20041246 Ver 1_Environmental Impact Statement_20020923

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September 23, 2002
Ms. L. Gail Grimes, P.E.
Assistant Manager, Project Development
and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
SUBJECT: US 321 Improvements, Caldwell and Watauga Counties, North Carolina
Draft Environmental Impact Statement; TIP Project No. R-2237C; FHW-E40320-
CEQ No. 020297
Dear Ms. Grimes:
In accordance with Section 102(2)(C) of the National Environmental Policy Act (NEPA)
and Section 309 of the Clean Air Act, the U.S. Environmental Protection Agency (EPA) is
providing comments on the subject Draft Environmental Impact Statement (DEIS). Highway
improvements are proposed for this segment of US 32I in the vicinity of the Town of Blowing
Rock covering a distance of approximately 4.3 miles. Originally, this project involved a 15-mile
segment of US 321 improvements. Public concern with the scope of the alternatives for the
northern 4.3-mile section at the Town of Blowing Rock caused this section to be withheld from
proceeding to design and construction, and an EIS was determined to be necessary in 1994.
Purpose and Need for the Project
This section of US 321 has failing or neaz failing levels of service throughout the project'
s length resulting from mountainous terrain with steep grades and several severe curves without
safe passing zones. In addition, this section had a total of 118 accidents within a recent
three-year period which is 28% higher than compazable roadways statewide. The primary. stated
purposes of the project is to improve the traffic flow and level of service and reduce the accident
rate for this roadway. EPA agrees with the purpose and need for these improvements to this
section of US 321 as described in the DEIS.
Alternatives
The DEIS documents the extensive efforts that have gone into the development of
preliminary alternatives, and the numerous meetings have been held with local and agency
officials. A total of 17 alternatives have been considered. There was consideration early on of
a complete rerouting of US 321 from the Lenoir area to Hampton, TN via NC 18 and US 19.

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This alternative and the no-build alternative were found to not address either of the identified
needs for this project. Other build alternatives were eliminated from further consideration
because of environmental or construction costs, or because of their substantial similarity to those
alternatives retained. Within the project area, the Traffic Systems Management (TSM) option
was also considered along with two- and three-lane configurations, aswas mass transit; however,
all were discarded because of their failure to address the identified needs. Geo-technical studies
and traffic studies were conducted to help define the environmental issues and appropriate
alternatives.
Both of the bypass alternatives have two variations. Alternative 1B would straighten two
sharp curves in the southern portion of the alignment, requiring substantial amount of additional
cut and fill work. Conversely, Alternative 4B includes a greater amount of bridging than 4A to
generally reduce the changes in terrain and impact to natural resources.
According to the DEIS all of the build-alternatives would meet the transportation purpose
and need of the project. However, only the Widening Alternative and bypass Altematives lA
and B would address safety concerns with the existing roadway by eliminating sharp curves and
narrow pavement. Altematives 4A and B would improve safety on the existing roadway
indirectly by reducing the traffic volume on existing US 321. However, it appears that some
improvements to existing US 321 to address safety and level of service needs would likely be
required in the future regardless of the construction of a bypass.
Some of the most important information in determining the degree that the various
alternatives would meet the project's purpose and need was obtained from the Origin and
Destination Study, which is discussed beginning on page 2-5. This study found that 75% of the
trips were from home to work and back, and 64% of the trips along US 321 in Blowing Rock
originated in Caldwell and Watauga counties. These findings demonstrate that the Widening
Alternative would provide the greatest transportation utility for these kinds of trips while
Alternatives 4A &B would provide the least.
Noise and Scenic
The alternatives with the greatest noise impacts are Alternatives lA and 1B with 69 and
61 residences impacted substantially (as defined by the DEIS of exceeding the noise abatement
criteria (NAC), having a substantial increase over existing levels or both). In comparison, the
Widening Alternative and Altematives 4A and 4B would have very similar impacts, at 28, 25
and 24 residences with substantial impacts, respectively. We note that noise abatement measures
were not found to be cost effective for any of the residential areas expected to be impacted
substantially.
Since noise mitigation was not found to be cost effective, EPA encourages NCDOT to
consider landscaping enhancement and scenic screening measures such as earthen berms,
retaining walls and vegetative plantings as space allows. In particular, we strongly urge the
consideration of these measures for those residential areas expected to experience severe
increases in noise levels as a result of a selection of any of the four bypass alternatives on new

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alignment. Generally, for the Widening Altemative in the more urban area, we believe that such
measures can be best meshed with other historic and scenic enhancements.
Historic Resources
Impact to historic resources is a key issue on this project. Under Section 106 of the
National Historic Preservation Act, the Widening Alternative would have an Adverse Effect,
requiring the taking of historic property, on the Green Park Historic District, and would result in
some noise and scenic view impacts to the Bollinger-Hartley House, which are not considered an
Adverse Effect under Section 106.
Since the purpose of the Blue Ridge Parkway is to protect the scenic, natural and cultural
resources within the parkway corridor and conserve the vistas from the parkway, vistas are an
important part of the parkway experience. The views from the Thunderhill overlook, within the
project area, received exceptional quality ratings by the National Park Service. Also, according
to the DEIS, the parkway is being considered for National Landmazk designation but the effect
of such designation on the parkway is not defined. All the Bypass Alternatives would impact the
Blue Ridge Parkway viewshed; however, Alternatives 4A and 4B would have an Adverse Effect
under Section 106. The bridging proposed for 4B would lessen these effects. EPA defers to the
State Historic Preservation Officer, the National Park Service, FHWR and NCDOT to address
these historic issues.
Natural Resources
Alternatives 4A&B would have the greatest adverse impact on resources associated with
the necessary crossing of 20 streams compared to 6 crossings for the Widening Alternative and 5
associated with Alternatives lA&B. Alternative 4B provides important bridging to minimize
this impact. While none of the directly impacted streams are assigned a critical water supply or
other high quality water designation, many could support trout populations. The resulting
removal of more tree canopy, associated mostly with the bypass alternatives and additional
development that may be induced, promotes water temperature increases that are detrimental to
trout habitat. The impact of stream crossings should be mitigated by the retention of vegetative
buffers wherever practicable.
Likewise, the impact to terrestrial wildlife from the Alternative 4A and 4B alignments is
greatest because of the remote, forested habitat that is bisected. Alternatives 1A&B would have
an intermediate level of impact to natural resources because they would cross land experiencing
development on the east side of the Town of Blowing Rock.
In this project area, it is noted that wetland vegetated communities are limited in extent
and do not vary substantially between alternatives. EPA believes that because of the scarcity of
these wetlands (see the attached comments for the discussion of methodology) they should merit
very high functional ratings for diversity of wildlife habitat and be avoided to the maximum
extent practicable.

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Cumulative Impacts
After reviewing the excellent analyses of potential indirect/cumulative impacts, we
believe that this project will not lead to substantial growth in the area and therefore will not
result in substantial alteration either through cumulative or indirect effects to the overall
environment of Blowing Rock. While bypass Alternatives 4A and B potentially improve
access for more development, the restricted access to the highway and the terrain would tend to
mute the roadway's impact. At the northern end of these alternatives, where the terrain is less
steeply sloped, some stimulation of development could result from a new roadway. The
long-term impacts of development on mountain views and natural resources will be determined
largely by how the municipalities and Watauga County guide and regulate growth.
Summary of Comments
All of the alternatives result in some direct environmental concerns; and there is not one
alternative that is clearly environmentally superior to all of the others. That said, one alternative
is clearly more damaging than. the other alternatives. Therefore, we rate Alternative 4A more
severely than the other alternatives assigning it an "EO" rating (environmental objections). This
rating is assigned primarily because this configuration would present the greatest visual impact
relative to the Blue Ridge Parkway, and it would result the greatest impact on the natural habitat.
The placement of this alternative and its cut-and-fill configuration would bisect a generally
undisturbed forested Blue Ridge escarpment and greatly hinder wildlife movement. Crossing 14
of the 20 streams with fill and culverts make this alternative substantially more damaging than
Alternative 4B, which maximizes the use of bridging instead of cuts and fills.
Otherwise, there remain major tradeoffs between the alternatives that would result in
impacts to the natural environment or impacts to the various cultural and economic resources.
Accordingly, EPA is rating the Widening Alternative and the other bypass Alternatives 1 A, 1 B
and 4B as "EC" (environmental concerns). The Widening Alternative provides substantial
transportation benefits while generally minimizing environmental impacts, and therefore should
get continued consideration if the Town of Blowing Rock's and historic/cultural concerns can be
adequately addressed.
EPA is assigning the DEIS a sufficiency rating of "1" since we believe that the document
reflects a comprehensive and objective analysis of all pertinent environmental parameters.
However, as discussed above, we see the need for further coordination with the Town and other
stakeholders on the Widening Alternative to see if additional changes can be made in order to
address their concerns. Enclosed for consideration are additional comments pertaining to the
technical information and analyses.
Thank you for the opportunity to review the DEIS. If you have any questions regarding
these comments, please contact me or Ted Bisterfeld of my staff at 404/562-9621.
Sincerely,

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Heinz J. Mueller, Chief
Office of Environmental Assessment
Enclosure: EIS Ratings System Criteria
Additional Comments
cc: Nick Graf, FHWA, Raleigh
Garland Pardue, USFWS Raleigh Field Office
Steve Lund, USACOE, Asheville Field Office
Additional Comments on the US 321 Blowing Rock DEIS
Socio-Economic
In 1999, EPA participated in the interagency Merger Team's deliberations about the
alternatives to be considered in detail in the EIS. The alternatives remaining under consideration

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at that time were: to widen existing US 321 on its present alignment; a bypass on new location
through the eastern portion of the Town of Blowing Rock (Alternative 1); and a complete
bypass to the east of the town on new location through forested land and tunneling under the
Blue Ridge Parkway (Alternative 4). The Widening Alternative already was receiving
considerable analysis by NCDOT. TSM provisions were applied as were enhancements for
making the project compatible with the surrounding development. EPA and the other
environmental resource agencies were presented with the results of the work by NCDOT.
However, although no concurrence was reached because of major environmental issues against
retaining Alternative 4 for further analysis, NCDOT decided to carry it forward along with the
Widening Alternative and Alternativel for more detailed analysis in the DEIS.
Data cited for population and economic trends rely on the 1990 Census and other data
from the 1990s. While there are estimates for year 2000 population, etc., this information should
have included the year 2000 Census data.
Community cohesion, according to the document, is a negative factor for the bypass
alternatives only. EPA considers the addition of two additional lanes to be a negative factor for
the Widening Alternative but not to the degree of impediment that a new, controlled access
roadway presents to existing communities. Two neighborhoods are identified as being impacted
by each of the bypass alternatives. Without more specific information, it seems likely that the
community cohesion impact along the Alternative 1 corridor would be more severe than along
Altemative 4.
Economic Impacts
This analysis evaluated the potential impact on businesses of the various alternatives. It
was very informative regarding one of the key project issues. This type of analysis should be
standard for all improvement projects considering a bypass of commercial business districts.
We agree with the findings that construction of the Widening Alternative would be
highly disruptive to US 321 businesses. The findings about business impact following
construction, however, are the most interesting and of greater importance. The key factor is the
differentiation of businesses by the proportion of opportunity and destination types of sales.
Blowing Rock, being a resort, has adestination-dominant economy. Bypass alternatives were
found to result in an overall loss of sales revenue just under 12 percent to existing US 321
businesses, while the incorporation of a landscaped median along a 4-lane US 321 would result
in lost sales of just under 3 percent. Please clarify what time frames are meant by
post-construction neaz term and longer term impacts in the analysis.
We note that the town desires to retain a "village appeal" which we assume would include
the commercial area of US 321. One factor to consider is how excessive traffic speed could
hinder this goal along this long, straight section of US 321. NCDOT has done an excellent job
addressing the appearance of a widened right-of--way, but has not fully addressed the importance
of speed control through the commercial district and the associated pedestrian safety issues.
There is an emphasis in the document to highlight the natural and historic attributes of this

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mountain community. The document strongly infers a direct relationship between the quality of
these attributes to the economic success and general appeal of the Blowing Rock community.
We agree with this relationship.
We note the substantive analysis of the potential economic impact to busuiesses along
present US 321. Given that Blowing Rock has atourist-based economy, it was interesting that
the analysis concluded that the Widening Alternative (with landscaped median) would have
minimal adverse impact on sales revenue, and that all of the bypass alternatives would result in
greater loss of sales revenue. Part of the overall economic issue which NCDOT, FHWA must
deal with is the great disparity in the total costs of the alternatives.
Natural Resource Impacts
Discussed on page 3-66 is the NC Division of Water Quality's (DWQ) methodology
which was utilized to assess the functional importance of the wetland resources. EPA has stated
in comments on other projects its disagreement with this methodology because of the unequal
and low weighting of factors for wildlife functional values. In this project area, it is noted that
wetland vegetated communities are limited in extent and do not vary substantially among
alternatives. We wish to note that the DWQ assessment methodology does not include any
factor for wetland scarcity, which is another shortcoming of the methodology. EPA believes that
because of the scarcity of wetlands in this project area, the impacted wetlands should merit very
high functional ratings for diversity of wildlife habitat.
Relocations
Regarding residential relocations, the Widening Alternative affects 16 residences,
Alternative lA affects 24, Alternative 1B affects 27 (not 24 as indicated in Table 4-1),
Alternative 4A affects 8 and Alternative 4B affects 6 residences. According to the DEIS,
replacement housing in the $40,000-100,000 price range may not be readily available in the area.
The issue of adequate replacement housing should be more fully addressed in the FEIS.