedures Manual.

Division 14 Construction – Waste Material
Hazardous waste material is anticipated to result from construction. NCDOT will not place hazardous waste in areas with
jurisdictional resources.

UPDATE: Inert waste (e.g., soil, rock, debris) and any hazardous waste generated or encountered by construction will be
handled in accordance with 2018 (or current) Standard Specifications for Roads and Structures including Section 107-
25, 802, and other applicable sections to prevent incidental environmental impacts.
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Finding of No Significant Impact March 2021 Green Sheet - Project Commitments
STIP A-0009C Page 2 of 7
Division 14 Construction – Trout Streams
The Wildlife Resources Commission (WRC) will coordinate with NCDOT on moratorium needs during further project
development or during project permitting. Trout supporting streams and a 25-foot buffer will be identified on erosion
control plans and later delineated in the field so that the contractor avoids disturbance in those streams and their buffers
during the prescribed moratorium period. A trout buffer variance, most likely along Sweetwater and Stecoah creeks, may
also be required on the project and coordinated with the Division of Environmental Quality (DEQ), Division of Land
Resources.

Implement Guidelines for Construction of Highway Improvements Adjacent to or Crossing Trout Waters in North Carolina
during design and construction.

Division 14 Construction – FEMA Coordination
This project involves construction activities on or adjacent to FEMA-regulated stream(s). Therefore, the Division shall submit
sealed As-built construction plans to the Hydraulics Unit upon completion of structure construction, certifying that the
drainage structure(s) and roadway embankment that are located within the 100-year floodplain were built as shown in
the construction plans, both horizontally and vertically.

Division 14 Hydraulics Unit – FEMA Coordination
The Hydraulics Unit will coordinate with the NC Floodplain Mapping Program (FMP) to determine status of project with
regards to the applicability of NCDOT’s Memorandum of Agreement (MOA), or approval of a Conditional Letter of Map
Revision (CLOMR) and subsequent final Letter of Map Revision (LOMR).

Division 14 Project Development – Hazardous Spill Basins
Investigate on the potential implementation of hazardous spill basins at Hydraulic Sites 2 and 3 during final design.

UPDATE: Potential implementation of hazardous spill basins to be determined during final design of proposed drainage
improvements that fall within a half mile of the critical water supply boundary for the Town of Robbinsville.

Division 14 Project Development – Vegetation
Herbicide treatments will be coordinated with the US Forest Service on the road easement.

Division 14 Project Development Team; Biological Surveys Group – Indiana bat and Northern long-eared bat
UPDATE: NCDOT commits to removing trees required for the project during October 15th to April 15th, avoiding impacts to
potentially roosting bats. Additionally, surveys for bats and evidence of roosting bats during surveys on July 8-9, 2019,
returned signs of bat usage at one bridge site, which will not be impacted by the proposed work.
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STIP A-0009C Page 3 of 7
NCDOT commits to no additional permanent lighting to the project area; limiting temporary lighting and night work to the
single area needed for the wildlife passage/Appalachian Trail bridge, to be completed over a few nights between
November and March; and demolition of man-made structures only during the winter or after confirming the absence of
roosting bats.

Division 14 Construction and Planning and Programming – Section 7 ESA
If the golden-winged warbler becomes a listed species, NCDOT and FHWA will fully comply with Section 7 of the
Endangered Species Act.

Winter tree clearing (October 15 – April 15) on the project for the purposes of rare bat habitat protection will also help
avoid direct impacts of the project on nesting birds such as golden-winged warbler.

Habitat enhancement in the form of forest clearing or select cutting/thinning will be pursued in two locations to mitigate
habitat losses from the project. The primary location is adjacent to the Stecoah Gap early successional habitat/breeding
habitat. Additionally, select clearing will be pursued in habitat that once supported a breeding pair of golden-winged
warblers near the intersection of NC 143 with NC 28. NCDOT will provide a one-time treatment of non-native invasive
vegetation within the habitat enhancement areas. Planting of native vegetation will focus on species composition
favored by golden-winged warbler and be undertaken in the enhancement areas, as needed, and on and in vicinity of
AT land bridge.

Division 14 Project Development – Golden-Winged Warbler Conference Opinion
A Section 7 conference opinion for golden-winged warbler (current candidate species) is under development and will be
completed before construction authorization.

Division 14 Project Development – Archaeology
Section 106 effects determinations pending the results of an intensive archaeological survey report for the Selected
Alternative. The results of the intensive study and the project’s effects on archeological resources will be assessed by
NCDOT, in coordination with Section 106 consulting parties, in accordance with the processes and procedures described
in the Section 106 Programmatic Agreement (PA) developed for use through final design, right of way and construction.
The PA is contained in Appendix B.

Archaeological Sites 31GH34, 31GH78, 31GH94, 31GH599, 31GH673, and 31GH691 are eligible for listing on the National
Register of Historic Places (NRHP) under Criterion D and currently fall within the Selected Alternative’s archaeological
Area of Potential Effects (APE) for the proposed project. Although avoidance is recommended, the sites do not warrant
preservation in place.
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Archaeological Site 31GH46, which also falls within the Selected Alternative APE, is NRHP-eligible under Criterion D. This
site will be avoided during the construction phase of the project including any staging activities. If avoidance is
determined not possible, further consultation with NC-HPO and consulting parties is required.

In addition, within the Selected Alternative portion of the APE, archaeological Site 31GH45 could not be assessed for the
NRHP due to denial of access by the landowner, while Archaeological Site 31GH723 could not be fully assessed for the
NRHP due to adjacent impervious material and other disturbances. Subsurface testing (including additional deep trench
testing) at these sites and other properties, such as those owned by USFS, that were inaccessible during the survey will be
done once right-of-way and easements are acquired by NCDOT or when right-of-access is granted.

If these sites or any newly identified sites are determined eligible for the NRHP, NCDOT will coordinate with the North
Carolina State Historic Preservation Office (NC-HPO) and other consulting parties as identified on appropriate mitigation.
All potential mitigation at these sites will be covered in the 106 Form for adverse effect and incorporated in the
stipulations of a Memorandum of Agreement (MOA).

Additional eligible sites (31GH92, 31GH664, 31GH703, and 31GH716) under Criterion D and (31GH696 and 31GH705) under
Criterion A along with unassessed sites (31GH35, 31GH625, 31GH700, 31GH709, 31GH729, and 31GH731), which were
identified during the Corridor K archaeological investigations, are located outside of the Selected Alternative’s portion of
the undertaking’s APE. If determined at a later date that the above-mentioned sites are to be impacted by the project,
they will be addressed in accordance with the procedures outlined in the Section 106 project PA.

UPDATE: NCDOT and FHWA will continue to seek alternatives or modifications to the undertaking that could avoid or
minimize effects to these sites. If through ongoing consultation, any of these sites are determined to be adversely
affected by the undertaking and data recovery is determined to be the best course of action to mitigate the adverse
effects, NCDOT will develop Data Recovery Plans (DRPs) for these nine sites through consultation with the SHPO and the
THPOs (or their designee) of the EBCI, CN, UKB, MCN, Catawba Nation, and the A-0009C CR Task Force.

Archaeological Site is also NRHP-eligible under Criterion A.

Refinements to the design plans and APE may require that other sites be subjected to additional investigation to
determine their respective NRHP eligibility. This currently includes but is not limited to sites 31GH35, 31GH45, 31GH625,
31GH703, 31GH723, 31GH729 and/or 31GH731. If Sites 31GH35, 31GH45, 31GH625, 31GH703, 31GH723, 31GH729 and/or
31GH731, and any other sites are determined eligible for the NRHP under Criterion D through further testing within the
Undertaking’s APE and they are determined through continued consultation to not warrant preservation in place, NCDOT
and FHWA will continue to seek alternatives or modifications to the undertaking that could avoid, or minimize effects to
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STIP A-0009C Page 5 of 7
these sites. If through ongoing consultation, any of these sites are determined to be adversely affected by the
undertaking and data recovery is determined to be the best course of action to mitigate the adverse effects, NCDOT, in
consultation with the SHPO and the THPOs (or their designee) of the EBCI, CN, UKB, MCN, the Catawba Nation and the A-
0009C cultural resources Task Force will develop, separate DRPs for those sites as determined appropriate, as defined in
the project Programmatic Agreement.

Sites 31GH696 and 31GH705 have been determined eligible under Criterion A and cannot be subjected to any ground
disturbing activities.

Division 14 Project Development - Design Team; Division 14 Construction – Historic Architecture
 John and Mattie Colvard House: Tree surveying to avoid trees during construction – replace any
balled/burlapped trees that cannot be avoided.
 John and Ruby Cody House: Protective measures for stone wall that lines driveway.
 Cheoah Historic District: Minimize tree cutting and restore landscaping after temporary detour is removed.
UPDATE:
• John and Mattie Colvard House: Tree surveying to avoid trees during construction. Trees to avoid during
construction will be marked and protected with orange safety fence – replace with any balled/burlapped trees
that cannot be avoided.
• John and Ruby Cody House: Protective measures. Orange safety fence will be placed in front of for stone wall
that lines driveway.

Division 14 Project Development - Design Team; Division 14 Construction – Historic Architecture, Archaeology
As a result of the meeting held with the Advisory Council on Historic Preservation (ACHP) on August 10, 2020, NCDOT and
Federal Highway Administration (FHWA) entered into a Section 106 Programmatic Agreement (PA).

A PA is appropriate when it is difficult to fully determine how a particular undertaking may affect historic properties or the
location of historic properties and their significance and character. The PA outlines procedures, roles and responsibilities,
and continued consultation through final design, right of way and construction.

The PA includes consultation from the consulting parties identified during the Section 106 process. It also includes
signatory parties from entities with land ownership, such as the US Forest Service and the Eastern Band of Cherokee
Indians (EBCI).
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The following topics may be covered in the PA:

• Effects calls from June 1 including conditions
• Periodic design reviews and consultation points
• Principles to follow
• Avoidance and mitigation measures
• Archaeology reviews
• Unanticipated discovery
• Course of action to develop a memorandum of agreement (MOA) if necessary for archaeology
• Specifications or aspects of the roadway alignment

The intent of the PA is to get a No Adverse Effect (NAE) call for the entire project for both historic and archaeology sites.
The PA will be executed prior to the Finding of No Significant Impact (FONSI).

UPDATE: NCDOT, in coordination with Section 106 consulting parties, will implement the PA developed for this project
through final design, right of way and construction.

Division 14 Construction and Project Development - Design Team – Appalachian Trail Parking Lot
Ensure adequate turnaround for vehicles exiting the Appalachian Trail parking lot on NC 143.

UPDATE: Adequate turnaround space will be provided for vehicles existing the Appalachian Trail parking lot on NC 143.
NCDOT is providing right-in/right-out access with bulb-out turnarounds to parking area. Travel flow will be one-way
(counter-clockwise) in parking lot. There will be approximately 8 parking spaces.

Access to the Appalachian Trail will be maintained during construction.

The Appalachian Trail is normally open 24 hours a day, 365 days a year and will require a Workzone Pedestrian Plan prior
to initiation of construction in the vicinity of the Appalachian Trail. During construction, the contractor shall maintain a
safe pedestrian route and environment for Appalachian Trail hikers, including wayfaring signs warning of construction
ahead, a clearly marked route for hikers through or around the construction site, and when appropriate, flaggers to aid
hikers in the construction zone. At the discretion of the contractor, and under the supervision of the NCDOT, flaggers will
assure hikers do not pass through the construction site when there is potential danger. The construction contractor shall
endeavor to minimize stoppage of hikers and regulate construction for hikers while ensuring safe passage.

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STIP A-0009C Page 7 of 7
The current trailhead parking on the east side of NC 143 will be retained after construction for parking and access to the
eastern side of the land bridge. NCDOT shall coordinate with the USFS, NPS, and ATC on any measures needed to protect
these features and associated amenities during construction. The NCDOT will repair and restore any damage to these
areas from construction activities. After construction NCDOT will maintain the pavement, striping, and curbs, while the
USFS would maintain the grass, vegetation at the trailhead, signs, and other associated amenities.

NCDOT will provide funding for the manufacture of new trail signs for the Appalachian Trail. These signs will be
manufactured, installed, and maintained by the ATC on the new land bridge and relocated sections of trail.

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TABLE OF CONTENTS
Photo Source: Graham County Travel & Tourism (2018)
1.0 ERRATA
2.0 SECTION 4(F) DOCUMENTATION
3.0 PUBLIC AND AGENCY COORDINATION
APPENDICES
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1-1 MARCH 2021

This section identifies any revisions to the EA (August 2020) or updates to studies contained in the EA.
• Tiered and planted retaining walls were included in the EA (August 2020) adjacent to the proposed land bridge. During
subsequent Value Engineering (VE) review, it was determined these planted tiered retaining walls would require irrigation
installation underneath to maintain vegetation, which would result in increased maintenance costs and concerns for the
safety of maintenance crews. As such, the tiered planted retaining walls were replaced with vertical retaining walls
utilizing sculpted/decorative shotcrete as included in the rendering below.

1.0 ERRATA
Land Bridge Typical Section *shoulder typical may vary in final design
Image credit: NCDOT Visualization
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1-2 MARCH 2021

• Section 7 Concurrence for Indiana bat (Myotis sodalist) and northern long-eared bat (Myotis septentrionalis) was
received from USFWS on November 23, 2020 (Appendix B). Commitments within the concurrence agreement include
winter tree clearing (October 15 – April 15); no additional permanent lighting to the project area; limiting temporary
lighting and night work to the single area needed for the wildlife passage/Appalachian Trail land bridge, to be
completed a few nights between November and March; and demolition of man-made structures only during the winter
or after confirming the absence of roosting bats.
• A conference opinion is under development for the golden-winged warbler (Vermivora chrysoptera) (which is
anticipated to be listed as a federally-protected species in the near future). The project is anticipated to impact
approximately 0.45 acre of nesting/early successional habitat near Bill Rose Road for new right-of-way and easements.
Proposed conservation measures include:
– Retaining walls near the Appalachian Trail (AT) to minimize downstream fill slope and disturbance within breeding
pair habitat.
– Habitat enhancement in the form of forest clearing, select cutting/thinning and native vegetation installation.
– Measures already proposed for bat habitat conservation will also be beneficial to the golden-winged warbler
including winter tree clearing.
– Native vegetation will be planted on terraced retaining walls and the land bridge to better meet vegetation
coverage objectives.
– Off road equipment for construction will be pressure washed to help remove propagules (seeds or vegetative
parts capable of reproduction) of nonnative invasive plant species prior to being brought onto USFS property.
– Additional information on the golden-winged warbler can be found in the Conference Opinion assessment.
• The Biological Evaluation was revised following the publication of the signed EA. These revisions include removal of
Carey’s sedge from the species list and the addition of Smilax hugeri and Maianthemum stellatum. Symphyotrichum
oblongifolium was originally in the list of species found within the project study area, but upon further review, the
observation was deemed to be Symphyotrichum phlogifolium which is not a rare species.
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1-3 MARCH 2021

• The US Forest Service (USFS) requested that EA Section 3.7 (National Forest Lands) incorporate the following statement:
"The Nantahala and Pisgah Forest Plan may need to adjust MA 14 boundaries to reflect the realignment of the
Appalachian Trail.”
• Geotechnical subsurface investigations for the Selected Alternative were conducted during summer and fall 2020. Fresh
testing samples were taken from the Anakeesta/Weyhutty formation, which is noted for having rock mineralization that
generates acidic runoff (“acidic rock”), particularly when excavated and exposed to air and water. Testing results
indicate that the Selected Alternative avoids acidic rock producing formations. Recommendations regarding
construction in areas of acidic rock are as follows:
– No specific treatment or material handling will be required for excavation on this project.
– No specific water chemistry testing or monitoring is recommended with respect to this issue, outside of other erosion
control and water quality preservation items required for the project.
– Durable excavated rock material, if approximating Class I or II rip rap, or Class VII in the NCDOT Standard
Specifications may be used to construct 1.5:1 rock embankments parallel to streams, if this is desirable to reduce the
project footprint.
• Archaeology surveys were completed in December 2020 for previously inaccessible areas of NFS land within the project
study area. One additional archaeological site (31GH742) was identified within the project study area; however, it is not
recommended as eligible for listing on the National Register of Historic Places and is not near the Selected Alternative.
No impacts to archeological site 31GH742 are associated with the proposed project.
• Project impacts were updated in early March 2021 to reflect design refinements that have occurred since the
completion of the EA in August 2020.
– Impact quantities were updated based on proposed construction limits plus a 25-foot buffer, rather than the 35-foot
buffer used to generate the more conservative impact quantities reflected in the EA. Updated impacts are as
follows:
 Water Quality: 137 linear feet of Trout water impacts are anticipated on NFS land.
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1-4 MARCH 2021

 Wetlands/Waters of the US: 10,349 linear feet of impacts to streams could be created by the proposed project
(approximately 1,054 linear feet of impacts at culvert extensions and 9,295 linear feet due to fill placement). Of
the total project stream and wetland impacts, 260 linear feet of stream impacts and 0.01 acres of wetland
impacts are anticipated on NFS lands.
 Vegetation and Habitat: Within the Stecoah Gap area on NFS lands and adjacent existing right-of-way, direct
impacts will occur across approximately 7 acres of rich cove forest, 3 acres of basic montane oak-hickory forest,
and 10 acres of either existing road/shoulders or other disturbed and maintained areas including powerline
corridors.
– The following project impacts were updated since completion of the EA to reflect proposed right-of-way refinements:
 Forest Service Land (NFS Land): The proposed right-of-way for the Selected Alternative requires 7.09 acres of NFS
land outside existing right-of-way.
 Farmlands Soils and Agriculture: Approximately 20.1 acres of direct impacts to farmland soils are anticipated with
the proposed right-of-way, including 5.93 acres of prime farmland, 9.72 acres of farmland of local importance,
and 4.46 acres of farmland of statewide importance.
 Relocations and Right-of-Way: The proposed project would relocate ten residences and three businesses, as
indicated in the project relocation report.
 Trail of Tears: The proposed project would not encroach upon the Trail of Tears and does not extend outside of the
existing right-of-way.
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2-1MARCH 2021
This section summarizes Section 4(f) findings following the publication of the EA (August 2020) and expands on North Carolina
Historic Preservation Office (HPO) concurrence signed August 19, 2020.
Mitigation for impacts related to the realignment of the AT are being developed in coordination with the NPS, USFS, and ATC
and are included in the Section 106 Programmatic Agreement (PA). The proposed land bridge and AT realignment fall within
the USFS Management Area (MA) for the Appalachian Trail. The land bridge and AT realignment will be developed to avoid
and minimize impacts to the AT and its attributes to the fullest extent practicable.
On November 17, 2020, FHWA sent letters to USFS and NPS requesting concurrence that the proposed project will not adversely
affect the activities, features, or attributes qualifying the Appalachian Trail for protection under Section 4(f). Concurrence was
received from both USFS and NPS on March 9, 2021. The Section 4(f) concurrence letters are included in Appendix B.
This project resulted in a de minimis finding in accordance with Section 4(f) regulations. The Section 4(f) determination was
finalized through coordination with the USFS, NPS, and other appropriate agencies. Section 106 concurrence from the
NC Historic Preservation Office was used as a basis for the de minimis finding.
2.0 SECTION 4(F)
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3-1 MARCH 2021

This section describes public outreach and agency
coordination that occurred after the EA was approved on
August 26, 2020.
Circulation of the EA
The EA for the project was approved by FHWA and NCDOT
on August 26, 2020. NCDOT distributed copies to state and
federal environmental resource and regulatory agencies and
local governments. The EA and Public Hearing maps were
available for public review online and at the NCDOT Graham
County Maintenance Yard in Robbinsville, the NCDOT District
Engineer’s Office in Andrews, and the NCDOT Division
Engineer’s Office in Sylva. Comments on the EA were
accepted by NCDOT through October 30, 2020. The EA was
distributed through the State Clearinghouse. The State
Clearinghouse comment period ended October 12, 2020.
Public Hearing
NCDOT held a Virtual Public Hearing for the proposed project
on October 1, 2020 from 6:00 to 8:00 p.m. Newsletters were
mailed two weeks prior to the Public Hearing to 1,698
property owners. A public notice ran in the newspaper the
week of the Hearing and a press release was published online
one week before the Public Hearing, with an associated
social media push on Twitter, Facebook, and NextDoor. The
Public Hearing included a formal presentation, followed by
review of the Public Hearing maps. Meeting materials are
available on the project website, including public hearing
maps.
Approximately 33 citizens signed-in during the Virtual Public
Hearing. Ten people posted questions or comments in the
online meeting chat box. A total of twenty-seven (27) specific
comments/questions were contained in the ten (10)
comments posted in the chat box during the Virtual Public
Hearing. A total of 42 comments were received during and
following the public hearing through the Virtual Public
Hearing chat box, e-mail, and transcribed voicemails.

3.0 AGENCY & PUBLIC
INVOLVEMENT
SECTION CONTENTS
3.1 Circulation of the EA…..………………….............................5-1
3.2 Public Hearing………….….…...............................................5-1
3.3 Agency Comments on the EA............................................5-2
3.4 Public Comments on the EA…………..…...........................5-2
3.5 Merger Coordination…….…................................................5-2
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These questions and comments were noted or otherwise
addressed during the Virtual Public Hearing.
Summary of Comments Received During the Virtual Public
Hearing via the Chat Box:
• Comments in support of the project – 3 (11%)
• Comments regarding property impacts – 2 (7%)
• Questions about A-0009A and project schedule – 3 (11%)
• Comments regarding the proposed land bridge – 5 (19%)
• Comments regarding the Appalachian Trail parking lot – 3 (11%)
• Comments regarding the proposed multi-use path – 2 (7%)
• Comments/questions regarding the design – 6 (22%)
• Questions regarding culverts/pipes – 3 (11%)
Agency Comments on the EA
State and federal regulatory and resource agencies
provided comments on the EA. These comments and
responses are contained in Appendix A.1. Agency
comments included a several general permitting
requirements applicable to all roadway construction projects
and comments related to project commitments and
mitigation.
Public Comments on the EA
A total of fifty-nine (59) subject-specific positions were
contained in the forty-two (42) comments submitted through
the Virtual Public Hearing chat box, e-mail, and transcribed
voicemails during the 30-day comment period following the
publication of EA and the project’s Virtual Public Hearing.
The comment summary, including responses to each
comment, is included in Appendix A.2. The comments and
questions were primarily focused on the proposed land
bridge, multi-use path, and property impacts. A summary of
the comments follows.
• Comments in support of the project – 12 (20%)
• Comments regarding property impacts – 7 (12%)
• Questions about A-0009A and project schedule – 1 (2%)
• Comments regarding the proposed land bridge – 7 (12%)
• Comments regarding the Appalachian Trail parking lot – 2 (3%)
• Comments regarding the proposed multi-use path – 16 (27%)
• Comments/questions regarding the design – 4 (7%)
• Questions related to noise effects – 2 (3%)
• Comments in opposition to the project (1) (2%)
• General Questions/Comments – 4 (7%)
• Request to be added to project mailing list – 2 (3%)
• General opposition to the project – 1 (2%).
Merger Coordination: LEDPA &
Avoidance and Minimization
A NEPA/404 Merger Team meeting was held on November
12, 2020 to obtain concurrence on the Least Environmentally
Damaging Practicable Alternative (LEDPA) (Concurrence
Point 3) and Avoidance and Minimization (Concurrence Point
4A). Alternative 1 was selected as the LEDPA. The Merger
Team reached concurrence on project avoidance and
minimization measures as listed in the Concurrence Point 4A
form. Concurrence forms for Points 3 and 4A can be found in
Appendix B.
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In addition to selecting the Improve Existing Alternative,
avoidance and minimization efforts implemented during the
development of the LEDPA include the following:
• 2:1 fill slopes.
• 1.5:1 cut slopes where possible.
• Expressway gutter and shoulder berm gutter to reduce
cross-section width.
• Alignment shifts to avoid relocations and
avoid/minimize stream, wetland, and historic resource
impacts.
• Alignment shifts and symmetrical or asymmetrical
widening for a best-fit alignment to avoid/minimize
impacts and reduce earthwork.
• Retaining walls to avoid/minimize impacts and reduce
earthwork.
• Land bridge to avoid habitat fragmentation effects
and visual impacts for Appalachian Trail users.
In final design:
• All slopes in jurisdictional areas are anticipated to be the
maximum allowable for standard grass lined slopes (2:1).
• Minimum applicable typical sections will be proposed
throughout the project.
• Propose retaining and extending existing culverts where
practicable.
• Slight adjustments to the horizontal and vertical
alignments where practicable to minimize jurisdictional,
cultural and environmental impacts. Geotechnical
design will evaluate steepening slopes in some areas as
practicable.
• Extending existing culvert headwalls vertically, where
practicable, in a few locations to avoid stream loss
(possible examples are Tulula Creek, downstream end of
Sweetwater Creek at Slaybacon Road and upstream
end of Stecoah Creek).

Photo Credit: Graham County Travel and Tourism
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APPENDICES
Photo Source: Graham County Travel & Tourism (2018)
A RESPONSES TO COMENTS ON THE EA
B AGENCY COORDINATION
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APPENDIX A.1
RESPONSES TO AGENCY COMMENTS ON THE ENVIRONMENTAL ASSESSMENT

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Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
NC Department of
Administration, State
Environmental
Review
Clearinghouse
General General 1.1 The above referenced environmental impact information has
been submitted to the State Clearinghouse under the provisions
of the National Environmental Policy Act. According to G.S.
113A-10, when a state agency is required to prepare an
environmental document under the provisions of federal law,
the environmental document meets the provisions of the State
Environmental Policy Act. Attached to this letter
for your consideration are comments made by the agencies in
the review of this document. If any further environmental
review documents are prepared for this project, they should be
forwarded to this office for intergovernmental review.
Noted.
NC Department of
Agriculture
General General 2.1 No comment. Noted.
NC Department of
Environmental
Quality (NCDEQ),
Division of Water
Resources
Project
Specific
Agency
Coordination
3.1 This project is being planned as part of the 404/NEPA Merger
Process. As a participating team member, NCDWR will continue
to work with the Merger Team on this project.
Noted.
NC Department of
Environmental
Quality (NCDEQ),
Division of Water
Resources
Project
Specific
Stormwater 3.2 To meet the requirements of NCDOT’s NPDES permit
NCS000250, the road design plans shall provide treatment of the
stormwater runoff through BMPs as detailed in the most recent
version of the North Carolina Department of Transportation
Stormwater Post-Construction Stormwater Program Manual,
and the Best Management Practices Toolbox Manual. The BMPs
should, to the MEP, be selected and designed to reduce impacts
of the target pollutants of concern (POCs) for the receiving
waters.
Prior to construction, an erosion and sedimentation
plan will be developed for the Least Environmentally
Damaging Practicable Alternative (LEDPA) in
accordance with applicable rules, regulations and
guidance. This plan will follow Guidelines for
Construction of Highway Improvements Adjacent to or
Crossing Trout Waters in North Carolina in accordance
with NCDEQ and NCDOT guidance and best
management practices. NCDOT's Post-Construction
Stormwater Program manages long-term stormwater
runoff from NCDOT projects to protect water quality.
A Stormwater Management Plan will be prepared
during final design of the project to direct the drainage
design and manage long-term stormwater runoff. As
part of the plan, NCDOT will implement new structural
best management practices and non-structural
pollution minimization measures.
APPENDIX A.1
RESPONSES TO AGENCY COMMENTS ON THE ENVIRONMENTAL ASSESSMENT
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Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
Project
Specific
Design
Standards in
Sensitive
Watersheds
3.3 Review of the project reveals the presence of surface waters
classified as Water Supply Critical Area in the project study area.
Given the potential for impacts to these resources during the
project implementation, the NCDWR requests that the NCDOT
strictly adhere to North Carolina regulations entitled Design
Standards in Sensitive Watersheds (15A NCAC 04B .0124)
throughout design and construction of the project. This would
apply for any area that drains to streams having WS CA (Water
Supply Critical Area) classifications.
See response to Comment 3.2.
Project
Specific
Trout Waters 3.4 Sweetwater, Tulula, and Stecoah Creeks are class Trout waters
of the State. The NCDWR recommends that the most protective
sediment and erosion control BMPs be implemented to reduce
the risk of turbidity violations in trout waters. In addition, all
disturbances within trout buffers should be conducted in
accordance with NC Division of Land Resources and NC Wildlife
Resources Commission requirements. Post-construction
stormwater BMPs should, to the MEP, be selected and designed
to reduce TSS and avoid a sustained increase in the receiving
water temperature.
As noted in the Project Commitments, the Wildlife
Resources Commission (WRC) will coordinate with
NCDOT on moratorium needs during further project
development or during project permitting. Trout
supporting streams and a 25-foot buffer will be
identified on erosion control plans and later
delineated in the field so that the contractor avoids
disturbance in those streams and their buffers during
the prescribed moratorium period. A trout buffer
variance, most likely along Sweetwater and Stecoah
creeks, may be required on the project and
coordinated with the Division of Environmental
Quality (DEQ), Division of Land Resources.

Implement Guidelines for Construction of Highway
Improvements Adjacent to or Crossing Trout Waters in
North Carolina during design and construction.
Project
Specific
Acidic Rock 3.5 Prior to commencing ground disturbing activities, an acceptable
monitoring and mitigation plan for the presence of sulfide-
bearing rock must be approved by the NCDWR.
2020 rock testing results indicate that the
LEDPA/Selected Alternative traverses formations with
low acid-producing potential. As such, no specific
treatment or material handling will be required for
excavation on this project and no specific water
chemistry testing or monitoring is recommended with
respect to this issue, outside of other erosion control
and water quality preservation items required for the
project.
General Wetland
/Stream
Impacts
3.6 The environmental document should provide a detailed and
itemized presentation of the proposed impacts to wetlands and
streams with corresponding mapping. If mitigation is necessary
as required by 15A NCAC 2H.0506(h), it is preferable to present
a conceptual (if not finalized) mitigation plan with the
environmental documentation. Appropriate mitigation plans
will be required prior to issuance of a 401 Water Quality
Certification.
The Natural Resources Technical Report (October
2019) referenced in the EA (August 2020) provides a
detailed presentation of potential impacts to
jurisdictional resources for the LEDPA/Selected
Alternative's preliminary design. Location-specific
stream and wetland impact quantities were presented
on 11/12/2020 to the Merger Team at Concurrence
Point 4A (Appendix B). Potential impacts to
jurisdictional resources for the LEDPA were updated in
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Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
FONSI. NCDOT has received agreement from the
NCDEQ Division of Mitigation Services to provide
compensatory mitigation through the in-lieu fee
program.
General Wetland
/Stream
Impacts
3.7 Environmental impact statement alternatives shall consider
design criteria that reduce the impacts to streams and wetlands
from storm water runoff. To meet the requirements of NCDOT’s
NPDES permit NCS000250 these alternatives should include
road designs that allow for treatment of the storm water runoff
through best management practices as detailed in the most
recent version of the North Carolina Department of
Transportation Stormwater Best Management Practices Toolbox
manual, which includes BMPs such as grassed swales, buffer
areas, preformed scour holes, retention basins, etc.
See response to Comment 3.2.
General Wetland
/Stream
Impacts
3.8 After the selection of the preferred alternative and prior to an
issuance of the 401 Water Quality Certification, the NCDOT is
respectfully reminded that they will need to demonstrate the
avoidance and minimization of impacts to wetlands (and
streams) to the maximum extent practical. In accordance with
the Environmental Management Commission’s Rules (15A NCAC
2H.0506[h]), mitigation will be required for impacts of greater
than 0.1 acre to wetlands. In the event that mitigation is
required, the mitigation plan shall be designed to replace
appropriate lost functions and values. The North Carolina
Division of Mitigation Services may be available to assist with
wetland mitigation.
NCDOT will work with NCDWR and the USACE to
identify and provide all required mitigation to satisfy
compensatory mitigation requirements for this
project.

Avoidance and minimization measures were
incorporated into the preliminary engineering designs
for the LEDPA/Selected Alternative as discussed at
NEPA/404 Merger Team Meetings for Concurrence
Point 3 and 4A on November 12, 2020 (Appendix B).
The results of this meeting are detailed in this FONSI.
As noted in Section 3.6 of the EA (August 2020), a
mitigation plan for unavoidable impacts to streams
and wetlands will be developed in consultation with
the USACE.
General Wetland
/Stream
Impacts
3.9 In accordance with the Environmental Management
Commission’s Rules (15A NCAC 2H.0506[h]), mitigation will be
required for impacts of greater than 300 linear feet to any single
stream. In the event that mitigation is required, the mitigation
plan shall be designed to replace appropriate lost functions and
values. The North Carolina Division of Mitigation Services may
be available to assist with stream mitigation.
NCDOT will obtain all applicable permits, including a
Section 404 Permit and associated 401 Water Quality
Certification. Avoidance and minimization measures
incorporated into the LEDPA are discussed in this
Finding of No Significant Impact (FONSI) under Section
3.5.
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Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
General Wetland
/Stream
Impacts
3.10 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.
All impacts, corresponding mapping, and mitigation
information will be included in the 401 Water Quality
Certification Application submitted by NCDOT to
NCDWR.

As noted in Section 3.6 of the EA (August 2020), a
mitigation plan for unavoidable impacts to streams
and wetlands will be developed in consultation with
the USACE.
General Wetland
/Stream
Impacts
3.11 The NCDWR is very concerned with sediment and erosion
impacts that could result from this project. The NCDOT 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.
See response to Comment 3.2.
General Wetland
/Stream
Impacts
3.12 The NCDOT 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.
All project impacts to jurisdictional resources,
including short-term construction impacts, will be
included in final impact calculations provided in the
permit applications.
General Wetland
/Stream
Impacts
3.13 Where streams must be crossed, the NCDWR 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
NCDOT should not install the bridge bents in the creek, to the
maximum extent practicable.
As discussed at CP 2A and 4A and included in the
Hydraulic Planning Report (December 2019) prepared
for the project recommends that culvert inverts be
buried one foot below the stream bed. NCDOT will
avoid placement of bridge bents in creeks to the
maximum extent practicable.
General Wetland
/Stream
Impacts
3.14 Whenever possible, the NCDWR 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.
Noted. Since this is a widening project, most proposed
structures are extensions of existing structures.
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Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
General Wetland
/Stream
Impacts
3.15 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.
To meet the requirements of NCDOT’s NPDES permit
NCS000250, please refer to the most recent version of the North
Carolina Department of Transportation Stormwater Best
Management Practices Toolbox manual for approved measures.
See response to Comment 3.2.
General Wetland
/Stream
Impacts
3.16 Sediment and erosion control measures should not be placed in
wetlands or streams.
Noted. Also see response to Comment 3.5.
General Wetland
/Stream
Impacts
3.17 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.
The construction contractor will be required to acquire
applicable permits relative to borrow pits and comply
with requirements for borrow pits, dewatering, and
any temporary work conducted in jurisdictional areas.
General Wetland
/Stream
Impacts
3.18 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.
The 401 Water Quality Certification application will
include proposed methods for stormwater
management.
General Wetland
/Stream
Impacts
3.19 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 NCDOT and written concurrence from
the NCDWR. 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.
NCDOT will obtain all required permits, including a
Section 404 Permit and associated 401 Water Quality
Certification. Avoidance and minimization measures
incorporated into the LEDPA will be detailed in the
permit application.
General Wetland
/Stream
Impacts
3.20 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.
Concrete shall be handled in accordance with the NPDES
Construction General Permit NCG010000.
Noted. NCDOT will follow the procedures as detailed
in the special provisions related to concrete-wash
water containment.
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EA Section Topic Comment
No. Comment Text Response
General Wetland
/Stream
Impacts
3.21 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.
Temporary access and haul roads, other than public
roads, constructed or used in connection with the
project shall be considered a part of the project and
addressed in the erosion and sedimentation control
plans developed by the final design team.
General Wetland
/Stream
Impacts
3.22 Unless otherwise authorized, placement of culverts and other
structures in waters and streams 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 downstream of the above
structures. The applicant is required to provide evidence that
the equilibrium is being maintained if requested in writing by
the NCDWR. If this condition is unable to be met due to bedrock
or other limiting features encountered during construction,
please contact the NCDWR for guidance on how to proceed and
to determine whether or not a permit modification will be
required.
See response to Comment 3.13.
General Wetland
/Stream
Impacts
3.23 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.
The final design for the LEDPA will be completed in
accordance with the NCDOT Guidelines for Drainage
Studies and Hydraulic Design.
General Wetland
/Stream
Impacts
3.24 If foundation test borings are necessary; it shall be noted in the
document. Geotechnical work is approved under General 401
Certification Number 4132/Nationwide Permit No. 6 for Survey
Activities.
If additional geotechnical investigations are needed,
subsurface investigations, including borings, will be
conducted in accordance with the current NCDOT
Geotechnical Unit Guidelines and Procedures Manual.
General Wetland
/Stream
Impacts
3.25 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 NCS000250.
Noted. The project's erosion and sediment
control/stormwater pollution prevention plan will be
implemented and maintained during the construction
of the project in accordance with all applicable laws
and regulations.
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Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
General Wetland
/Stream
Impacts
3.26 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 the 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.
NCDOT will implement approved BMP measures from
the most current version of NCDOT Construction and
Maintenance Activities Manual.
General Wetland
/Stream
Impacts
3.27 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.
On-site wetland delineations within the project
corridor were performed by qualified biologists from
June 2, 2019 to July 12, 2019 and from October 21,
2019 to October 24, 2019.
General Wetland
/Stream
Impacts
3.28 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.
NCDOT will implement approved BMP measures from
the most current version of NCDOT Construction and
Maintenance Activities Manual.
General Wetland
/Stream
Impacts
3.29 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.
All appropriate measures will be taken to protect
streams and aquatic life based on NCDOT standard
practices.
General Wetland
/Stream
Impacts
3.30 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.
Appropriate measures will be taken to preserve and
reestablish riparian vegetation to the maximum extent
possible. NCDOT 's contractor will preserve trees,
where possible, along the project. In addition, final
designs will be prepared in accordance with BMPs
from NCDOT's toolbox, which recommends the
reestablishment of riparian vegetation
NC Department of
Environmental
Quality (NCDEQ),
Solid Waste Section
General Solid Waste
and Recycling
4.1 During the project, every feasible effort should be made to
minimize the generation of waste, to recycle materials for which
viable markets exist, and to use recycled products and materials
in the development of this project where suitable. Any waste
generated by this project that cannot be beneficially reused or
recycled must be disposed of at a solid waste management
facility approved to manage the respective waste type. The
Section strongly recommends that any contractors are required
to provide proof of proper disposal for all waste generated as
part of the project. A list of permitted solid waste management
facilities is available on the Solid Waste Section portal site at:

http://deq.nc.gov/about/divisions/waste-management/waste-
management-rules-data/solid-waste-management-annual-
reports/solid-waste-permitted-facility-list
NCDOT will require all contractors to provide proof of
proper disposal for all generated waste to permitted
facilities.
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EA Section Topic Comment
No. Comment Text Response
NC Department of
Environmental
Quality (NCDEQ),
Inactive Hazardous
Sites Branch
General Hazardous
Sites
5.1 Four (4) sites were identified within one mile of the project as
shown on the attached report. The Superfund Section
recommends that site files be reviewed to ensure that
appropriate precautions are incorporated into any construction
activities that encounter potentially contaminated soil or
groundwater. Superfund Section files can be viewed at:
http://deq.nc.gov/waste-management-laserfiche.
The NCDOT Geoenvironmental Unit investigated the
project study area to identify hazardous material sites
of concern (November 2019), as summarized in
Section 3.22 of the EA. No sites with high risks to cost
or schedule were identified. Low monetary and
scheduling impacts to hazardous materials sites are
anticipated to result from construction of the LEDPA.
No direct impacts to hazardous materials are
anticipated with LEDPA. Indirect effects will be
minimized during the construction.
NC Department of
Environmental
Quality (NCDEQ),
Hazardous Waste
Section
General Hazardous
Waste
6.1 Any hazardous waste generated from the demolition,
construction, operation, maintenance, and/or remediation (e.g.
excavated soil) from the proposed project must be managed in
accordance with the North Carolina Hazardous Waste Rules. The
demolition, construction, operation, maintenance, and
remediation activities conducted will most likely generate a solid
waste, and a determination must be made whether it is a
hazardous waste. If a project site generates more than 220
pounds of hazardous waste in a calendar month, the HWS must
be notified, and the site must comply with the small quantity
generator (SQG) requirements. If a project site generates more
than 2200 pounds of hazardous waste in a calendar month, the
HWS must be notified, and the facility must comply with the
large quantity generator (LQG) requirements.

Generators are required to determine their generator status and
both SQGs & LQGs are required to obtain a site EPA
Identification number for the generation of hazardous waste.
NCDOT will comply with the NC Hazardous Waste
Rules.
NC Department of
Environmental
Quality (NCDEQ),
Division of Air
Quality
General Open Burning 7.1 Any open burning associated with subject proposal must be in
compliance with NC State open burning regulations (15 A NCAC
2D.1900)
NCDOT and the contactor will comply with all
applicable regulations and ordinances related to open
burning and fugitive dust control in effect at the time
of construction.
NC Department of
Environmental
Quality (NCDEQ),
Division of Water
Quality, Water
Quality Regional
Operations Section
General Permitting 8.1 401 Water Quality Certification - You may need to contact the
Army Corp of Engineers and the North Carolina Division of
Water Resources Asheville Regional Office concerning 401/404
permits if the project involves dredging, filling, excavations, or
placing structures in or near jurisdictional waters (e.g. streams,
wetlands, lakes). Contact Amy Annino at 828-296-4500 for
further information. Refer to DWR Acid Rock Policy additionally.
NCDOT will coordinate with USACE and NCDWR as
needed regarding dredging, filling, excavations, or
structures in or near jurisdictional waters.
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A.1-9 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
NC Department of
Environmental
Quality (NCDEQ),
Division of Energy,
Mineral, and Land
Resources (DEMLR),
Land Quality and
Stormwater Sections
General Sedimentation
and
Stormwater
9.1 The Sedimentation Pollution Control Act of 1973 must be
properly addressed for any land disturbing activity. An erosion
and sedimentation control plan and/ or a trout stream buffer
waiver may be required if one or more acres are to be
disturbed. A Plan or trout buffer waiver must be filed with and
approved by applicable Regional Office (Land Quality Section) at
least 30 days before beginning activity. A NPDES Construction
Stormwater permit (NCG010000) is also usually issued should
design features meet minimum requirements.
NCDOT acknowledges that an erosion and
sedimentation control plan will be required prior to
any land disturbing activities.
General Sedimentation
and
Stormwater
9.2 Sedimentation and erosion control must be addressed in
accordance with North Carolina Department of Transportation’s
approved program. Particular attention should be given to
design and installation of appropriate perimeter sediment
trapping devices as well as stable Stormwater conveyances and
outlets.
See response to Comment 3.2.
General Stormwater 9.3 For this site compliance with 15A NCAC 2H .0126 - NPDES
Stormwater Program may be required. This program regulates
three types of activities: Industrial, Municipal Separate Storm
Sewer System & Construction activities that disturb ≥1 acre.
See response to Comment 3.2.
General Stormwater 9.4 Compliance with 15A NCAC 2H 1000 -State Stormwater
Permitting Programs which regulate site development and post-
construction stormwater runoff control may be required for this
site. Areas subject to these permit programs include all 20
coastal counties, and various other counties and watersheds
throughout the state.
See response to Comment 3.2.
NC Department of
Environmental
Quality (NCDEQ),
Division of Water
Resources, Public
Water Supply Section
3.5, 3.6 Water Quality
and
Stormwater
10.1 The proposed project is located within a water supply
watershed. The necessary precautions should be taken during
construction and other activities to prevent leakage of fluids
from construction equipment, and to prevent herbicide
overspray from entering surface waters. We concur with the
issuance of the necessary permits for construction of this
project provided the site is maintained in accordance with the
necessary permits, and the stormwater runoff discharge does
not contravene the designated water quality standards.
Noted.
General Public Water
Supply Systems
10.2 Plans and specifications for the construction, expansion, or
alteration of a public water system must be approved by the
Division of Water Resources/Public Water Supply Section prior
to the award of a contract or the initiation of construction as per
15A NCAC 18C .0300 et. seq., Plans and specifications should be
submitted to 1634 Mail Service Center, Raleigh, North Carolina
27699-1634. All public water supply systems must comply with
state and federal drinking water monitoring requirements. For
Noted.
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
A.1-10 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
more information, contact the Public Water Supply Section,
[phone].
General Water Line
Relocation
10.3 If existing water lines will be relocated during the construction,
plans for the water line relocation must be submitted to the
Division of Water Resources/Public Water Supply Section at
1634 Mail Service Center, Raleigh, North Carolina 27699-1634.
For more information, contact the Public Water Supply Section,
[phone].
Existing water lines likely will be relocated to construct
the project. Plans will be submitted to the NCDWR
Public Water Supply Section as required.
NC Department of
Environmental
Quality (NCDEQ),
Asheville Regional
Office UST Section
3.22 Underground
Storage Tanks
(USTs)
11.1 The Asheville Regional Office (ARO) UST Section recommends
removal of any abandoned or out-of-use petroleum USTs or
petroleum ASTs within the project area. The UST Section should
be contacted regarding use of any proposed or on-site
petroleum USTs or ASTs. We may be reached at [phone].
NCDOT will contact the Asheville Regional Office (ARO)
UST Section as needed regarding UST use.
3.22 Underground
Storage Tanks
(USTs)
11.2 Any petroleum USTs or ASTs must be installed and maintained in
accordance with applicable local, state, and federal regulations.
For additional information on petroleum ASTs it is advisable that
the North Carolina Department of Insurance at [phone]
ext. 239, USEPA [phone], local fire department, and Local
Building Inspectors be contacted.
Noted.
3.22 Underground
Storage Tanks
(USTs)
11.3 Any petroleum spills must be contained and the area of impact
must be properly restored. Petroleum spills of significant
quantity must be reported to the North Carolina Department of
Environmental Quality (NCDEQ) – Division of Waste
Management (DWM) UST Section in the ARO.
Noted.
3.22 Underground
Storage Tanks
(USTs)
11.4 Any soils excavated during demolition or construction that show
evidence of petroleum contamination, such as stained soil,
odors, or free product must be reported immediately to the
local Fire Marshall to determine whether explosive or inhalation
hazards exist. Also, notify the UST Section of the ARO.
Petroleum contaminated soils must be handled in accordance
with all applicable regulations.
Noted.
3.22 Underground
Storage Tanks
(USTs)
11.5 Any questions or concerns regarding spills from petroleum USTs,
ASTs, or vehicles should be directed to the UST Section at (828)
296-4500. If you have any questions or need additional
information, please contact me via email at
[e-mail] or by phone at [phone].
Noted.
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
A.1-11 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
3.22 Underground
Storage Tanks
(USTs)
11.6 Notification of the proper regional office is requested if
"orphan" underground storage tanks (USTS) are discovered
during any excavation operation.
The NCDOT Geotechnical regional office will be
notified if orphan USTs are discovered. No orphan
UST's were identified in the Geoenvironmental Phase I
Report (December 2019).
NC Department of
Public Safety,
Division of
Emergency
Management
General Floodplain
Management
12.1 If the proposed project encroaches into the Special Flood Hazard
Area (SFHA), North Carolina Executive Order 123 directs NCDOT
to coordinate with and follow the FHWA floodplain
management requirements which are found in the Federal
Executive Order 11988. To ensure NCDOT compliance with EO
11988 and 44 CFR the NCDOT Hydraulics Section and the NC
Floodplain Mapping Program have a Memorandum of
Agreement (MOA). Please coordinate with NCDOT Hydraulics to
determine if the proposed encroachments and crossings within
this project are eligible to fall within the MOA.
Noted. NCDOT Division 14 will coordinate with NCDOT
Hydraulics as needed regarding eligible SFHA
encroachments and crossings.
NC Wildlife
Resources
Commission
(NCWRC)
3.3, 3.20 Section 4(f),
Appalachian
Trail
Relocation
13.1 The NCDOT proposes to improve the roadways from
Robbinsville to Stecoah in Graham County, NC, as the
Appalachian Development Highway System project, Corridor K.
NCWRC concurs with the Preferred Alternative, which would
improve the existing US 129, NC 143 and NC 28 between
Robbinsville and Stecoah to include passing/climbing lanes and
paved shoulders. We also concur with the proposed land bridge
across NC 143 at the crossing of the Appalachian Trail. The EA
indicated that the land bridge would serve both Appalachian
Trail hikers and wildlife and that the Appalachian Trail would be
placed in the center of the land bridge. Research has shown that
wildlife crossings are less effective when people are present.
The center of the bridge may not be the most appropriate place
for the trail. We recommend investigations into characteristics
that make wildlife overpasses most successful in order to
provide the safest facility for both wildlife and the traveling
public.
Noted. Final location of the realigned AT is being
developed in coordination with the USFS, NPS, and the
Appalachian Trail Conservancy. NCWRC input
regarding the location of the realigned AT on the land
bridge will be relayed to the parties involved in setting
the location of the relocated AT and NCWRC will be
invited to future meetings with the USFS, NPS, and
ATC regarding placement of the AT on the land bridge.
NOAA - National
Marine Fisheries
Service (NMFS)
General Essential Fish
Habitat (EFH)
14.1 NOAA’s National Marine Fisheries Service (NMFS) reviewed the
project described in the public notice SAW-2009-01346. Based
on the information in the public notice, we confirm the
Wilmington District's determination that the proposed work
would NOT occur in the vicinity of essential fish habitat (EFH)
designated by the South Atlantic Fishery Management Council,
Mid-Atlantic Fishery Management Council, or the NMFS. Present
staffing levels preclude further analysis of the proposed work
and no further action is planned. Consequently, we have no
comments or recommendations under the Magnuson-Stevens
Act or the Fish and Wildlife Coordination Act. This position is
neither supportive of nor in opposition to authorization of the
proposed work.
Noted.
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A.1-12 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
United States Army
Corps of Engineers
(USACE), Asheville
Regulatory Field
Office
2.3, 3.14 Passing/Climbi
ng Lanes
15.1 The EA indicates in several areas that there will be
passing/climbing lanes throughout the project or identifies
passing/climbing lanes in specific locations of the preferred
alternatives (reference 2.3 Preferred Alternative pdf pgs 23, 25
and also on pg 48 and maybe some other pages that I
missed). Considering that we are still in the process of trying to
determine where passing/climbing lanes will be, I think the
language should be revised to indicate that passing/climbing
lanes will be included “where appropriate” (or other such
language that indicates these decisions aren’t final) and in
specific areas that passing/climbing lanes are proposed, rather
than indicating that these locations are final and approved by
the team.
The Merger Team identified Alternative 1, with
passing and climbing lanes, as the LEDPA. The
Concurrence Point 3 meeting minutes and form are
contained in Appendix B.
United States
Environmental
Protection Agency
(USEPA) Region 4
N/A General 16.1 At this time based on information provided in the Public Notice
and associated plans, EPA Region 4 has no comments or
concerns with the project presented.
Noted.
United States
Environmental
Protection Agency
(USEPA) Region 4
3.5, 3.6 Water Quality 17.1 Section 3 of the EA states that the proposed project is located
within the Beech Creek, Carver Branch, Cody Branch, Edwards
Branch, Harwood Branch, Johnson Gap Branch, Orr Branch,
Pigpen Branch, Slay Bacon Branch, Stecoah Creek, Stillhouse
Branch, Sweetwater Creek, Tulula Creek, and Wolf Creek
watersheds. The NCDOT anticipates impact to 8,066 linear feet
of Trout Waters (based on the project footprint plus a 25-foot
buffer). The North Carolina Wildlife Resources Commission
classifies some of these Trout Waters as trout streams requiring
additional protections during construction. The EPA supports
NCDOT's construction moratorium for NC Wildlife Resources
Commission identified trout streams from January to April of
any given year and the implementation of construction
guidelines for trout waters.
See response to Comment 3.4.
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A.1-13 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
3.5, 3.6 Wetlands 17.2 Wetlands are located throughout the project limits and are
concentrated near Carver Branch, Harwood Branch, Pigpen
Branch, Slay Bacon Branch, Sweetwater Creek, and Wolf Creek,
and their associated tributaries. A total of 1.12 acres of wetland
impacts are within the proposed project area. Measures to
avoid and minimize any impacts to jurisdictional wetlands
should be considered and documented in the Final EA.

Consistent with Section 404 of the Clean Water Act, the project
should avoid and minimize, to the maximum extent practicable,
placement of fill into jurisdictional waters of the United States,
which include wetlands and streams. It should be noted that
jurisdictional Waters of the United States can differ from Waters
of the State subject to the State of North Carolina laws and
regulations, which are the basis for any County issued permits.
Any fill material in Waters of the United States will potentially
require a permit authorization from the U.S. Army Corps of
Engineers (COE). Any wetland or stream losses allowed under a
COE Section 404 permit should be mitigated by the applicant.
This mitigation can be designed and implemented by the
applicant or procured by the purchase of wetland and/or stream
mitigation credits from a commercial wetland mitigation bank.
See response to Comment 3.8.
3.10 Acidic Rock 17.3 The proposed project will include the excavation of
approximately 27,564 cubic yards of geological unit ZWE (acidic
rock) along NC 28 and Bill Crisp Road. Excavation of acidic rock
poses a high risk of generating acid runoff. Acid runoff can
destroy aquatic habitats and degrade water quality, making it
unfit for consumption. NCDOT is currently conducting a
geotechnical investigation that runs until the Summer of 2021.
The EPA looks forward to reviewing the minimization and
mitigation findings to handle the treatment of acidic rock.
Noted. 2020 rock testing results indicate that the
Selected Alternative traverses formations with low
acid-producing potential. As such, no specific
treatment or material handling will be required for
excavation on this project and no specific water
chemistry testing or monitoring is recommended with
respect to this issue, outside of other erosion control
and water quality preservation items required for the
project.
General Stormwater 17.4 The proposed construction of the Corridor K improvements will
increase impervious surface area, thereby increasing
stormwater runoff during times of precipitation. The EPA
recommends that any contractor working on-site should use
best management practices and should address any potential
impacts to off-site streams and waterways. The EPA also
recommends that site grading, excavation, and construction
plans should include implementable measures to prevent
erosion and sediment runoff from the project site during and
after construction.
See response to Comment 3.2.
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A.1-14 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
United States Forest
Service (USFS)
Green
Sheet
Appalachian
Trail
Relocation
19.1 While conversations and design are still underway regarding the
relocation of the Appalachian Trail and the land bridge, the USFS
request commitments from NCDOT related to the
responsibilities and funding for construction and trail relocation,
to ensure continuity and public safety.
NCDOT, in coordination with Section 106 consulting
parties, implemented a Section 106 Programmatic
Agreement developed for this project through final
design, right of way and construction. Additional
information is contained in the PA.
Green
Sheet
Non-Native
Invasive Plant
Species (NNIS)
19.2 We request additional language in the project commitments for
non-native invasive plant species control that has been
previously approved in other documents:

• "NCDOT will work within adjacent NCDOT rights-of-way to
prevent the encroachment of non-native invasive plant species
(NNIS) onto NFS lands committing to the following measures:
o To prevent the spread of NNIS, NCDOT will require
contractors to pressure wash all off-road equipment prior to
coming on NFS lands.
o NCDOT and USFS personnel will identify any priority NNIS
species within cut and fill slope areas prior to construction.
These areas will be cleaned and grubbed with the NNIS roots
disposed off NFS lands.
• "NCDOT staff will work with USFS staff on a periodic basis
after construction to control priority NNIS along the right-of-way
on NFS lands. In turn, USFS will work with NCDOT to identify and
effectively control NNIS and provide a prioritized list."
This was discussed at the draft EA comment meeting
between FHWA, NCDOT and USFS on August 13, 2020.
It was stated that this language would be included in
the Federal Land Transfer and not the project
commitments. This language addresses maintenance
activities, which FHWA does not participate in after
construction is complete. FHWA and NCDOT are
committed to including the requested additional
language in the Federal Land Transfer documentation.
3.7 Nantahala and
Pisgah Land
Management
Plan
19.3 There may be a need for a Nantahala and Pisgah Land
Management Plan administrative change to modify the
management area boundaries of the Appalachian Trail
Foreground management area (MA 14). Previously, there were
discussions about the potential need of a Forest Plan
Amendment in the Nantahala and Pisgah Land Management
Plan regarding scenery resources, but those concerns have since
been addressed in the Visual Impact Analysis. The administrative
change will tier to this EA, hence the need for the document to
reflect the recommended language. We request a footnote in
section 3.7 (National Forest Lands) to tee up the potential need
for an administrative change to MA 14. We recommend
language such as this: "The Nantahala and Pisgah Forest Plan
may need to adjust MA 14 boundaries to reflect the realignment
of the Appalachian Trail."
FONSI Section 1.0 (Errata) notes that the Nantahala
and Pisgah Forest Plan may need to adjust MA 14
boundaries to reflect the realignment of the
Appalachian Trail.

The FONSI includes updated project commitment
language as recommended by the USFS.

Per email correspondence from the USFS, the project’s
consistency with the Nantahala and Pisgah Forest Plan
is considered “to be determined” pending the
implementation of the PA.
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A.1-15 MARCH 2021

Agency/Organization Relevant
EA Section Topic Comment
No. Comment Text Response
3.7 Plant Species 19.4 The USFS is working directly with Stantec to resolve plant
species found within NFS land. We recommend on page 42
under the section 3.7 (Forest Service Land) the following:

• Remove Carey's sedge from the species list. Add Smilax hugeri
(a forest concern species), and Maianthemum stellatum which is
new to North Carolina and the Nantahala and Pisgah.
• We request the location where Symphyotrichum oblongifolium
was found as this would be a very rare occurrence both in North
Carolina and the national forest.
The Biological Evaluation was revised following the
publication of the signed EA. These revisions include
removal of Carey’s sedge from the species list and the
addition of Smilax hugeri and Maianthemum
stellatum. Symphyotrichum oblongifolium was
originally in the list of species found within the project
study area, but upon further review, the observation
was deemed to be Symphyotrichum phlogifolium
which is not a rare species.
North Carolina
Department of
Natural and Cultural
Resources, State
Historic Preservation
Office
3.3 Section 106 20.1 We have reviewed the above-referenced public notice and note
that the issuance for any permits related to the undertaking
include a commitment to enter a Programmatic Agreement (PA)
that outlines procedures, roles & responsibilities, and continued
consultation through the project to address effects on Cultural
and Archaeological Resources. We, therefore, have no further
comments on the notice and apologize for our delayed
response.
Noted.

DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
MARCH 2021

APPENDIX A.2
RESPONSES TO PUBLIC COMMENTS ON THE ENVIRONMENTAL ASSESSMENT

DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
A.2-1 MARCH 2021

Name Topic Means of
Comment
Comment
No. Comment Text Response
Martha Banks Support
of the
Project
Virtual Public
Hearing Chat
Box
1.1 Thinks it looks a whole lot better than it did years ago, thanks for
everyones hard work.
Thank you for your comments during the NCDOT
STIP Project #A-0009C Virtual Public Hearing.
Property
Impacts
Virtual Public
Hearing Chat
Box
1.2 Are any homes on Bill Crisp Rd being affected? Bill Crisp Road is being realigned to tie
perpendicular to Hyde Town Road. No homes are
anticipated to be relocated. On the public meeting
map, you can see the affected properties
designated by the light green color. Feel free to
contact us with any other questions or concerns.
Proposed
land
bridge
Virtual Public
Hearing Chat
Box
1.3 I would love to see a cool rope bridge instead of a land bridge 😁😁 Comment noted.
AT
parking
lot
Virtual Public
Hearing Chat
Box
1.4 How many parking spots will be at Stecoah Gap? The Gap is used a
lot and hard to find a space a lot of times. Can the parking area at
Stecoah Gap be enlarged?
Adequate turnaround space will be provided for
vehicles existing the Appalachian Trail parking lot on
NC 143. As of March 15, 2021, NCDOT is providing
right-in/right-out access with bulb-out turnarounds
to parking area. Travel flow will be one-way
(counter-clockwise) in parking lot. There will be
approximately 8 parking spaces.
Design
questions
Virtual Public
Hearing Chat
Box
1.5 How tall are the retaining walls? A question, can someone send me
information about increasing the State Maintenance of Bill Crisp
Road to the end of the road?
Could you verify the location of where you wish to
know the height of the walls? The wall heights can
vary depending on each wall. Your request for
increasing maintenance of Bill Crisp Road to the end
of the road will be passed along to the NCDOT
District Engineer, J Andy Russell. He can be
contacted directly at [e-mail]. Feel free
to contact us with any other questions or concerns.
Melanie Mayes
(WaysSouth)

Support
of the
Project
Virtual Public
Hearing Chat
Box
2.1 WaysSouth also supports this project. Very pleased to see it
maintains the natural environment of the area, yet increases driver
and pedestrian safety. Thanks team for your work.
Thank you for your comments during the NCDOT
STIP Project #A-0009C Virtual Public Hearing.
Proposed
land
bridge
Virtual Public
Hearing Chat
Box
2.2 Really pleased with the land bridge at AT crossing. Will help wildlife
and increase safety for hikers and drivers. Thanks.
Thank you for your comments during the NCDOT
STIP Project #A-0009C Virtual Public Hearing.
Support
of the
project
Publicinput.com 2.3 WaysSouth is excited about the project and identifies no major
environmental concerns. We wholeheartedly support the
Environmental Assessment for the proposed alternative (Alternative
1). We believe that the Assessment will support a Finding of No
Significant Impact (FONSI) and that the Least Environmentally
Comments noted. Thank you for your support of
the proposed project.

APPENDIX A.2
RESPONSES TO PUBLIC COMMENTS ON THE ENVIRONMENTAL ASSESSMENT
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
A.2-2 MARCH 2021

Name Topic Means of
Comment
Comment
No. Comment Text Response
Melanie Mayes
(WaysSouth) (cont.)

Damaging and Practicable Alternative was identified. We believe
the project will improve transportation within Graham County and
will enhance connectivity with the broader western North Carolina
area. We also believe that the project minimizes environmental
degradation, supporting the region’s impressive biodiversity, while
allowing residents continued enjoyment of their mountain
communities and streams. Finally, the size, scope, and cost of the
project is reasonable given the area’s transportation needs.

We share the concerns of Graham County, Robbinsville, and the
local communities that improvements are needed in their
transportation infrastructure. The project's preferred alternative
recognizes that the transportation needs of the area can be met by
improving the connection between Robbinsville and Stecoah. This
project avoids especially harmful impacts by following the existing
route rather than cutting across forested lands and neighborhoods.
The proposal adds passing lanes where possible, resulting in a
mostly three-lane facility. The road maintains the economic viability
of downtown Robbinsville by avoiding a bypass. Dedicated turn
lanes are proposed at several locations, including Robbinsville High.
Some new sidewalks are included, including around Robbinsville
High, which will enhance appearance and usability for Robbinsville
residents and visitors.

We are gratified that DOT has minimized the impacts to homes (9)
and businesses (5). We are pleased that the controversial routes
across the mountain formerly proposed – either through Tatham
Gap or up Jutts Creek – are eliminated.

WaysSouth commends NCDOT for producing a design that will meet
the transportation needs of the residents of western NC, and will
have minimal negative impact on the environment because
traversing through undisturbed forest and streams is minimized.
Additionally, this approach results in a project that makes economic
sense – a right-sized roadway will preserve what makes rural
Graham County so special – the forests, the mountains, the
streams, and the wildlife. We appreciate various mitigation efforts
to minimize impacts on endangered species such as the Indiana bat
and northern long-eared bat, e.g., no tree clearing from October to
April. We note the planned development of a plan in concert with
the US Army Corp of Engineers to minimize and mitigate the effects
of unavoidable impacts to streams and wetlands under the Clean
Water Act. We are also pleased that NCDOT will work with the
Forest Service to avoid planting invasive and non-native species,

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A.2-3 MARCH 2021

Name Topic Means of
Comment
Comment
No. Comment Text Response
Melanie Mayes
(WaysSouth) (cont).

and to continue maintenance in the future to minimize their spread
along the rights of way.

We appreciate the project commitments to mitigate negative
impacts. We appreciate the project’s commitment to develop a
Project Special Provision to deal with handling and treating any
acid-producing waste material generated during construction, and
to appropriately place the material involving total encapsulation if
necessary. That the initial surveys find only small outcrops of the
acid-producing rock suggests that these approaches are feasible and
will be protective of the region’s stream waters and aquatic life. We
also appreciate the coordination with the Wildlife Resources
Commission to build buffers around trout-supporting streams
during construction, and to time construction (avoided during
January to April) to minimize impacts. We note that several
archaeological sites were identified, and we appreciate those being
eligible for listing on the National Register of Historic Places, and we
also appreciate specific mentions of mitigation for certain existing
historical properties.

WaysSouth would like to also extend thanks to DOT and its
consultants for involving the environmental community and
WaysSouth in their planning process. WaysSouth has been
interested in this portion of Corridor K for at least a decade, and in
the past we were disappointed to oppose the project because of its
unacceptable impacts on the conservation values of western NC.
Since the announcement of the project restart in early 2019, DOT
and its consultants conducted open meetings with environmental
stakeholders, and later participated in a local meeting to discuss the
project with concerned Stecoah Valley residents and Graham
County leaders. Further, our ideas for design alternatives at the
intersection of NC28 and NC143, and at the Appalachian Trail
crossing were welcomed, and DOT and consultants participated in
several ad hoc meetings to discuss our suggestions. We are so
pleased to have worked in a collaborative and transparent manner
with DOT and its consultants, and the leaders of this project should
be commended for their efforts.

In summary, WaysSouth supports the Environmental Assessment
for this project, and we remain ready to assist you in future efforts.

Proposed
land
bridge
Publicinput.com 2.4 The Appalachian Trail crossing at Stecoah Gap will be accomplished
by a land bridge to facilitate both human and wildlife crossings, and
to maintain a more natural appearance. The crossing will certainly
Comments noted. Thank you for your support of
the proposed project.
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A.2-4 MARCH 2021

Name Topic Means of
Comment
Comment
No. Comment Text Response
Melanie Mayes
(WaysSouth) (cont.)
improve safety for pedestrians, wildlife, and traffic. The design
visualization of the crossing looks lovely and this concept should
greatly improve the appearance and utility of the existing crossing.
We believe this innovative crossing will serve as a model for other
projects in North Carolina, and that the crossing may become a
tourist attraction in and of itself. The crossing is at an important
boundary for biodiversity, where climbing lanes coming up each
side of the gap would have made crossing the road perilous for
wildlife. The historical parking area will be maintained and enough
space will be available for turning around. The tiered and vegetated
retaining wall will improve the appearance of the highway when
approaching the gap. Also, lessons learned may be applicable to
other similar scenarios.
Proposed
multi-use
path
Publicinput.com 2.5 The Hydetown Road greenway in Stecoah Valley will also add to the
value of the facility for local residents.
Comment noted. Thank you for your support of the
proposed project.
Callie Moore
(MountainTrue)

Support
of the
Project
Virtual Public
Hearing Chat
Box
3.1 MountainTrue fully supports this project. You did an excellent job
with the EA. We will submit more detailed comments in writing.
Thank you for your comments during the NCDOT
STIP Project #A-0009C Virtual Public Hearing.
Questions
about A-
0009A
and
project
schedule
Virtual Public
Hearing Chat
Box
3.2 I thought that those particular alternatives T-1 and T-4 were
completely abandoned by DOT after the public outcry in February
2019?
Comment verbally addressed during the Virtual
Public Meeting. T-1 and T-4 will not be studied for
A-0009A given funding constraints and public
support to improve existing US 129.
Support
of the
project
Publicinput.com 3.3 MountainTrue respectfully submits the following comments with
regard to the Environmental Assessment for the “Corridor K,
Appalachian Highway Development System” project in Graham
County, North Carolina. MountainTrue is an incorporated 501(c)(3)
nonprofit organization dedicated to creating and sustaining a
healthy environment by championing resilient forests, clean waters,
and healthy communities, promoting clean energy, and increasing
civic engagement in policy-making in the Southern Blue Ridge
Mountains. Thank you for the opportunity to comment.

I am pleased to be writing to you today to express MountainTrue’s
full support for the Preferred Alternative that would improve the
existing alignments of US 129, NC 143 and NC 28 between
Robbinsville and Stecoah, increasing shoulder widths and adding
passing/climbing lanes where necessary. We agree with the decision
to remove the Andrews to Robbinsville portion of the project to
better focus on delivering improved mobility and reliability between
the existing four-lane section on NC 28 at Stecoah and US 129 in
Comments noted. Thank you for your support of
the proposed project.
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Callie Moore
(MountainTrue)
(cont.)
Robbinsville. The Preferred Alternative results in no new significant
fragmentation of forests and minimizes impacts to existing homes
and businesses.

We appreciate the project’s commitment to intensive study of acid-
producing rock in the areas of excavation and total encapsulation of
the material if the results warrant such an extreme level of
mitigation for the protection of water quality in the project area.

Our only suggestion for project improvement is to consider
purchasing a wider right-of-way along Stecoah Creek and fully
restoring the dimension, pattern and profile of the stream as part of
the mitigation plan for impacts to Waters of the U.S. The original
meanders of the stream are still visible on the aerial photographs
presented for this project. Mitigating stream impacts onsite is the
first preference of watershed managers, if a viable location is
available. We believe it is and we would love to see this section of
stream restored, rather than simply moved out of the way of the
road improvements and mitigated elsewhere.

Thank you for a thorough and well-presented Environmental
Assessment of this project! Since it seems we don’t get to make
such positive statements often enough, I’ll say it again:
MountainTrue fully supports this project as proposed!
Proposed
land
bridged
Publicinput.com 3.4 MountainTrue also fully supports the proposed land bridge to
facilitate the crossing of wildlife and pedestrians across NC 143 at
one of the widest parts of the improved highway. Building this
structure and relocating the Appalachian Trail onto it, would
mitigate negative visual and noise impacts of the highway crossing
and prevent unsafe slick conditions during freezing temperatures
that other types of pedestrian crossings might create. Safe passage
for wildlife will minimize vehicle crashes and fatalities of both
wildlife and humans.
Comment noted. Thank you for your support of the
proposed project.
Proposed
multi-use
path
Publicinput.com 3.5 From a healthy communities perspective, we also fully support the
addition of sidewalks from Robbinsville High School to the
intersection of US 129 and Five Point Road and the multi-use path in
Stecoah. These project additions, along with the land bridge will
positively impact pedestrian mobility and safety within the project
area.
Comments noted. Thank you for your support of
the proposed project.
Shawn Lakey

Property
Impacts
Virtual Public
Hearing Chat
Box
4.1 It looks like it's taking my house, 307 Hwy 28. Is that right? Project team contacted Lakey family regarding their
question about potential impacts to a specific
property. Project team left voicemail for Lakey
family indicating that there are options that can be
explored in final design to avoid displacing their
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Shawn Lakey (cont.) home and provided contact information for design
team if resident has any follow up questions.
Hugh Irwin
(Wilderness
Society)

Questions
about A-
0009A
and
project
schedule
Virtual Public
Hearing Chat
Box
5.1 What will be the sequence of the 3 sections? Comment verbally addressed during the Virtual
Public Meeting. Construction of the project on US
129 from south of Five Point Road (SR 1275) to NC
143 and along NC 143 to Beech Creek Road (SR
1223) (“CA”) is scheduled to start in August 2022.
The section of NC 143 from Beech Creek Road (SR
1223) to north of the Appalachian Trail (“CB”) is
scheduled to start construction in September 2022.
The section of the project that includes NC 143 from
north of the Appalachian Trail to NC 28 and NC 28
to east of Gunters Gap Road (SR 1235) (“CC”) is
scheduled for construction in October 2022.
Proposed
land
bridge
Virtual Public
Hearing Chat
Box
5.2 Really like the design of the land bridge Thank you for your comments during the NCDOT
STIP Project #A-0009C Virtual Public Hearing.
Support
of project
Publicinput.com 5.3 Dear Corridor K Project Management Team:

Please accept these comments from The Wilderness Society (TWS)
on the Environmental Assessment for Project A-0009C of Corridor K.
TWS has followed the development of this project for years. We are
pleased to support the preferred alternative (Alternative 1). NCDOT
and all parties should feel good that this innovative and
collaborative alternative addresses the transportation needs of
Western North Carolina while also safeguarding the significant and
irreplaceable environmental assets of this region.

TWS particularly appreciates NCDOT’s approach to environmental
issues since the restart and refresh of the project. The fresh look at
issues and the openness to feedback and ideas has allowed
solutions to emerge that addressed not only long-standing issues
but also issues that emerged as design concepts emerged. NCDOT
and consultants were open to seeing the perspectives of a wide
range of stakeholders and remained open to solving issues in
innovative and collaborative ways. This attitude and approach
allowed exciting new solutions to emerge that addressed
transportation needs while minimizing impacts to communities and
the environment. Not only are community impacts avoided and
minimized but proposed improvements such the multi-use paths in
Robbinsville and Stecoah and the AT land bridge will provide critical
infrastructure that will benefit both communities and the
environment for the long term.
Comments noted. Thank you for your support of
the proposed project.
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Hugh Irwin
(Wilderness
Society) (cont.)

We support Alternative 1 and believe that the Environmental
Assessment will support a Finding of No Significant Impact (FONSI).
We think that the EA is correct in identifying Alternative 1 as the
Least Environmentally Damaging and Practicable Alternative. The EA
does a good job in its analysis, but more importantly, NCDOT and its
consultants did the hard and creative work of coming up with
innovative solutions to very difficult issues. Alternative 1 solves
problems that have defied solution for decades – how to provide for
the real transportation needs of Graham County and Western North
Carolina while also avoiding massive environmental impacts and
also impacts to communities. Solving this difficult problem took
innovative and creative solutions. We applaud NCDOT for meeting
this extremely difficult task with what are truly creative and
innovative solutions.
Proposed
land
bridge
Publicinput.com 5.4 TWS is particularly pleased with the proposed land bridge at
Stecoah Gap. As plans for A-0009C improvements developed, it
became clear that passing lanes that in general would alternate
between different sides of the road would converge at Stecoah Gap,
creating 4 lanes at the Stecoah Gap curve that would pose
difficulties for both hikers and wildlife. As NCDOT and its
consultants considered different designs for the highway addressing
hiker and wildlife needs as well as safety, they created an
alternative that not only solved issues and problems but created an
innovative solution that should be used as an example in other
highway designs. The resulting land bridge allows the best use of
passing lanes to enable traffic to navigate this steep section of
highway separating vehicles from hikers and wildlife for the safety
of both. It also provides an attractive crossing of the highway that
will best preserve the experience of AT hikers, and will enable
wildlife to successfully cross the highway in this critical area with
prime USFS wildlife habitat on both sides, thus preserving and
enhancing a critical wildlife corridor. The land bridge and associated
landscaping is also extremely attractive. This will preserve and
enhance the intersection between the Appalachian Trail and the
highway, creating an striking but inviting interface between the
historic and natural features of the Appalachian Trail and national
forest land on the one hand and the highway on the other. The land
bridge is likely to become a scenic feature that is appreciated from
the AT as well as from the highway. We applaud this feature as well
as other features of Alternative 1 that approach highway design
from the standpoint of solving transportation problems while also
preserving and enhancing community and environmental values.
Comments noted. Thank you for your support of
the proposed project.
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Hugh Irwin
(Wilderness
Society) (cont.)
Fred Baggott

Questions
about A-
0009A
and
project
schedule
Virtual Public
Hearing Chat
Box
6.1 The T-1 and T-4 parts are postponed? Until when? Comment verbally addressed during the Virtual
Public Meeting. T-1 and T-4 are included in NCDOT
STIP Project A-0009A are not currently being
studied. See below for additional details provided
via email to Mr. Baggott.
Questions
about A-
0009A
and
project
schedule
Publicinput.com 6.2 I was on the NCDOT public call tonight. Thanks for informing us
about the new timing for these proposed roads. (T-1 and T-4). So,
nothing will happen until 2032, or beyond, regarding Robbinsville to
Andrews? And what was(were) the reason(s) for the long delay?
The NCDOT State Transportation Improvement
Program (STIP) will be voted on next week by the
NCDOT Board of Transportation. The STIP is a
program of all anticipated construction projects for
a 10 year period from 2022-2032. A-9A, Corridor K
from Robbinsville to Andrews, is shown as an
unfunded project in future years (beyond 2032) in
this document. It is shown in the current 2020-2029
STIP as an unfunded project in future years. At no
time over the past 10 years has A-9A been
programmed for construction in the 10 year STIP.
The focus for the past 10 years has been to
construct the A-9C section between Stecoah and
Robbinsville. All projects across North Carolina must
compete for funding through the Strategic
Transportation Investments law passed in 2013.
This law requires the Division and local
governments through their Metropolitan or Rural
Planning Organization to prioritize projects and
determine funding based on a data driven process.
As Appalachian Development Highway System
(ADHS) funds can only be utilized on identified
Appalachian Highway corridors, the projects on the
ADHS compete against each other. We only have
two incomplete ADHS corridors in North Carolina –
Corridor K (A-9) and Corridor A (A-11). The Division
and Southwestern RPO have consistently prioritized
the A-9C section of Corridor K as the top priority for
ADHS funding. A-9A has never been the top priority
nor has it scored very well. Furthermore, the
NCDOT only has approximately $200 million of
ADHS funds remaining to program ADHS projects.
The estimated cost of A-9C is $130M so, once we
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Fred Baggott (cont.) fully determine the cost of A-9C and if remaining
funds are available, we may be able to prioritize and
program additional improvements on the A-9A
section. Obviously, we do not expect to have
enough remaining ADHS funds to complete the
entire A-9A section, but we will seek to make the
most improvements as is possible. I hope this helps
to answer your questions. I realize that this may be
confusing and I apologize for all of the acronyms.
Glen McCoy Proposed
land
bridge
Virtual Public
Hearing Chat
Box
7.1 land bridge is a lot less expensive than a tunnel Comment verbally addressed during the Virtual
Public Meeting. Comment noted. Alternatives with
tunnels were eliminated due to maintenance and
operations costs associated with the tunnels were
estimated to be a notable portion of the Division 14
annual maintenance budget.
Questions
regarding
culverts/p
ipes
Virtual Public
Hearing Chat
Box
7.2 There are 2 culverts that are not shown located in Stecoah near
Martin Jenkins Rd. Are these to be removed or changed. Ok, the
proposed expansion will add road on top of my culvert. It is a 15
inch diameter plastic product. Will that need to be replaced?
Project team contacted Glen McCoy by phone and
email after Virtual Public Hearing to discuss his
question related to culverts. 15-inch plastic culverts
likely will need to be replaced.
David Sumner Proposed
land
bridge
Virtual Public
Hearing Chat
Box
8.1 Let's save some much-needed tax dollars and delete both the land
bridge and the Hwy 28 walkway.
Comment noted. Thank you for your comments
during the NCDOT STIP Project #A-0009C Virtual
Public Hearing.
Leroy Walden Proposed
multi-use
path
Virtual Public
Hearing Chat
Box
9.1 Please explain the multi-use trail in Stecoah - are there plans to
eventually extend this beyond the boundaries shown in this
presentation? Will there be a protected pedestrian crossing to the
Stecoah Diner from the multi-use trail?
Comment verbally addressed during the Virtual
Public Meeting. There are no plans to extend the
multi-use path further than what was shown on the
public hearing maps. Local officials presented the
need for a multi-use path to NCDOT, however, a
protected pedestrian crossing at Stecoah Diner will
not be included at this time.
Kyle Norcross Design
Questions
Virtual Public
Hearing Chat
Box
10.1 Has any plan for decorative concrete for retaining walls been
discussed? Will fill slopes also be benched and landscaped? I
noticed some existing entrances that don't appear to have new
entrances is it NCDOT proposal to remove these existing entrances.
Can landscaping and decorative concrete walls be considered?
particularly fill slope and cut slope landscaping
Comment verbally addressed during the Virtual
Public Meeting. Decorative concrete will be applied
to the retaining walls in the Stecoah Gap area at the
Appalachian Trail.
Questions
regarding
culverts/p
ipes
Virtual Public
Hearing Chat
Box
10.2 I can help with missing culverts. I live on Martin Jenkins Rd where
Glenn is talking about
Project team contacted Glen McCoy by phone and
email after Virtual Public Hearing to discuss his
question related to culverts. 15-inch plastic culverts
likely will need to be replaced.
Gary Blank

Support
of the
project
Publicinput.com 11.1 I want to weigh in with an endorsement of the preferred alternative
for this project. I spent most of ten weeks during the summer of
1998 doing biological fieldwork in Sweetwater and Stecoah Valleys,
tramping through the fields and woods to gather data for the
Supplemental EIS in its early phase. I was not in favor of the massive
Thanks very much for your comments on A-0009!
We’re very happy with how the process has
unfolded this time and that Graham County
residents will finally have an improved
transportation system! There will be a virtual Public
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Gary Blank (cont.) cuts and fills (>700 feet on each side) that could have been required
for those either of those new alignments and the tunnels. This plan
is much better environmentally and respects the beauty of that
landscape, the integrity of the ecosystems and doesn't screw up the
water supply for half the people living there. I teach the NEPA
process and appreciate how this project has evolved.
Hearing on October 1 at 6:00pm - details are under
development but will be posted on the project
webpage when available. I hope you’ll join us! In
the meantime, feel free to reach out with any
additional questions or comments!
Edd Satterfield

Support
of the
project
Publicinput.com 12.1 1. We have a plan, let’s fast track it and get it done. 2. Keep the land
bridge. 3.We do not need to waste taxpayers money on a
pedestrian trail and pedestrian bridge for one or two dudes to get
to Stecoah Diner. 4. We need to move the section from Robbinsville
to Andrews up, 2032 is way too long. Start the EA now, with the
money we are saving on the Stecoah-Robbinsville section compared
to the ARC funding for the corridor is supposed to be banked, we
have no reason to wait. 5. We do not need to do decorative
landscaping on cut and fill slopes, in a few years nature takes over
and it will landscape it’s self.
Good morning! Thank you for sharing your
thoughts regarding the proposed Corridor K project
in Graham County (STIP Project No. A-0009C.). Your
comments will be submitted into the official Public
Records. The comment period for the October 1,
2020 Public Hearing ends on October 30, 2020. The
project team will review and carefully consider all
comments received and document the decision-
making process in the final environmental
document, called a Finding of No Significant Impacts
(FONSI). The FONSI is scheduled to be completed in
December 2020 and will be posted on the project
website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project. If you have
any additional comments or questions concerning
the proposed Corridor K project, please feel free to
contact us. Thank you! Amy

I just wanted to follow up on your comments about
the Corridor K project in Graham County (STIP
Project A-0009C). We appreciate you taking the
time to provide feedback and have incorporated
your comments into the Public Record. With respect
to your comment about the multi-use path in
Stecoah, this was originally studied due to local
request for a walkway for recreational and health
purposes. We will be conveying your concerns to
local officials, who will provide a recommendation
on whether or not to pursue the path. Funding for
the Andrews to Robbinsville portion depends on
several elements, including remaining ADHS funds
and state funding priorities. The state uses a data-
driven prioritization program to determine which
highway projects receive funding. Projects are
scored and ranked using measures such as safety,
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Edd Satterfield
(cont.)
benefit-cost, and local priorities. NCDOT uses this
information as a primary factor for determining
project schedules. I hope this helps provide a little
clarification on funding and project schedules!
Please let me know if you have any other questions
or if it’d be helpful to have a call to discuss your
comments further.
Doyle Brock Support
of the
project
Publicinput.com 13.1 Yes, my name is Doyle Brock. I live in Robbinsville. I've traveled this
road since I was a kid, I'm ninety five years old and I've walked the
road long ago when it had very little traffic and was all gravel. But
after looking at the proposed improvements while it looks good to
me you've been involved with the Lions Club trying to get a four-
lane through Graham County for the last fifty years, but it's at least
we're getting a start on it. So you can put me down as being in favor
of the proposed section that you all sent out on the same brochure
that I had a copy of which it looks good to me. So the quicker the
better, soJust I'm I won't be able but I wouldn't want to find out
where the where the meeting was to take place. It didn't show I
never did find it on this mail thing. Just other than it special meeting
was being called. But where is that meeting you my number is 828-
479-3578. If you will, give me a ring as to where the where the
meeting is to be. Okay. Thank you.
Handout was mailed to Mr. Brock and Amy
Sackaroff spoke to Mr. Brock on the phone two
times to review meeting materials and discuss
project. Mr. Brock expressed general support for
the project as proposed. Alexa Kennedy left
voicemail for Mr. Brock to return call if he had any
further questions about the handout.
Noreen and Frank
Morley

Support
of the
project
Publicinput.com 14.1 I approve the way the project will be handled. Look forward to its
completion!
I just wanted to reach out to thank you both for
sharing your thoughts regarding the proposed
Corridor K project in Graham County (STIP Project
No. A-0009C). We’re very happy with how the
process has unfolded this time and that Graham
County residents will finally have an improved
transportation system! Your comment will be
submitted into the official Public Records. The final
environmental document, called a Finding of No
Significant Impact, is scheduled to be complete in
December 2020 and will be posted on the project
website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Judy Robinson

Support
of the
project
Publicinput.com 15.1 NCDOT - I was so pleased to read about the proposed Preferred
Alternative for this project. I believe that these improvements to
the existing roads will greatly enhance the safety of the route while
preserving the natural beauty of this rural mountain area. I think
the land bridge over the AT will benefit both hikers and wildlife, and
it looks like it will be visually attractive as well based on the
Alexa Kennedy spoke to Judy on the phone to
discuss comment. Judy had no further questions
about the project.

A follow-up email was sent after the phone
conversation: Just sending a quick follow up to our
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Judy Robinson
(cont.)
renderings included. I am greatly relieved that the original plan for
the 4 lane with the tunnel was abandoned for this much more
appropriate alternative.
phone conversation earlier. Thank you again for
your feedback on the A-0009C project. The final
environmental document, called a Finding of No
Significant Impact, is scheduled to be complete in
December 2020 and will be posted on the project
website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Tom Hoffman Support
of the
project
Publicinput.com 16.1 I wish to express my support for your adoption of Alternative 1 for
Corridor K in Graham County. Improving the existing highway
infrastructure meets the needs of county residents and businesses
with minimal impact to the environment. Adding passing lanes,
widening shoulders and providing a safe way for Appalachian Trail
hikers to cross 143 are adequate solutions to the problems
encountered on 143 and 28 as they now exist.
I just wanted to reach out to thank you for sharing
your thoughts regarding the proposed Corridor K
project in Graham County (STIP Project No. A-
0009C). We’re very happy with how the process has
unfolded this time and that Graham County
residents will finally have an improved
transportation system! Your comment will be
submitted into the official Public Records. The final
environmental document, called a Finding of No
Significant Impact, is scheduled to be complete in
December 2020 and will be posted on the project
website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Ann Strange Support
of the
project
Publicinput.com 17.1 Thank you for listening to environmental issues and coming up with
a good compromise plan.
Comment noted. No follow-up email or phone
number for Ann were given.
Morgan
Sommerville
(Appalachian Trail
Conservancy)

Support
of the
project
Publicinput.com 18.1 Dear Mr. Sullivan and Ms. Austin:
This is the reply of the Appalachian Trail Conservancy (ATC) to your
request for comments on the above noted project, which intersects
the Appalachian National Scenic Trail (A.T.) at Stecoah Gap between
the towns of Robbinsville and Stecoah, in Graham County North
Carolina. The A.T. is a unit of the National Park System and is
managed in this location through the A.T.’s Cooperative
Management System in partnership with the volunteers of the
Smoky Mountains Hiking Club, the USDA Forest Service, the NPS
Appalachian National Scenic Trail [ANST] and ATC. As a unit of the
National Park System the A.T. is a Section 4(f) resource, and due to
its age and eligibility for listing on the National Register of Historic
Places the A.T. is a Section 106 resource. The ATC notes that the
Graham County Commissioners have endorsed the “improve
existing” alternative and views the Graham County endorsement as
Comments noted. Thank you for your support of
the proposed project.
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Morgan
Sommerville
(Appalachian Trail
Conservancy)
(cont.)
critical to assuring this alternative adheres to the purpose of the
project, i.e. “to provide the transportation infrastructure necessary
for the well-being of local residents by improving mobility and
reliability between the existing four-lane section on NC 28 at
Stecoah and US 129 in Robbinsville.”

The ATC has reviewed the EA for Corridor K, STIP Project No. A-
0009C and joins with Graham County to support selection of the
“improve existing” alternative as the preferred alternative for the
project, with the following ATC stipulations: ATC's support of the
"improve existing" preferred alternative is dependent upon
execution of a Programmatic Agreement to resolve impacts on the
ANST under Section 106 and to address Section 4(f) concerns,
construction of the proposed land bridge to allow safe passage of
wildlife and A.T. hikers across the widened highway at Stecoah Gap,
acquisition of the whole private tract of land on the southwest side
of Stecoah Gap which will be crossed by the proposed A.T.
relocation, construction of a relocation which moves the A.T. from
the east side of the ridge to the west side of the ridge to mitigate
visual impacts of the widened highway as seen from the A.T.,
retention of a parking area at Stecoah Gap which may be used by
A.T. hikers, and construction of a connector trail between the
parking area and the A.T. on the south end of the land bridge. It is
the presumption of the ATC that the NCDOT and/or the FHWA will
be responsible for completing these stipulations.

Thank you for your positive and persistent partnership work to
develop this project and for the opportunity to comment. We
appreciate your appropriate consideration of the Appalachian
National Scenic Trail in the planning of this project. We look forward
to successful completion as soon as possible.
Sandra Gross
(Tennessee Citizens
for Wilderness
Planning)

Support
for
project
Publicinput.com 19.1 I write on behalf of Tennessee Citizens for Wilderness Planning, an
Oak Ridge-based environmental advocacy organization with a
longtime interest in Corridor K projects. Much of our state-wide
membership recreates on the lands and waters of East Tennessee
and western North Carolina.

The preferred alternative is a good approach. It is good to improve
the existing route, rather than going through the mountains. This
option minimizes damage and disruption to wildlife, streams,
residents, and businesses.

Thanks to Department of Transportation for this thoughtful,
strategic approach.
Comments noted. Thank you for your support of
the proposed project.
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Name Topic Means of
Comment
Comment
No. Comment Text Response
David Newsome Property
impacts
Publicinput.com 20.1 I've been getting I've gotten a couple of brochures associated with
this corridor k Improvement, and I can't figure out why am I've
been selected to get this brochure. I do own some property in
Cherokee County, and I'm just wondering if the proposal wage
conceivably could affect my property. My name is David Newsom.
My telephone number is 828-628-3615.I'd really like to know the
answer to this question. If you could please provide that. Thank you.
Hi, Mr. Newsome – Just following up on our phone
conversation to let the rest of the project team
know that we spoke about your property in
Cherokee County and that the portion of the project
from Andrews to Robbinsville in Cherokee County is
currently unfunded.
Cal Stiles/Van
Winkle Law Firm

Property
impacts
Mailed
comment
21.1 Dear Property Owner: If you have not already been contacted by
the North Carolina Department of Transportation {"NCDOT'') about
property takings for the Corridor K from NC 28 at Stecoah to US 74
East of Andrew project, you likely will be relatively soon. What you
may not be aware of is that the amount of compensation offered
for condemned property is often far below the full and fair amount
required under our North Carolina and United States Constitutions.
The Van Winkle Law Firm is committed to our clients in all
proceedings relating to eminent domain. Our decades of eminent
domain experience include situations and cases affecting owners of
single and multi-family homes, apartment buildings, shopping
centers, convenience stores, restaurants, industrial properties,
commercial properties, timberland, farms, undeveloped land, and
tenants of leased property. We have successfully litigated for
landowners to jury verdicts involving all sorts of property,
recovering amounts greatly in excess of what was offered by
governmental condemnors. We invite you to have a free conversat
ion with us about this matter by calling 828-258-2991. If you engage
our firm to seek just compensation for you, we will do so on a
contingency basis; therefore, our fee wi ll be calculated on the
amount received above the initial offer. Seeking assistance from a
qualified eminent domain defense attorney early in the process is
important. Delay can lead to loss of evidence. We encourage you to
contact us at your earliest convenience.
As noted in Section 2.1 of the Environmental
Assessment,
(https://www.ncdot.gov/projects/corridor-
k/Documents/a-0009c-final-ea-8-26-20.pdf),
Corridor K from Andrews to Robbinsville (A-0009A)
is not included in the current study. Public
meetings were held in February 2019 to present
study corridors from Andrews to Robbinsville;
however, public feedback and the lack of available
funding for the entire corridor contributed to the
decision to remove the A-0009A portion of the
project. As such, the study corridors between
Andrews and Robbinsville have not been studied in
detail and A-0009A is currently unfunded.
Additional details can be found in the project FAQs
(https://www.ncdot.gov/projects/corridor-
k/Pages/faq.aspx). NCDOT selected the Improve
Existing Alternative as the Selected Alternative for
Corridor K between Robbinsville and Stecoah.
Mapping of the Selected Alternative can be viewed
on the project webpage. With regard to Corridor K
between Robbinsville and Stecoah, NCDOT is
holding a virtual public hearing on October 1, 2020
from 6pm to 8pm for the public to receive
information on the proposed project and ask the
project team questions. Residents can also view
printed meeting materials at several locations in the
Graham County area: o NCDOT Graham County
Maintenance Yard 2447 Tallulah Road Robbinsville,
NC 28771 o NCDOT District 3 Office 191
Robbinsville Road Andrews, NC 28901 o Highway
Division 14 253 Webster Road Sylva, NC 28779
Although the N.C. Department of Transportation
works to minimize the number of homes and
businesses displaced by a road project, it is
inevitable, in many cases, that a certain amount of
private property is needed. Residents can find
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Cal Stiles/Van
Winkle Law Firm
(cont.)
several resources on the right of way acquisition
process on the NCDOT website:
https://www.ncdot.gov/projects/Pages/property-
owner-resources.aspx Citizens can send their
questions and comments to the project team:
[e-mail] or contact
the team directly.
Pam Lakey Property
Impacts
Publicinput.com 22.1 Yes, this is Pam Lakey and my house is 307 Highway 28 right where
they're doing the widening of the road. I've got showing right of
way, and it's showing my house in part and most of my land and I
need to find out whether or not this is correct or not. Please give
me a call back. 828-735-4933
Amy Sackaroff left detailed voicemail answering
Mrs. Lakey’s question and noted that the Lakey
family is welcome to contact the project team with
any additional questions.
Anita Holder, Billie
Holder, Roger
Holder
Property
Impacts
Publicinput.com 23.1 Request to maintain access to David M Holder property (at station
43+00LT NC 28); Request to maintain access to Billie and Nina
Holder property (at station 117+00 RT NC 28). Access to the Billie
and Nina Holder property is via an easement from Hooper but don’t
want to be dependent on easement for sole access; forced to ford
the creek now. Request to maintain access from NC 28 to Michael
Holder property (at station 148+00). Request alignment shift as
much as possible to Michael Holder property station 146+00 to
156+00 RT, request to maintain access to property, concerned with
the grade of the access and if there would be any usable remnant.
Wanda Austin spoke with Holder family to address
questions.
Design
question
Publicinput.com 23.2 Concerned with loss of water source at base of fill section on Roger
Holder property 150+00 to 153+00 LT. Concerned with sight
distance and safety of NC 28 and Gunter Gap Road intersection
Raymond and Kelly
Karr
Property
Impacts
Publicinput.com 24.1 If this is not the proper contact email for questions, please forward
to the appropriate persons. Thank you.

Regarding the proposed replacement of a culvert under NC143
between Orr Branch and Nathan Garland roads. We live on the
West side of NC143, but the water to our home comes from a spring
on the mountain to the East. The water line travels under the
bridge at Nathan Garland, and through the current culvert under
NC143. (drawing attached).

Will provisions be made to limit the loss of water to our property
during this construction? Also, it appears there will be limited
impact to our property other than a triangular piece marked out for
'proposed right of way'. I was hoping to obtain clarification as to
where that actually is on our existing property.
Mr. Karr, It was a pleasure speaking with you in
regards to how your property could be affected on
the A-9 project. As mentioned, the design on the
Hearing Map is preliminary and there may not be
any right of way acquisition on your property. As
the final design progresses, we will get a better
understanding of any potential impacts. As we
discussed with the water line, it will most likely be
removed since NCDOT prefers not to have utilities
in culverts. Verification of ownership, legal access,
and any potential solutions such as relocating the
water will be investigated during final design.
Please feel to contact us if you have further
questions.
Robert Kyle
Norcross

Property
Impacts
Scanned
comment sheet
25.1 My wife and I own multiple tracts of land along the current route
that will be impacted by additional ROW. We would like to thank
the team for the route that has been chosen. We believe it is the
best of all the options that were presented. Engineering has done
Thank you for sharing your thoughts regarding the
proposed Corridor K project in Graham County (STIP
Project No. A-0009C.). Your comments have been
incorporated into the official Public Record. The
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Robert Kyle
Norcross (cont.)

an excellent job of minimizing impacts to homes, businesses,
personal property, and the Stecoah Valley. We would like to discuss
our concerns personally with a representative from the team.
project team met on November 3, 2020 to review
and carefully consider all comments received. Your
comments were reviewed and are being considered
as the project moves into final design. With respect
to your comments regarding the proposed lanes on
NC 28 through Stecoah Valley, the project team
evaluated a number of traffic scenarios along the
entire length of the project. Turning lanes were
added where needed due to traffic volumes and the
number of turning movements at those locations. It
is important to note that the addition of
passing/climbing lanes can result in a 20% reduction
in all crashes and a 33% reduction in fatal/injury
crashes on rural, two-lane roadways. As such, the
addition of an extra lane and shoulders on NC 28
will help create a safer experience for all road-users
based on the physical constraints that have to be
considered in the design. Further, a center turn
lane for the entire length of Stecoah Valley would
not meet the conditions of the project’s formal
Purpose and Need Statement to provide the
mobility and travel reliability benefits afforded by
alternating passing/climbing lanes.

If you have any additional comments or questions
concerning the proposed Corridor K project, please
feel free to contact us.

Design
question
Publicinput.com 25.2 Please consider landscaping and decorative concrete walls along the
route. Property owners have planted trees and shrubs along the
route to help with noise and cars headlights. Many of these trees
will be removed during the widening process. I purchased one tract
of land and let the trees grow to specifically block the headlights
from my home. On the provided map that shows the A-T crossing it
indicates a stepped cut slope wall with landscaping. Can this be
provided along the entire route?

Please consider a center turn lane replacing one of the proposed
lanes from Wolf Creek General Store to Stecoah Heights Road The
addition of a center turn lane would allow for much safer
movement in and out of side roads. This stretch of highway is
heavily used by commercial vehicles entering and exiting a local
businesses in Stecoah. One business moves large earth moving
machines and trucks in and out of the community mostly using the
northern Stecoah Road intersection, this intersection is also
advertised as one entrance to the Stecoah Valley Center. Another
local business with large trucks uses Hyde Town road Intersection. A
restaurant a campground and some other smaller businesses use
the Lower Stecoah road intersection. The traffic for Stecoah Valley
Center and another campground primarily use the southern Stecoah
Road Intersection across from Bill Crisp Road. In conjunction with
the center turn lane I ask that you consider acceleration and
deceleration lanes at the heavily used intersections of Lower
Stecoah Road, both Stecoah Road Intersections and Hyde Town Rd.
These lanes would utilize the proposed shoulder width for
dedicated turning. The lanes could be created at these intersections
by simply narrowing the opposite side shoulder or bike path slightly
and increasing the shoulder width on the side requiring the
deceleration/acceleration lane. The scenario at the Northern
Stecoah Road entrance is particularly concerning - If a car is passing
in the uphill passing lane (the center lane) and a car is making a left
hand turn (from the center lane) onto Stecoah Road while waiting
for downhill traffic to pass an accident could occur as the uphill
passing car will be coming out of a corner and have limited sight
distance. I do not believe these changes would impact the minimum
required speed. I do not believe these changes would impact any
additional property outside of your current plan and they should
not incur any additional cost as overall width from edge of
pavement to edge of pavement would be the same. The value of
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Robert Kyle
Norcross (cont.)
these changes in terms of safety however would be tremendous.
General
questions
/comment
Publcinput.com 25.3 I attended the public meeting in Stecoah on Tuesday night I am a
resident of the community. It is concerning the lack of notices that
were provided before the meeting I don't feel that the community
was aware of the meeting. Most of the residents I have spoken to
were unaware of the meeting. I arrived late as my wife noticed on
the Graham Star Facebook page that the meeting was being
conducted. I believe some flyers, posters, and signs should have
been provided through-out the community. Impacted property
owners could have and should have been contacted. The majority of
local residents work and many work out of town. In a rural area
where the majority of the residents work away from home the
decision to have a meeting on a Tuesday night at 5 knowingly limits
the local participation to almost zero. I feel a Saturday evening
meeting would be more appropriate and would have more
community participation. I do not know if the times and dates were
set by local county commissioners or the DOT.
Grey Lakey

Property
impacts
Publicinput.com 26.1 To Whom it May Concern: I am a resident of Stecoah. I live on
Stecoah Rd., near Hwy 28. I am concerned that the proposed road
will not offer adequate benefit to residents when compared to the
potential negative impacts, such as noise pollution, destruction of
homes and environmental harm. I feel the road would be justified if
there were a hospital in or near Robbinsville. If safety of residents is
a concern to project leaders, increasing access to healthcare should
be an equal priority.
I just wanted to reach out to you regarding your
comments on the Corridor K Improvements (A-
0009C) project. We appreciate you taking the time
to provide feedback and have incorporated your
comments into the official Public Record. Since the
project restart in 2015, the team has examined
various design options to find an alternative that
would serve the needs of residents, while
minimizing impacts. Part of this process has
involved various technical studies and analyses to
determine project impacts, including noise, air, and
visual impacts. NCDOT conducted a noise study and
found that no noise impacts were anticipated with
the project due to low traffic volumes. As part of
the environmental process, the team has held
numerous meetings with resource agencies
(including US Army Corp of Engineers, US Forest
Service, and the Environmental Protection Agency)
to ensure the selected alternative is one that causes
the least harm while still being practicable. The A-
0009C Team has also held various meetings with
environmental stakeholders (including Mountain
True, WaysSouth, and Wilderness Society) over the
years to ensure that local environmental concerns
were taken into account. Section 3.0 of the EA
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Grey Lakey (cont.) (found here) further details anticipated impacts and
measures to address these. Our goal is to provide a
project that will address the transportation needs of
the area, while maintaining the unique beauty of
our mountains. Please let me know if you have any
other questions or if it’d be helpful to have a call to
discuss your concerns further.
Dawson Jordan Proposed
land
bridge
Publicinput.com 27.1 Hi, my name is Dawson Jordan. I'm a resident of Robbinsville North
Carolina. And I was just calling in reference to the proposed I guess
land crossing that's going on top of Stecoah Mountain. I'd heard
that that would cost approximately five million dollars to the land
bridge and I just like to leave my personal opinion and I think that's
a complete waste of taxpayer dollars. They cross everywhere else.
We don't need an abundance of languages around here that
perfectly capable animals and wildlife of crossing the road but up a
wildlife crossing sign rather than spending five million dollars of
taxpayer money funds to put in a land bridge, I believe that is
absurd. Thank you.
Emily Love spoke with Mr. Jordan on 10/27/2020 to
discuss his concerns regarding the land bridge. Mr.
Jordan had no further questions about the project.
Lance Holland Proposed
land
bridge
Publicinput.com 28.1 This is Lance Holland. I live in Stecoah. I am a professional location
scout for Motion Pictures and other photo projects and I suggest
strongly and I love all the ideas of the latest proposal for the
corridor, but on the land bridge over Stecoah Gap. You should make
accommodations for a photo spot looking East that is an incredible
Sunrise photo. I've had several film Crews there. There's people out
there shooting it all the time and up from that land bridge you'll be
able to see over the trees. So if you don't make a path in some
guardrail or something at the edge of it people are going to beat a
trail out there anyway, and then fall off the bridge into the traffic
just a word. I think this is very important. Thank you very much if
you need to contact phone number is 828-488-2531
Emily Love spoke with Mr. Holland on 10/28/2020
regarding his concerns. Mr. Holland had no further
questions about the project.
Unknown Citizen 1

Proposed
land
bridge
Mailed
comment
29.1 Like the land bridge to accommodate the Appalachian Trail Comment noted.
AT
Parking
Lot
Mailed
comment
29.2 Hope ample parking is included. Comment noted. As of March 15, 2021, NCDOT is
providing right-in/right-out access with bulb-out
turnarounds to parking area. Travel flow will be
one-way (counter-clockwise) in parking lot. There
will be approximately 8 parking spaces.
Proposed
multi-use
path
Mailed
comment
29.3 I really like the idea of a walkway beside Highway 28. Comment noted.
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Unknown Citizen 1
(cont.)

Design
question
Mailed
comment
29.4 Hope that turning lanes would be added for Stecoah Road and
Hydetown Road. Hope that retaining walls are built that are
aesthetically pleasing; also, landscaping to help with noise.
Comment noted.
Rick Davis Proposed
land
bridge
Publicinput.com 30.1 Really like the bridge at the AT. I just wanted to reach out to thank you for sharing
your thoughts regarding the proposed Corridor K
project in Graham County (STIP Project No. A-
0009C). Your comment will be submitted into the
official Public Record. The project team met on
November 3, 2020 to review and carefully consider
all comments received. Your comments were
reviewed and are being considered as the project
moves into final design. The final environmental
document, called a Finding of No Significant Impact,
is scheduled to be complete in December 2020 and
will be posted on the project website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
AT
parking
lot
Publicinput.com 30.2 Please include ample parking at this area for visitors and hikers.
Proposed
multi-use
path
Publicinput.com 30.3 Please keep the walking/bike lane in Stecoah. This is a great idea.
Design
question
Publicinput.com 30.4 Please consider including repetitive buffers along the road at
appropriate locations.
R. Anne Gordon

Proposed
multi-use
path
Publicinput.com 31.1 No walkway thru Stecoah will take homes and is very dangerous for
those walking. Will take septic tanks from 3 homes in Stecoah.
Leonard Bridges, R..Anne Gordon. 2 properties
Thank you for sharing your thoughts regarding the
proposed Corridor K project in Graham County (STIP
Project No. A-0009C). Your comment will be
submitted into the official Public Records. With
respect to your comments about the proposed
multi-use path, no residential or business
relocations are anticipated due to the pathway. The
multi-use path was originally studied due to local
request and we will be conveying your concerns to
local officials, who will provide a recommendation
on whether or not to pursue the multi-use path. The
project team will document the decision-making
process in the final environmental document, called
a Finding of No Significant Impact (FONSI). The
FONSI is scheduled to be complete in December
2020 and will be posted on the project website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Proposed
multi-use
path
Mailed
comment sheet
31.2 The walkway "to nowhere" is not needed in our valley. We have a
walking trail at our Community Center (not over a 1/2 mile away).
No need for "druggies" to have more space to roam our valley. It
also affects homes and businesses. Please use the money
elsewhere.
Niki Gibbs

Proposed
multi-use
path
Mailed
comment sheet
32.1 I have questions about the multi-use pathway in Stecoah. Is the
pathway necessary? Will it take land or homes that could be saved
otherwise? I don't want additional money to be spent on something
that isn't necessary or won't be used.
Thank you for sharing your thoughts regarding the
proposed Corridor K project in Graham County (STIP
Project No. A-0009C). Your comment will be
submitted into the official Public Records. The
multi-use path was originally studied due to local
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Niki Gibbs (cont.) requests and no residential relocations are
anticipated due to the pathway. We will be
conveying your concerns to local officials, who will
provide a recommendation on whether or not to
pursue the multi-use path. The project team will
document the decision-making process in the final
environmental document, called a Finding of No
Significant Impact (FONSI). The FONSI is scheduled
to be complete in December 2020 and will be
posted on the project website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Ty Gibbs

Proposed
multi-use
path
Mailed
comment sheet
33.1 The only question I have is why the money needs to be spent on a
sidewalk through Stecoah? There is never anyone walking this road
so I see no need to spend tax payer's money on something that
might get used by only a few people. If this walkway gets put in how
many people will lose land? Also will this cause one homeowner to
lose there home over a walkway?
Thank you for sharing your thoughts regarding the
proposed Corridor K project in Graham County (STIP
Project No. A-0009C). Your comment will be
submitted into the official Public Records. The
multi-use path was originally studied due to local
requests and no residential relocations are
anticipated due to the pathway. We will be
conveying your concerns to local officials, who will
provide a recommendation on whether or not to
pursue the multi-use path. The project team will
document the decision-making process in the final
environmental document, called a Finding of No
Significant Impact (FONSI). The FONSI is scheduled
to be complete in December 2020 and will be
posted on the project website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Kathy Cody Proposed
multi-use
path
Mailed
comment sheet
34.1 Don't see need in sidewalk Comment noted. No email or phone number were
provided for follow-up.
George P. Smith Proposed
multi-use
path
Mailed
comment sheet
35.1 Please do not put a sidewalk in Stecoah Alexa Kennedy spoke with George Smith about his
concerns and informed him that his comments
would be conveyed to local officials. George had no
further comments on the project. Carla S. Smith Proposed
multi-use
path
Mailed
comment sheet
36.1 No walk way in Stecoah
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Leondus McCracken Proposed
multi-use
path
Mailed
comment sheet
37.1 The resources of our community is being uprooted for no practical
reason other than give a fast paced non residential society access to
overrule our small community values and local businesses. For all
practicle purposes, we just need an xtra lane starting up NC 28 and
crossing NC 143 mtn.
Dear Mr. and Ms. McCracken, Thank you for
submitting comments on the Corridor K
Improvements (A-0009) project. I will be able to
answer questions about the noise study for you.
The noise study was done by the NCDOT Traffic
Noise and Air Quality Group but I am very familiar
with the project having been involved with it for 25
years. I tried calling you number to discuss noise
with you (828-935-0768) but I could not get
through. Perhaps the weather has something to do
with it. If you would like to call me at 919-395-6147,
I will be happy to answer your questions. I have a
copy of the report available and I can look up the
area where you live and tell you the findings.
Thanks you for your interest in the project.
Noise
effects
Mailed
comment sheet
37.2 Who did the survey for impact of noise pollution to the Valley? How
will the road control traffic speed for our small community? I live
next to Highway 28 and the noise is already at a level of nuisance
and the speed of traffic is at times excessive. I can just imagine what
it will bring when there is another lane to bring the volume closer to
my home and allow greater speeds for traffic to move through our
community.
Donna McCracken Proposed
multi-use
path
Mailed
comment sheet
38.1 The resources of our community is being uprooted for no practicale
reason other than give a fast paced non residential society access to
overrule our small community values and local businesses. For all
practicle purposes, we just need an xtra lane starting up NC 28 and
crossing NC 143 mtn.

Noise
effects
Mailed
comment sheet
38.2 Who did the survey for impact of noise pollution to the Valley? How
will the road control traffic speed for our small community? I live
next to Highway 28 and the noise is already at a level of nuisance
and the speed of traffic is at times excessive. I can just imagine what
it will bring when there is another lane to bring the volume closer to
my home and allow greater speeds for traffic to move through our
community.
Traci Burchfield

Proposed
multi-use
path
Mailed
comment sheet
39.1 Putting a sidewalk for a short distance down the side of a four lane
is not safe. It would encourage people to walk beside traffic when
there is no need. There is a perfectly good walking trail at the SVC.
What is the reason for putting a sidewalk along the four lane?
Where does it go? Why would it be necessary? We have a walking
trail at Stecoah Valley Center for walk or exercising purposes. This is
a waste of money plus it would not be safe.
Alexa Kennedy spoke with Ms. Burchfield about
their comments and informed them that their
concerns would be conveyed to local officials. Traci
had no further questions of comments on the
project.
Chad Burchfield

Proposed
multi-use
path
Mailed
comment sheet
40.1 I do not see the need for a 16-foot walkway along the 3-lane road. I
understand that people will lose there homes due to the
construction of the walkway and I disagree with that.
Thank you for sharing your thoughts regarding the
proposed Corridor K project in Graham County (STIP
Project No. A-0009C). Your comment will be
submitted into the official Public Records. With
respect to your comments about the proposed
multi-use path, no residential relocations are
anticipated due to the pathway. The multi-use path
was originally studied due to local request and we
will be conveying your concerns to local officials,
who will provide a recommendation on whether or
not to pursue the multi-use path. The project team
will document the decision-making process in the
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Name Topic Means of
Comment
Comment
No. Comment Text Response
Chad Burchfield
(cont.)
final environmental document, called a Finding of
No Significant Impact (FONSI). The FONSI is
scheduled to be complete in December 2020 and
will be posted on the project website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
David Hyde Proposed
multi-use
path
Mailed
comment sheet
41.1 Looking @ Sheet 6, Typical Section, What is the reason for the
multi-use path. There is no reason for this. It will only provide a path
for ATV's and such to travel, no one ever walks this portion of the
roadway. The is no reason to walk here, the elimination of this walk
way would reduce cost by allowing a typical embankment slope
with a less in height retaining wall - big savings by putting the
walkway & retaining wall in will also limit access to property on the
south side of Hwy 28. There is one access that was left out of your
design, this is a ramp from Hwy 28 to the Holder property. Access
from Lower Stecoah Road - I was here when 28 was built & I used
the access ramp to get to the property many times. The multi-use
path is not needed. No where to go, restricts access to property,
elimination of path will be a big cost savings
Thank you for sharing your thoughts regarding the
proposed Corridor K project in Graham County (STIP
Project No. A-0009C). Your comment will be
submitted into the official Public Records. With
respect to your comments about the proposed
multi-use path, the pathway was originally studied
due to local request for a walkway for recreational
and health purposes. We will be conveying your
concerns to local officials, who will provide a
recommendation on whether or not to pursue the
multi-use path. The project team will document the
decision-making process in the final environmental
document, called a Finding of No Significant Impact
(FONSI). The FONSI is scheduled to be complete in
December 2020 and will be posted on the project
website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project.
Yvona Hyde

Opposi-
tion to the
project
Publicinput.com 42.1 What's the purpose? Since there is no more traffic than normal,
when the Nantahala Gorge had the slide the present road was fine.
Why put money into a road that is not needed. I have lived here all
my life and we have done great without a new road. To move a
creek over would make fish and other insects not happy. No need in
it. It beautiful and fine where it’s at. Do not build the road and the
walkway. Why? Do you want to build it? Crazy to mess a beautiful
community up when tourist also like it the way it is, like we do.
Think about it, A WASTE. PLEASE NO CORRIDOR K.
I just wanted to follow up on your comments about
the Corridor K project in Graham County (STIP
Project A-0009C). We appreciate you taking the
time to provide feedback and have incorporated
your comments into the Public Record. The purpose
of the A-0009C project is to provide the
transportation infrastructure necessary for the well-
being of local residents by improving mobility and
reliability. Limited roadway options cause impaired
reliability during winter weather, landslides, and
traffic incidents. Steep grades, narrow shoulders,
and sharp curves on the existing roads impair
mobility within the area. Section 1.0 of the EA
(found here) further details the project needs. Our
goal is to provide a project that will address the
transportation needs of the area, while maintaining
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A.2-23 MARCH 2021

Name Topic Means of
Comment
Comment
No. Comment Text Response
Yvona Hyde (cont.) the unique beauty of our mountains. I hope this
provides a little clarification on the project’s
purpose and need. Please let me know if you have
any additional comments or questions concerning
the proposed project.
Nadine Morden General
questions
/comment
Publicinput.com 43.1 Hi, my name is Nadine Morden. Just calling to see if I could get a
transcript of tomorrow's meeting. Thank you.
Amy Sackaroff spoke with Ms. Morden on 10/8/20
to let her know the timeline for the transcript and
that it would be sent to her as soon as it is available.
Transcript sent to Nadine on 12/16/20.
Cal Wiederholt General
questions
/comment

Publicinput.com

44.1 Please no 4 lane highway between Stecoah and Robbinsville. It
would destroy the character of Stecoah and mar the pristine,
undeveloped beauty of Graham County
Good morning! Thank you for sharing your thoughts
regarding the proposed Corridor K project in
Graham County (STIP Project No. A-0009C.). Your
comments will be submitted into the official Public
Records. The comment period for the October 1,
2020 Public Hearing ends on October 30, 2020. The
project team will review and carefully consider all
comments received and document the decision-
making process in the final environmental
document, called a Finding of No Significant Impacts
(FONSI). The FONSI is scheduled to be completed in
December 2020 and will be posted on the project
website at
https://www.ncdot.gov/projects/corridor-
k/Pages/default.aspx upon completion. We
appreciate you taking the time to share your
thoughts about the proposed project. The proposed
improvements to existing NC 143 and NC 28
includes the addition of alternating passing lanes or
climbing lanes but there is no plan for a four-lane
roadway for the length of the project. There are
several locations where the cross-section is four
lanes wide, where a passing or climbing lane is
transitioning from one direction to the other. The
project team will continue to evaluate measures
during the final design phase to further reduce
anticipated impacts throughout the entire project
corridor. Thanks again for your feedback! If you
have any additional comments or questions
concerning the proposed Corridor K project, please
feel free to contact us. Thank you! Amy
Mary Millsaps General
questions
/comment
Publicinput.com 45.1 With SECU of Robbinsville. Questions about Corridor K and how it
will affect Tulula Road.
Amy Sackaroff spoke with Ms. Millsaps on 10/7/20
and explained project terminus is to the north and
that the credit union would not be affected by the
proposed project.
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A.2-24 MARCH 2021

Name Topic Means of
Comment
Comment
No. Comment Text Response
Jackson Hurst General
questions
/comment
Publicinput.com 46.1 Hi I would like to sign up for project updates and be added to the
mailing list for the Corridor K (A-0009C) Robbinsville-Stecoah
Project.
Diane Wilson added Mr. Hurst to the project mailing
list.
Dan Huff General
questions
/comment
Publicinput.com 47.1 I don't have online access and I'd like to get a meeting information
and the maps and projects you don't project updates. In my
mailbox, cuz I can't access online. So please add me to the list for on
mail updates on the edge of a k project here in Stecoah Valley.
Thank you.
Meeting materials mailed to Mr. Huff on 9/29/20.
NOTE: Technical difficulties with the audio recording of the Virtual Public Hearing (VPH) prohibited the verbatim transcription of responses to questions received in the VPH Chat Box; however, the
above responses to the Chat Box comments/questions reflect the project information provided at that time.
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MARCH 2021
APPENDIX B
AGENCY COORDINATION
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Meeting Minutes

NCDOT STIP No. A-0009C
Concurrence Points 3 & 4A Meeting
11.12.2020, 1:00pm

Attendees
Crystal Amschler (USACE)
Aaron Williams (FHWA)
Janet Mizzi (USFWS)
Amy Mathis (USFS)
Erik Crews (USFS)
Amanetta Somerville (USEPA)
Elizabeth Toombs (Cherokee Nation)
Michael Bolt (EBCI)
Gary Sneed (EBCI)
Wanda Austin (NCDOT Division 14)
Josh Deyton (NCDOT Division 14)
Garrett Higdon (NCDOT Division 14)
Dave McHenry (NCDOT Division 14)
Kevin Mitchell (NCDWR)
Robert Patterson (NCDWR)
Marla Chambers (NCWRC)
Renee Gledhill-Early (NCSHPO)
Lindsay Ferrante (OSA)
Casey Kirby (OSA)
John Mintz (OSA)
Rose Bauguess (Southwestern RPO)
Michael Bright (NCDOT Utilities)
Jim Dunlop (NCDOT Congestion
Management)
Pam Cook (NCDOT TPD)
Roger Castillo Santamaria (NCDOT TPD)
Heather Hildebrandt (NCDOT Bike & Ped)
Herman Huang (NCDOT PICSViz)
Jamie Lancaster (NCDOT EAU)
Matt Wilkerson (NCDOT Archaeology)
Jody Kuhne (NCDOT Geotechnical)
Marissa Cox (NCDOT Biological Surveys)
John Jamison (NCDOT EPU)
Mike Sanderson (NCDOT EPU)
Carla Dagnino (NCDOT ECAP)
Jonathan Moore (NCDOT Hydraulics)
Erik Seiler (NCDOT Hydraulics)
Marc Shown (NCDOT Hydraulics)
Donna Dancausse (Facilitator)
Stacy Oberhausen (TGS/NCDOT PM)
Jay Twisdale (TGS)
Randy Henegar (TGS)
Ben Henegar (TGS)
Jimmy Terry (TGS)
Andrew Topp (VHB)
Amber Coleman (Stantec)
Amy Sackaroff (Stantec)
Steve Smallwood (Stantec)
Emily Love (Stantec)
Thomas Hoppe (Stantec)
Alexa Kennedy (Stantec)

Purpose: To obtain concurrence on the Least Environmentally Damaging Practicable Alternative (LEDPA)
and Avoidance and Minimization measures.
Project Status: The Environmental Assessment (EA) was signed in August 2020. Merger team meetings
for Concurrence Points 1, 2, and 2A were held in 2019 and 2020.
Public Outreach: Public Meetings were held on February 12 and 14, 2019. A virtual Public Hearing was
held on October 1, 2020. Comments received at the Public Hearing included support for the project,
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Meeting Minutes

questions about the multi-use path, and concerns about property impacts. The United States Army Corp
of Engineers (USACE) Section 404 Public Notice was posted on September 22, 2020.
Concurrence Point 3 (LEDPA): NCDOT selected Alternative 1 as the Preferred Alternative. Alternative 1
meets purpose and need while increasing reliability and mobility in the project area, is supported by
local officials and environmental stakeholders, and has adequate funding available to construct. Stantec
walked through impacts anticipated with Alternative 1. Relocation impacts are being updated for the
Finding of No Significant Impact (FONSI). Cultural resources will undergo a project level Programmatic
Agreement. Coordination with United States Forest Service (USFS) is ongoing to determine consistency
with the current Forest Service Plan.
• USFS requested impacts be shown as TBD for Forest Service Plan consistency as it has not yet
been determined whether the project will be consistent.
• United States Environmental Protection Agency (USEPA) inquired if there were any other
comments other than property concerns received for the project.
o Stantec noted that other comments received included support for the project, support
for the land bridge, one opposition to the land bridge, and concerns about the multi-use
path.
• USACE noted there were no comments or concerns on their part for the LEDPA decision.
• USACE, United States Fish and Wildlife Service (USFWS), Southwestern Rural Planning
Organization (RPO), FHWA, North Carolina Division of Water Resources (NCDWR), North
Carolina State Historic Preservation Office (NCSHPO), USEPA, North Carolina Wildlife Resources
Commission (NCWRC), and NCDOT concurred with Alternate 1 as the LEDPA (CP 3). USFS will
send a letter of concurrence.
Concurrence Point 4A (Avoidance and Minimization): The LEDPA includes 2:1 fill slopes, 1.5:1 slopes
where possible, expressway gutter and shoulder berm gutter, alignment shifts, and retaining walls to
avoid and minimize impacts. Stream and wetland impacts (calculated using a 25’ buffer of the slope
stakes) were shown for the project.
• NCWRC noted concerns over the Appalachian Trail (AT) crossing in the middle of the land bridge
as it might reduce effectiveness of the crossing for wildlife and would prefer for the AT to cross
on one side of the land bridge.
o USFS noted there should be room to move the AT to one side as long as enough
vegetation is maintained to mitigate scenery impacts.
• USFWS inquired about the location of the golden-winged warbler.
o NCDOT Environmental Policy Unit (EPU) noted there are golden-winged warblers
located near the parking area at the AT and near the old USFS road below the AT.
 NCDOT Division 14 noted they are considering habitat enhancement for the
species in this area and will include this in the conference consultation.
o NCDOT Division 14 noted there is another population near the first switchback on NC
143 at Bill Rose Road and they are examining mitigation in this area as well.
• USFS noted the AT stakeholders would like to see the entire tract purchased for the trail
relocation as well as mitigation for scenery impacts.
• Stantec noted that USFS sent an email last week with hydrology recommendations and the team
is aware of these recommendations. Geotechnical testing has been completed for a good
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Meeting Minutes

portion of the project to test for acidic rock. Based on the low indicators, treatment or other
special provisions for acidic rock is not anticipated.
• USACE noted there were no comments or concerns on their part.
• USACE, USFWS, Southwestern RPO, FHWA, NCDWR, WRC, USEPA, and NCDOT concurred with
the avoidance and minimization (CP 4A) efforts presented. USFS will send a letter of
concurrence. NCSHPO does not participate in CP 4A.
Next Steps: The Section 106 Programmatic Agreement is anticipated in December 2020. The FONSI is
anticipated for December 18, 2020. CP 4B is anticipated in May 2021 and CP 4C is anticipated in October
2021.
• NCDOT EPU inquired about the type of letting.
o NCDOT Division 14 noted it would be a conventional letting.
• NCDOT EPU inquired about the type of permit that USACE anticipates.
o USACE noted the decision had not been made yet, but they will initiate conversations to
determine the permit type and will then inform the team.

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A-0009C: US 129, NC 143, & NC 28 IMPROVEMENTS, GRAHAM COUNTY – CONCURRENCE POINT 3
NEPA/404 MERGER TEAM MEETING AGREEMENT
Concurrence Point No. 3: Least Environmentally Damaging Practicable Alternative

PROJECT NO./TIP NO./ NAME/DESCRIPTION:
WBS Element: 32572.1.FS10
FA No. APD-0074(178)
STIP Project Number: A-0009C
STIP Description: Corridor K Improvements along US 129, NC 143, and NC 28 from
Robbinsville to Stecoah.

____ No-Build Alternative

____ Alternative 1: This alternative would improve existing roadway shoulders and
adding passing/climbing lanes between US 129 south of Robbinsville and the
existing four-lane section of NC 28 in Stecoah. In Robbinsville, proposed
improvements include: resurfacing, a dedicated eastbound right-turn lane from
US 129 to NC 143, dedicated left-turn lanes at Robbinsville High School and Five
Point Road (SR1275), and sidewalks from Robbinsville High School’s entrance on
NC 143 to the intersection of US 129 and Five Point Road (SR 1275). East of
Robbinsville, the Preferred Alternative includes: passing or climbing lanes, eight-
foot paved shoulders, and dedicated left-turn lanes at Mountain Creek Road,
Tatham Road, and Sweeten Creek Road. At the Appalachian Trail, this
alternative provides both eastbound and westbound climbing lanes and eight-
foot paved shoulders. A land bridge would provide a grade-separated crossing
for the Appalachian Trail at NC 143. In Stecoah, this alternative would provide:
eight-foot paved shoulders, alternating passing/climbing lanes, a multi-use path
on the south side of NC 28 between Stecoah Road and Hyde Town Road, and a
slight realignment of Bill Crisp Road to create a four-leg intersection with NC 28
and Stecoah Road.

The Merger Team has concurred on November 12, 2020, with the selection of the Least
Environmentally Damaging Practicable Alternative as shown above.

USACE NCDWR
Crystal Amschler Date Kevin Mitchell Date
USFWS NCWRC
Janet Mizzi Date Marla Chambers Date
USFS SHPO
Amy Mathis Date Renee Gledhill-Earley Date
RPO USEPA
Rose Bauguess Date Amanetta Somerville Date
FHWA NCDOT
Aaron Williams Date Wanda Austin Date
X
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11/13/2020
11/13/2020
11/13/2020
11/13/2020
11/13/2020
11/16/2020
11/13/2020
11/13/2020
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A-0009C: US 129, NC 143, & NC 28 IMPROVEMENTS, GRAHAM COUNTY – CONCURRENCE POINT 4A
NEPA/404 MERGER TEAM MEETING AGREEMENT

Concurrence Point No. 4A: Avoidance and Minimization

PROJECT NO./TIP NO./ NAME/DESCRIPTION:
WBS Element: 32572.1.FS10
FA No. APD-0074(178)
STIP Project Number: A-0009C
STIP Description: Corridor K Improvements along US 129, NC 143, and NC 28 from
Robbinsville to Stecoah.

The project team conducted avoidance and minimization efforts throughout the preliminary
design and planning phase. Below is a summary of avoidance and minimization efforts
implemented during the development of the LEDPA (Alternative 4A).
Avoidance and Minimization of Jurisdictional Resources
In addition to selecting the Improve Existing Alternative over alternatives that included new
location sections, avoidance and minimization measures currently incorporated in the Preferred
Alternative design include the following:

 2:1 fill slopes.
 1.5:1 cut slopes where possible.
 Expressway gutter and shoulder berm gutter to reduce cross-section width.
 Alignment shifts to avoid relocations and avoid/minimize stream, wetland, and historic
resource impacts.
 Alignment shifts and symmetrical or asymmetrical widening for a best-fit alignment to
avoid/minimize impacts and reduce earthwork.
 Retaining walls to avoid/minimize impacts and reduce earthwork.
 Land bridge to avoid habitat fragmentation effects and visual impacts for Appalachian
Trail users
 Tiered, benched retaining walls with aesthetic treatment to minimize visual impacts at
Appalachian Trail
In final design:
 All slopes in jurisdictional areas are anticipated to be the maximum allowable for
standard grass lined slopes (2:1) to minimize jurisdictional impacts.
 Minimum applicable typical sections will be proposed throughout the project to
minimize jurisdictional impacts.
 Final design will propose retaining and extending existing culverts where practicable to
minimize in stream work.
 Effort will be made throughout the project in final design to make slight adjustments to
the horizontal and vertical alignments where practicable to minimize jurisdictional,
cultural and environmental impacts. Geotechnical design will evaluate steepening
slopes in some areas as practicable.
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A-0009C: US 129, NC 143, & NC 28 IMPROVEMENTS, GRAHAM COUNTY – CONCURRENCE POINT 4A
 Consideration will be given to extending existing culvert headwalls vertically, where
practicable, in a few locations to avoid stream loss (possible examples are Tulula Creek,
downstream end of Sweetwater Creek at Slaybacon Road and upstream end of
Stecoah Creek).
 The design team will be prepared at CP 4B and/or 4C to discuss jurisdictional impacts as
well as provide a more detailed explanation of minimization efforts made at a specific
location, as needed.

The Merger Team has concurred on this date of November 12, 2020, the avoidance and minimization
efforts as stated above.

USACE NCDWR
Crystal Amschler Date Kevin Mitchell Date
USFWS NCWRC
Janet Mizzi Date Marla Chambers Date
USFS SHPO
Amy Mathis Date Renee Gledhill-Earley Date
RPO USEPA
Rose Bauguess Date Amanetta Somerville Date
FHWA NCDOT
Aaron Williams Date Wanda Austin Date
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11/12/2020
11/12/2020
11/13/2020
11/13/2020
11/12/2020
11/16/2020
11/13/2020
11/13/2020
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street Suite #B
Asheville, North Carolina 28801

1
November 23, 2020
Dave McHenry
NC Department of Transportation
Division 14
253 Webster Road
Sylva, North Carolina 28779

Subject: 21-068, Section 7 Concurrence for Graham County A-0009C Corridor K
Appalachian Highway Development System; NC WBS: 32572.1.FS10

Dear Mr. McHenry,

On November 3, 2020, we received your letter requesting section 7 concurrence on effects the
subject project may have on the federally endangered Indiana bat (Myotis sodalis) and northern
long-eared bat (NLEB, Myotis septentrionalis) 4(d) Rule compliance notification. The following
comments are provided in accordance with section 7 of the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531-1543) (Act).

Additionally, a conference opinion will be developed for golden-winged warbler (Vermivora
chysoptera), which is currently under review for listing. So as to avoid any construction delays
that might occur if the species were to be listed between now and the completion of project
construction, the U.S. Fish and Wildlife Service (Service) will prepare a conference opinion
based on the proposed action and conservation measures as proposed by the NCDOT in
cooperation with the North Carolina Wildlife Resources Commission (NCWRC) and the U.S
Forest Service (USFS), as outlined in a biological assessment or assessment type document, yet
to be submitted.

Project Summary
The North Carolina Department of Transportation (NCDOT) proposes to improve US129,
NC143 and NC28 on their existing alignments from the town of Robbinsville, North Carolina to
the existing four-lane section east of Stecoah, North Carolina. The proposed work will involve
areas of tree clearing, grading, drilling, blasting, removal of man-made structures and a minimal
amount of night work with associated temporary lighting.

You have committed to remove trees required for the project during October 15th to April 15th,
avoiding impacts to potentially roosting bats. Additionally, surveys for bats and evidence of
roosting bats during surveys on July 8-9, 2019, returned signs of bat usage at one bridge site,
which will not be impacted by the proposed work. You have also committed to no additional
permanent lighting to the project area; limiting temporary lighting and night work to the single
area needed for the wildlife passage/Appalachian Trail land bridge, to be completed over a few
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2
nights between November and March; and demolition of man-made structures only during the
winter or after confirming the absence of roosting bats.

With these commitments in place, we concur with your determination that the proposed project
may affect, but is not likely to adversely affect, the Indiana bat. Given recent survey efforts we
have reason to believe that the Gray bat (Myotis grisescens) may also utilize these habitats.
However, at this time we have no known records of this species in the immediate project
vicinity, although neighboring counties do have current populations. Gray bats forage on a
variety of flying aquatic and terrestrial insects present along streams, rivers, and lakes. They
migrate between summer and winter roosting habitat and will use transient or stopover caves or
cave-like features along the way. The proposed avoidance measures would reduce the probability
for take of this animal, therefore, we concur with a ‘may affect, not likely to adversely affect”
determination for this species as well.

As outlined in the Biological Opinion completed on the 4(d) rule for the federally threatened
Northern long-eared bat (Myotis septentrionalis) on January 5, 2016, this activity is now
excepted from take prohibitions for Northern long-eared bat, based on the project location.
Project activities in the action area: (1) would not affect a known hibernation site; (2) are not
located within ¼ mile of a known hibernation site, or; (3) are not located within a 150' radius of
a known maternity (tree) site.

Based on the information provided, we have no concerns for Carolina northern flying squirrel
(Glaucomys sabrinus coloratus), Appalachian elktoe (Alasmidonta raveneliana), spotfin chub
(Erimonax monachus), Virginia spirea (Spirea virginiana), small whorled pogonia (Isotria
medeoloides), or rock gnome lichen (Gymnoderma lineare) given lack of habitat in the project
area, lack of field survey results and/or absence of established species distribution within the
project area.

Obligations under Section 7 of the ESA must be reconsidered if: (1) new information reveals
impacts of this identified action that may affect listed species or critical habitat in a manner not
previously considered, (2) this action is subsequently modified in a manner that was not
considered in this review, or (3) a new species is listed or critical habitat is determined that may
be affected by the identified action.

If you have questions about these comments please contact Ms. Holland Youngman of our staff
at 828-258-3939, Ext. 42235. In any future correspondence concerning these projects, please
reference our Log Number 21-068.

Sincerely,

Janet Mizzi
Field Supervisor

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North Carolina Division Office 310 New Bern Ave, Suite 410
Raleigh, NC 27601 November 17, 2020 [phone] [phone]
http://www.fhwa.dot.gov/ncdiv/

In Reply Refer To:
HDA-NC
Ms. Denise Nelson
Environmental Protection Specialist
National Park Service
Appalachian National Scenic Trail
PO Box 50
Harpers Ferry, WV 25425

Dear Ms. Nelson:

The purpose of this letter is to request your written concurrence, as the official with jurisdiction
over the Appalachian National Scenic Trail (ANST), that the impacts from the proposed North
Carolina Department of Transportation (NCDOT) Corridor K (STIP No. A-0009C) project will
not adversely affect the activities, features, or attributes of the ANST.

The ANST is both a Section 106 historic resource and a Section 4(f) resource due to its
eligibility for listing on the National Register for Historic Places (NRHP) and its protected
recreational function. For Federally funded projects such as A-0009C, public parks and
recreation facilities are afforded special protection under Section 4(f) of the USDOT Act
(recodified in 49 U.S.C. 303 and 23 U.S.C. 138), and Section 6009(a) of SAFETEA-LU (23 CFR
774). Provisions within SAFETEA-LU state that if a transportation project is determined to not
adversely affect the activities, features, and attributes of the resource protected under Section
4(f), then a de minimis finding can be made by the Federal Highway Administration (FHWA) to
satisfy the requirements of Section 4(f).

The improve existing alternative has been selected as the preferred alternative. This alternative
would improve existing US 129, NC 143, and NC 28 to include passing and climbing lanes, and
paved shoulders between Robbinsville to Stecoah. At the ANST location, a land bridge is
proposed to facilitate the crossing of wildlife and pedestrians across NC 143, and would relocate
the ANST inside of the land bridge. The proposed land bridge would be approximately 160 feet
long, 220 feet wide, and 29 feet tall filled with earth and planted material. The proposed typical
section at the ANST includes four 12-foot climbing lanes with eight-foot paved shoulders, two-
foot grass shoulders, and a tiered retaining wall. Through coordination with the Appalachian
Trail stakeholders and the Advisory Council on Historic Preservation (ACHP), FHWA believes
that the proposed project will have no adverse affect on the activities, features, or attributes that
qualify the ANST for protection under Section 4(f). Based on this information, FHWA intends to
make a de minimis finding regarding impacts to the ANST.

As the official with jurisdiction over the ANST, FHWA is requesting your written concurrence
on the de minimis finding for the proposed A-0009C project. We ask that you respond in writing
no later than Wednesday, December 16th, 2020.

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2

If you have any questions or concerns, please do not hesitate to contact Aaron Williams, of this office, at
919-747-7024 or [e-mail].

Sincerely,

For John F. Sullivan, III, P.E.
Division Administrator

ec: Michelle Aldridge, USFS
Amy Mathis, USFS
Wanda Austin, NCDOT
Renee Gledhill-Earley, SHPO
Clarence Coleman, FHWA

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United States Department of the Interior

NATIONAL PARK SERVICE
Appalachian National Scenic Trail
P.O. Box 50 (Deliveries: 252 McDowell St.)
Harpers Ferry, WV 25425

IN REPLY REFER TO:
1.A.1

March 9, 2021

Mr. Aaron T. Williams
Transportation and Safety Engineer
U.S. Department of Transportation
Federal Highway Administration
North Carolina Division Office
310 New Bern Avenue, Suite 410
Raleigh, NC 27601

RE: Corridor K (STIP No, A-009C) Project Section 4(f) Determination for the Appalachian National
Scenic Trail

Dear Mr. Williams:

The National Park Service (NPS), Appalachian National Scenic Trail has reviewed your letter dated
November 17, 2020 requesting our concurrence with the U.S. Federal Highway Administration’s
(FHWA) proposed de minimis finding for impacts of the proposed Corridor K (STIP No, A-009C) Project
(Project) on the Appalachian National Scenic Trail (ANST). The FHWA believes that the proposed
Project will have no adverse affect on the activities, features, or attributes that qualify the ANST for
protection under Section 4(f) of the U.S. Department of Transportation Act.

The NPS concurs with a de minimis finding for the Appalachian National Scenic Trail for this Project as
proposed. As noted in your letter, the “improve existing alternative” has been selected and a land bridge
that would carry the ANST is proposed to facilitate wildlife and pedestrians across NC 143. The FHWA
has consulted with the ANST stakeholders and the Advisory Council on Historic Preservation on
development and execution of a Programmatic Agreement to avoid, minimize, or mitigate effects of this
undertaking on historic properties including the ANST.

Thank you for consulting with us on this project to avoid adverse effects to the Appalachian National
Scenic Trail. Please contact Denise Nelson of my staff at [phone] or by email at
[e-mail] with any questions or requests for additional information on this matter.

Sincerely,

Wendy K. Janssen
Superintendent

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North Carolina Division Office 310 New Bern Ave, Suite 410
Raleigh, NC 27601 November 17, 2020 [phone] [phone]
http://www.fhwa.dot.gov/ncdiv/

In Reply Refer To:
HDA-NC
Mr. Cavan Fitzsimmons
Acting Forest Supervisor
U.S. Forest Service North Carolina
160 Zillicoa Street, Suite A
Asheville, NC 28801

Dear Mr. Fitzsimmons:

The purpose of this letter is to request your written concurrence, as the official with jurisdiction
over the Appalachian National Scenic Trail (ANST), that the impacts from the proposed North
Carolina Department of Transportation (NCDOT) Corridor K (STIP No. A-0009C) project will
not adversely affect the activities, features, or attributes of the ANST.

The ANST is both a Section 106 historic resource and a Section 4(f) resource due to its
eligibility for listing on the National Register for Historic Places (NRHP) and its protected
recreational function. For Federally funded projects such as A-0009C, public parks and
recreation facilities are afforded special protection under Section 4(f) of the USDOT Act
(recodified in 49 U.S.C. 303 and 23 U.S.C. 138), and Section 6009(a) of SAFETEA-LU (23 CFR
774). Provisions within SAFETEA-LU state that if a transportation project is determined to not
adversely affect the activities, features, and attributes of the resource protected under Section
4(f), then a de minimis finding can be made by FHWA to satisfy the requirements of Section
4(f).

The improve existing alternative has been selected as the preferred alternative. This alternative
would improve existing US 129, NC 143, and NC 28 to include passing and climbing lanes, and
paved shoulders between Robbinsville to Stecoah. At the ANST location, a land bridge is
proposed to facilitate the crossing of wildlife and pedestrians across NC 143, and would relocate
the ANST inside of the land bridge. The proposed land bridge would be approximately 160 feet
long, 220 feet wide, and 29 feet tall filled with earth and planted material. The proposed typical
section at the ANST includes four 12-foot climbing lanes with eight-foot paved shoulders, two-
foot grass shoulders, and a tiered retaining wall. Through coordination with the Appalachian
Trail stakeholders and the Advisory Council on Historic Preservation (ACHP), the Federal
Highway Administration (FHWA) believes that the proposed project will have no adverse affect
on the activities, features, or attributes that qualify the ANST for protection under Section 4(f).
Based on this information, FHWA intends to make a de minimis finding regarding impacts to the
ANST.

As the official with jurisdiction over the ANST, FHWA is requesting your written concurrence
on the de minimis finding for the proposed A-0009C project. We ask that you respond in writing
no later than Wednesday, December 16th, 2020.

DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348

2

If you have any questions or concerns, please do not hesitate to contact Aaron Williams, of this office, at
919-747-7024 or [e-mail].

Sincerely,

For John F. Sullivan, III, P.E.
Division Administrator

ec: Michelle Aldridge, USFS
Amy Mathis, USFS
Wanda Austin, NCDOT
Renee Gledhill-Earley, SHPO
Clarence Coleman, FHWA

DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348
DocuSign Envelope ID: 60621554-B837-4EAB-B056-00EF05FBD348