20161221_US 13/ NC 11_20140203

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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• �ATLANTA FEDERAL CENTER
61 FORSYTH STREET
ATLANTA, GEORGIA 30303-8960
Date: February 3, 2014
Mr. Richard W. Hancock, P.E.
Manager, Project Development and Environmental
Analysis Branch .
North Carolina Department of Transportation
1548 Mail Service Center '
Raleigh, North Carolina 27699-1548
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SUBJECT: EPA Review Commenfs of the Federal Environmental Assessment for the Proposed
Improvements to NC 11 and US 13 near the Town of Ahoskie, Hertford County, North Carolina;
TIP No.: R-5311 -
Dear Mr. Hancock: .
The U.S. Environmerital Protection Agency (EPA) has reviewed the subject document
and is providing comments in accordance with Section 309 of the Clean Air Act and Section
102(2)(C) of the National Environmental Policy Act (NEPA). The North Carolina Department of
Transportation (NCDOT) and the Federal Highway Administration propose to improve NC 11
and US 13 for an approximate distance of 7.8 miles near the towns of Ahoskie and Winton, in
Hertford County, N.C. � �
The NC 11 and US 13 Improvements project is in the NEPA/Section 404 Merger process
and EPA has been a participating member of this team. According to EPA's records,
Concurrence Point 1 Purpose and Need was signed on September 14, 2011. Concurrence Point
2, Detailed Study Alternatives �was signed by Merger team agencies on September 19, 2012.
Concurrence Point 2A Bridging and Alignment Decisions was concurred upon on June 18, 2013.
EPA has provided specific technic.al review comments in an attachment'to this letter (See
Attachment A). . �
In summary, EPA has not identified an environmentally preferred alternative and
recognizes the potential environmental justice relocation issues associated with detailed study
alternatives (DSAs) #3 and #5 and their fewer jurisdictional wetland impacts. EPA is
recommending that the NCDOT and FH�NA confirm relocation impact totals and also provide
additional documentation for the FONSI regarding environmental justice issues. EPA will �
participate on the NEPA/Section 404 Merger team and work with NCDOT, FHWA, and
Intemet Address (llRL) • http://www.epa.gov
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permitting and resources agencies on the selection of the Least Environmentally Damaging
Practicable Alternative (LEDPA). Piease feel free to contact Mr. Christopher Militscher of my
staff at miliischer.chrisna,epa.gov or 404-562-9512 should you have any questions concerning �
these comments. •
Sincerely,
. ��
- Heinz J. Mueller, Chief
NEPA Program Office
< � Office of Environmental Accountability
Attachment A
Cc: H. Wicker, USACE, w/attachments
A. Chapman, NCDENR w/attachments
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ATTACHMENT A
Technical Review Comments on Federal EA
Proposed NC 11 and US 13 Improvements near Ahoskie '
� Hertford County, North Carolina
� TIP No.: R-5311
Detailed Studv Alternatives
The NCDOT and other Merger team agencies carried forward 4 Detailed Study
Alternatives (DSAs) into the Environmental Assessment (EA). DSA #1 is a proposed Freeway
with part on new location. DSA# 3 is a Freeway/Expressway design on existing location. DSA
#5 is a`Superstreet' design on existing location: DSA #6 is a`Superstreet' design with part on
new location. A comparisori of �impacts of the DSAs #1, #3, #5 and #6 is identified in Table 6 of
the EA. EPA notes that for DSA #1, #3 and # 5 the total relocation alternatives do not add up
(i.e., DSA #1: 1 residential + 0 business = 2 total; DSA #3: 54 residential + 2 business = 50; „
DSA #5: 54 residential + 2 business = 52). These errors should be clarified prior to or at the
Concurrence Point 3, Least Environmentally Damaging Practicable Alternative (LEDPA)
meeting �
Natural Resources Impacts
� Jurisdictional wetland impacts are substantially different between the DSAs, with DSA
#1 having the greatest at 118.7 acres and DSA #5 having the lowest at 48.7 acres. DSA#6 has
83.5 acres and DSA# 3 has 77 acres: All of the DSAs have similar stream impacts between 1,101
linear feet and 1,171 linear feet. The DSAs with the least jurisdictional impacts to wetlands have
the greatest impact to residences and businesses. Most of the wetlands within the project study
area are classified under the N.C. Wetlands Assessment Methodology (NCWAM) as non-
riparian hardwood flats. The EA provided `NCDWQ ratings' for wetlands but did not utilize the
NCWAM system. The predominant streams in the project study area include Flat Swamp, �
Ahoskie Creek and Mill Branch and tributaries to these systems. All of the streams and
tributaries are classified as C waters; Nutrient Sensitive Waters (C;NSW). Floodplain impacts
are shown as O�acres in Table 6 for all four DSAs.
Terrestrial forest impacts are provided in Table 11 of the EA. However, this table also
includes maintained/disturbed areas which EPA does not generally consider to be terrestrial
forest. Terrestrial forest impacts range between 99.78 acres for DSA #5 and 164.16 acres for
DSA #1. There are no Federally-protected species in the project study area expected to be
impacted by the proposed project. .
Human Resources Impacts ,
Residential and business relocations are discussed above. In addition, DSAs #3 and #5
also are expected to impact (adverse effect) 1 historic property and 2 community facilities
(Pleasant Plains Church and cemetery). DSAs #3 and #5 are also anticipated to �cause a
disproportionately high and adverse to affected environmental justice communities (i.e., minority
and low-income) because there is i�sufficient available housing in the area to accommodate

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relocates. NCDOT's and FHWA's environmental justice analysis is included on pages 42 and 43
of the EA and includes demographics regarding county population percentages and income and
poverty levels'within the minority communities. EPA requests that additional information be
included in the Finding of No Significant Impact (FONSI) regarding the availability of "
affordable housing within the county as there were no demographics or perspective relocation
reports to support the statement concerning the lack of available housing. Regarding the issue of
community cohesion impacts, it is recommended that the FONSI include specific information as
to how community cohesion wi�l be altered by DSAs #3 and #5. �
DSAs #3 and #5 have the greatest noise receptor impacts at 26 and DSAs #1 and #6 are
estimated at 2 and 1 receptor, respectively.
Prime farmlands impacts range between 51.5 acres for DSA #6 and 68.9 acres for DSA
#3. The FONSI should identify if there are any prime farmland fields that are dissected by DSAs
#1 and #6 due to the new location aspects of those two alternatives. The FONSI should identify
if there will potentially be access road issues associated with the new location alternatives and if
any proposed access roads will cause additional impacts to jurisdictional resources.