20120285 Ver 1_Complete File_20061106

October 19, 2004
Ms. Kristina Solberg, Project Manager
North Carolina Department of Transportation, PDEA
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Ms. Solberg:
Subject: Comments About Information/Questions Requested By Merger Team Document and
Position Briefing Paper for the Elevation to Resolve Nonconcurrence of the Merger
Team at "Partial Concurrence Point 2" for TIP Project No. U-3321, Gaston County
East-West Connector Study, Gaston and Mecklenburg Counties, North Carolina
As a result of the September 29, 2004, elevation meeting, the NCDOT requested that the
U.S. Fish and Wildlife Service (Service) provide a list of questions or requests for further
information regarding Project U-3321 by October 7, 2004. We provided our request for
information via e-mail on that date (copy enclosed). On October 18, 2004, we received the
NCDOT's responses. We have reviewed the responses to our requests and the requests and
questions of the other resource agencies and are providing the following comments and an
overall briefing regarding our reasons for nonconcurrence.
The information in your document does not provide the level of detail necessary for us to change
our position regarding concurrence with the NCDOT's selection of Detailed Study Alternatives
(DSAs). We continue to support an "improve existing" scenario as an important component for
evaluating, avoiding, and minimizing the environmental impacts of this project.
COMMENTS REGARDING THE NCDOT'S OCTOBER 18, 2004, DOCUMENT
In the subject document there are references to certain alternatives' meeting or not meeting
"critical elements" of the current purpose and need. The purpose and need, as written, has no
critical elements defined, and the merger team never discussed any part of the purpose and need
as being "critical". When determining DSAs, there is flexibility in the National Environmental
Policy Act (NEPA) to add DSAs for a variety of reasons--public input, level of controversy,
additional knowledge, natural resource concerns--and we believe the Service's input and that of
other resource agencies is adequate justification to maintain an improve existing scenario as a
DSA. An improve existing scenario is part of a reasonable range of alternatives providing a
valuable basis for comparison and potentially environmentally positive attributes not found in
new location alternatives. We believe at least one of the scenarios should be carried forward as a
DSA.
Specific concerns include the following:
1. Provide survey data for federally listed species in the project study area including both the
new location corridors and the improve existing scenario (FWS).
The natleral resources investigation will commence after Detailed Study Alternatives are
selected. Therefore, it is unknown at this time whether suitable habitat exists. If protected
mussels are found within the project stucly nrea NCDOT will addre,rs any impacts to project
alternatives at that time. Natural resource data is not necessary in determining if a proposed
alternative meets the project's Purpose and Need. This type of analysis would be done
during the Detailed Study Alternatives (DSAs) stage.
As we have stated previously, the Service has concerns regarding the possibility of impacts
to federally listed species for the new location alternatives. At this early point in the process,
eliminating all of the improve existing scenarios leaves only "no build" as a potential
avoidance alternative for impacts to federally listed species if such species are discovered in
the new location corridors.
Our request was not intended to provide a purpose and need fitness test. Rather, it is a way
to help ensure that the process can continue past Concurrence Point 2 without having to stop
and pick up a new alternative for detailed study if there are significant impacts to listed
species associated with the other alternatives. Analysis of a broad range of alternatives,
including an alternative that avoids impacts, may be a very important factor in ensuring
compliance with the Endangered Species Act of 1973, as amended (Act). We remind you
that section 7(d) of the Act prohibits "any irreversible or irretrievable commitment of
resources with respect to the agency action which has the effect of foreclosing any reasonable
and prudent alternative measures which would not violate subsection 7(a)(2)."
2. Provide the impact data for improve existing scenario 4+ as described on pages 26-27 of the
July 14, 2004, handout (FWS).
Only a cursory level impact analysis was done for the 'improve existing' alternatives. These
impacts are not at the same level of detail as the corridor level "new location" alternative
impacts. Therefore, it is not constructive to draw a comparison. Additionally, impacts are
not used in determining whether alternatives meet Purpose and Need or which alternatives
should be carried forward.
We believe it is important to gather the data, display these impacts, and make a true
comparison. Again, the request for these data is not a fitness test for purpose and need.
2
3. Evaluate the traffic and congestion improvements to I-85 and US 29/74, assuming the new
location alternative is a toll road (Service).
It has not been determined that this project will be a toll facility. A toll would be one fundin,Q
option. Traditionally funding has not heen an element of the alternative selection process.
Regardless of the funding mechanism for this highway, paying a toll to use a road versus
using a public, non-toll road, will influence what and how much traffic uses the new road
versus existing I-85. Given that there is a proposal for this road to be a toll road, we believe
it could alter the traffic numbers enough to force improvements to I-85 and US 29/74, even
with the new highway. In addition, this is anything but a"traditional" situation, the Turnpike
Authority is less than 2 years old, and toll roads have not been analyzed as possible funding
sources for roads in North Carolina.
POSITION BRIEFING PAPER
The following describes our reasons for not concun-ing with the request to eliminate all non-new
location alternatives for the subject project prior to signing Concurrence Point Two.
Merger Process History
May 15, 2002 - First meeting to discuss Purpose and Need.
July 24, 2002 - Concurrence reached on Purpose and Need.
February 17, 2003 - A meeting to "review and discuss the preliminary new location corridor
segments and identify those that should be carried forward for functional design as potential
candidates for Detailed Study" (January 14, 2004, memo).
August 17, 2004 - First "Partial Concurrence" meeting to evaluate scenarios involving non-new
location alternatives.
September 15, 2004 - First elevation meeting regarding "Partial Concurrence" for the subject
project.
Listed Species
At this time we believe there is the potential for federally listed species to occur within the
impact area of the new location corridors. Our records indicate occurrences of the federally
endangered Schweinitz's sunflower (Helianthus schweinitzii) and the federally threatened bald
eagle (Haliaeetus eucocephalus) within the defined study area in the vicinity of the new location
alternatives. We are aware of no occurrences of listed species in the vicinity of the non-new
location alternative scenarios.
The first obligation of the action agency is to avoid impacts to listed species. Currently, there is
no site specific biological data for the new location alternatives. Without these data it would be
premature to eliminate alternatives that potentially provide the only opportunities to avoid and
minimize project impacts to listed species. In addition, as described in an e-mail to the Merger
Team on August 31, 2004, a new population of the federally endangered Carolina heelsplitter
(Lasmigona decorata) mussel was discovered in the Fishing Creek system in the upstate of South
Carolina, in the Catawba River basin. This is the first find of this species on the west side of the
Catawba in recent history. The extent of stream miles occupied by the heelsplitter is unknown at
this time, but it could be fairly extensive given the habitat and the lack of survey data. None of
the streams in the general new location corridor proposed for this project have had recent mussel
surveys. Given this new information, the Service strongly recommends stream surveys to
determine the habitat suitability for, and the presence of, any sensitive aquatic species in the new
location corridor alternatives before the non-new location alternative scenarios are eliminated.
Streams, Wetlands, and Wildlife Habitat
New location highway projects permanently alter streams, wetlands, and wildlife habitat
configuration and function directly through destruction or fragmentation and indirectly and
cumulatively by providing access to previously undeveloped or moderately developed land.
With the rapid development occurring in this region, we have concerns about putting forward a
set of alternatives that will only serve to facilitate development and sprawl. Again, the non-new
location alternative scenarios present the most likely opportunity to avoid and minimize impacts.
We acknowledge that southern Gaston County is growing without the new location Gaston
East-West Connector Project. However, we believe that a new highway will induce a higher rate
of development in the area and further degrade the natural environment.
Process Issues
Merger Process - The Merger Team has been asked to concur and sign a concurrence form at a
point that is not part of the first Merger Process or the draft revised Merger 01 Process. The
information presented thus far clearly outlines the complexity of the project, and we agree that
looking at it in pieces may make the information easier to sort through. However, we do not
believe that another signatory concurrence point is appropriate without a formal revision of the
Merger 01 Process. Is the NCDOT proposing to add the "Partial Concurrence Point" as a step la
to the Merger 01 process?
Purpose and Need - In the August 2004 meeting, the NCDOT presented the non-new location
scenarios and reasons to eliminate each of them. The primary reason for eliminating these
scenarios, in the NCDOT's opinion, is that they do not meet the purpose and need for the project
because they do not sufficiently improve traffic capacity and eliminate congestion. However,
traffic numbers presented at the same meeting indicate that even with the completion of the new
location facility, a portion of existing I-85 would still operate at a Level of Service F, or failing,
in the design year. With that infortnation, it would appear that none of the alternatives fully meet
the purpose and need.
4
When the team wrote the purpose and need statement and agreed to its language, there were no
measures or thresholds (such as "sufficiently") in the statement. Further, there is no language in
the CEQ regulations for NEPA that measures "how much" an alternative meets the purpose and
need. Conversely, the regulations do require that the agencies shall: "Rigorously explore and
objectively evaluate all reasonable alternatives" (40 CFR 1502.14(a)). In our opinion, the
current treatment of the non-new location scenarios is neither rigorous nor objective.
In summary, we are concerned about potential direct, indirect, and cumulative impacts to listed
species and fish and wildlife habitat. Our comments on this and other projects have consistently
favored non-new location alternatives as a way to avoid and minimize impacts. Given that
environmental impacts of the new location alternatives will be substantial, we believe that at
least one non-new location scenario needs to be evaluated in order to provide an appropriate
comparison of impacts and a reasonable range of alternatives. We believe that the non-new
location scenario 4+ likely provides less potential for impacts to our trust resources and meets
the stated purpose and need.
If you have questions about these comments, please contact Ms. Marella Buncick of our staff at
828/258-3939, Ext. 237. In any future correspondence concerning this project, please reference
our Log No. 4-2-02-444.
Sincerely,
Brian P. Cole
Field Supervisor
Enclosure
cc:
Mr. Steve Lund, U.S. Army Corps of Engineers, Asheville Regulatory Field Office, 151 Patton
Avenue, Room 208, Asheville, NC 28801-5006
Mr. Chris Militscher, U.S. Environmental Protection Agency, Terry Sanford Federal Courthouse,
310 New Bern Avenue, Room 206, Raleigh, NC 27601
Mr. Brian Wrenn, North Carolina Department of Environment and Natural Resources, Division
of Water Quality, Wetlands Section, 1621 Mail Service Center, Raleigh, NC 27699-1621
Ms. Marla J. Chambers, Highway Projects Coordinator, North Carolina Wildlife Resources
Commission, 12275 Swift Road, Oakboro, NC 28129
USFWS Request for Additional Information Regarding Project U-3321
The US Fish and Wildlife Service requests the following:
1. Provide the impact data for the improve existing scenario 4+ as described on pages
26-27 of the July 14, 2004 handout.
2. Provide information about other road projects in the study area (either currently in
planning or those funded) and how those improvements will influence future traffic and
congestion.
3. Evaluate Scenario 4+ with the TSM measures described on pages 7-10 of the July 14,
2004 handout and any other TDM and/or mass transit measures to achieve a best case
scenario for an improve existing alternative.
4. Evaluate the traffic and congestion improvements to I-85 and US 29/74 assuming the
new location alternative is a toll road.
5. Provide survey data for federally listed species in the project study area. Including
both the new location corridors and the improve existing scenarios.
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? Q 9 Michael F. Easley, Governor
William G. Ross Jr., Secretary
? -7 ;\ ? ? ??.i '? North Carolina Department of Environment and Natural Resources
0 ,tA ,it.?? Alan W. Klimek, P.E. Director
?, ,? Division of Water Quality
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Kristina Solberg, P.E., Project Manager ?µ-
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John HennessY, SuPervisor
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Position Briefing Paper for the Elevation Process to Resolve Non-Concurrence at
Partial Concurrence Point #2 for TIP Project U-3321, Gaston County East-West Connector Study, Gaston and Mecklenburg Counties The purpose of this document is to provide the position of the North Carolina Division of Water
Quality (DWQ) on TIP Project No. U-3321, East-West Gaston Connector in Gaston County.
The project history is as follows:
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• May 15, 2002 - The 404/NEPA Merger Project Team met to discuss the statement ot?
Purpose and Need of the project. 'Z"(`'
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o Concurrence was not achieved.
f,V ?"? o Additional information was requested for the agricultural economy in Gaston
G? ? r n`f?4S County and for the need of improved connectivity between Gaston and
? . Mecklenburg Counties.
'01 o NC DOT promised the Merger Team fair and equal analysis for all alternatives. • July 24, 2002 - The 404/NEPA Merger Project Team signed Concurrence Point #1 for
Purpose and Need of the project.
o The purpose of the proposed action is to improve east-west tran.sportation e?
?{y,n•-' Is' mobiliry in the area around the City of Gastonia, between Gastonia and the
0 Charlotte metropolitan area in general, and particularly to establish direct access
?,?„l? between the rapidly growing area of southeast Gaston County and west
Mecklenburg County. The projeet purpose is based on the following:
¦ Improve mobility, access, and connectivity in southern Gaston County and 0
between southern Gaston County and Mecklenburg County. J?,14
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e congestaon and cmprove traffic flow on the sections of 1-85, US ?
S/r? 29174 and US 321 in the project study area; improve high-speed, safe 4regional travel service along the US 29-74 intrastate corridor; and
generally improve safety and reduce above average accident rates in the
project study area.
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February 17, 2004 - A Pre-Concurrence Point #2 Meeting was held to discuss new
alignment alternatives.
August 17, 2004 - A Partial Concurrence Point #2 Meeting was held to discuss possible
elimination of non-new location alternatives. Several agencies voiced concerns about
eliminating all non-new location alternatives. Specifically, DWQ felt that a full
assessment of the traffic and environmental analyses was not presented at the meeting.
Concurrence was not reached.
• September 14, 2004 - The first meeting in the elevation process took place to reopen
discussions on the non-new location alternatives. Concurrence was not reached. DWQ
was not present at this meeting.
• September 29, 2004 - The second meeting in the elevation process took place. This
meeting included the next level of supervisors for the resource agencies involved in the
Merger Process. The end result of this meeting consisted of the resource agencies
submitting a list of information requests to DOT. Information requested by the resource
agencies included impacts to streams, wetlands, historic and archaeological sites, revised
traffic analyses based on the new location facility being a toll road, potential
combinations of non-new location alternatives to meet the purpose and need, etc.
Position Statement
DWQ feels that it is inappropriate to eliminate the non-new location alternatives at this time.
Early elimination of the non-new location alternatives would not allow for an appropriate
assessment of the full range of alternatives. DWQ has two fundamental concerns with early
elimination of the non-new location alternatives:
1. It would circumvent the avoidance and minimization process.
2. It would provide the potential for delays during the 404/401 permitting process.
This opinion is expressed in discussions of the following issues: Purpose and Need, Impacts
Information, Threatened and Endangered Species, and Partial Concurrence Points. These issues
are discussed below.
Purpose and Need
The Merger Team agreed to a purpose and need statement that is unduly narrow. During the
team's discussions, concern about the restrictive nature of the purpose and need was expressed.
Concurrence on the statement was finally achieved through a commitment made by NC DOT
that the specific language would not limit the assessment of non-new location alternatives nor
would it pre-suppose any alternative at a specific location. The following statement is taken
from the May 15, 2002 Concurrence Point #1 Meeting Minutes:
The Statement of'Purpose and Need repeutedly uses the term "southern Gustnn County", is that
the area we're talking about south of I-85?
Southern Gaston Counry is expected to receive the most growth based on the
Comprehensive Land Use Plan, but we are referring to east-west transportation needs
and not just southern Gaston Coccnty. It was not the intent to pre-suppose any
alternatives at a specific location, siech as ruling out alternatives for improved
connectiviry north of 1-85. the dncument will be reviewed in this light and revised
accordingly.
In Merger Process meetings and Elevation Process meetings at which DWQ has been present,
this commitment has not been fulfilled. DWQ is of the opinion that an overly restrictive
interpretation is being used to judge each alternative's ability to meet the purpose and need,
particularly in light of previous commitments made by NC DOT. Using this narrow
interpretation, NC DOT asserts that the non-new location alternatives do not sufficiently meet
the purpose and need. However, this assertion is based on cursory analyses using a combination
of the non-new location alternatives (known as the Multi-Modal alternative) and is done so
without the benefit of environmental analyses to support this position. By not fully exploring
Multi-Modal combinations, the spectrum of non-new location alternatives is arbitrarily limited,
thus making these alternatives appear inconsistent with the purpose and need. DWQ feels that
this places qualifiers for meeting purpose and need that are not defined within the purpose and
need statement nor within the Merger Process. Although DWQ agrees that the new location
alternatives better satisfy the purpose and need as written, DWQ feels that this course of action
would circumvent the required avoidance and minimization analysis and potentially result in
difficulties during permitting.
Impacts Information
The primary responsibility of DWQ is to protect the streams, wetlands, and other water bodies of
the State of North Carolina. DWQ must consider a project's purpose and need and the
subsequent project alternatives in relation to the avoidance and minimization of impacts. In
accordance with the Merger '0 1 agreement, a preliminary assessment of natural and human
environments using landscape scale assessment practices is required prior to agreement on
Concurrence Point No. 2. #?-To date the Merger Team has not been provided with sufficient
data, as promised (July 14, 2004 Information Package) regarding impacts to streams, wetlands,
historic and archaeological sites, parks and recreational areas, residences, businesses, community
facilities, etc. Without estimates of these impacts to consider in conjunction with traffic analysis
data, DWQ cannot make an informed decision regarding the elimination of the non-new location
alternatives. This has the potential to create a possible situation where the NEPA process may
conflict with the 404/401 permitting process, a situation w}iic-hthat the Merger Process was
created to avoid.
Threatened and Endangered Specie.s
Issuance of the 401 Water Quality Certification, in accordance with 15A NCAC 2H.0500,
requires that DWQ ensure that the existing uses of waters of the State are protected.
Consideration of wildlife resources is specifically required in the protection of existing uses. US
Fish and Wildlife Service and NC Wildlife Resources Commission feel that the potential for the
federally endangered Carolina Heelsplitter (Lasmigona decorata) to be present in the NC
sections of the Catawba River Basin provides sufficient incentive to retain a non-new location
alternative until a full biological assessment can be made of the study area. Biological
assessments are underway, but until final results of the studies are submitted, it would be unwise
to eliminate the avoidance alternative available through the non-new location alternatives. In
addition, retaining a non-new location alternative would be in keeping with Section 7. of the
Endangered Species Act, which requires an avoidance alternative when threatened or endangered
species are present within a project study area. If the non-new location alternatives are
eliminated prior to the biological assessment, and the Carolina Heelsplitter is found within the
project study area, and an avoidance strategy cannot be developed to properly mitigate the
impacts to this population, then the only avoidance alternative would be a"No Build"
alternative. This would severely delay the construction of any facility to meet the purpose and
need of the project.
Partial Concurrence Points
DWQ does not agree with the proposal to achieve signed partial concurrence for Concurrence
Point #2. DWQ feels that this would short-circuit the Merger Process by eliminating alternatives
without proper evaluation and comparison to the full scope of the alternatives. Although DWQ
agrees that this is an extremely complex project, it feels that signed concurrence is not
appropriate for partial concurrence points. By eliminating all non-new location alternatives
through signed concurrence before the new location alternatives can be evaluated, the Merger
Team is "locked in" to a new location, regardless of the impacts resulting from the new location
alternative. This does not meet the spirit of the Merger Process and can lead to conflicts with the
404/401 permitting process. DWQ is willing to break concurrence points up into multiple
meetings to accommodate complexity, but providing written concurrence on partial concurrence
points unnecessarily limits the alternatives and the avoidance and minimization strategies of the
Merger Team.
1K-,Z`J1 North Carolina Wildlife Resources Commission K?
Richard B. Hamilton, Executive Director
TO: Kristina Solberg, P. E., Project Manager
Project Development & Environmental Analysis Branch, NCDOT
FROM: Marla Chambers, Highway Projects Coordinator
Habitat Conservation Program, NCWRC
THROUGH: David Cox, Supervisor
Habitat Conservation Program, NCWRC
DATE: October 19, 2004
SUBJECT: Partial Concurrence Point 2 on non-new location alternatives for the proposed
Gaston East-West Connector, Gaston and Mecklenburg Counties. TIP No.
U-3321.
Staff biologists with the North Carolina Wildlife Resources Commission (NCWRC) have
participated in the NEPA/404 Merger process and attended Merger Team meetings, including
two meetings of Partial Concurrence Point 2 on non-new location alternatives for the proposed
Gaston East-West Connector. We have the following comments regarding the subject
concurrence point. These comments are provided in accordance with the provisions of the
National Environmental Policy Act (42 U.S.C. 4332(2)(c)) and the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).
The NCDOT proposes to improve east-west transportation mobility between Gaston
County and western Mecklenburg County. During the alternatives development phase of this
project, TIP Project No. U-3321, both new location and non-new location alternatives were
considered. Due to the size of the project, Concurrence Point 2 has been divided into two
"Partial Concurrence", or "Pre-Concurrence", points. New location corridor segments were
agreed upon at the first Partial Concurrence Point 2 meeting on February 17, 2004. At issue in
the second Partial Concurrence Point 2 meetings, held on August 17, 2004 and September 14,
2004, was whether any non-new location alternatives meet the purpose and need of the project.
Gaston East-West Connector 2 October 19, 2004
Gaston & Mecklenburg Counties
In the project area, Gaston and Mecklenburg Counties are separated by the Lake Wylie
portion of the Catawba River. The existing crossings of the waterway in the project study area,
I-85 and US 29-74, cross approximately 1 mile apart and pass just to the north of Charlotte-
Douglas International Airport. New location corridors would carry traffic through southern
Gaston County, near the state line, crossing both the South Fork Catawba River and Catawba
River arms of Lake Wylie, terminating southwest of the airport. Both the new location and non-
new location preliminary alternatives would connect to I-485, currently under construction,
which will run north and south between the airport and Lake Wylie. Other crossings of the
main-stem of the Catawba River lie within three miles of the project study area to the north, NC
27, and approximately 3 miles to the south of the study area, NC 49.
Careful and serious consideration must be given to a ful( range of possible alternatives at
this stage of the project's development, in order to arrive at the Least Environmentally Damaging
Practical Alternative at Concurrence Point 3. Highly valuable natural, recreational and cultural
resources exist in the project study area and every effort should be made to avoid unnecessary
impacts. Crowders Mountain State Park, Daniel Stowe Botanical Garden and Lake Wylie are
found in the study area. Lake Wylie is a very popular lake for fishing and boating and is also
used for water supply. The internationally renowned Bass Masters Classic fishing tournament
was held at Lake Wylie this year.
In addition, many streams flow through the study area, some of which have the potential
to be inhabited by the federal and state Endangered mussel, the Carolina heelsplitter (Lasmigona
decorata), which was recently found in the Catawba River basin in the upstate of South Carolina.
Non-new location alternatives avoid many of the impacts to the area's valuable resources that
would occur with the new location alternatives and therefore should receive serious
consideration as project alternatives to be carried forward for detailed study. New location
alternatives would have much greater direct impacts to aquatic and terrestrial wildlife habitats
and recreational resources and have the potential for much greater secondary and cumulative
impacts to those resources, considering the proximity to Charlotte and Lake Wylie, and therefore
should be regarded as a last resort. As development in the area increases, water quality will
likely decrease, impacting the water supply, quality of recreational experiences on Lake Wylie
and possibly further jeopardize the survival of the Carolina heelsplitter. It would be premature to
eliminate alternatives that avoid potential impacts to this species without thorough mussel
surveys in areas likely impacted by a new location alternative, directly or indirectly.
Computer models were used to predict traffic characteristics in the year 2025 and
compare five scenarios, including the No-Build, non-new location Scenarios 2, 3 and 4, and the
new location Scenario 5. The No-Build or po-Nothing alternative, Scenario l, as described in
the meeting information packet that was received prior to the August 17, 2004 meeting, included
several minor improvements involving the addition of traffic signals at six currently unsignalized
intersections. Scenario 2 improves I-85, Scenario 3 improves US 29-74, and Scenario 4
improves both roadways, but the analysis of these three scenarios did not include any
improvements to ramps or overpasses in the I-85 corridor, nor any turn lane improvements on
US 29-74 or any other arterials. Scenario 5, locally known as the Garden Parkway, was not
analyzed as a toll road, although it has been reported that the proposed Garden Parkway is in the
lead for one of the three toll road projects being selected by the North Carolina Turnpike
Gaston East-West Connector
Gaston & Mecklenburg Counties
October 19, 2004
Authority. A toll road would likely attract less traffic from I-SS and US 29-74 than a non-toll
alternative.
Scenario 4 Plus, which adds Transportation System Management (TSM)
improvements to Scenario 4 such as improvements to ramps, turn lanes and adjoining roads, was
mentioned but not included in the traffic analysis. NCWRC believes that Scenario 4 meets the
purpose and need of the project. Additional strategies could be added to Scenario 4 Plus that
may increase its potential to improve the Level of Service (LOS) and safety on the existing
highways, which would provide a best case scenario for the non-new location alternatives.
These include Transportation Demand Management (TDM) strategies (some of which are
currently being implemented), Mass Transit strategies (which are currently being studied), and
possibly additional TSM improvements beyond those listed in the meeting packet. A more
accurate and appropriate comparison of preliminary alternatives would include the analysis of
Scenario 4 Plus and Scenario 5 as a toll road, however, NCDOT is unwilling to provide this
additional analysis requested by NCWRC and other resource agencies.
The traffic operations analyses predict that by constructing a new roadway, traffic flow
on I-85 and US 29-74 can be improved to a level similar to that achieved by widening I-85 and
US 29-74. That being the case, it stands to reason that both new location and non-new location
alternatives meet the project purpose and need similarly. Differences in traffic characteristics
should not be used to select or eliminate alternatives on the basis of which is better at this stage
in the Merger Process, but rather to answer the basic question of whether an alternative meets the
project purpose and need. None of the scenarios presented for comparison, including the new
location alternative, fully eliminated failing (LOS F) road segments from the target roadways,
however Scenario 4 provided considerable LOS improvement over the no-build scenario
(Scenario 1).
We believe with the additional strategies of Scenario 4 Plus, this alternative adequately
meets the purpose and need of the project by improving east-west transportation mobility in the
area around the City of Gastonia, and between Gastonia and the Charlotte metropolitan area. We
believe that Scenario 4 Plus will reduce congestion and improve traffic flow on the sections of I-
85 and US 29-74, improve high-speed, safe regional travel service along the US 29-74 intrastate
corridor and will generally improve safety and reduce the above average accident rates in the
project study area and will do so to an extent similar to Scenario 5.
It is anticipated that additional improvements to I-SS and US 29-74 corridors will be
necessary under Scenario 5, particularly as a toll road. NCDOT indicated that improvements to
the existing east-west corridors could be handled through a separate project; however it is the
purpose and need of this project to address those deficiencies. Making those additional
improvements under a separate project would basically be constructing both a new location
alternative and a non-new location alternative, greatly increasing the impacts and the costs, when
we feel that improving existing roadways will address the project needs.
Portions of the project's purpose and need statement refer to the "need to improve
mobility, access and connectivity within southern Gaston County and between southern Gaston
County and Mecklenburg County" and "particularly to establish direct access between the
Gaston East-West Connector 4 October 19, 2004
Gaston & Mecklenburg Counties
rapidly growing area of southeast Gaston County and west Mecklenburg County." The main
population centers in Gaston County generally surround the parallel east-west corridor of I-85
and US 29-74. Southern Gaston County is generally rural, except the rapidly growing area
closest to Lake Wylie.
While an additional crossing of the Catawba River would provide a convenient access to
Charlotte for those living close to the lake in southeast Gaston County, the negative impacts to
the southern portion of the county, Lake Wylie and the water supply in the form of increased
development and urban sprawl and associated habitat fragmentation and decreases in wildlife
habitat, water quality and open space out-weigh the benefit of convenience. The closest existing
crossings of the Catawba River to the rapid growth area in southeast Gaston County are
approximately 10 miles apart, US 29-74 to the north and NC 49 to the south, not far from the
Gaston County/South Carolina state line. Access to these east-west roadways that provide direct
access to Charlotte is currently provided via NC 273 and/or NC 279. As long as the connecting
roadways are maintained to adequately carry the area's traffic load, the access, connectivity and
mobility issues for the targeted areas of the two counties will be resolved.
For the above mentioned reasons, NCWRC therefore maintains that non-new location
alternative, Scenario 4 Plus, meets the purpose and need of the subject project. Thank you for
the opportunity to provide our agency's position on this matter. If you have any questions
regarding these comments, please contact me at [phone].
ec: Brian Wrenn, NCDWQ
Chris Militscher, USEPA
Marella Buncick, USFWS
Steve Lund, USACE

MEMORANDUM
TO: Kristina Solberg, PE
Project Development Engineer
North Carolina Department of Transportation
FROM: Robert W. Cook, AICP
Transportation Program Manager
Charlotte-Mecklenburg Planning Commission/MUMPO
SUBJECT: Position Paper-TIP Project U-3321
Further Study of Non-New Location Alternatives
DATE: October 18, 2004
It is the position of the Mecklenburg-Union Metropolitan Planning Organization
(MUMPO) that none of the non-new location alternatives merit further analysis as part of
the evaluation of U-3321 and therefore should be eliminated from further study. The text
that follows will elaborate on why this position is being taken.
Purpose & Need
The mutually agreed upon Purpose and Need for this project states as follows:
The purpose of the proposed action is to improve east-west transportation mobility in ihe
area around the City of Gastonia, between Gasfonia and the Charlotte metropolitan area
in general, and particularly to establish direct access between the rapidly growing area
of southeast Gaston County and west Mecklenburg County. This project purpose is
based on the following:
Need fo improve mobilify, access, and connectivity within southern Gasfon
County and between southern Gaston County and Mecklenburg County.
Need to reduce congestion and improve tratfic flow on fhe sections of 1-85, US
29-74 and US 321 in the project study area; improve high-speed, safe regional
travel service along the US 29-74 intrasfate corridor; and generally improve
safety and reduce above average accident rafes in the study area.
In determining whether to further study the identified non-new location alternatives, one
must focus on the established purpose of, and need for, the project. None of the non-
new location alternatives will succeed in providing "...direct access between..." southern
Gaston County and Mecklenburg County. Any improvements associated with the non-
new location alternatives will, of course, be limited to existing facilities: I-85, US 29-74,
and the Norfolk Southern rail line. These three facilities fixed to a narrow corridor
running through the middle of Gaston County. Only a facility constructed on new
location, as has been proposed by U-3321, will meet purpose and need by providing the
"direct access" explicitly mentioned in the Purpose and Need statement.
One of the primary reasons for the need to provide direct access is the substantial
employment in southwestern Mecklenburg County combined with the steady population
increases in southern Gaston County. Many of the people choosing to reside in Gaston
County are employed at, or in the vicinity of, Charlotte-Douglas International Airport.
The airport itself is the third largest employer in Mecklenburg County, and employment in
the airport area is expected to grow significantly due to planned airport expansions and
the development of an intermodal facility. Employment in the area will also be bolstered
by the strategies approved by the Charlotte City Council when it adopted the Dixie-
Berryhill Strategic Plan. Much of the land within the study area was zoned residential,
but is now planned for employmenUmixed-use.
The approved Purpose and Need statement further notes the need "to improve east-
west transportation mobility in the area around the City of Gastonia... With the
exception of the I-85/US 29-74 corridor, east-west routes in Gaston County are virtually
non-existent, and the problem is particularly acute in the southern part of the county.
Project U-3321 will correct that situation and significantly improve mobility within the
county, without affecting corridors that are projected to be highly congested in the future.
? I-85 ?
The scope of improvements that would be required along I-85 would have a tremendous
negative impact on the physical and social environment. Every interchange would have
to be reconstructed, as would virtually all overpasses. Much development has taken "ki ?
?. place in close proximity to the corridor; this is especially true near the interchanges. The
t required reconstruction of interchanges and overpasses would require a great deal of ,??' ?
?
additional right-of-way, which in turn would likely require the relocation of a significant v^?
? number of homes and businesses. Moreover, nearby homes not acquired for right-of-
way could be greatly impacted--temporarily by construction and permanently by the
noise associated with the increased traffic volumes.
?
US 29-74
This facility is becoming less a road for regional travel, and more a road for local
residents to use for shopping and other similar trips. Evidence of this can be seen
clearly in Gastonia in the area of Franklin Square and Eastridge Mall, but also in
Belmont where a large regional shopping center is to be built, and on Gastonia's west
side where a Wal-Mart Supercenter recently opened. Introducing regionat traffic that
could use U-3321 to US 29-74 will exacerbate worsening congestion. 'y
Feeder Roads
Relying upon I-85 and US 29-74 to accommodate traffic that would use U-3321 will not
only affect those facilities, but will also affect their feeder roads. Unfortunately, few of
them are designed for the increased volumes that would be realized by motorists
attempting to access them. Most pass through existing neighborhoods that would be
negatively impacted by the increased traffic volumes, and there is little room for
increasing capacity without causing great harm to the those neighborhoods. For
example, those wishing to reach Exit 23 would have to pass through the cores of Lowell
and McAdenville. Those using Exit 17 would have to pass through two historic districts
in Gastonia, and a neighborhood that would potentially generate environmental justice
concerns.
The first milestone in the environmental analysis of this project was reaching
concurrence on Purpose and Need. The agreed upon Purpose and Need definitively
states that the purpose of the project is to provide access between southeast Gaston
County and Mecklenburg County, and to improve east-west mobility around Gastonia.
Since the non-new location alternatives fail to meet these tests, the only logical
conclusion to be reached is to eliminate them from further consideration.
m
US Army Corps
o} Englneers.
Wilmington Distdct
`
Gaston E-W Connector Study, U-3321
Gaston/Mecklenbug Counties,'NC
• Elevation Procedure under Section 404/NEPA
Merger Process
• Ability of Improvements to Existing Roads to
Meet Project Purpose and Need
1. The subject study concerns a proposal to improve east-west transportation mobility in the area between the
Gastonia and Charlotte metropolitan areas in general and between southeast Gaston County and western
Mecklenburg County in particular. The project study area is bounded by I-85 on the north, the South Carolina
State Line on the south, the Charlotte-Douglas Airport on the east and the I-85/US 29-74 intersection and
Crowder's Mountain State Park on the west. A Purpose and Need Statement for the project was signed by the
Merger Team on July 24, 2002.
2. A Merger Team meeting was held on August 17, 2004 to consider whether proposed improvements to the existing
east-west routes of Interstate Highway 85 and US Highway 29-74 would meet the project purpose. In summary,
traffic modeling data was presented which showed that widening I-85 and US 29-74 would nominally reduce
congestion, improve traffic flow and reduce vehicle travel times but would probably not address the regional needs
to improve mobiliry and connectivity. It was NCDOT's opinion that if an alternative did not fully meet all aspects of
the purpose and need statement that it should not be carried forward for additional study. Considering the multi-
faceted P& N Statement, the merger team members, with the exception of FHWA and the MPOs, rejected this
position stating that widening still met the overall purpose of the project and it would be premature to eliminate it at
this point in the process. Connectivity was not fully addressed because NCDOT did not evaluate improvements to
existing arterial routes beyond interchanges that could serve to connect southern Gaston Counry to I-85/US 29-74.
The meeting adjourned without agreement.
3. On September 8, 2004, NCDOT notified merger team members that it intended to elevate the issue of the ability of
a widened I-85 and US 29-74 to meet the project purpose and need. We believe that this is an issue-oriented
elevation request and not a concurrence point elevation.
4. On September 14, 2004 the merger team reconvened as the first step in the elevation process. The NCDOT
reiterated its position in Item #2 above. No additional information was presented. The merger team requested that
NCDOT provide the GIS-level impact data for the widening alternative that was described in Item 7 of the August
17, 2004 meeting handout so that it could be considered in concert with the traffic data. NCDOT declined to
provide this information indicating that the decision must be made on purpose and need alone. No agreement
was reached.
5. On September 29, 2004 a meeting of Merger Team Supervisors was held as the next step in the elevation
process. No concurrence was reached on the issue of whether or not to carry forward any non-new location
alternatives. The NCDOT agreed to provide a written response to questions and requests for additional
information by non-concurring merger team members. This response was e-mailed to agencies on October 15,
2004. This response contained no new information sufficient to change our position.
6. The NCDOT has not clearly demonstrated that improvements to existing east-west routes of Interstate 85 and US
29-74 would not meet the basic purpose of the project. NCDOT's data show that these improvements would meet
some but not all of the facets of the P&N Statement. The issue of connectivity has not been fully addressed.
There is insufficient information on record to demonstrate that improvements to existing routes is not a practicable
alternative or that these improvements would have unacceptable environmental impacts. It is recommended that
Scenario 4+ (improve both I-85 and US 29-74 and potentially include improvements to connecting routes) be
carried forward for additional study and documentation of transportation benefits as well as impacts.
10/19/04 POC Steven Lund
[phone], extension 223
Gaston Urban Area Metropolitan Planning Organization
181 South Street P.O. Box 1748
Gastonia, NC 28052 Gasfonia, North Carolina 28053
MEMORANDUM
To: Kristina Solberg, PE
Project Development Engineer
NCDOT
From: Hank Graham, AICP
Senior Transportation Planner
Gaston MPO
Re: Gaston Urban Area MPO Position Paper for Partial Concurrence Point #2 regarding
TIP Project U-3321.
Date: October 19, 2004
TIP_Proiect U-3321 Purpose and Need Statement - Position
The purpose of the proposed action is to improve east-west transportation mobility in the area
around the City of Gastonia, between Gastonia and the Charlotte metropolitan area in general,
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County. This project purpose is based on the following:
• Need to improve mobility, access and connectivity within southern Gaston County and
between southern Gaston County and Mecklenburg County.
• Need to reduce congestion and improve traffic flow on the sections of I-85, US 29/74 and
US 321 in the project study area; improve high-speed, safe regional travel service along
the US 29-74 intrastate corridor; and generally improve safety and reduce above average
accident rates in the study area.
FINDING: The Gaston Urban Area MPO attest that the No-Action and the proposed New
Location alternative are the only alternatives that satisfy the purpose and needs statements
referenced above for TIP Project U-3321. The new location alternative is the only
alternative that provides direct access and connection between Southern Gaston and
Mecklenburg Counties. Subsequently the new location alternative will improve mobility
for I-85 and US 29/74 by providing an alternative route for the County's growth areas.
Gaston Countv Pro_iect History and Summary
Future traffic congestion is the major reason for constructing this roadway. The Gaston Urban
Area MPO held five citizen workshops, six public meetings, and 13 formal public hearings
1
before adopting the locally named US 321/74 Bypass on their 1991 Plan; however the line on the
Map was conceptual, and had not been subject to a feasibility study. In 1997, the Transportation
Advisory Committee (TAC) of the Gaston Metropolitan Planning Organization (MPO) created
the US 321/74 Bypass Citizen's Committee. The first step for the Committee was to establish an
alignment for the Parkway. The preferred alignment recommendation was completed on August
1998 and adopted by the Gaston MPO TAC in January 1999. Second, the Bypass Committee
staff examined the existing and potential land development issues within the corridor and
developed an evaluation report. The Committee, not staff, wished to be educated on and
subsequently recommended and promoted "SMART GROWTH" land use and development
principals along the proposed corridor. The Committee finally developed a land use
recommendations report for the corridor in 2001. The TAC changed the project's name from the
US 321/74 Bypass to the Garden Parkway in November 2001 because of its close proximity and
easy access to the Daniel Stowe Botanical Garden (DSBG).
Citizens US 321/74 Bvpass Committee Composition
The committee was comprised of representatives from each of the affected planning jurisdictions
and other interest groups: Gastonia-3, Belmont-2, Gaston County-2, Dallas-2, Bessemer City-1,
Cramerton-l, and the Gaston County Quality Natural Resources Commission-1, the Gaston
County Economic Development Commission-1, and the Gaston County Historic Preservation
Commission-1. The Committee underwent an extensive educational process using visual
preference surveys and/or visioning exercises. Two (2) public forums were held to give citizens
the chance to hear and voice ideas. Organized educational syinposiums were conducted for the
first two or three meetings to discuss land use topics related to "sprawl", retail in suburb areas,
and traffic on minor arterial and collector streets, transit-oriented development, conventional
suburban growth, traditional neighborhood development, "smart growth", etc. The Committee
conducted approximately 18-20 meetings, workshops and public hearings over a two year and 6
month time period.
The Gaston Urban Area Metropolitan Planning Organization (MPO) recommends a new four
lane divided roadway with fully controlled access to improve east-west mobility in southern
Gaston County. This new highway is shown on the Gaston Urban Area Thoroughfare Plan and
is locally known as the "US 321/74 Bypass" and "The Garden Parkway". The "Garden
Parkway" is the number one priority on the MPO's Unmet Needs List, which is a subset of the
Gaston Urban Area Thoroughfare Plan.
Transportation Improvement Program (TIP) Status
Two segments of the bypass are currently listed in the "Unfunded Projects" section of the State
of North Carolina's Transportation Improvement Program (TIP). The first is the Gaston East-
West Connector from the end of West Boulevard in Charlotte to Interstate 85 in Gaston County.
The second segment is the US 321 Bypass from I-85 to US 321 North. There is no funding
associated with either of these roadway segments, therefore the inclusion in the TIP is wishful
thinking.
The East-West Connector would provide an excellent connection to the Charlotte-Douglas
International Airport. The preferred alignment researched and established by the Gaston Bypass
Committee proposed nine (9) interchanges for the roadway segment currently known as the
Gaston East-West Connector.
2
The Gaston Urban Area traffic simulation model indicates that both I-85 and US 29/74 will be at
or over capacity in 20 years, even with the Connector in place. Therefore improvements to either
of these two roadways will not be a feasible alternative for the East-West Connector as all
improvements will be necessary in the future.
Summary
• The U.S.321 Bypass was first identified in 1989 during the process to update the
Thoroughfare Plan.
• Updated Thoroughfare Plan adopted in 1991 included the bypass.
• 1994-Committee of 100 includes the bypass as part of the Metropolitan Roadway Plan.
• 1994-Mecklenburg-Union MPO revises its thoroughfare plan to include the bypass.
• 1997-Bypass Committee formed by the MPOs Transportation Advisory Committee begins
meeting to refine the bypass alignment to provide an alternative travel corridor through
Southern Gaston County.
• August 1998-Bypass Committee completes its work and sends recommendation to the TAC.
• January 1999-TAC takes final vote on alignment of the bypass.
• March 1999-TAC votes to adopt revised Thoroughfare Plan which includes new bypass
alignment.
• November 1999-local mutual adoption process of the Thoroughfare Plan is complete which
signifies support for the bypass.
• 2001-Bypass Committee completes Land Use Study with recommendations for affected
municipalities.
• Studies for TIP Project U-3321, which is a portion of the Garden Parkway, began in July
2001 using grant funds obtained by Ms. Sue Myrick (US House of Representatives).
FINDING: In conjunction with the clearly defined "Purpose and need" statement, the
volume of data and work conducted by the Bypass Citizen's committee is a testament to the
amount of public, private and political support for the proposed project.
Issue Being Elevated in the NEPA/404 Merger Process - Concurrence Point #2
The NCDOT considered the following basic types of alternatives in accordance with FHWA
Guidelines (Technical Advisory T6640.8A):
l. No-Action - Gaston MPO concurs that this should remain as an alternative for the proposed
project.
2. Transportation System Management (TSM) and Transportation Demand Management
(TDM) Measures - Gaston MPO does not concur that this alternative group is a feasible
alternative for the proposed project.
3. Mass Transit - Gaston MPO does not concur that this alternative group is a feasible
alternative for the proposed project.
4. Improve Existing Roadways (Improve I-85, Improve US 29/74 or Improve Both I-85
and US 29/74) - Gaston MPO does not concur that this alternative group is a feasible
alternative for the proposed project.
5. New Location - Gaston MPO concurs lhat this should remain as an alternative for the
proposed project.
3
FINDING: The Gaston MPO believes that the studies and analyses that have been
completed to date sufficiently demonstrate that TSM/TDM measures, mass transit, and
improvements to existing roadways do not meet all critical elements of the purpose and
need for the proposed project and should be eliminated from further study. The Gaston
MPO agrees that Mass Transit, TSM, TDN1, Improvements to I-85, and Improvements to
US 29-74 do not meet purpose and need and should not be carried forward as Detailed
Study Alternatives for this proposed Project U-3321.
FINDING: A different project purpose and need for another geographic study area, a
different population base with different land use patterns should and would yield the need
to include I-85 and/or US 29/74 as project alternatives, but not for TIP Project U-3321.
4
INFORMATION/QUESTIONS REQUESTED I3Y MERGER TLANI
GASTON COUNTY EAST-WEST CONNECTOR STUDY
TIP PROJECT NO. U-3321
GASTON AND MECKLENBURG COUNTIES
FEDERAL PROJECT NUMBER: STP-1213(6)
STATE PROJECT NUMBER 8.2812501
WBS ELEMENT 34922.1.1
The following requests for information and questions were submitted by the non-
concurring agencies (USACE, USFWS, NCWRC, NCDWQ, EPA) from the U-3321
Merger Team for Partial Concurrence Point #2. Information or questions have been
compiled by NCDOT and grouped by topics, they are as follows.
1. Mass Transit
2. Information on Other Road Projects
3. Tolls
4. Funding
5. NEPA Regulations
6. Scenario 4+ Impacts
7. Constructability and Facility Size
8. Expanded Alternatives
9. T&E Species
10. Other
Under each request or group of similar requests is a response, reference to where an
answer is located, or why we could or could not provide responses. The subsequent
responses will hopefully provide an opportunity for the Merger Team to achieve Partial
Concurrence Point #2.
MASS TRANSIT
• Information on all existing mass transit in the study area and projections for future
mass transit improvements and ridership. (WRC)
Existing mass transit consists of local bus service connecting Gaston and
Mecklenburg Counties. Current Ma,ss Transit ridership in Mecklenburg Counry is
2.6% and 0.3% in Gaston Counry. Mecklenburg County assumes future transit
ridership to be between 2% and S% of total trips. Because of the low transit
ridership in Gaston Counry, future ridership is not projected or included in the
Gaston MPO model. Expansion of mass transit in the study area includes the West
Corridor which will be compri,sed of either Bus Rapid Transit (BRT) or Light Rail
Tran.sit (LRT). The EIS for this corridor is expected to begin this month.
• NCDOT should provide information on the following (a detailed explanation and
analysis on how these Mass Transit initiatives may effect predicted traffic volumes in
the design year for I-85 and US 29/74 and how a New Location Freeway alternative
U-3321 Gaston East-West Connector Study 1 Response to Merger "Ceam Requests I
might potentially reduce future ridership assumptions for Mecklenburg County).
(EPA)
- Gastonia Express or Route 85X express service from Gastonia to Charlotte.
Current and future predicted ridership.
June 03 thru May 04 - 28,453
CATS does not prepare futacre rider,ship projections for individual routes.
- Future Transit Ridership Assumptions in MPO's Travel Models for Gaston
County.
Gaston MPO does not include a transit component in their model because of
insignificant ridership numbers in the county. There i.s no indication in the
county that these numbers will increase in the neur f'uture. The ridership
assumptions for Mecklenburg County is 2- S% .
- NC Passenger Rail Service (AMTRAK) between Charlotte and Gastonia.
Current and predicted ridership, number of stations between Gastonia and
Charlotte, width of existing right of way, and plans for any service expansion.
Currently there is only one option to travel from Gastonia to Charlotte via
Amtrak. The northbound Crescent Line leaves Gastonia at 12:41 PM and
arrives in Charlotte 1:23 PM. The southbound Crescent Line leaves
Charlotte at 3: 25 PM anci arrives in Gastonia at 3:52 PM. It is a professional
opinion that ridership between Charlotte and Gastonia via AMTRAK is very
low and should not be con.siderecl a valid transportation option. Future
service expansion is unknown.
- Proposed Airport People Mover between Charlotte Int. Airport and I-85.
Current status.
The West Corridor Major Investment Study (MIS) prepared Sept. 25, 2002 for
the Charlotte Area Transit System identified a January 1998 update to the
Charlotte / Douglas International Airport Master Plan. This update identified
the construction of a new airport expressway connecting I-85 to the existing
pa.s,senger terminnl and also irlentified a"people mover" to connect the
terminal, satellite parking and a relocated rental car facility north of
Wilkinson Boulevard. There are no cccrrent plans to extend the "people
mover" further north.
- LRT/BRT Alternatives 2A & 2B from Charlotte to Gaston County line.
Current status and future ridership projections.
The preparation of the Environmental Impact Statement for the West Corridor
is expected to begin this month. The EIS will identify an ulternative to move
forward into design with. The West Corridor Major Investment Study (MIS)
U-3321 Gasron East-West Connector Study 2 Response to Merger Team Requests
prepared Sept. 25, 2002 for the Charlotte Area Trunsit System identified
future ridership projections for Altenautives 2A ancl 2B as follows:
Alternative Bus BRT LRT
BRT -(Moreheacl St. - Wilkin,son Bv. ) 2,000 7,000 - 8,000 N/A
LRT -(Morehead St. - Wilkinson Bv.) 2,000 N/A 7,000 - 8,000
BRT -(Mint St. - Wilkinson Bv.) 2,000 5,000 - 6,000 N/A
LRT- (Mint St. - Wilkinson Bv.) 2,000 N/A 5,000 - 6,000
- LRT/BRT Alternatives 3A & 3B from Charlotte to Dixie River Road. Current
status and future ridership projections.
The preparation of the Environmental Impact Statement for the West Corridor
is expected to begin this month. The EIS will identify an alternative to move
forward into design with. The West Corridor Mujor Investment Study (MIS)
prepared Sept. 25, 2002 for the Charlotte Area Transit System identified
future ridership projections for Alternatives 3A and 3B as follows:
Alternative Bus BRT LRT
W-3A BRT -(Mint St. - West Bv.) 2,000 4,000 - 5,000 N/A
W-3A LRT -(Mint St. - West Bv ) 2,000 N/A 4,000 - 5,000
W-3B BRT -(Morehead St. - Clanton Rd. -
West Bv. - Tyvola Rd. ) 2,500 7,000 - 8,000 N/A
W-3B LRT- (Morehead St. - Clanton Rd. -
West Bv. - T vola Rd. ) 2,500 N/A 7,000 - 8,000
INFORMATION ON OTHER ROAD PROJECTS
Other TIP projects in the area: NCDOT should provide a status of the following
projects and provide detailed traffic information on how these improvements reflect
on increased mobility, reduced congestion, and improved safety in the Project Study
Area: (EPA)
- R-2608; 4-lane new location route from I-85 west of Gastonia to US 321
north of Gastonia for approximately 7.5 miles.
- U-2408; NC 274 widening to 4-lanes for approximately 2.8 miles.
- U-3405; NC 274 widening to 5 lane for approximately 1.4 miles.
U•3321 Gaston East-West Connector Study 3 Responsc to Merger Team Requests (
TIP Projec•t Number R-2608 is an unfunded project us listed in tlae 2004-2010 TIP.
Only a portion of this nroposed project, near I-85, is within the U-3321 project study
area. Projects U-3321 und R-2608 were developed from the thoroughfare plan
alignment for the Garden Parkway which is and has been the number one prioriry
project for the Gaston Urban Area MPO f'or ,several years. This project is not
included in the regional model, however, it is anticipated thctt it will be included for
the 2030 model with the Detailed Study Alternatives. Currently no traffic information
is available for this project, anticipnted benefits of* this project such as increased
mobility or reduced congestion would be speculative. See additional information
from Newsletter #2..
TIP Projects U-2408 and U-3405 are fitndect projects in the TIP and were included in
the regiorial model for the Gaston Urban Area MPO. The regional rreodel account.r
for the effects of the traffitc distribution.
U-2408: Gastonia - From NC 274 (Bessemer City Rd) To
US 29-74 (Franklin Blvd)
R/W : 12 /20 /02
LET : 11 / 16/ 04
U-3504: Bessemer City - NC 274 (Gastonia Hwy) From SR 1484 (Maine Ave) To
west of NC 275
R/W : 08 /20 /04
LET : 07 / 18 /06
• Information on other road projects in the area and how they affect future traffic
conditions (WRC)
• Provide information about other road projects in the study area (either currently in
planning or those funded) and how those improvements will influence future traffic
and congestion. (FWS)
Programmed improvements in the TIP are accounted for in the regional model.r of the
Gaston and Mecklenburg MPOs. These improvements are thereby included for the
No-Build and Build Scenarios. The No-Build Alternative always assumes that
projects will move forward to completion.
U-3321 Gaston East-West Connector Study 4 Response to Mcrgcr Team Kequests
TOL•LS
• Evaluate the traffic and congestion improvements to I-85 and US 29/74 assuming the
new location alternative is a toll road. (FWS)
• Scenario 5 as a toll road (WRC).
• The percentage for truck traffic on 1-85 is estimated at 20 percent (Pages 34 and 35).
What is the estimated truck traffic on a New Location Freeway that is a toll road?
(EPA)
• Analysis of the LOS and traffic volumes for I-85, US 29/74, and the new location
with the assumption that the new location facility would be a toll road. (DWQ)
• NCDOT should provide a revised traffic analysis for the New Location Freeway
alternative based upon the likelihood that the `Gaston Freeway' is proposed to be a
toll road by the N.C. Turnpike Authority. (EPA)
It has not been determinecl that this project will be a toll facility. A toll would be one
funding option. Traditionally,funding has not been an element of the alternative selection
process.
FUNDING
• Given the limited resources available for planning projects, please explain why an
unfunded project is receiving priority. (DWQ)
NCDOT received a Congressional mandate to being planning and environmental studies
on this project.
• This facility is presently not funded in the TIP. Please identify the funding source for
the new location facility. (DWQ)
It is anticipated that this project will he eligible,for Highway Trust Funds and Federal
Aid funding. Funding for construction has not been identified in the TIP at this time.
NEPA REGULATIONS
• Why does the NCDOT believe that the widen existing alternatives do not meet the
purpose and need? What part of the purpose and need statement is not met?
Agencies feel that this has not been answered to their satisfaction. (WRC)
U-3321 Gaston East-Wcst Connector Study 5 Responsc to Mcrger Team Requests I
?
J
The widen-existing alternutives do not meet the criticul elements of the Purpose and ?
Need Stutement. i
Under NEPA and Section 404, does an alternative have to fully meet the exact letter
of the purpose and need statement to be considered reasonable and feasible? Or is the
ability of an alternative to meet the project purpose subject to a broader
interpretation? (USACE)
An alternative has to meet the critical elements of the Purpose and Need Statement as
identif ied by the lead agencies.
• Document the need for an additional crossing of the Catawba River. (USACE)
The need for an additional crossing has heen documented through the Thoroughfare
Plan development process for both the Gaston and Mecklenburg MPOs. Both
planning organizations show an alignment (based on transportation need) across the
Catawba River.
SCENARIO 4+ IMPACTS
Has DOT evaluated the environmental and social impacts from improvements to I-85
and US 29/74 on any level? If so, will DOT share that information with the merger
team so it can be considered in concert with traffic modeling data? (USACE)
Per the July 14, 2004, Partial Concurrence Point 2 meeting handout (Item 7 of the
agenda, Page 26), EPA is requesting that NCDOT provide the impact information for
Scenario 4+ as shown in this pre-meeting package. Impacts for this alternative to
wetlands, streams, historic properties, relocations, etc., are listed on Page 26 and were
to be reported to the agencies at the 8/17 Merger meeting. (EPA)
• Impacts of Improve Existing Roadways, as indicated in Section 7(page 26) of the
meeting information packet for the August 17, 2004 meeting, that were to be
provided at the meeting. (WRC)
• Potential impacts to streams (linear feet), wetlands (acres), and other water bodies
(acres) due to improvements to I-85 and US 29/74. Landscape scale assessment is
acceptable. (D WQ)
• Provide the impact data for improve existing scenario 4+ as described on pages 26-27
of the July 14, 2004 handout. (FWS)
• Potential impacts to park and recreation areas, community facilities, and historic sites
due to improvements to I-85 and US 29/74. Also the number of residences and
businesses to be relocated by proposed improvements to I-85 and US 29/74. (DWQ)
U-3321 Gaston East-West Connector Study 6 Response to Merger Team Requests I
Only a cursory level impact analysis was done for tlie `imprnve existing' alternatives.
These impacts are not at the same level of detail as the corridor level `new location'
alternative impacts. Therefore, it is not constructive to draw n comparison.
Additionally, impacts are not used in determining whether ulternntives meet Purpose
and Need or which alternatives should be carried forwarcl.
CONSTRUCTABILITY AND FACILITY SIZE
The size of the facility (no. of lanes, on- and off-ramp lanes, etc.) needed for an
improve existing alternative (I-85 and US 29/74). Include constructability issues and
estimated costs. (DWQ)
• Bridge replacements (auto and railroad) due to improvements to I-85 and US 29/74.
Include constructability issues with parallel bridges. (DWQ)
Thi,s information is not necessarv in determining if a proposed ulternative meets the
project's Purpose and Need. This type of analysis would be done during the Detailed
Study Alternatives (DSAs) stage.
EXPANDED ALTERNATIVES
• Document the issues/problems with improvements/widening of the main arterial
routes that currently serve southern Gaston County. This would include US 321, NC
274, NC 279, NC 273. Look beyond just improving the intersections with I-85 and
US 29/74. DOT's consultant touched on this during the meeting on August 17
talking about congestion issues, but did not provide any information. (USACE)
• An additional multi-modal scenario that would evaluate Scenario 4 Plus and
incorporate mass transit improvements, TDM and any other TSM improvements that
together would provide a best-case scenario for Non-New Location alternatives.
Assumptions and variables put into the model for the above analysis. (WRC)
• Further analysis of the multi-modal alternative that explores creative combinations of
improve existing, TSM, mass transit, improvement of Y-lines, and build aiternatives
to meet the Purpose and Need of the project. (DWQ)
NCDOT should identify and specifically review with Merger team members the 70
TSM location improvements identified in the July 14"' package (Pages 7 through 10).
(EPA)
U-3321 Gaston East-West Connector Study 7 Responsc to Merger Team Requests I
Evaluate Scenario 4+ with the TSM measures described on pages 7-10 of the July 14,
2004 handout and any other TDM and/or mass transit measures to achieve a best case
scenario for an improve existing alternative. (FWS) • Scenario 4 Plus - which includes the TSM improvements described in Section 5.1 of
the meeting infortnation packet for the August 17, 2004 meeting. (WRC)
If connectivity is a failing of improvements to I-85 and US 29/74, did the NCDOT
evaluate improvements to existing arterial routes beyond interchanges (such as US
321, NC 274, NC 7, and/or NC 273) that could serve to connect southern Gaston
County to I-85 and US 74? If so, what are the impacts from such improvements?
(USACE)
In order for a new location faciliry to carry an estimated 50,000 vehicles per day at
an accePtable level of service (LOS) a full control access f'reeway is needed. Mass
transit is included in the model for all scenarios.
T&E SPECIES
Does suitable habitat exist for the federally endangered Carolina heelsplitter within
any of the new location corridors? Do ES populations exist in these same corridors?
Is DOT prepared to revisit Concurrence Point 2 if an ES avoidance alternative is
prematurely eliminated? (USACE)
• Provide survey data for federally listed species in the project study area including
both the new location corridors and the improve existing scenarios. (FWS)
The natural resources investigation will commence after Detailed Study Alternatives
are selected. Therefore, it is unknown at this time whether suitable habitat exists. If
protected mussels are found within the project study area NCDOT will address any
impacts to project alternatives at that time. Natural resource data is not necessary in
determining if a proposed alternative meet,s the project's Purpose and Need. This
type of analysis would be done during the Detailed Study Alternatives (DSAs) ,stage.
OTHER
• Scenario 1- No-Build as a true "Do Nothing" Alternative, without the "minor
improvements" used in the original analysis that are considered TSM improvements.
(WRC)
The " Do Nothing" Alternative does not include TSM improvements.
U-3321 Gaston Gast-Wcst Conneclor Study 8 Kesponse to Merger Tcam Rcquests I
From the July 3, 2002, Purpose and Need package, Section 9.3.2, Design Year Traffic
Volumes for 2025 are shown on page 35. ADT volumes are expected to increase
from 19 to 64 percent on I-85, 31 to 329 percent on US 29/74 and 8 to 88 percent on
US 321. EPA would like to know why there is such an unpredictable wide range of
ADT volume percentages in the design year and which percentages were used in the
traffic models for the alternatives considered. (EPA)
The project study area is 20 miles wide and there are variations thut depend on
where yoac're looking. For exanap[e, a 329 percent increase on US 29-74 is attributed
to where I-485 (a new highway) will irttersect.
U-3321 Gaston East-West Connector Smdy 9 Kcsponse to Merger Team Requests I
? NORT14 CAROLlNA
Turnpike Au#hori#y
Turnpike Environmental Agency Coordination Meeting
TEAC Meeting Protocols & Project Coordination Plans
MEETING MINUTES
(Draft)
Date: December 15, 2006
Time:
Place:
Purpose:
Attendees:
Moming Session - 9:00 am to 12:00 pm
Donnie Brew, FHWA Scott McLendan, USACE
Clarence Coleman, FHWA Kathy Matthews,:USEPA
George Hoops, FHWA Militscher; USEPA
Sarah McBride, NCDCR-SHPO M1ttala Buncick; !USFWS (via phone)
Cathy Brittingham, NCDENR-DCM te*06Wtt,:NCTA
Steve Sollod, NCDENR-DCM
j ? Gail Grimes;'NCTA
John Hennessy, NCDENR-DWQ Jenniferflarris, NCTA
Rob Ridings, NCDENR-DWQ David Joyner, NCTA
David Wainwright, NCDEfi4R?WQ ;
? Bill Malley, Akin Gump
Amy Simes, NCDENR ?
`-` ? y °Jeff Dayton, HNTB
Wally Bowman, NCDOT Division 5, ' Craig Deal, HNTB
-
,
David Chang, NCDOT-Hydraulics nit Donna Keener, HNTB
John Conforti, NCOOT-PDEA Adin McCann, HNTB
Charles Co)? NCDOT PI?EA?; =??,,, Tracy Roberts, HNTB
Missy Dickens, NCDOT-PDFA ?A'

Design?? ,?
Deway4,S?rkes, NCDOT-Road* Christy Shumate, HNTB

Whit Webb, HNTB
Marl? Cham : rs, NCWRC ?`
? Chris LloYd, PB
.
Travis Wlson,;;.?+ICWRC Jill Gurak, PBS&J
Eric Alsmeyer, USACE David Griffin, URS
Bill Biddlecome, U5?ACE
The following items wer??i??ussed during the meeting:
The NCTA opened the meeting with introductions and a brief history of the North Carolina Turnpike Authority
(NCTA). The NCTA was created by the state legislature to enhance project delivery without compromising
environmental responsibility, quality, and safety. The NEPA and Section 404 permitting processes are critical to
accomplishing this goal and the NCTA is aware of the need to advance both together. The agencies were asked to
come to the meetings with open minds and the NCTA vowed to be open and honest with all stakeholders
throughout the coordination process.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 2 of 12
Tumpike Environmental Agency Coordination Meeting Protocols
The Turnpike Environmental Agency Coordination (TEAC) meeting protocols were presented. Several of the
agency representatives recommended that a detailed agenda be sent prior to the monthly meetings. This
information should contain sufficient detail to allow the agencies to determine if their attendance is required. The
NCTA will provide meeting materials prior to the meeting, and it will be at the agencies' discretion to decide on
attendance. These meetings are anticipated to be monthly. "Snapshot" projects may not warrant travel to Raleigh
by out of town agency representatives. Participation for "snapshot" projects may be accomplished through
conference calls. Future meetings may be audio recorded to aid in preparing accurate meeting minutes.
Draft Section 6002 Coordination Plan
The primary purpose of this first TEAC meeting was to review the Section 6002 Draft Coordination Plan. A template
of the Draft Coordination Plan and a table describing the legislative background fat elements of the plan were
included in the Turnpike 101 binders and also distributed to meeting attendees. NCTA is in the process of drafting
project-specific Coordination Plans for the Section 6002 projects - Cape Fear Skyway, Mid-Currituck Bridge, and
Monroe Connector/Bypass. The final Project Coordination Plans will be approved by Fl-11NA-Division Office.
The elements of the draft Project Coordination Plan discussed were: ,..
Section 1: General
The plan meets the requirements for a Coordination` Plan' in SAFETEA-LU Section 6002?
. Section 2: Project Initiation
A project initiation letter will be sent to FHWA at the beginnirig of the study process. FHWA will issue a
Notice of Intent for the project.
Section 3: Project Schedule ;
A project schedule will be attached to each project-specifc Coordination Plan. The schedule will be
developed collaboratively with the agencies, and may be'"updated throughout the project development
process.
Section 4: Agency Roles
Agencies will be identified as tead Agencies, Cooperating Agencies, and/or Participating Agencies in each
Coordination Plan.° OHWA, NCDQT, and NCTA wilt be Lead Agencies for the candidate toll projects. The
definition of a Coopera?ir?g Agenc?+ has not changed witta Section 6002 and will generally consist of
agencies with peRnitting interests in the project. Cooperating Agencies generally are included on the cover
of the NEPA document so filiatthe agencies can Use the document to fulfill their own NEPA requirements.
.
USACE is ty,picapy a,Cooperating Agency for projects requiring an individual Section 404 permit.
A Participating Agencycan be any agency with an interest in a project or any agency that would be
eicpected to provide cornments on a Drait EIS. Cooperating Agencies are a sub-set of the Participating
Agencies.
Section 6002 sets forth a formal process for the Lead Agencies to invite participating agencies. In this
process, one of the Lead Agencies will submit a written request to other agencies inviting them to
participate. Federal agencies are not required to respond; they will be assumed to have accepted the
invitation unless written explanation of their refusal is provided. State and local agencies will be requested
to respond in writing'in all cases.
Section 5: Agency Meetings
Monthly meetings will be used to provide updates to agencies and receive comments from the agencies on
the projects. Meeting materials will be provided in advance; additional materials may be provided at the
meeting, for discussion at future meetings. NCTA is investigating the use of a secure internet site for
storing and distributing meeting materials. NCTA will coordinate with the agencies to determine if this
method of providing information is effective or if other arrangements are required. At a minimum, a detailed
agenda with a list of issues to be discussed and a summary of the previous month's meeting will be
distributed with the meeting announcement. Sufficient information will be provided with the announcement
so that agencies can determine whether it is necessary to attend. The length of the meetings will vary
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 3 of 12
depending on the projects and issues to be discussed. NCTA will coordinate closely with NCDOT to
schedule meetings to coincide with regularly-scheduled Merger Meetings.
Section 6: Identification and Resolution of Project lssues
Agencies should raise any potential issues they have during project scoping. Because many of the
candidate toll projects have a long history, NCTA is aware of many of the potential issues. Previous
comments received from the agencies on NCTA projects will be collected and summar"¢ed. The project-
specific Coordination Plans will include details on how previous agency inputs are incorporated into the
current study.
Attempts will be made to resolve issues informally; however, Section 6002 does provide procedures when
informal issue resolution is not possible.
Section 7: Methodologies and Level of Detail for Altematives Analysis
Methodologies used to screen alternatives and analyze impacts will be determined in coordination with the
cooperating and participating agencies. NCTA will prepare a memorandum summarizing the
methodologies to be used and will obtain agency comments. This wi11 include the level of engineering
detail to be used on designs. In general, NCTA anticipates that functional designs will;,be used to analyze
and compare Detailed Study Alternatives in the Draft:ElS. Preliminary design may be"coiTtpleted on all or
portions of the Detailed Study Alternatives if necessary to satisfy NEPA or permitting requirerrients; the
need for this increased level of detail will be determined ora'a case-by-case basis . In any case, the
Detailed Study Alternatives will be designed to an equivalent level of detail to allow for relative comparison
in the Draft EIS. Preliminary designs will be completed for tFie Preferred Alternative and reflected in the
Final EIS in order to refine the design and further minimize impacts. :; 11 Several of the agencies expressed general suppor# for this approach, noting that in most cases an
increased level of design would not affect the decision on a Preferred Alternative and completing
preliminary design on multiple alternatives is often an inefficient use of time and funds.
No change to the level of investigations for other work' is anticipated; including wetland and stream
delineations, noise studies, and air quality reports.` The NCTA plans to follow existing procedures and
methodologies as used by NCDOT. Section 7.4 (Level of'13etail) of the Coordination Plan should be revised to include the timing for decisions
on bridging and the pracess forpresenting and discussing this issue with agencies.
Sections 8 and 9: Developmant of Purpose and Need 8 Development and Screening of Altematives
NCTA will prepare a`preliminary purpose and need statement and present it to agencies for input. NCTA
envisions that the pwrpose and need will evolve throughout the project and will not seek concurrence on a
written purpose and need.` Additional input on the purpose and need will be solicited from agencies during
the screening of alternativeS. Public input will also be sought at this point on both the purpose and need
and alternatives, and it is possible that based on public comment, the purpose and need would be revised.
Operation as a toll facility may or may not be included as part of a projecYs stated purpose and need, but it
may be used as a considera#ion in screening alternatives. For example, toll feasibility may be used as a
screening criterion where a project would not be financially feasible without implementation of tolls. If the
purpose and nee8 specifically calls for completion of a toll road, the only reasonable alternatives would be
new location alternatives, because under North Carolina law, existing roads cannot be tolled.
Information on potential locations for alternatives, along with environmental constraints mapping, will be
presented to the agencies as early as possible so that potential issues can be identified. This is similar to
scoping in other projects.
EPA noted that they will need to confirm how this process fits with their existing procedures for scoping and
document review and comment. EPA does not normally provide written comments on a project until the
Draft EIS is published in the Federal Register.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 4 of 12
Section 10: Selection of Preferred Altemative/LEDPA
On most projects, a public hearing will be held after publication of the DEIS to collect comments on the
Detailed Study Alternatives. Following the hearing, NCTA will meet with agencies to discuss selection of a
preferred alternative'. NCTA will propose a preferred alternative in a report to the agencies. This report will
address all applicable regulatory requirements, as identified in Section 10.1 of the project-specific
Coordination Plans. The agencies will present comments to the NCTA and FHWA in writing. The FHWA will
identify the Preferred Alternative in the Final EISZ. The FHWA may also request a written indication as to
the likelihood that a permit will be obtained from the appropriate agencies.
Section 11: Avoidance, Minimization, Mitigation, and Enhancement
Avoidance and minimization efforts will be built in to the design process. As mentioned above, the
Preferred Alternative may be developed to a higher level of design for the purposes of considering
mitigation. NCTA intends to use NC Ecosystem Enhancement Program"s (EEP) in-lieu fee program to
comply with mitigation requirements to the extent possible; however, NCTA agrees that opportunities for
on-site mitigation will be identified and considered during project clevelopment.Section 11 of the Draft
Coordination Plan will be revised to separate Section 112 intb subsections for fln5ite Mitigation (11.2.1)
and EEP (11.2.2). Onsite mitigation options would be identified conceptually in the braft EIS and in more
detail for the Preferred Alternative in the Final EIS.
Section 12: Section 4041401 Permitting
Several permits and approvals, in addition to the 404 and 401, woultl be required for most of the turnpike
projects, including Coastal Area Management Act (CAMA) peimits, stormwater management permits,
Federal Emergency Management Agency (FEMA) flood zone?permits, Coast Guard bridge permits, buffer
authorizations, Section 106 consultations, Section 4(f) approvals, and Section 7 consultations. These items
will be included in the project-specific Coordination Plans, as applicable.
The permit application process set forth in the draft Coordination Plan will be revised as follows:
• Sections 12.1 (Early Coordination) and 12.2 (Cb,mrnent Opportunities) will be revised in the project-
specific Coordination Plans to include other agencies ft'om which permits will be required.
• Section 12.4 (F,iling,.of Section 404 PermitApplication) refers to the "permit application" submitted
to USACE alotig 'with fihe Draft EIS that triggers USACE to issue a public notice for the Draft EIS
and public,hearing. This section will be retitled "Request for Public Notice."
• Section, 12.8 (44pdated Pettnit Application aed Decision) will be revised to include Section 12.6
(Section 401 Certification by NCDENR), as well as to include other permits and approvals required
for a project.
• NCT.A will add a section discussing pre-application screening and coordination with permitting
agertcies, including time #or detailed hydraulic design review, which will shorten permit decision
time.
: A timeline for permitting vvith regards to tlesign-build construction will be developed in coordination with the
agencies.
Project-Specific Coordination Plans
Draft Coordination Flans for Cape Fear Skyway, Mid-Currituck Bridge, and Monroe ConnectoNBypass were
distributed. Comment? on these draft Coordination Plans will be discussed at the January TEAC meetings. Local
govemment coordination sections are in the process of being drafted. NCTA requested feedback on the list of
cooperating and participafing agencies, and the extent to which divisions of umbrella agencies, such as DENR,
should be broken out.
DENR and EPA are indicated in the Project Coordination Plans as cooperating agencies; however, neither DENR
nor EPA has traditionally served as a cooperating agency. They will be included as participating agencies.
' The agencies request input on the selection of the preferred altemative at a T'EAC meeting prior to publication of the
Preferred Alternative Report.
Z These procedures wi11 be revisited and coordinated with the agencies in cases where a preferred alternative is identified in the
Draft EIS.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 5 of 12
MEETING MINUTES
(Draft)
Date: December 15, 2006
Time: Spotlight Project - 1:00 pm to 2:15 pm
Place: NCTA Board Room
Purpose: Project Update for Triangle Parkway -
Attendees: `
Clarence Coleman, FHWA
George Hoops, FHWA
John Hennessy, NCDENR Division of Water Quality ?
Rob Ridings, NCDENR Division of Water Quality - TPU
Missy Dickens, NCDOT-PDEA .
Travis Wlson, NCWRC
Eric Alsmeyer, USACE Raleigh '
Steve DeWitt, NCTA
Gail Grimes, NCTA
Jennifer Harris, NCTA
Bill Malley, Akin Gump
Jerry McCrain, EcoScience
Craig Deal, HNTB
Adin McCann, HNTB
Jay Bissett, Mulkey
Johnny Banks, Mulkey
Cindy Carr, Mulkey
Bill Hood, Mulkey
Michelle Fishburne, Mulkey ,,;
Other Agency Representative5 -- see attendees from morning session
The following iterns were discussed during the mee'ting:
Highlight5 of the last agency coatdination meetings held in July and October were reviewed. Based on questions
and comments received from the,agencies at the July coordination meeting, NCTA met with the USACE and
NCDWQ in eacly October to discuss, the McCrimmon Connector. Afthough the McCrimmon Connector was not
officially part of the Triangle Parkway: project, the NCTA studied the connection at the request of CAMPO and the
Town of Morrisville;;, Based on traffic and revenue studies, as well as estimates of construction, operation, and
maintenance costs, the NCTA has determined that it is not fnancially feasible to add this connection to the Triangle
Parkway project. However, it was noted that the I-540 interchange with Triangle Parkway was designed to
accommodate a future ronnection to McCrimmon Parkway, and the Triangle Parkway will be designed to
accommodate a future connectbr to the McCrimmon Parkway. Decisions made for the Triangle Parkway will not
restrict future road design options.
It was noted that Wilbur Smith Associates (WSA) is preparing an investment-grade traffic and revenue study for
both the Triangle Parkway and Western Wake Parkway. The study should be completed in June 2007.
CAMPO's long-range transportation plans show the Triangle Parkway as a non-toll facility. CAMPO is amending
their plan to show the project as a toll-facility. A corresponding air quality conformity update is scheduled to be
completed in June 2007. The conformity update will be completed before FHWA signs the final environmental
document (which is expected to be Finding of No Significant Impact).
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 6 of 12
Constraints that affect roadway design such as the CDC building/GSA property, the EPA property, the Keystone
development facilities, and the expansion of Eisai's facilities were discussed. A bridge over Burdens Creek is
planned and would likely involve reconstruction of the NC 54 bridge. Improvements at the I-40 interchange with NC
147 may be required. Traffic projections are currently being updated and would be reviewed before decisions are
made regarding the I-40/NC 147 interchange. The NCTA is coordinating with FHWA and NCDOT on this issue.
Functional designs for these areas are expected to be available for the January 2007 Tumpike Environmental
Agency Coordination Meeting. Designs for any required improvements to the interchange are expected to remain
within existing ROW limits. Any lane improvements/widening on NC 147 would likely occur in the median.
Preliminary reviews of NC 147 identified a stream located within the existing median.
Current functional designs show that the Kit Creek Drive connection to Davis Drive wiil be cut off by Triangle
Parkway. The Town of Morrisville has concerns this will eliminate east-west mobility along Kit Creek Drive. The
NCTA is evaluating bridge concepts to maintain the Kit Creek connection to Davis Qrive. Based on the initial
concepts, no additional stream or wetland impacts are anticipated as result of this`grade separated crossing.
NCTA will have more information regarding this topic at the January meeting. Access to Davis Drive from Triangle
Parkway is provided at the proposed split diamond interchange.
A handout (figure) showing the schematic locations of the proposed toll plaza facilities was provided to attendees.
The current toll collection concept for the Triangle Parkway included ramp plazas only and would not create
additional stream or wetland impacts. Toll plazas would be located at I-540 ramps and the split diamond
interchange ramps for Hopson Road. The NCTA is evaluating ttie Proposed mainline toll plaza location on I-540P
to determine if additional wetland impacts would occur.
A revised preliminary impacts table was provided; to the attendees. The iab7e includes revised impacts to
residential and commercial properties. Jay noted the proposed cloverleaf interchange design at Davis Drive and
Hopson Drive creates more impacts than the proposed split diamond interchange design. There are no changes to
the stream and wetland impacts as a result of the service"roads proposed between the two interchanges in the split
diamond interchange concept. The split diamond configuration wvald reduce and`minimize perennial stream
impacts, have slightly more intermittent stream impacts; and create the same impacts to non-riparian wetlands as
the cloverleaf design. Stream and wetland impacts have-been avoided alnng Burdens Creek by using a bridge to
completely span this area. A rxiainline toll plaza near Burdens Creek was`also eliminated to reduce stream and
wetland impacts. Stream impacts occurprimarily along intermittent streams. Current functional designs reduce
impacts to perennial streams: The NCTA is currently evaluating how to connect Jenkins Road to maintain
EPA/NIEHS access to the air' q , uality monitoring facility on the horth end of the EPA property. The current Jenkins
Road bridge over Burdens Creek is expected to be retained and used for this purpose. There will be no takes on
EPA property.
Cut and fill slopes will be steepened where possible to reduce potential impacts to streams and wetlands.
Consideration will be given tn'using retainingwalls in some areas to reduce impacts.
A draft concepiual stream relocation plan was distributed to appropriate agencies representatives. The draft plan
focuses on evaluating the possibility of performing on-site stream relocation and mitigation. The NCTA and NCEEP
have discussed th6 availability of off site mitigation through the in-lieu fee mitigation program. The NCEEP has
sufficient credits available for the Tnangle Parkway project in the watershed area. EEP also stated it can provide
mitigation credits for #he Western Wake parkway.
The NCTA would like to have,agency agreement on mitigation strategy prior to the FONSI and permit application.
The EA document is schedaled for March 2007, and the FONSI for July 2007. Construction is anticipated in late
2007.
NCWRC noted the highly erodible Triassic Basin soils disadvantage for on-site mitigation would also apply to any
parallel stream impacts that would require stream relocation. The erodibility problem would apply to stabilization of
relocated streams. The NCTA will keep this in mind as avoidance and minimization measures are implemented
during roadway design.
Approximately 2,900 LF of perennial stream and 3,900 LF of perennial stream would potentially be impacted by the
Triangle Parkway, but the impacts at NC 147 remained to be determined. The numbers on the impact table do not
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 7 of 12
represent subset impacts for individual streams
The NCTA would like to proceed with off-site mitigation through the EEP in-lieu fee mitigation program. The NCTA
pursued off-site mitigation because of agency concerns presented in previous meetings. The NCDWQ conceded
that it is widely known and accepted that Triassic Basin soils are highly erodible. However, Triassic Basin soils
should not be used as the only reason to eliminate consideration of on-site mitigation opportunities. This may
create the idea that stream mitigation should not be done in Triassic soils and that is not the case.
The NCTA noted that the unstable soils issue is one of many potential concerns. There are concerns about
stepping down the stream system to tie-in to existing grade. Other concerns include the fact these are small
stream systems, there is an existing sewer line easement, and the wooded buffer that would need to be removed
for purposes of construction.
Smaller areas of on-site mitigation would be used where feasible to stabilize impacts at culverts and pipes. These
areas could be used to increase mitigation provided on-site by as much as 500 or 1000 LF at each location.
USACE asked if the split diamond design was going to require strearn relocation and create relocation impacts and
if additional ROW could be purchased or condemned by the NCTA to provide mitigation for'Yhese impacts. This
question could not be answered during the meeting. Mitigationissues will be discussed at the JBnuary meeting,
along with updated traffic studies, air quafity information, and fhat an alternative recommendation would be
presented for agency consideration.
The NCTA is working with FHWA to determine the need for operational itnprovements at the NC 147/I-40
interchange. The functional designs and associated impacts will be discussed at the next agency coordination
meeting in January. _
Toll trafFc is expected in January. Preliminary designs wiA be prepared based on the toll traffic data.
The NCTA will provide an information package with the EA for publ'tc notice. The NCTA will coordinate the draft
permit application with the USACE prior to the distribution of the EA and the advertisement of the Public Hearing.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page8of12
MEETING MINUTES
(Draft)
Date:
Time:
Place:
Purpose:
Attendees:
December 15, 2006
Spotlight Project - 2:15 pm to 3:00 pm
NCTA Board Room
Project Update for Westem Wake Parkway
PaNGpants: ? uep(oa: Clarence Coleman, FHWA -'' All Participants
George Hoops, FHWA Ann Steedly, ARCADI5
John Hennessy, NCDWQ Steve Smallwood, ARCAD'IS
Rob Ridings, NCDWQ =- Len HiN; ARCADIS
Gary Lovering, NCDOT-Roadway Design Unit Tysoti Graves, ARCADIS
David Chang, NCDOT-Hydraulics Unit Bamey O'Quinn, ARCADIS
Leilani Paugh, NCDOT-Natural Environment Unit
Missy Dickens, NCDOT-PDEA
Eric Alsmeyer, USACE
Steve DeWitt, NCTA
Jim Eden, NCTA •
Gail Grimes, NCTA
Jennifer Harris, NCTA
Kristina Miller, ARCADIS
Martha Register, ARCADIS ; . Jerry McCrain, EcoScience Corp
Donna Keener, HNTB/NCTAGEC
Tracy Roberts, HNTB/NCTA GEC,
The following items were tiJscussed during the meeting:
A PowerPoint presentation provided the background, current project status, general information and projected
schedule. A'copy of the presentatioh was provided to the participants. More detailed information was included in a
project handoutalso provided to the'meeting participants.
A correction was noted on the Prelitninary Tolling Locations diagram provided to the participants -The Future
Morrisville Parkway,`shown on the diagram north of Carpenter-Fire Station Road, should be located to the south of
Carpenter-Fire Station Road and t'he road north of Carpenter-Fire Station Road is actually Amberly Parkway.
?,.
NCDWQ requested additional information on planned payment methods, especially regarding through traffic.
NCTA described the various types of payment methods currently under consideration (e.g. cash, credit, video
license recognition, call ahead, etc., pending available/current technology).
USACE requested additional information on how collecting of tolls would affect traffic flow, acceleration
weave/merge conditions, especially in regard to the need for additional or lengthened ramps/lanes. The NCTA
noted that traffc flow and potential environmental impacts are being considered in the location of toll plazas.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 9 of 12
NCDWQ questioned if the free altemative route required by NCTA enabling legislation requires that the free
alternative be the same type of facility as the toll route. NCTA responded that the free alternative facility can be any
parallel route, even if it is not the same type of facility as the proposed toll road. NCDWQ requested clarification
whether an ICI (Indirect and Cumulative Impacts) analysis would be prepared for the project prior to permitting. An
ICI is underway for the project.
P-Load model is a nutrient overland-flow model (sediment, nitrogen and phosphorus) and not the more commonly
seen in-stream flow model. The PLOAD model looks at larger scale modeling which is more suited to this project.
NCDWQ also noted that the project schedule which provides three months to process the wetland permit was very
optimistic. The public notice, published by the USACE, is followed by a 30-day public camment period. After the
comment period is closed and the USACE has responsed to the comments, NCDVNQ has'a 60-day clock to
process the permit. NCDWQ requested the NCTA look at their schedule in light of these regulatory response
windows and consider allowing more time for permitting.
NCDOT noted a 4C meeting for Section C of the project is planned fot April 2007. Additianally, final plans for
Section C and preliminary plans for Sections A and B are in preparation.
The Western Wake Parkway project is located entirely within the Cape Fear River basin. -
NCDOT noted that the jurisdictional wetland re-verification for the project has identified some wetlands that have
increased in size due to beaver activity. NCDOT is proceeding from the:hydraulics standpoint with decisions made
during the project 46 meeting regarding the use of, culverts and bridges. In particular, one wetland has expanded
from 250 feet to 400 feet in width and would now likely require a 4-barrel culvet# and not a 3-barrel culvert.
However, if culverts are not feasible hydraulically, NCDO7 w,ill likely bridge the system, but only as wide as
necessary to provide for appropriate hydraulic opening. No objections were voiced to this approach.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 10 of 12
Date:
Time:
Place:
MEETING MINUTES
(Draft)
December 15, 2006
Spotlight Project - 3:00 pm to 4:15 pm
NCTA Board Room
Purpose: Project Update for the Gaston E-W Connector
Attendees:
Clarence Coleman FHWA
George Hoops FHWA
Sarah McBride NCDCR-SHPO
John Hennessy NCDWQ
Dewayne Sykes NCDOT-Roadway Design °
Missy Dickens NCDOT-PDEA
Tony Houser NCDOT- Roadway Design
David Chang NCDOT-Hydraulics
Travis Wilson NCWRC
Marla Chambers NCWRC
Eric Alsmeyer USACE-Raleigh
Chris Militscher USEPA
Marella Buncick USFWS (via phone)
Steve DeWitt NCTA
Gail Grimes NCTA
Jennifer Harris NCTA
Bill Malley Akin Gump
Jerry McCrain EcoScience Corp;.
Jeff Dayton HNTB
Craig Deal HNI"f3T
Adin McCann HNTB"
Tracy Roberts HNTB
Whit Webb HNTB
Jill Gurak PBS&J
Clint Morgan PBSO -,
The following-items were discussed during the meeting:
A PowerPoint presentation provided a review of the project history, studies recently completed, studies in progress,
and next steps undertaken as part of the Draft Environmental Impact Statement (DEIS) process. More detailed
information was included in a project handout also provided to the meeting participants.
Toll scenarios for the Detailed Study Alternatives will be modeled in 2007.
Additional information was requested about the elimination of the "improve" existing alternative from further study.
Concurrence Point 2 was achieved by signature of the Review Board in accordance with the Merger 01 elevation
procedures. The Review Board consisted of senior managers of NCDOT, FHWA, NCDENR, and USACE. The
USFWS, USEPA, and NCWRC elected to abstain from Concurrence Point 2 following the Review Board decision.
They provided reasons for their abstention in letters/emails.
Information requested by the Review Board regarding the Improve Existing Roadways Alternatives was provided to
the Review Board. This was a new process at the time, and distribution protocols were not established. It was
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 11 of 12
assumed that Review Board members would distribute information as needed to the staff in their agencies. The
NCTA will provide the materials given to the Review Board to the agencies.
An Alternatives Development and Analysis Report that documents the entire alternatives development process
currently is being reviewed and will be distributed to interested agencies representatives upon finalization.
FHWA stated that another reason the Improve Existing Roadways Alternative could be eliminated is that funding is
not available to construct the project as a non-toll facility. This can be applied to the purpose and need statement or
as a screening factor when considering alternatives. This was guidance provided by FHWA in relation to a project
in Colorada
The historic architecture field work will be completed in early January. The survey report likely submitted to the
SHPO in March.
The mussel survey report and protected species report will be submitted to USFW5 in early 2009 for concurrence
on the findings. The FHWA requests that all correspondence with USFWS be routed through FHWA.
The agencies requested a field review to inspect natural resources: Functional assessments of jurisdictional
resources will be included in the NRTR. NCTA will apply the bufFer rules on the main stem of the Catawba River
and that they apply only to the main stem.
The geotechnical studies will consider the feasibility of either fill or structure across the fly ash basin at the Allen
Steam Station. The stability of the fly ash basin material will affect houvmuch fill would be needed or how deep
piers would need to be constructed to support a.bridge. The bridge overthe.Catawba River heading westward also
needs to clear an active rail line spur (used by the 5team Station) near the west bank of the river between the river
and the fly ash basin. Clearance requirements over this railroad track may influence the choice of fill or structure.
A preliminary hydraulics report will be prepared during the preliminarydesign process on the Detailed Study
Alternatives to determine bridging and culvert sizes for major stream Crossings needed from a hydraulic standpoint.
The NCTA anticipates that a meeting will be held with environmental agencies to review the hydraulic report results
as well as the results of the jurisdictional,resources surveys.
The DEIS would include a qualitative ICI analysis. A quantitaiive analysis, if necessary, would be performed for the
Preferred Altemative and repor#ed in the FEIS. The Detailed Study Alternatives are relatively close together with
similar interchanges, so indirect and cumuflative impacts are expected to be similar amongst the Detailed Study
Alternatives. The USFWS expre§sed concern about potential indirect and/or cumulative impacts to bald eagle and
to the one small Schweinitz's sunflower;population. Inr3irect and cumulative impacts to protected species will be a
part of the ICai
A questionwas asked about toliing.influencelaffect impacts on the local area, and how will toll collection sites be
determined and where will they 6e located. General locations for potential toll collection sites were identified in the
Traffic and FteVenue Study. These will be considered during the refinements of the Detailed Study Alternatives'
designs. Toll collection facilities will lie included in the footprints of the Detailed Study Alternatives under toll
scenarios.
There are two options for Section 404/401 permitting: one permit with phasing or multiple permits. The NCTA has
made no decision regarding ttiis!"issue on the project. NCDWQ suggested the I-540 project be considered as an
example. This project used:aphased permit, which was amended as funding became available to construct each
section. Time between construction of sections/phases will influence the type of permit used. For example, if there
will be 15 years between the construction of sections/phases, then multiple permits may be appropriate.
There is limited corridor protection available at this time. After a Preferred Alternative is identified, a Corridor
Protection Map can be filed with Gaston County. However, protection is provided for a three-year period beginning
when a subdivision or site plan is filed with the local government. If NCTA does not acquire the right-of-way within
three years, the subdivision petition can proceed. NCTA has limited funds for buying right of way not needed for
near term construction.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
Page 12 of 12
A question was raised regarding staged construction. There are two major north/south routes in southern Gaston
County, US 321 and NC 279. The first phase of the project is proposed to be from NC 279 to I-485. The second
phase would extend westward to terminate at US 321, with the third phase ending the project at I-85. The traffic
and revenue study would consider these phases in determining financial feasibility.
The NCWRC asked if the Gaston project will continue to follow the Merger 01 process and will a Coordination Plan
be created for the Gaston project. A decision regarding the environmental review process to implement for the
Gaston East-West Connector has not yet been made.
The January agency meeting will probably include a snapshot review for Gaston. More discussion will follow in
February and March when the field surveys for wetlands, streams, bald eagle, historic architecture, and
archaeology are complete.
ACTION ITEMS:
• NCTA will provide copies of the materials provided to the Review Board during ihe Concurrence Point 2
elevation process to the agencies.
• NCTA also will provide copies of the Alternatives Development and Analysis Report to the agencies, after
internal NCTA reviews have been completed. `'
• The FHWA will submit the mussel survey report and protected plant„species report to USFWS in early
2007. All correspondence with USFWS be routed through;FHWA.
• Functional assessments for jurisdictional resources will be it1cluded yuvith the NRTR.
Turnpike Environmental Agency Coordination Meeting (12/15/06)
i
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Agenda
January 25, 2007
4? Ongoing Studies
Human Environment
¦ Historic Architecture
¦ Archaeology
Natural Environment (EcoScience GEC)
¦ Natural Resources Subconsultants (Status, progress and updates)
¦ Field Verification Meetings
• USACE and NCDWQ
It* Upcoming Studies
Roadway Design (Status, progress and updates)
¦ Engineering Designs
¦ Traffic Operations Analysis
¦ Hydraulic Studies
Special Technical Studies
¦ Geotechnical Analysis at Fly-Ash Basin
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DRAFT
O1/25/2007
Section 6002 Coordination Plan for Monroe Connector/Bypass Project
TIP Projects R-3329 & R-2559
COORDINATION PLAN
1. General.
1.1. Yurpose. This plan is intended to satisfy the requirement for a Coordination Plan under
Section 6002 of SAFETEA-LU (23 U.S.C § 139).
1.2. Applicability. The plan applies to the Monroe Connector/Bypass project (TIP No.
R-3329 & R-2559), which has been designated by the NCTA as a candidate turnpike
project.
2. Project Initiation
2.1. Project Initiation Notice. The environmental review process for a project will be
initiated when the North Carolina Turnpike Authority submits a project initiation notice
to the FHWA. This notice will be provided in the form of a letter from NCTA to FHWA.
A draft Notice of Intent will be included with this notice.
2.2. Notice of Intent. After receiving a project initiation notice from NCTA, and after
determining that an EIS is needed, FHWA will issue a Notice of Intent to prepare an EIS.
The NOI will be published in the Federal Register.
3. Project Schedule
3.1. Schedule. The NCTA will prepare a project schedule showing projected dates for
completing all environmental studies and permitting. The schedule will conform to
SAFETEA-LU time frames for comment periods and the FHWA "Vital Few Goal" of
achieving a median time frame of three years for completing an EIS. A draft schedule
for the Monroe ConnectorBypass project is attached as Exhibit 1.
3.2. Agency Consultation. The schedule will be shared with the agencies and discussed at a
monthly meeting. Agency comments will be considered and the schedule may be
revised as appropriate.
3.3. Updating Schedules. The project schedule may be revised from time to time by the lead
agencies during the environmental review process. Under the statute, the schedule may
be extended by the lead agencies for good cause, and may be shortened only with the
consent of Cooperating Agencies, if Cooperating Agencies are designated.
DRAFT - 01/25l2007
4. Agency Roles
4.1. Lead Federal Agenc . C'HWA will be the lead Federal agency. As lead Federal agency
in the Section 6002 process, FHWA is responsible for making certain decisions as
specified in Section 6002. In addition, FHWA has an overall responsibility for
facilitating the expeditious completion of the environmental review process.
4.2. Joint Lead A eg ncies. NCTA will be a joint lead agency, and thus will share with FHWA
the responsibilities of the "lead agency" under the process defined in Section 6002.
NCDOT also will have the status of a joint lead agency; however, NCDOT will
primarily have a review/support role in the process, consistent with the Preconstruction
Guidelines adopted by NCDOT and NCTA in July 2006.
4.3. Participating A e. NCTA will issue letters inviting Federal and non-Federal
agencies to serve as Participating Agencies for each project developed under this plan.
Participating Agencies include any Federal, State, or local agencies that may have an
interest in the project.
4.3.1. Invitation List. Invitations will be sent to Federal and non-Federal agencies that,
in the judgment of FHWA and NCTA, may have an interest in the project. Table 1
lists agencies identified as having an interest in the Monroe Connector/Bypass
proj ect.
Table 1: Agency Roles
Cooperating
Agency Participating
Agency
US Army Corps of Engineers ? ?
US Environmental Protection Agency ?
US Fish and Wildlife Service ?
NC Department of Cultural Resources ?
Historic Preservation Office ?
State Office of Archaeology ?
NC Department of Environment & Natural Resources ?
Division of Water Quality
?
Wildlife Resources Commission ?
Mecklenburg-Union Metropolitan Planning Organization ?
4.32. Deadline. Invitation letters will specify a 30-day deadline for agencies to respond
to the invitation.
4.3.3. Federal Invitees. A Federal agency that is invited to be a Participating Agency
will be presumed to have accepted the invitation, unless the agency informs
NCTA in writing, by the deadline, that it: "(A) has no jurisdiction or authority
with respect to the project; (B) has no expertise or information relevant to the
project; and (C) does not intend to submit comments on the project."
DRAFT - 01/25/2007
4.3.4. Non-Federal Invitees. Non-Federal agencies are not required to accept
designation; they become Participating Agencies only if they affirmatively accept
the invitation. If a non-Federal agency declines or does not respond to the
invitation, the agency will not be considered a participating agency.
4.3.5. No Implied Support. Designation as a Participating Agency shall not imply that
the Participating Agency supports a proposed project; or has any jurisdiction over,
or special expertise with respect to evaluation of, the project.
4.4. Cooperating A eg n?. A Participating Agency also may be designated as a Cooperating
Agency. The responsibilities of a"Cooperating Agency" are defined in the CEQ
regulations and are unchanged by SAFETEA-LU. In general, designation as a
Cooperating Agency signifies a somewhat higher level of involvement and responsibi]ity
in the environmental review process. Federal, State, or local government agencies can
Ue designated as Cooperating Agencies. Table 1 identifies Cooperating Agencies for this
project.
4.5. Local Government Coordination. The Mecklenburg-Union Metropolitan Planning
Organization (MUMPO) will serve as the official local representative for the project.
MUMPO staff will be provided the same opportunities for input as other Participating
Agencies. Local municipalities will be kept appraised of project developments through
their involvement with MUMPO. In addition, a NCTA staff member will represent
NCTA at MUMPO Technical Coordinating Committee (TCC) meetings.
5. Agencv Meetings
5.1. Monthly MeetiW. The principal method for agency coordination on turnpike projects
will be monthly meetings hosted by NCTA. These meetings will be used as a forum for
discussing all turnpike projects, including those being studied under other procedures as
well as those being studied under Section 6002. All monthly meetings will be held at the
NCTA office in Raleigh, unless otherwise specified in the meeting invitation.
5.2. Meetiniz Dates. The schedule for the monthly meetings will be determined by FHWA
and NCTA after consultation with NCDOT and the Participating Agencies. This
schedule will be established, to the extent possible, for 12-month periods. The schedule
will be coordinated with NCDOT interagency meetings to avoid or minimize conflicts.
The schedule for 2007 is attached as Exhibit 2.
5.3. Meeting Materials. The materials for each monthly meeting will include an agenda, a
summary of the previous meeting, and (if applicable) other materials to review in
advance of the upcoming meeting. To the extent possible, materials for each monthly
meeting will be provided to the Participating Agencies at the preceding monthly meeting
- for example, the June meeting materials will be provided at the May meeting. Any
materials that are not provided at that time will be posted on a secure web site for
downloading at least one week prior to the meeting. The secure web site also will be
used to make an archive of all monthly meeting materials available to all Participating
Agencies.
DRAFT - 01/25/2007
5.4. Meeting Summaries. After each monthly meeting, the NCTA will prepare a meeting
summary. I'he summary will list the attendees, topics discussed, unresolved issues, and
action items. The Meeting Summary will be provided to the attendees in draft form via
email for their review and comment.
5.5. Attendees. Participating Agencies (including Cooperating Agencies) will designate
primary contacts for Turnpike Projects. These primary contacts will regularly attend
monthly meetings. Attendance may vary from month to month depending on the issues
Ueing discussed. [Agertcies should desigirate a primary contact undprovide contact
inforrnatiort to NCTA.]
6. Identification and Resolution of Yroiect Issues
6.1. Constraint Mapping and Environmental Data. As early as practicable in project
development, NCTA will provide FHWA and the Participating Agencies with mapping
that shows key environmental resources, communities, topographic conditions, and other
constraints in the project area. "I'his mapping also will identify potential conceptual
alternatives for the project, to the extent possible. (An "alternative" at this stage will
generally be defined as a corridor.) The mapping may be accompanied by other
supporting materials.
6.2. Field Visits and Agency Meetings. One or more field visits may be held with
Yarticipating Agencies to discuss constraints and obtain early input into development of
alternatives. Attendees in field visits may be a sub-set of the Participating Agencies,
depending on the issues to be discussed on the field visit. The results of the field visit(s)
will be discussed at a monthly meeting, which will provide another opportunity for
agency input.
6.3. Issues of Concern. After the field visit(s) and monthly meeting, Participating Agencies
will be given a 30-day period to identify any issues of concern, which are defined in
SAFETEA-LU as issues that could result in denial of a permit or substantial delay in
issuing a permit. Issues of concern must be identified in writing. Agencies will be asked
to submit any issues of concern in writing to FHWA and NCTA on agency letterhead.
6.4. Monitorin ag nd Updating. NCTA will maintain a list of the issues of concern identified
by the Participating Agencies. Separate meetings may be scheduled to resolve specific
issues of concern. Additional issues may be added to the list based on new information
or changed circumstances at any point in project development.
6.5. Informal Issue Resolution. Issues of concerns that are not resolved among the regulatory
participants in the monthly meetings can be elevated for consideration by the more
senior officials within the relevant agencies. [Note to reviewers: This is a placeholcler
_f'or developrnent of more sPeciftc lartguage regarding ari issue resolution process]
6.6. Formal Issue Resolution. Under the statute, NCTA or the Governor may request a
meeting at any time to resolve issues of concern. If such a meeting is requested, FHWA
will convene a meeting in accordance with SAFETEA-LU to resolve the specified issues
of concern. If an issue of concern is not resolved within 30 days after such a meeting, a
DRAFT - 01 /25/2007 4
report must be submitted to Congress and to the heads of certain agencies, as provided in
SAFETF,A-LU. If such a meeting is not requested, FHWA and NCTA will seek to
address and resolve the agencies' issues of concern as part of normal agency
coordination during the environmental review process.
7. Methodologies and Level of Detail for Alternatives Analysis
7.1. Proposed Methodologies. Early in project development, NC"TA will prepare materials
outlining proposed methodologies for analyzing alternatives. The materials will
summarize the methodologies intended to be used for each substantive area within the
EIS - noise, air, water resources, traffic issues, secondary and cumulative impacts, etc.
Standard procedures will simply Ue referenced, where applicable. Any modifications to
standard procedures will be identified and discussed in more depth.
7.2. Opportunity for Agency Input. The proposed methodologies will be developed in
consultation with affected agencies. For example, the USACE and NCDENR will Ue
consulted in developing the methodology for analyzing impacts to aquatic resources; the
SHPO will be consulted in developing methodologies for analyzing impacts to historic
sites (including both architectural and archeological resources).
7.3. Ongoing Coordination. Methodologies for alternatives analysis will be refined
throughout the environmental review process. The Lead Agencies will discuss
adjustments, as appropriate, with Participating Agencies at monthly meetings.
7.4. Level of Detail. The Lead Agencies, in consultation with the Participating Agencies,
will determine the appropriate level of design detail for preliminary alternatives, for the
detailed study alternatives, and for the preferred alternative.
7.4.1. PreliminarYAlternatives. In general, functional design will be prepared for all
preliminary alternatives, except for those preliminary alternatives that have a
"fatal flaw" that allows them to be dismissed as unreasonable without a functional
design.
7.4.2. Detailed Studv Alternatives. In general, functional design will be used as the
basis for comparing the impacts of the alternatives in the DEIS (known as the
Detailed Study Alternatives) and will be used for developing the cost estimates
presented in the DEIS. A higher level of design detail may be developed for
Detailed Study Alternatives in some cases; this issue will be discussed with
Participating Agencies in accordance with Sections 7.1, 7.2, and 7.3.
7.4.3. Bridging Decisions. The Lead Agencies, in consultation with USACE and
NCDENR (and, if the appropriate, other Participating Agencies) will determine
bridge locations and approximate lengths for each of the Detailed Study
Alternatives.
7.4.4. Preferred Alternative. The Preferred Alternative may be developed to a higher
level of detail in the FEIS, in accordance with procedures specified in FHWA/FTA
guidance for the Section 6002 process. If phased construction is anticipated, the
DRAFT - 0 1/25/2007
]ligher level of design detail may be developed f'or a portion of the Preferred
Alternative. As allowed under Section 6002, the higher level of design detail may
be prepared for the purpose of developing mitigation measures and/or for
complying with permitting requirements (e.g., Section 404 permitting).
7.5. Lead Agency Decision. If there are disagreements about methodology, or about the
appropriate level of design detail, FHWA and NCTA will seek to resolve those
disagreements with the agencies having the relevant expertise - for example, the SHPO
on historic property issues. After consultation, the lead agencies will determine the
methodology to be used in the NEPA document. The basis for that decision will be
documented in the project file.
8. Development of Purpose and Need
8.1. Preliminarv P&N with Supporting Information. Early in project development, NCTA
will prepare a brief preliminary statement of purpose and need - generally no more than
one page in length. The preliminary statement purpose and need will be distributed to
the agencies. This preliminary statement will be accompanied by supporting information
to the extent that it is available. This information will include:
• GIS map of study area (with study area identified)
• Summary of local concerns that resulted in project addition to LRTP and MTIP
• Traffic data related to project needs
• Justification for designation as turnpike project (based on funding needs, ete.)
• Description of how the action will address the need.
8.2. Discussion at Monthly Meeting. The preliminary purpose and need will be discussed
with the Participating Agencies at a monthly meeting. This will provide an early
opportunity for agency input into the Purpose and Need for the project. In accordance
with Section 6002, the comment period will be 30 days (unless otherwise agreed).
8.3. Ongoing Refinement of Purpose and Need. The purpose and need will be refined, as
appropriate, based on input from the Participating Agencies. Refinement of the purpose
and need may be a gradual, iterative process that occurs during the project development
process, up to publication of the DEIS (and possibly afterward in response to comments
on the DEIS). This process will include an opportunity for agencies and the public to
comment on the purpose and need as part of their review of the alternatives screening
report. (See Part 9.4 and 9.5 below.)
9. Development and Screening of Alternatives
9.1. Conceptual Alternatives. An initial set of conceptual alternatives will be developed as
early as practicable in the process. The conceptual alternatives may be developed
concurrently with the preliminary purpose and need statement. These alternatives will
be provided to the agencies along with the environmental constraint mapping that
provides the basis for identifying issttes of concern. (See Part 6.1 above.)
DRAFT - 01/25/2007
9.2. Alternatives Development. Througll agency coordination and public involvement,
NC"I'A will develop a range of preliminary alternatives for consideration. This range
may extend beyond the initial set of conceptual alternatives. This effort is intended to be
comprehensive and inclusive. NCTA will maintain a summary of all alternatives
suggested Uy Participating Agencies and the public.
9.3. Alternatives Screening Report. The NC"I'A will prepare an alternatives screening report
that presents the justification for eliminating alternatives from further consideration, and
identifies alternatives proposed for detailed study. The alternatives screening report will
Ue provided to the Participating Agencies and discussed in a monthly meeting.
9.4. OpporiLmity for Public Input. A summary of the alternatives screening report will be
made available for public review and comment. A public meeting (or meetings) will be
held in the project area during the public comment period on this report. This comment
period will serve as the public's opportumity for involvement in both developing the
purpose and need and determining the range of alternatives to be considered in the EIS.
A report summarizing public input will be provided to Participating Agencies. Agencies
will be given notice of the public meeting and will be welcome to attend.
9.5. Opportunity for Agency Input. Participating Agencies will be given a 30-day period to
provide additional comments on the alternatives screening report following distribution
of the report summarizing public comments. Participating Agencies will not be asked to
concur in the alternatives screening report. Participating Agencies will be asked to
submit any significant objections to the alternatives screening report in writing to FHWA
and NCTA on agency letterhead.
9.6. Lead Agency Decision. The Lead Agencies will decide how to proceed based on the
comments received from Participating Agencies and the public. If there are unresolved
issues, the Lead Agencies will continue to address those issues through ongoing
coordination with the Participating Agencies as the process moves forward.
10. Selection of Preferred Alternative/LEDPA
10. 1. Preferred Alternative Report. The NCTA will prepare a report identifying its preferred
alternative and the justification for selecting that alternative. The report will address all
applicable regulatory requirements, such as Section 404 and 401 of the Clean Water Act,
Section 4( fl of the USDOT Act, and the North Carolina Coastal Area Management Act.
The report will be prepared in coordination with FHWA.
10.2.Opportunity for Agenc,y Input. The NCTA will provide FHWA, NCDOT, and all
Participating Agencies with a copy of the preferred alternative report. The report will be
discussed at a monthly meeting. Agencies will be provided with a 30-day period to
comment on the report after the meeting. Agencies will not be asked to concur in this
report. Agencies will be asked to submit any significant objections in writing to FHWA
and NCTA on agency letterhead.
10.3.Lead Agency Decision. FHWA will formally identify its preferred alternative after
considering all written comments received from Participating Agencies. Typically, the
DRAFT - 0 1/25/2007 7
F}-IWA's preferred alternative will Ue identified in the FEIS. It could be identified in the
DF.,IS, if the above actions are completed prior to publication of the DEIS.
ll. Avoidance, Minimization, Mitimation, and Enhancement
11.1. Integration into Project Development. Opportunities to avoid, minimize, and mitigate
impacts, and to enhance the impacted resources, will be considered throughout the
process, including during initial development of alternatives. As allowed under
Section 6002, the preferred alternative may be developed to a higher level of detail for
purposes of developing mitigation measures and meeting permitting requirements.
11.2. Required Compensatory Miti a? tion. "I'he Lead Agencies will consult with USACE and
NCDENR to determine the type, size, and location of required compensatory
mitigation for impacts to waters of the United States.
11.2.1. On-Site Miti a. The potential for on-site mitigation for impacts to waters of
the United States will be considered in the DEIS for each of the Detailed Study
Alternatives. This discussion will typically include a discussion of conceptual on-
site mitigation locations. The potential for on-site mitigation will be discussed in
more detail for the Preferred Alternative in the FEIS.
11.2.2. Off-Site/Ecosvstem Enhancement Program (EEP). Where applicable, the NCTA
will coordinate with the Ecosystem Enhancement Yrogram (EEP) during project
development and design regarding the use of credits from the EEP to meet
mitigation requirements for impacts to waters of the United States.
12. Section 404/401 Permitting and Other Permits/Approvals
12.1. Early Coordination. NCTA will conduct early coordination with the Participating
Agencies to identify applicable permitting requirements and to determine the analysis
and documentation required to satisfy those requirements. See Parts 6 and 7 above.
Permits/approvals that may be applicable to this project include:
• Section 404/401 Permits
• Section 7 approval
• Air quality conformity compliance
12.2. Comment Opportunities. The Participating Agencies will be invited to provide written
comments at several points in the process as noted above. The Lead Agencies will
consider all written comments submitted by the Participating Agencies. If a
Participating Agency raises an issue of concern (defined as issues that could delay
issuance of a permit or result in denial of a permit), the Lead Agencies will confer with
that agency, and with other agencies as appropriate, to address those issues.
12.3. Jurisdictional Determinations. The NCTA will prepare the necessary documentation to
obtain jurisdictional determinations by the USACE (and, as appropriate, NCDENR) for
all wetlands and streams within a conidor along each of the detailed study alternatives
DRAFT - 01/25/2007 8
(unless otherwise determined as part of the discussion of inethodologies in accordance
with Section 7 of this plan). These determinations will be used as the basis for
comparing wetlands and stream impacts in the DEIS. The width of the corridor within
which jurisdictional determinations are made will be determined on a project-by-
project Uasis.
12.4. Pre-Application Consultation. 'I'he NCTA will engage in pre-application consultation,
as appropriate, with each agency that is responsible for making a permit decision on
the project. For projects requiring a Section 401 and Section 404 permits, the pre-
application consultation will include a detailed hydraulic design review.
12.5. Request for Public Notice. "1'he NCTA will submit the Section 404 permit application
to the USACE at the time the DE[S is issued. This application will typically be
suUmitted prior to identification of a preferred alternative; thcrefore, it typically will
not identify the specific alternative for which the permit is being requested. This
submittal will enable the tJSACF, to issue a public notice and to use the FHWA/NCTA
public hearing on the DEIS as the USACE's public hearing on the Section 404
application. [Note: This could be modified on a ease-by-case basis. J
12.6. Public Hearing. The public hearing on the DEIS will also serve as the public hearing
for the Section 404 permit application. [Note: This coul(l be iuoclqiecl on a case-by-
case hasis.J
12.7. Refining the Permit Application. After selection of a preferred alternative, the NCTA
will coordinate on a regular basis with the USACE, NCDENR, and other agencies as
appropriate regarding the Section 404 and Section 401 permit applications for the
project. This coordination may occur as part of the monthly meetings and/or in
separate meetings convened to discuss permitting issues. These meetings will include
discussions of:
• avoidance and minimization measures
• compensatory mitigation
• review of hydraulic design [the process for this review will be defined more
specifically in project-specific coordination plans]
• review of stormwater management plans
• review of final permit drawings
12.8. Permit Application and Decision. After the permitting meetings described above, the
NCTA will submit an updated Section 404 permit application to the USACE and a
Section 401 certification request to NCDENR. Permit applications under other
applicable laws (e.g., a bridge permit, or a CAMA permit) will also be filed.
12.9. Permit Decisions, The NCDENR and the USACE will consider and act upon the
Section 401 and Section 404 submittals in accordance with their procedures.
DRAFT - 01/25/2007
12.10.Permitting Delav_. If a Section 404 permit (or any other permit or approval) is not
issued within 180 days after the FHWA issues a ROD and a complete permit
application is submitted, the USDOT will be required by Section 6002 to submit a
report to the Congress - specifically, to the Committee on Environment and Public
Works of the Senate and the Committee on Transportation and Infrastructure in the
House of Representatives. Reports must be submitted every 60 days thereafter until
the issue is resolved. The same requirement applies to other permitting decisions.
DRAFT - 01/25/2007 10
Exhibit 1
PROJECT SCHEDULE
Notice of Intent Winter 2007
Identify Detailed Study Alternatives TBD
DEIS TBD
Identify Preferred Alternative TBD
FEIS TBD
ROD TBD
Permit Application(s) TBD
Let Contract/Begin Construction TBD
DRAFT - 01/25/2007
Exhibit 2
t: -.-.N"9.4 2C-!? ?.:Oll
2007 CONCURRENCE AND INTERAGENCY MEETINGS
?FEBRUARY
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-State and Federal Holidays
Eastern Concurrence Meetings
ill i]
Interagency Meetings - Mornings
Western Concurrence Meetings
' Eastern Hydraulics Meetings Western Hydraullcs Meetings
' NC Turnplke Authority East NC Turnpike Authorlty West - Afternoon
NC Turnpike Authority East & West
DRAFT - 01/25/2007 12
Gaston E-W Connector
Agenda
January 25, 2007
?1? Ongoing Studies
? Human Environment
¦ Historic Architecture
¦ Archaeology
i Natural Environment (EcoScience GEC)
¦ Natural Resources Subconsultants (Status, progress and updates)
¦ Field Verification Meetings
• USACE and NCDWQ
? Upcoming Studies
?Roadway Design (Status, progress and updates)
¦ Engineering Designs
¦ Traffic Operations Analysis
¦ Hydraulic Studies
? Special Technical Studies
¦ Geotechnical Analysis at Fly-Ash Basin
' NORTH CARflLiNA
??"?? Turnpike Au#hority
?
? NORTH CAROLINA
?tirnpike Avthority
GASTON E-W CON N ECTOR
January 25, 2007
Description
New location roadway from I-85 west of Gastonia in Gaston County to NC 160 in Mecklenburg
County. Project is a candidate toll road facility.
Purpose
• Improve mobility, access, and connectivity in southern Gaston County between southern
Gaston County and Mecklenburg County
• Reduce congestion and improve traffic flow on the sections of I-85, US 29-74, and US 321 in
the project study area
• Improve high-speed, safe regional travel service along the US 29-74 intrastate corridor
• Generally improve safety and reduce above average rates in the project study area
Length
21.5 miles
Estimated Cost
$715M to $1,525M (January 2007 dollars)
Free Alternate Route
Existing I-85 or US 29-74 through Gaston and Mecklenburg Counties
Typical Section
Six lane facility with a new crossing over Catawba & South Fork Rivers
Timeline (draft)
Financial feasibility study
Draft environmental report
Final environmental report
Issue Record of Decision
Award construction contract
Project opening
October 2006
February 2008
July 2009
January 2010
May 2010
2015
Current Activities
• Field surveys for natural resources (wetland and stream delineations, bald eagle surveys),
historic resources, and archaeological resources are in progress and near completion.
• Starting design and traffic analysis.
• Starting community profile and qualitative indirect and cumulative effects assessment.
Future Activities - February TEAC Meeting '.
• Field Verification Meetings with USACE and NCDWQ.
• Present findings of field surveys for natural resources (wetland and stream delineations, bald
eagle surveys), historic resources, and archaeological resources.
Turnpike Agency Coordination Meeting
1/25/07

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September 27, 2004
Ms. Kristina Solberg, P.E.
NCDOT Project Manager, PDEA
North Carolina Department of Transportation
1584 Mail Service Center
Raleigh, North Carolina 27699-1584
RE: Written Brief to Merger 01 Process Review Board: NCDOT Elevation Process for
TIP Number U-3321, Gaston East-West Corridor Study (Proposed "Gaston
Freeway" or "Garden Parkway"), Gaston and Mecklenburg Counties; Federal
Project Number STP-1213(6); State Project Number 8.2812501
Dear Ms. Solberg:
This letter and attachment represents the U.S. Environmental Protection Agency's (EPA)
formal response and written brief to the North Carolina Department of Transportation's
(NCDOT) notice of potential elevation for the above referenced Merger 01 project. By copy of
this letter, EPA is providing the same information to the Merger 0 1 Process Review Board
members consistent with the Implementation Guidance for Conflict or Dispute Resolution
executed on October 20, 2003.
It is my understanding that this is the first `formal elevation' of a NCDOT Merger 01
project. While EPA has not yet been offered the opportunity to be a formal signatory agency to
the Merger 01 Implementation Guidance, EPA believes that the Conflict or Dispute Resolution
agreement is a reasonable method of trying to resolve issues when the Merger team agency
representatives can not agree or reach consensus. However, EPA and NCDOT are bound to the
Inter-Agency Agreement (IAG #RW-NC-94591501-0) provisions regarding disputes contained at
Item VI.4.a, Mutually Understood Conditions. It is recognized in the IAG that the NEPA/404
merger process was being updated and may include specific dispute resolution guidelines that
could include EPA. EPA management officials were not invited to review the Merger Ol
Conflict or Dispute Resolution Implementation Guidance prior to its execution by NCDOT, the
North Carolina Department of Natural Resources (DENR), the U.S. Army Corps of Engineers
(ACE) and the Federal Highway Administration (FHWA).
As stated in the IAG, resolution of the issue will require mutual cooperation by both
parties. After the Interim Concurrence Point 2 meeting on September 9, 2004, and the notice of
potential elevation by the NCDOT , Mr. Militscher of my staff went to your office on 5eptember
10`h to request that another Merger meeting be scheduled the week September 13th to try to reach
a compromise amongst the Merger team agencies. Mr. Militscher also requested the same of Mr.
Derrick Weaver, PDEA Unit Head. With the exception of the Division of Water Quality (DWQ)
representative who was not able to attend the September 14`h meeting due to late notice, that pre-
elevation Merger meeting ended without the interim concurrence which NCDOT (and FHWA) is
seeking.
The attachment to this letter outlines EPA's specific concerns and rationale for its
position. The scope and magnitude of the proposed project will result in irreversible changes to
the nature and character to half of Gaston County and the regional planning area. The proposed
Draft Environmental Impact Statement (DEIS) should, "rigorously explore and objectively
evaluate all reasonable alternatives, ...." [CEQ: 43 FR 55994, Section 1502.14(a)]. EPA is
convinced that a combination of potential improvements to the existing failing facilities (I-85 and
US 29/74) along with other possible system improvements is a feasible alternative worthy of
further consideration.
EPA has in the past supported the elimination of alternatives for numerous Merger
projects where the detailed transportation and environmental analysis conducted by NCDOT
clearly shows that these alternatives do not justify further consideration under NEPA and clearly
do not meet the purpose and need. However, NCDOT has not conducted even a cursory
environmental analysis for the other "No-build Alternatives". There are over 70 potential
Transportation System Management (TSM) measures which have not been discussed by the
Merger team representatives in any detail. Furthermore, EPA disagrees with some of the key
assumptions in the preliminary transportation analysis and some of the necessary analyses have
not been conducted (e.g., Mass Transit Alternative: Future Transit Ridership Assumptions in
MPO's Travel Models - Gaston: N/A - Not specifically included in models).
In summary and conclusion, EPA would encourage NCDOT and FHWA to consider a
compromise position to dropping all of the alternatives except for the "No-build" and "Build a
New Location Freeway" at this stage of the NEPA process. EPA believes that some of the "No-
build Alternatives" (e.g., Scenario 4+ and Mass Transit with TSM for I-85 and US 29/74) do
meet the stated purpose and need in total or in part. Thus, all reasonable and feasible alternatives
should be carried forward for detailed study to the DEIS stage in order to allow the public and
decision-makers the opportunity to comparatively evaluate a full range of alternatives.
Furthermore, performing detailed environmental studies for a full range of alternatives by
NCDOT is consistent with past efforts for proposed new location highway projects under the
Merger process. EPA would be willing to sign a Partial Concurrence Point 2 form which
includes at least some "No-build Alternatives".
We appreciate your consideration in this matter. Thank you.
Sincerely,
Heinz J. Mueller, Chief
NEPA Program Office
Office of Policy and Management
Attachment
Review Board Members:
S. Kenneth Jolly, Chief, Regulatory Division
U.S. Army Corps of Engineers - Wilmington District
Dempsey E. Benton, Chief Deputy Secretary
North Carolina Department of Natural Resources
Roger E. Sheats, Jr., Deputy Secretary
North Carolina Department of Transportation
Don Voekler, Assistant Division Administrator
Federal Highway Administration
cc: A. Stanley Meiburg, EPA Deputy Regional Administrator
Russell L. Wright, EPA Assistant Regional Administrator
Gregory J. Thorpe, Ph.D., NCDOT, PDEA Director
ATTACHMENT
Clarification on `Concurrence':
NCDOT has provided a misstatement of fact in its September 9, 2004, e-mail regarding
the Notice of Potential Elevation following the August 17, 2004, Partial Concurrence Point 2
meeting. EPA has not a rg eed that Mass Transit or combinations of other No-build Alternatives
do not meet the purpose and need (P/N) for the project and should not be carried forward as
Detailed Study Alternatives (DSA). At no time during the August 17`h meeting or subsequent to
that meeting has EPA's Merger team representative stated verbally (or provided in writing) that
Mass Transit or a potential combination of the No-build Alternatives do not meet the purpose
and need statement. Mr. Militscher left the meeting in order not to be late for the scheduled 1:00
pm Merger meeting (R-2597). NCDOT did not allow sufficient time for the August 17'h meeting
for agency comments on the "No-build Alternatives" and a large part of the 3-hour meeting was
consumed by the several PBS&J consultants.
Subsequent to the August 17`h meeting, NCDOT did provide a copy of the Gaston County
Air Conformity Analysis as requested. However, NCDOT has not addressed the specific issue
raised by Mr. Militscher during the August 17`h meeting regarding `induced travel' from a New
Location facility. This information and the underlying assumptions involving `promoting'
increased traffic within the project study area are critical in understanding and analyzing future
air pollutant emissions. The responses EPA received regarding potential air quality issues for
the New Location Alternative within the Charlotte-Gastonia-Rock Hill Subpart 2 Moderate 8-
hour Ozone Non-attainment Area were curt and `non-responsive'.
Project History:
EPA is concerned that some of the `verbal commitments' to the resource agencies
including EPA by the former NCDOT Project Manager (Ms. Jennifer Harris, P.E.) for this
project are not being taken seriously by the current NCDOT Project Manager. Ms. Harris
assured Mr. Militscher and other agency representatives during the P/N meetings that all No-
build Alternatives, including Mass Transit, would be given full consideration during the
development of alternatives. EPA understood this prior commitment to mean an equitable
environmental analysis of these alternatives as well. This commitment has not been met in
EPA's view of NCDOT's refusal to provide detailed study for one or two of the "No-build
Alternatives" (Scenarios described as 2, 3, 4 and 4+ in the August 17`" handout and the
TSM/TDM Alternative and the Mass Transit Alternative).
The No-Build Alternatives:
NCDOT has not provided an equitable environmental analysis of the No-build
Alternatives. For example, for the Mass Transit Alternative, the "Pros and Cons" are cursory,
not supported by coordinated planning studies and generally inaccurate. In addition to providing
increased mobility and connectivity, Mass Transit would also provide potentially less capacity
demand at peak hours on current failing roadways. Mass Transit is generally more
`environmentally-friendly' and would potentially result in less impacts to the human and natural
environment (e.g. Less business and residential relocations, less wetland and stream impacts,
etc.). Mass Transit is potentially safer than a New Location Freeway. Mass Transit, if designed
properly, is a more efficient means of transportation. Connection of a`Light Rail' system to the
Charlotte International Airport at the eastern termini with bus connections to other points around
Charlotte would be an ideal commuter station. None of these "Pros" made it into the meeting
materials. Ridership studies were not performed by Gaston County in their model and NCDOT
has very possibly underestimated future ridership interest between the commuting areas of
Gastonia and Charlotte. To the contrary of NCDOT's post-meeting e-mail comments, EPA
believes that a Mass Transit Alternative combined with specific Traffic System Management
(TSM) measures and some "Improve-Existing" options fully meets the P/N and is a reasonable
and feasible alternative which should be given full and equitable consideration in the DEIS.
Similarly, the analysis provided for the Scenario 4+ Alternative (i.e., Improve Existing
Roadways Alternative with TSM measures) also understates the benefits derived from this
alternative compared to a New Location Facility. In addition to `maintaining level of service'
(LOS) and reducing accident rates after the construction period, this alternative would also
potentially improve connectivity between Gaston and Mecklenburg Counties by widening
existing bridges over the South Fork of the Catawba River and the main stem of the Catawba
River. With TSM measures, there would also be improved mobility within the project study
area. This alternative may also be more `environmentally-friendly' and result in less induced
travel and air pollution, less wetland and stream impacts, etc. This alternative may be more cost-
effective than a New Location Freeway. NCDOT points to the "Con" of not providing
connectivity to southern Gaston County. The P/N does not state that this is where the
connectivity must occur and that the existing facilities are located in the agreed to project study
area. However, without a full NEPA analysis, NCDOT proposes to eliminate this alternative
from further detailed study by rhetorically stating it does not meet the P/N. EPA believes that an
Improve-Existing Alternative combined with specific TSM measures fully meets the P/N and is a
reasonable and feasible alternative which should be given full and equitable consideration in the
DEIS.
Another issue of concern for EPA is the idea that even with the construction of a$600
million New Location Freeway, the LOS for critical segments along I-85 and US 29/74 in the
2030 design year will continue to be LOS F(F+ as qualified by FHWA). Thus, the New
Location Freeway does not completely improve conditions along the failing roadways in the
design year and NCDOT acknowledges that additional TSM and other improvements will be
necessary even after the New Location Freeway is constructed. Because of the full scope and
intent of the P/N can not be met even with the New Location Alternative in the design year of
2030, NCDOT needs to fully consider and evaluate additional reasonable and feasible
alternatives.
The Merger Process:
EPA is very disappointed that consensus could not be reached at the Partial Concurrence
Point 2 meeting. EPA is equally disappointed that NCDOT and its consultant have not
efficiently used resource agency time during the Merger Process. Most significantly, EPA was
very troubled by the method in which NCDOT developed the New Location Freeway corridors at
the February 17, 2004, Partial Concurrence Point 2 meeting for the New Location corridors.
EPA and other resource agencies were asked to review and eliminate corridor segments from
over 90 individual roadway segments. EPA's representative to the Merger team is not a highway
design engineer. It was not an efficient use of his time to painstakingly go over more than 90
permutations of roadway segments to develop the New Location Corridors. The NCDOT
consultant also had last minute revisions which were not provided ahead of time to the resource
agency representatives who tele-conferenced into the meeting (e.g. FWS, WRC). This further
confused and delayed this process. An indeterminate number of segments were eliminated
based upon hiQhway design criteria and not environmental constraints. This multi-agency/multi-
discipline method of developing NCDOT highway corridors is not consistent with current
Merger 01 Implementation Guidance or TEA-21 streamlining initiatives. On other large-scale,
proposed new location Merger projects, NCDOT develops a dozen or so viable transportation
corridors based upon highway design criteria, identifies the environmental constraints, and the
Merger agencies work together to modify, delete, add or adjust these NCDOT proposed corridors
based upon the environmental constraints. EPA's representative cooperated fully with NCDOT
during this `highway corridor development" meeting but found it to be a very inefficient method.
EPA understands that other resource agency representatives shared similar concerns.
The current Merger 01 Implementation Guidance does not specifically address "Partial
Concurrence Points". EPA acknowledges the potential scope and magnitude of the proposed
project and the complexity of issues. However, EPA does not prefer this piecemeal concurrence
approach. EPA would prefer that several days (if needed) be scheduled in advance (e.g., In May
of 2005 when NCDOT has identified another Partial Concurrence Point 2 meeting to further
eliminate New Location Corridors) to identify all reasonable and feasible alternatives needed to
be evaluated in detail in the DEIS. The U-3321 project is listed as an NCDOT priority project
for Division 12 and is assigned to a TIP Program Manager. EPA has not seen any difference in
PDEA/NCDOT resource commitment or priority of scheduling from that of any other Merger
project. ,
There are 3 pages of identified TSM locations provided in the August 17`h Merger team
meeting handout (Pages 7-10 from July 14`h Partial concurrence Point 2 meeting package). The
Merger team has not discussed any specifics of these potential improvement CORSIM analysis
targets. Unlike the efforts to identify New Location Corridors, NCDOT has not allowed
sufficient time nor emphasized the approximate 70 TSM improvement options included in the
handouts.
NEPA/CEQ Regulations:
Under Section 1502.14 of the CEQ regulations, `Alternatives including the Proposed
Action', the first sentence stresses: "This section is the heart of the environmental impact
statement." EPA believes that a true comparative form for the alternatives can not be obtained as
addressed in this section of the CEQ regulations by eliminating all but a"No Action" and "Build
a new Freeway" alternatives without providing a detailed environmental analysis for all
reasonable and feasible alternatives. Furthermore, NCDOT and FHWA have verbally identified
that even with a new Freeway alternative, an undisclosed number of TSM measures and other
improvements will eventually be required for the existing roadways (I-85 and US 29/74)
although this issue has not been confirmed in writing.
Under EPA's NEPA regulations under 40 CFR Part 6, Section 6.506(5), it further
addresses the issue of alternatives covered in the NEPA document including the reasons for
rejecting an alternative and disclose any significant environmental benefits precluded by such
rejection. The decision-makers and the public will be unaware of any potential environmental
benefits from other `No-build alternatives' if they are eliminated at this stage of NEPA planning.
Public Disclosure:
EPA is concerned that a full public disclosure of the reasonable and feasible alternatives
will not be included in the DEIS. The proposed new Freeway represents a potential $600 million
investment in public dollars which will irreversibly and permanently alter the character and
quality of life in half a county and the Gastonia region. For NCDOT and FHWA to dismiss Mass
Transit and other reasonable and feasible alternatives without providing a detailed environmental
analysis and without first obtaining public feedback from the DEIS is premature and contrary to
the spirit and intent of NEPA.
Air Quality:
Gaston County is located in the Gastonia-Charlotte-Rockhill Subpart Moderate 8-hour
Ozone non-attainment area under the Clean Air Act. EPA requested during the August 17`n
meeting some indication from FHWA and NCDOT on the potential for induced travel with the
New Location Freeway alternative. It is understood by EPA that there will be offsetting
gains/losses in air pollutant emissions. To date, EPA has not seen a specific traffic analysis
showing induced travel from the New Location Freeway Alternative.
Threatened & Endan erpecies:
EPA has learned from FWS and WRC that there may be a potential for threatened and
endangered mussels to exist within the project study area, including the streams and tributaries to
the South Fork of the Catawaba River and the main stem to the Catawba River. FWS has
indicated during past meetings that biological surveys need to be conducted and a true
`avoidance' alternative should be developed consistent with Section 7 of the Endangered Species
Act. The "No-build" or "No Action" alternative is not viewed by EPA as an avoidance
alternative (Contrary to statements from NCDOT and FHWA). The `No Action' does not satisfy
the P/N. The `No Action' is not viewed by EPA as an avoidance alternative as it does not
commit any action to solve the identified transportation needs. EPA and other agencies have
signed Concurrence Point 1 acknowledging that there is a demonstrated transportation problem
along the I-85 and US 29/74 corridors and the `No Action' does not address this need. If the
threatened or endangered species are found within the New Location Freeway corridors (which
all cross the Catawba River: South Fork & main stem), there will be no reasonable and feasible
avoidance alternative to evaluate.
Other Issues (Funding, Toll Authority, and Economic Development)
Apparently, this project has only funding for planning and environmental studies.
Therefore, it is unclear why this TIP project has taken on such a priority for Merger Process
Concurrence Point decision-making when it is not programmed for funding through the 2004-
2008 TIP.
There have been newspaper accounts that the proposed "Garden Parkway" or "Gaston
Freeway" is to be the top priority for the NCDOT to create a toll road. This issue was not
addressed during the August 17`h Partial Concurrence Point 2 meeting or other Merger meetings.
EPA was not aware that the NC Legislature created a toll authority ("Turnpike Authority") in
October of 2002 which would seek funding from the NC Legislature and administer the proposed
New Location Freeway. NCDOT needs to discuss and explore this issue with the resource
agencies and other interested parties. Any foreseeable actions regarding a possible toll facility
should be fully disclosed in the NEPA process and should be considered in the traffic and
environmental analyses for the alternatives.
During the August 17'h and September 14`h meetings, it became apparent to EPA and
other agencies that the Gaston MPO representative stressed that a`fairly good' part of the need
for the proposed New Location Freeway is for economic development in southern Gaston
County. Economic development was not substantiated during the P/N concurrence process and
has not been documented by neither NCDOT/FHWA nor local planning officials. This
underlying desire to accommodate additional development and sprawl by providing the access
and right-of-way would require that a full Indirect and Cumulative Impact analysis be performed
by NCDOT.
Merger Review Board Elevation Meeting
Gaston East-West Connector
TIP No. U-3321
October 27, 2004
AGENDA
10:00 am Welcome Roger Sheats
10:05 am Introductions Roger Sheats
10:10 am Project History Derrick Weaver
10:15 am Member Brief's Drew Joyner
(time keeper)
GUMPO
MUMPO
NCDOT
FHWA
NC WRC
NCDWQ
USFWS
USEPA
USACE
10:45 am Review Board Questions
11:45 am Summary / Closing Remarks Roger Sheats
12:00 am Adjourn
?o?o? V V ' r9pG
O Y
Briefing Paper for Review Board
October 27, 2004
Primary Issues - The DWQ has two fundamental concerns associated with the premature
elimination of alternatives:
• Circumvents the Avoidance and Minimization Process
• Delays in 404/401 permitting due to incomplete alternative analysis
Purpose and Need
Approved Purpose and Need
The purpose of the proposed action is to improve east-west transportation mobility in the area
around the City of Gastonia, between Gastonia and the Charlotte metropolitan area in general,
and particularly to establish direct access between the rapidly growing area of southeast Gaston
Counry and west Mecklenburg County. The project purpose is based on the following:
¦ Improve mobiliry, access, and connectivity in southern Gaston Counry and between southern
Gaston County and Mecklenburg Counry.
¦ Reduce congestion and improve traffic flow ori the sections of I-85, US 29174 and US 321 in
the project study area; improve high-speed, safe regional travel service along the US 29-74
intrastate corridor; and generally improve safery and reduce above average accident rates in
the project study area.
Prior to agreeing to the Purpose and Need statement, the DWQ asked if the statement as
written would preclude a fair assessment of non-new location alternatives. DWQ was
assured both orally and in writing that a broad interpretation of the Purpose and Need
would be employed during the planning of the project, and that a full and fair assessment
of all alternatives would be considered:
The following statement is taken from the official May 15, 2002 meeting minutes
The Statement of Purpose and Need repeatedly uses the term "southern Gaston County", is that
the area we're talking about south of 1-85?
Southern Gaston County is expected to receive the most growth based on the Comprehensive
Land Use Plan, but we are referring to east-west transportatian needs and not ju.rt southerrc
Gaston County. It was not the intent to pre-suppose any alternatives at a specific location, such
as ruling out alternatives for improved connectivity north of'I-85. The document will he reviewed
in this light and revised accordingly.
No e hCarolina
Transportation Permitting Unit QtllClllly
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, Norih Carolina 27604
Phone: [phone] / FAX 919•733-6893 / Internet: http://h2o.enr.state.nc.us/ncwetlands
wuuliaei F. cabitiy, iaUVeinui
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
An Equal OpporlunitylAflirmative Action Employer - 50% Recycled/10°/a Post Consumer Paper
Impacts and Alts Developed
At this time, we do not believe that the non-new location alternatives have received a full and
fair assessment when compared to the new location alternatives.
In the position paper submitted by the DOT it was stated that traffic modeling on 4+
alternative was not developed. It was assumed that the alternative would not work. See
statement below:
Becaicse of operational deficiertcies identifiecl in Scenario 4, numerous TSM-tyPe
irrtprovetnents along US 29-74 were incorporated into Scenario 4, resulting in Scenario
4+.
The corridor-level model wa.r not rerun for these improvements. It is likely that making
these improvements would simply shift the congestion farther downstream. The regional
demand model runs already completed show that improvements made to US 29-74 and
existing 1-85 continue to attract more traffic due to the latent travel demand in the area,
resulting in a"build it and they will continue to come" situation. The cycle of making
recommended improvements, running the model, identifying new ureas of congestion,
making those improvernents, then running the model again, was not necessary to
adequately evaluate the ability of the Improve Existing Roadways Alternatives to meet the
project purpose and need. It woccld simply add more improvements to the list for
Scenario 4+.
• In the position paper submitted by the DOT it was stated that the same level of analysis
for potential impacts on non-new location alternatives was not performed for the non-new
location alternatives as for the 94 new location segments that were assessed by the team.
See statement below:
Only a cursory level impuct analysis was done for the `improve existing' alternatives.
These impacts are not at the same level of detail as the corridor level `new location'
alternative impacts. Therefore, it is not constructive to draw a comparison.
Threatened and Endangered Species
• EMC Rules require protection of existing uses with the issuance of the 401 WQC
• Wildlife is explicitly listed as an existing use to be protected
• We typically rely on the expertise of WRC and USFWS to fulfill this rcquirement
• At present, the WRC has concerns about the full and fair assessment of alternatives
• Failure to due an assessment of a full range of alternatives can result in failure to do
avoidance and minimization. Thus, causing permit delays, at best, and denial at worst.
• Potential for impacts to federally listed endangered species with new location alternatives
Level of Service (LOS)
• According to the documentation presented, the LOS would be improved if a new location
alternative is built and would not be improved if a non-new location alternative is built.
However, for both new location and non-new location alternatives, certain sections of I-
85 and US 29/74 would have failing LOS in the design year 2025.
• Improvements would need to be made to I-85 and US 29/74 regardless of the alternative
chosen.
• Most of the deficiencies in LOS on I-85 are a result of poor service on surface streets
adjacent to I-85 interchanges. Thus, it appears that much of the congestion on I-85 could
be reduced by improvements to secondary roads rather than by improvements to I-85.
(DOT Information Package for U-3321, July 14, 2004)
• Given this information, it is not clear that alternative 4+ would not meet the east-west
transportation needs of the area. In our opinion, additional information is needed to
demonstrate the effectiveness of the 4+ alternative.
Conclusion
The DWQ is not necessarily opposed to the construction of a new location alternative. In fact, it
is likely that a new location alternative will ultimately be chosen and built. However, issuance of
the 401 Water Quality Certification and the Catawba Buffer Authorization requires the
avoidance and minimization of impacts that can only be accomplished through a full and
equitable assessment of all
GASTON EAST-WEST CONNECTOR
DRAFT Briefing Paper
October 19, 2004
Introduction
Through several meetings held since August 2004, the NEPA/404 Merger Team has been unable
to reach consensus on a portion of Concurrence Point 2 for TIP Project U-3321, the Gaston East-
West Connector.
This briefing paper is organized as follows:
• Issue Being Elevated in the NEPA/404 Merger Process
• Project History in the Thoroughfare Planning Process
• Project History in the NEPA Process
• Purpose and Need Statement
• Surrunary of the Inability of Improve Existing Roadway Alternatives to Meet Purpose
and Need
• Summary of Traffic Analyses Results
• Other Considerations
Issue BeinQ Elevated in the NEPAJ404 Merger Process
The NCDOT considered the following basic types of alternatives in accordance with FHWA
Guidelines (Technical Advisory T6640.8A):
1. No-Action
2. Transportation System Management (TSM) and Transportation Demand Management
(TDM) Measures
3. Mass Transit
4. Improve Existing Roadways (Improve I-85, Improve US 29-74 or Improve Both I-85 and
US 29-74)
5. New Location
The Merger Team could not agree on which non new-location alternatives should be carried
forward as Detailed Study Alternatives.
The NCDOT believes the studies and analyses that have been completed to date sufficiently
demonstrate that TSM/TDM measures, mass transit, and improvements to existing roadways do
not meet the critical elements of the purpose and need for the proposed project and should be
eliminated from further study.
The NCDOT, Federal Highway Administration (FHWA), Gaston Urban Metropolitan Planning
Organization (GLTMPO), Mecklenburg Union Metropolitan Planning Organization (MUMPO),
and State Historic Yreservation Office (SHPO) agree that no non new-location alternative should
be carried forward as a Detailed Study Alternative.
The US Fish and Wildlife Service (USFWS), NC llivision of Water Quality (NCDWQ),
NC Wildlife Resources Commission (NCWRC), US Environmental Protection Agency (USEPA),
and US Army Corps of Engineers (USACE) support retaining some or all of the non new-location
alternatives as Detailed Study Alternatives.
In accordance with CEQ and FHWA regulations, the No-Action (or No-Build) Alternative is
always carried forward as an alternative in the Draft Environmental Impact Statement.
Summarv of the Inabilitv of Improve Existim Roadwav Alternatives to Meet Purpose and
Need
The FHWA provides guidance relating to the role of the Purpose and Need Statement in the
alternatives development process (FHWA Memorandum titled "The Importance of Purpose and
Need in Environmental Documents, September 18, 1990). Based on this guidance, the following
points were considered in evaluating the ability of the Improve Existing Roadways Aliernatives
to meet the project's purpose and need
1. The project purpose and need drives the process for alternatives consideration, in-depth
analysis, and ultimate selection.
2. If an alternative does not satisfy the purpose and need for the project, as a rule, it should
not be included in the analysis as an apparent reasonable alternative.
The purpose and need should be as comprehensive and specific as possible. This will
assist in pinpointing and refining the alternatives which should be analyzed. Further, it
will in a sense "protect" those viable alternatives from sniping by external interests and
capricious suggestions to study something else. If the purpose of and need for the
proposed project are rigorously defined, the number of "solutions" which will satisfy the
conditions can be more readily identified and narrowly limited.
4. The purpose and need define what can be considered reasonable, prudent, and practicable
alternatives.
5. At times, it is possible that no alternative meets all aspects of the project's purpose and
need. In such a case, it must be determined if the alternatives are acceptable and
worthwhile pursuing in light of the cost, environmental impact and less than optimal
transportation solution. To properly assess this, it is important to determine the elements
? of the purpose and need which are critical to the project, as opposed to those which may
? be desirable or simply support it, the critical elements are those which if not met, at least
? to some minimal level, would lead to a"no-build" decision.
?
.? i
The project's purpose and need has two critical basic elements; 1) improve east-west mobility and
connectivity within southern Gaston County and between southern Gaston County and west
c Mecklenburg County and 2) improve traffic flow on I-85 and US 29-74 (the only existing east-
. west corridors in the study area).
a ?
? Improving existing I-85 and US 29-74 (under Scenario 4 or Scenario 4+) would not meet the
i need for connectivity and would only minimally improve traffic flow on existing I-85 and US 29-
74. The travel demand modeling and corridor-level operations analyses (described in a
?subsequent section) show that the diversion of traffic achieved by a new location roadway is more
2
effective at improving traffic flow on I-85 and US 29-74 than providing direct improvements to
these roadways.
South of US 29-74 there are no continuous east-west roadways in the southern half of Gaston
County. Improving US 29-74 and I-85 would not improve connectivity in this area. Drivers
would still have to travel north on two-lane roadways, many through downtown areas, to go east
and west.
The need for a new connection between Gaston and Mecklenburg Counties is clearly
demonstrated in the purpose and need statement. Geographically, southern Gaston County and
western Mecklenburg County are completely isolated from each other by the Catawba River.
There are no crossings of the Catawba River south of US 29-74 until the NC 49 Buster Boyd
Bridge in York, South Carolina, about 11 miles downstream from US 29-74.
The comprehensive land use plans of both Gaston County and Mecklenburg County show
southeast Gaston County and western Mecklenburg County as high growth areas. Both
comprehensive plans show a new roadway connection across the Catawba River between these
two high growth areas. Western Mecklenburg County and the Charlotte-Douglas Airport are
expected to be, or already are, major employment centers. The Charlotte-Douglas Iniernational
Airport is proposing a new intermodal facility in the southwest portion of their property.
The Gaston Urban Area Thoroughfare Plan identifies a new location roadway in southern Gaston
County with a new crossing of the Catawba River as their top priority in the MPO's unmet needs
list. The Mecklenburg-Union Thoroughfare Plan also identifies a transportation need for an
additional crossing of the Catawba River. The current travel demand model shows a new location
freeway would attract about 55,000 vehicles per day in 2025.
A recent draft memorandum from the General Councils of FHWA and FI'A dated September 20,
2004 discusses the integration of the transportation planning process, which includes
Thoroughfare Plan development, and the NEPA process.
"The transportation planning process required by 23 USC 134 and 135 and 49
USC 5303-5306 is designed to set the parameters for the project development
process. Projects must come from the transportation improvement program
(TIP or STIP) established to implement the plan. As a result, much of the
data and decisionmaking undertaken by state and local officials during the
planning process carry forward into the project development activities that
follow the TIP or STIP. This means that the planning process and the
environmental assessment required during project development by the
National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4231 et sey.)
must work in tandem, with the results of the transportation planning process
feeding into the NEPA process. To a much greater degree than other Federal
programs, Congress has put great emphasis on the transportation planning
process for shaping transportation decisions, and has retained and refined that
emphasis in surface transportation law over decades."
3
Proiect Historv in the ThorouQhfare Plannini! Process
The Gaston Urban Area Metropolitan Planning Organization (MPO) recommends a new location
highway to improve east-west mobility in southern Gaston County. This new highway is shown
on the Gaston Urban Area Tharoughfare Plan and is locally known as the "The Garden
Parkway". The "Garden Parkway" is the number one priority on GUMPO's Unmet Needs List,
which is a subset of the Gaston Urban Area Thoroughfare Plan.
The need for improved east-west mobility and the bypass concept was first identified in 1989
during the citizen participation process associated with the update of the Gaston Urban Area
Thoroughfare Plan. The Gaston Urban Area MPO held five citizen workshops, six public
meetings, and 13 formal public hearings before adopting the locally named "Garden Parkway" as
a part of their 1991 Plan.
In 1994, the Mecklenburg-Union MPO Transportation Advisory Committee (TAC) adopted a
conceptual regional thoroughfare plan that included the `Garden Parkway'.
Proiect Historv in the NEPA Process
Study Initiation
Studies for TIP Project U-3321 began in July 2001 using grant funds obtained by The
Honorable. Sue Myrick (US House of Representatives).
Concurrence Point 1
May 15, 2002 Initial Concunence Point 1 meeting
Concurrence on the purpose of and need for the project was not reached at this meeting
and the Merger Team requested the following additional information:
• economic data related to the agricultural industry in Gaston County.
• the need for improved connectivity between Gaston and Mecklenburg Counties.
July 24, 2002 Second Concunence Point 1 meeting
The additional information requested by the Merger Team was presented and
Concurrence Point 1 was achieved.
Concurrence Point 2
Februarv 17, 2004 Pre-Concurrence Point 2 meeting
The purpose of this meeting was to attain agreement for which new location alternatives
NCDOT should prepare functional designs prior to the new-location Concurrent Point 2
meeting. Approximately 92 miles of new location roadway segments were presented to
the team (1200-foot wide corridors), and on February 17, 2004 the team identified 72
4
miles of new location roadway to carry forward for functional design. These functional
designs are currently being worked on.
An agreement on alternatives that were eliminated from further consideration was signed
by all Merger Team inembers at the August 17, 2004 meeting.
August 17, 2004 Partial Concurrence Point 2 meeting
The purpose of this merger meeting was to achieve concurrence on the non-new location
alternatives to be carried forward for detailed study. Because of the project scope and
size of the project study area, the merger team leaders decided to break Concurrence
Point 2 into sections to make the process more manageable. The meetings were
scheduled as information became available.
The alternatives presented at the August 17, 2004 included No Build (Scenario 1). Ni<iss
li?', Sv?icni \'Lniageuw,rtt C1'ti:41). lra1?cinuntl ?-1?niai?cu??;nt i'11)41).
Improve existing I-85 (Scenario 2), Improve existing US 29-74 (Scenario 3), and
Improve Both I-85 and US 29-74 (Scenario 4), and Improve Both I-85 and US 29-74
plus TSM-Type Measures (Scenario 4+), and a new location freeway (Scenario 5).
The NCDOT presented travel demand projections and traffic operations data on the No-
Build Alternative, Improve Existing I-85, Improve Existing US 29-74, and Improve Both
Existing I-85 and US 29-74. The travel demand information was from the regional travel
demand model prepared in TransCad. The corridor-level traffic operations data was
based on CORSIM.
The NCDOT and FHWA proposed that none of the non-new location alternatives be
carried forward because the data collected indicates these alternatives do not meet the
Purpose of and Need for the project. These alternatives include Mass Transit, Traffic
System Management (TSM), Traffic Demand Management (TDM), Improvements to I-
85, Improvements to US 29-74, and Improvements to I-85 and US 29-74.
The Merger Team was not able to reach concunence at the `Partial Concunence Point 2'
meeting for the Gaston East-West Connector Study. Therefore the North Carolina
Department of Transportation (NCDOT) and FHWA made a decision to elevate
Concurrence Point 2 to the Review Board for resolution.
NCDOT, Federal Highway Administration (FHWA), Gaston Urban Metropolitan
Planning Organization (GUMPO) and Mecklenburg Union Metropolitan Planning
Organization (MUMPO), and State Historic Preservation Office (SHPO) agree that none
of the non-new location alternatives meet purpose and need and therefore should not be
carried forward as Detailed Study Alternatives (DSAs).
US Fish and Wildlife Service (USFWS), NC Division of Water Quality (NCDWQ),
NC Wildlife Resources Comunission (NCWRC), US Environmental Protection Agency
(USEPA), NC Division of Cultural Resources (NCDCR), and US Army Corps of
Engineers (USACE) agree that some or all of the Scenarios presented meet purpose and
need and should be carried forward as Detailed Study Alternatives.
Elevation Meetings for Concurrence Point 2
September 14, 2004 - Elevation Meeting# I
Merger Team members attended. Concurrence was not achieved.
September 29, 2004 - Elevation Meeting #2
The supervisors of the Merger Team members attended. Concurrence was not achieved.
Agencies not concurring with NCDOT agreed to prepare a list of items they would need
to enable them to come to a decision.
Week Ending October 8, 2004
The following agencies provided requests for information and questions to NCDOT:
USACE, USFWS, USEPA, NCDWQ, and NCWRC.
Week Ending October 15, 2004
NCDOT provided a response to the information requested by USACE, USFWS, USEPA,
NCDWQ, and NCWRC
TIP Proiect U-3321 Purpose and Need Statement
The purpose of the proposed action is to improve east-west transportation mobility in the area
around the City of Gastonia, between Gastonia and the Charlotte metropolitan area in general,
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County. This project purpose is based on the following needs:
• Need to improve mobility, access and connectivity within southern Gaston County and
between southern Gaston County and Mecklenburg County.
• Need to reduce congestion and improve traffic flow on the sections of I-85, tIS 29-74 and
US 321 in the project study area; improve high-speed, safe regional travel service along
the US 29-74 intrastate corridor; and generally improve safety and reduce above average
accident rates in the study area.
The project study area consists of the following general boundaries: I-85 to the north, the South
Carolina State line to the south, the Charlotte-Douglas International Airport to the east, and the
I-85 and US 29-74 junction to the west.
6
Summary of TrafCc Analvses Results
Regional travel demand modeling and corridor-level traffic operations analyses for the year 2025
were performed for the following scenarios to evaluate traffic flow in the study area:
Scenario 1- No Build Alternative
No capacity improvements to I-85 or to US 29-74.
Scenario 2 - lmprove 1-85
Widen I-85 to eight lanes in each direction (addition of one through-lane in each
direction) from the existing 8-lane area at Exit 26 (Belmont) west through Gastonia to the
interchange of US 29-74 and I-85. This scenario does not include any improvements to
ramps or overpasses in the I-85 corridor.
Scenario 3- lmprove US 29-74
Widen the bridges over the Catawba River and the South Fork Catawba River to six
lanes. Widen the four-lane section that exists west of Gastonia from Myrtle School Road
west to I-85 to six lanes. This scenario does not include any turn-lane improvements on
US 29-74 or on any other arterials in the project study area.
Scenario 4- lmprove both 1-8.5 and US 29-74
Scenario 4 is a combination of Scenarios 2 and 3.
Scenario S- B?iild a New Location Freeway
Build a new location freeway south of I-85 from I-85 west of Gastonia to I-485. No
improvements would be made to existing I-85 or US 29-74.
Reeional Travel Demand Model
Scenarios 2 and 3 were run to provide an evaluation of the relative influence of
improvements on I-85 versus improvements on US 29-74. Based on these two scenarios,
improvements on I-85 had the most influence on travel patterns and volumes, although
improvements to US 29-74 did have some effect.
The Merger Team agreed that improvements to one of these roadways alone (Scenarios 2
and 3) did not meet purpose and need. Therefore, the discussions that follow focus on
comparing Scenario 4 to Scenarios 1 and 5.
The travel demand model provided the following information for each scenario:
• Average daily traffic volumes for major roadways in the study area
• Peak hour traffic volumes for major roadways in the study area.
• Volume to capacity ratios (a measure of congestion) on major roadways
• Regional Statistics
o Vehicle miles traveled (VMT) daily on roads in the region
o Congested vehicle miles traveled (Congested VMT) daily on roads in the
region
o Vehicle hours traveled (VHT) daily on roads in the region
o Congested vehicle hours traveled (Congested VHT) daily on roads in the
region
7
General Conclusions from the Regional Travel llemand Model
• Improving I-85 and US 29-74 attracted three to four percent more traffic to the
existing corridor.
• Building a new location roadway diverted 20 percent of the existing traffic volume
from I-85 and 12 percent from US 29-74.
• Building a new location roadway resulted in better volume to capacity ratios on I-85
and US 29-74 than improving the existing roadways. (Can you give the v/c ratio.
Also a brief explanation of what v/c ratios are?
• Building a new location roadway is approximately twice as effective at reducing
regional vehicle hours traveled, congested vehicle miles traveled, and congested
vehicle hours traveled. (Again, do you think your audience will know what you are
talking about?)
Corridor Level Traffic Operations Analysis
Using traffic volume information from the regional travel demand model, the CORSIM
computer model was used to evaluate traffic operations along the I-85 and US 29-74
corridors for the 2025 peak periods that would occur under each scenario.
Results from the CORSIM analysis were consistent with the results from the travel
demand model. The CORSIM model produced a series of corridor-level statistics for
each modeled scenario. These included vehicle hours traveled, hours of delay, and
averagespeed.
General Conclusions from the Corridor-Level Analysis
• Increasing capacity on I-85 and US 29-74 result in only slight improvements in
vehicle hours traveled, hours of delay, and average travel speeds along the corridor.
• Diverting traffic to a new location freeway results in substantial improvements in
vehicle hours traveled, hours of delay, and average travel speeds along the I-85, US
29-74, US 321, and I-485 corridors due to the reductions in traffic volumes on these
roadways.
Based on the results of the CORSIM analysis for Scenario 4, a list of additional
improvements that would be needed along and in the direct vicinity of the I-85 and US
29-74 corridors to help maximize the efficiency of traffic operations along the corridor
was developed. This TSM list included approximately 70 improvements such as adding
turn lanes or additional lanes in interchange ramps.
Other Considerations
US 29-74
Because of operational deficiencies identified in Scenario 4, numerous TSM-type improvements
along US 29-74 were incorporated into Scenario 4, resulting in Scenario 4+.
8

The corridor-level model was not rerun for these improvements. It is likely that making these
improvements would simply shift the congestion farther downstream. The regional demand
model runs already completed show that improvements made to US 29-74 and existing I-85
continue to attract more traffic due to the latent travel demand in the area, resulting in a"build it
and they will continue to come" situation. The cycle of making recommended improvements,
running the model, identifying new areas of congestion, making those improvements, then
running the model again, was not necessary to adequately evaluate the ability of the Improve
Existing Roadways Alternatives to meet the project purpose and need. It would simply add more
improvements to the list for Scenario 4+.
I-85
I-85 would require widening to a minimum of eight lanes throughout the study area under
Scenario 4 or 4+. All interchanges along I-85 in the project study area would need to be
reconstructed in order to meet current design standards. Also, structures over I-85 within the
project study area do not have sufficient horizontal clearances to allow for additional lanes,
thereby requiring replacement of these structures. The re-construction of interchanges and
replacement of structures would result in lengthy construction periods and driver delays through
these construction zones, and would require complex maintenance-of-traffic plans to allow for the
safety of the motorists and the construction workers.
In addition to work at the eleven interchanges in the project study area, there are fifteen cross
street bridges and six railroad bridges that would need to be replaced because of inadequate
horizontal clearances.
In order to maintain existing traffic patterns, these new bridge structures would need to be
constructed on new alignments, and where possible, adjacent to the existing structures. The
construction of these bridges would result in increased driver delay and could impact driver safety
during the construction period. In order to attempt to minimize these delays, it would be
recommended to stagger the replacement of these bridges within the project study area limits. By
staggering this construction, there could be a delay of 10 years or more before widening of I-85
could be completed. While structural issues of bridges would not be as prevalent along US 29/74,
there would be driver delays and potential economic impacts to local merchants due to changes in
travel patterns.
There is an existing Freeway Management System (Intelligent Transportation System [TTS]
technology) in Mecklenburg County. If a new location alternative were selected as the preferred
alternative, this new location route would be used as an alternate route during incidents on I-85.
(I don't think the merger team cares if the project affects the equity formula or not.
9
SCENARIO DESCRIPTIONS
GASTON COUNTY EAST-WEST CONNECTOR STUDY
TIP PROJECT NO. U-3321
GASTON AND MECKLENBURG COUNTIES
FEDERAL PROJECT NUMBER: STP-1213(6)
STATE PROJECT NUMBER 8.2812501
Below is a summary of the scenarios discussed at the August 17, 2004 Merger Team Meeting:
Scenario 1- No Build Alternative
No capacity improvements to I-85 or to US 29-74.
Scenario 2 - Improve I-85
Widen I-85 to eight lanes in each direction (addition of one through-lane in each
direction) from the existing 8-lane area at Exit 26 (Belmont) west through Gastonia to the
interchange of US 29-74 and I-85. This scenario does not include any improvements to
ramps or overpasses in the I-85 corridor.
Scenario 3- Improve US 29-74
Widen the bridges over the Catawba River and the South Fork Catawba River to six
lanes. Widen the four-lane section that exists west of Gastonia from Myrtle School Road
west to 1-85 to six lanes. This scenario does not include any turn-lane improvements on
US 29-74 or on any other arterials in the project study area.
Scenario 4- Improve both I-85 and US 29-74
Scenario 4 is a combination of Scenarios 2 and 3.
Scenario 4+ - Improve I-85 and US 29-74 and include TSM Measures
Based on the results of the corridor-level operations analysis for Scenario 4, a Scenario
4+ was developed.
Scenario 4+ includes the improvements from Scenario 4 plus:
• Additional through-lane in each direction on I-85 (widen to 10 lanes)
from Exit 21 (Cox Road) to Exit 27 (NC 273)
• Intersection, ramp, and cross-street improvements along entire length of
I-85 and US 29-74 in study area (the long list in the meeting packet)
Scenario 5- Build a New Location Freeway
Build a new location freeway south of I-85 from I-85 west of Gastonia to I-485. No
improvements would be made to existing I-85 or US 29-74.
Scction 404/NEPA I1r11erger Froject Teatri M:eeting Agreement
Con:currcnce k'Qint N0.1 - Purpase and Need.
Proiect No.ITIP No fName/Deacripfion•
F'ederal Pruject Numberr STI'-12l3)(6); StaEe ProRect Nun?ber 8;??"1?if?l;
71P Numl??er: U-3a?21
'
Qescriptictki- Gasran East-West Corridnr Studv in F:lL?ton wid Meckicnburg, Counti(!s
P?pr nse and Need of Prapased P'roje_ct•
'.Che purpose oFtht proposed action ia tointpr??ve e2st-ir-est trantiportaYioii rno6iCi(y? ir? the
area aroun?l the Cit;? aFGast??nia, bet??cen Gastania and che Charlatte metropolitan area
in general, and panic;ularly tcj establish tlircct acceis between (he rapidly growing area of
southeast Ciastcrn CoLuuv ilI1CI 1?V?"uY M@CICIt,'11bi1Cg C'vunty. TI7lS pte?jeCt purpoSe j5 bASefl
an the fqClowing:
Need to impror•e tnobiiity, aceess and eonnktivit}• %vithin southem Gastan
Caunty and bettiveen tiout}iern Castcrn t~aunty anci Mccklcnburg Count}r.
?Ieed to reduce cangeslic?n anri improve traEfic t?oti??? the scctions of1-85T IJS
29-74 and U5 321 in the pcnject study ar&a; improw?e Ivgh-speed, safe regiotYal ,
traact servicr along khe L15 29-7:I irttrastate corridor; and gcncrally improve safety
and reciuce above averagc accident rares in the study art3.
Ttie project stLfdy area consists vt'the fbliowing general bnundaries: 1-95 to the north,. the
South Caroiina Stmte lint to thc south, the C:liarlotte-Dauglas Internationul Airport to the
cast, and thc 1-85 a»d US 29-74.lunclion to thc,wcst.
The Project Team concurred an this ciate 4f ? ZCJW with ihepurpase:af
ancf need for the prapased project as sta[ed:above.
.
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TURNPIKE ENVIRONMENTAL AGENCY
COORDINATION MEETING - WEST
Agenda
January 25, 2007
? Introduction and Welcome 1:30 - 1:45
# Project Coordination Plans 1:45 - 2:00
The revised general coordination plan will be distributed to agency representatives
and posted on the TEAC website. The plan is presented at this meeting to highlight
the revisions incorporated per agencies' request only. The plan will be discussed in
detail at the February 14, 2007 meeting. This will allow agencies adequate time to
fully review the plan and prepare questions or comments for fhe detailed
discussions. Additionally, agreement upon the agencies fhat will serve as
cooperating and participating agencies for the NCTA projecfs is proposed.
? "Snapshot" Projects 0- 2:00 - 2:15
Gaston East-West Connector
? "Spotlight" Projects ? 2:15 - 4:00
Monroe Connector/Bypass
? NORTH CAROLINA
-Turnpike Authority
Monroe Connector / Bypass
Agenda
January 25, 2007
? Introductions and Sign-in
? Project Background
Monroe Connector History
Monroe Bypass History
? Preliminary Purpose and Need
Deficiencies in Existing Transportation System
Discussion of Preliminary Purpose and Need
?? Project Study Area
Proposed Study Area Boundaries
Discussion of Study Area
? Known Significant Environmental Issues
Agency Comments on Previous Studies
Special Studies
Suggested Methodologies
? Project Approach and Schedule
Section 6002 Project Coordination Plan
Environmental Impact Statement
Project Schedule
?? Project Resources
TEAC Website
Notice of Intent
Preliminary Traffic & Revenue Study
?? Wrap Up / Next Steps
Final Comments
Local Officials Scoping Meeting (Feb. 1)
Public Scoping/CIW
February TEAC Meeting - Spotlight Update
?NC?ftTH CAROLINA
-Turnpike Authority
,
Notes for Presentation
Two fundamental concerns with a premature elimination of
alternatives:
1) Circumvents Avoidance and Minimization Process
2) Delays in Permitting 404/401 (3rd Party intervention)
Purpose & Need
• Broad versus Strict interpretation
• Recollection of DWQ staff
• Written meeting minutes
Impacts & Modeling
• Modeling for 4+ not performed
• Assessment of impacts for New Location done, Non-Location not
done
Threatened and Endangered Species
• Protection of Existing Uses
• Wildlife listed specifically as an existing use
• Defer to WRC, DMF, and USFWS
• All have expressed concerns at this time
• If don't eliminate non-New Location properly Dead in the water if
T&E issue arises
LOS
• Even new location alternative need upgrades to I-85
• Not assessed at this time
Conclusion
• Not necessarily opposed to a new location alternative
• However, need to do full and fair assessment of alternatives to
eliminate
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STATE OF NORTH CAROLINA
DEPARTMENT pF TRArJSpORTATION
MICHAEL F. EASLEY LYNDO TIPPETT
GOVERNOR September 15, 2005
SECRETARY
STATE PROJECT: 34922.1.1 (U-3321)
F. A. PROJECT: STP-1213 (6)
COUNTY: Gaston-Mecklenburg
DESCRIPTION; Gaston County East-West Connector from I-85 West of Gastonia to NC
160 in Mecklenburg County
MEMORANDUM TO: Mr. Gregory J. Thorpe, PhD, Director
Project Development and Environmental Analysis Branch
,? 04-u"-
FROM: John L. Pilipchuk, LG, PE, Western Regional Geotechnical Manager
Geotechnical Engineering Unit
(a? 0?
Gregory A. Smith, LG, PE, GeoEnvironmental Supervisor
Geotechnical Engineering Unit
SUBJECT: Allen Steam Plant Fly Ash Basins
The GeoEnvironmental Section performed a non-intrusive investigation of two fly ash basins immediately
south of Duke Power's Allen Steam Plant property near Belmont. Our findings are to partially assist in
deternuning the suitability of Segments K1B-KIC-K1D for additional study. The northern basin is
inactive and vegetated, while the southern basin currently receives approximately 12,000 gallons of fly
ash slurry per day. The above segment alignments cross a portion of the northern basin.
Fly ash was placed in the basin via water slurry; the solid material settled out and the water was
discharged from the basin into the Catawba River. Typical of such operations, Duke Power practiced no
engineering control over consolidation of the ash. The resulting material has low strength and is
generally unsuitable as a structural foundation without modifications. Roadway construction across the
basin must therefore include considerable in-situ modifications to the ash's physical properties necessary
for improved constructability or its excavation and replacement with suitable embankment material.
MAILINO ADDRESS:
NC DEPARTMENT OF TRANSPORTATION TEIEPHONE: 919-250-4088 LOCATION:
GEOTECHNICAL ENGINEERING UNIT FAX: [phone] CENTURY CENTER COMPLEX
GEOENVIRONMEN7AL SECTION BUILDING B
1589 MAII SERVICE CENTER WEBSITE: WWW.DOH.DOT.STATE.NC.US 1020 BIRChi RIDGE DRIVE
RuEIGH NC 27699-1589 RnLEIGH NC 27610
/
Mr. Gregory J. Thorpe, PhD
September 15, 2005
Page 2
Fly ash usually exhibits physical properties suitable for embankment material when it has been properly
dried and compacted. Environmental impacts regarding contaminant concentrations within fly ash
generally are not a major concern, as with bottom ash, but appropriate chemical analyses must be
performed prior to acceptance of the material.
A geotechnicaUgeoenvironmental field investigation can be scheduled if more detailed information is
needed to make a final decision regarding the status of the segments in question. Please contact Greg
Smith, GeoEnvironmental Supervisor, at [phone] for additional geoenvironmental information or
John Pilipchuk, Western Regional Geotechnical Manager, at [phone] for additional geotechnical
information.
Subject: Gaston E-W Connector, TIP U-3321
Fram: Marella [e-mail]
Date: Mon, 19 Dec 2005 16:21:57 -0500
To: dweaver@dot. state. nc.us, [e-mail], [e-mail],
[e-mail], [e-mail], [e-mail]
CC: Brian [e-mail], [e-mail]
On December 8, 2005, the USFWS abstained from signing Concurrence Point 2 for the Gaston East-West
Connector Project, Gaston and Mecklenburg Counties, NC, for the following reasons:
1. According to discussions at the last Merger meeting for this project, U-3321 is being "handed off' to
the NC Turnpike Authority. Since this project is now an NC Turnpike Authority study project, we
believe it is no longer in the Merger Process. Merger is a process for which decisions are made in a
building block fashion, each subsequent step dependent on the previous step. Therefore, we believe it is
inappropriate for our Agency to sign off on alternatives when we will not be involved in selecting a
LEDPA (CP 3) or in Avoidance and Minimization considerations (CP4). We have provided input that a
deciding official can use to help determine an appropriate range of alternatives.
2. Our understanding is that the study of potential turnpike projects will include an analysis of economic
considerations to determine a project's feasibility. Thus faz, economic considerations beyond the cost to
build a project have rarely been discussed relative to the feasibility of a project. If economic viability is to
be considered a criterion used to determine feasibility for this particular project, we believe that the
current Purpose and Need should be re-visited to include economic considerations.
If, in the future, the NC Turnpike Authority adopts the Merger Process and current merger team members
are tasked by NCDOT to participate in another, dual, merger process we will revisit our abstention from
this concurrence point decision.
Thank you.
marella buncick
USFWS
160 Zillicoa St.
Asheville, NC 28801
828-258-3939 ext 237
1 of 1 12/19/2005 4:40 n'
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COMPARISONS - 9ECTION J
PROJECTNO.
TIP NO.
COUNTV
DESCRIPTION
OATE
PREPAREO BY
B07ANICAL OARDEN AREA
"J" SEOMENTS
92812501 FHWASTP-1213(6)
U-3321
GASTON AND MECKLENBURG COUNTIES
GASTONCOUNiVEAST-WESTCONNECTnRSTUDY
BI79R005
PBSBJ
Raleined by Merger Team for Datailad SIUAy
Eliminatad by Mnrgar Taam Irom Detaded Sludy

9EOMENi LABEL + t?
J4d + J5S •
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J4d + J%1 -
J1o + J11 • c
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JS. + JSb +
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Jtl + K1A c
J2d + JS. +
JSb + 1(4A + c
J4d + J%1 +
J7o + J1f +
Len Ih ll
NumMr o1 Inlerchen es 51192
4 41402
3 48776
4 39016
3 48192
< 39852
3 51888
C 42128
3
Minor Road Crouln s IINe1 n ulrin nds ne enllon 4 3 4 3 3 2 4 3
Ma or innsmUdon Llne Crossin s 8 6 a 2 5 3 8 B
RNlroad Llne Crmsin s 0 0 0 0 0 0 0 0
ConelrucllunCuet Inmllllomufs f184.5 51713 $1728 5761.8 f7944 f184.0 187.5 178.J
ReslAences wllhln RIW 90 46 BB 44 BB 40 90 48
Businuus within RIW 1 1 1 1 1 2 1 1
P?rNURwrulion Arqs within R/W 0 0 0 0 0 0 0 0
Schools wllhln R/W 1 0 1 0 1 0 1 0
Churcha. wllhln N/W 2 0 2 0 2 0 2 0
Cemeledes In R/W 2 0 2 0 2 0 2 0
Potmllel Mlslorlc SIIos within RIW 2 2 2 2 2 3 2 2
Low•Income or Mlnorl Po ul?lions within RJW No No Na No No No No No

Slroams 0 ol Crossin s within const. Ilmlls
Strums Llnear Ff withln conal. Ilmib aMduslvs of brltl e cmnin e
WNlands Imcns within consl. Ilmlla 31
19832
0 26
10938
0 30
13317
0 25
10821
0 33
14127
0 28
10578
0 32
14282
0 27
11508
0
WMlands, ecras within tons1. IImIU NWI
Flood Iains ro . melnlino crossln lan th 11 2.89
2195 1.15
587 2089
1872 1.15
220 2.89
2251 1.15
570 2.89
2233 1.15
821
Namod Strums N ol crouln s 2 0 2 0 2 0 2 0
Other Pennnlal Slrums M of crouln s) 3 4 2 3 3 4 3 4
Othn Inlermltlent Stnems 0 otcrouln s 28 22 28 22 28 21 27 29
Other Weurbodin wlthln iVW
707 d Lid.d SlnsmIs
RI arlan BuMer Im acla 8
Yes
yes 5
No
No 8
Vee
Yee 5
No
No 8
Yee
Y. E
No
No 7
Ves
V- B
No
No

Dormenl Su eAund Sllat In R/W 0 0 0 0 0 0 0 ?
0
Groundwaler Dlecher ? Arees 1n RIW 0 0 0 0 0 0 =

Nafunl H?rlta e Pr ram 511es In R/W
0
0
0
0
0
0
0 0

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Lee th ft 48700 54292 41314 51906 39432 50444 04435 55027
Number ot Intorchan a 3 a 3 < 9 4 3 4
Mlnor Road Crossin s IIMN n ulrln nde u srallon 3 8 9 6 2 5 J 8
Ma or Trammlulon Une Crouln s 6 B 2 4 3 5 8 B
Rellroad Lln. Crouln s 0 0 0 0 0 0 0 0
ComlrucllonCnellnmllllorouf5 175.4 203.8 E169.7 192.1 1872 2124 174.9 09.9
Ruldmciss, wllhin R/W 44 BB 42 86 44 81 04 BB
Buatlnsitus wlthln RIW 2 2 2 2 1 2 2 2
PsrNsIRecroosllon Anas within R/W 0 0 0 0 0 0 0 0
$ehoob within iUW 0 1 0 7 0 1 0 1
Churthes wllhinRlW 0 2 0 2 0 2 0 2
Camalarlst In R/W 0 2 0 2 0 7 0 2
Polanllel Hlsbdc Sllo within R/W - 3 3 3 3 2 3 9 3
Low-Incomo or Mlnorl Po ulslbns within RIVY No No N. Na No No No No

9tnsms N ol Crosslnqs within consl. Ilmlls)
Stnams Llnaar FI wllhln consl. Ilmlb eacWsiva ol bdd a cro uln ?
Wdlands faues within consl. Ilmib 28
10113
0 36
13520
0 27
9798
0 35
17205
0 28
11431
0 38
13983
0 29
10783
0 37
14170
0
WHlands (acnswilhlnconsl.llmlb NWI 1.15 2.89 1.15 2.69 1.15 2.89 1.15 2.69
Flootl lalns ro . mdnllno cronln Im Ih 11 583 2195 220 1832 642 2122 821 2233
Nemed Slrnms N ol crouln s 0 2 0 2 0 Y 0 2
Other Pennnld Strnmt M ol crossin s 4 3 J 2 4 9 < 3
Olher InUrmltNnl Slmamf M ol crouln s 21 31 24 31 24 71 25 32
Olhn WaIerDOdNS wllhln R/W 6 7 8 7 5 7 7 B
JOJ E Lshd Streem? No Yes No Vea No Ves No Veg
RI arlen Bufler Im acls No Vea No Ves No Yee No Yee

Dormsnl 9u arlund Sit?? In H/W 0 0 0 0 0 0 0 0
OroundwHer Dlscher a Aroef In R/W 0 0 0 0 0 0 0 0
Nalunl Hvlla a Vronm SINs In RIW 0 0 0 0 0 0 0 0
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Section 404/NEPA Merger Team Meeting Agreement
Concurrence Point No. 2- Detailed Study Alternatives
Pro_iect No./'I'IP No./Name/Description:
Federal Project Number: STP-1213(6); State Project Number 8.2812501;
TIP Number: U-3321
Description: Gaston East-West Connector Study in Gaston and Mecklenburg Counties
Alternatives Carried Forward for Detailed Study:
Non-New Location Alternatives: None to be carried forward for detailecl study in accordance with
NEPA/404 Merger Process Review Board Decision (see separate signed partial Concurrence Point #2
forms for non-new location alternatives from July 2005).
New Location Alternatives:
Alt # H Segments J Segments K Segments
4 H2A-H3 J4a-J4b-J2c•J2d-l5a45b K2A-KXl-K3E3-K3C
5 H2A-143 J4a-J2b-J2aJ2d-JX4-Jle-Jif K1A-KIB-KIGK4A
6 112A-I i3 J4a-J26-J2c-J2d-JX4-J l e-J I f K 1 A-K I B-K l GK 1 D
9 112A-H3 J4a-J2b-J2c-J2d-JX4Jle-Jlf KIA-K3A-K3B-K3C
22 H2A-H2B-H2C J3-J2c-J2J-J5a-J5b K2A-KXI-K3B-K3C
23 H2A-H2B-H2C J3-J2c-J2d-JX4-JIc-Jlf KIA-KIB-KlGK4A
24 H2A-H2B-H2C J3-J2c-J2d-JX4-JIe-J(f KIA-KIB-KIGKIU
27 H2A-H2B-H2C J3-J2c-J2d-JX4-JIe-Jlf KIA-K3A-K3B-K3C
58 H1A-HIB-H1C J(a-JXl-J2d-JSa-JSb K2A-KXl-K3[3-K3C
64 H1A-H1B-HlC Jla-J(b-Jlc-Jld-Jle-Jlf KlA-KIB-KIGK4A
65 H1A-HIB-HIC Jla-Jlb-Jlc-Jld-Jle-Jlf KlA-KIB-KIGKID
68 HIA-HIB-H1C Jla-Jlb-Jl o-Jld-Jle-Jlf KlA-K3A-K3B-K3C
76 H l A-HX2 J2a-J26-J2o-J2d-J5a-J5b K2A-KX I-K3B-K3C
77 H l A-HX2 J2a-J2b-J2o-J2d-JX4-J 1 e-J 1 f K t A-K I B-K 1 GK4A
78 HIA-HX2 J2a-J2bJ2c-J2d-JX4-Jle-Jif KlA-KlB-KIGKID
81 H 1 A-HX2 J2a-J2b-J2c-J2d-JX4-J le-J 1 f K 1 A-K3A-K3F3-K3C
The Project Team concurred on this date of 9/20/05 with the Detailed Study Alternatives listed
above to be carried forward in the Draft EIS for the proposed project.
USACE
USEPA
NCDOT
USFWS
NCDWQ NCWRC
NCDCR FHWA
GUMPO MUMPO
F/HAL
Date:
Time:
Place:
Subject:
MINUTES
NEPA/404 MERGER TEAM MEETING - CONCURRENCE POINT 2
GASTON COUNTY F,AST-WEST CONNECTOR STUDY
TIP Project U-3321
Gaston and Mecklenburg Counties, North Carolina
September 20, 2005
1:00 PM
Board Room - Transportation Building
1 S. Wilmington Street
Raleigh, NC
Concurrence Point #2 Meeting for TIP Project U-3321
Attendees: Ron Lucas -
Aldie Whitmore -
Dan Grissom -
Michael Holder -
Uerrick Weaver -
Shannon Lasater -
Teresa Hart -
Tony Houser -
Lee Moore -
I3rian Hanks -
Chris Manley -
Gd Lewis -
Mary Pope Furr -
Michael Wray -
Shannon Ransom
Mark Staley -
Robert Memory -
Sarah McBride -
Chris Militscher -
Brian Wrenn -
Polly Lespinasse -
John Hennessy -
Marla Chambers -
Steve Lund -
Hank Graham -
Robert Cook -
Gail Grimes -
Anne Redmond -
Jill Gurak -
David Bass -
Lou Raymond -
Lauren Wolfe -
Mark Stephens -
Glenda Gibson -
Mike Pekarek -
FHWA
NCDOT Division 10
NCDOT llivision 12
NCDOT Division 12
NCllOT YDEA
NCDOTPDEA
NCDOT PDEA
NCDOT Roadway Design
NCDO'I' Roadway Design
NCDOT Structure Design
NCDOT Natural Environment Unit
NCDOT Human Environment Unit
NCDOT Human Environment Unit
NCDOT Transportation Planning
NCDOT Transportation Planning
NCDOT Roadside Environmental
NCDOT Utilities Coordination Unit
SHPO
EPA
NCDWQ
NCDWQ
NCDWQ
WRC
USACE
Gaston Urban Area MPO
Mecklenburg-Union MPO
NCTA
HNTB
PBS&J
YI3S&J
PBS&J
YBS&J
PBS&J
Gibson Engineers
Gibson Engineers
September 20, 2005 T/P Project U-3321
NEPA1404 Merger Teum Meeting Gustan Counry Enst-West Cannector Study
Attendees via Videoconference:
Marella Buncick - USFWS
Introduction
Mr. Weaver began the meeting with the introduction of everyone in attendance and participating via
videoconference. The purpose of this meeting was to decide which of the 90 preliminary new location
alternatives should be carried forward for detailed study. The packet distributed to the Merger Team prior
to the meeting included the initial recommendations of the FHWA, NCDOT, Gaston MPO, and
Mecklenburg-Union MPO . Those recommendations narrowed down the 90 preliminary alternatives to
16 Detailed Study Alternatives.
Ms. Gurak noted that the elevation process for the non-new location alternatives was completed in July
2005, in accordance with the NEPA/404 Merger Memorandum of Agreement (MOA). The decision by
the elevation process Review Board (consisting of executive management representatives from FHWA,
NCDOT, USACE, and NC DENR) was to eliminate non-new location alternatives from detailed study as
part of Concurrence Point #2 (signed concurrence forms were included in the packet in Appendix A).
MeetinQ Displays
The following items were displayed during the meeting to facilitate decision making:
• A map (included in the packet as Figure 2) showing the critical nodes and alternatives.
• A map with the functional design segments overlaid with environmental features (included in the
packet as Appendix C).
• A map provided by the Gaston Urban Area MPO showing planned and platted development in
the area that had not yet been included in the County's downloadable GIS database. Also shown
on the map were the functional design alternatives and the original Gaston MPO preferred
alignment.
Backaround Issues
Some background issues were brought up at the start of this mceting by Merger Team members and are
documented below.
1- Ms. Chambers expressed concern about decisions made for this project at the elevation Review Board
meetings held prior to this meeting. She statcd she had received no minutes to these meetings, and knew
nothing about why or how the Review Board decisions were made. She stated she would like a Review
Board meeting summary to aid in making decisions about this project. Several other Merger Team
members stated they also had not received any information about the Review Board meetings or the
Board's decision. Mr. Militscher noted that the Merger Process MOA requires the Merger Team to be
immediately notified of Review Board decisions. Both Mr. Militscher and Mr. Hennessy stated that
something needed to be done about the lack of communication.
Some Merger Team members had copies of a summary prepared by PBS&J for the Review Board. There
was some misunderstanding that this document was meeting minutes to the final Review Board meeting
where the Board made its decision. The Review Board meeting at which the decision was made was not
attended by staff and meeting minutes are not available. The summary document was provided to the
Review Board at its request prior to their final meeting. At their request, the attendees from the resource
2
September 20, 2005
NEPA1404 Merger Team Meeting
TIP Project U-3321
Guston Counry F.,'ast-West Conneclor Study
agencies (EPA, USFWS, USACE, NC DWQ, SI-IPO, NC WRC) will be emailecl a copy of this summary
document.
NCDOT apologized about the miscommunication, noting this project was the first to be elevated to the
Review Board level. Mr. Weaver stated a copy of the Review Board summary document would be sent
to them by PBS&J.
Mr. Militscher stated that since US EPA was not included in the clevation process, he does not feel his
agency is bound by this decision. He iiidicated he will be commenting on the Draft EIS with this in mind.
2- Ms. Buncick brought up the fact that since this project is now a NC Turnpike Authority (NCTA)
project, she wanted to know how this would affect the merger process and the decisions made by the
Merger Team. She and Mr. Militscher wanted to know if decisions (including past decisions) would be
made based on different criteria now that this project is a NCTA project. Ms. Buncick expressed concern
that the Detailed Study Alternatives decided on at this mecting may not be carried forward due to the
economic component of a toll road project. Mr. Militscher wanted to know why this project was still
going through the merger process if it was being turned over to NCTA.
The North Carolina Turnpike Authority (NCTA) explained that toll projects do not pay for themselves
initially and that they are all `candidate' projects at this time, subject ro traffic revenue stuclies to
determine their economic feasibility. lf the project is determined to be infeasible as a toll project, it will
then be turned back over to the NCDOT to be planned and constructeci as a free (non-toll) facility. Mr.
Weaver stated that a NEPA document must be done whether this is a toll project or not. The NCTA and
NCDOT will carry forward the alternatives recommended for Detailed Study decided on at today's
meeting through the DEIS, and the project will continue to follow an interagency process. NCTA stated
that an agency coordination process will be implemented for NCTA projects, but that the process has not
been finalized. NCTA currently is working with the executive management of other resource agencies on
a process.
Review of Decision Making MethodoloQy
Ms. Gurak explained the decision-making methodology for identifying alternatives for detailed study.
She referred to the large maps showing the segments of the alternatives as well as the environmental
features maps displayed. The decision-making methodology requires eight key decisions between pairs
of nodes (options) along the functional designs segments. There are seven (7) nodes: I-85 (85E and
85W), US 321 (321N and 321S), a point west of the South Fork Catawba River (CTR-N and CTR-S), and
at I-485 (485).
The basic premise of this comparison/decision making methodology is that, if possible, at least one
connection between critical pairs of nodes should be maintained, and redundant connections should be
eliminated. There are enough planning and design data available to be able to narrow choices, but still
keep all or most basic options open (in case a fatal flaw is later found along a corridor segment).
The eight key decisions under this methodology are listed below,
Decision # Node-to-Node
llecision Needed
85E to 321N Choose from two options.
September 20, 2005 TIP Project U-332 /
NEPA1404 Merger Team Meeting Gaston County East-West Connector Sludy
2. 321 N to CTR-N Choose from two options.
3. 321 N to CTR-S Choose from two options.
4. 3215 to CTR-N Choose from two options.
5. 3215 to CTR-S Choose from two options.
6. CTR-N to 485 Choose from four options
7. CTR-S to 485 Choose from three northern options
8. CTR-S to 485 Choose from two southern options
Mr. Hennessy asked if the impacts were based on GIS data. Ms. Gurak stated that impacts were based on
GIS data and functional roadway designs, and that this is the same level of data that is usually available at
this stage in the planning process,
Discussion of Kev Decisions
The Merger Team discussed the eight key decisions to identify the alternatives to carry forward as
Detailed Study Alternatives. In some cases, decision points were combined or added onto. The decisions
are listed below.
AREA WEST OF US 321- Decision Point l(Nodes 85F_ and W to Nodes US 321N und S)
The Merger Team compared all the H-segment combinations and, for the 85E-321N routes, decided to
keep both the western option (H2A+H3B+H2C+J3) and the eastern option (H2A+H3+J4a) as Detailed
Study Alternatives for the following reasons:
The eastern option has higher human environment impacts, but the western has higher natural
environment impacts. Keeping both options allows the Merger Team to make a decision when
more detailed information about impacts is available.
Both options have potential environmental justice (EJ) issues. Keeping both options available
allows for more design options later to avoid the EJ areas.
The Merger Team also decided to eliminate the segment combination from 85E to 3215
(H2A+H2B+HXI+HIC+JIa). This option was not originally included as part of Decision Point 1
because it is the only option to get from 85E to 321S. The Merger Team eliminated it because this
alternative has substantially more stream impacts than other H segment combinations reaching from I-85
to US 321 (about 4,080 linear feet more than the next highest impacts) and would be substantially more
expensive (about $41 miliion more in construction costs than the next highest costs).
Summary of Deeision Point 1(Nodes SSE and W to Nodes US 321 N and S)
The Merger Team decided to retain the following segment
combinations for detailed study:
• H2A-H3-J4a
• H2A-H2B-H2C-J3
• H1A-H1B-H1GJla
• H 1 A-HX2-J2a
September 20, 2005 TlP Project U-3321
NEPA1404 Merger 7enm Meeting Gaston Cnunry East-West Connector Sludy
CENTRAL ARF.4 - Decision Points 2(Nodes 321 N to C'TR-N) 3(Nodes 321 N to CTR-S), 4(Nodes 321 S
to CTR-N), und S(Nodes 321 S to CTR-S)
The Merger Team decided to keep the options recommended in the packet for Decision Points 2 through
5 as combinations to include in the Detailed Study Alternatives, which are:
• Decision Point 2 - northern alternative (J4b-J2aJ2d-J5a-J5b-K2A)
• Decision Point 3 - northern alternative (J4b-J2c-J2d-JX4-J 1 e-J 1 f-K 1 A)
• Decision Point 4 - northern alternative (JXl-J2d-JSa-JSb-K2A)
• Decision Point 5 - southern alternative (J 1 b-J 1 c-J 1 d-J lc-J 1 f-K i A)
For Decision Points 2 and 3(whieh begin at Node 321N), the segment combinations that indude JX7
(JX2 for alignments using J2a) have a functional design that is not desirable to NCDOT. The design in
this area involves a half-clover interchange at US 321 as a result of a railroad crossing. Segment JX7
would cause back-to-back horizontal curves in this interchange area, and super elevations of the ramps
and the mainline would be in opposite directions, which make it difficult to tie the ramps into the
mainline. This combination of design issues makes the design potentially unsafe. Thesc design problems
were not apparent until the functional designs had been completcd.
?, sR
z.i:,
w ?32 N ?,?x?_ . f
JX1?:? ?
SA 321_
??ioel {
1?
` - `, J 1
Mr. Hennessy asked if the functional design for segment JX7 meets AASHTO standards. Mr. Houser
stated that although it does, it is not a preferable design . Mr. Houser stated the AASHTO standards are
guidelines, and that meeting the minimum AASHTO requirements may not result in good designs in
individual cases, such as segmcnt JX7. Mr. Houser noted that at this stage in the planning process, he
would like to eliminate poorer designs where possible. Mr. Weaver stated that it was important to narrow
down the number of alternatives carried forward for detailed study in order for this project to move
fbrward quickly and be easier to present to the public. Mr. Weaver also noted that the impacts were
similar for the segment combination options between 321 N-CTRN and 321 N-CTRS. The Merger Team
agreed to eliminate those alternatives using segment JX7. As a consequence of climinating segment JX7,
segments JX2 and JXS would consequently be eliminated since they follow the same alignment as JX7.
(Note that segment JXS is an outdated segrnent not used by any of the alternatives.)
The group reviewed the impacts for the scgment combinations included in Decision Point 4(3215-
CTRN) and llecision Point 5(3215-CTRS) and agreed with the original recommendations to retain
segment combinations JX 1-J2d-JSa-JSb-K2A and J 1 b-J 1 c-J 1 d-J 1 e-J 1 f-K 1 A for detailed study.
5
September 20, 2005
NEPA1404 Merger Teunt Meeting
'lIP Project U-3321
Gaston County East-West Connector Study
For Decision Point 4, JX1-J2d-JSa-JSb-K2A was retained for detailed study and JIb-JIc-JX6-JSb-K2A
was eliminated because JX1-J2d-J5a-J5b-K2A was less expensive ($194 million vs $212 million) and
more direct. Other impacts were very similar.
For Decision Point 5, J 1 b-J 1 c-J 1 d-J t e-J 1 f-K l A was retained for detailed study and JXI -J2d-JX4-J 1 e-J 1 f-
K 1 A was eliminated because J I b-J 1 c-J l d-J 1 e-J 1 f-K l A has about 855 less linear feet of stream impact
and less floodplain impact. Other impacts and the costs were similar. Also, retaining segment
combination Jlb-Jlc-Jld-Jle-Jlf-K1A provided an alternate route.
Summary of Decision Points 2, 3, 4, and 5(Between Nodes 321 N and S
and Nodes CTR-N and S)
The Merger Team decided to retain the following segment
combinations for detailed study:
• J4b-J2c-J2d-J5a-J5b-K2A
• J4b-J2c-J2d-JX4-Jle-Jlf-K1A
• JXl-J2d-J5a-J5b-K2A
• Jlb-Jlc-Jld-Jle-Jlf-K1A
Decision Point 610 ode CTR-N to Node_I=4K
J
The Merger Team decided to retain segment combination KX 1-K3B-K3C for detailed study and
eliminate segment combinations K2B-K2GK2D and K2B-KX4-K3C and KX1-KX3-K2D.
Segment combinations using K2D were eliminated for the following reasons:
Designs that use segment K3C are better than designs that use segment K2D. Segmcnt K2D has
a less desirable design due to a curve immediately east of the Catawba River bridge and just west
of I-485, This curve cannot be flattened due to space constraints related to tying into I-485.
Segment combinations using K2D had about 2,500 to 3,100 more linear feet of stream impact
than the segment combinations that use K3C.
Segment combination K2B-KX4-K3C was eliminated from further consideration in comparison to
segment combination KX1-K3B-K3C because it had more residential relocations (155 vs. 107), with most
of these additional rclocations in one subdivision on the west side of Southpoint Road.
Summary of Deeision Point 6(Between Node CTR-N and Node 1-485)
The Merger Team decided to retain the following segment
combination for detailed study:
• KX1-K3B-K3C
6
.September 20, 2005
NEPA1404 MerKer Tenm Meeting
77P Project U-3321
Gaston County Enst-West Connector Study
Decision Point 7(Node CTR-S to Node 1-485 [northern options/)
The Merger Team decided to retain segment combination K3A-K3B-K3C for detailed study and
eliminate segment combinations K3A-KX3-K2D and K I B-KX2-K2D for the following reasons:
• Designs that use segment K3C are better than designs that use segment K21). Segment K2D has
a less desirable design due to a curve immediately east of the Catawba River bridge and just west
of I-485. This curve cannot be flattened due to space constraints related to tying into I-485.
• K3A-K3B-K3C has 2,100 to 2,200 fewer linear feet of stream impacts.
During these last discussions (Decision Points 7 and 8), the videoconference connection with the USFWS
was lost.
Although K3A-K3B-K3C has a better design at I-485 (does not use segment K21)), it does impact a
potential historic site located at the NC 279 interchange area (Segment K3A). The impact to the potential
historic site is unavoidable with this option. If this option needs to be eliminated later due to the potential
historic site, other alternatives to get froin Node CTR-S to Node I-485 will be available through the
segment combinations retained under Decision Point S. The potential historic site will be evaluated in a
Phase II historic architectural survey that will be prepared for the Detailed Study Alternatives in the Draft
EIS.
Mr. Hennessy stlted that most of the options for Decision Points 6 and 7 were very close to one another
location-wise, and likely would have si?nilar impacts/issues associated with water quality. Therefore, it is
a good idea to eliminate any alternatives that are not preferable based on other issues (less desirable
design, relocations, etc.).
Summary of Decision Poiiat 7(Between Node CTR-S and Node I-485)
The Merger Team decided to retain the following segment
combination for detailed study:
• K3A-K3B-K3C
Decision Point 8(Node CTR-S to Node I-485 (southern options])
The Merger Team decided to retain both the northern option (segment combination KiB-K1C-K1D) and
the southern option (segment combination KlB-K1C-K4A) for detailed study. Segment combination
K1B-K1GK1D has a straighter alignment and fewer stream impacts, but it has more residential
relocations (141 vs 91) and is dependent on the ability to construct a roadway over or through the Allen
Steam Station's retired (dormant) fly ash basin. Mr. Raymond stated that based on the geotechnical
report prepared by NCDOT's Geotechnical Unit (attached) and discussions with the Steam Station plant
manager, constructing a roadway through the t7y ash basin may have constructability issues and may
interfere with the Steam Station operations. The plant manager, Mr. Immel, stated in a telephone
conversation that a roadway through the fly ash basin would be a fatal flaw to the operation of the Steam
Station. Mr. Militscher noted that a fly ash basin is not a jurisdictional resource and the Merger Team
should not be avoiding or minimizing impacts to it at this point.
Summary of Deeision Point 8(Between Node CTR-S and Node I-485)
The Merger Team decided ro retain the following segments
combination for detailed study:
• K1B-K1GK1D
• K1B-K1C-K4A
7
September 20, 2005
NEPA1404 MerKer Team Meeting
T!P Project U-3321
Gastnn Counry East-West Connector Study
Condusion
At the end of the mecting, with the elimination of sebment combinations described above, the Merger
Team had narrowcd down the 90 prcliminary new location alternatives to 16 recommended Detailed
Study Alternatives. The Merger Team did not sign a Concurrence Point 2 form, but agreed to sign it once
the form was updated to list the 16 Detailed Study Alternatives that the team agreed upon. The form has
been updated with the recommended Detailed Study Alternatives and is attached for reference.
NCDOT will call the USFWS for commenUconcurrence on the last few decisions made at the meeting.
The 16 Detailed Study Alternatives recommended by the Merger Team to be carried forward for detailed
study are:
Alt # H Segments J Segments K Segments
4 H2A-H3 J4a-J4b-J2c-J2d-J5a-J5b K2A-KX1-K36-K3C
5 H2A-H3 J4a-J2b-J2c-J2d-JX4-J1e-Jif K1A-K18-K1C-K4A
6 H2A-H3 J4a-J2b-J2c-J2d-JX4-J1e-J1f K1A-K16-K1C-K1D
9 H2A-H3 J4a-J2b-J2c-J2d-JX4-J1e-J1f K1A-K3A-K36-K3C
22 H2A-H26-H2C J3-J2c-J2d-J5a-J5b K2A-KX1-K3B-K3C
23 H2A-H2B-H2C J3-J2c-J2d-JX4-Jle-J1f K1A-K1B-K1C-K4A
24 H2A-H2B-H2C J3-J2c-J2d-JX4-Jle-J1f K1A-K1B-K1C-K1D
27 H2A-H2B-H2C J3-J2c-J2d-JX4-Jle-J1f K1A-K3A-K3B-K3C
58 H1A-H16-H1C J1a-JX1-J2d-J5a-J5b K2A-KX1-K3B-K3C
64 H1A-H1B-H1C J1a-J1b-J1c-J1d-Jie-J1f K1A-K1B-K1C-K4A
65 H1A-H1B-H1C Jia-Jib-J1c-J1d-J1e-J1f K1A-K1B-K1C-KiD
68 H1A-H1B-H1C J1a-J1b-J1c-J1d-J1e-J1f K1A-K3A-K3B-K3C
76 H1A-HX2 J2a-J2b-J2c-J2d-J5a-J5b K2A-KX1-K38-K3C
77 H1A-HX2 J2a-J2b-J2c-J2d-JX4-J1e-J1f K1A-K1B-KiC-K4A
78 H1A-HX2 J2a-J2b-J2c-J2d-JX4-J1e-Jif K1A-K1B-K1C-K1D
81 H1A-HX2 J2a-J2b-J2c-J2d-JX4-J1e-J1f K1A-K3A-K3B-K3C
Attachments
1. Table showing the total estimated impacts for each of the 16 recommended Detailed Study
Alternatives
2. Excel spreadsheets showing the segment combinations retainedleliminated for each area of the
project (H segments, J segments, and K segments) and their estimated impacts.
3. Figure 3- showing the recommended Detailed Study Alternatives
CC: Meeting Attendecs
Minutes Prepared by: PBS&J
8
•? I `T r !
REVIEW BOARD SUMMARY
OF
THE EVALUATION OF
IMPROVE EXISTING ROADWAYS
ALTERNATIVES
GASTON COUNTY EAST-WEST
CONNECTOR STUDY
T.I.P. PROJECT NO. U-3321 -
Prepared For:
dEp ,r °, ,. .
North Carolina Department of Transportation
Project Development and Environmental Analysis Branch
Prepared By:
M61
1616 East Millbrook Road
Raleigh, NC 27609
[phone]
June 10, 2005
TABLE OF CONTENTS
Review Board Summary of the Evaluation of Improve Existing
Roadways Alternatives
Gaston County East-West Connector Study
TIP Project Number U-3321
1.0 Introduction ........... ... ........ .... ........ ....... ............................. ....... . ........ .... ....... . ................ 3
1.1 B ackground .............................................................................................................. 3
1.2 Purpose of Report .................................................................................................... 3
1.3 Purpose and Need for the Project ............................................................................ 3
1.4 Basic Types of Alternatives ..................................................................................... 3
2.0 Memo from FHWA and FTA General Councils on Planning Process Integration ..... 4
3.0 NEPA/404 Merger Process Summary ......................................................................... 4
3.1 Concurrence Point 1(Purpose and Need) - Achieved July 24, 2002 .................. 4
3.2 Concurrence Point 2(Alternatives for Detailed Study) - In process . ................. 4
3.3 Review Board ...................................................................................................... 5
4.0 Travel Demand and Traffic Operations Modeling ....................................................... 5
4.1 Travel Demand Model Scenarios ............................................................................ 5
4.2 Traffic Operations Analyses .................................................................................... 8
4.3 Conclusions from the Travel Demand Modeling and Traffic Operations Analyses 8
5.0 Potential Impacts ..........................................................................................................9
5.1 Potential Environmental Impacts ......................................:.................................... 10
5.2 Potential Engineering Issues .................................................................................. 12
6.0 Inconsistency with Local Thoroughfare Plans and Comprehensive Land Use Plans 14
6.1 Thoroughfare Planning Process ............................................................................. 14
6.2 Comprehensive Land Use Plans ............................................................................ 14
7.0 Inability of Improve Existing Roadways to Meet the Project's Purposes and Needs 14
8.0 Summary .................................................................................................................... 15
1.0 Introduction
1.1 Background
The North Carolina Depar[ment of Transportation (NCDOT) proposes to improve east-west
travel between I-85 west of Gastonia in Gaston County and I-485/NC 160 in Mecklenburg
County. The Gaston County East-West Connector Study is designated as TIP Project No. U-3321
in the NCDOT's 2004-2010 Transportation Improvement Program (TII'). The TIP shows Project
U-3321 as a multi-lane highway on new location from I-85 west of Gastonia to NC 160 in
Mecklenburg County.
The project study area consists of the following general boundaries in Gaston and Mecklenburg
Counties:
* I-85 to the north,
* the South Carolina State line to the south,
* the Charlotte-Douglas International Airport to the east, and
* the I-85 and US 29-74 junction to the west.
1.2 Purpose of Report
The purpose of this report is to explain why the studies and analyses that have been completed to
date sufficiently demonstrate that the Improve Existing Roadways (IER) alternatives should be
eliminated from further study. These alternatives do not meet the critical elements of the purpose
and need for the proposed project and they are not consistent with the local thoroughfare plans
and comprehensive land use plans.
1.3 Purpose and Need for the Project
The purpose of the proposed action is to improve east-west transportation mobility in the area
around the City of Gastonia, between Gastonia and the Charlotte metropolitan area in general,
and particularly to establish direct access between the rapidly growing area of southeast Gaston
County and west Mecklenburg County. This project purpose is based on the following needs:
* Need to improve mobility, access and connectivity within southern Gaston County and
between southern Gaston County and Mecklenburg County.
* Need to reduce congestion and improve traffic flow on the sections of I-85, US 29-74 and
US 321 in the project study area; improve high-speed, safe regional travel service along
the US 29-74 intrastate corridor; and generally improve safety and reduce above average
accident rates in the study area.
1.4 Basic Types of Alternatives
The NCDOT considered the following basic types of alternatives in accordance with FHWA
Guidelines (Technical Advisory T6640.8A):
L No-Action
2. Transportation System Management (TSM) and Transportation Demand Management
(TDM) Measures
3. Mass Transit
4. Improve Existing Roadways (Improve I-85, Improve US 29-74 or Improve Both I-85 and
US 29-74)
5. New Location
2.0 Memo from FHWA and FTA General Councils on Planning Process Inteuation
A recent draft memorandum from the General Councils of FHWA and FTA dated September 20,
2004 discusses the integration of the transportation planning process, which includes
Thoroughfare Plan development, and the NEPA process.
"The transportation planning process required by 23 USC 134 and 135 and 49
USC 5303-5306 is designed to set the parameters for the project development
process. Projects must come from the transportation improvement program
(TIP or STIP) established to implement the plan. As a result, much of the
data and decision making undertaken by state and local officials during the
planning process carry forward into the project development activities that
follow the TIP or STIP. This means that the planning process and the
environmental assessment required during project development by the
National Environmental Policy Act of 1969 (NEPA) (42 U.S.C. 4231 et seq.)
must work in tandem, with the results of the transportation planning process
feeding into the NEPA process. To a much greater degree than other Federal
programs, Congress has put great emphasis on the transportation planning
process for shaping transportation decisions, and has retained and refined that
emphasis in surface transportation law over decades."
3.0 NEPA/404 Merger Process Summarv
3.1 Concurrence Point 1(Purpose and Need) - Achieved July 24, 2002
3.2 Concurrence Point 2(Altcrnatives for Detailed Study) - In process.
Because of the project scope and size of the project study area, the merger team leaders
decided to break Concurrence Point 2 into sections to make the process more
manageable.
Februarv 17, 2004 Pre-Concunence Point 2 meeting
Identified which new location alternatives NCDOT should prepare functional designs
prior to the new-location Concurrence Point 2 meeting.
4
Auizust 17, 2004 Partial Concurrence Point 2 meetinQ
The purpose of this merger meeting was to achieve concurrence on the non-new location
alternatives to be carried forward for detailed study. Agreement on the Improve I-85 and
US 29-74 Alternative could not be reached and the decision was made to elevate to the
Review Board.
3.3 Review Board
September 14, 2004 - Elevation Meeting #1
Merger Tearn members attended. Concurrence was not achieved.
September 29, 2004 - Elevation Meeting #2
The supervisors of the Merger Team members attended. Concurrence was not achieved.
Agencies not concurring with NCDOT agreed to prepare a list of items they would need
to enable them to come to a decision.
Week Ending October 8, 2004
The following agencies provided lists of information and questions to NCDOT: USACE,
USFWS, USEPA, NCDWQ, and NCWRC.
Week Endinp, October 15, 2004
NCDOT provides a response to the information requested by USACE, USFWS, USEPA,
NCDWQ, and NCWRC.
October 27, 2004 - Elevation Meeting #3
On October 27, 2004, the Review Board met to discuss the project and the issues that the
Merger Team had not reached consensus on.
Februarv 8. 2005 - Elevation Meeting #4
The Review Board met to continue discussion of the project issues.
4.0 Travel Demand and Traffic Operations Modelin
4.1 Travel Demand Model Scenarios
As described below, a variety of scenarios were modeled in the regional travel demand model to
estimate traffic volumes and changes in travel patterns that would occur. The results from the
travel demand model also were used to evaluate traffic operations along I-85 and US 29-74.
A No-Build Alternative (Scenario 1) was modeled as a basis for comparison. Scenario 5 and
Scenario Sa are the New Location Alternatives scenarios. Scenarios 2, 3, 4, 4+, 4a, and 8 are
various combinations of improving existing roadways. Scenarios 6 and 7, not reported here, were
various runs to support the development of functional designs for the preliminary new location
alternatives.
Scenario 1- No Build Alternative
No capacity improvements to I-85 or to US 29-74. The addition of Vaffic signals
at six (6) currently unsignalized intersections.
Scenario 2- Improve I-85 to 8 lanes
Widen I-85 to eight lanes in each direction (addition of one through-lane in each
direction) from the existing 8-lane area at Exit 26 (Belmont) west through
Gastonia to the interchange of US 29-74 and I-85. This scenario does not include
any improvements to ramps or overpasses in the I-85 corridor.
Scenario 3- Improve US 29-74 to 6lanes
Widen the bridges over the Catawba River and the South Fork Catawba River to
six lanes. Widen the four-lane section that exists west of Gastonia from Myrtle
School Road west to I-85 to six lanes. This scenario does not include any turn-
lane improvements on US 29-74 or on any other arterials in the project study
area.
Scenario 4- Improve I-85 to 8 lanes and US 29-74 to 6 lanes
Scenario 4 is a combination of Scenarios 2 and 3.
Scenario 4+ - Improve I-85 to S lanes and US 29-74 to 6 lanes with TSM-type measures
(See Figure 1)
Based on the results of the corridor level [raffic operations analysis (CORSIM)
for Scenario 4, a list was developed of additional improvements that would be
needed along and in the direct vicinity of the I-85 and US 29-74 corridors that
would help maximize the efficiency of traffic operations along the corridor. This
list included approximately 70 TSM-type measures such as adding turn lanes or
additional lanes in interchange ramps. The scenario that included these TSM-
type measures was called Scenario 4+.
Scenario 4a - Improve Existing I-85 to 10 lanes (See Figure 1)
Scenario 4a is Scenario 4+ with the following modifications:
• 10 lanes on I-85 from Exit 21 east to Exit at I-485 (widen I-85 to 8 lanes from
Exit 14 east to Exit 21and widen to 6lanes on US 29-74).
• Capacity increases on the following road segments that connect I-85 and US 29-
74:
• NC 279 (New Hope Rd) - Widen to 6 lanes from just north of I-85 to US
29-74
• Cox Rd widen to 6lanes from just north of I-85 to US 29-74
• Cox Rd widen to 4 lanes from US 29-74 south to Garrison
Blvd/Armstrong Park Drive/Gardner Park Ave (this rd has 3 names in
cox rd vicinity)
• Redbud Drive widen to 4 lanes from US 29-74 sou[h to NC 279
• NC 7 at Exit 26 widen to 4 lanes from north of I-85 to US 29-74
6
? Considerations were included in the model to account for intersection
improvements along US 29-74 and at interstate ramps that would result
from implementing the intersection improvements recommended in
Scenario 4+.
Scenario 5- Build a 4-lane New Location Freeway
Build a new location freeway south of I-85 from I-85 west of Gastonia to I-485.
No improvements would be made to existing I-85 or US 29-74.
Scenario Sa - Build a 6-lane New Location Freeway
Scenario Sa, a 6-lane new location freeway, is a modification of the Scenario 5
(4-lane new location freeway). The PM peak hour traffic volume results for
Scenario 5 indicated a 6-lane freeway on new location would be needed, so the
regional travel demand was rerun with a 6-lane new location freeway.
Scenario 8- Scenario 4a plus capaciry improvements to north/south feeder roads (See
Figure 2)
Scenario 8 started with Scenario 4a (Improve Existing I-85 to 101anes). Added
to this were capacity improvements (one lane in each direction) to north/south
roads that connect southern Gaston County to US 29-74 and I-85, as have been
suggested in a general way by some of the resource agencies. Below is a list of
the roadways where capacity improvements were added in the regional model.
The list was developed with input from the Gaston Urban Area MPO. It does not
include all the feeder roads that have exits on I-85. For future reference, the list
was numbered from 1 through 10 based on the roadway section.
Section
1 NC 273 south all the way to NC 279 at the Botanical Garden (41ane divided)
2 NC 7 from Exit 27 south to NC 273 (41ane divided)
3 NC 279 (New Hope Rd) from Exit 20 on I-85 south all the way to NC 273 at the
Botanical Garden (5 lanes)
4 Redbud Dr from Exit 22 at I-85 south to NC 279 (4 lane divided)
5 NC 274 (Union New Hope Rd) Robinwood Rd south past the airport continuing
on Union/New Ho e Rd swin in northwest to NC 279 (41ane divided)
6 Robinwood Rd from NC 279 New Hope Rd south to NC 274 (4lanes)
7 Robinson Rd from NC 274 south to US 321 (5 lanes)

8 NC 274 at Exit 14 south to Myrtle School Rd, continuing south on Myrtle School
Rd all the way to US 321. This road changes names to David Rd then
Sta ecoach Rd before meetin u with US 321. (4 lane divided or 5 lane)
9 NC 274 from State Line to Union/S. New Hope (4 lane divided)

10 US 321 widened to 6 lanes from State Line to I-85 (Note: This project impacts
the City's Main Historic District but the widening is necessary to handle existing
and ro'ected future traffic.)
7
4.2 Traffic Operations Analyses
In order to evaluate Scenarios 1-5, corridor level traffic operations analysis was performed using
a traffic micro-simulation model - CORSIM. This operational analysis evaluated future 2025
peak hour operations of the Improve Existing Roadways Alternatives (Scenarios 2-4) as
compared to Scenario 5(New Location) and Scenario 1(No-Build).
4.3 Conclusions from the Travel Demand Modeling and Traffic Operations Analyses
Latent demand for Interstate travel exists in the area
The regional travel demand model showed that as capacity was increased on I-85 and US
29-74 (i.e. more lanes added to I-85 and US 29-74), more people would use it. For
example, if I-85 was widened to eight lanes through the study area (Scenarios 4, 4a, and
4+), this would attract up to 1,000 more vehicles during the PM peak hour over the
estimates for the No-Build scenario. ff I-85 was widened to lO lanes (Scenario 8), this
would attract up to 1,600 more vehicles per hour during the PM peak.
Substantial diversion of traffic off of I-85 and US 29-74 projected to occur if a New Location
roadway were built
Up to 20-25 percent of the traffic on I-85 would be diverted to a new location Gaston
Connector if one were constructed (Scenarios 5 and Sa). This means that I-85 would
carry up to 1,400 less vehicles per PM peak hour compared to the No-Build scenario and
up to 2,800 vehicles per PM peak hour less compared to widening I-85 to 10 lanes.
Regional network statistics demonstrate a reduction in conizested travel for a New Location
roadway and for Scenario 8(Widen I-85 to lO lanes and widen feeder routes).
Statistics for the entire modeled roadway network were generated from the regional travel
demand model. These statistics are for AM and PM peak periods and include vehicle
miles traveled> vehicle hours traveled, congested vehicle miles, and congested vehicle
hours.
Building a new location roadway resulted in lower vehicle hours traveled, lower
congested vehicle hours, and lower congested vehicle miles on the roadway network than
widening I-85 to 8 lanes (Scenario 4).
Building a new location roadway reduced congested vehicle miles traveled as effectively
as widening I-85 to 10 lanes (Scenarios 4a and 4+). Only when all the north/south feeder
roads were widened (Scenario 8), does the non-new location alternative reduce congested
vehicle hours substantially more.
8
Traffic onerations would be enerally better or as good on I-85 with a new location freewa,y in
l?ace
Building a new location roadway (Scenario Sa) generally resulted in better or equal
average levels of service on I-85 and US 29-74 than improving these existing roadways
(Scenario 4a and 8), even to 101anes. See Exhibit 1.
EXHIBIT 1
Levei
of
Service
5F
4 E/F
3 D/E
2 C/D
1C
0
Levels of Service on I-85
Westbound PM Peak Hour in 2025
Interchange - West to East
¦ Scenario 1
No Build
Scenario 4a
? I-85 to 10 lanes
? Scenario 5a
New location
6 lane freeway
Scenario 8
?I-85 to 10 lanes
With Y-line
Improvements
5.0 Potential Imnacts
Several potential impacts were considered in the evaluation of the improve existing roadways
alternatives. Impacts analyzed were for Scenario 8 since this scenario (which improved the
north/south feeder roads [or y-lines]) provided the best opportunity to meet the purpose and need
out of all the Improve Existing Roadways Alternatives.
Scenario 8 includes numerous improvements to north/south feeder roads in southern Gaston
County as shown in Figure 2. Most of these improvements would be widening existing US and
NC routes such as US 321, NC 7, NC 273, NC 274, and NC 279 to four or five-lane roadways.
Figure 2 also shows a representative index of the approximate location in the project study area
of Figures 3-6.
9
13 14 17 19 20 21 22 23 26 27 29 1-485
The estimates of potential impacts were based on information obtained from NCDOT and Gaston
County GIS databases, aerial photography, and preliminary field observations. Potential impacts
for Scenario 8 have been organized into two categories, environmental and engineering.
Potential impacts from improving the existing east-west roadways, I-85, and US 29-74 are
discussed for both categories, along with impacts due to the feeder route improvements. The
following table illustrates the potential impacts from the feeder route improvements for the 10
roadway sections described above in Section 4.1. Further discussion is provided below.
5.1 Potential Environmental Impacts
Human Environment
In general, improvements to exisiing I-85 and US 29-74 likely would have an overall lesser
impact on the natural environment than a new location alternative. However, impacts to the
human environment may be equal to or greater than a new location alternative for Scenario 8.
Potential impacts to the human environment would be greatest for improvements along US 321,
NC 279, and NC 273. The following human environment impacts along the feeder routes would
be in addition to the human environment impacts associated with improvements along I-85 and
US 29-74.
Relocations. Widening sections of the feeder routes would impact churches, residences,
businesses, churches, community facilities, parks and historic districts along these roadways.
NC 279 (Section 3) and NC 274 (Section 8) could potentially impact 20 churches along the
approximate 16 miles of improvements. In general, potential residential impacts are greatest
along existing two-lane routes such as NC 273, NC 279, and NC 274 where single-family homes
and their individual driveways are located on both sides of the roadway. Potential business
impacts would be greatest near or between I-85 and US 29-74, such as along US 321 (Section 10)
and NC 7(Section 2). Figures 3 and 4 show the high density development along US 321 and
NC 7 where business impacts could occur, respectively.
Potential community facility impacts would be greatest along NC 279 (Section 3) and NC 274
(Section 5). Figure 5 shows a section of NC 279 (Section 3) with a high potential for impacts to
community facilities, churches, and potential historic properties.
Parks. Two roadway sections have the potential to impact parks based on additional roadway
widening. Widening of NC 7 through Belmont could impact Crescent Park (Figure 4) and the
widening of NC 279 could impact the Daniel Stowe Botanical Garden.
Historic Sites and Districts. A Phase I survey of historic architectural resources was conducted
in May 2003 for the new location study area. The study also identified known historic sites and
districts on or eligible for the National Register of Historic Places located in the I-85 and US 29-
74 corridors.
10

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Historic sites are located along existing US 29-74 (Franklin Boulevard) and US 321 (York
Street). Where these two roadways intersect in Gastonia is the Downtown Historic District
(National Register of Historic Places) which could not be avoided by improvements. Figure 3
shows the Downtown Historic District in Gastonia. Improvements to US 29-74 (Wilkinson
Boulevard) through Belmont could impact the Beimont Historic District.
There are six potential historic sites along NC 279 (Section 3) and US 321 (Section 10) that could
be impacted by improvements. Figure 5 shows some of the potential historic sites along NC 279.
Natural Environment
Potential impacts to the natural environment could be high along existing US 29-74, where
approximately 6.3 miles of improvements would be necessary to upgrade to six-lanes along the
corridor. Where improvements are necessary, there are several stream and floodplain crossings.
Six new bridge crossings would be required, one over the Catawba River, one over the South
Fork of the Catawba River, and four west of Myrtle School Road.
Potential impacts to the natural environment would be greatest for improvements along US 321
(Section 10) and NC 273 (Section 1) due to the stream crossings and bridge replacements.
Improvement to US 321 would require crossing two streams (one crossing is an existing
potentially historic bridge) with three new bridges. Also, four floodplains would potentially be
crassed and two known hazardous material sites could be impacted. The two hazardous material
sites are RCRA or CERCLA sites, A.B. Carter, Inc. and Woody's Tire Fire. The A.B. Carter,
Inc. site generated, treated and land disposed of wastewater and sludge from a chroming and
nickel plating operations for the textile machinery. The Woody's Tire Fire site was used to store
used tires with roughly 50,000 to 100,000 tires that caught on fire.
Improvements to NC 273 would require crossing two streams with two new bridges one of which
will be over the South Fork of the Catawba River.
Air Quality
The current NCDOT Transportation Planning TransCad model includes all current T1P projects.
At this time, a new location roadway such as the one represented on the Gaston Urban MPO
Thoroughfare Plan is modeled. Without updating the model, it is unknown what will happen to
air quality if the new location freeway represented in lhe model is replaced with `improve
existing I-851US 29-74' for TIP Project U-3321, the Gaston County East-West Connector Study.
5.2 Potential Engineering Issues
Constructabiliry
I-85 would require widening to a minimum of eight to ten lanes throughout the study area under
Scenario 8. The total length of proposed improvements along I-85 would be approximately 20.5
miles. All interchanges along I-85 in the project study area (a total of 11) would need to be
reconstructed in order to meet current AASHTO design standards. In addition to work at the
eleven interchanges in the project study area, there are fifteen (15) cross street bridges and six
railroad bridges that would need to be replaced because of inadequate horizontal clearances for
additional lanes. Figure 6 shows an example of one of the substandard interchanges in the
12
project study area (I-85 at Ozark Avenue [Exit 19]) where an interchange and a railroad bridge
would have to be reconfigured if improvements were made to existing I-85.
Maintenance of Traffic(MOT) and Travel Delays
The re-construction of interchanges and replacement of structures along I-85 would result in
lengthy construction periods with significant driver delay through these construction zones, and
would require complex maintenance-of-traffic plans to allow for the safety of the motorists and
the construction workers. In order to maintain existing traffic patterns, these new bridge
structures would need to be constructed on new alignments, and where possible, adjacent to the
existing structures. These reconstructions and realignments would impact adjacent businesses.
Safety, Bridge Replacement, and Construction Schedule
The construction of new bridge structures would result in increased driver delay and could impact
driver safety during the construction period. In order to attempt to minimize these delays, it
would be recomrnended to stagger the replacement of these bridges within the project study area
limits. By staggering [his construction, there could be a delay of 10 years or more before
widening of I-85 could be completed, resulting in continued driver delays. This estimate of
construction schedule was based on the local knowledge of the NCDOT Division Construction
Engineer.
Diversion of Traffic Patterns
While structural issues of bridges would not be as prevalent along US 29-74 as compared to I-85,
there would likely be increased driver delays and potential economic impacts to local merchants
due to changes in travel patterns because of construction along a majority of this east-west
corridor.
Construction of feeder route improvements outside of the urban areas would be disruptive to
traffic patterns in southern Gaston County, which currently suffers from the lack of east-wesf
connectivity. Improving the feeder routes while constructing or making improvements along
existing I-85 and US 29-74 would reduce mobility and increase travel times between Gaston and
Mecklenburg County. Waiting until the I-85 and US 29-74 improvements were completed
would extend the already extremely lengthy construction period.
Cost
Preliminary construction cost estimates were developed by NCDOT in September 2004 for
Scenario 4+. The estimated construction cost was $291.9 million dollars. However, right-of-
way (r/w) and utility costs were excluded from the estimate. Based on the additional length of
improvements along existing I-85 (approximately 4.9 miles) and feeder route improvements for
Scenario 8, it is anticipated that the cost estimate (exclusive of r/w and utility costs) would be
higher and could come close to or exceed the costs of the New Location route.
13
6.0 Inconsistencv with Local Thoroughfare Plans and Comprehensive Land Use
Plans
6.1 Thoroughfare Planning Process
The Gaston Urban Area Metropolitan Planning Organization (MPO) recommends a new location
highway to improve east-west mobility in southern Gaston County. This new highway is shown
on the Gaston Urban Area Thoroughfare Plan and is locally known as the "US 321/74 Bypass"
and the "Garden Parkway". The "Garden Parkway" is the number one priority on the MPO's
Unmet Needs List, which is a subset of the Gaston Urban Area Thoroughfare Plan.
The Mecklenburg-Union MPO Thoroughfare Plan also identifies a transportation need for an
additional crossing of the Catawba River.
6.2 Comprehensive Land Use Plans
The comprehensive land use plans of both Gaston County and Mecklenburg County show
southeast Gaston County and western Mecklenburg County as high growth areas. Both
comprehensive plans show a new roadway connection across the Catawba River between these
two high growth areas. Western Mecklenburg County and the Charlotte-Douglas Airport are
expected to be, or already area, major employment centers. The Charlotte-Douglas International
Airport is proposing a new intermodal facility in the southwest portion of their property.
7.0 Inabilitv of Improve Existing Roadwavs to Meet the Proiect's Purposes and
Needs
The project's purpose and need has two critical basic elements; 1) improve east-west mobility and
connectivity within southern Gaston County and between southern Gaston County and west
Mecklenburg County and 2) improve traffic flow on I-85 and US 29-74 (the only existing east-
west corridors in the study area).
The following summarizes the inability of the Improve Existing Roadways Alternatives
(Scenarios 4, 4+, 4a, and 8) to meet the project's purposes and needs:
1. South of US 29-74 there are no continuous east-west roadways in the southern half of
Gaston County. Improvements to I-85, US 29-74 and north/south feeder roads proposed
under Scenario 8 would not improve east-west mobility in southern Gaston County.
2. Geographically, southern Gaston County and western Mecklenburg County are
completely isolated from each other by the Catawba River. There are no crossings of the
Catawba River south of US 29-74 until the NC 49 Buster Boyd Bridge in York, South
Carolina, about 11 miles downstream from US 29-74. Improvements to I-85, US 29-74
and north/south feeder roads would not provide the needed connectivity between
southeastern Gaston County and western Mecklenburg County.
14
3. The regional travel demand model runs show that improvements made to US 29-74 and
existing I-85 continue to attract more traffic due to the latent travel demand in the area,
resulting in a"build it and they will continue to come" situation.
4. The regional travel demand modeling and corridor-level operations analyses (described in
Section 3) demonstrate that the diversion of traffic achieved by a new location roadway
(Scenario S) is more effective or as effective at improving traffic flow on I-85 and US 29-
74 than providing direct improvements to these roadways.
Improving existing I-85 and US 29-74 would not meet the need for connectivity and
would only minimally improve traffic flow on existing I-85 and US 29-74. People would
still have to travel north on two-lane roadways, many through downtown areas, and some
through historic districts, to go east and west. Even when improvements to north/south
feeder roads were added to create Scenario 8, additional traffic is attracted to I-85 during
the peak hour because of the latent demand. As a result, the levels of service along I-85
degrade for Scenario 8 as compared to Scenario 4a.
6. While improving existing I-85 would improve traffic capacity and operations along I-85
in the study area, it is not a reasonable alternative due to travel delays during
construction, long construction duration, and community disruption caused by the
required improvements to existing I-SS and the north-south feeder routes in the study area
to improve access to the interstate. Scenario 8 would require construction at 11
interchanges and 15 cross street bridges along I-85, replacing six (6) bridges along US
29-74 and rep(acing 10 bridges along the y-lines.
7. Scenario 8(Improve 1-85 to lO lanes, US 29-74 to 6 lanes and improve feeder roads) will
significantly impact the human environment within the entire project study for
businesses, residences, community facilities, safety, travel patterns, and historic sites.
Potential impacts to the human environment would be greatest for improvements along
US 321, NC 279, and NC 273. Potential impacts to the natural environment would be
greatest for improvements along US 321 and NC 273 due to the stream crossings and
bridge replacements. Potential impacts to the natural environment could be high along
existing US 29-74 where six new bridge crossing would be required.
8. Scenario 5(Build a New Location Freeway) satisfies the critical elements of the purpose
and need statement because it 1) improves east-west mobility and connectivity within
southern Gaston County and between southern Gaston County and west Mecklenburg
County and 2) Improves traffic flow along I-85 and US 29-74.
8.0 Summarv
As described above, the NCDOT believes the studies and analyses that have been completed to
date sufficiently demonstrate that the Improve Existing Roadways (IER) alternatives should be
eliminated from further study. These alternatives do not meet the critical elements of the purpose
and need for the proposed project and they are not consistent with the local thoroughfare plans
and comprehensive land use plans.
15
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DRAFT
1/17/2007
Section 6002 Coordination Plan for [INSERT NAME] Project
Note: This draft has been prepared as a template for project-specific plans. There will be a separate
Coordination Plan for each project that follows the Section 6002 process.
COORDINATION PLAN
1. General.
1. l. Purposc. This plan is intcndcd to satisfy thc rcquircmcnt for a Coordination Plan
undcr Scction 6002 of SAFETEA-LU (23 U.S.C § 139).
1.2. Applicability. Thc plan applics to the [INSERT NAME] projcct, which has becn
designatcd by the NCTA as a candidate turnpike project.
2. Project Initiation
2.1. Project Initiation Notica The environmental review process for a project will be
initiated when the North Carolina Turnpike Authority submits a project initiation
notice to the FHWA. This notice will be provided in the form of a letter from
NCTA to FHWA. A draft Notice of intent will be included with this noticc.
2.2. Notice of Intent. After recciving a project initiation notice from NCTA, and after
determining that an EIS is needed, FHWA will issue a Notice of Intent to prepare
an EIS. The NOI will be published in the Federal Rcgister.
3. Pro4ect Schedule
3. l. Schedule. Thc NCTA will prepare a project schedulc showing projected datcs for
completing all environmental studies and permitting. The schedule will conform
to SAFETEA-LU time frames for comment pcriods and the FHWA "Vital Fcw
Goal" of achieving a median time frame of thrce years for completing an EIS. The
schedule will include, at a minimum, projccted dates for thc following actions:
• issuing the notice of intcnt;
• identifying the detailed study alternatives;
• issuing the DEIS;
• announcing the preferred alternative;
• issuing thc FEIS;
• issuing the ROD;
DRAFT - 01/17/2007
projcct; and (C) docs not intcnd to submit commcnts on thc project." [Note to
reviewers: Thesefindings are reya+ired by the statute, ifa,federal agency declines
nn invitation to he u participating agency.]
4.3.4. Non-Fcdcral Invitccs. Non-Fcderal agcncics arc not requircd to acccpt
designation; they become Participating Agencies only if they affirmativcly accept
thc invitation. If a non-Fcderal agency declines or does not respond to thc
invitation, thc agcncy will not bc considcred a participating agcncy.
4.3.5. No Implicd Support. Dcsignation as a Participating Agcncy shall not imply that
thc Participating Agcncy supports a proposcd projcct; or has any jurisdiction ovcr,
or special expertisc with respect to evaluation of, the project.
4.4. Cooperating Ae?ncies. A Participating Agcncy also may bc designatcd as a
Coopcrating Agcncy. Thc responsibilitics of a"Cooperating Agency" arc defined
in the CEQ regulations and arc unchanged by SAFETEA-LU. In general,
designation as a Cooperating Agency signifies a somewhat highcr levcl of
involvement and responsibility in the environmcntal review proccss. Federal,
Statc, or local government agencies can bc designated as Cooperating Agencics.
For this projcct, the following agencics will bc invited to serve as Coopcrating
Agcncies: [INSERT NAMES]
5. AQCncy McctiW
5.1. Monthly Meetings. The principal method for agency coordination on turnpike
projects will be monthly mectings hosted by NCTA. These meetings will be used
as a forum for discussing all turnpikc projccts, including thosc being studied under
other procedures as well as thosc being studied under Section 6002. All monthly
mcctings will bc hcld at the NCTA office in Raleigh, unlcss otherwisc specified in
the meeting invitation.
5.2. Mceting Dates. The schedule for thc monthly meetings will be determined by
FHWA and NCTA aftcr consultation with NCDOT and thc Participating Agcncics.
This schcdule will be established, to the cxtcnt possible, for 12-month pcriods.
The schedule will be coordinated with NCDOT interagency meetings to avoid or
minimizc conflicts.
5.3. Meeting Materials. The materials for cach monthly meeting will include an
agcnda, a summary of the previous meeting, and (if applicable) othcr matcrials to
review in advance of the upcoming mecting. To the cxtcnt possiblc, materials for
each monthly meeting will be provided to the Participating Agencies at the
preceding monthly meeting - for example, the Junc meeting materials will bc
provided at the May mecting. Any materials that are not provided at that timc will
be postcd on a sccurc web sitc for downloading at least onc weck prior to thc
mccting. Thc sccurc wcb sitc also will bc uscd to makc an archivc of all monthly
meeting materials available to all Participating Agcncies.
DRAFT - 01/17/2007 3
resolution prucess. One option to consider is using the ILT as a forum,for
resolving issue,s that cannot be resolved in the monthly meetings. J
6.6. Formal [ssue Resolution. Under the statute, NCTA or the Governor may rcqucst a
mecting at any time to resolve issues of conccrn. If such a mceting is requested,
FHWA will convenc a meeting in accordance with SAFETEA-LU to resolve the
speciticd issues of concern. If an issuc of concern is not resolved within 30 days
after such a meeting, a report must bc submitted to Congress and to thc heads of
certain agencies, as providcd in SAFETEA-LU. If such a meeting is not
requested, Fi IWA and NCTA will seek to address and resolve the agencies' issues
of concern as part of normal agency coordination during the environmental review
proccss. [Note to reviewer.s: The reference to the Governor is specifically in the
statute.J
" SIP
7. Mcthodologics and Lcvcl of Dctail for Altcrnatives Analysis
?\ o\
7.1. Proposcd Methodologies. Tarly in project dcvclopment, NCTA will prepare
materials outlining proposed methodologies for analyzing alternatives. Thc M tU
materials will summarize the methodologies intendcd to be used for each ?A
substantive area within the EIS - noisc, air, watcr resources, traffic issues,
`-? secondary and cumulative impacts, etc. Standard procedures will simply bc
rcfcrenccd, wherc applicable. Any modifications to standard proccdures will be
identified and discussed in more depth.
7.2. Opportunitv for Agenc y lnput. The proposed mcthodologies will be devclopcd in
consultation with affected agencies. For cxamplc, the USACE and NCDENR will
? be consultcd in dcvcloping the methodology for analyzing impacts to aquatic
resources; the SHPO will be consulted in dcvcloping methodologies for analyzing
impacts to historic sitcs (including both architectural and archcological resourccs).
7.3. Ongoing Coordination. Mcthodologies for alternatives analysis will be refined
throughout the environmental review process. The Lead Agencies will discuss
adjustmcnts, as appropriate, with Participating Agencies at monthly mcetings.
7.4. Lcvel of Dctail. Thc Lead Agencies, in consultation with thc Participating
? Agcncies, will dctermine the appropriatc lcvcl of dcsign detail for preliminary
alternatives, for thc dctailed study alternatives, and for the preferred alternativc.
7.4.1. Preliminary Alternatives. In gcneral, functional design will be prepared for all
prcliminary alternativcs, except for thosc preliminary alternatives that have a
"fatal flaw" that allows them to bc dismisscd as unrcasonablc without a functional
dcsign.
7.4.2. Detailed Study Altcrnatives. In general, functional design will be uscd as the
basis for comparing the impacts of the alternatives in the DEIS (known as the
Detailed Study Alternatives) and will be uscd for developing the cost estimates
presented in the DF,IS. A higher level of design dctail may be developed for
DRAFT - 0 1/17/2007 5
purpose and nccd may be a gradual, itcrativc proccss that occurs during the project
devclopment proccss, up to publication of the DEIS (and possibly aftcrward in
responsc to commcnts on thc DEIS). This proccss will includc an opportunity for
agcncies and the public to commcnt on the purposc and need as part of their
rcview of the altcrnatives screcning report. (Sec Part 9.4 and 9.5 below.)
9. Dcvelopmcnt and Scrccning of Altcrnativcs
9.1. Conccptual Altcrnativcs. An initial sct of conccptual altcrnatives will bc
developcd as early as practicablc in thc process. The conccptual alternativcs may
bc dcvclopcd concurrcntly with thc prcliminary purposc and nccd statemcnt.
Thesc altcrnativcs will be providcd to thc agencics along with the environmental
constraint mapping that providcs thc basis for idcntifying issucs of conccrn. (Sce
Part 6.1 above.) [Note to reviewers: This is a"will " because Section 6002
requires agencies to he given information ahout environmental issues and "the
general [ocations of the alternatives under consideration" as early as practicable
in the process. /
9.2. Altcrnatives Dcvclopmcnt. Through agcncy coordination and public involvemcnt,
NCTA will dcvclop a rangc of prcliminary altcrnativcs tor considcration. This
range may cxtend bcyond thc initial set of conceptual alternatives. This effort is
intcnded to be comprehensive and inclusivc. NCTA will maintain a summary of
all altcrnativcs suggestcd by Participating Agcncics and thc public.
9.3. Alternatives Screening Report. The NCTA will prepare an alternativcs scrcening
rcport that presents the justification for eliminating alternativcs from further
considcration, and idcntifics alternativcs proposcd for dctailcd study. Thc
alternatives screcning rcport will be provided to the Participating Agcncics and
discussed in a monthly mccting.
9.4. Opportunity for Public Input. A summary of thc altcrnativcs screcning report will
bc madc availablc for public rcvicw and commcnt. A public mceting (or
meetings) will bc held in the projcct arca during thc public commcnt period on this
rcport. This commcnt pcriod will scrvc as thc public's opportunity for
involvcment in both dcveloping thc purposc and nced and dctermining thc rangc
of altcrnatives to bc considcrcd in thc EIS. A rcport summarizing public input will
bc provided to Participating Agencics. Agencies will be given notice of the public
mccting and will bc wclcomc to attcnd.
9.5. Opportunitv for Agcncy Input. Participating Agcncies will bc givcn a 30-day
pcriod to provide additional comments on the alternatives screening rcport
following distribution of the report summarizing public comments. Participating
Agencics will not be asked to concur in thc altcrnatives screening report.
Participating Agcncies will bc askcd to submit any significant objcctions to thc
altcrnatives screcning report in writing to FHWA and NCTA on agency letterhead.
DRAFT - 01/17/2007
12. Scction 404/401 Permitting_aici Othcr Pcrmits/Approvals
12.1. Early Coordination. NCTA will conduct carly coordination with thc ? tc?
Participating A c??ics to identify potential ., .
: applicablc pcrmitting
rcquircmcnts and to dctcrminc thc ailalysis and docttmcntation rccuircd to satisl? tlsc
rcquircmcnts. Sec Parts 6 and 7 abovc. Pcniiits that may bc applicablc to this projcct
incluclc:
IINSER'1'ANY PERMITS THATAREAPPLICAf3Ll?]:
12.2. Comment Opportunitics. Thc n T r??nCE participating A gcncics will bc invitcd to
providc writtcn comments at scvcral points in thc proccss as notcd abovc. Thc Lcad
agene+es-Aq;cncics will considcr all writtcn commcnts submittcd by the "S^id
k'?r,RParticipating Agc_ncics. If'''° Uc n Cr: no NGr,r.,.ro a participaling AgencY
raiscs an issucs of conccrn (dcfined as issucs that cou(d dclay issuancc of a pcrmit or
result in dcnial oFa permit), thc lead-Lcad ageneies-Agcncics will confer with die
Ue nGE .,.,d/,... NGnFNkihat agcncY, and with other agencies as appropriate, to
address thosc issucs.
12.3. Jurisdictional Determinations. The NCTA will prepare thc ncccssary documcntation to
obtain jurisdictional dctcrminations by the USACC (and, as appropriatc, NCDENR) for
all wetlands and streams within a corridor along cach ofthe detailed study alternatives
(unlcss othcrwisc dctcrmincd as part of thc discussion of mcthodologies in accordancc
with Scction 7 of this plan). Thcse detcrminations will bc uscd as thc basis for
comparing wetlands and stream impacts in the DEIS. The width of thc corridor within
which jurisdictional dctcrminations arc madc will bc dctcrmincd on a projcct-by-
projcct basis.
12.4. Prc-Application Consultation. Thc NCTA will cngagc in prc-application consultation,
as appropriatc, with cach agcncy that is responsiblc for making a pcrmit dccision on
thc projcct. For projccts rcquiring a Scction 401 and Scction 404 pcrmits, tllc prc-
application consultation will includc a dctailcd hydraulic clcsign rcvicw.
12.5. G;l:n ,.'• ce,.4:,.., nnn oo.-.r:, n 1:e.,+;0H (Rcqucst tor I'ublic Noticc?. Thc NCTA will
submit the Section 404 permit application to the USACE at thc timc the DEIS is
issucd. This application will typically bc submitlcci prior to iclcntilication of a
nrclcrrcd altcrnativc: thcrcforc, it tvnicallv will not idcntifv thcttl snccific altcrnativc
for which the pcrmit is bcin r requcstcd. This submittal will enable the USACE to
issue a public notice and to use the FHWA/NCTA public hearing on the DEIS as the
USACE's public hearing on thc Section 404 application [Note: This could he
modifted on a case-by-case basis.]
DRAFT - 0 1/17/2007 9
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Agenda
January 25, 2007

Introduction and Welcome
Project Coordination Plans
The revised general coordination plan will be distributed to agency represenfatives
and posted on the TEAC website. The plan is presented at this meeting to highlighf
the revisions incorporated per agencies' requesf only. The plan will be discuss in
detail at fhe February 14, 2007 meeting. This will allow agencies adequate time to
fully review the plan and prepare quesfions or comments for fhe detailed
discussions. Additionally, agreement upon the agencies that will serve as
cooperating and participating agencies for the NCTA projects is proposed.
1:45 - 2:00

1:30 -1:45
2:00 - 2:15
"Spotlight" Projects .- ?
Monroe Bypass/Connector
2:15 - 4:00
lu?"???ke ?,uthorl?y
"Snapshot" Projects
Gaston East-West Connector
?
DRAFT
1/17/2007
Section 6002 Coordination Plan for [INSERT NAMEJ Project
Note: Tkis rlraft ltas heete prepared as a template for project-specific plnris. Tleere will be a separate
Coordiiintiote P/ai: f'or each prnject that fnllows tke Section 6002 process.
COORDINATION PLAN
1. General.
1.1. Pttrpose. This plan is intended to satisfy the requirement for a Coordination Plan
under Section 6002 of SAFETEA-LU (23 U.S.C § 139).
1.2. Applicabilitv. The plan applies to the [INSERT NAME] project, which has been
designated by the NCTA as a candidate turnpike project.
2. Project Initiation
2.1. Project Initiation Notice. I'he environmental review process for a project will be
initiated when the North Carolina Turnpike Authority submits a project initiation
notice to the FHWA. This notice will be provided in the form of a letter from
NCTA to FHWA. A draft Notice of Intent will be included with this notice.
2.2. Notice of Intent. After receiving a project initiation notice from NCTA, and after
determining that an EIS is needed, FHWA will issue a Notice of Intent to prepare
an EIS. The NOI will be published in the Federal Register.
3. Project Schedule
3.1. Schedule. The NCTA will prepare a project schedule showing projected dates for
completing all environmental studies and permitting. The schedule will conform
to SAFETEA-LU time frames for comment periods and the FHWA "Vital Few
Goal" of achieving a median time frame of three years for completing an EIS. The
schedule will include, at a minimum, projected dates for the following actions:
• issuing the notice of intent;
• identifying the detailed study alternatives;
• issuing the DEIS;
• announcing the preferred alternative;
• issuing the FEIS;
• issuing the ROD;
DRAFT - 01/17/2007
• applying for and obtaining the Section 404 permit and other required permits or
approvals - e.g., Section 401 certification, Coast Guard bridge permit, etc.;
• obtaining financing (issuance of bonds); and
• letting contracts and Ueginning construction.
3.2. Agency Consultation. The schedule will be shared with the agencies and
discussed at a monthly meeting. Agency comments will be considered and the
schedule may be revised as appropriate.
3.3. Updating Schedules. The project schedule may be revised from time to time by
the lead agencies during the environmental review process. Under the statute, the
schedule may be extended by the lead agencies for good cause, and may be
shortened only with the consent of Cooperating Agencies, if Cooperating Agencies
are designated. [Note to reviewers: This coraditiort is specified iri the statute itself.]
4. Aizencv Roles
4.1. Lead Federal Agency. FHWA will be the lead Federal agency. As lead Federal
agency in the Section 6002 process, FHWA is responsible for making certain
decisions as specified in Section 6002. In addition, FHWA has an overall
responsibility for facilitating the expeditious completion of the environmental
review process.
4.2. Joint Lead Agencies. NCTA will be a joint lead agency, and thus will share with
FHWA the responsibilities of the "lead agency" under the process defined in
Section 6002. NCDOT also will have the status of a joint lead agency; however,
NCDOT will primarily have a review/support role in the process, consistent with
the Preconstruction Guidelines adopted by NCDOT and NCTA in July 2006.
4.3. Participating Agencies. NCTA will issue letters inviting Federal and non-Federal
agencies to serve as Participating Agencies for each project developed under this
plan. Participating Agencies include any Federal, State, or local agencies that may
have an interest in the project.
4.3.1. Invitation List. Invitations will be sent to Federal and non-Federal agencies that,
in the judgment of FHWA and NCTA, may have an interest in the project. A list
of Participating Agencies is attached as Exhibit 1 to this plan. [TO BE
DRAFTED]
4.3.2. Deadline. Invitation letters will specify a 30-day deadline for agencies to respond
to the invitation.
4.3.3. Federal Invitees. A Federal agency that is invited to be a Participating Agency
will be presumed to have accepted the invitation, unless the agency informs
NCTA in writing, by the deadline, that it: "(A) has no jurisdiction or authority
with respect to the project; (B) has no expertise or information relevant to the
DRAFT - 01/17/2007 2
project; and (C) does not intend to submit comments on the project." [Note to
reviewers: These findings are required by the statute, if a federal agency decliraes
an invitation to be aparticipating agency.]
4.3.4. Non-Federal Invitees. Non-Federal agencies are not required to accept
designation; they become Participating Agencies only if they affirmatively accept
the invitation. If a non-Federal agency declines or does not respond to the
invitation, the agency will not be considered a participating agency.
4.3.5. No Implied Support. Designation as a Participating Agency shall not imply that
the Participating Agency supports a proposed project; or has any jurisdiction over,
or special expertise with respect to evaluation of, the project.
4.4. Cooperating A eg ncies. A Participating Agency also may be designated as a
Cooperating Agency. The responsibilities of a"Cooperating Agency" are defined
in the CEQ regulations and are unchanged by SAFETEA-LU. In general,
designation as a Cooperating Agency signifies a somewhat higher level of
involvement and responsibility in the environmental review process. Federal,
State, or local government agencies can be designated as Cooperating Agencies.
For this project, the following agencies will be invited to serve as Cooperating
Agencies: [INSERT NAMES]
5. Agency Meetings
5.1. Monthly Meetings. The principal method for agency coordination on turnpike
projects will be monthly meetings hosted by NCTA. These meetings will be used
as a forum for discussing all turnpike projects, including those being studied under
other procedures as well as those being studied under Section 6002. All monthly
meetings will be held at the NCTA office in Raleigh, unless otherwise specified in
the meeting invitation.
5.2. Meeting Dates. The schedule for the monthly meetings will be determined by
FHWA and NCTA after consultation with NCDOT and the Participating Agencies.
This schedule will be established, to the extent possible, for 12-month periods.
The schedule will be coordinated with NCDOT interagency meetings to avoid or
minimize conflicts.
5.3. Meetiniz Materials. The materials for each monthly meeting will include an
agenda, a summary of the previous meeting, and (if applicable) other materials to
review in advance of the upcoming meeting. To the extent possible, materials for
each monthly meeting will be provided to the Participating Agencies at the
preceding monthly meeting - for example, the June meeting materials will be
provided at the May meeting. Any materials that are not provided at that time will
be posted on a secure web site for downloading at least one week prior to the
meeting. The secure web site also will be used to make an archive of all monthly
meeting materials available to all Participating Agencies.
DRAFT - 01/17/2007
5.4. Meeting Summaries. After each monthly meeting, the NCTA will prepare a
meeting summary. The summary will list the attendees, topics discussed,
unresolved issues, and action items. The Meeting Summary will be provided to
the attendees in draft f'orm for their review and comment.
5.5. Attendees. Participating Agencies (including Cooperating Agencies) will
designate primary contacts for Turnpike Projects. 1'hese primary contacts will
regularly attend monthly meetings. Attendance may vary from month to month
depending on the issues being discussed. [IF POSSIBLE, INCLUDE LIST OF
PRIMARY CONTACTS HERE, OR IN AN ATTACHMENT TO THF.,
AGREEMF,N'I']
6. Identification and Resolution of Project Issues
6.1. Constraint Mapping and Environmental Data. As early as practicable in project
development, NCTA will provide FHWA and the Participating Agencies with
mapping that shows key environmental resources, communities, topographic
conditions, and other constraints in the project area. This mapping also will
identify potential conceptual alternatives for the project, to the extent possible.
(An "alternative" at this stage will generally be defined as a corridor.) The
mapping may be accompanied by other supporting materials.
6.2. Field Visits and Agencv Meetings. One or more field visits may be held with
Participating Agencies to discuss constraints and obtain early input into
development of alternatives. Attendees in field visits may be a sub-set of the
Participating Agencies, depending the issues to be discussed on the field visit. The
results of the field visit(s) will be discussed at a monthly meeting, which will
provide another opportunity for agency input.
6.3. Issues of Concern. After the field visit(s) and monthly meeting, Participating
Agencies will be given a 30-day period to identify any issues of concern, which
are defined in SAFETEA-LU as issues that could result in denial of a permit or
substantial delay in issuing a permit. Issues of concern must be identified in
writing. Agencies will be asked to submit any issues of concern in writing to
FHWA and NCTA on agency letterhead.
6.4. Monitorin a? nd Updating. NCTA will maintain a list of the issues of concern
identified by the Participating Agencies. Separate meetings may be scheduled to
resolve specific issues of concern. Additional issues may be added to the list
based on new information or changed circumstances at any point in project
development.
6.5. Informal Issue Resolution. Issues of concerns that are not resolved among the
regulatory participants in the monthly meetings can Ue elevated for consideration
by the more senior officials within the relevant agencies. (Note to reviewers: This
is a placeholder for developrnent of rnore specirc language regarding art issue
DRAFT - 01/17/2007 4
resolutior? process. One optiorr to consider is zrsing lhe ILT us a.foru»i for
resolving issues that cunnot be resolvecl in tlre monthly meetings.]
6.6. Formal Issue Resolution. tlnder the statute, NCTA or the Goverrior may request a
meeting at any time to resolve issues of concern. If such a meeting is requested,
FHWA will convene a meeting in accordance with SAFETEA-LU to resolve the
specified issues of concern. If an issue of concern is not resolved within 30 days
after such a meeting, a report must Ue submitted to Congress and to the heads of
certain agencies, as provided in SAFCTF,A-LU. If such a meeting is not
requested, FHWA and NCTA will seek to address and resolve the agencies' issues
of concern as part of normal agency coordination during the environmental review
process. [Note to reviewers: The r-eference to tlte Governor is speciftcally in the
slatute.]
7. Methodologies and Level of Detail for Alternatives Analysis
7.1. Proposed Methodologies. Early in project development, NCTA will prepare
materials outlining proposed methodologies for analyzing alternatives. The
materials will summarize the methodologies intended to be used for each
substantive area within the EIS - noise, air, water resources, traffic issues,
secondary and cumulative impacts, etc. Standard procedures will simply be
referenced, where applicable. Any modifications to standard procedures will be
identified and discussed in more depth.
7.2. Opportunitv for Agency Input. The proposed methodologies will be developed in
consultation with affected agencies. For example, the USACE and NCDENR will
be consulted in developing the methodology for analyzing impacts to aquatic
resources; the SHPO will be consulted in developing methodologies for analyzing
impacts to historic sites (including both architectural and archeological resources).
7.3. Ongoing Coordination. Methodologies for alternatives analysis will be refined
throughout the environmental review process. The Lead Agencies will discuss
adjustments, as appropriate, with Participating Agencies at monthly meetings.
7.4. Level of Detail. The Lead Agencies, in consultation with the Participating
Agencies, will determine the appropriate level of design detail for preliminary
alternatives, for the detailed study alternatives, and for the preferred alternative.
7.4.1. Preliminary Alternatives. In general, functional design will be prepared for all
preliminary alternatives, except for those preliminary alternatives that have a
"fatal flaw" that allows them to be dismissed as unreasonable without a functional
design.
7.4.2. Detailed Study Alternatives. In general, functional design will be used as the
basis for comparing the impacts of the alternatives in the DEIS (known as the
Detailed Study Alternatives) and will be used for developing the cost estimates
presented in the DEIS. A higher level of design detail may be developed for
DRAFT - 01/17/2007
Detailed Study Alternatives in same cases; this issue will Ue discussed with
ParticipatingAgencies in accordance with Sections 7.1, 7.2, and 7.3.
7.4.3.
7.4.4. Yreferred Alternative. The Preferred Alternative may be developed to a higher
level of detail in the FE[S, in accordance with procedures specified in FHWA/FTA
guidance for the Section 6002 process. If phased construction is anticipated, the
higher level of design detail may be developed for a portion of the Preferred
Alternative. As allowed under Section 6002, the higher level of design detail may
Ue prepared for thc purpose of developing mitigation measures and/or for
complying with permitting requirements (e.g., Section 404 permitting).
7.5. Lead A ency Decision. If there are disagreements about methodology, or about
the appropriate level of design detail, FHWA and NCTA will seek to resolve those
disagreements with the agencies having the relevant expertise - for example, the
SHPO on historic property issues. After consultation, the lead agencies will
determine the methodology to be used in the NEPA document. The basis for that
decision will be documented in the project file.
8. Development of Purpose and Need
8.1. Preliminary P&N with Supporting Information. Early in project development,
NCTA will prepare a brief preliminary statement of purpose and need - generally
no more than one page in length. The preliminary statement purpose and need
will be distributed to the agencies. This preliminary statement will be
accompanied by supporting information to the extent that it is available. This
information will include:
• GIS map of study area (with study area identified)
• Summary of local concerns that resulted in project addition to LRTP and MTIP
• Traffic data related to project needs
• Justification for designation as turnpike project (based on funding needs, etc.)
• Description of how the action will address the need.
8.2. Discussion at Monthlv Meeting. The preliminary purpose and need will be
discussed with the Participating Agencies at a monthly meeting. This will provide
an early opportunity for agency input into the Purpose and Need for the project.
In accordance with Section 6002, the comment period will be 30 days (unless
otherwise agreed).
8.3. Ongoing Refinement of Purpose and Need. The purpose and need will be refined,
as appropriate, based on input from the Participating Agencies. Refinement of the
DRAFT - 01/17/2007 6
purpose and need may be a gradual, iterative process that occurs during the project
development process, up to publication of the DEIS (and possibly afterward in
response to comments on the DEIS). This process will include an opportunity for
agencies and the public to comment on the purpose and need as part of their
review of the alternatives screening report. (See Part 9.4 and 9.5 below.)
9. Development and Screening of Alternatives
9.1. Conceptual Alternatives. An initial set of conceptual alternatives will be
developed as early as practicable in the process. The conceptual alternatives may
be developed concurrently with the preliminary purpose and need statement.
These alternatives will be provided to the agencies along with the environmental
constraint mapping that provides the basis for identifying issues of concern. (See
Part 6.1 above.) [Note to reviewers: This is a"will " because Section 6002
requires agerrcies to he giveri it}for»iation ubozit errvirorimental issues ancl "the
general locatiorrs of the alterriatives urzder cori.ti•ideratiori " as early as practicable
in the proeess.J
9.2. Alternatives Development. Through agency coordination and public involvement,
NCTA will develop a range of preliminary alternatives for consideration. This
range may extend beyond the initial set of conceptual alternatives. This effort is
intended to be comprehensive and inclusive. NCTA will maintain a summary of
all alternatives suggested by Participating Agencies and the public.
9.3. Alternatives Screenin?Report. The NCTA will prepare an alternatives screening
report that presents the justification for eliminating alternatives from further
consideration, and identifies alternatives proposed for detailed study. The
alternatives screening report will be provided to the Participating Agencies and
discussed in a monthly meeting.
9.4. Opportunity for Public Input. A summary of the alternatives screening report will
be made available for public review and comment. A public meeting (or
meetings) will be held in the project area during the public comment period on this
report. This comment period will serve as the public's opportunity for
involvement in both developing the purpose and need and determining the range
of alternatives to be considered in the EIS. A report summarizing public input will
be provided to Participating Agencies. Agencies will be given notice of the public
meeting and will be welcome to attend.
9.5. Opportunity for A,gency Input. Participating Agencies will be given a 30-day
period to provide additional comments on the alternatives screening report
following distribution of the report summarizing public comments. Participating
Agencies will not be asked to concur in the alternatives screening report.
Participating Agencies will be asked to submit any significant objections to the
alternatives screening report in writing to FHWA and NCTA on agency letterhead.
DRAFT - 0 1/17/2007
9.6. Lead Agencv Decision. The Lead Agencies will decide how to proceed based on
the comments received from Participating Agencies and the public. 1f there are
unresolved issues, the Lead Agencies will continue to address those issues through
ongoing coordination with the Participating Agencies as the process moves
forward.
10. Selection of Prefened Alternative/LI;DPA
10.1.Preferred Alternative Report. The NCTA will prepare a report identif'ying its preferred
alternative and the justification for selecting that alternative. "Che report will address all
applicaUle regulatory requirements, Section 404 and 401 of the Clean
Water Act, Section 4(f) of the USDOT Act
. The report will be prepared in coordination with FHWA.
10.2.Opportuni , for Agency Input. The NCTA will provide FI IWA, NCDOT, and all
Participating Agencies with a copy of the preferred alternative report. 'Che report will be
discussed at a monthly meeting. Agencies will be provided with a 30-day period to
comment on the report aiter the meeting. Agencies will not be asked to concur in this
report. Agencies will be asked to submit any significant objections in writing to FHWA
and NCTA on agency letterhead.
10.3.1-ead Agency Decision. FHWA will formally identify its preferred alternative after
considering all written comments received from Participating Agencies. Typically, the
FHWA's preferred alternative will be identified in the FEIS. It could be identified in the
DEIS, if the above actions are completed prior to publication of the DEIS.
11. Avoidance, Minimization, Mitigation, and Enhancement
11.1. Integration into Project Development. Opportunities to avoid, minimize, and mitigate
impacts, and to enhance the impacted resources, will be considered throughout the
process, including during initial development of alternatives. As allowed under
Section 6002, the preferred alternative may be developed to a higher level of detail for
purposes of developing mitigation measures and meeting permitting requirements.

11.2.2. Ecosvstem Enhancement Pro r? am (EEP). Where applicable, the NCTA
will coordinate with the Ecosystem Enhancement Program (EEP) during project
development and design '
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12. Section 404/401 Permittinfy
12.1. Early Coordination. NC"I'A will conduct early coordination with the
to identi fy
See Parts 6 and 7 above. '
12.2. Comment Opportunities. The will be invited to
provide written comments at several points in the process as noted above. The Lead
will consider all written comments submitted by the '- . [f :
raises issue of concern (defined as issues that could delay issuance of a permit or
result in denial of a permit), the will confer with k,;r
and with other agencies as appropriate, to
address those issues.
12.3. Jurisdictional Determinations. The NCTA will prepare the necessary documentation to
obtain jurisdictional determinations by the USACE (and, as appropriate, NCDENR) for
all wetlands and streams within a corridar along each of the detailed study alternatives
(unless otherwise determined as part of the discussion of inethodologies in accordance
with Section 7 of this plan). These determinations will be used as the basis for
comparing wetlands and stream impacts in the DEIS. The width of the corridor within
which jurisdictional determinations are made will be determined on a project-by-
project basis.
12.4. 12.5. . The NCTA will
submit the Section 404 permit application to the USACE at the time the DEIS is
issued.
? Th will enable the USACE to
issite a public notice and to use the FHWA/NCTA public hearing on the DEIS as the
USACE's public hearing on the Section 404 application. [Note: This could be
modified ori a case-hy-case ba.tis.]
DRAFT - 0 1/17/2007 9
12.6. Public Hearing. The public hearing on the DEIS will also serve as the public hearing
for the 404 permit application. `
12.7. Refining the Permit Application. After selection of a preferred alternative, the
NCTA will coordinate on a regular basis with the USACE, NCDENR, and other
agencies as appropriate regarding the Section 404 i permit application _
for the project. This coordination may occur as part of the monthly meetings and/or in
separate meetings convened to discuss permitting issues. These meetings will include
discussions of:
• avoidance and minimization measures
• compensatory mitigation
• review of hydraulic design
• review of stormwater management plans
• review of final permit drawings
12.8. ?- I ? a._: ?Permit Application and Decision. After the permitting meetings
described above, the NCTA will submit an updated Section 404 permit application to
the USACE and an Section 401 certification request to NCDENR. k?:,,
_'.`?.(
f?
129. Permit Decision,.
NCDENR and the USACE will consider and ?act upon ? ? ? ? .?_ ?° ? ,•,, E : ; ?? ?.
submittals in accordance with their procedures.
,
12.10. Permitting Delay. If a Section 404 permit (or any other permit or approval) is not
issued within 180 days after the FHWA issues a ROD and a complete permit
application is submitted, the USDOT will be required by Section 6002 to submit a
report to the Congress - specifically, to the Committee on Environment and Public
Works of the Senate and the Committee on Transportation and Infrastructure in the
House of Representatives. Reports must be submitted every 60 days thereafter until
the issue is resolved. The same requirement applies to other permitting decisions.
DRAFT - 01/17/2007 10