20071134 Ver 1_More Info Letter_20070809

«.~~,,~.
~ .~-~.
'~ _-
.~~~.
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
August 9, 2007
MEMORANDUM TO: Dave Baker, US Army Corps of Engineers
Brian Wrenn, NCDENR-DWQ/Wetlands
FROM: Steve L. Brown, P.E., Project Planning Engineer
Project Development and Environmental Analysis Branch
LYNDO TIPPETT
SECRETARY
SUBJECT: R-2518A/B and R-2519A/B - US 19E Improvement Project
As a follow up to our meeting on 7/24/07 regarding:
1. The history and rationale behind the terminus of project R-2519A and beginning of project R-
2519B.
2. The rationale for combining projects R-2518A, R-2518B and R-2519A under a single Section
404 permit and 401 Water Quality certification.
3. The rationale for combining all four projects (R-2518A, R-2518B, R-2519A, and R-2519B)
under a single Biological Assessment.
4. Assurance that issuing a permit for projects R-2518-19A will not preclude any avoidance and
minimization efforts on the following project R-2519B.
After review of the project files, discussions with available former project managers of the four
projects, and review of the current design plans, the following is offered in response:
The projects R-2518 and R-2519 were originally split into roughly equal A and B sections to
facilitate phased funding and phased construction scheduling of the corridor. Section breaks
were selected based on logical terminii and an intention to make each section and
independent facility to the extent practicable. The dividing line between R-2519A and R-
2519B appears to have been chosen in an effort to end project R-2519A short of the US19
and NC 80 intersection, which is a major intersection at which significant reconfiguration is
proposed. The majority of traffic at this intersection travels east to Spruce Pine, therefore, it
is logical to maintain this intersection within the R-2519B project.
2. In an agency coordination meeting in June 1998, it was suggested by the U. S. Fish and
Wildlife Service (USFWS) that NCDOT combine projects R-2518 and R-2519A into a single
environmental document that properly assesses accumulative and cumulative impacts of the
projects. The USFWS cited the geographical proximity as well as the similar schedules for
both projects as reasons to combine them. A concern was also expressed that dividing the
projects into smaller sections would not fully assess the overall corridor improvement's total
impact on the environment. Based largely on this input, NCDOT made the decision to
MAILING ADDRESS: TELEPHONE: [phone] LOCATION:
NC DEPARTMENT OF TRANSPORTATION FAX: [phone] TRANSPORTATION BUILDING
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET
1548 MAIL SERVICE CENTER WEBSITE.' WWW.DOH.DOT.STATE.NC.US RALEIGH NC
RALEIGH NC 27699-1548

combine R-2518A/B and R-2519A into a single environmental document and 404/401
permit/certification.
The project study area for the BA is based on watershed boundaries; rather than road breaks,
traffic concerns, and constructability, which are used to determine TIP /permitting breaks.
The western boundary of the BA study area (Nolichucky Watershed) is only '/z mile into the
eastern edge of R-2518A. Therefore, the BA study area covers R-2518B, R-2519A/B and
only '/2 mile of R-2518A. The reviewing body for the Biological Assessment, USFWS,
suggested early in the Section 7 Consultation process that, due to shared resources (water and
endangered species) between all four projects, a single BA be produced to fully evaluate the
direct, indirect, and cumulative impacts of the projects to the Appalachian elktoe.
4. Projects R-2518 and R-2519 propose widening of an existing roadway in a corridor with
many environmental and physical constraints. There is little opportunity for horizontal or
vertical alignment changes along the corridor or between sections of the projects. Project R-
2519B is currently in the Merger O1 process at the CP 4A (Avoidance and Minimization)
stage. Stream and wetland avoidance and minimization efforts for R-2519B have been
presented to the Merger Ol team based on the current preliminary roadway design of R-
2519B, which is a continuation of the R-2519A preliminary design. Therefore, NCDOT does
not foresee a future loss of significant avoidance or minimization efforts on project R-2519B
due to permitting the alignment of R-2519A as presented.
Please contact me at [phone], x-235, or via e-mail at slbrown~cixlot.state.nc.us with any
questions or comments regarding this information.
Cc: Greg Thorpe, PDEA
Teresa Hart, PDEA
Phil Harris, NEU
Elizabeth Lusk, NEU
Carla Dagnino, NEU