20140762 All Versions_Scoping Comments_20140319

Department of Environment and Natural Resources
Project Review Form
Project Number: 14-0343
County: Watauga and Ashe
Due Date: 3/19/2014
Date Received: 02/26/2014
Project Description: Finding of No Significant Impact - Addendum - Proposal to widen US 221 to a
four lane, median divided facility from US 421 in the Deep Gap community to US
221 Business -NC 88 intersection in the town of Jefferson. TIP _No. R=2915.
Please refer to '130200 and-14-0025
This Project is being reviewed as indicated below:
Regional Office
Regional Office Area
In -House Review
Asheville
Fayetteville
Mooresville
Raleigh
Washington
Wilmington
V Winston-Salem
Air
,/ DWR-Surface Water
DWR-Aquifer
,/ DEMLR (LQ & SW)
UST
DWR-Public Water
Air Quality
/ Parks & Recreation
Waste Mgmt
_ Water Resources Mgmt
DWR-Public Water
DWR-Water Quality Program
,/ DWR=Transportation•Unit
ti-- -
Coastal Management
DCM-Marine Fisheries
Military Affairs
DMF-Shellfish Sanitation
Wildlife
✓ Wildlife — DOT M Chambers
Manager Sign-Off/Region:
Date:
In -House Reviewer/Agency:
Response (check all applicable)
No objection to project as proposed. No Comment
Insufficient information to complete review
Other (specify or attach comments)
F/ 72014
If you have any questions, please contact:
Lyn Hardison at lyn.hardison(&,ncdenr.gov or (252) 948-384i4A,',"DSilArb4;:' Lt1tn�,T�
943 Washington Square Mall Washington NC 27889
�.1CN
Courier No. 16-04-01

Proposed US 221 Widening
From US 421 to US 221 Business/NC 88 in Jefferson
Watauga and Ashe Counties
WBS Element 34518.1.1
Federal Aid Project STP-0221(13)
STIP Project No. R-2915
ADMINISTRATIVE ACTION
Addendum to the Finding of No Significant Impact
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
AND
NORTH CAROLINA DEPARTMENT OF
TRANSPORTATION
December 2013
Submitted Pursuant to National Environmental Policy Act 42 U.S.C. 4332(2)(C)
APPROVED:
Date
Date
re �'
Ri hard W. 1 avncock, PE, Unit Head
Project Development and Environmental Analysis Unit
North Carolina Department of Transportation
LJohn F. Sullivan III, .E., D' Ision Administrator
0` Federal Highway Administra ion

Proposed US 221 Widening
From US 421 to US 221 Business/NC 88 in Jefferson
Watauga and Ashe Counties
WBS Element 34518.1.1
Federal Aid Project STP-0221(13)
STIP Project No. R-2915
ADMINISTRATION ACTION
Addendum to Finding of No Significant Impact
December 2013
Document prepared by:
PARSONS
5540 Centerview Drive, Suite 217
Raleigh, North Carolina 27606
�z 201 4pcbree,7
Dat • Edward S. Robbins, PE
Project Manager
12 God
ate Michael Wray, PE
Project Planning En
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For The
North Carolina Department of Transportation:
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Date

Proposed US 221 Widening
From US 421 to US 221 Business/NC 88 in Jefferson
Watauga and Ashe Counties

WBS Element 34518.1.1
Federal Aid Project STP-0221(13)
STIP Project No. R-2915

Project Commitments

The following special commitments have been agreed to by NCDOT:

 NCDOT will coordinate with the North Carolina Wildlife Resources Commission to
determine the status of the potential WRC public access project at South Fork New
River.

 NCDOT will comply with the North Carolina Wildlife Resources Commission’s
moratorium prohibiting in-stream work and land disturbance within the 25-foot trout
buffer from October 15 to April 15 for all streams supporting wild trout, including, but
not limited to, Beaver Creek, Call Creek, Cole Branch, Gap Creek, Little Gap Creek,
and Old Field Creek.

 Design Standards in Sensitive Watersheds will be adhered to during project
construction (15A NCAC 4B.0124).

 NCDOT will re-survey the South Fork New River within the footprint of the existing
and proposed bridge at that crossing prior to permitting to ensure no individuals of
Virginia spiraea have inhabited the area.

 The Hydraulics Unit will coordinate with the NC Floodplain Mapping Program (FMP)
to determine the status of the project with regard to applicability of NCDOT’s
Memorandum of Agreement or approval of a Conditional Letter of Map Revision
(CLOMR) and subsequent final Letter of Map Revision (LOMR).

 NCDOT will provide an individual Section 404 permit for the U.S. Army Corps of
Engineers and a Section 401 Water Quality Certification for the North Carolina
Division of Water Quality.

 NCDOT will design the roadway alignment and profile in front of the Fleetwood
Community Center to not impact the underground storage tanks. No permanent right
of way will be purchased from the Fleetwood Community Center. Temporary
construction easement may be necessary to properly tie the proposed to the existing.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI December 2013 i
TABLE OF CONTENTS

Page

PROJECT COMMITMENTS
1.0 Type of Action ...................................................................................................... 1
2.0 Description of Proposed Action ............................................................................. 1
3.0 Alternatives Considered ....................................................................................... 1
4.0 Preferred Alternative ............................................................................................ 4
5.0 Summary of Project Impacts ................................................................................ 4
6.0 Comments & Coordination ................................................................................... 9
7.0 Additions & Revisions to the Environmental Assessment .................................... 20
8.0 Floodplain Impacts ............................................................................................ 21
9.0 Basis for Finding of No Significant Impacts (FONSI)............................................ 22

LIST OF TABLES
Table 1 – Summary of Potential Impacts from the Functional Design ... .......................3
Table 2 – Summary of Direct Project Impacts ............................................................. 4
Table 3 – Anticipated Impacts to Terrestrial Communities .......................................... 7

APPENDICES
Appendix A – Figures 1-A and 1-B – Project Location and Study Area
Appendix B – Voluntary Agricultural District (VAD) Correspondence
Ashe County School Board Correspondence
Environmental Protection Agency Comments
NC Department of Environmental and Natural Resources Comments
North Carolina Wildlife Resources Commission Comments
National Park Service – Viewshed Correspondence
Eastern Band of Cherokee Indian Correspondence
United Keetoowah Band of Cherokee Indian Correspondence
Appendix C – Concurrence Forms
Appendix D – Noise Abatement Review Study
Archaeological Consultation Letters
Appendix E – Public Hearing map Comments
US Army Corps of Engineers Public Comments & Correspondence
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 1 December 2013
1.0 Type of Action

This is a Federal Highway Administration (FHWA) administrative action,
Finding of No Significant Impact (FONSI). The North Carolina Department of
Transportation (NCDOT) and FHWA has determined that this project will not
have any significant impact on the human or natural environment. This FONSI
is based on the October 18, 2012 Environmental Assessment (EA), which has
been independently evaluated by the FHWA and determined to adequately and
accurately disclose the environmental issues and impacts of the proposed
project. The EA, together with the information contained in this FONSI
(including responses to comments on the EA), provides sufficient evidence and
analysis for determining that an Environmental Impact Statement (EIS) is not
required.

2.0 Description of Proposed Action

The NCDOT and FHWA propose to widen US 221 to a four-lane, median-
divided facility from US 421 in the Deep Gap Community of Watauga County to
the US 221 Business/NC 88 intersection in the town of Jefferson in Ashe
County. The project is approximately 16.1 miles in length and is shown in
Figures 1-A and 1-B in Appendix A.

2.1 Summary of Purpose and Need

The purpose of this project is to upgrade the existing roadway to a multi-
lane facility to increase capacity, alleviate congestion, improve traffic
operations, and reduce the rate of traffic crashes.

3.0 Alternatives Considered

A full range of alternatives were considered, including a No-Build
Alternative, a Public Transportation Alternative, a Transportation Systems
Management (TSM) Alternative, and improvements to the existing facility.

3.1 No-Build Alternative

The No-Build Alternative would not provide any substantial
improvements to the US 221 study corridor. The No-Build Alternative would not
meet the purpose and need identified for the proposed project. It would not
improve the traffic flow or level of service (LOS) of US 221 through the project
study area, nor would it address the corridor’s higher-than-average crash rates.
Therefore, the No-Build Alternative was not recommended.

3.2 Public Transportation Alternative

The project study area is not well served by mass transit. Based on the
project context, improvements to public transportation would not improve
vehicle flow or safety on US 221 and would not eliminate the need for widening
the existing facilities and improving the alignment. Therefore, the Public
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 2 December 2013
Transportation Alternative does not satisfy the purpose and need for this
project and was eliminated from further study.

3.3 Transportation Systems Management

TSM improvements involve improving traffic flow of the roadway within
the existing right-of-way with minimum capital expenditures and without
reconstructing or adding additional through lanes to the existing road. TSM
improvements will not increase capacity or improve levels of service to the levels
required to prevent failing traffic conditions in the 2035 design year. Therefore,
the TSM Alternative was eliminated from further study.

3.4 Build Alternatives

During the December 16, 2008 meeting for Concurrence Point 2 (Design
Options), the following four widening scenarios were presented:

1. Widening Scenario 1 – Asymmetrical Widening to the East
This alternative would widen US 221 asymmetrically to the east.

2. Widening Scenario 2 – Asymmetrical Widening to the West
This alternative would widen US 221 asymmetrically to the west.

3. Widening Scenario 3 – Symmetrical Widening
This alternative would widen US 221 symmetrically about the existing
centerline of the roadway.

4. Widening Scenario 4 – “Best Fit” Widening Alternative
This alternative would widen US 221 at locations that “best fit” the current
road location and surrounding land uses. “Best fit” locations were evaluated
and selected to improve the existing roadway alignment, minimize impacts,
and permit traffic maintenance during construction.

The impacts of the four (4) widening scenarios at the functional design level are
presented in the following table (Table 1). The impacts shown in this table
were slope stakes plus 40 feet.
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TIP Project R-2915 US 221 Widening
Addendum to the FONSI 4 December 2013
4.0 Preferred Alternative

It was determined at the CP2 and CP2A meetings and reconfirmed at the
“Concurrence Point 3 (CP3) – Least Environmentally Damaging Practicable
Alternative (LEDPA/Preferred Alternative)” meeting held on March 13, 2013 that
the “Best Fit” Widening Alternative was the merger team’s Preferred Alternate.
This alternate was selected because it accomplishes the purpose and need while
minimizing the impacts to the surrounding environment and communities (as
shown in Table 1).

5.0 Summary of Project Impacts

Descriptions of the anticipated impacts are provided in the following
section, and the impacts from the preliminary design are summarized in Table
2.
Table 2 - Summary of Direct Project Impacts from the Preliminary Design
Feature Anticipated Impacts
Project length – miles 16.1
Residential relocations 70
Business relocations 33
Total relocations 103
Major utility crossings 1
Historic Properties (See Note 1) No Adverse Effects – 2 properties
Archaeological Sites No sites eligible for National Register
of Historic Places will be impacted
Cemeteries (See Note 2) 2
Wetland Impacts – acres (See Note 3) 3.7
Stream Impacts – linear feet (See Note 3) 20,804
100-year floodplain crossings 5
Water supply/watershed protected areas 0
Hazardous spill basin areas 2
Impacted noise receptors (See Note 4) 22
Federally protected species 11 – No Effect
Hazardous Material Sites 13
Voluntary Agricultural District Impacts (acres) 3.0
Notes:
(1) = Baldwin Bethany Cemetery and Barnett Idol House
(2) = Gap Creek Cemetery and Baldwin Bethany Cemetery – minor impacts
(3) = Shown acreage includes 25-foot clearing limits outside slope stake lines
(4) = Based upon new traffic noise analysis dated September 10, 2012.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 5 December 2013

Relocations - The project will result in the displacement of approximately 70
homes, 33 businesses, and two religious facilities.

Land Use – Future development within the project study area and its vicinity
will most likely follow the current land use patterns. This project is consistent
with the Jefferson/West Jefferson Thoroughfare Plan, which calls for the
widening of US 221 to a four-lane facility. The 2008 West Jefferson Land Use
Plan recommends that the Town collaborate with NCDOT in the implementation
of the thoroughfare plan.

Farmland – A Farmland Conversion Impact Rating for Corridor Type Projects
(NRCS-CPA-106) was completed for this project (see Appendix E). Approximately
36,452 acres of land in Ashe County (13.3%) and 18,192 acres in Watauga
County (8.4%) are farmland in government jurisdiction. The US 221 widening
improvements will convert approximately 152 acres of farmland to highway use.
The total prime and unique farmland impacted by the project is approximately
37 acres. The total statewide and local important farmland impacted by the
project is 54 acres.

Voluntary Agricultural District (VAD) – NCDOT presented the project to the
Ashe County Voluntary Farmland Preservation Board on February 25, 2013 in
a special public hearing. The Farmland Preservation Board met on March 5,
2013 to discuss the project and information presented to them. The board
determined that NCDOT had met the expectations of Chapter 161:10 of the
Voluntary Farmland Preservation Program. The Board of Commissioners met
on March 18, 2013 and Dale Weinberg, Chairman of the Farmland Preservation
Advisory Board presented that information to the Ashe County Board of
Commissioners. This project will impact a total of three acres of voluntary
agricultural farmland affecting a total of five parcels. This information can be
found in Appendix B.

Community Facilities – No permanent community facility impacts are
associated with the proposed project.

Indirect and Cumulative Effects – No notable indirect or cumulative effects
are anticipated to result from this project. The project is expected to result in a
slight increase in residential development, which will likely take the form of
larger-lot, single-family residences. However, the cumulative effect of this
project, when considered in the context of other past, present, and future
actions, and the resulting impact to notable human and natural features is
considered minimal.

Environmental Justice - Based on the demographic findings and public
comments, environmental justice issues have not been raised on this project.
In addition, both adverse and beneficial impacts associated with the projects
construction would be experience equally by all travelers through the area.
Based on these considerations, the project would not create any
disproportionate effects to low-income or minority populations.

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 6 December 2013
Archaeological and Historic Architectural Resources – Two archaeological
surveys have been conducted for this project. The section between Baldwin and
Jefferson was surveyed in 1977 (Scheitlin et al. 1979). The section between US
421 in Watauga County and Baldwin in Ashe County was surveyed in 2012
(O'Neal 2013). Neither survey identified any sites recommended eligible for the
NRHP. See consultation letters from the North Carolina State Historic
Preservation Office in Appendix D.

The North Carolina State Historic Preservation Office has concurred that the
project, as currently designed, will have No Adverse Effect on the Baldwin
Bethany Cemetery and the Barnett Idol House.

Section 4(f) and Section 6(f) Resources – The project study area includes four
Section 4(f) resources: Baldwin Bethany Cemetery (National Register eligible),
Barnett Idol House (National Register eligible), Fleetwood Community Center,
and Foster Tyson Park. The only impact anticipated by this project is to the
Fleetwood Community Center, where the driveway will need to be re-tied to US
221 (temporary impact). A letter of de minimis impact from the Ashe County
School board regarding the Fleetwood Community Center is included in
Appendix B.

There are no 6(f) resources within the project study area.

Utilities - Construction of the proposed project will require relocation or
modifications of existing public utilities. Any adjustments, relocations, or
modifications will require coordination with the affected utility company during
the final design phase.

Hazardous Material Sites/Underground Storage Tanks – Thirteen (13)
possible UST facilities were identified within the proposed project corridor.
NCDOT anticipates low monetary and scheduling impacts resulting from these
sites. No Hazardous waste, landfills, or other geo-environmental concerns were
discovered.

Terrestrial Communities – Terrestrial communities in the project study area
will be impacted by project construction as result of potential grading and
paving portions of the project study area. Table 3 presents the extent of each
terrestrial community type in the project study area and the anticipated impact
to each community type based on the preliminary roadway design plans.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 7 December 2013

Table 3 - Anticipated Impacts to Terrestrial Communities
Community Coverage (ac)
Maintained/Disturbed Land 152.47
Successional Land 26.08
Pasture Land 31.48
Agricultural Land 3.4
Tree Farm 10.9
Sub Total 224.33
Terrestrial Forests
Mixed Hardwood/White Pine Forest 20.3
White Pine Forest 45.24
Montane Oak-Hickory Forest 98.53
Northern Hardwood Forest 21.23
Sub Total 185.3

Total Terrestrial Communities 409.63

Waters of the United States – Approximately 20,804 linear feet of
jurisdictional streams will be impacted as a result of the project. These impacts
include 18,139 linear feet of designated trout waters. Approximately 3.7 acres
of jurisdictional wetlands will be impacted. The impacts are based on an
additional 25 feet of clearing area beyond the slope stake lines. These impacts
are based on preliminary design mapping and could change during final project
design.

Rare and Protected Species – As of January 5, 2012 and September 22, 2010,
the USFWS lists eleven (11) federally protected species for Ashe and Watauga
Counties, respectively. All 11 species were determined to be “No Effect.”

Water Quality – Construction of the project will slightly increase the amount of
impervious surface within the project study area, which will subsequently
increase stormwater runoff. To reduce the potential for stormwater, the NCDOT
will 1) include stormwater treatment devices in the proposed roadway’s final
design; and 2) utilize protective sediment and erosion control best management
practices (BMPs) during construction, as detailed in 15A NCAC 4B .0124
(Design Standards in Sensitive Watersheds).

The Hydraulics Unit will coordinate with the NC Floodplain Mapping Program
(FMP), the delegated state agency for administering FEMA’s National Flood
Insurance Program, to determine status of the project with regard to
applicability of NCDOT’s Memorandum of Agreement with FMP (dated 6/5/08),
or approval of a Conditional Letter of Map revision (CLOMR) and subsequent
final Letter of Map Revision (LOMR).

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 8 December 2013
Water resources in the study area are part of the New River Basin (US
Geological Survey Hydrologic Unit 05050001). The North Carolina Wildlife
Resources Commission (NCWRC) has identified Gap Creek (S1), Little Gap
Creek (S37), Old Field Creek (S56), Beaver Creek (S124), Call Creek, and South
Beaver Creek as trout waters. Old Field Creek is also designated as ORW. Based
on NCDOT’s “Best Management Practices for Protection of Surface Waters”, a
study to determine the best location for construction of hazardous spill basin(s)
in the vicinity of Old Field Creek will be completed by the NCDOT Hydraulics
Unit during the preparation of the project’s hydraulic design plans.

Riparian Buffers - The proposed project is located entirely within the New
River Basin. The New River Basin does not have NCDWQ river basin buffer
rules in effect at this time. Therefore, no streams in the study area are subject
to river basin buffer rules.

Air Quality – The project is located Ashe and Watauga Counties, which have
been determined to comply with the National Ambient Air Quality Standards
(NAAQS). The proposed project is located in attainment areas; therefore, 40 CFR
Parts 51 and 93 are not applicable. This project is not anticipated to create any
adverse effects on the air quality of these attainment areas.

Noise – Two noise walls will be further evaluated during final design. The first
noise wall will be approximately 800 feet long and 11.5 feet high near Crescent
Drive and US 221. The second noise wall will be approximately 2,400 feet long
and 12.4 feet high from Long Street to Cherry Drive along US 221.

Mineral Resources – The proposed project does not pose any impacts to
mining or mineral resources.

Direct Impact Avoidance & Minimization – Impacts to wetlands, streams,
homes, businesses, churches, and cemeteries were minimized by adjusting
alignments, widths, and slopes and by reducing the design footprint in an effort
to minimize impacts. A list of specific avoidance and minimizations can be
found on the CP 4A form found in Appendix C.

Permits – A list of permits that may be required for this project is provided
below:

 Section 401 General Water Quality Certification – A NCDWQ Section
401 Water Quality Certification is required prior to the issuance of the
Section 404 NWP. A Section 401 General Water Quality Certification will
be required for any activity that may result in a discharge into “Waters of
the United States” or for which the issuance of a federal permit is
required. Prior to issuance of the Water Quality Certification, NCDWQ
must determine that the project will not result in cumulative impacts
that cause or will cause a violation of downstream water quality
standards. Based on the anticipated wetland (3.7 acres) impacts a 401
Water Quality Certification will be required.

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 9 December 2013
 Section 404 (Impacts to “Waters of the United States”) – Impacts to
“Waters of the United States” fall under the jurisdiction of the USACE.
Discharges of dredge or fill material into jurisdictional wetlands, streams,
or open waters associated with the construction of the bridge or other
roadway improvements will require a Section 404 permit from the
USACE. The proposed project impacts 3.7 acres of wetlands, which
exceeds the NWP permit thresholds for wetland/stream impacts (0.5‐acre
cumulative wetland impact). Therefore, an Individual Section 404 permit
will likely be required.

 State Stormwater Permit - Final determination of permit applicability
lies with the USACE and North Carolina Division of Water Quality
(NCDWQ). After final designs are completed, NCDOT will coordinate with
regulatory agencies to obtain the necessary permits.

6.0 Comments & Coordination

The following sections describe public involvement and agency coordination
efforts conducted after publishing the EA.

Circulation of the Environmental Assessment – The EA was circulated to
federal, state, and local agencies for review and comments on October 18, 2012.
The EA and project mapping were also made available for public review. The
review period for the EA closed in January 2013.

Agency Comments Received on the Environmental Assessment – Comments
on the EA were received from the Environmental Protection Agency (EPA), North
Carolina Department of Environment and Natural Resources (NCDENR), North
Carolina Wildlife Resources Commission (NCWRC), and NCDOT Roadside
Environmental Unit. These letters are provided in Appendix B. Project-specific
comments requiring a detailed response from the EPA are included in the
following bullets.

 “On pages 19 and 20 of the EA, Table 10 shows a summary of potential
impacts at the functional design level for East, West, Symmetrical and
Best Fit Alternatives for 7 different sections of the project. Within these
sections (e.g. Section 1,4.54 miles), the East Alternative has 4,419.93
linear feet of impact to streams and the Best Fit Alternative has 5,157.11
linear feet of impact (with greater residential and business relocations - 3
& 3 additional). The overall impacts to the human and natural
environment (highlighted totals) actually indicate that the West
Alternative has lower impacts to streams and residential and business
relocations than the recommended Best Fit Alternative. EPA requests
that the NCDOT and other Merger Team agencies evaluate each section
of the proposed project at or prior to the Concurrence Point 3 Least
Environmentally Damaging Practicable Alternative (LEDP A) meeting to
determine the environmentally preferred alternative for each section of
the project. As currently presented in Table 10, the recommended Best
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 10 December 2013
Fit Alternative for certain sections of the project may not be the overall
LEDPA.”

Response:

Segment 1
Segment 1 reflects lower stream impacts due to the interchange at US 421.
These impacts were not reflected in the east side widening option in the draft
EA. The majority of segment 1 in the Best Fit Alignment is widening on the east
side. The difference in impact is approximately 20 linear feet.

Segment 3
It appears we are shifting from widening on the west side (avoids relocatees on
east side from (Sta. 285+00 to 290+00+/-) to widening on the east side, which
impacts the stream on the west side in the transition. The east-side widening
option avoids the stream on the west side but impacts the parcels on the east
side. This stream impact accounts for the difference. East side widening would
add four additional relocatees while saving approximately 260 linear feet of
stream impact.

Segment 7
The Best Fit Alignment transitions from widening on the west side (Sta. 795+00
to 800+00) to matching the east side alignment at the tie in. This transition
avoids a stream on the east side in Section 6 but increases the impacts in
segment 7. The east-side option impacts the entire stream (approximately 650
linear feet). This transition area is what causes the best fit stream impacts to be
slightly higher than those of the other alternatives considered.

Note: The corrected stream impacts are shown in Table 1 (page 3).

 “EPA also requests that the transportation agencies consider substantial
avoidance and minimization measures to further reduce impacts to
jurisdictional streams and wetlands of the LEDPA, including the use of
retaining walls, steeper side slopes with rock reinforcement, and reduced
median widths.”

Response:

NCDOT will investigate further avoidance and minimization measures during
the final design phase.

 “The EA does not address the stream mitigation site at the intersection of
US 221 and US 421. The FNSI should address this issue that was
discussed at several Merger meetings and NCDOT's re-design efforts to
avoid impacts to it.”

Response:
The stream mitigation site that was constructed as part of the US 421 project is
no longer impacted by this project. All of the widening along US 421 for this
area will take place in the median to avoid this site.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 11 December 2013

 “The EA discusses compensatory mitigation for unavoidable impacts on
page 35 of the EA. Compensatory mitigation is proposed to be sought by
the transportation agencies through the N.C. Ecosystem Enhancement
Program (EEP). There is no discussion in the EA as to the current stream
and wetland assets available through the EEP that would functionally
mitigate for the anticipated impacts (including more than 3 miles of
impacts to designated trout waters).”

Response:

The compensatory mitigation for this project will be handled as part of the final
design. NCDOT will investigate potential onsite stream and wetland mitigation
opportunities. If on-site mitigation is not feasible, mitigation will be provided by
the NCDENR Ecosystem Enhancement Program (NCEEP).

 “EPA notes that the recommended Best Fit Alternative impacts
approximately 120 residences and 29 businesses, 2 churches, 1
cemetery, and 1 community facility.”

Response:

The right-of-way (ROW) impacts shown on page S-5 of the EA are from the
preliminary design and relocation report. The ROW impacts shown on pages 19
and 20 are from the Functional Design with slope stakes plus an additional 40
feet.

 “Terrestrial community impacts are estimated at 410 acres. However,
Table 11 on page 28 of the EA includes maintained and disturbed lands,
successional land, pasture land and agricultural land totaling
approximately 214 acres. Terrestrial forest impacts would be expected to
be approximately 196 acres.”

Response:

We have broken out the mature growth forests on page 7 in Table 3 of this
report. According to our calculations, a total of 185.3 acres should be
considered mature growth forests.

 “Noise receptor impacts from the Build alternative are shown on page 63
of the EA, Table 22, as 9 receptors. EPA understands from the noise
analysis provided that a number of receptors would be eliminated
through relocation of residences from near the existing right of way upon
completion of the proposed project.”

Response:

A new noise report is included in Appendix D.

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 12 December 2013
 “The EA indicates that Section 7 Endangered Species Act consultation for
a protected plant (Virginia spiraea) is still ongoing with the U.S. Fish and
Wildlife Service.”

Response:

After further correspondence with USFWS, it was concluded that this project
would have "No Effect" on Virginia spiraea due to the location of the
downstream known population being around a bend and after a tributary joins
the South Fork New River. In addition, there are no known Virginia spiraea
populations on the South Fork New River upstream of the project crossing. Per
request from USFWS, NCDOT has committed to an additional survey of the
footprint of the existing and proposed bridge over the South Fork New River
prior to permitting to ensure no individuals of Virginia spiraea have inhabited
the area.

 “The EA does not address coordination underway with the National Park
Service due to the proximity of the Blue Ridge Parkway (view-shed issue)”

Response:
Correspondence with the National Parks Service is included in Appendix B. The
National Park Service concluded that this project would have minor impacts on
the Parkway’s viewshed and required no efforts to mitigate the impacts.

 “and the Eastern Band of the Cherokee Indians and the United
Keetoowah Band of the Cherokee Indians (within the geographical area of
both tribes). The transportation agencies should document coordination
efforts with these parties during the Merger process and include relevant
information in the FNSI.”

Response:
The United Keetoowah Band of the Cherokee Indians had “No comment or
objections.” Correspondence with the United Keetoowah Band of the Cherokee
Indians is included in Appendix B.

The Eastern Band of Cherokee Indians did not respond to our requests as of
May 20, 2013. A copy of our correspondence to them is included in Appendix
B.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 13 December 2013
Project-specific comments requiring a detailed response from NCDENR’s
December 19, 2012 Memorandum are included in the following bullets. NCDOT
did not receive these comments until August 28, 2013.

 There is no mention of the existing mitigation site in the EA. There has
been much discussion regarding the need to avoid the site. Its location
should be included on the project mapping, and it should be discussed
in the Environmental Effects section of the EA.

Response:

The mitigation site is discussed in the CP4A form (in Appendix C). The site is
located north side of US 421 just west of the US 221 intersection. The
mitigation site runs parallel to US 421 and encompasses the tributary that
flows east into Gap Creek. The site was avoided by widening US 421 toward the
median instead of toward the outside shoulder.

 A CP 2A field meeting was held May 24, 2012. The EA is dated October
2012. It is very confusing that the results of the meeting are not
incorporated into the EA. It should be updated with all relevant
environmental commitments prior to the date of issuance.

Response:

The CP2A form (in Appendix C) from our March 13, 2013 meeting contains the
latest concurrence on the bridging decisions.

 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,
NCDWQ requests that 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.

Response:

The Design Standards in Sensitive Watersheds (15A NCAC 04B .0124) is
included on the Project Commitments page. The project is not within a Water
Supply Critical Area (see NCDENR’s comment 2 dated August 23, 2013).
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 14 December 2013

 Should the project be located within the Critical Area of a Water Supply,
NCDOT may be required to design, construct, and maintain hazardous
spill catch basins in the project area. The number of catch basins
installed should be determined by the design of the crossings, so that
runoff would enter said basin(s) rather than flowing directly into the
stream, and in consultation with NCDWQ.

Response:

This project is not in a Water Supply Critical Area.

 Gap Creek, Old Field Creek, SF New River, Beaver Creek, Cole Branch,
and Little Buffalo Creek are Trout waters of the State. NCDWQ
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.

Response:

Comment is noted.

 Review of the project reveals the presence of surface waters classified as
WSV; High Quality Waters of the State in the project study area. This is
one of the highest classifications for water quality. Pursuant to 15A
NCAC 2H .1006 and 15A NCAC 2B .0224, NCDOT will be required to
obtain a State Stormwater Permit prior to construction except in North
Carolina's twenty coastal counties.

Response:

Comment is noted.

 Review of the project reveals the presence of surface waters classified as
C; Tr; Outstanding Resource Waters of the State in the project study
area. The water quality classification of C; Tr; ORW is one of the highest
classifications in the State. NCDWQ is extremely concerned with any
impacts that may occur to streams with this classification. It is preferred
that these resources be avoided if at all possible. If it is not possible to
avoid these resources, the impacts should be minimized to the greatest
extent possible. Given the potential for impacts to these resources during
the project implementation, NCDWQ requests that NCDOT strictly
adhere to North Carolina regulations entitled "Design Standards in
Sensitive Watersheds" (15A NCAC 04B .0124) throughout design and
construction of the project. Pursuant to 15A NCAC 2H .1006 and 15A
NCAC 2B .0224, NCDOT will be required to obtain a State Stormwater
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 15 December 2013
Permit prior to construction except in North Carolina's twenty coastal
counties.

Response:

Comment is noted.

Project-specific comments requiring a detailed response from NCDENR’s
August 23, 2013 Memorandum are included in the following bullets.

 DWQ's comments on the FONSI stated that the project was in the Critical
Area of the Water Supply. This statement was incorrect. The project is
not located in the Critical Area of the Water Supply

Response:

Comment is noted.

 Little Buffalo Creek are class C; Tr; +; 303(d) waters of the State. Little
Buffalo Creek is on the 303(d) list for impaired use for aquatic life due to
impaired biological integrity. The NCDWR is very concerned with
sediment and erosion impacts that could result from this project. The
NCDWR recommends that the most protective sediment and erosion
control BMPs be implemented in accordance with Design Standards in
Sensitive Watersheds (l5A NCAC 04B .0124) to reduce the risk of further
impairment to Little Buffalo Creek. The NCDWR requests that road
design plans provide treatment of the storm water runoff through best
management practices as detailed in the most recent version of NCDOT's
Stormwater Best Management Practices.

Response:

Comment is noted, and 15A NCAC 04B .0124 is included on the Project
Commitments page.

 Gap Creek, Little Gap Creek, Old Fields Creek, Beaver Creek, South
Beaver Creek, Little Buffalo Creek, and their unnamed tributaries are Tr
(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 Resource
Commission requirements.

Response:

Comment is noted.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 16 December 2013

 Review of the project reveals the presence of surface waters classified as
WSV; High Quality Waters of the State in the project study area. This is
one of the highest classifications for water quality. Pursuant to 15A
NCAC 2H .1006 and 15A NCAC 2B .0224, the NCDOT will be required to
treat stormwater to the maximum extent practicable, and be in
compliance with their NCS00250.

Response:

Comment is noted.

 Review of the project reveals the presence of surface waters classified as
C; Tr; Outstanding Resource Waters of the State in the project study
area. The water quality classification of C; Tr; ORW is one of the highest
classifications in the State. The NCDWR is extremely concerned with any
impacts that may occur to streams with this classification. It is preferred
that these resources be avoided if at all possible. If it is not possible to
avoid these resources, the impacts should be minimized to the greatest
extent possible. 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. Pursuant to 15A NCAC 2H .1006 and 15A
NCAC 2B .0224, the NCDOT will be required to treat stormwater to the
maximum extent practicable, and be in compliance with their NCS00250.

Response:

Comment is noted.

 An analysis of cumulative and secondary impacts anticipated as a result
of this project is required. The type and detail of analysis shall conform
to the NC Division of Water Resources Policy on the assessment of
secondary and cumulative impacts dated April 10, 2004.

Response:

An Indirect and Cumulative Effects Assessment was completed in June 2009.
The information contained in the EA is a summary of that report.

Project-specific comments requiring a detailed response from the NCWRC are
included in the following bullets.

 The NCWRC submitted scoping comments, dated 5/26/2006, and has
participated in the Merger process for this project. We have reviewed the
FONSI document, including comments received at the public hearings,
and have a number of concerns. Many citizens' comments reflected those
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 17 December 2013
we submitted in our scoping letter. Many were concerned about the
water quality, trout streams, and wildlife in the project area. A common
theme among commenters was that the project scope was too large for
the needs of the area.

Response:

The project scope was determined using the traffic forecast, traffic capacity
models, crash data, and functional classification for this corridor. The
proposed typical section and project limits are designed to accommodate the
2035 project traffic at an acceptable level of service.

 The crash data in the October 2012 Environmental Assessment (EA) were
based on 2004 to 2007 accident reports, and the traffic forecasts used
2007 as the current conditions and compared them to the design year
2035. We are concerned that these data and forecasts might be using
figures prior to the 2008 economic crisis and may not accurately reflect
current and future traffic levels, which are the basis for determining the
project's scope. We recommend an investigation to determine whether a
general widening of the existing two lanes and shoulders, plus specific
safety improvements at key intersections, and possibly some passing
lanes, would meet the purpose and need of the project with considerably
less impacts and cost.

Response:

PDEA consulted the NCDOT Transportation Planning Branch on September 20,
2013 to review this comment about the traffic forecast. Current 2012 traffic
volumes (as shown on the NCDOT 2012 Traffic Volume Maps) were reviewed
and it was determined that current traffic levels have not decreased since the
2007 traffic forecast. In addition, base year traffic volumes and level of service
reflect current congestion issues. The Guidelines to Determine When to Request
an Updated Traffic Forecast (NCDOT 2/24/2009) conclude that an updated
traffic forecast is not warranted. Therefore, it was concluded that the 2035
traffic projections remain valid.

Traffic Systems Management (e.g., adding turn lanes, minor re-alignments)
would not increase the overall capacity of the road and was therefore eliminated
as an option.

 We question the adequacy of an EA/FONSI analysis to address such
impacts with potentially far reaching effects. Additional studies are
needed. For example, one of the most frequent types of crashes involved
collisions with animals. Going from two lanes to four lanes with a median
would greatly increase the distance an animal has to go to cross the road
and may result in more accidents of this type. More information is
needed to ensure safety with this design.

Response:

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 18 December 2013
Only 15.6% of crashes are caused by animals. The proposed alternative will
increase the sight and stopping distances throughout the corridor.

 The indirect and cumulative impacts were not adequately addressed in
the EA or FONSI. A sixteen mile stretch of a two-lane road converted to a
four-lane median-divided facility is likely to induce significant
development. A more in-depth analysis of indirect and cumulative effects
is warranted, especially considering the high quality and sensitive
resources surrounding the project that will be impacted. Protective
measures should be in place to prevent degradation of these resources by
secondary development prior to any construction.

Response:

An Indirect and Cumulative Effects Assessment was completed in June 2009.
The information contained in the EA is a summary of that report.

Project-specific comments requiring a detailed response from the NCDOT
Roadside Environmental Unit are included in the following bullets.

 “On the Project Commitments Green Sheet, the second commitment
concerns the moratorium for the South Fork New River. The same
moratorium is discussed in Section V., Environmental Effects of the
Proposed Action, A. Natural Resources, 4. Waters of the United States, g.
Construction Moratoria, on page 36. This appears to be for smallmouth
bass. It is my understanding that for that past few years NCDOT has
stopped agreeing to a moratorium for smallmouth bass (and some other
‘common’ species). I would request that this commitment be investigated
further and potentially be removed, or an explanation given as to why we
are reversing our current policy concerning this type of moratorium.”

Response:

The May 1 through July 15 moratorium has been removed from the project
commitments.

 “On the Project Commitments Green Sheet, the third commitment
includes a list of streams subject to a trout moratorium. Two of the
streams are misnamed. Deep Gap Creek should be Gap Creek, and Old
Fields Creek should be Old Field Creek.”

Response:

This commitment has been corrected.

 “In Section IV. Proposed Improvements, H. Structures, on page 23, the
second paragraph states, “The proposed structures for the remaining
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 19 December 2013
stream crossings presented in Table 9 of Appendix B …”. There is no
Table 9 in Appendix B. I assume this should be referencing Table B-4.
This is the only table in Appendix B with any type of structure
information included.”

Response:

The EA should reference Table B-4.

 “In Section V., Environmental Effects of the Proposed Action, A. Natural
Resources, 3. Water Resources, on page 28, Table 12 provides the BUC,
SIN, and description of the named streams in the project study area.
The SIN for Little Gap Creek is incorrect. It should be [10-1-23-1], not
[20-1-23-1] (‘20’ would put it in the White Oak River Basin on the coast).
This same SIN is also show incorrectly in Appendix B, Table B-1.”

Response:

Noted.

 “In this same section (V.A.3.), on page 29 the paragraph following Table
12 states, “Little Buffalo Creek is listed on the 2010 Final 303(d) list …”.
As of August 10, 2012, we should be referring to the 2012 Final 303(d)
list. The streams should be reevaluated with the 2012 Final 303(d) list
and this section of the document revised as needed.”

Response:

The 303(d) classifications have not changed from the 2010 to the 2012 list. No
new streams within the project area have been added. Here is the most current
language:

Little Buffalo Creek is listed on the 2012 Final 303(d) list as impaired due to
ecological/biological integrity for benthos.

Summary of Public Hearing Comments – In accordance with 23 USC 128, the
North Carolina Department of Transportation certifies that a public hearing for
the subject project has been held, and the social, economic, and environmental
impacts, consistency with local community planning goals and objectives, and
comments from individuals have been considered in the selection of the
Preferred Alternative.

A Public Hearing was held on December 4, 2012 at the Ashe County
Public High School. The meeting was advertised via a newsletter that
announced the meeting, on the NCDOT website, and via a press release to local
media. The Informal Public Hearing was held from 4:00 PM to 6:30 PM with a
drop-in format, and a formal presentation and hearing were held from 7:00 PM
to 9:00 PM. Displays available for review included the public hearing maps.

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 20 December 2013
All of the written and verbal comments and responses are provided in Appendix
E.

Comments from Public Notice by US Army Corps of Engineers – The US
Army Corps of Engineers issued a Public Notice on January 15, 2013 to solicit
comments from the public on possible alternatives and issues to consider. We
have included a summary/response to these comments and the original letter
in Appendix E.

7.0 Additions & Revisions to the Environmental Assessment

Archaeological Survey – The proposed improvements to U.S. 221 from US 421
in Deep Gap, Watauga County, to US 221 Business/NC 88 in Jefferson, Ashe
County is a Federally-funded project. Therefore the project must comply with
Section 106 of the National Historic Preservation Act that requires the lead
Federal agency (the NCDOT on behalf of the Federal Highways Administration
[FHWA]) to consult with the North Carolina State Historic Preservation Office
(HPO [on behalf of the Advisory Council on Historic Preservation]) regarding the
project's potential to impact archaeological resources eligible for or listed on the
National Register of Historic Places (NRHP).

Consultation with HPO began in 1977 when personnel with the Archaeology
Section of the N.C. Department of Cultural Resources, Division of Archives and
History, conducted an archaeological survey of the section of proposed US 221
between Baldwin and Jefferson (Scheitlin et al. 1979). The survey identified 26
archaeological sites, all of which were recommended ineligible for the NRHP.
HPO concurred with these recommendations, and the section was later
constructed as a two-lane road. Updated scoping information was submitted to
HPO on April 7, 2006. On May 24, 2006, HPO recommended that a
comprehensive archaeological survey be conducted by an experienced
archaeologist to identify and evaluate the significance of archaeological remains
that may be damaged or destroyed by the proposed project.

In May 2012, the NCDOT sponsored an archaeological survey of the Area of
Potential Effects {A.P.E.} of the section between Deep Gap in Watauga County
and Baldwin in Ashe County. The survey identified five archaeological sites, all
of which were recommended ineligible for the NRHP. The NCDOT submitted the
archaeological survey report to HPO on January 24, 2013. On March 5, 2013
HPO concurred with the report's findings and recommended no further
archaeological work for the project.

Scheitliln, Thomas E., Mark A. Mathis, Jerry l. Cross, Thomas H. Hargrove,
John W. Clauser, Jr., Michael T. Southern, Dolores A. Halt Linda H.
Pinkerton, Dale W. Reavis, and Thomas D. Burke

1979 North Carolina Statewide Archaeological Survey: An Introduction and
Application to Three Highway Projects in Hertford, Wilkes, and Ashe
Counties. North Carolina Archaeological Council Publication No. 11.
Archaeology Branch, Division of Archives and History, Department of
Cultural Resources, Raleigh, North Carolina.
TIP Project R-2915 US 221 Widening
Addendum to the FONSI 21 December 2013

O'Neal, Michael Keith
2013 Archaeological Survey and Evaluation of the Proposed US 221 Improvement
from Deep Gap to Baldwin, Watauga and Ashe Counties, North Carolina.
{NCDOT TIP R- 2915; Federal Aid No. STP-125[1]; ER 06-1023.} Report
submitted to the North Carolina Department of Transportation, Raleigh.
Archaeological Consultants of the Carolinas, Inc., Clayton, North
Carolina.

Noise Abatement Review – A new noise abatement review has been completed;
as discussed above, there are now two proposed noise wall locations. These
areas will be studied further as part of the final design process. A copy of this
report is provided in Appendix D.

8.0 Floodplain Impacts

The Federal Emergency Management Agency (FEMA), in cooperation with
federal, state, and local governments, has developed floodway boundaries and
Flood Insurance Rate Maps (FIRMs) for Ashe and Watauga Counties. A
considerable portion of the project study area is within the floodplains. These
areas are primarily designated as Zone AE floodways and floodplains, which
correspond to a statistical 1% annual chance of flooding (i.e., 100-year flood)
(NFIP, 1980). The Zone AE floodplains are flanked by “Zone X” flood areas,
which are those areas having a 0.2 percent annual chance flood (i.e., 500-year
flood).

The NCDOT Hydraulics Unit will coordinate with the NC Floodplain
Mapping Program (FMP), the delegated state agency for administering FEMA’s
National Flood Insurance Program, to determine status of project with regard to
applicability of NCDOT’s Memorandum of Agreement with FMP (dated 6/5/08),
or approval of a Conditional Letter of Map Revision (CLOMR) and subsequent
final Letter of Map Revision (LOMR). This project involves construction activities
on or adjacent to FEMA-regulated stream(s).

TIP Project R-2915 US 221 Widening
Addendum to the FONSI 22 December 2013
9.0 Basis for Finding of No Significant Impact (FONSI)

This FONSI, in conjunction with the EA (incorporated by reference), have
been independently evaluated by the FHWA and determined to adequately and
accurately discuss the need, environmental issues, and impacts of the proposed
project and appropriate mitigation measures. No significant impacts to natural,
social, ecological, cultural, economic, or scenic resources are expected. The
proposed project is consistent with local plans, and the project has been
coordinated with federal, state, and local agencies. In view of this evaluation
and based on responses to the EA and subsequent public involvement, it has
been determined that a Finding of No Significant Impact (FONSI) is applicable
for this project. Therefore, neither an EIS nor further environmental analysis is
required. The FHWA takes full responsibility for the accuracy, scope, and
content of the EA and this FONSI.

Additional information concerning this proposal and document can be
obtained by contacting the following individuals:

John F. Sullivan III, PE, Division Administrator
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, North Carolina 27601
Telephone: [phone]

Richard W. Hancock, PE, Unit Head
Project Development and Environmental Analysis Unit
NC Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Telephone: [phone]

Appendix A

Figures 1-A and 1-B – Project Location and Study Area

Smyth /
Project
Location
Johnson
Avery
Ashe
/
Baldwin
\ \ Fleetwood
\
Deep Gap
Watauga
Grayson
VIRG_ INIA_
NORTH CAROLINA
1
West
Jefferson
Caldwell
Beaver
Creek
Jefferson
Alleghany
Wilkes
NORTH CAROLINA DEPARTMENT
OF TRANSPORTATION
DIVISION OF HIGHWAYS
PROJECT DEVELOPMENT AND
ENVIRONMENTAL ANALYSIS BRANCH
US 221 (R-2915)
Environmental Assessment
Ashe and Watauga Counties
Figure 1-A
PROJECT LOCATION

Project Location
0 1 2 3 4
Miles
North Carolina Department of TransportationEnvironmental StudyUS 221 - NCDOT Project # R-2915Ashe and Watauga Counties, NC
Figure 1-B: Study Area

B l u e Ridge Parkway
(S
R

1145) Mul
atto M
o
untain Rd
D
ic
k P
hillip
s
R
d
(SR 1 17 8 ) P aul Goo d man Rd
(SR 10 0 3) Idle wild Rd
Ba
l
d M
o
un
ta
in
R
d
Bog
gs R
d
(SR 11 7 7) Wa te r Ta nk Rd
E Mill Cre ek Rd
B
a
l
d
M
o
u
n
ta
in
R
d
(SR
1147) Nettle Knob Rd
Buck Mountain Rd
N
C
-
1
6
&
88
SouthernProjectTerminus
NorthernProjectTerminus
West Jefferson
Jefferson
Mount Jefferson State Natural Area
South Fork New R i v e r
221
194
421
163
221
194
Watauga County
Ashe County
Wilkes County
88
Fle etwood
Deep Gap
Baldw in
Beaver C reek
To dd
221Bus
221Bus
(SR 1
149) Mount Jeffe
r
s
o
n
R
o
a
d
(S R 11 7 1 ) W est P i n e S w a m p R d .
(
S
R 1100) Cra n b e rry Springs R d .
(S R 111
2
)
Woodstown
Rd.
(SR 1200)Frank Edwards Rd.
(SR 1272)Vernon Roten Rd /NC 194
(S R 1143)
Clarence

L
y
a
l
l
Rd.
Legend
Ashe County Courthouse - NRHP
Fleetwood Volunteer Fire & Rescue, Inc.
Public Schools
Parks
(SR 13
6
0
)
Heg
G
r
eene R
d
.

Moret
z
Farm
Road
(SR 126
5
)Deep
G
a
pEstates
R
d
.

(S R 1 1 0 3 ) L i b e r t y Grove Church Rd.
(S
R 1216) Lemly Rd.Hemlock Ln.
(SR 1169)
W
i
n
d
y

H
ill Rd.(SR 1106) Ra
i
lroad Grade Rd.

Appendix B

Voluntary Agricultural District (VAD) Correspondence
Ashe County School Board Correspondence
Environmental Protection Agency Comments
National Park Service – Viewshed Correspondence
Eastern Band of Cherokee Indian Correspondence
United Keetoowah Band of Cherokee Indian Correspondence

County of Ashe
150 Government Circle, Suite 2500
Jefferson, North Carolina 28640
March 19, 2013
Michael Wray
Project Planning Engineer
Western Unit
DOT / 221 Highway Project
RE: Voluntary Agriculture District Report and Public Hearing
Dear Mr. Wray:
County Manager
1)r, Patricia Mitchell, ('1?cl)
Office 336-8,16-5.i01
[e-mail]
Attached you will find the report from the Ashe County Volunteer Agriculture District Board
that was presented to the Board of Commissioners on March 18, 2013. Also attached is the
Agenda of the meeting in which the Public Hearing was held.
If you need additional information, please do not hesitate to contact me.
Dr. Patricia Mitchell, CEcD
County Manager &
Economic Developer

ASHE COUNTY BOARD OF COMMISSIONERS
REGULAR MEETING
AGENDA
March 18, 2013
TIME BUSINESS
1:00 p.m. L Mid -Year Budget Review & Work Session in the Second Floor
Conference Room
3:30 II. Meeting Called to Order at the Ashe County Courthouse
Opening Prayer and Pledge of Allegiance
Approval of Minutes — March 4, 2013 Regular Session
March 4, 2013 Executive Session
Adoption ofAgenda
3:35 III. Public Hearing— Planning Director Adam Stumb - Proposed
Amendment to the Ashe County Watershed Map
3:50 IV. Dale Weinberg, Chairman, Farmland Preservation Advisory
Board — Findings & Recommendations from the Voluntary
Agricultural District (VAD) Public Hearing regarding the
Highway 221 Widening Project
4:05 V. Stephanie Craven & Peggy Bailey — "Week of the Young Child"
Proclamation
4:15 VI. Tax Administrator Keith Little — Monthly Tax Report
4:25 VIL County Manager Dr. Patricia Mitchell & Assistant Director of
Economic Development Cory Osborne— Presentation of Ashe
County Photos
4:40 VIIL Public Comment
GENERAL SESSION
Airport Advisory Board Appointment — First Presentation
Economic Development Commission Appointment — First Presentation
Commissioner Comments
Announcements

Ashe County Voluntary Farmland Preservation Board
Public Hearing — February 25, 2013 - 6:00 p.m.
Ashe County Courthouse
Attending; Dale Sheets, Ryan Hufnan, Trathen Cheek, Marlin McVey, Martin Weaver; Thelma
DuVall, Carolyn Carter Trent, Betty Carter Corriher, Tint Goias, Ed Robbins, Courtney Wait,
Judy Bare, Pat Mitchell, CoryOsbonte, Carolyn Shepherd, Dean Witherspoon, MaryM.
Witherspoon, GlenHenlschel
Department of Transportation Staff --Janine Robbins, Public Involvement Officer for eight years
with North Carolina Department of Public Transportation, Graduate of North Carolina State
University; Martha Hodge — Community Planner with North Carolina Department of
Transportation for 4.5 years, Graduate of University of North Carolina; Kristen Webb, John
Cot fortie, Michael Wray
Martin Weaver called the meeting to order —Hearing for US 221 Widening Project.
Janille Robbins with the Department of Transportation spoke —
• level of service on 221 explained
• explained how they are planning the road for the future
• explained the design of the road and why it is designed that way
• talked about how the road will impact farmland and landowners
• stated that Farmland Preservation Board had 30 days to submit information and questions
to the Department of Transportation regarding the road
The road is split into five sections —
• A — Right of Way = Jii1y 201.3 Constructwn - 2015
• B — Right of Way — July 2013; Construction - 2015
• C —Right of Way -• April 2014; Construction - 2017
• D —Right of Way — September 2013; Construction — 2017
• 4 of 5 sections have funding
• 103 relocations (30 commercial; 70 homes)
Explained map of projected road —
• 1 access road per parcel
• Talked about U turn areas on road
• Funding is 80% federal and 20% state
• Said Miller farn is only farm affected on new road
• Any property takes are based on property appraisal from state
USDA says approximately 152 acres of farmland will be affected
Will tractor and trailers be able to make turns at U turn spots or will they have to drive to
Jefferson to come back to Railroad Grade Road (question not answered)
1

Martin Weaver asked will median be opened at entrance of Fleetwood Fire Department.
Janille stated that emergency openings will exist.
Some roads will have left turn access.
If your property does not have an access point you will not have one, however if you do have
access you will receive at least one access to your property
Submitted by:
Ryan Huffman &
Trathen Cheek
2/25/2013
2

Ashe County Voluntary Farmland Preservation Board
Regarding Public Hearing — February 25, 2013
Follow Up Board Meeting
March 5, 2013 — 6:00 p.m. — Agriculture Service Center
The Ashe County Voluntary Farmland Preservation Board held a special called meeting on Tuesday,
March 5, 2013 at 6:00 p.m. at the Agriculture Service Center. The purpose of the meeting was to review
information teamed from the February 25th, 2013 Public Hearing by the North Carolina Department of
Transpotation as to how property in the Ashe County Voluntary Farmland Preservation Program will be
affected by the Highway 221 road construction project and to prepare a written report for the North
Carolina Department of Transportation and the Ashe County Commissioners to meet the expectations of
Chapter 161:10 in the Voluntary Farmland Preservation Program.
The minutes from the March 5, 2013 are as follows:
Attending— Ryan Hfinat, Jttdy Bare, Dale Sheets, Dale Wineberg, Marti:: McVey, Trathen Cheek, Glen
Hentschel, Carolyn Shepherd —Ashe County Extension Director
1) Of Chapter 161.10 — hat the need for the project requiring the condemnation been
satisfactorily shown by the agency requesting the action?
Yes, there was a detailed map from start to finish displayed at the hearing, and statistics were given why
the road should he widened. Also the high volume of traffic and level of service were discussed and the
road is being planned for the future.
2) Of Chapter 161.10 — has the financial Impact analysis been conducted by the agency
seeking the action?
There has been a cost estimate in reference to the highway, however we are unclear if a financial impact
Itas been declared to the land owner.
3) Of Chapter 161.10 — have alternatives been considered to the proposed action that are
less disruptive to the agricultural activities and farmland base of the voluntary
agricultural district within which the proposed action Is to take place?
Yes, alternatives have been considered, however to go a different route more farmland would be affected,
than the existing route planned.

Vickie Moore
Subject: FW: Feb. 25 Hearing in Ashe
From: Carolyn Shepherd
Sent: Wednesday, March 06, 2013 9:56 AM
To: 'Wray, Michael G'
Cc: Carolyn Shepherd; Judy Bare; Dale Sheets; Dale Wineberg; 'Ryan Huffman'; Martin McVey; 'Martin Weaver; Trathen
Cheek; Vickie Moore
Subject: Feb, 25 Hearing in Ashe
Good Morning Michael,
The Farmland Preservation Board met last night to complete the report that will be submitted to DOT and reported
to the County Commissioners at their next scheduled meeting of March 181h. Board members had the following
questions and they asked that I forward them to DOT for clarification. As you were my Initial DOT contact, I am sending
them to you.
Parcel 11 19227 —180 of 4.7 acres
Parcel 1119227 —144 of 21.6 acres _ both of these in the name of Thelma Duvall
Parcel # 19227 — 360 of 5.52 acres — in the name of Judy Bare and Dean Witherspoon
Each of these are in the VAD(Farmland Preservation). Graphics from the picture map presented and discussed at the
meeting showed that an additional 5-6 feet will be taken for right of way along these properties that will adjoin the road.
However, these parcels were not shown to be in the VAD on the map. The committee doubled checked on these parcels
and they are in the VAD; The committee is concerned that there may be - in addition to these, other properties
unidentified as VAD properties and that total acreage may be affected (Le the report given was that 134 acres of VAD
property would be affected by the project), but this may not be the total affected as the 3 parcels mentioned above
were not In the 1 %: acres mentioned to be affected.
in addition, the committee questioned the compensation to land in VAD that would be taken for the road project. The
committee is concerned about the formula used in the compensation process for farmland. What Is the financial analysis
and how will you determine the valuation of farmland on the impact of land taken on farmers(as a 1 time payoff when
the farmer will have lost an annual income over numerous years?)
In the statute, the wording says "Has a financial impact analysis been conducted by the agency seeking the action". The
committee wants clarification on this statement —does this refer to the cost of the road, the financial impact to the
landowners, or both?
Thank Michael for your help in answering these questions. All of these questions will be referenced in the presentation
the Commissioners on March 18 when the FP Chair presents the report. Thanks for your help In clarifying the above.
Carolyn
Carolyn Shepherd
County Extension Director
North Carolina State University
College of Agriculture and Life Sciences
North Carolina Cooperative Extension, Ashe County Ctr.
134 Government Circle, Suite 202
Jefferson, NC 28640
[phone]
[phone] (fax)
Carolyn [e-mail]
t

1
Robbins, Ed
Subject:FW: R-2915 US 221 Widening: Farmland Preservation
Importance:High

From: Wray, Michael G
Sent: Monday, March 18, 2013 9:47 AM
To: Carolyn Shepherd ([e-mail])
Cc: 'Vickie Moore'
Subject: R-2915 US 221 Widening: Farmland Preservation
Importance: High 

Carolyn, 

NCDOT and Parsons have done further investigation into the questions you had prior to tonight’s meeting.  Below are 
the findings, as reported by Parsons: 

We have used the latest information shown on Ashe County GIS Website (http://ashegis.ashecountygov.com/webgis/) 
to update our Farmland Preservation information. 

The following table summarizes our preliminary design’s impact to your members properties (these areas should be 
considered preliminary and not used for negotiation purposes): 

Location Total Property 
Acreage 
Acreage to be 
Acquired Owners Name 
1 20.4 0.6 Kermit Lee & Jane B Miller 

2 13.6 1.2 Clayton & Ruth H Lemly 

3 1.4 0.4 Barry K & Sandra T Liddle 

4 25.1 0.4 Thelma W Duvall 

5 5.2 0.4 Gary & Judy Bare Trustee 

Totals 65.7 3.0   

Upon receiving your current role of members, we will re‐verify this information and alert you to any additional 
properties that are affected. 

Below are the answers to your other concerns: 

“In addition, the committee questioned the compensation to land in VAD that would be taken for the road project.  The 
committee is concerned about the formula used in the compensation process for farmland. What is the financial analysis 
and how will you determine the valuation of farmland on the impact of land taken on farmers(as a 1 time payoff when 
the farmer will have  lost an annual income over numerous years?)” 

2
The Right of Way appraiser will determine the highest and best use of the property and then use a sales comparison 
approach to determine the value.  This is the same approached used for all of NCDOT’s property acquisitions. 

“In the statute, the wording  says “Has a financial impact analysis been conducted by the agency seeking the action”. The 
committee wants clarification on this statement – does this refer to the cost of the road, the financial impact to the 
landowners, or both?” 

A Right of Way estimate was performed by NCDOT for the project by section (R‐2915 is divided into A through E 
sections).  This project is still at a very preliminary design stage and  NCDOT does not like making individual property 
evaluations at this point in the project process. 

If you have any further questions, please do not hesitate to give Michael Wray, (919)707‐6050, or myself a call. 

Thanks, 
Ed Robbins, P.E. 

 5540 Centerview Drive, Suite 217
Raleigh, NC 27606
T: [phone]  
C: [phone]
F: [phone] 
[e-mail] 
www.Parsons.com 

Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
ASHE COUNTY
sckoo(s
Cha// J;"9 yoan3 •'r,nds fo soar.
Donnie R. Johnson, Superintendent • Charles L. King, Chairman • Charles B. Jones, Jr., Vice -Chairman
Dr. Lee Beckworth • Polly Jones • Terry Williams
May 1,2013
Tim D. Goins, PE
Parsons Engineering
5540 Centerview Drive, Suite 217
Raleigh, North Carolina 27606
Dear Mr. Goins:
The Ashe County School Board concurs that the NCDOT widening of US 221 (Project R-2915) will
not adversely affect the activities, features, or attributes that qualify the Fleetwood Community
Center for protection under Section 4(f) of the Safe, Accountable, Flexible, Efficient Transportation
Equity Act.
Should you need any additional information in order to complete the preliminary phase of this
project, please contact my office.
Thank you,
Donnie R. Johnson
Superintendent
www.ashe.k12.nc.us
PO Box 604 • 320 South Street • Jefferson, NC 28640 • 336.246.7175 • 336.246.7609 fax • Courier No. 15-65-01

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
,m _ yz REGION 4
8 i` Q ATLANTA FEDERAL CENTER
a� o$ 61 FORSYTH STREET
c<)19''9< PRo-1 ATLANTA, GEORGIA 30303-8960
January 10, 2013
Dr. Gregory Thorpe, Ph.D.
Manager, Project Development and Environmental Analysis
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, N.C. 27699-1548
SUBJECT: Federal Environmental Assessment, US 221 Widening, Watauga and Ashe Counties,
TIP No.: R-2915
Dear Dr. Thorpe:
The U.S. Environmental Protection Agency (EPA) has reviewed the subject document
and is providing comments in accordance with Section 309 of the Clean Air Act and Section
102(2)(C) of the National Environmental Policy Act (NEPA). The North Carolina Department
of Transportation (NCDOT) and the Federal Highway Administration (FHWA) are proposing to
widen US 221 to a 4-lane, median divided facility for approximately 16.1 miles between US 421
to US 221 Business/NC 88 in Watauga and Ashe Counties.
The proposed project is included in the NEPA/Section 404 Merger process. EPA
concurred with the purpose and need, Concurrence Point 1, on January 22, 2008, detailed study
alternatives (DSAs) on December 16, 2008, and Concurrence Point 2A, bridging decisions on
July 25, 2012. EPA's detailed technical review comments on the Federal Environmental
Assessment (EA) are attached to this letter (See Attachment A).
EPA requests that the environmental concerns identified in the attachment be addressed
through the NEPA/Section 404 Merger process and prior to the issuance of the Finding of No
Significant Impact (FONSI). We appreciate the opportunity to review the EA and request a copy
of the FONSI when it becomes available. Please feel free to contact Mr. Christopher Militscher
of my staff should you have any questions concerning these comments at 404-562-9512.
Sincerely,
rye
Heinz J. Mueller, Chief
NEPA Program Office
w/Attachment
of Highv
JAN 1 4 2013
Preconstruction
Project Development and
--rental Analysis l3ranh
Internet Address (URL) ® http://www.epa.gov
Recycled/Recyclable e Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)

Attachment A
Detailed Technical Comments
US 221 Widening
Federal EA for TIP No. R-2915
Watauga and Ashe Counties
Jurisdictional Wetland and Stream Impacts
The proposed recommended alternative ("Best Fit") is anticipated to impact 20,804 linear
feet of jurisdictional streams and 6.84 acres of jurisdictional wetlands. The proposed project
entails 24 stream crossings and five (5) 100-year floodplain crossings. Designated trout waters
have been identified as Gap Creek, Little Gap Creek, Old Field Creek, Beaver Creek, Call Creek
and South Beaver Creek. Of the 20,804 linear feet of stream impacts, NCDOT estimates that
18,139 linear feet to designated trout waters. Old Field Creek from Call Creek to the South Fork
of the New River has been designated as Outstanding Resource Waters (ORW). Portions of the
South Fork of the New River have been designated as Water Supply V, High Quality Waters
(WS-V; HQW). Little Buffalo Creek is listed on the 2010 Final 303(d) list as impaired waters for
aquatic life due to impaired ecological/biological integrity.
On pages 19 and 20 of the EA, Table 10 shows a summary of potential impacts at the
functional design level for East, West, Symmetrical and Best Fit Alternatives for 7 different
sections of the project. Within these sections (e.g. Section 1, 4.54 miles), the East Alternative
has 4,419.93 linear feet of impact to streams and the Best Fit Alternative has 5,157.11 linear feet
of impact (with greater residential and business relocations — 3 & 3 additional). The overall
impacts to the human and natural environment (highlighted totals) actually indicate that the West
Alternative has lower impacts to streams and residential and business relocations than the
recommended Best Fit Alternative. EPA requests that the NCDOT and other Merger Team
agencies evaluate each section of the proposed project at or prior to the Concurrence Point 3
Least Environmentally Damaging Practicable Alternative (LEDPA) meeting to determine the
environmentally preferred alternative for each section of the project. As currently presented in
Table 10, the recommended Best Fit Alternative for certain sections of the project may not be the
overall LEDPA.
EPA also requests that the transportation agencies consider substantial avoidance and
minimization measures to further reduce impacts to jurisdictional streams and wetlands of the
LEDPA, including the use of retaining walls, steeper side slopes with rock reinforcement, and
reduced median widths.
The EA does not address the stream mitigation site at the intersection of US 221 and US
421. The FNSI should address this issue that was discussed at several Merger meetings and
NCDOT's re -design efforts to avoid impacts to it.
The EA discusses compensatory mitigation for unavoidable impacts on page 35 of the
EA. Compensatory mitigation is proposed to be sought by the transportation agencies through

the N.C. Ecosystem Enhancement Program (EEP). There is no discussion in the EA as to the
current stream and wetland assets available through the EEP that would functionally mitigate for
the anticipated impacts (including more than 3 miles of impacts to designated trout waters).
Other Impacts and Issues
EPA notes that the recommended Best Fit Alternative impacts approximately 120
residences and 29 businesses, 2 churches, 1 cemetery, and 1 community facility. Terrestrial
community impacts are estimated at 410 acres. However, Table 11 on page 28 of the EA
includes maintained and disturbed lands, successional land, pasture land and agricultural land
totaling approximately 214 acres. Terrestrial forest impacts would be expected to be
approximately 196 acres. Noise receptor impacts from the Build alternative are shown on page
63 of the EA, Table 22, as 9 receptors. EPA understands from the noise analysis provided that a
number of receptors would be eliminated through relocation of residences from near the existing
right of way upon completion of the proposed project.
The EA indicates that Section 7 Endangered Species Act consultation for a protected
plant (Virginia spiraea) is still ongoing with the U.S. Fish and Wildlife Service.
The EA does not address coordination underway with the National Park Service due to
the proximity of the Blue Ridge Parkway (view -shed issue) and the Eastern Band of the
Cherokee Indians and the United Keetoowah Band of the Cherokee Indians (within the
geographical area of both tribes). The transportation agencies should document coordination
efforts with these parties during the Merger process and include relevant information in the
FNSI.

Beverly Eaves Perdue
Governor
MEMORANDUM
AVA
CCDEE R
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Charles Wakild, P.E Dee Freeman
Director Secretary
December 19, 2012
To: Lyn Hardison, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs
From: Amy Euliss, Division of Water Quality, Winston Salem Regional Office
Subject: Comments on the Environmental Assessment (EA) related to proposed widening of US
221 to a four lane, median divided facility from US 421 in the Deep Gap community to
SU 221 Business -NC 88 intersection in the town of Jefferson, Ashe County, Federal Aid
Project No.STP-0221 (13), State Project No. 34518.1.1, TIP R02915. State
Clearinghouse Project No. 13-0200.
This office has reviewed the referenced document dated October, 2012. The NC Division of Water
Quality (NCDWQ) is responsible for the issuance of the Section 401 Water Quality Certification for
activities that impact Waters of the U.S., including wetlands. It is our understanding that the project as
presented will result in impacts to jurisdictional wetlands, streams, and other surface waters. NCDWQ
offers the following comments based on review of the aforementioned document:
Project Specific Comments:
1. This project is being planned as part of the 404/NEPA Merger Process. As a participating team
member, NCDWQ will continue to work with the team.
2. There is no mention of the existing mitigation site in the EA. There has been much discussion
regarding the need to avoid the site. Its location should be included on the project mapping, and it
should be discussed in the Environmental Effects section of the EA.
3. A CP 2A field meeting was held May 24, 2012. The EA is dated October 2012. Its very confusing
that the results of the meeting are not incorporated into the EA. It should be updated with all
relevant environmental commitments prior to the date of issuance.
4. 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, NCDWQ requests that 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.
5. Should the project be located within the Critical Area of a Water Supply, NCDOT may be required
to design, construct, and maintain hazardous spill catch basins in the project area. The number of
catch basins installed should be determined by the design of the crossings, so that runoff would
enter said basin(s) rather than flowing directly into the stream, and in consultation with NCDWQ.
Transportation and Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwateraualitv.orq
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
Naturally

6. Gap Creek, Old Field Creek, SF New River, Beaver Creek, Cole Branch, and Little Buffalo Creek
are Trout waters of the State. NCDWQ 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.
7. Review of the project reveals the presence of surface waters classified as WSV; High Quality
Waters of the State in the project study area. This is one of the highest classifications for water
quality. Pursuant to 15A NCAC 2H .1006 and 15A NCAC 2B .0224, NCDOT will be required to
obtain a State Stormwater Permit prior to construction except in North Carolina's twenty coastal
counties.
8. Review of the project reveals the presence of surface waters classified as C; Tr; Outstanding
Resource Waters of the State in the project study area. The water quality classification of C; Tr;
ORW is one of the highest classifications in the State. NCDWQ is extremely concerned with any
impacts that may occur to streams with this classification. It is preferred that these resources be
avoided if at all possible. If it is not possible to avoid these resources, the impacts should be
minimized to the greatest extent possible. Given the potential for impacts to these resources during
the project implementation, NCDWQ requests that NCDOT strictly adhere to North Carolina
regulations entitled "Design Standards in Sensitive Watersheds" (15A NCAC 04B .0124)
throughout design and construction of the project. Pursuant to 15A NCAC 2H .1006 and 15A
NCAC 2B .0224, NCDOT will be required to obtain a State Stormwater Permit prior to construction
except in North Carolina's twenty coastal counties.
General Comments:
1. 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.
2. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff. These alternatives shall include road designs that
allow for treatment of the storm water runoff through best management practices as detailed in the
most recent version of NCDOT's Stormwater Best Management Practices Manual, such as grassed
swales, buffer areas, preformed scour holes, retention basins, etc.
3. 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 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 NC Ecosystem Enhancement Program may be available for use as wetland mitigation.
4. In accordance with the Environmental Management Commission's Rules {15A NCAC
2H.0506(h)}, mitigation will be required for impacts of greater than 150 linear feet to any single
stream. In the event that mitigation is required, the mitigation plan shall be designed to replace
appropriate lost functions and values. The NC Ecosystem Enhancement Program may be available
for use as stream mitigation.

5. 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.
b. NCDWQ is very concerned with sediment and erosion impacts that could result from this project.
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.
7. An analysis of cumulative and secondary impacts anticipated as a result of this project is required.
The type and detail of analysis shall conform to the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004.
8. 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.
9. Where streams must be crossed, NCDWQ prefers bridges be used in lieu of culverts. However, we
realize that economic considerations often require the use of culverts. Please be advised that
culverts should be countersunk to allow unimpeded passage by fish and other aquatic organisms.
Moreover, in areas where high quality wetlands or streams are impacted, a bridge may prove
preferable. When applicable, NCDOT should not install the bridge bents in the creek, to the
maximum extent practicable.
10. Whenever possible, NCDWQ prefers spanning structures. Spanning structures usually do not
require work within the stream or grubbing of the streambanks and do not require stream channel
realignment. The horizontal and vertical clearances provided by bridges shall allow for human and
wildlife passage beneath the structure. Fish passage and navigation by canoeists and boaters shall
not be blocked. Bridge supports (bents) should not be placed in the stream when possible.
11. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across
the bridge and pre-treated through site -appropriate means (grassed swales, pre -formed scour holes,
vegetated buffers, etc.) before entering the stream. Please refer to the most current version of
NCDOT's Stormwater Best Management Practices.
12. Sediment and erosion control measures should not be placed in wetlands or streams.
13. 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.
14. 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.
15. Based on the information presented in the document, the magnitude of impacts to wetlands and
streams may require an Individual Permit 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 NCDWQ. Please be aware that any
approval will be contingent on appropriate avoidance and minimization of wetland and stream
impacts to the maximum extent practical, the development of an acceptable stormwater
management plan, and the inclusion of appropriate mitigation plans where appropriate.
16. 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.
17. 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.
18. Unless otherwise authorized, placement of culverts and other structures in waters and streamsshall
be placed below the elevation of the streambed by one foot for all culverts with a diameter greater
than 48 inches, and 20 percent of the culvert diameter for culverts having a diameter less than 48
inches, to allow low flow passage of water and aquatic life. Design and placement of culverts and
other structures including temporary erosion control measures shall not be conducted in a manner
that may result in dis-equilibrium of wetlands or streambeds or banks, adjacent to or upstream and
down stream of the above structures. The applicant is required to provide evidence that the
equilibrium is being maintained if requested in writing by NCDWQ. If this condition is unable to
be met due to bedrock or other limiting features encountered during construction, please contact
NCDWQ for guidance on how to proceed and to determine whether or not a permit modification
will be required.
19. 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.
20. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3883/Nationwide Permit No. 6 for Survey
Activities.
21. 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.
22. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP
measures from the most current version of NCDOT Construction and Maintenance Activities
manual such as sandbags, rock berms, cofferdams and other diversion structures shall be used to
prevent excavation in flowing water.
23. 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

NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, Ili
Governor Secretary
MEMORANDUM
To:
From:
RE:
Crystal Best
State Clearinghouse
r/
i
Lyn Hardison --A
t
Division of Envirorrmental Assistance and Customer Service
Environmental Assistance and Project Review Coordinator
14-0025
Finding of No Significant Impact (FONSI)
Proposed to widen US 221 to a four land, median divided facility from US 421 in the
Deep Gap community to US 221 Bus. NC 88 intersection in the Town of Jefferson,
TIP R-2915
Watauga and Ashe Counties
Date: August 23, 2013
The Department of Environment and Natural Resources has reviewed the proposal for the referenced
project. Based on the information provided, our agencies have identified permits that may be required.
The Division of Water Resources Water Quality Program and NC Wildlife Resource Commission are
concerned that the FONSI Environmental document does not adequately address the impacts to
jurisdictional wetlands, waters of the State, rare species and the natural resources within the project
area. Please forward this memorandum and the attachments to the applicant so the concerns can be
addressed and the necessary adjustments can be made to the report.
The Department encourages the applicant to continue communicating with the agencies and address
their concerns prior to the issuance of the FONSI and moving forward with the project.
Thank you for the opportunity to respond.
Attachment
1601 Mail Service Center, Raleigh, North Carolina 27699-1601
Phone: [phone] Internet: wwwnodenr,gov
An Equal Opportunity t Affirmative Action Employer — 50% Recycled i IP% Post Consumer Paper

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Programs
Pat McCrory Thomas A. Reeder John E. Skvarla, Ili
Governor Director Secretary
August 23, 2013
MEMORANDUM
To: Lyn Hardison, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs
From: Amy Euliss, Division of Water Resources, Winston Salem Regional Office
Subject: Comments on the Final Finding of No Significant Impact related to proposed US 221
Widening from US 421 to US 221 Business/NC 88 in Jefferson, Watauga and Ashe
Counties, Federal Aid Project No. STP-0221(13), State Project No. 34518.1.1, TIP R-
2915, State Clearinghouse Project No. 14-0025.
This office has reviewed the referenced document dated May, 2013. The NC Division of Water
Resources (NCDWR) is responsible for the issuance of the Section 401 Water Quality Certification for
activities that impact Waters of the U.S., including wetlands. It is our understanding that the project as
presented will result in impacts to jurisdictional wetlands, streams, and other surface waters. The
NCDWR offers the following comments based on review of the aforementioned document:
Project Specific Comments:
1, The Division of Water Quality (DWQ) submitted comments to the State Clearinghouse dated
December 19, 2012. The FONSI does not show a record of those comments. Please update the
FONSI to reflect a receipt of the comments.
2, DWQ's comments on the FONSI stated that the project was in the Critical Area of the Water
Supply. This statement was incorrect. The project is not located in the Critical Area of the Water
Supply
3. This project is being planned as pan of the 404/NEPA Merger Process, As a participating team
member, the NCDWR will continue to work with the team.
4, Little Buffalo Creek are class C; Tr; +; 303(d) waters of the State. Little Buffalo Creek is on the
303(d) list for impaired use for aquatic life due to impaired biological integrity. The NCDWR is
very concerned with sediment and erosion impacts that could result from this project. The NCDWR
recommends that the most protective sediment and erosion control BMPs be implemented in
accordance with Design Standards in Sensitive Watersheds (15A NCAC 04B .0124) to reduce the
risk of further impairment to Little Buffalo Creek. The NCDWR requests that road design plans
Transportation and Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: www.ncwaterpuality.orq
An Equal Opportunity 1 A(tirmaltve Acton Employer
One
NorthCarolina
Naturally

provide treatment of the storm water runoff through best management practices as detailed in the
most recent version of NCDOT's Stormwater Best Management Practices.
5. Gap Creek, Little Gap Creek, Old Fields Creek, Beaver Creek, South Beaver Creek, Little Buffalo
Creek, and their unnamed tributaries are Tr (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.
6. Review of the project reveals the presence of surface waters classified as WSV; 1-ligh Quality
Waters of the State in the project study area. This is one of the highest classifications for water
quality. Pursuant to I5A NCAC 2H .1006 and 15A NCAC 2B .0224, the NCDOT will be required
to treat stormwater to the maximum extent practicable, and he in compliance with their NCS00250.
7, Review of the project reveals the presence of surface waters classified as C;Tr; Outstanding
Resource Waters of the State in the project study area. The water quality classification of C;Tr;
ORW is one of the highest classifications in the State. The NCDWR is extremely concerned with
any impacts that may occur to streams with this classification. It is preferred that these resources be
avoided if at all possible. If it is not possible to avoid these resources, the impacts should be
minimized to the greatest extent possible. 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. Pursuant to 15A NCAC 21-1.1006 and 15A
NCAC 2B .0224, the NCDOT will be required to treat stormwater to the maximum extent
practicable, and be in compliance with their NCS00250.
8. An analysis of cumulative and secondary impacts anticipated as a result of this project is required.
The type and detail of analysis shall conform to the NC Division of Water Resources Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004,
General Comments:
4. 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(1ft, 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.
10. Environmental impact statement alternatives shall consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff. These alternatives shall 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 NCDOT's Stormwater Best Management Practices Manual, July 2007,
such as grassed swales, buffer areas, preformed scour holes, retention basins, etc.
1 I. 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 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 NC Ecosystem Enhancement Program may be available for use as wetland mitigation.

12. In accordance with the Environmental Management Commission's Rules (I5A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 150 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 NC Ecosystem Enhancement Program may be available for use as stream
mitigation.
13, 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.
14. 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,
15. 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.
16. 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,
17. 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.
18. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across
the bridge and pre-treated through site -appropriate means (grassed swales, pre -formed scour holes,
vegetated buffers, etc.) before entering the stream, Please refer to the most current version of
NCDOT's Stormwater Best Management Practices.
19, Sediment and erosion control measures should not be placed in wetlands or streams.
20. 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.
21. 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.
22. 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.
23. 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 pl-I and possible aquatic life and
fish kills.
24. 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.
25. 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.
26. 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.
27. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3883/Nationwide Permit No. 6 for Survey
Activities.
28. 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.
29. 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.

30. 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.
31. 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.
32. 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.
33. Riparian vegetation (native trees and shrubs) shall he 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.
The NCDWR appreciates the opportunity to provide comments on your project. Should you have any
questions or require any additional information, please contact Amy Euliss at [phone] or
[e-mail].
cc: Andy Williams, USACE Raleigh Regional Office (electronic copy only)
Chris Militscher, Environmental Protection Agency (electronic copy only)
Marella Buneick, US Fish and Wildlife Service (electronic copy only)
Marla Chambers, NC Wildlife Resources Commission (electronic copy only)
DWR, TPU
File Copy

North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
TO: Lyn Hardison, Environmental Assistance Coordinator
Division of Environmental Assistance & Outreach (DEAO), NCDENR
FROM: Marla Chambers, Western NCDOT Permit Coordinator ' 7" - eiLa'm1R'2--.
Habitat Conservation Program, NCWRC
DATE: August 21, 2013
SUBJECT: Review of the Finding of No Significant Impact for NCDOT's proposed widening
of US 221 from US 421 to US 221 Business/NC 88 in Jefferson, Watauga and
Ashe Counties. TIP No. R-2915. DENR Project No. 14-0025, originally due
8/19/2013, extended to 8/21/2013.
The North Carolina Department of Transportation (NCDOT) has submitted for review a Finding of
No Significant Impact (FONSI) document for the subject project. Staff biologists with the North
Carolina Wildlife Resources Commission (NCWRC) have reviewed the information provided.
These comments are provided in accordance with the provisions of the National Environmental
Policy Act (42 U.S.C. 4332(2)(c)), the Fish and Wildlife Coordination Act (48 Stat. 401, as
amended; 16 U.S.C. 661-667d), and the Clean Water Act of 1977 (33 U.S.C. 466 et seq.).
The NCWRC submitted scoping comments, dated 5/26/2006, and has participated in the Merger
process for this project. We have reviewed the FONSI document, including comments received at
the public hearings, and have a number of concerns. Many citizens' comments reflected those we
submitted in our scoping letter. Many were concerned about the water quality, trout streams, and
wildlife in the project area. A common theme among commenters was that the project scope was too
large for the needs of the area.
High quality natural resources currently occur throughout the project area. Nearly all streams in the
project area are classified as trout waters by NCDWQ, except the South Fork of the New River
(SFNR), which is Class WS-V, High Quality Waters (HQW). Most of the streams also have the "+"
designation, indicating important resources downstream that should be protected. At least two of the
streams are also classified as Outstanding Resource Waters (ORW). A number of State and
Federally listed aquatic species occur in the SFNR and the State Threatened bog turtle is known to
inhabit wetlands along the project.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh NC 27699-1721
Telephone: [phone] • Fax: [phone]

R-2915, US 221
Watauga and Ashe Counties Page 2 August 21,.2013
Like many of the local residents who sent in comments, we expressed concerns with the scope of the
project in our aforementioned scoping letter. The crash data in the October 2012 Environmental
Assessment (EA) were based on 2004 to 2007 accident reports, and the traffic forecasts used 2007 as
the current conditions and compared them to the design year 2035. We are concerned that these data
and forecasts might be using figures prior to the 2008 economic crisis and may not accurately reflect
current and future traffic levels, which are the basis for determining the project's scope. We
recommend an investigation to determine whether a general widening of the existing two lanes and
shoulders, plus specific safety improvements at key intersections, and possibly some passing lanes,
would meet the purpose and need of the project with considerably less impacts and cost.
The direct impacts proposed for this project appear quite high, over 20,000 linear feet of streams, 3.7
acres of wetlands, 70 residential relocations and 33 business relocations. We question the adequacy
of an EA/FONSI analysis to address such impacts with potentially far reaching effects. Additional
studies are needed. For example, one of the most frequent types of crashes involved collisions with
animals. Going from two lanes to four lanes with a median would greatly increase the distance an
animal has to go to cross the road and may result in more accidents of this type. More information is
needed to ensure safety with this design.
The indirect and cumulative impacts were not adequately addressed in the EA or FONSI. A sixteen
mile stretch of a two-lane road converted to a four -lane median -divided facility is likely to induce
significant development. A more in-depth analysis of indirect and cumulative effects is warranted,
especially considering the high quality and sensitive resources surrounding the project that will be
impacted. Protective measures should be in place to prevent degradation of these resources by
secondary development prior to any construction.
Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at [phone].
cc: Marella Buncick, ['SEWS
Loretta Beckwith, USACE
Christopher Militscher, USEPA
Amy Euliss, NCDWQ

inaccuracies require that qualified personnel perform onsite wetland delineations prior to permit
approval.
24. 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.
25. 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.
26. Riparian vegetation (native trees and shrubs) shall be preserved to the maximum extent possible.
Riparian vegetation must be reestablished within the construction limits of the project by the end of
the growing season following completion of construction.
NCDWQ appreciates the opportunity to provide comments on your project. Shall you have any questions
or require any additional information, please contact Amy Euliss at [phone].
cc: Monte Matthews, US Army Corps of Engineers, Raleigh Field Office (electronic copy only)
Mitch Batuzich, Federal Highway Administration (electronic copy only)
Chris Militscher, Environmental Protection Agency (electronic copy only)
Marella Buncick, US Fish and Wildlife Service (electronic copy only)
Marla Chambers, NC Wildlife Resources Commission (electronic copy only)
Transportation Permitting Unit
File Copy

FW Fw R-2915 Widening of US 221 in the Deep Gap Area.txt
Subject:FW: Fw: R-2915 Widening of US 221 in the Deep Gap Area
-----Original Message-----
From: [e-mail] [mailto:[e-mail]]
Sent: Wednesday, January 07, 2009 11:39 AM
To: [e-mail]
Cc: Vick, Franklin; [e-mail]
Subject: Re: Fw: R-2915 Widening of US 221 in the Deep Gap Area
Thanks Gary. Please take the lead in working w/ NCDOT on this.
Phil

From: Gary W Johnson
Sent: 12/16/2008 10:00
To: Phil Francis
Cc: [e-mail],[e-mail]
Subject Re: Fw: R-2915 Widening of US 221 in the Deep Gap Area(Document link:
Phil Francis)
Phil,
I have reviewed the attached power point slides provided to us by Mr. Qubain
as well as checking areial photography and our vista inventory. The
improvement of US 221 in the Deep Gap area where it intersects with US 441
will have a minor impact on the Parkway's viewshed. The Parkway motor road
follows a long sweeping curved alignment where it is closest to US 221.
This alignment would focus both north and southbound vehicle occupants'
attention towards US 221 if there were roadside vista cuts on the outside of
the curving alignment, but there are not. After this curve the motor road
heading north moves away from US 221 where the Parkway is running
perpendicular to US 221 for about 3/4 of a mile and then the motor road runs
more or less parallel to US 221 for about a mile and the two roadways are
about 1 1/4 miles apart from each other. While there are roadside vistas along
parkway right the impacts of improving US 221 would be some 1
1/4 miles in the distance. The improvement of US 221 with associated widening
of right-of-way with additional lanes will increase its footprint and thus
make it more visible but this, I would think will only have minor to moderate
impacts on the Parkway views. Again the distance helps diminish the visual
impact. The improvement of roads is usually followed by changes in land use so
this may have more of an affect on the visual quality of the Parkway views
than the road itself depending upon the scale of land use changes in the
future.
Based upon the information provided, US 221 is being improved along relative
flat rolling terrain, rather than on a mountain side, so the visibility of new
cut and fill slopes should be minimal.
My conclusion is that the improvement of US 221 may have minor impacts on
Parkway views, while future land use changes facilitated by the road
improvement may have moderate affect on visual quality of the Parkway views.
I believe the above short analysis should provide NCDOT and Parsons with an
understanding of our impact finding. If they would like some additional
thoughts from us, I am happy to provide that for them. I have no mitigations
to offer that would reduce the minor impacts that may result from this
improvement project.
I have taken the liberty to copy Mr. Quabain and Mr. Vick on this email to
facilitate our response given the noncontroversial nature of our response and
Page 1
FW Fw R-2915 Widening of US 221 in the Deep Gap Area.txt
minimal concern over this project.
Let me know what else you may need.
Thanks,
Gary
Gary W. Johnson
Chief RPPS Division
Blue Ridge Parkway
199 Hemphill Knob Road
Asheville, NC 28803
Phone: [phone] ext. 210
Fax: [phone]
Page 2
1
Robbins, Ed
From:Robbins, Ed
Sent:Tuesday, April 16, 2013 1:00 PM
To:'[e-mail]'
Subject:US 221 Widening in NC: Archaeological Survey
Attachments:R-2915 Archaeological Survey.pdf; R-2915 Archaeological Survey Townsend.doc
Dear Mr. Townsend:

The NCDOT and FHWA propose to widen US 221 to a four-lane, median-divided facility from US 421 in the Deep Gap
Community of Watauga County to the US 221 Business/NC 88 intersection in the town of Jefferson in Ashe County, North
Carolina. The project is approximately 16.1 miles in length

Please find attached a copy of the revised archaeological report describing the results of the archaeological survey for the
proposed improvements.

If you have any comment or concerns about this project, please contact me at [phone], or by email at
[e-mail].

If you have no comments or concerns, a quick email stating so would be appreciated.

Sincerely,
Ed Robbins, P.E.

 5540 Centerview Drive, Suite 217
Raleigh, NC 27606
T: [phone]
C: [phone]
F: [phone]
[e-mail]
www.Parsons.com 

Parsons
5540 Centerview Drive  Suite 217  Raleigh, North Carolina 27606  [phone]  www.parsons.com

April 16, 2013

Mr. Russell Townsend
Tribal Historic Preservation Officer
Eastern Band of Cherokee Indians
PO Box 455
Cherokee, NC 28719

RE: US 221 ENVIRONMENTAL STUDY, T.I.P. I.D. NO. R-2915
Archaeological Survey

Dear Mr. Townsend:

The NCDOT and FHWA propose to widen US 221 to a four-lane, median-divided facility
from US 421 in the Deep Gap Community of Watauga County to the US 221
Business/NC 88 intersection in the town of Jefferson in Ashe County, North Carolina.
The project is approximately 16.1 miles in length

Please find attached a copy of the revised archaeological report describing the results
of the archaeological survey for the proposed improvements.

If you have any comment or concerns about this project, please contact me at (919)
854-1347, or by email at [e-mail].

If you have no comments or concerns, a quick email stating so would be appreciated.

Sincerely,

PARSONS TRANSPORTATION GROUP, INC.

Ed Robbins, PE
Project Manager

Attachments (1)
1
Robbins, Ed
From:Lisa LaRue-Baker - UKB THPO [[e-mail]]
Sent:Friday, April 19, 2013 11:50 AM
To:Robbins, Ed
Cc:[e-mail]
Subject:Re: US 221 Widening in NC: Archaeological Survey
The United Keetoowah Band of Cherokee Indians in Oklahoma has reviewed your project under Section 106 of
the NHPA and at this time, have no comments or objections. However, should there be any inadvertent
discovery of human remains, please cease all work and contact us immediately.

Lisa C. Baker
Acting THPO
United Keetoowah Band of Cherokee Indians in Oklahoma
PO Box 746
Tahlequah, OK 74465

c 918.822.1952
[e-mail]

Please FOLLOW our historic preservation page and LIKE us on FACEBOOK

--- On Tue, 4/16/13, Robbins, Ed <[e-mail]> wrote:

From: Robbins, Ed <[e-mail]>
Subject: US 221 Widening in NC: Archaeological Survey
To: "[e-mail]" <[e-mail]>
Date: Tuesday, April 16, 2013, 11:56 AM
Dear Ms. LaRue-Baker:

The NCDOT and FHWA propose to widen US 221 to a four-lane, median-divided facility from US 421 in the Deep Gap Community
of Watauga County to the US 221 Business/NC 88 intersection in the town of Jefferson in Ashe County, North Carolina. The project
is approximately 16.1 miles in length

Please find attached a copy of the revised archaeological report describing the results of the archaeological survey for the proposed
improvements.

If you have any comment or concerns about this project, please contact me at [phone], or by email at
[e-mail].
2

If you have no comments or concerns, a quick email stating so would be appreciated.

Sincerely,

Ed Robbins, P.E.

5540 Centerview Drive, Suite 217
Raleigh, NC 27606
T: [phone]
C: [phone]
F: [phone]
[e-mail]
www.Parsons.com

Appendix C

Concurrence Forms

SECTION 404 / NEPA MERGER PROCESS CONC
NCE AGREEMENT
CONCURRENCE POINT 1: Purpose and Need and Study Area Defined
US 221 from US 421 to NC 88 / US 221 Business, Watauga and Ashe Counties
NCDOT TIP Project No.: R-2915
TIP Description: The North Carolina Department of Transportation proposes to widen US 221 to a multi -lane
facility, from US 421 near Deep Gap to NC 88 / US 221 Business in Jefferson. The proposed action involves
approximately 16.1 miles of existing US 221 with a majority of the roadway located in Ashe County and just over
a mile located in Watauga County.
Purpose and Need: The purpose of this project is to upgrade the existing roadway to a multi -lane facility, so as to
increase capacity, alleviate congestion, improve traffic operations and reduce traffic accidents,. The needs to be
address by this project include:
Improve Traffic Flow for Highway system
® Existing US 221 currently experiences capacity deficiency and operates at levels of service D. E and F.
Additional Considerations
Above Average Crash Rates
® Existing crash rates and accident severity are relatively high along portions of the project and will likely
worsen if no improvements are made.
The Merger Team met on January 22, 2008 and concurs with the Purpose and Need/ Study Area Defined for
the proposed widening improvements of US 221 to a multi -lane facility in Watauga and Ashe Counties. The
Study Area Defined is as shown in Exhibit 3 of the meeting handout, with the clarification that the View Shed
for the Blue Ridge Parkway and the Mount Jefferson State Park is considered as part of the study area.
FHWA Ja4. NCDOT
Jake Riggsbeey - '' Date
USACE
USEP
Chris Militscher
USFW
me Matthews
elia Buncick
Date
/(2z(c:3P__)
—bate
Date
NCDWQ
SHPO
Joseph Qubain
Renee Gledhill- Early
NCWRC -P7c�
Marla Chambers
Date
V2z/ ,
Date

SECTION 404 / NEPA MERGER PROCESS CONCURRENCE AGREEMENT
CONCURRENCE POINT 2: Design Options for Detailed Study
US 221 from US 421 to NC 88 / US 221 Business, Watauga and Ashe Counties
NCDOT TIP Project No.: R-2915
TIP Description: The North Carolina Department of Transportation proposes to widen US 221 to a multi -lane
facility, from US 421 near Deep Gap to NC 88 / US 221 Business in Jefferson. The proposed action involves
approximately 16.1 miles of existing US 221 with a majority of the roadway located in Ashe County and just over
a mile located in Watauga County.
Alternatives to Study in Detail: / / >
Best -fit widening C�Or,SeGlyiait / 3 f 741,'�'�1 ety��vf° A'� �s ❑ No
Typical Section 1 _Four -lane divided with 23-foot raised�median an shou er ,e ® Yes 0 No
STA. 10 + 00 TO STA. 670 + 00 dBR'� 4'anf, 4e/1 t E ►�f ec
o� rearm
Typical Section 2:Four-lane divided with 36-foot depresse ern.and shoulder Yes 0 No
STA. 670 + 00 TO STA. 825 + 00
Typical Section 3:Project Tie -In Five -lane divided (one left lane) with shoulder /Yes 0 No
STA. 825 + 00 TO STA. 845 + 00
The Merger Team met on December 16, 2008 and concurs with the alternatives to be carried
forward for the proposed project as indicated above.
FHWA
USACEo-• _^,_--
USE e A l - 1
USFWS �i�- "' Gt 6
1.
NCDOT
NCDWQ .!'"' t
SHPO �}1141/
•QQ
NCWRC �Uln

SECTION 404 / NEPA MERGER PROCESS CONCURRENCE AGREEMENT
CONCURRENCE POINT 2a Bridge Decisions
US 221 from US 421 to NC 88 / US 221 Business, Watauga and Asite Counties
NCDOT TIP Project No.: R-2915
TIP Description: The North Carolina Department of Transportation proposes to widen US 221 to a multi -hole
facility, from US 421 near Deep Gap to NC 88 / US 221 Business in Jefferson. The proposed action involves
approximately 16.1 miles of existing US 221 with. a majority of the roadway located in Ashe County and just
over a mile located in Watauga County.
Bridging Decisions:. The Merger Process Team met on April 12, 2012 and May 24, 2012 to discuss the
preliminary hydraulics design for the existing major drainage structures along the "Best Fit" Alternative for R-
2915. Based upon the current preliminary design information, the Merger Team concurs with proposed box -
culvert and bridging decisions for the US 221 widening improvements, as presented in the Concurrence Point
2a meeting. The major crossings arc listed below:
Site
No.
Proposed Hydraulic
Structure(Additional Length)
Site
No.
Proposed Hydraulic Structure
(Additional Length)
1
New 3(d) 8' x 8' RCBC (135 ft)
10
New Dual Structures
I B
New • l(a? l2' x 8' RCBC (304ft)
11.
Extend IC 4' x 5' RCBC (120 ft)
2
Extend 10)6' x 4' RCBC (67 ft)
12
Extend I @ 7' x 8' RCBC (185 ft)
3
Extend 2 a% 9' x 5' RCBC (79 ft)
13
New Bottomless Culvert (282 ft)
4
Extend 2 - 42" RCP(70 ft)
14
Extend L - 84" CMP (8 ft)
5
Extend 2 - 42" RCP (12 ft)
16
Extend 2 - 84" CMP (80 ft)
6
New-1@6' x 4' RCBC (64 ft)
17
Extend 3 @ 10' x 8' RCBC (65 ft)
7
New Culvert (249 ft)
18
Extend 2 - 60" CMP (55 ft)
8
New Bridge (130 ft)
9
Retain, Add New Structure
The Merger Process Teant met on March 13, 2013 and concurs with the proposed hydraulic structures
associated with the improvements of US 221 to a four -lane median divided facility in Watauga and
Ashe Counties
FHWA t%AA-ctvt.d. 0 l
Michael Batuzic}LJ
USACE
Date
Montd Matthews Date
USE1C„/` A -
Christopher Militscher
USFW
I-ligh
Country
RPO j t✓ .*Y
David Graham
Date
6- 0453' NCWRC
IJia�lta Buncick Dat
Dale
3-'!3// 7
P)/,p
Renee Gledhill -Early D
Marla Chambers / Dhte

US 221
SECTION 404 / NEPA MERGER PROCESS CONCURRENCE AGREEMENT
CONCURRENCE POINT 3: LEDPA SELECTION
US 221 front US 421 to NC 88I US 221 Business, Watauga and Ashe Counties
NCDOT TIP Project No.: R-2915
TIP Description: The North Carolina Department of Transportation proposes to widen
US 221 to a multi -lane facility, from US 421 near Deep Gap to NC 88 / US 221 Business in
Jefferson. The proposed action involves approximately 16.1 miles of existing US 221 with a
majority of the roadway located in Ashe County and just over a mile located in Watauga
County.
LEDPA Selection: Widen existing US 221 using the Best Fit Alternative
The Merger Process Team met on March 13, 2013 and concurs with the proposed Best
Fit Alternative associated with the improvements of US 221 to a four -lane median
divided facility in Watauga and Ashe Counties.
FHWA LILuzi t y�I ,'4 —!:3 ...�; NCDO1
Michael Uatuzich.T Date
I1SAC
i
E NCDWQ J•�n�j 11.1✓.:.-.-,^.,
Monte i atthews Date Amy Ea ass
4SE1 2--C-112I NCDCR
Christopher Militscher Date
usrws
Ma ells t Date
High
Country /
David Graham
Date
Renee Gledhill -Early
NCWRC 00D "c
Marla Chambers
e
-13

US 221
SECTION 404 / NEPA MERGER PROCESS CONCURRENCE AGREEMENT
CONCURRENCE POINT 4A,: AVOIDANCE AND MINIMIZATION
US 221 from US 421 to NC 88 / US 221 Business, Watauga and Ashe Counties
NCDOT TIP Project No,: R-2915
TIP Description: The North Carolina Department of Transportation proposes to widen
US 221 to a multi -lane facility, from US 421 near Deep Gap to NC 88 / US 221 Business in
Jefferson. The proposed action involves approximately 16.1 miles of existing US 221 with a
majority of the roadway located in Ashe County and just over a mile located in Watauga
County.
The Merger Process Team met on March 13, 2013 and concurs with the following
Avoidance and Minimization measures for the LEDPA (best fit alignment) of the US
221 widening Project:
Section 404 Avoidance Minimization:
Various measures were employed to avoid and minimize the impacts to streams and
wetlands utilizing thebest fit alignment as well. Streams were crossed perpendicularly
and/or at their narrowest points, as feasible. Design modifications have been made at several
points in the study to avoid/minimize stream and wetlands involvement. Several potential
stream and wetland avoidance/minimization opportunities were identified during the
Concurrence Point #2A meetings held with resource agencies in April and May, 2012. Two
different interchange designs were originally studied with the current interchange design
(interchange 1) being preferred by the .merger team. Interchange 1 was preferred due to
interchange 2 impacts to a pristine ecosystem previously not impacted. Interchange 1
stream impacts were previously impacted in the widening of US 421.
A new bridge is proposed at Site 8, duaI structures are proposed at Site 10, and a new bottomless
culvert is proposed at Site 13.
Minimize LEDPA impacts further based on 25' slope stakes or less.
Site 1 will allow for appropriately sized barrels to accommodate the entire stream through one barrel,
including alternating baffles for fish passage.
In the vicinity of Site I; efforts will be nia.de to re-establish a riparian buffer to shade trout streams as
much as possible.
Design. of US 421 was changed to inside widening to avoid mitigation site.

Additional minimization:
Design of sediment and erosion control measures wilt adhere to Design Standards for Sensitive
Watersheds.
A retaining wall is proposed along Gap Creek Cemetery to minimize impacts to grave sites.
The SI-IPO rendered the following decision regarding the Best Fit Alternative for the
Baldwin Bethany Cetetery and the Barnett Idol Flouse : No Effect for both properties, since
there will be no construction within the historic boundary and no changes to elements that
make it eligible.
The Merger Process Team met on March 13, 2013 and concurs with avoidance and
minimization measures as stated above:
FHWA l tt u l '- i.
Michael Batuzicti-r
USAGE (Z11�
Mont Matthews Date
--' 1)51 13 NCDCR
Christopher Militscher Date
USFWS
High
Country
RPO G,�- 'T 'he-...,., .97/7jj
David Graham Date
PQ�O q'/13
Renee Gledhill -Early Date
es _ Q_-- s - Yet/3NCWRC !' 4L
Mare la Buhcick Date Marla Chambers
'Jri3/t3
Date ,2�

Appendix D

Noise Abatement Review Study
Archaeological Consultation Letters
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
BEVERLY EAVES PERDUE EUGENE A. CONTI, JR.
GOVERNOR September 10, 2012 SECRETARY
MEMORANDUM TO: Mitch Batuzich, P.E.
FHWA Area Engineer
FROM:
SUBJECT:
Joseph A. Rauseo
Senior Traffic Noise Engineer
Traffic Noise & Air Quality Group
Noise Abatement Review
US 221 Widening — Watauga and Ashe Counties;
F.A. Proj. # STP-0221(13); WBS # 34518.1.1;
TIP # R-2915
The NCDOT Traffic Noise Abatement Policy effective July 13, 2011 stipulates that
"Projects let for construction on or after July 13, 2011 shall be reviewed under the criteria
of this policy..." To maintain compliance with the effective policy, the Traffic Noise &
Air Quality Group reviewed the Traffic Noise Analysis (TNA) dated September 6, 2000
for the subject project, and has the following comments:
1. The TNA determination that traffic noise abatement is not feasible was based
upon preliminary design available at the time of the initial analysis.
2. Based upon present project design and the effective policy, traffic noise abatement
will be feasible and reasonable for the predicted traffic noise impacts on Crescent
Drive, as well as for Long Street and Cherry Drive.
Our recommendation is that two noise walls, NW1 and NW2, be added to the US 221
Widening Project (TIP #: R-2915) in the vicinity of Crescent Drive and Long
Street/Cherry Drive, respectively.
MAILING ADDRESS: TELEPHONE: [phone]
NC DEPARTMENT OF TRANSPORTATION FAX: [phone]
HUMAN ENVIRONMENT SECTION
1598 MAIL SERVICE CENTER
RALEIGH NC, 27699-1598
WEBSITE: WWW. NCDOT.ORG
LOCATION:
PROJECT DEVELOPMENT &
ENVIRONMENTAL ANALYSIS BRANCH -
CENTURY CENTER BUILDING B
1020 BIRCH RIDGE DRIVE
RALEIGH NC, 27610

Noise Abatement Review – US 221 Widening – TIP #: R-2915
2
Noise Wall NW1

Noise wall “NW1” is recommended to be 806 feet in length, and 9,249 square feet in
above-ground area. NW1 is recommended to be an average of 11.5 feet in height, ranging
between 6.0 feet and 16.0 feet as necessary to meet the acoustic profile.

The recommended noise wall NW1 will provide at least a 7 dB(A) noise level reduction to
4 first-row receptors, and at least a 5 dB(A) noise level reduction benefit to a total of 10
noise sensitive receptors. The 925 square feet average noise wall area per benefited
receptor is less than the maximum allowable 2,710 square feet.

Table 1: US 221 Widening Project Noise Barrier NW1 Performance
Without-Barrier and With-Barrier Noise Levels
Receptors Predicted Noise Levels,
Leq(h) (dB(A))
ID# Use NAC D.U.s Address Build1 With-
Bar NLR
R-044 Res B 1 242 Crescent Drive 58 58 0
R-045 Res B 1 310 Crescent Drive 57 55 2
R-046 Res B 1 320 Crescent Drive 62 58 4
R-047 Res B 1 279 Crescent Drive 51 50 0
R-048 Res B 1 211 Crescent Drive 52 50 1
R-049 Res B 1 311B Crescent Drive 54 53 1
R-050 Res B 1 311A Crescent Drive 55 51 4
R-051 Res B 1 320 Crescent Drive 56 52 4
R-052 Res B 1 329 Crescent Drive 58 52 6
R-053 Res B 1 351 Crescent Drive 60 53 7
R-054 Res B 1 357 Crescent Drive 62 54 8
R-055 Res B 1 361 Crescent Drive 64 55 9
R-056 Res B 1 387 Crescent Drive 66 56 10
R-057 Res B 1 421 Crescent Drive 68 56 12
R-058 Res B 1 341 Crescent Drive 60 53 7
R-059 Res B 1 387A Crescent Drive 71 58 13
R-060 Res B 1 455 Crescent Drive 70 61 9
R-061 Res B 1 433 Crescent Drive 62 57 5
Predicted “Build-Condition” With-Barrier Benefits:2 102,3
1. Predicted traffic noise level impacts to 4 receptors due to approaching or exceeding
NAC. Predicted impacts to 0 receptors are due to a predicted “substantial increase” in
noise levels.
2. The optimized US 221 noise barrier -NW1- is predicted to provide at least 5 decibels (5
dB(A)) in noise level reduction (NLR) to 10 receptors.
3. The predicted NLR for several benefited receptors is greater than 7 dB(A) to facilitate
breaking line-of-sight between impacted receptors and US 221 traffic.

Noise Abatement Review – US 221 Widening Project – TIP #: R-2915

3
Table 2: US 221 Widening Project Noise Barrier NW1 (TIP #: R-2915) – Noise Wall Analysis
Noise
Wall Start End Length
(ft.)
Area
(sq. ft.)
Height (ft.)
(Min. / Avg. / Max.)
NW11
-NW1- Sta. 10+00.00 -NW1- Sta. 18+06.04
806 9,249 6.0 11.5 16.0 -L- Sta. 681+11.47
100.57’ LT
-L- Sta. 689+31.80
90.54’LT
1. The newly recommended traffic noise abatement noise wall design meets the feasibility and
reasonableness criteria of the 2011 NCDOT Traffic Noise Abatement Policy.

Noise Wall NW2

Noise wall “NW2” is recommended to be 2,430 feet in length, and 30,230 square feet in above-
ground area. NW2 is recommended to be an average of 12.4 feet in height, ranging between 8.0 feet
and 14.1 feet as necessary to meet the acoustic profile.

The recommended noise wall NW2 will provide at least a 7 dB(A) noise level reduction to 2 first-row
receptors, and at least a 5 dB(A) noise level reduction benefit to a total of 12 noise sensitive
receptors. The 2,519 square feet average noise wall area per benefited receptor is less than the
maximum allowable 2,570 square feet.

Table 3: US 221 Widening Project Noise Barrier NW2 Performance
Without-Barrier and With-Barrier Noise Levels
Receptors Predicted Noise Levels, Leq(h)
(dB(A))
ID# Use NAC D.U.s Address Build1 With-
Bar NLR
R-062 Res B 1 327 Long Street 68 61 7
R-063 Res B 1 341 Long Street 67 61 6
R-064 Res B 1 401 Long Street 67 62 5
R-065 Res B 1 409 Long Street 66 61 5
R-066 Res B 1 417 Long Street 65 60 5
R-067 Res B 1 433 Long Street 62 57 5
R-068 Res B 1 114 Cherry Drive 62 57 5
R-069 Res B 1 314 Long Street 65 62 3
R-070 Res B 1 342 Long Street 63 60 3
R-071 Res B 1 406 Long Street 61 59 2

Noise Abatement Review – US 221 Widening – TIP #: R-2915
4
Table 3: US 221 Widening Project Noise Barrier NW2 Performance
Without-Barrier and With-Barrier Noise Levels
Receptors Predicted Noise Levels, Leq(h)
(dB(A))
ID# Use NAC D.U.s Address Build1 With-
Bar NLR
R-072 Res B 1 418 Long Street 61 58 3
R-073 Res B 1 430 Long Street 59 56 3
R-074 Res B 1 101 Stone Street 62 59 3
R-075 Res B 1 105 Cherry Drive 62 56 6
R-076 Res B 1 125 Cherry Drive 60 54 6
R-077 Res B 1 135 Cherry Drive 59 54 5
R-078 Res B 1 224 Cherry Drive 68 58 10
R-079 Res B 1 110 Oak Grove Circle 60 55 5
R-080 Res B 1 314 Cherry Drive 64 62 2
Predicted “Build-Condition” With-Barrier Benefits:2 122
1. Predicted traffic noise level impacts to 4 receptors due to approaching or exceeding NAC.
Predicted impacts to 0 receptors are due to a predicted “substantial increase” in noise levels.
2. The optimized US 221 noise barrier -NW2- is predicted to provide at least 5 decibels (5 dB(A))
in noise level reduction (NLR) to 12 receptors.

Table 4: US 221 Widening Project Noise Barrier NW2 (TIP #: R-2915) – Noise Wall Analysis
Noise
Wall Start End Length
(ft.)
Area
(sq. ft.)
Height (ft.)
(Min. / Avg. / Max.)
NW21
-NW2- Sta. 10+00.00 -NW2- Sta. 34+29.70
2,430 30,230 8.0 12.4 14.1 -L- Sta. 818+67.58
84.53’ RT
-L- Sta. 842+99.09
60.37’ RT
1. The newly recommended traffic noise abatement noise wall design meets the feasibility and
reasonableness criteria of the 2011 NCDOT Traffic Noise Abatement Policy.

Please contact me if additional information is required in this matter.
Traffic Noise Analysis R-2915/ US 221
NCDOT – September 2012

Watauga/Ashe Counties

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2
Michael F. Easley, Governor
Lisbeth C. Evans, Secretary
Jeffrey J. Crow, Deputy Secretary
May 24, 2006
MEMORANDUM
TO:
North Carolina Department of Cultural Resources
State Historic Preservation Office
Peter B. Sandbeck, Administrator
Gregory'. Thorpe, Ph.D.
Division of Highways
Department of Transportation
FROM: Peter Sandbeck
Office of Archives and History
Division of Historical Resources
David Brook, Director
SUBJECT: US 221 from US 421 to NC 88 in Jefferson, R-2915, Ashe and Watauga Counties, ER 06-1023
Thank you for your memorandum dated April 7, 2006, concerning the above project.
Several archaeological sites were recorded during an archaeological survey of a portion of the project area.
Additional previously recorded sites are located within or adjacent to the project area. Based on the
topographic and hydrological situation, there is a high probability for the presence of prehistoric or historic
archaeological sites.
We recommend that a comprehensive survey be conducted by an experienced archaeologist to identify and
evaluate the significance of archaeological remains that may be damaged or destroyed by the proposed project.
Potential effects on unknown resources must be assessed prior to the initiation of construction activities.
We have conducted a search of our maps and files and located the following structure of historical or
architectural importance within the general area of this project:
Gentry Worth House, 203 East Main Street, Jefferson, Ashe County, State Study -listed.
West Jefferson Hotel, corner of S. Second Ave. and W. Main St., Jefferson, Ashe County, State Study -listed.
St. Mary's Episcopal Church, US 221 and NC 163, Jefferson, Ashe County, State Study -listed.
Ashe County Courthouse, Main Street, Jefferson, Ashe County, Watauga County, National Register of Historic
Places.
Blue Ridge Parkway, (view shed), Watauga County, determined eligible for the National Regis ter.
Location Mailing Address Telephone/Fax
ADMINISTRATION 507 N. Blount Street, Raleigh NC 4617 Mail Service Center, Raleigh NC 27699-4617 [phone]/733-8653
RESTORATION 515 N. Blount Street, Raleigh NC 4617 Mail Service Ccntcr, Raleigh NC 27699-4617 [phone]/715-4801
SURVEY & PLANNING 515 N. Blount Street, Raleigh, NC 4617 Mail Service Center, Raleigh NC 276994617 [phone]/715-4801

Alfred Jacob Moretz House, Deep Gap, NE side SR 1359, 1.6 miles S of jct. with SR 1367, Watauga County,
surveyed property.
We recommend that a Department of Transportation architectural historian identify and evaluate any
structures over fifty years of age within the project area, and report the findings to us.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
please contact Renee Gledhill -Earley, environmental review coordinator, at 919/733-4763. In all future
communication concerning this project, please cite the above referenced tracking number.
cc: SCH
Mary Pope Furr
Matt Wilkerson

Pat McCrory, Governor
Susan W. Kluttz, Secretary
Kevin Cherry, Deputy Secretary
March 5, 2013
MEMORANDUM
TO:
FROM:
North Carolina Department of Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Matt Wilkerson
Office of Human Environment
NCDOT Division of Highways
Ramona M. Bartos
Office of Archives and History
Division of Historical Resources
David Brook, Director
SUBJECT: Draft Report of the Archaeological Survey of US 221 Improvements,
R-2915, Federal Aid # S 1'P-125(1); Ashe and Watauga Counties, ER 06-1023
Thank you for your letter of January 24, 2013, transmitting the draft archaeological survey report by Michael
O'Neal of Archaeological Consultants of the Carolinas for the above project. We have reviewed the report and
offer the following comments.
For purposes of compliance with Section 106 of the National Historic Preservation Act, we concur that the
following properties are not eligible for the National Register of Historic Places:
31WT300 (revisit), 31WT365&365**, 31WT366, 31WT367**, 31WT368, 31WT369, 31AH276,
31AH277&277**, 31AH278** and 31AH279
None of these archaeological sites retain sufficient integrity to provide important information regarding the
prehistoric or historic past of North Carolina.
We concur with the author's recommendation that no additional archaeological investigation is warranted in
connection with this project as currently proposed. The report meets our office's guidelines and those of the
Secretary of the Interior. Specific concerns and/or corrections which need to be addressed in the preparation
of a final report are attached for the author's use.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
please contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579. In all future
communication concerning this project, please cite the above -referenced tracking number.
cc: Michael O'Neal, Archaeological Consultants of the Carolinas, Inc.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Specific Comments, US 221 Improvements, R-2915, Ashe and Watauga Counties
1. The report needs extensive editing. There are many missing words, typographical errors and sentence
fragments scattered throughout the document.
2. The Tuscarora War did not end in 1712, as the last big battle of the war at Neoheroka did not occur
until March of 1713.
3. In several places in the report during the discussion of corridor width, the document states that the
corridor was primarily 61 meters (200 feet) wide, but in some places it was 91 meters (200 feet) wide.

Appendix E

Public Hearing Map Comments
US Army Corps of Engineers Public Comments & Correspondence
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
PAT MCCRORY ANTHONY J. TATA
GOVERNOR SECRETARY
MEMO TO: Post Hearing Meeting Attendees _.K""
FROM: Jay A. Bennett, PE
State Roadway Desi
DATE: May 14, 2013
SUBJECT: Project: 34518.1.1 (R-2915) Watauga / Ashe Counties
US 221 from US 421 in Watauga County to US 221 Business / NC 88 in Jefferson
in Ashe County
Post Hearing Meeting Minutes
A design public hearing was held on December 4, 2012 at Ashe County High School for the
subject project. Approximately 160 people were in attendance. Thirty written comments were
received. The following people met on February 26, 2013 to discuss these comments:
Mr. Jay Bennett, PE, NCDOT, Roadway Design
Mr. Greg Sealy, NCDOT, Utilities Unit
Mrs. Susan Lancaster, PE, NCDOT, Roadway Design
Mr. Glenn Mumford, PE, NCDOT, Roadway Design
Mr. Doug Taylor, PE, NCDOT, Roadway Design
Mr. Gary Lovering, PE, NCDOT, Roadway Design
Ms. Brenda Moore, PE, NCDOT, Roadway Design
Ms. Tatia White, PE, PLS, NCDOT, Roadway Design
Ms. Elise Groundwater, NCDOT, Congestion Management
Mr. John Conforti, NCDOT, PD&EA
Mr. Michael Wray, NCDOT, PD&EA
Mr. Tris Ford, NCDOT, Public Involvement and Community Studies
Mr. Marshall Clawson, PE, NCDOT, Hydraulics Unit
Mr. Jamille Robbins, NCDOT, Public Involvement and Com. Studies
Mr. Trent Beaver, PE, NCDOT, Division 11 Construction (via telephone)
Mr. Tim Goins, PE,,Earsons Transportation Group
Mr. Ed Robbins, PE, Parsons Transportation Group
Ms. Kristin Webb, NCDOT, PD&EA

R-2915
May 14, 2013
Page 2
Executive Summary
The NCDOT preferred typical section for US 221from US 421to NC 194 (South Jefferson
Avenue) is a 4 lane divided highway with a 23' raised median with grassed shoulders. From
South Jefferson Avenue to approximately 0.5 mile north of SR 1149 (Mount Jefferson Road)
along US 221, the NCDOT preferred typical section is a 4 lane divided highway with 36'
depressed median with grassed shoulders. The remainder of the project will propose a 4 lane
highway separated by a monolithic concrete island with grassed shoulders. Directional
crossovers with median u-turns will be implemented throughout the project corridor.
The written comments received were centered around bypassing the existing alignment, traffic
management, alignment and grade concerns, aesthetics, right of way, and access. These
comments were discussed and are summarized below:
Written Comments and Responses
A. Bypass
1. Jerry Styers
Mr. Styers prefers a bypass a mile to the east or west while leaving the existing road for local
traffic only.
Response: The additional cost of a bypass instead of widening existing US 221 would be
prohibitive. The current design utilizes the existing 2 lanes and adds the additional lanes left or
right as well as utilizing right of way that NCDOT currently owns for approximately half of the
project. To construct a bypass, right of way will have to be purchased for all lanes as well as
having to do grading, paving, etc. for the entire length of project. This approach would create
additional impacts to wetlands and streams that are currently not impacted.
B. Traffic Management
1. Charles and Ellen Vitale
Mr. and Mrs. Vitale travel on West Pine Swamp Road to access US 221. They are concerned
about unsafe detours they will need to navigate during project construction. They are also
concerned about EMS response times being delayed. They are in agreement that the road will be
safer post construction.
Response: Generally traffic will be maintained on 2 lanes while the 2 new lanes are constructed.
Final locations of the detours will be developed in the Traffic Management Plan prior to
construction beginning. The Trafiid-Management Plan will take into consideration all possible
safety considerations for both the construction crews and local citizens in order to inconvenience
the travelling public as little as possible. Minutes of this meeting will be forwarded to the Traffic
Management Unit.

R-2915
May 14, 2013
Page 3
C. Alignment and Grade
1. Roger Newton
Mr. Newton states the curve at Grover Goodman's property needs to be corrected and made a 4
lane highway. (Located around station—L- 270+00 R-2915C)
Response: The final alignment and grade will be designed to accommodate a 60 mph design
speed. Widening to 4 lanes will also help with sight distance.
2. Mr. James Trivette
Mr. Trivette is concerned about the sharp horizontal curves and steep grades on Lemly Hill Road.
Response: Lemly Hill Road will be tied into US 221 using NCDOT standard tie in practices.
Locations along Lemly Hill Road outside of the tie in area are outside the project scope and will
not be corrected under this project. Funding for this project is specifically set aside for the
widening of US 221 and reconnection of intersecting roads.
3. Mrs. Martha Kincaid
Mrs. Kincaid is concerned about the sharp horizontal curves and steep grades on US 221 between
Windy Hill Road and Liberty Grove Road.
Response: US 221 will be designed to accommodate a 55 mph posted speed where possible.
Both the horizontal curves and grades will be designed for safe travel at this design speed for the
entire length of the project corridor. Clearing will be done to accommodate the new 4 lane
highway and will provide greater sight distance throughout the project.
D. Aesthetics
1. Watauga County Planning Board Deep Gap Gateway Corridor Committee
The Deep Gap Gateway Corridor Committee would prefer context sensitive design solutions in
the Deep Gap area specifically in the US 421 / US 221 interchange area. They request matching
the aesthetics to the Blue Ridge Parkway, evergreen plantings adjacent to the right of way for
screening purposes, and reflective markings due to being a heavy fog area. Because of the views
of the valley, woodlands, and mountains, they request special attention be given to all signs, sign
structures, and lighting so as not to disturb the natural setting.
Response: NCDOT will take into consideration context sensitive design solutions during final
design but may not be able to incorporate all of the requests without a cost sharing partnership
with the requesting party. Both the pavement markings and signing requests will be considered
during final design. Additional landscaping will also be considered but may require a cost share
partnership to fully implement. Additional coordination with Watauga County will be required
during final design.

R-2915
May 14, 2013
Page 4
E. Right of Wav
1. Avi Shaki
Mr. Shaki inquired about NCDOT's process to offer current fair market value or potential market
value for his property. (interchange r/w area)
Response: NCDOT policy is to offer fair market value based on current appraisals for the
property needed to build the project. Right of Way acquisition is scheduled to begin in July
2013. It will take approximately two years to complete the purchase of the right of way needed
for the entire project. The right of way schedule is subject to change.
Mr. Shaki also inquired about the reason the interchange was placed on the west side of US 421.
The previous design was an at grade intersection instead of an interchange.
Response: The interchange shown is based on minimizing environmental impacts in this area.
The at grade intersection was changed to a free flow interchange due to the concern for fog
limiting the ability of drivers to see a traffic signal. A free flow interchange which separates the
traffic conflicts will greatly reduce future accidents in this area.
Mr. Shaki inquired about access across the creek to US 421 on his property.
Response: NCDOT must provide new access to a parcel if existing access will be cut off due to
proposed construction or pay for loss of access. However, if there is not currently access across
the creek, the property owner will be responsible for his own access across the creek. The access
from the existing service road to US 421 will remain open. Exact location of the driveway tie
will be considered during the right of way stage.
2. Archie and Nancy Pierce
Mr. and Mrs. Pierce are in favor of the project and would like to be considered for acquisition as
soon as possible due to their age. They also are requesting help with relocation. Their home is
inside of the proposed easement area (parcel 632).
Response: NCDOT will proceed with acquisition of property with relocations near the
beginning of the right of way acquisition stage. There is also an advanced acquisition process for
qualified property owners. Mr. and Mrs. Pierce may feel free to contact Daneil Miles of the
Division 11 Right of Way office at [phone] for more information. R/W acquisition is
scheduled to begin in April 2014 for this area of the project. The right of way schedule is subject
to change.
F. Access
1. Roger Newton
Mr. Newton is requesting a crossover at the intersection of US 221 and River Ridge Rd. (-Y 14-)
Response:
NCDOT does not agree with providing a crossover at the River Ridge intersection due to the
sight limiting terrain around the intersection.

R-2915
May 14, 2013
Page 5
2. William Moretz
Mr. Moretz is concerned about access to Moretz Farm Rd. He owns acreage on both sides of US
221 that he uses for his Christmas tree farm. He is concemed about the u-turn that his equipment
will have to make to reach both sides of his farm. He feels this u-turn will be a hazard and is
requesting a full movement intersection limited for farm equipment.
Response: NCDOT would not be in favor of designing a full movement intersection exclusively
for farm equipment. U-turns will be designed to accommodate appropriate traffic. The
proposed design should make the intersection safer by providing an exclusive turn lane separate
from the north and south bound traffic.
3. Alan Crees
Mr. Crees is the engineer working on behalf of High Country Conunercial property. They are in
the process of developing a commercial subdivision on their property that is located by —SR1- off
US 421. They are requesting the following:
A. Can the proposed service road be relocated to match the alignment on their Master Site
Plan (see Figures 1 & 2)?
Response: It appears the service road could be relocated however the developer needs to
coordinate with the adjacent properties that are provided access by the service road as
well.
B. Canthe r/w along the proposed road be reduced from 60' to 45' so that it has less impact
on the lots?
Response: NCDOT will not commit to the reduction of the r/w until the development
plan is approved.
C. How can they proceed with the subdivision development plan while NCDOT is still in the
design phase?
Response: After coordinating with adjacent property owners regarding the service road
location, the developer is encouraged to submit their plans to NCDOT Division 11,
District 2 office for further review via the driveway permitting process. The District
Engineer for this area is Mr. Ivan Dishman and may be reached at [phone].
4. Jan Welborn
Ms. Welborn owns a trucking company along US 221 (near —L- 15+00 Rt at —SR- 2). The
proposed r/w appears to impact her barn and another building as well. Her home and garage will
not be impacted. She operates semi trucks with 53' trailers that need a drive opening wide
enough to get trucks in and out.
Response: NCDOT does not prp-ppse controlling access along the service road. During final
design, driveway tie-ins will be designed and NCDOT will take this driveway opening into
consideration.

R-2915
May 14,2013
Page 6
5. Martin Lambert
Mr. Lambert's property is located on parcel 3 along -SR- 2. Mr. Lambert is not in favor of the
service road. He states the road will devalue his property and desires direct access to US 421 like
he currently enjoys.
Response: NCDOT is fully controlling access in the interchange area that intersects US 421 and
US 221. Direct access will not be allowed to US 421. It would be unsafe to allow property
owners direct access to the highway in the interchange area. A service road is provided to allow
property owners safer access further away from the interchange area.
6. Gary Stainback
Mr. Stainback lives between -Y14- River Ridge Rd. and -Y15- Windy Hill Rd. (-L- 290+00 Rt.)
He is in favor of the project but would like to know, if another u-turn location could be added
near his home.
Response: Mr. Stainback will have access to US 221 at -L- 253+00 and —L- 313+70. NCDOT
is not in favor of adding an additional crossover because of the terrain in this area.
7. Harold Charles Style, Jr., Harold Charles Style, Lauren Ashley Style, Mr. and Mrs.
Harold E. Steelman, Sr., Harold E. Steelman, Jr. (These properties are located at or near
parcel 5 along -5R2-)
It appears the septic system on parcel 5 would be impacted by the proposed service road and will
require acquisition of this property. Both parcel 2 (James Barry Greene and adjacent property,
James E. and Margaret Greene utilize the same driveway off US 421). They are requesting
NCDOT consider realigning this drive to the left and still maintain the access to US 421. This
would continue to serve both parcels. The service road could then be shortened and the cul-de-
sac moved to the edge of parcel 5 and save this parcel.
Response:
NCDOT is not in favor of realigning the drive because of its close proximity to the northbound
ramp at the interchange. Too many conflicts exist to allow driveway access in this area.
8. James Leonard Greer (parcel 15)
Mr. Greer states that his septic field is within the proposed r/w. Other locations inside his
property have failed to perk in the past. How will NCDOT address this?
Response: If there are no other locations for the septic system to be relocated, NCDOT Trill have
to acquire the property and provide relocation assistance. NCDOT Right of Way will contact
Mr. Greer once the right of way acquisition stage begins (currently scheduled to begin July 2013)
to initiate negotiations.
9. Joseph and Angela Turrisi (parcel 81)
Mr. and Mrs. Turrisi are requesting driveway access across the adjacent Thomas and Patricia
Griggs property onto Idlewild Road: 'They prefer this over the current access directly onto US
221. Regardless of the final driveway access, they are requesting their driveway be paved due to
the inclement weather conditions..
Response: NCDOT policy is to re -tie driveways along their current location where possible.
NCDOT cannot severely impact another parcel to build a new driveway access when a driveway

R-2915
May 14, 2013
Page 7
access currently exists. Driveways will be tied in to the new highway using like material as the
existing driveway. (Existing gravel drives will be gravel, existing soil drives will be soil, etc...)
10. Curtis and Peggy Cheek (-L- 120+00 Lt.)
Mr. and Mrs. Cheek have approximately 29 acres with 250 feet of road frontage on US 221.
They are requesting good access for their property.
Response: This section of US221 will be partially controlled. Generally, one access point will
be allowed per parcel except on very large parcels with road frontage of 2000' or greater. A right
in / right out access will be located somewhere along the road frontage.
11. Lloyd Pickard (-L- 232+00 Lt.)
Mr. Pickard is concerned with the access of Twin Bridges Drive to US 221. He is in favor of the
project and is inquiring about how to go north / south. He is on the board of directors of the
Property Owners Association that serves 35 homes.
Response: U-turns will be utilized in order to access US221 from Twin Bridges Drive. The
closest u-turn south is at —L- 216+00 (1600') and north at —L- 253+00 (2100'). U-turns are
located where topography and environmental features would allow.
12. Jerry Ashley (-L- 425+00 Rt.)
Mr. Ashley is concerned about the loss of his business as well as access to US 221. He states his
business is shown inside the limits of proposed right of way.
Response: It appears the business is located on parcel 153 (Jessie Baldwin) but both parcels
share a driveway access onto US 221. The business looks like it will have to be
acquired or possibly moved back beyond the buffer zone for Old Field Creek. Access will be
allowed as a right in / right out and drivers can utilize the u-turn 300' to the north in order to
travel south on US 221.
13. William Stringer
Mr. Stringer accesses US 221 using West Pine Swamp Road (-Y4-). He is concerned that left
turns will not be allowed. Traffic going south on US 221 will have to travel north 1500' and
make a u-turn that in his opinion will be unsafe.
Response: Left turns are desired for Cranberry Spring Road (-Y5-), West Pine Swamp Road (-
Y4-), and Church Hill Road (-Y6-) all within very close proximity to each other. NCDOT is
spreading those left turns out into u-turns located further south and north to allow for safer
turning and merging.
14. Sally Patrick
Ms. Patrick does not think the left turn storage will be sufficient for turning traffic going south to
access the school. She is requesting anbther u-turn be added beyond the leftover into the school
for parents to u-turn and enter the school going north instead.
Response: During final design, NCDOT will consider the left turn lane storage length needed
during peak hours and design accordingly. The addition of a u-turn further south could tempt
traffic already waiting in the left turn lane to abruptly leave the leftover lane to access the u-turn
and avoid waiting. This would create an unsafe conflict with south bound traffic.

R-2915
May 14, 2013
Page 8
15. Pete Yates
Mr. Yates is requesting NCDOT move the u-turn at station —L- 69+00 north about 150' to the
southern edge of the cemetery property to simplify access to the cemetery for the elderly.
Response: Moving the u-turn further north would adversely impact the cemetery due to the
additional right of way needed to construct the turn around.
Verbal Comments and Responses
1. Tom Pope
Mr. Pope is in favor of the project and wanted to encourage property owners to express their
concerns and questions. He believes as the road develops, so will the community.
2. Unnamed Audience Member
This audience member is concerned about the sharp horizontal curves and steep grades along
Windy Hill Road and Lemly Hill Rd onto US 221 between Windy Hill Road and Liberty Grove
Road.
Response:
US 221 will be designed to accommodate a 60 mph design speed. Both the horizontal curves and
grades will be designed for safe travel at this design speed for the entire length of the project
corridor. Windy Hill Road (-Y15-), Liberty Grove Road (-Y11-), and Lemly Road (-Y13-), will
be tied into the new highway. Improvements on -Y11-, -Y13-, and -Y15- will be limited to the
tie-ins to US 221. The scope and funding for this project only allows for minor adjustments for
tie-ins of side road intersections. Clearing and grading will be done to accommodate the new 4
lane highway which will provide greater sight distance at intersections throughout the project
limits.
3. Jeff Grogan
Mr. Grogan doesn't feel the current design is being a good steward of taxpayer dollars.
Response:
US 221 widening utilizes the existing 2 lanes of the road to the extent practical. This is a
substantial savings compared to a bypass or other new location alternatives. It also utilizes the
right of way previously purchased by the state in the northern sections. The interchange area at
the beginning of the project will provide a safer transition between US421 and US221 by
reducing the number of traffic conflict points.
4. Brad Vessal
Mr. Vessal desires for NCDOT to utilize local contractors for this project and keep the money in
the state of NC. He stated since this is using NC taxpayer dollars, NC contractors should be
utilized.
Response:
This project will be awarded to the•lowest responsible bidder: The project will be funded with
State and Federal funds. The contract will be available for bids from all pre -qualified
contractors, but not limited to local bidders only.

R-2915
May 14, 2013
Page 9
Schedule
According to the STIP, the project schedule is as follows:
Section Right of Way Let
R-2915A (map 1) July 2013 July 2015
R-2915B (map 1) July 2013 July 2015
R-2915C (map 2) April 2014 February 2017
R-2915D (map 3) September 2013 September 2015
R-2915E (map 4) PY PY
If anyone has any revisions to these minutes, please contact Gary Lovering, PE, Project Engineer
at [e-mail].
JAB/scl
Attachments
ec: Post Hearing Meeting Attendees
Jennifer Harris, PE, NCDOT, PD&EA
Carla Dagnino, NCDOT, PD&EA
Drew Joyner, NCDOT, PD&EA
Bruce Klappenbach, NCDOT, Structures
DeWayne Sykes, NCDOT, Utilities
Mohammed Mulla, PE, NCDOT, Geotechnical
Stuart Bourne, PE, NCDOT Traffic Management Unit
Michael Pettyjohn, PE, NCDOT, Division 11
Jay Twisdale, PE, NCDOT, Hydraulics
Lawrence Gettier, PE, NCDOT WZTC
Greg Fuller, PE, NCDOT ITS & Signals
Zachary Little, PE, NCDOT, Signal Design
Betty Yancey, NCDOT, Right of Way
Daneil Miles, NCDOT, Division 11 Right of Way
Elena Talanker, NCDOT, Transportation Planning
Van Argabright, NCDOT, STIP
David Graham, RPO
Donnie Brew, FHWA

R-2915
May 14, 2013
Page 10
PRELIMINARY SITE PLAN
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Figure 1

R-2915
May 14, 2013
Page 1 1
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Figure 2

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
69 DARLINGTON AVENUE
WILMINGTON, NORTH CAROLINA 28403-1343
REPLY TO
ATTENTION OF:
February 25, 2013
Regulatory Division/1200A
Action ID: SAW-2012-00882/TIP R-2915
North Carolina Department of Transportation
Attn: Dr. Gregory Thorpe
Project Development and Environmental Analysis
1548 Mail Service Center
Raleigh, North Carolina 27699
Dear Dr. Thorpe:
Reference is made to your application dated January 9, 2013, regarding a potential future
requirement for Department of the Army (DA) authorization to discharge dredged or fill material
into waters of the United States associated with the proposed improvements and widening of US
221 to a multi -lane facility from US 421 near Deep Gap, Watauga County, North Carolina to NC
88/US 221 Business in Jefferson, Ashe County, North Carolina. A Public Notice was issued on
January 15, 2013, to solicit comments from the public on possible alternatives to consider as this
proposal moves through the interagency Merger evaluation. It is understood that your permit=
application was to facilitate this Public Notice and was not intended to initiate a 404 permit
decision at this time,
After review of your proposal, comments were received from one non-profit organization,
one local business, one federal agency, and several adjacent landowners. Two of the individuals
requested NCDOT assistance to determine if the preferred alternative would impact their
respective properties. I would ask that you, or a member of your staff follow-up with those
individuals. The remaining comments are pertinent for future decisions involving this project
and are therefore attached for your review.
If you have questions or comments, please contact me at telephone [phone] ext. 30.
Sincerely,
Monte Matthews
Regulatory Project Manager
Raleigh Field Office
Attachments

Copies Furnished (with attachments):
Ms. Amy Euliss
NC DENR Winston-Salem Regional Office, Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Mr. Brian P. Cole
United States Fish & Wildlife Service
160 Zillicoa Street
Asheville, NC 28801
Ms. Marla Chambers
Western NCDOT Permit Coordinator
NC Wildlife Resources Commission
12275 Swift Road
Oakboro, NC 28129
Ms. Jennifer Derby, Chief
Wetlands and Marine Regulatory Section, Water Protection Div. -Region IV
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303
Ms. Renee Gledhill -Early
SHPO
4617 Mail Service Center
Raleigh, NC 27699-4617
Mr. Craig Hughes, Transportation Planner,
High Country Council of Governments
468 New Market Blvd.
Boone, NC 28607
Mr. Chris Militscher, USEPA
USEPA Region 4 NEPA Program Office
61 Forsyth Street, SW
Atlanta, GA 30303
Mr. Mitch Batuzich
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, NC 27601

Matthews, Monte K SAW
From:
Sent:
To:
Subject:
Matthews, Monte K SAW
Monday, February 25, 2013 1:32 PM
Matthews, Monte K SAW
FW: Public Comment (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
Original Message
From: greg tague [mailto:[e-mail]]
Sent: Friday, February 01, 2013 11:17 AM
To: Matthews, Monte K SAW
Subject: Fw: US 221 (R-2915) ENVIRONMENTAL ASSESSMENT ASHE & WATAUGA COUNTIES
Original Message
From: greg tague <blockedmailto:[e-mail]>
To: monte . k . matthews(aluf .army . mil
Sent: Friday, February 01, 2013 11:10 AM
Subject: Fw: US 221 (R-2915) ENVIRONMENTAL ASSESSMENT ASHE & WATAUGA COUNTIES
Original Message
From: greg tague <blockedmailto:[e-mail]>
To: monte.k.mathewsPuf.army.mil
Sent: Friday, February 01, 2013 9:57 AM
Subject: US 221 (R-2915) ENVIRONMENTAL ASSESSMENT ASHE & WATAUGA COUNTIES
AS PER OUR TELEPHONE CONVERSATION, 2/1/13.
REFERENCE FIGURE 2 SHEET 11 OF 14 -
CONCERNS:
BEAVER CREEK RUNS PARALLEL WITH 221 AND SNAKES AROUND BETWEEN 221 AND BEAVER CREEK SCHOOL
ROAD FROM HELEN BLEVINS ROAD TO 221, CROSSING UNDER 221 AT SOME POINT. THE AREA IN CONCERN
IS THE LAND BETWEEN HELEN BLEVINS AND 221 THAT FLOODS QUITE OFTEN DUE TO AN INADEQUATE DRAIN
PIPE SOME WHERE BETWEEN HELEN BLEVENS AND 221 (GOING TOWARDS JEFFERSON AVE. FROM HELEN
BLEVENS). THE DRAIN PIPE AND BRIDGE UNDER HELEN BLEVENS IS LARGE AND CAN HANDLE LARGE
AMOUNTS OF WATER. HOWEVER, WHEN THAT WATER MEETS BEAVER CREEK NEAR THE HELEN BLEVINS BRIDGE
(AFTER THE LARGE CULVERT AT HELEN BLEVINS) IS WHERE THE PROBLEM STARTS. EVIDENTLY, THERE IS
A CULVERT THAT IS NOT LARGE ENOUGH TO HANDLE THE RELEASE OF THE HIGH VOLUME OF WATER FEEDING
THROUGH THERE NEAR 221. THE CULVERT FILLS WITH DEBRIS AND CAUSES FLOODING BETWEEN BEAVER
CREEK AND 221 FROM HELEN BLEVENS TO CLOSE TO JEFFERSON AVE AND PARTICULARLY BETWEEN THE
NATIONS INN AND ASHE PRO HARDWARE. CONCERNS ARE WHEN YOU CHANGE THE LAND FORMATION THIS
COULD CHANGE THE FLOW OF WATER AND CREATE EVEN MORE FLOODING. PLEASE TAKE A LOOK AT THIS
AREA BEFORE MAKING YOUR CHANGES. THERE ARE MANY HOMES AND BUSINESSES ON HELEN BLEVINS AND
BEAVER CREEK SCHOOL ROAD THAT COULD BE IMPACTED EVEN GREATER IF THIS IS NOT ATTENDED TO.
CURRENTLY, OUR BUSINESS HAS BEEN RE-EVALUATED AND PLACED IN THE 100 YEAR FLOOD PLAIN BY FEMA.
WE ARE GREATLY CONCERNED WITH MORE PROBLEMS DUE TO CHANGES TO 221. PLEASE HELP THE
BUSINESSES AND HOMEOWNERS IN THIS AREA, FORE IT WOULD BE A RELIEF FOR FOLKS THAT ARE HAVING
TO CONTEND WITH THIS FLOODING PROBLEM.

SINCERELY, GL0RZ4 TAGUE - tagoomaPbeIlsouth.net
Classification: UNCLASSIFIED
Caveats: NONE
Classification: UNCLASSIFIED
Caveats: NONE

CO
NVE
RSAT ION i�CO
Time
1430 pm
Date February 11, 2013
Type:
Visit Conference
Location Of Visit/Conference:
X Telephone
Incoming
0 Outgoing
Name of Person(s)Contacted
or In Contact with You:
Organization
Telephone No,
Nell Domeck
Private landowner at
Gap Creek
[phone]
SUBJECT: Action ID. 2012-00882, TIP R-2915; Watauga and Ashe Counties,
North Carolina.
SUMMARY: Received a call from Ms. Domeck in response to our Public Notice
dated 1-15-2013 regarding the proposed widening of US 221 •between Deep Gap
and Jefferson. Ms. Domeck is opposed to this project and relayed the
following concerns: 1) concerned with flooding and filling the floodplain
of Gap Creek and other tributaries; 2) Impact (direct and indirect) to Gap
Creek and other tributaries within the New River basin; 3) negative impacts
on ingress and egress for adjacent property owners; 4) she questions the
traffic projections relating to project need; 5) impacts to aquatic
organisms (including trout within Gap Creek); 6) worried about inadequate
sediment and erosion control; and 7) potential for increase noise impacts.
ACTION REQUIRED: Forward to NCDOT for consideration on alternatives.
ACTION TAKEN:
Signature
Title
Date

3020 Pioneer Place
Crestwood, KY 40014
February 7, 2013
Mr. Monte Mathews
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive Suite 105
Wake Forest, NC 27587
Dear Mr. Matthews:
RECEIVE
FEB 11 2013
RALEIGH REGULATORY
FIELD OFFICE
My mother owns a summer home on Highway 221 in Ashe County, which was built by
my grandparents in the early 1950s. I have visited there almost every year since I was
born in 1957. Gap Creek and the surrounding area are very near and dear to me. I have
witnessed how changes in the area, such as Christmas tree farming, straightening the
creek, and filling near the creek for construction, have adversely affected Gap Creek.
Two of my family's bridges have washed away and there has been tremendous erosion to
the banks. The creek and riparian zone now look nothing like they did when I was a child
in the 1960's. I am vehemently opposed to the proposed widening of Highway 421 to 4
lanes with a median because it will adversely affect Gap Creek and the many endangered
species in the area.
I understand that improvements could be made to the road safer, such as shoulder
improvements, adding turn lanes and widening the existing lanes. However, I drive
Highway 221 every summer going to West Jefferson and to Highway 421 and do not
believe that 4 lanes are necessary. It has always seemed like a relatively safe road to me.
In addition to the environmental impact, 4-laning 221 would disrupt people's lives,
change the character of the area and create problems with access to the road. I fear that
we might not even be able to get out of our driveway if there is additional fill. The
approach to the road from my mother's driveway is already steep. Furthermore, if there is
a 23-foot wide median, many homeowners will be unable to turn in both directions from
their driveways. People will make u-turns, which will create a different safety issue.
I sincerely hope that the Wilmington District for the US Army Corps of Engineers will
deny the NCDOT's request for authorization to discharge dredged or fill material into
Gap Creek.
Sincerely, /LA./riCe/�,�
--D- Gti1�
Amanda Dreckman

Linda B. Crouse
180 Indian Lake Drive
West Jefferson, NC 28694
February 13, 2013
Mr. Monte Matthews
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive
Suite 105
Wake Forest, NC 27587
Dear Mr. Matthews:
This letter is to follow up on the notification that I received concerning the proposed
discharge dredged or fill materials into the Old Field Creek. Thanks for your patience
while we discuss the impact it would have concerning this Historic Native Trout Stream
My Grandfather, Andrew Black, purchased property along Old Field Creek back in the
Great Depression. The stream was so pure and plentiful of native trout that the fish
actually swam over the top of each other. Over the years, the beaver have discovered the
goodness of this stream and have built homes along the way.
The Containment center along Hwy 221 is located above my property. There is trash that
blows out and gets washed down stream onto my property. The plastic that gathers can't
be good for the wildlife that live in the stream.
The Old Field Creek is a very powerful stream. Just 2 weeks ago, we received a large
amount of rain. It washed 140' of fence out on my property. The creek just flows where
it is easiest to travel. I am concerned that if the process of road construction "moves" the
stream — a heavy rain will cause the stream to cut its own course to travel. These streams
involved have been researched for the 100 year flood plan — looks like a lot of hope the
streams won't get up — or they are going to move a lot of water.
The Hwy 221 project is needed. I recognize that progress concerning this will greatly
improve the quality of traffic flow from Ashe to 421. My biggest concern is the path of
the road. Hwy 221 from what I was told, was part of the original train path. This of
course followed the Old Field Creek. If you travel the road — you will see that the creek
or additional streams seem to be on either side of the road, this requires that the road go
back and forth to avoid the streams.
Many of my neighbors and friends are confused as to why the Hwy 221 expansion chose
to follow the original road, verses cutting a new road (example) like the 421 road going
to Boone. This expansion cut through the back part of properties and did not displace the
amount of homes that are being proposed for our project.

Mr. Monte Matthews
February 13, 2013
Page 2
Southern Ashe is the most desirable part of Ashe County. The 70 homes to be destroyed
contain people who in some cases are old — they have lived there for most of their lives
and their tax values on their homes have been greatly reduced — so ultimately - they will
not even be able to buy back — especially in the southern Ashe Area.
Attached are some pictures for you to see the power of Old Fields Creek.
Sincerely,
Linda B. Crouse
Attachments

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Owner: CROUSE
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OLD FIELDS
500 Year Flood Results
Buildings
City Limits
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Flood Way
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Parcels
Roads
raxgrid Townships
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:ounty Voting Districts
OLD FIELDS
Fire Zones
FLEETWOOD/TODD/WI FD
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Owner: CROUSE, LINDA BLACK Address: P 0 BOX 1575
452 Size: 18.540 acres Bldg Value: 157100 Total Value:
Page: 279 Gpin: 295551654722 Xfer Date: 7/25/2007

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CORNEAL L. DOMECK, III
7507 GREENLAWN ROAD
LOUISVILLE, KENTUCKY 40242
[phone]
February 9, 2013
Mr. Monte Matthews
US Corps of Engineers
Raleigh Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Re: Corps Action ID # SAW-2012-00882
(Widening of US 221- Ashe Co., NC)
Dear Mr. Matthews:
RECE VEC
FEB 1 3 2013
RALEIGH REGULATORY
FIELD OFFICE
My family has owned a cabin in Ashe County on US 221 for the last 65
years. I am strongly opposed to the widening of the current road. The project also
threatens numerous streams such as Gap Creek (where our property is located).
Gap Creek has been degraded by past development and tree farms. The
construction process and widening of the road may be more than this stream can
take.
Gap Creek used to support a healthy trout population and was stocked by
the State. However, developers were allowed to straighten the creek and runoff
of pesticides caused the State to abandon the stocking program. The creek still
has speckled trout, crayfish, and other species which will be threatened by this
project.
I have also fished the New River for many years. It has also been changed
by development and siltation. Again, the health of the affected New River
drainage system will be threatened by this project. The environmental issues
mentioned in your notice should make the denial of this permit self-evident.
There is also a cultural factor to be considered. Families and their small
communities have existed along this road for generations. Widening this road to
four lanes will destroy this valley forever. There are now many roads and private

driveways that intersect with US 221. Ingress and egress from the current road is
difficult, but getting across multiple lanes of traffic will be next to impossible.
We believe that the best thing is to do nothing except for making specific
improvements such as a turning lane or the like where safety warrants. If a new
road is to be built, it should be relocated to the west (toward Boone). This
approach was used in improvements to US 421 between Deep Gap and Boone
with great success. If NCDOT doesn't have the money to do this, then it should do
nothing. Quite simply, there is no public purpose which justifies the
environmental and cultural consequences of this project.
Finally, we trust that you will undertake a critical analysis of this matter and
not just rubber stamp the State's ill-conceived plan.
Respectfully,
I \
I/
0 Pvt.-41, d
CORNEAL L. DOMECK, 111

ANNE SKLARE
7200 CREEKTON DRIVE
LOUISVILLE, KY 40241
Mr. Monte Matthews
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
Dear Mr. Matthews:
RALEIGH, REGULATORY
HELD OFFICE
I am writing regarding the proposed widening of US 221 to a multi -lane facility from
US 421 near Deep Gap in Watauga, North Carolina to NC 88/US 221 Business in
Jefferson in Ashe County, North Carolina. My family has owned property on US 221
in Ashe County for more than 60 years and the potential impact of the widening
project is of grave concern.
A road widening project of the scope that is proposed —especially one that calls for
4 lanes, a grassy median of between 17.5 feet to 36 feet wide, and 8-foot shoulders
on both sides —would exacerbate flooding and erosion of Gap Creek that runs along
US 221. By diminishing the width of the natural flood plain and speeding the
current in areas restricted by the presence of fill for the widened road, this project
will cause ongoing environmental and property damage.
I urge the Corps to deny authorization to the NCDOT to discharge dredged or fill
material into the waters of the New River Basin. Pollution of these waterways with
dredged or fill material would negatively impact the environment, fish and wildlife,
and the local economy that benefits from tourism and sporting activities such as
fishing, canoeing and hiking in and around the South Fork of the New River and the
creeks near US 221.
I appreciate this opportunity to express these concerns and hope that the Corps will
deny approval of NCDOT's application related to the widening of US 221. The scope
of the proposed "Best -Fit Widening" alternative for US 221 is not justified in light of
the harm that would result.
Sincerely,
Anne Sklare

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MOUNTAIN KUBOTA OF BOONE
418 DEEP GAP DR
DEEP GAP, NC 28618
828-264-2711/828-264-2719 FAX
Januray 31, 2013
Mr. Monte Matthews
US Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive
Suite 105
Wake Forest, NC 27587
FEB 0.7.2013
FIALEIGH. REG(J .ATORY
Dear Mr. Matthews,
Please see below two primary concerns we have with the proposed widening of US221 and the
proposed new interchange at US421 Corps Action ID#: SAW-2012-00882; TIP Project No. R2915, in
Deep Gap, NC.
Concerns:
1. Disruption from construction
2. Loss of visibility of our business building, signage and equipment display lot to traffic flow on
US421 and US221.
We are a small business equipment dealership located in Deep Gap, NC. We have been in
business now for 1 `/2 years. As the owner of Mountain Kubota, we have made a significant investment
n land and facility based on the location benefits. The new interchange will bring obstruction of
visibility of our equipment display lot as well as our building. The result is a loss of sales.
When the construction begins, it will disrupt access and traffic flow for our customers. Again,
this disruption will result in loss of sales for our business.
When the disruption of the construction project is taken into account, along with the long term
impact of the interchange on visibility, it is possible to have a significant reduction in sales revenue and
therefore profit.
We currently have 9 employees at our dealership in Deep Gap, NC. Our business provides
income to all these employees and that income could be jeopardized by the new interchange. We have
had a good start-up, even in this difficult economic environment, and hope to continue to grow. With
the location and interchange design proposed, our future success could be limited.
We at Mountain Kubota ask that our opinion of potential impact be considered as the project
moves forward. We would like plans and decisions to be developed and implemented which will factor
in our concerns and issues. Also, if we are either damaged by loss of sales due to construction or loss
of visibility an appropriate compensation settlement be granted.

Our current location works very well for us for visibility and access. We have also invested in
advertising to tell our customers where we are located. We do not want to lose any of our growth
momentum now or in the future.
Thank you for consideration of issues defined in our letter and we look forward to your
response. On behalf of all of us at Mountain Kubota -
Sincerely,
Terry J es & Elna Jones
Owners of Mountain Kubota ofBoone LLC

Southeast Regional Office
263 1311' Avenue South
St. Petersburg, Florida 33701-5505
[phone]; FAX [phone]
http://sero.nmfs.noaa.gov/
January 15, 2013
(Sent via Electronic Mail)
Colonel Steven A. Baker District Engineer, Wilmington District
Department of the Army, Corps of Engineers
Regulatory Division
P.O. Box 1890
Wilmington, North Carolina 28402-1890
Dear Colonel Baker:
NOAA's National Marine Fisheries Service (NMFS) reviewed the projects described in the
public notice(s) listed below.
Based on the information in the public notice(s), the proposed project(s) would NOT occur in the
vicinity of essential fish habitat (EFH) designated by the South Atlantic Fishery Management
Council or NMFS. Present staffing levels preclude further analysis of the proposed activities and
no further action is planned. This position is neither supportive of nor in opposition to
authorization of the proposed work.
NOTICE NO. APPLICANT NOTICE DATE DUE DATE
2012-00882 NCDOT January 15, 2013 February 14, 2013
Please note these comments do not satisfy your consultation responsibilities under section 7 of
the Endangered Species Act of 1973, as amended. If the activity "may effect" listed species or
critical habitat that are under the purview of NMFS, consultation should be initiated with our
Protected Resources Division at the letterhead address.
Sincerely,
Pace Wilber (for)
Virginia M. Fay
Assistant Regional Administrator
Habitat Conservation Division

CO
RSAT ION ECORD
Time
am
Date January 24, 2013
Type: Visit Conference X Telephone
Location Of Visit/Conference:
> Incoming
I I
Outgoing
Name of Person(s)Contacted
or In Contact with You:
Organization
Telephone No.
Brenda Laurance
Adjacent landowner
[phone]
SUBJECT: Action ID. 2012-00882; Watauga/Ashe County, North Carolina.
SUMMARY: Call from Ms. Brenda Laurance, 744 Railroad Grade Road, phone
336-877-1455 concerning the public notice currently running for this
project. She is elderly and/or disabled and has not been able to attend
any of DOT's public hearings. Due to the scale of the maps included with
the public notice, she is unable to determine how the current proposal
would affect her property.
ACTION REQUIRED: Refer to DOT for appropriate action
NAME OF PERSON DOCUMENTING CONVERSATION SIGNATURE DATE
Monte Matthews January 24, 2013
ACTION TAKEN:
Signature
Title
Date

CO
\./
RSATION RECORD
Time
am
Date
February 11, 2013
Type:
Visit Conference
Location Of Visit/Conference:
X Telephone
v
Incoming
Outgoing
Name of Person(s)Contacted
or In Contact with You:
Organization
Telephone No.
Rebecca Houck
Adjacent landowner
[phone]
SUBJECT: Action ID. 2012-00882; Watauga/Ashe County, North Carolina.
SUMMARY: Call from Ms. Rebecca Houck, Clarence Lyall Road, phone 336-877-
3375 concerning the public notice currently running for this project. Due
to the scale of the maps included with the public notice, she is unable to
determine how the current proposal would affect her property.
ACTION REQUIRED: Refer to DOT for appropriate action
NAME OF PERSON DOCUMENTING CONVERSATION
Monte Matthews
SIGNATURE
DATE
February 11, 2013
ACTION TAKEN:
Signature
Title
Date

BOARD OF
DIRECTORS
Henry Doss,
Chairman
Bob Lovett,
Vice Chairman
Bob Kelly,
Treasurer
Martha Stephenson,
Secretary
Jonathan Halsey
Fred Jordan
Dixie Leonard
Russ Moxley
John Pine
Julio Stephens
Lorrie Sprague
Dave Wallace
Anna Ziegler
STAFF
Brad Baskctte,
Stewardship
Coordinator
Lynn Caldwell,
Restoration Director
Carol Coulter,
Director of Operations
Laura Green,
Administrative Asst.
Ben Lucas,
Land Protection
Coordinator
George Santucci,
President
Courtney Wait,
Advocacy Coordinator
Dave Wesolowski,
Water Quality
Assistant
February 14, 2013
National Committee for the New River
PO Box 1480
West Jefferson, NC 28694
Re: Corps Action ID #: SAW-2012-00882
TIP Project No. R-2915
National Committee for the New River (NCNR) is a 501(c)(3) nonprofit organization that
believes that clean water, healthy land, and empowered people benefit our communities
by creating a watershed where people want to live, work and play.
For many years NCNR has been following erosion issues in the 221 corridor due to
stormwater runoff from impervious surfaces, historic straightening of creeks, and lack of
riparian buffers. While NCNR realizes that the 221 widening is necessary to the area in
terms of safety and economy, we realize that increased impervious surface from widening
will also increase the stormwater runoff and "flashiness" of the creeks along the highway,
further contributing to the erosion and entrenchment of the creeks.
It is NCNR's understanding that it is DOT's goal to avoid negatively impacting any of
creeks and wetlands the planned expansion could affect. If there are unavoidable impacts
NCNR would like to work with the Corps of Engineers and NCDOT to identify and
mitigate the creeks directly affected by the highway widening project. Mitigation
activities include stabilizing and restoring creeks and wetlands in this corridor, and
ensuring fish passage through stream crossings.
While all of the creeks listed are creeks of concern to NCNR, the creek of greatest priority
is Old Fields Creek, whose headwaters are near West Jefferson (Environmental
Assessment Sheet # 9) and flows into the South Fork New River in Fleetwood, NC (EA
Sheet # 5). The distance from the headwaters to the confluence is about 5 miles and the
entire stream and its watershed is designated as an Outstanding Resource Waters.
For over a decade, the streambanks of Old Fields Creek at its confluence with the South
Fork New River in Fleetwood had been documented by field observations and cross -
sections as being severely unstable, with high, vertical, eroding banks. The creek had
experienced heavy erosion due to historic agricultural practices, buffer degradation, and
upstream impacts such as road construction and residential buildings. During the 12 years
or so that the creek was being observed, some sections of the stream channel moved 100
feet. In the late 1990's and again in early 2000's the New River Soil and Water
POST OFFICE SOX 1480 WEST JEFFERSON, NORTH CAROLINA 28694 336-846 -6267
03, Dip
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WWW.NCNR.ORG
[e-mail]
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share. In the summer and fall of 2011 construction was completed. The conservation easement
was the last phase of the project. A significant amount of time and resources has been dedicated
to restoring Old Fields Creek. NCNR does not want to see all that hard work wasted as a result
of this project. We would also like to see the entire creek from headwaters to confluence
stabilized and reconnected to the floodplain to minimize damage to structures and heavy erosion
during rain events.
Furthermore, we advocate for a canoe access where Highway 221 crosses the New River (EA
Sheet # 4). There are currently no formal public river access sites along this popular reach of the
South Fork New River. Boating, tubing, and fishing are a large part of the tourism economy in
Ashe and Watauga Counties.
It would be a gesture of diplomacy from NCDOT to reduce further destruction to the New River
watershed, improve existing unstable streambanks with mitigation funding, and improve the
community's ability to access and enjoy our treasured resource.
We appreciate your careful consideration of these comments. We welcome discussion and can
be contacted at any time.
Since el
CO
Pre , NCNR

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