20170239 Ver 1_U-3109 A&B LEDPA confirmation SAW-2002-20667_20170213

Wanucha, Dave
From: Bailey, David E CIV USARMY CESAW (US) <[e-mail]>
Sent: Monday, February 13, 2017 8:44 AM
To: [e-mail]; Wanucha, Dave; Davila, Felix; Wilson, Travis W.; Jordan, Gary; Gledhill-earley,
Renee
Cc: Matthews, Monte K CIV USARMY CESAW (US); Dagnino, Carla S; Mason, James S; Mellor, Colin
Subject: U-3109 A&B LEDPA confirmation; SAW-2002-20667
Attachments: U-3109 Memo to USACE .dotx.pdf
Merger Team members,
Please see the attached memo prepared by NCDOT regarding the Mebane Bypass project (U-3109 A&B) in Alamance County, NC.
In January 2017 NCDOT identified that the final design stream impacts for the A Section were significantly (�2x) higher than what
was proposed in the 2007 Final Environmental Impact Statement (FEIS). As a result, and given current proposed project
scheduling, the NCDOT met with the U.S. Army Corps of Engineers (USACE) and N.C. Division of Water Resources (NCDWR) to
discuss how to proceed with the permitting process. At the 1/17/2017 meeting, the USACE and NCDWR suggested that NCDOT
provide additional information regarding the increase in impacts, as well as a re-assessment of the alternatives that were
discussed in the FEIS/CP 3. The purpose of the additional information was to determine if the LEDPA decision (Alternative 9)
agreed to in the CP 3 meeting is still justifiable, or whether a CP 3 re-visit is necessary.
The attached information, provided to the USACE on 2/9/2017, details the site-by-site proposed stream and wetland impacts for
both the A and B project Sections, particularly those reported in the FEIS vs. the Final Design impacts following the CP 4C
meeting on 5/14/2015. NCDOT has also included itemized explanations for impact discrepancies between the FEIS and Final
Design, including changes in the Jurisdictional Determination following the 2012 reverification, estimating impacts using slope
stakes only vs. slope stakes + 25', and including channel re-alignment and bank stabilization impacts in Final Design only. In
summary, NCDOT found that NCDOT's preferred alternative (Alternative 9) still has the lowest amount of stream impacts (562
I.f. and 365 I.f. less than Alt. 8 and 10, respectively) and wetland impacts (0.07 ac. less than Alt. 8, same as Alt. 10) as compared
to the other FEIS/CP 3 alternatives.
After review of the attached memo and review of the CP 3, 4A, 4B, and 4C decisions, the USACE agrees with NCDOT that
Alternative 9 is still the LEDPA, that a CP 3 revisit meeting is unnecessary, and that the project can go forward with permit
evaluation through the Individual Permit process. Note that the Merger Team's choice of Alternative 9 was based in large part to
reductions in impacts to the Graham-Mebane Reservoir water supply watershed critical area and Cates Farm (Section 4(f)
resource and on National Register of Historic Places), compared to Alternatives 8 or 10; these constraints have not changed.
Also, project commitments made during the FEIS process and the CP 4A meeting remain in-tact as discussed in the attachment.
In lieu of a meeting, I request that the Merger Team members review the attached memo and respond with any comments
regarding the USACE's findings within 2 weeks of this email. If you have any questions or concerns please let me know.
Sincerely,
Dave Bailey
David E. Bailey, PWS
Regulatory Project Manager
US Army Corps of Engineers
CE-SAW-RG-R
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
Phone: [phone], Ext. 30.
Fax: [phone]
Email: [e-mail]

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ROY COOPER
GOVERNOR
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
February 9, 2017
U.S. Army Corps of Engineers
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, NC 27587
ATTN: Mr. David Bailey
NCDOT Division 7 Project Coordinator
JAMES H. TROGDON, III
SECRETARY
SUBJECT: Review of Permit Impacts and Re-assessment of Project Alternatives
for the proposed relocation of NC 119 from Interstate 40/85 to north of SR
1918 (Mrs. White Lane) in Mebane (Mebane Bypass), Alamance County,
North Carolina, Division 7. Federal Aid Project No. STP-119 (1), TII' No.
U-3109.
Dear Sir:
During the permit application preparation for the subject project, it was identified that the
final design impacts for the A Section were significantly higher that what was proposed
in the Final Environmental Impact Statement (FEIS). Due to this increase, the North
Carolina Department of Transportation (NCDOT) met with the U.S. Army Corps of
Engineers (USACE) and N.C. Division of Water Resources (NCDWR) to discuss how to
proceed with the permitting process. At the meeting, held on January 17, 2017, it was
determined that NCDOT will need to provide additional information regarding the
increase in impacts, as well as a re-assessment of the alternatives that were discussed in
the FEIS. The information in this letter is provided for review and to subsequently submit
to the Merger Team. After re-evaluating all three alternatives that were presented in the
FEIS, NCDOT has concluded that Alternative 9, based on both impacts and minimization
considerations for the critical area and the Cates Farm, is still the Least Environmentally
Damaging Practicable Alternative (LEDPA) for this project. Below is a detailed review
of the A Section of the project, which will be permitted first, as well as a review of the
three alternatives from the NEPA document (Alternatives 8, 9[LEDPA], and 10).
Mailing Address: Telephone: [phone] Location:
NC DEPARTMENT OF TRANSPORTATION FCiX: (J19� 212-5%HS IOZO BIRCH RIDGE DRIVE
NATURAL ENVIRONMENT SECTION Customer Service: I-877-368-4968 RALEIGH NC 2%61�
1 S9H MAIL SERVICE CENTER
Rnc,E[GxNC27699-1598 Website: www.ncdot.gov

Avoidance and Minimization
Below is an overview of the avoidance and minimization that NCDOT has agreed to for
this project, listed based on the document or meeting that it is attributed to. Any
additional information for an item is listed below the item in italics.
Avoidance and Minimization included in FEIS/CP 4A (both Sections A and B�
FEIS
• During the development of the preliminary engineering designs for each Detailed
Study Alternative, including the Preferred Alternative (Alternative 9), efforts
were made to avoid and minimize impacts to wetlands and streams wherever
practicable. Where stream crossings were unavoidable, they were located, within
design constraints, as perpendicular as practicable, in order to minimize the length
of stream impacted.
• The alignment for all three Detailed Study Alternatives, including the Preferred
Alternative (Alternative 9), proposed under the preliminary engineering designs
crosses Wetland 1(WL1) where the direct impacts would be the least; staying as
much on the eastern edge of the wetland as possible while not encroaching upon a
parallel section of MoAdams Creek to the west.
o Wetland WL1 is not impacted by the project and appears to have been
eliminated in the 2012 re-delineation.
• The alignment skirts between Wetland 3(WL3), which is near the eastern
boundary of the alignment, and Wetland 4(WL4), which is on the western
boundary of the alignment, while avoiding impacts to Craftique Furniture
Company.
o Wetland WL3 is not impacted by the project, but Wetland WL4 (now WF)
is impacted at Permit Site 13.
• Wetlands 11 (WL11) and 13 (WL13) are associated with the extension of
Corrigidor Road. The alignment impacts the western edge of WL11 and WL13 to
avoid impacting the City of Mebane WWTP operations.
o Wetland WL11 (now WA) is impacted at Permit Site 19 and Wetland
WL13 (now WC) is impacted at Permit Site 20.
• Jurisdictional impacts would be further minimized by a reduction in side slopes to
2:1 in the areas of wetland impacts. Sensitive placement of drainage structures,
during final design of Preferred Alternative 9, would minimize degradation of
water quality and reduce adverse impacts on aquatic habitat viability in streams
and tributaries. Based on preliminary designs, there are no substantial fill slopes
associated with this project. A determination would be made during final design if
retaining walls should be included in the design. Once surveys of the project area
are available, the preliminary design can be revised to further minimize impacts to
the human and natural environments.
U-3109 Review of Section A Impacts and Project Alternatives
Page 2 of 17

• The Mebane Rogers Road tie-in near proposed NC 119 was designed to end
before the creek crossing (Site 5; Figure S.4 of the FEIS) for Alternative 8 and
Preferred Alternative 9.
o This feature, Stream UT14 (renamed SU in Section A and SA in Section
B), was going to be impacted at this location in the Alternative 9 A Section
final design due to the installation of a single-barrel box culvert.
However, a design revision was made and the culvert will no longer be
installed. The stream will still incur minor bank stabilization impacts (35
linear feet) at this location due to the stormwater management design,
which was not considered in the FEIS impacts.
• The tie-in from proposed NC 119 to existing NC 119 south of the Mill Creek
community was designed to end before the Mill Creek crossing for the Detailed
Study Alternatives, including Preferred Alternative 9, in this area.
• In the vicinity of the Fieldstone community, the mainline alignment was shifted
slightly outside the corridor limits to reduce impacts to MoAdams Creek,
necessitating a slight expansion of the corridor limits in this area.
• A bridge over Mill Creek is an additional minimization component. Bridging
floodplain wetlands along the larger stream systems, such as Mill Creek, would
decrease the degree of potential habitat fragmentation and reduce potential
wildlife mortality due to traffic operations by providing riparian corridors for
wildlife use.
o Preliminary design for the B Section shows that bridges will be employed
over Mill Creek.
CP 4A (items that were not listed in the FEIS�
• The realignment of Third Street in the vicinity of the U.S. Post Office was
designed to reduce impacts to the Fieldstone apartments, as well as other
residences in that area.
• An access road was incorporated into the design near the beginning of the project
to reduce impacts to the Fox Run apartments.
• The Cates Farm on-site stream restoration project will be discussed and evaluated
at CP 4B.
o Cates Farm is associated with the B Section of the project; a more
detailed restoration discussion will occur when Section B is at or near CP
4B.
Avoidance and Minimization, A Section Stormwater Management Plan
After CP 4A, the project was split into its 2 Sections. The information that follows in this
section is for the A Section of the project only. Detailed information regarding the post-
4A avoidance and minimization for Section A will be provided at a later date.
• A combination of grassed swales, roadway ditches, and structural BMPs were
employed to minimize water quality impacts. In most locations, the outlets for the
storm drainage systems were placed at least 50 feet from the Jurisdictional
Stream. However, due to topography, none of the lateral grass swales located
along the embankment fill slope met the recommended minimum length of swale.
U-3109 Review of Section A Impacts and Project Alternatives
Page 3 of 17

• Class B rip rap aprons/pads will be installed at pipe outlets at Stations 80+50 -L-
LT and 97+98 -L- LT.
• A Class I rip rap energy dissipator basin will be installed at a pipe outlet at Station
100+70 -L- LT.
• Pre-formed Scour Holes (PSH) comprised of Class B rip rap will be installed at
Stations 130+50 -L- LT and 140+50 -L- LT.
• Hazardous Spill Basins will be installed at the following locations:
0 161+92 -L- RT
0 179+68 -L- RT
0 20+90 -Y 16RPA- LT
0 32+55 -Y20- LT
Comparison of Section A Final Design and FEIS Impacts for the LEDPA (Alternative 9�
Streams
The FEIS estimated a total of 3,178 linear feet of permanent stream impacts associated
with the LEDPA (Alternative 9), with 2,373 linear feet occurring in what is now the A
Section of the project and 805 linear feet occurring within the B Section. Slope stakes
were used in the document-level impact estimates. Final design impacts for the A Section
total 4,926 linear feet of permanent stream impacts (permanent fill plus bank
stabilization), which is an increase of 2,553 linear feet of permanent stream impact
compared to the FEIS estimate for that section. Table 1 compares the permanent stream
impacts from the FEIS for Section A of the LEDPA to the final design impacts for that
section. Impacts are listed in order of Permit Sites; any features that were included in the
FEIS that did not end up being impacted in final design are at the end of the table.
U-3109 Review of Section A Impacts and Project Alternatives
Page 4 of 17

Table 1. U-3109A, Comparison of LEDPA Permanent Stream Impacts from FEIS and Final Design
Total Perm. Final Design Additional Final
FEIS Stream Final
Final Design Perm. Stream Design Perm.
Permit Stream ID Impacts (Slope Design Changes to Delineation Between
Stream Impacts Stream Impacts
Site (FEIS ID) Stakes Only) Impacts Within Slope Beyond Slope Fill 1 FEIS and Final Design
(lin. ft.) (lin. ft.) Stakes (lin. ft.)1 Stakes (lin. ft.)1 Slope
Stream lengthened at post-FEIS
1 SB (UT2) --- 352 ___ JD re-verification (2012) by over
3001inear ft. (which is where
entire impact is occurring)
Pipe extends beyond
slope stakes by 8
2 SC (UT3) 187 348 275 lin. ft.; Channel 2:1 UT extended at post-FEIS JD re-
realignment of 65 verification (2012)
lin. ft.
Pipe extends beyond
slope stakes by 20
3 SD (UT1) 149 320 178 lin. ft.; Channel 2:1 ---
realignment of 122
lin. ft.
5 SF (UT4) 132 02 ___ Stream shortened at post-FEIS JD
re-verification (2012)
6 SG --- 25� ___ Was not delineated at FEIS
(added in 2012)
MoAdams Channel realignment Site 18 may not have been
�' 1 g Creek 376 755 (564/191) 323 (228/95) 4321in. ft.(336/96) 2' l included in FEIS
U-3109 Review of Section A Impacts and Project Alternatives
Page 5 of 17

Table 1. U-3109A, Comparison of LEDPA Permanent Stream Impacts from FEIS and Final Design (Continued)
Total Perm. Final Design Additional Final
FEIS Stream Final
Final Design Perm. Stream Design Perm.
Permit Stream ID Impacts (Slope Design Changes to Delineation Between
Stream Impacts Within Stream Impacts
Site (FEIS ID) Stakes Only) Impacts Slope Stakes Beyond Slope Fill 1 FEIS and Final Design
(lin. ft.) (lin. ft.) (lin. ft.)1 Stakes (lin. ft.)1 Slope
7A SH (UTS) --- 18 --- --- --- ---
Pipe extends beyond
slope stakes by 13
8A SJ (UT6) 325 463 420 lin. ft.; Channel 4:1 ---
realignment of 30
lin. ft.
8B SK --- 82 ___ Was not delineated at FEIS
(added in 2012)
10 SM (UT7) 266 396 295 Channel realignment 2.1 ---
of 101 lin. ft.
Only 53 lin. ft.
outside of slope
l0A SN (UT7A) 22 74 21 stakes remained, so it 2:1 ---
was considered a
total take
Pipe extends beyond
slope stakes by 12
11 SO (UT8) 195 270 205 lin. ft.; Channel 2:1 ---
realignment of 53
lin. ft.
U-3109 Review of Section A Impacts and Project Alternatives
Page 6 of 17

Table 1. U-3109A, Comparison of LEDPA Permanent Stream Impacts from FEIS and Final Design (Continued)
Total Perm. Final Design Additional Final
FEIS Stream Final
Final Design Perm. Stream Design Perm.
Permit Stream ID Impacts (Slope Design Changes to Delineation Between
Stream Impacts Within Stream Impacts
Site (FEIS ID) Stakes Only) Impacts Slope Stakes Beyond Slope Fill 1 FEIS and Final Design
(lin. ft.) (lin. ft.) (lin. ft.)1 Stakes (lin. ft.)1 Slope
12B S 1 --- 105 ___ Was not delineated at FEIS
(added in 2016)
12C S2 0� Was not delineated at FEIS
--- --- ---
(added in 2016)
Pipe extends beyond Site 16 was not included in
slope stakes by 4 lin. calculation of impacts in FEIS,
13,16 SR (UT10) 163 677 (183/494) 583 (153/430) ft. (4/0); Channel 2:1 although Y-line present. Stream
realignment of 901in. was extended in post-FEIS JD re-
ft. (26/64) verification (2012) to exist at Site
161ocation
14 SS 02 Was not delineated at FEIS
--- ---
(added in 2012)
15 ST (UT11) 323 447 353 Channel realignment 2:1 ---
of 941in. ft.
17 SU (UT14) ---3 35 0 Bank Stabilization of 2:1 Alternative 9 originally did not
35 lin. ft. include impacts to this site
U-3109 Review of Section A Impacts and Project Alternatives
Page 7 of 17

Table 1. U-3109A, Comparison of LEDPA Permanent Stream Impacts from FEIS and Final Design (Continued)
FEIS Stream Total Perm. Final Design Additional Final Final
Permit Stream ID Impacts (Slope Final Design Perm. Stream Design Perm. Design Changes to Delineation
Site (FEIS ID) Stakes Only) Stream Impacts Stream Impacts Fill Between FEIS and Final Design
Impacts Within Slope Beyond Slope Stakes 1
(lin. ft.) (lin. ft.) Stakes (lin. ft.)1 (lin. ft.)1 Slope
20 SL (UT25) 155 327 212 Channel realignment 3:1 ---
of 1151in. ft.
SE (UT24)4 80 ___ Revised to ephemeral at post-
--- --- ---
FEIS JD visit (2012)
TOTALS 2,373 4,9265 2,865 1,247
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post-FEIS.
2 Pernut Site present in final design, but only temporary impacts present at site.
3 1961inear feet are listed for this feature in Alternative 9; however, after review, it was determined that this impact occurs in the B Section and no impact was anticipated in the A Section.
4 Stream UT 24 was re-named to Stream SE in the 2012 JD re-verification; however, it was determined to be ephemeral during the JD site visit and was dropped as a jurisdictional feature in
the final design.
5 8141inear feet of the final design impact total is due to permanent impacts to streams that were not considered in the FEIS impacts.
U-3109 Review of Section A Impacts and Project Alternatives
Page 8 of 17

The comparison of slope stakes impacts for streams that were listed in the FEIS and the same
streams at final design showed that permanent impacts within Section A of the LEDPA increased
492 linear feet from 2,373 to 2,865. For those same streams, an additional 1,247 linear feet of
permanent impact is also proposed beyond the slope stakes in the final design, due to pipe
extensions or channel realignment. Impacts beyond slope stakes were not considered in the FEIS.
In addition, a total of 814 linear feet of permanent impacts were added to Section A of the
project on newly discovered/lengthened stream features that were not considered in the FEIS. All
of these combined increases/additions result in the 4,926 linear feet of permanent impacts
(permanent fill plus bank stabilization) proposed in the final design.
Listed below are some site-specific contributors to the differences between the FEIS and final
design permanent stream impacts in Section A:
• The jurisdictional reaches of three previously-identified features (at the time of the FEIS)
were extended after the FEIS was completed. Streams SB (Site 1), SC (Site 2), and SR
(Site 16) were all extended, which likely contributed to the increase in impacts at Site 2
(187 linear feet to 348 linear feet) and the addition of Sites 1 and 16 to the final design
(addition of 352 linear feet and 4941inear feet, respectively).
• Another contributor to the difference between the document and final design is the
addition of jurisdictional features after the FEIS was completed. A total of 444 linear feet
of permanent impact is proposed on streams that were not added to the project until the
after the FEIS (257 linear feet at Site 6[Stream SG], 82 linear feet at Site 8B [Stream
SK], and 105 linear feet at Site 12B [Stream Sl]).
• Final design proposes 18 linear feet of permanent impact at Site 7A to Stream SH (UTS),
but it was not proposed in the FEIS.
• 35 linear feet of bank stabilization related to the stormwater management design is
proposed at Site 17. This site did not have any proposed impacts in the LEDPA in the
FEIS.
• Impacts at Site 18 (MoAdams Creek) may have accidentally been omitted from the FEIS
(191 linear feet). The area where this site is located was included in the FEIS design, but
no impacts were identified. A feature with a separate stream ID is noted on the FEIS
mapping (UT 26) at this site, but impacts at this site accidentally being attributed to this
feature rather than MoAdams Creek appears unlikely because UT 26 is not included in
the FEIS estimated impacts table.
• It should be noted that, in two cases, permanent impacts that were identified in the FEIS
were eliminated in the final design. Stream SF (Site 5) was shortened during the 2012 JD
re-verification and Stream SE was determined to be ephemeral; both of these actions
eliminated the FEIS-level permanent impacts identified for those features (132 linear feet
and 80 linear feet, respectively).
Wetlands
The FEIS estimated a total of 0.249 acres of permanent wetland impacts, all of which were
within the A Section. After final design, proposed permanent wetland impacts within the A
Section are 0.38 acres, with 0.29 acres being either permanent fill or excavation and 0.09 acres
being mechanized clearing. Table 2 compares the FEIS and final design permanent wetland
U-3109 Review of Section A Impacts and Project Alternatives
Page 9 of 17

impacts within Section A. Any features that were included in the FEIS, but not in the final design
were placed at the bottom of the table.
Table 2. U-3109A, Comparison of LEDPA Permanent
Wetland Impacts from FEIS and Final Design
Permit Wetland ID FEIS Perm. Final Design
Site No. (FEIS ID) Impacts (Slope Perm.
Stakes) (ac.) Impacts (ac.)
9 WB (WL2) 0.002 0.01
12 WD --- 0.08
12A WE --- 0.03
13 WF (WI,4) 0.021 0.08
19 WA (WL11) 0.049 0.05
20 WC (WL13) 0.019 0.13
--- WL11 0.105 ---
--- WL31 0.008 ---
--- WL51 0.045 ---
SECTION A TOTALS 0.249 0.38
WLl, WL3, and WLS were eliminated in 2012 re-delineation.
There is an increase of 0.131 acres between the FEIS and final design. The slight increase to the
overall impact amount can be partially attributed to the addition of impacts at Wetlands WD
(Site 12) and WE (Site 12A), which were not identified at the document stage, but account for
0.11 acres of permanent wetland impact in the final design. Another partial explanation is the
fact that the FEIS-level impacts were only calculated using slope stakes, which would not have
accounted for the 0.09 acres of inechanized clearing.
U-3109, Comparison of Alternatives (Sections A and B�
Since the impacts for the A Section for both permanent stream and wetland impacts increased
between the FEIS and final design, it was determined that a review of the three alternatives
presented in the FEIS would be prudent in order to reaffirm the decision that Alternative 9 was/is
the LEDPA for this project. All three alternatives, Alternatives 8, 9(LEDPA), and 10 were
reviewed in their entirety (both Sections A and B) during this assessment.
To ensure that all three alternatives were reviewed with the same level of scrutiny (since
Alternative 9 jurisdictional features had been re-verified and new features were identified),
portions of Alternatives 8 and 10 that do not overlap with Alternative 9 were field-assessed to
determine whether either contained any potentially new features. Only one feature, Wetland W 1,
was identified in the B Section of Alternative 8; no new features were identified in Alternative
10. Wetland W 1 was included in the assessment, but has not be field-verified by USACE or
NCDWR.
U-3109 Review of Section A Impacts and Project Alternatives
Page 10 of 17

Streams
Table 3 compares final design stream impacts for Alternative 9 and assumed final design stream
impacts for Alternatives 8 and 10 in Section A and preliminary design stream impacts in Section
B to the FEIS stream impacts for each of the three alternatives considered in that document. The
FEIS impacts are based on slope stakes only. Final design permanent stream impacts for Section
A include both permanent fill and bank stabilization. Preliminary impacts for Section B in all
three alternatives were calculated using slope stakes plus 25-foot measurements and consider all
impacts as permanent fill. Any features that were included in the FEIS, but did not have a
permanent impact in advanced design are listed at the bottom of their respective section.
Since all three alternatives share common slope stakes for a majority of Section A, it is assumed
in Table 3 that the final design impacts in Alternative 9 in those common areas would also have
occurred in Alternatives 8 and 10 if those alternatives were brought forward. The only location
where impacts would occur/potentially occur outside of the common slope stakes in this Section
are impacts at UT14 (now Stream SU in Section A) and Mebane Rogers Road/East Stagecoach
Road. Alternative 8 and 9 avoid this feature in the FEIS and Alternative 10 would have impacted
it. For the final/assumed final impacts, Alternative 8 would still avoid this feature, while
Alternative 9 does impact it with bank stabilization, and Alternative 10 is still assumed to impact
it with a stream crossing/culvert. The Alternative 10 assumed final impacts at this site (Site 17)
are based on the impacts from the initial final design of Alternative 9, which was supposed to
impact Stream SU with a single-barrel box culvert; however, the iinal design was modified to
remove this impact from Alternative 9. It is assumed that this initial site design for Alternative 9
would have also been the design for Alternative 10, so those impacts were used to estimate the
site impact in the latter alterative.
U-3109 Review of Section A Impacts and Project Alternatives
Page 11 of 17

Table 3. U-3109 (Sections A and B) Streams, Comparison of Alternatives
Section A
Alternative 8 Alternative 9(Preferred) Alternative 10
FEIS Assumed FEIS Final FEIS Assumed
Final Final
Stream Impacts Impacts Design Impacts
Permit ID (Slope Design (Slope Perm. (Slope Design
Site No. Perm. Perm.
(FEIS ID) Stakes) Stakes) Impacts Stakes)
(lin. ft.) Impacts (lin. ft.) (lin. ft.) (lin. ft.) Impacts
(lin. ft.) (lin. ft.)
1 SB (UT2) --- 352 --- 352 --- 352
2 SC (UT3) 187 348 187 348 187 348
3 SD (UT1) 149 320 149 320 149 320
5 SF (UT4) 132 0 132 0 132 0
6 SG --- 257 --- 257 --- 257
7,18 MoAdams 376 755 376 755 376 755
Creek (564/191) (564/191) (564/191)
7A SH (UTS) --- 18 --- 18 --- 18
8A SJ (UT6) 325 463 325 463 325 463
8B SK --- 82 --- 82 --- 82
10 SM (UT7) 266 396 266 396 266 396
l0A �UT�A� 22 74 22 74 22 74
11 SO (UT8) 195 270 195 270 195 270
12B S 1 --- 105 --- 105 --- 105
12C S2 --- 0 --- O1 --- 0
13,16 SR 163 677 163 677 163 677
(UT 10) (183/494) (183/494) (183/494)
14 SS --- 0 --- O1 --- 0
15 (UT11) 323 447 323 447 323 447
17 (U 14) --- --- --- 35 812 1283
20 �T25� 155 327 155 327 155 327
SE 80 --- 80 --- 80
(UT24)
U-3109 Review of Section A Impacts and Project Alternatives
Page 12 of 17

Table 3. U-3109 (Sections A and B) Streams, Comparison of Alternatives (Continued)
Section B
Alternative 8 Alternative 9(Preferred) Alternative 10
Prelim. Prelim. Prelim.
Design Design Design
FEIS FEIS FEIS
Perm. Perm. Perm.
Stream Impacts Impacts Impacts
Permit Impacts Impacts Impacts
Site No. ID (Slope (Slope (Slope (Slope (Slope (Slope
(FEIS ID) Stakes) Stakes) Stakes)
(lin. ft.) Stakes (lin. ft.) Stakes (lin. ft.) Stakes
+ 25 ft.) + 25 ft.) + 25 ft.)
(lin. ft.) (lin. ft.) (lin. ft.)
1 (UT14� 283 637 196 280 2632 303
2 Mill Creek 04 04 04 04 04 04
2 UT15 --- --- --- --- 04 1785
3 (UT16) 194 253 293 400 302 358
4 �UT1�� 204 126 216 146 215 259
10 SI (UT29) --- 299 --- 299 --- 299
11 SJ (UT28) 91 181 100 181 94 181
12 UT12 274 303 --- --- --- ---
12 UT 13 35 109 --- --- --- ---
Section A Totals 2,373 4,891 2,373 4,926 2,454 5,019
Section B Totals 1,081 1,908 805 1,306 874 1,578
PROJECT TOTALS 3,454 6,799 3,178 6,232 3,328 6,597
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2 The FEIS impact listed for this feature accounted for impacts at two locations, one in Section A and one in Section B. Impact amount in FEIS totaled 344 linear
feet, which was split between the two sites (Site 17 in A and Site 1 in B); split was based on measurements taken in Microstation.
3 The impact amount is based on initial Alternative 9 impact at this site, which was for a single-barrel box culvert installation. The design for Alternative 9 was
modified, but it is assumed that the Alternative 9 design is what would have been used for Alternative 10; therefore, that impact amount (69 linear feet of permanent
fill and 59 linear feet of bank stabilization) was used for Alternative 10.
4 The FEIS assumed that Mill Creek would be spanned and no impacts would occur in any alternative. Therefare, preliminary designs on all three alternatives
assumed the same. However, a site number was assigned to this feature in case the final design impacts the creek.
5 The FEIS assumed that UT15 would not be impacted by the Mill Creek bridge crossing in Alternative 10. However, after reviewing the feature during preliminary
design impact assessment, it was determined that the feature would likely be impacted.
Although permanent stream impacts overall increased between the FEIS and the final design in
the A Section of the project, a majority of these increases, as stated above, would have also
occurred in the other two alternatives if either were chosen instead of Alternative 9. This is
because Alternatives 8, 9(Preferred), and 10 all share common slope stakes for a majority of
their lengths within the A Section. Assuming the impacts would have increased similarly within
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the three alternatives where common slope stakes occur, Alternative 8 would have the lowest
assumed amount of permanent impact in Section A at 4,891 linear feet, Alternative 9 would be in
the middle with 4,926 linear feet, and Alternative 10 would have the highest assumed final
design impacts at 5,019 linear feet. Alternative 9 would now be higher than Alternative 8 in
Section A(they were equal in the FEIS) due to the addition of 35 linear feet of bank stabilization
impacts required as part of the stormwater design at Stream UT14 (SU) and Mebane Rogers
Road/East Stagecoach Road (a type of impact that was not considered in FEIS-level design).
However, since the cause of the difference is bank stabilization, this increase in Alternative 9
impacts does not result in an increase in loss of water impacts when compared to Alternative 8.
Stream UT14 (SU) is the only impact site outside of the common slope stakes in Section A.
Alternative 10 would be the highest due to the assumed culvert impact at Stream UT14 (SU).
Alternative 10 also had the highest Section A stream impact total in the FEIS.
When considering the preliminary designs of the alternatives in Section B, all three alternatives
had an increase in impacts compared to the FEIS. This is partially due to the change from "slope
stakes only" estimates in the FEIS to "slope stakes plus 25-foot" estimates that are typically
shown in the preliminary design phase projects. However, the trends displayed in the FEIS
persisted even with the increases, where Alternative 9 is still the lowest impact, Alternative 10 is
second lowest, and Alternative 8 is the highest in Section B.
For the entire project (Sections A and B), permanent stream impacts, although higher than
predicted by the FEIS, still follow the same overall trend that was expressed in the NEPA
document. Alternative 9 still has the lowest overall stream impact of the three alternatives,
Alternative 10 is second lowest, and Alternative 8 is the highest.
Wetlands
Table 4 compares final design wetland impacts for Alternative 9 and assumed final design
wetland impacts for Alternatives 8 and 10 in Section A and preliminary design wetland impacts
in Section B to the FEIS wetland impacts for each of the three alternatives considered in that
document. The FEIS impacts are based on slope stakes only. Final design permanent stream
impacts for Section A include both permanent fill, excavation, and mechanized clearing.
Preliminary impacts for Section B in all three alternatives were calculated using slope stakes plus
25-foot measurements and consider all impacts as permanent fill. Any features that were
included in the FEIS, but did not have a permanent impact in advanced design are listed at the
bottom of Section A; no wetlands were identified in Section B in the FEIS.
Since all three alternatives share common slope stakes for a majority of Section A, it is assumed
in Table 4 that the final design impacts in Alternative 9 in those common areas would also have
occurred in Alternatives 8 and 10 if those alternatives were brought forward. No wetland impacts
occur/would occur outside of common slope stakes in Section A.
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Table 4. U-3109 (Sections A and B) Wetlands, Comparison of Alternatives
Alternative 8 Alternative 9(Preferred) Alternative 10
Section A
FEIS Assumed FEIS FEIS Assumed
Impacts Impacts Final Design Impacts
Permit Wetland ID Final Design Final Design
Site No. (FEIS ID) (Slope perm. (Slope Perm. (Slope perm.
Stakes) Stakes) Impacts (ac.) Stakes)
(ac.) Impacts (ac.) �ac.) (ac.) Impacts (ac.)
9 ws �wL2� 0.002 0.01 0.002 0.01 0.002 0.01
12 WD --- 0.08 --- 0.08 --- 0.08
12A WE --- 0.03 --- 0.03 --- 0.03
13 WF (WI,4) 0.021 0.08 0.021 0.08 0.021 0.08
19 WA (WL11) 0.049 0.05 0.049 0.05 0.049 0.05
20 WC (WL13) 0.019 0.13 0.019 0.13 0.019 0.13
--- WL1 0.105 --- 0.105 --- 0.105 ---
--- WL3 0.008 --- 0.008 --- 0.008 ---
--- WL51 0.045 --- 0.045 --- 0.045 ---
Section B
Prelim. Prelim. Prelim.
FEIS Design Perm. FEIS Design Perm. FEIS Design Perm.
Impacts Impacts Impacts
Permit Wetland ID �Slope Impacts (Slope Impacts (Slope Impacts
Site No. (FEIS ID) (Slope Stakes (Slope Stakes (Slope Stakes
Stakes) Stakes) Stakes)
+ 25 ft.) + 25 ft.) + 25 ft.)
(ac.) (ac.) (ac.) (ac.) (ac.) (ac.)
3 W 12 --- 0.03 --- 0 --- ---
4 WA --- 0.01 --- 0.01 --- <0.01
5 WB --- 0.13 --- 0.12 --- 0.09
6 WC --- 0.14 --- 0.11 --- 0.16
7 WD-1 --- 0.18 --- 0.18 --- 0.18
8 WE-1 --- 0.06 --- 0.06 --- 0.06
9 WE-2 --- 0.01 --- 0.01 --- 0.01
10 WG --- <0.01 --- <0.01 --- <0.01
Section A Totals 0.249 0.38 0.249 0.38 0.249 0.38
Section B Totals 0.00 0.58 0.00 0.51 0.00 0.51
PROJECT TOTALS 0.249 0.963 0.249 0.893 0.249 0.893
Wetlands WL1, WL3, and WLS were eliminated in the 2012 re-delineation.
� W 1 is a new wetland complex identified in Alternative 8 that was not previously delineated and has not been field-verified.
3 Rounded totals are sum of actual impacts.
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Although there is an increase in impacts between the FEIS and final design/assumed final design
impacts in Section A of all three alternatives, all wetland impacts within that section are within
areas of common slope stakes. Therefore, an identical increase would occur in Section A
regardless of the alternative that was brought forward.
The FEIS did not identify any wetlands within the B Section of the project, which resulted in a
marked increase in preliminary impacts in all three alternatives. However, with the exception of
Wetland W 1 in Alternative 8, the remaining wetlands are impacted to some degree by all three
alternatives. These remaining wetlands are either within areas of common slope stakes or areas
of near overlap of the alternative boundaries, which explains why preliminary impact numbers
are so similar between alternatives (with Alternatives 9 and 10 tied for the lowest impact and
Alternative 8 containing the highest amount).
Considering wetland impacts in both sections, Alternative 9 is equal to Alternative 10 in having
the lowest wetland impact totals. Alternative 8 is the highest, partially due to the addition of
Wetland W1 and it trajectory across Wetlands WB and WC.
Conclusions
Although there has been an increase in stream impacts within the A Section from FEIS to final
design, a majority of those increases, assuming the same design was applied, would have
occurred regardless of the alternative chosen due to all alternatives having common slope stakes
for a majority of their routes. Overall project estimates show that, with those increased stream
impacts accounted for across all three alternatives in Section A and preliminary Section B
impacts included for each route, the overall stream impacts for Alternative 9 are still the lowest
of the three alternatives, which mimics the trend initially presented in the FEIS.
When considering wetland impacts, the projected impacts for all three alternatives are much
higher than what was reported in the FEIS. This is primarily due to the addition of several
wetlands within the B Section, which did not have any wetlands at the time of the FEIS.
However, the B Section increase across alternatives is similar since most of the wetlands are in
areas of either common slope stakes or partial overlap of the alternatives. A review of the
wetland impacts for the overall project shows that Alternative 9 is tied with Alternative 10 for
the lowest projected amount of impacts.
In addition to the updated wetland and stream impacts indicating that Alternative 9 is still the
LEDPA, other significant factors that led to this alternative initially being chosen still hold true
today. One reason that Alternative 9 was chosen was the fact that it most effectively balanced the
impacts of the project on both the Graham-Mebane Reservoir water supply watershed critical
area and the Cates Farm. To the west, there was concern about the impact to the reservoir critical
area and, between Alternatives 8 and 9, Alternative 9 had the lowest impacts (1.0 mile of
Alternative 8 and 0.7 mile of Alternative 9 were within the watershed). To the east, there were
concerns about the impact to the Cates Farm, which is a Section 4(� resource and is listed as a
historic property on the National Register of Historic Places (NRHP). For Alternative 9,
approximately 12.6 acres of land would be acquired of the approximately 100 acres listed on the
NRHP. Alternative 10 would acquire approximately 13.4 acres of the area listed on the NRHP.
An additional 4.6 acres of the farm would be isolated from the remaining historic property with
Alternative 9, compared to 23.4 acres with Alternative 10. Alternative 9 was considered the
lowest impact to the Cates Farm and, therefore, was the preferred alternative for this resource.
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After re-evaluating all three alternatives that were presented in the FEIS, NCDOT has concluded
that Alternative 9, based on both impacts and minimization considerations for the crit'ical area
and the Cates Farm, is still the LEDPA for this project.
Thank you for your time and assistance with this project. Please contact James Mason at either
jsmason(�a,ncdot. o�v or [phone] if you have any questions or need additional information.
Sincerely,
Philip S. Harris III, P.E., C.P.M.
Natural Environment Section Head
Cc: Dave Wanucha, NCDWR
U-3109 Review of Section A Impacts and Project Alternatives
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