20090372 Ver 1_Other Agency Comments_20080625

DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT, CORPS OF ENGINEERS
P.O. BOX 1890
/ WILMINGTON. NORTH CAROLINA 28402-1890
REPLY TO
ATTENTION OE:
CESAW-RG (1145b) 25 June 2008

MEMORANDUM FOR: North Carolina Department of Transportation, Mr. James A. McInnis,
Project Planning Engineer, PDEA Branch

SUBJECT: Section 404/NEPA Merger 01 Elevation Issue Brief

1. References:

a. Handout, Concurrence Points 1 and 2, Purpose and Need/Alternatives to be studied in
detail, NC 210 (Murchison Rd.), Proposed Fayetteville Outer Loop to NC 24-87 (Bragg Blvd.),
Cumberland County, TIP Project U-4444, Dated April 22, 2008.

b. Merger 01: Roles & Responsibilities Guidance Document

1. Project Name and Brief Description: Action ID SAW 2008-01507, TIP- U-4444, NC 210
(Murchison Rd) From Proposed Fayetteville Outer Loop to NC 24-87 (Bragg Boulevard)
Cumberland County, NC.

2. Last Concurrence Point: CP 1, Purpose and Need; Date of Concurrence: 5/22/08

3. Proposal and Position: NCDOT proposes to carry two alternatives forward for further
studies. The alternatives are as follows:

a. Freeway Alternative 1 (Interchanges at Honeycutt, Randolph and Butner)

Alternative 1 would involve widening Murchison Road to six lanes with a 22-foot median and
providing interchanges at Honeycutt Road, Randolph Street and Butner Road. A partial tight
diamond interchange would be provided at Honeycutt Road, with Honeycutt Road carried over
Murchison Road. A loop and ramp in the southeast quadrant minimize the impacts to the
wetland system located just north of this location. A partial tight diamond interchange would be
provided at Randolph Street, with Randolph Street carried over Murchison Road. A service road
would be constructed to provide access from Randolph Street to the old Fort Bragg Post
Cemetery and the Sandhills State Veterans Cemetery. A tight diamond interchange would be
provided at Butner Road with Butner Road carried over Murchison Road.

b. Freeway Alternative 2 (Interchanges at Honeycutt and Randolph Only)

Alternative 2 involves widening Murchison Road to six lanes with a 22-foot median and
provides interchanges at Honeycutt Road and Randolph Street. This alternative would remove
all access to Butner Road from Murchison Road. At Honeycutt Road, a tight diamond

interchange will be provided, with Murchison Road carried over Honeycutt Road. A loop and
ramp in the southeast quadrant minimize the impacts to the wetland system located just north of
this location. At Randolph Street, a semi-directional interchange with a loop ramp located in the
northeast quadrant will be provided. Randolph Street will be carried over Murchison Road. All
access to Butner Road from Murchison Road will eliminated. Butner Road traffic will utilize
existing Bragg Boulevard to Randolph Street, and then utilize the Randolph Street Interchange
with Murchison Road. This alternative requires Bragg Boulevard to remain open between
Randolph Street and Butner Road.

4. Reasons for Non-concurrence: Qualitative information for only two alternatives were
provided at the concurrence meeting even though conceptual designs and traffic capacity
analyses were prepared for a number of other interchange options, as stated in the concurrence
meeting handout (Reference La above). No qualitative information for these other interchange
options was offered to the merger team until questions concerning the potential alternatives were
raised. This information was presented as new information at the merger meeting and was not
provided in advance of the meeting so that there could have been time to review the information
and provide a more thorough discussion on the potential alternatives. To date the Corps has not
received adequate qualitative information to definitively agree to drop some of the identified
alternatives from further consideration. Further, the Corps also suggested another intersection

alternative at Butner that we believe should be investigated further. Therefore, we believe that
the process is still in the alternative development stage and we do not have enough qualitative
information to clearly eliminate alternatives from further consideration.

5. Potentially Violated Laws/Regulations: Section 404(b)(1) of the Clean Water Act. Where
the activity associated with a discharge which is proposed for a special aquatic site, such as a
wetland, does not require access or proximity to or sighting within the special aquatic site in
question to fulfill its basic purpose (i.e., is not "water dependent"), practicable alternatives that
do not involve special aquatic sites are presumed to be available, unless clearly demonstrated
otherwise. In addition, where a discharge is proposed for a special aquatic site, all practicable
alternatives to the proposed discharge, which do not involve a discharge into a special aquatic
site are presumed to have less adverse impact on the aquatic ecosystem, unless clearly
demonstrated otherwise.

The National Environmental Policy Act, as amended. Provide full and fair discussion of
reasonable alternatives which would avoid or minimize adverse impacts or enhance the quality
of the human environment. Objectively evaluate all reasonable alternatives by sharply defining
the issues and providing a clear basis for choice among options by the decisionmakers.

6. Alternative Course of Action: NCDOT should agree to continue the development of
reasonable alternatives to be considered for further study. This should include the possible
elimination of the Randolph Street interchange and utilization of a Randolph Street access via
Honeycutt Road/Bragg Blvd. or Butner Road/Bragg Blvd. route. NCDOT should agree to
provide the conceptual design and traffic capacity analysis information that was visually
presented to the merger team for review and consideration in their decision making. NCDOT
should agree to abide by the Merger 01 Roles and Responsibility Guidance and provide
qualitative information on operational/geometric/safety analysis for the alternatives identified so
that the project team can then decide on what alternatives can be eliminated or carried forward
for further study.

/s/
Richard K. Spencer
Regulatory Project Manager

Y
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i
TIP Project U-4444
Preliminary Freeway Alternatives

Freeway Preliminary Alternative Concept Development
Design concepts were developed for interchanges at Honeycutt Road, a proposed
Randolph Street Extension and Butner Road. The following options were considered for
each location:

Interchange with Honeycutt Road
Honeycutt Road over Murchison Road
Murchison Road over Honeycutt Road

Interchang with Randolph Street
Ti t diamond interchange
Ti t Diamond Interchange Shifted North with Braided Ramps
Free-Flow Interchange with Loop (Murchison Road over Randolph Street)
Free-Flow Interchange with Loop (Randolph Street over Murchison Road)
Free-Flow Interchange with Loop and Collector-Distributor
Semi-Directional Interchange with Dual Loops and Collector-Distributor
(Murchison Road Over Randolph Street)
Semi-Directional Interchange with Dual Loops and Collector-Distributor
(Shifted Away From Railroad)

Interchange with Butner Road
Southbound Murchison Flyover
Tight diamond interchange
Single-point urban interchange
No Butner Road access from Murchison Road (tie Butner Road into
existing Bragg Boulevard south of Murchison Road)

Conceptual designs and traffic capacity analyses were prepared for all of these
different options. Several meetings were held between NCDOT, Fort Bragg, Fayetteville
MPO and Lochner to discuss the different designs. Wetland impacts, protected species
and relocation impacts were considered in the selection of the concepts to be studied in
detail. Two alternative preliminary designs were prepared for the project.

Honeycutt Road Interchange Concepts

Honeycutt Road over Murchison Road
This interchange concept has a loop and a ramp in the southeast quadrant east of
Murchison Road and two ramps west of Murchison Road. Honeycutt Road would be
carried over Murchison Road on a bridge. The loop and ramp east of Murchison Road
will minimize impacts to a wetland located north of Honeycutt Road. This interchange
configuration will operate at an acceptable level of service. This concept was carried
forward as a part of Detailed Study Alternative 1.

Murchison Road over Honeycutt Road
This interchange concept also has a loop and a ramp in the southeast quadrant and
two ramps west of Murchison Ro;id. Murchison Road would be carved over Honeycutt
Road on a bridge with this concept, however. The loop and ramp in the southeast
quadrant will avoid impacts to the wetlands in the northeast quadrant of the interchange.
This interchange concept will operate at an acceptable level of service. This concept was
carried forward as a part of Detailed Study Alternative 2.

Randolph Street Interchange Concepts

Nine design concepts were developed for the proposed Randolph Street Extension
interchange.

Tight Diamond Interchange
A tight diamond interchange was considered for the proposed Randolph Street
Extension in conjunction with an interchange at Butner Road. A tight diamond
interchange would not accommodate traffic diverted from Butner if an interchange was
not provided at Butner Road. Murchison Road would be carried over proposed Randolph
Street Extension with this concept. The ramp termini on Randolph Street for the eastern
ramps would be signalized. The ramp tcrmini on Randolph Street for the western ramps
would be free flowing; however, the western ramps would intersect Randolph Street very
close to the at-grade railroad crossing. In addition, operational problems may result due
to the proximity of the Butner Road interchange. This concept was dropped from further
consideration due to safety concerns over the proximity of the at-grade railroad crossing
and the potential weaving problem between the northern Randolph Street ramps and the
southern Butner Road ramps. A sketch of the tight diamond interchange is shown on
Figure 1 below.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT

CEMETERY

w!P`; ?<`````<<

RAILROAD

RCW FORAGING HABITAT
RANDOLPH ST. •

CEMETERY
NC 210 (MU CHISON ROAD)

NOT TO SCALE

Figure 1 Tight Diamond Interchange

Tight Diamond Interchange Shifted North with Braided Ramps
Shifting the proposed Randolph Street interchange northward would provide
additional distance between the railroad and the ramp termini on the west side of
Murchison Road, but would decrease the distance between the Randolph Street
interchange and the Butner Road interchange. In order to avoid weaving problems, a
braided ramp configuration for the northern Randolph Street and southern Butner Road
ramps was also investigated.
Shifting the interchange north would reduce impacts to red-cockaded woodpecker
foraging habitat but would increase wetland impacts. The tight diamond interchange
with braided ramps would operate well without the operational concerns of the other tight

diamond interchange configuration. For this reason, this concept was carried forward as ,
part of Detailed Study Alternative 1. This interchange configuration would not carry the
additional traffic diverted from Butner Road if an interchange was not provided at Butner
Road, however. A sketch of the shifted tight diamond interchange is shown on Figure 2
below.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT
CEMETERY

W > LNJ[i ; ltLltNlji ; '

RAILROAD

RCW FORAGING HABITAT
RANDOLPH ST. ?

CEMETERY
NC 210 URCHISON ROAD)

NOT TO SCALE

Figure 2 Tight Diamond Interchange Shifted North

Free-Flow Interchange with Loop (Murchison Road over Randolph Street)
In order to increase the weaving distance between the Butner Road and Randolph
Street interchanges, the tight diamond concept was modified and the ramps on the eastern
side of Murchison Road were replaced with a free flowing loop and ramp in the southeast
quadrant of the interchange. Murchison Road would be carried over Randolph Street
with this concept. This configuration would operate better than the tight diamond
interchange, but the loop and ramp would have more effect on red-cockaded woodpecker
foraging habitat than the tight diamond interchange. In addition, the railroad crossing
would still present concerns for the western ramps. Operational problems might still
result from the proximity of the western Randolph Street and Butner Road ramps. For
these reasons, this interchange concept was dropped from further consideration. A sketch
of this concept is shown on Figure 3 below.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT

CEMETERY

W > 4AN4,;
•0••

RAILROAD

RCW FORAGING ITAT
RANDOLPH ST.

CEMETERY
NC 210 (MURCHISON ROAD)
NOT TO SCALE '

Figure 3 Free-Flow Interchange with Loop

Free-Flow Interchange with Loop (Randolph Street over Murchison Road)
This free-flow interchange concept would have a free flowing loop and ramp in
the southeast quadrant of the interchange. Randolph Street would be carried over
Murchison Road and the railroad with this concept. The western ramps would be carried
over the railroad on individual bridges. The loop and ramp would have more effect on
red-cockaded woodpecker foraging habitat than the tight diamond interchange.
Operational problems might result from the proximity of the western Randolph Street and
Butner Road ramps, as well. For this reason, this interchange concept was dropped from
further consideration. A sketch of this concept is shown on Figure 4.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT
CEMETERY

'<1111ETIANOX < < < ` `

RAILROAD

RCW FORAGING HABITAT
RANDOLPH ST.

CEMETERY
NC 210 (MURCHISON ROAD)
NOT TO SCALE '

Figure 4 Free-Flow Interchange with Loop (Randolph St. Over Murchison Rd.)

Free-Flow Interchange with Loop and Collector-Distributor
This free-flow interchange concept is similar to the previously discussed concept,
except a collector-distributor would be provided between the western Randolph Street
and Butner Road ramps. The proximity of the western ramps at Randolph Street to the
railroad crossing would be a concern. In addition, the proposed collector-distributor
would take more property from the Sandhills State Veterans Cemetery than not providing
the collector-distributor. For these reasons, this interchange concept was dropped from
further consideration. A sketch of this concept is shown on Figure 5.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT
CEMETERY

all

RAILROAD

RCW FORAGING HABITAT
RANDOLPH ST.

CEMETERY
NC 210 (MURCHISON ROAD)

NOT TO SCALE V

Figure 5 Free-Flow Interchange with Loop and Collector-Distributor

Semi-Directional Interchange with Dual Loops and Collector-Distributor
(Murchison Road Over Randolph Street)
This inter,. range concept would involve providing a ramp and loop in the
southeast quadrant and a ramp and loop in the northwest quadrant of the interchange. In
addition, a collector-distributor would be provided between the western Randolph Street
and Butner Road interchanges. Murchison Road would be carried over Randolph Street.
This concept was dropped from further consideration because the ramp and loop in the
northwest quadrant of the interchange would cross the railroad at-grade and the ramp and
loop in the southeast quadrant would affect RCW foraging habitat. A sketch of this
concept is shown on Figure 6.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT

CEMETERY \

W > 1=ANA, ? T 4N ;

RAILROAD

RCW FORAGING HABITAT
RANDOLPH ST.

CEMETERY
NC 210 (MURCHISON ROAD)
NOT TO SCALE

Figure 6 Semi-Directional Interchange with Dual Loops and Collector-Distributor

Semi-Directional Interchange with Dual Loops and Collector-Distributor (Randolph
Street Over Murchison Road)
This interchange concept would involve providing a ramp and loop in the
southeast quadrant and a ramp and loop in the northwest quadrant of the interchange. In
addition, a collector-distributor would be provided between the western Randolph Street
and Butner Road interchanges. Randolph Street would be carried over Murchison Road.
This concept was dropped from further consideration because the ramp and loop in the
southeast quadrant would affect RCW foraging habitat. A sketch of this concept is
shown on Figure 6.

Semi-Directional Interchange with Dual Loops and Collector-Distributor (Shifted
Away From Railroad)
This interchange concept would involve providing a ramp and loop in the
southeast quadrant and a ramp and loop in the northwest quadrant of the interchange. In
addition, a collector-distributor would be provided between the western Randolph Street
and Butner Road interchanges. Murchison Road would be carried over Randolph Street
and the railroad. Randolph Street would be shifted northward from earlier similar
concepts, allowing the western ramps to tie into Randolph Street just before the railroad,
allowing one wider bridge instead of three narrower bridges at the railroad. This concept
was dropped from further consideration because the ramp and loop in the southeast
quadrant would affect both RCW foraging habitat and wetlands. A sketch of this concept
is shown on Figure 7.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT

CEMETERY

RAILROAD

RANDOLPH ST. RCW FO AGING HABITAT

CEMETERY
NC 210 (MURCHISON ROAD)
NOT TO SCALE

Figure 7 Semi-Directional Interchange with Dual Loops and Collector-Distributor
(Shifted Away From Railroad)

Free-Flow Interchange with Loop in Northeast Quadrant
This interchange concept was developed to accommodate traffic diverted from
Butner Road if no access was provided from Butner to Murchison Road. Traffic from
Butner Road would use existing Bragg Boulevard to Randolph Street and would access
Murchison Road from the proposed Randolph Street interchange.

A loop and ramp would be provided in the northeast quadrant of the interchange.
This configuration would operate better than placing the loop and ramp in the southeast

quadrant due to the high traffic volumes accessing northbound Murchison Road from
Randolph Street. This configuration would result in higher wetland impacts but lower
impacts to RCW foraging habitat. This concept was carried forward as a part of Detailed
Study Alternative 2. A sketch of this concept is shown on Figure 8.

NC 24-87 (BRAGG BLVD.)

RCW FORAGING HABITAT

CEMETERY

? W X4'1=1

RAILROAD

RANDOLPH ST.
RCW FORAGING HABITAT

CEMETERY
NC 210 (MURCHISON ROAD)
NOT TO SCALE

Figure 8 Free-Flow Interchange with Loop in Northeast Quadrant

Butner Road Interchange Concepts

Southbound Murchison Flyover
A concept which included an at-grade intersection for northbound Murchison
Road and a flyover for southbound Murchison Road was investigated. It was found that
due to the large amount of traffic projected for Murchison Road in 2030, any option that
would cause the mainline to stop would not achieve an acceptable level of service. The
option would require a signalized intersection for the traffic turning left from Butner
Road to Murchison Road northbound towards Spring Lake. This option resulted in a
Level of Service "F" for the overall signalized intersection.

Tight Diamond Interchange
A tight diamond interchange would operate at an acceptable level of service with
the 2030 traffic. Due to the proximity of the proposed Randolph Street interchange, the
southern Butner Road interchange ramps would be braided with the northern Randolph
Street interchange ramps. The tight diamond interchange was carried forward as a part of
Detailed Study Alternative 1 because it would operate better than a single-point urban
interchange.

Single-Point Urban Interchange Option
A single-point urban interchange was also investigated for Butner Road. It was
found that a tight diamond interchange would operate better, so this concept was dropped
from further consideration.

No Access
This concept would involve not providing access to Butner Road from Murchison
Road. Butner Road would be realigned to tie into existing Bragg Boulevard. Existing
Bragg Boulevard would be left in place between Butner Road and Randolph Street.
Traffic wishing to access Fort Bragg on Butner Road would utilize the Randolph Street
interchange. This concept would reduce project impacts to Sandhills State Veterans
Cemetery and to businesses along Bragg Boulevard in Spring Lake. For this reason, this
concept was carried forward as a part of Detailed Study Alternative 2.

Interchange Concepts LOS AM
PM
Signal Location Signal LOS
OVERALL EBL EBT WBT WBR NBL NBR
Butner RPA-RPB C C A D A C A

B B A D A D A
OVERALL EBT EBR WBL WBT SBL SBR
Butner RPC-RPD A B A C A C A
cc B B A C A D A
OVERALL EBL NBL
Randolph RPA-RPB C C C
D C D

Signal Location Signal LOS
Ref. # R2 Butner RPA-RPB SAME AS #R1
Butner RPC-RPD SAME AS #R1

Signal Location Signal LOS
Ref. # R3 Butner RPA-RPB SAME AS #R1
Butner RPC-RPD SAME AS #R1

Signal Location Signal LOS
Ref. # R4 Butner RPA-RPB SAME AS #R1
Butner RPC-RPD SAME AS #R1

Signal Location Signal LOS
Ln Butner RPA-RPB SAME AS #R1
o: Butner RPC-RPD SAME AS #R1
OVERALL EBL EBT WBT SBR
°C Randolph LPC-RPC E D A F F
F C A F F

Signal Location Signal LOS
Ref. # R6 Butner RPA-RPB SAME AS #R5
Butner RPC-RPD SAME AS #R5
Randolph LPC-RPC SAME AS #R5

Signal Location Signal LOS
OVERALL EBL EBT WBT WBR NBL NBR
o~c Butner RPA-RPB C B A D D D D
D D A D D D D
OVERALL EBT EBR WBL WBT SBL SBR
Butner RPC-RPD B C A C B C A
C D A B F D A

AM Interchange Concepts LOS
PM

REF. # Weave :ion Weave LOS

Between Butner RPD & Randolph RPC B
R1 C
Between Randolph RPB & Butner RPA D
B
Between Butner RPD & Randolph RPC B
R2 C
Between Randolph LPA & Butner RPA D
C
Between Butner RPD & Randolph RPC B
R3 C
Between Randolph LPA & Butner RPA D
C

CD Slip RP & Randolph RPC B
R4 C
Between Randolph LPA & Butner RPA D
C
CD Slip RP & Randolph RPC B
R5 C
Between Randolph LPA & Butner KPA D
C
CD Slip RP & Randolph RPC B
R6 C
Between Randolph LPA & Butner RPA D
C
R7 Between Randolph LPA & Butner RPA D
C

Tight Diamond Interchange

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A tight diamond interchange was considered for the proposed Randolph Street
Extension in conjunction with an interchange at Butner Road. A tight diamond
interchange would not accommodate traffic diverted from Butner if an interchange was
not provided at Butner Road. Murchison Road would be carried over proposed Randolph
Street Extension with this concept. The ramp termini on Randolph Street for the eastern
ramps would be signalized. The ramp termini on Randolph Street for the western ramps
would be free flowing; however, the western ramps would intersect Randolph Street very
close to the at-grade railroad crossing. In addition, operational problems may result due
to the proximity of the Butner Road interchange. This concept was dropped from further
consideration due to safety concerns over the proximity of the at-grade railroad crossing
and the potential weaving problem between the northern Randolph Street ramps and the
southern Butner Road ramps.

~OrJCEr
Free-Flow Interchange with Loop (Murchison Road over Randolph Street
)
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This configuration would operate better than the tight diamond
interchange, but the loop and ramp would have more effect on red-cockaded woodpecker
foraging habitat than the tight diamond interchange. In addition, the railroad crossing
would still present concerns for the western ramps. Operational problems might still
result from the proximity of the western Randolph Street and Butner Road ramps. For
these reasons, this interchange concept was dropped from further consideration.

Free-Flow Interchange with Loop (Randolph Street over Murchison Road)
200' 200' 400'

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This free-flow interchange concept would have a free flowing loop and ramp in
the southeast quadrant of the interchange. Randolph Street would be carried over
Murchison Road and the railroad with this concept. The western ramps would be carried
over the railroad on individual bridges. The loop and ramp would have more effect on
red-cockaded woodpecker foraging habitat than the tight diamond interchange.
Operational problems might result from the proximity of the western Randolph Street and
Butner Road ramps, as well. For this reason, this interchange concept was dropped from
further consideration.

Co,JCEPT
Free-Flow Interchange with Loop and Collector-Distributor RFC F Pq

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This free-flow interchange concept is similar to the previously discussed concept,
except a collector-distributor would be provided between the western Randolph Street
and Butner Road ramps. The proximity of the western ramps at Randolph Street to the
railroad crossing would be a concern. In addition, the proposed collector-distributor
would take more property from the Sandhills State Veterans Cemetery than not providing
the collector-distributor. For these reasons, this interchange concept was dropped from
further consideration.

Semi-Directional Interchange with Dual Loops and Collector-Distributor
ReF5
(Murchison Road Over Randolph Street)

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This interchange concept would involve providing a ramp and loop in the
southeast quadrant and a ramp and loop in the northwest quadrant of the interchange. In
addition, a collector-distributor would be provided between the western Randolph Street
and Butner Road interchanges. Murchison Road would be carried over Randolph Street.
This concept was dropped from further consideration because the ramp and loop in the
northwest quadrant of the interchange would cross the railroad at-grade and the ramp and
loop in the southeast quadrant would affect RCW foraging habitat.

- fir,- ¢
Co~I~ept' R, ~
Semi-Directional Interchange with Dual Loops and Collector-Distributor (Randolph
Street Over Murchison Road)

F

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(ENGLISH

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This interchange concept would involve providing a ramp and loop in the
southeast quadrant and a ramp and loop in the northwest quadrant of the interchange. In
addition, a collector-distributor would be provided between the western Randolph Street
and Butner Road interchanges. Randolph Street would be carried over Murchison Road.
This concept was dropped from further consideration because the ramp and loop in the
southeast quadrant would affect RCW foraging habitat.
I

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Semi-Directional Interchange with Dual Loops and Collector-Distributor (Shifted FFA, P 7
Away From Railroad)

o 2W 400'
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Randoph Street (Shifted) over Murchison Road with CD W c~S cc

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This interchange concept would involve providing a ramp and loop in the
southeast quadrant and a ramp and loop in the northwest quadrant of the interchange. In
addition, it collector-distributor would be provided between the western Randolph Street
and Butner Road interchanges. Murchison Road would be carried over Randolph Street
and the railroad. Randolph Street would be shifted northward from earlier similar
concepts, allowing the western ramps to tie into Randolph Street just before the railroad,
allowing one wider bridge instead of three narrower bridges at the railroad. This concept
was dropped from further consideration because the ramp and loop in the southeast
quadrant would affect both RCW foraginq habitat and wetlands.