20110464 Ver 1_NC 88 Widening (2)_20080905

Department of Environment and Natural Resources
Project Review Form
Project Number: 09-0055 County: Ashe
Date Received: 09/02/2008
Due Date: 09/29/2008
Protect Description: Proposed Widening of NC 88 from US 221 Business in Jefferson to NC 194 in Ashe County,
TIP #U-3812
is Project is being reviewed as indicated below
Regional Office Regional Office Area In-House Review
Asheville Air Soil & Water Marine Fisheries
Fayetteville Water Coastal Management Water Resources
Mooresville Aquifer Protection Wildlife Environmental Health
Raleigh Land Quality Engineer ? Wildlife - DOT Solid Waste Mgmt
Washington Forest Resources Radiation Protection
Wilmington Land Resources Other
Parks & Recreation
Winston-Salem
Water Quality
? Water Quality - DOT
Air Quality

Manager Sign-Off/Region Date In-House Reviewer/Agency
Response (check all applicable)
No objection to project as proposed No Comment
Insufficient information to complete review Other (specify or attach comments)
If you have any questions, please contact
Melba McGee, Environmental Coordinator at [e-mail]
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NC 88
From NC 194 to US 221 Business in Jefferson
Ashe County
WBS Element 34977
Federal Project Number STP-88(2)
State Project Number 8 2497401
T.I.P. Project Number U-3812
ADMINISTRATIVE ACTION
FINDING OF NO SIGNIFICANT IMPACT
UNITED STATES DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
AND
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
submitted pursuant to 42 U.S.C. 4332(2)(C)
APPROVED:
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tPregory J. Thorpe, Ph.D., Branch Manager
Project Development and Environmental Analysis Branch, NCDOT
e120? ? `w- ?,
Date ohn F. Sullivan III, P. E., Division Administrator
'#JFederal Highway Administration
NC 88
From NC 194 to US 221 Business in Jefferson
Ashe County
WBS Element 34977
Federal Project Number STP-88(2)
State Project Number 8 2497401
T.I.P. Project Number U-3812
FINDING OF NO SIGNIFICANT IMPACT
August 2008
Documentation Prepared in the Project Development and Environmental Analysis Branch by
Eug araseio
Project Development Engineer
Linwood Stone
Project Engineer
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eresa Hart, P.E.
Western Project Development Engineer
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SEAL _
PROJECT COMMITMENTS
for
Finding of No Significant Impact
NC 88
From NC 194 to US 221 Business in Jefferson
Ashe County
WBS Element 34977
Federal Project Number STP-88(2)
State Project Number 8 2497401
T.I.P. Project Number U-3812
Bicycle and Pedestrian Division. & Division 11
• McFarland Publishing Company owns two buildings opposite one another on NC 88
Operations require that their employees cross NC 88 on a daily basis The Bicycle and
Pedestrian Division will study pedestrian access for the McFarland Publishing Company
• This issue was addressed at a project meeting on May 14, 2008 (see part VI C) The
final resolution for this issue (which was agreed upon by Bike and Pedestrian Division,
Division 11 and the Town of Jefferson) was as follows
• The speed limit will be lowered from 45 to 35 mph
• A triangular pedestrian crossing sign will be installed on the westbound side of
NC 88 (the eastbound side did not warrant a sign because of the reduced speed
from steep grade and long sight distance)
• No crosswalk markings will be installed
• No further studies or pedestrian counts are required
• The Town of Jefferson is currently developing a Pedestrian Plan that includes
°p recommendations for sidewalk on one side of NC 88 within the town limits The Bicycle
and Pedestrian Division will continue coordination with the Town of Jefferson regarding
their plan and sidewalk on NC 88
=? • The final resolution for the sidewalks from the meeting on May 14, 2008 (see part VI C)
was the following the sidewalks will be installed on the south side of NC 88, from the
intersection of North Main Street to the Town limits and end at the 3-1ane curb and
gutter section at Lawson Lane The Town also requested that the north side of NC 88
provide an adequate road shoulder and driveway curb cut that will accommodate a
F sidewalk when installed in the future NCDOT agreed to these resolutions and funding
for the sidewalks would be in accordance with the NCDOT Pedestrian Policy
t Guidelines The Bicycle and Pedestrian Division, Roadway Design Unit and Division
11, will continue coordination with the Town of Jefferson regarding their plan and
sidewalk on NC 88
Geotechnical Engineering Unit
• The GeoEnvironmental Section of the Geotechmcal Engineering Unit will conduct
assessments on four sites which now or formerly operated underground storage tanks at the
intersection of NC 88 and US 221 Business in the Town of Jefferson
• The GeoEnvironmental Section of the Geotechnical Engineering Unit will conduct
Finding of No Significant Impact Page 1 of 2
August 2008
assessments, prior to right of way acquisition, on three sites that formerly operated
underground storage tanks All three are at the intersection of NC 88 and US 221
Business in the Town of Jefferson
HEU (Architectural & Archaeology), Roadway Design Unit & Construction Unit/Divison
11
• The Joseph Benjamin Neal House is eligible for the National Register of Historic Places
The proposed National Register Boundary includes the entire property parcel The Roadway
Design Unit will coordinate with the Historic Architecture Group during final design
regarding realignment of the driveway to minimize impacts to and maintain the existing
character of the Neal Property The Construction Unit will coordinate with the Historic
Architecture Group during the Preliminary Field Inspection regarding construction limits
and methods for clearing, grading, and road construction activities to minimize impacts to
and maintain the existing character of the Neal Property
• Additional archaeological testing will be required if construction is to take place outside of
the Area of Potential Effects in the vicinity of the Joseph Benjamin Neal House (National-
Register-Eligible Property) as established during the 2001 Archaeological Survey The
Area of Potential Effects evaluated was approximately 180 feet wide and centered on the
existing centerline of NC 88 The Construction Unit will coordinate with the Archaeology
Group during the Preliminary Field Inspection regarding the location of construction
limits, staging areas, and easements, and notify the Archaeology Group if construction
activities are planned to extend beyond the Area of Potential Effects in the vicinity of the
Neal Property If warranted, the Archaeology Group will conduct additional survey and
testing activities in those areas, and update their conclusions and recommendations as
needed
Hvdraulics Unit, Roadside Environmental Unit & Construction Unit
• "Best Management Practices for the Protection of Surface Waters" will be incorporated
into design and construction
• "Design Standards in Sensitive Watersheds" will be incorporated into design and
construction due to the potential for project runoff to Little Buffalo Creek, which is
designated as "Trout Waters" by the Division of Water Quality
Hvdraulics Unit
• The Hydraulics Unit will coordinate with FEMA and local authorities in final design to
facilitate the floodway revision process and to ensure compliance with applicable
floodplain ordinances
HEU (Noise & Air Ouality Group)
• The Noise & An- Quality Group will conduct an updated Traffic Noise Analysis, using
TNM 2 5, after the "Date of Public Knowledge" as defined in the NCDOT Traffic Noise
Abatement Policy
• Both the Traffic Noise Analysis and Air Analysis reports were updated in May of 2008
The Noise Analysis report was performed utilizing the FHWA traffic Noise Model
software (TNM 2 S) to predict future noise levels and impacted receptors for NCDOT s
recommended alternative, Build Alternate 4 A summary of the findings of these reports
are provided in part VII F of this document, while the full reports are in Appendix 8
This commitment has been completed
Finding of No Sigmficant Impact Page 2 of 2
August 2008
Finding of No Significant Impact
Prepared by the
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
In Consultation with the Federal Highway Administration
1. TYPE OF ACTION
This is a Federal Highway Administration (FHWA) administrative action, Finding of No
Significant Impact (FONSI) The NC Department of Transportation and FHWA have
determined this project will not have any significant impact on the human environment This
FONSI is based on the Environmental Assessment (EA) which has been independently evaluated
by the FHWA and determined to adequately and accurately discuss the environmental issues and
impacts of the proposed project The EA was completed in August 2007
II. DESCRIPTION OF PROPOSED ACTION
The North Carolina Department of Transportation (NCDOT) proposes to improve NC 88 in
Ashe County from NC 194 to US 221 Business in the Town of Jefferson (see Figure 1) In the
EA, NCDOT's recommended alternate (Build Alternate 4) consisted of the following
• Realignment of the intersection of NC 88 and NC 194
• Realignment of the S-curve between Locust Grove Drive and Lawson Lane
• Center turn lane between Lawson Lane and US 221 Business
• Upgrading the facility to current standards with 12-foot lanes
• Pedestrian crossing for McFarland Publishing Company
• Resurfacing the entire length of the project
The project was divided into two parts for discussion purposes the rural portion (from NC
194 to Lawson Lane) and the urban portion (from Lawson Lane to US 221 Business) The
proposed cross section for the rural portion is a two-lane shoulder section with traffic safety
improvements at various locations, while the proposed cross section for the urban section is a
three-lane curb and gutter section The proposed right of way width for the project varies
between approximately 80 and 200 feet throughout the length of the project The total length of
the project is approximately 16 miles This project is included in NCDOT's 2009-2015
Transportation Improvement Program (TIP) Right of way acquisition is scheduled to begin in
the 2009-2015 TIP during fiscal year 2010, while construction is scheduled to begin during fiscal
year 2012 The total estimated cost of NCDOT's recommended alternative is $8,050,000 which
includes 4,600,000 for right of way and $3,450,000 for construction
III. ACTIONS REQUIRED BY OTHER AGENCIES
The proposed project will result in impacts to surface waters In accordance with Section 404
of the Clean Water Act (33 U S C 1344), it is anticipated an Individual Permit according to CFR
330 5(A) will be required from the US Army Corps of Engineers The proposed project will also
require a 401 Water Quality General Certification from the North Carolina Department of
Environment and Natural Resources, Division of Water Quality
IV. PURPOSE OF AND NEED FOR THE PROPOSED PROJECT
The purpose of this action is to improve safety on NC 88 and improve a link between NC 194
and the existing multilane section in the Town of Jefferson The need is based upon correcting a
restricted cross section in mountainous terram with poor horizontal and vertical alignment
V. SUMMARY OF ANTICIPATED BENEFICIAL AND
ADVERSE ENVIRONMENTAL IMPACTS
Table 1 provides a summary of the quantifiable impacts associated with the proposed action
The impacts in the table are associated with Build Alternate 4 (NCDOT's preferred alternate)
which consists of a two-lane shoulder section in the rural portion and a three-lane curb and gutter
section in the urban section
Table 1
Summary of Impacts for Build Alternate 4
Category Units Build Alternate 4
Project Length Miles 16
Typical Roadway Sections
Rural Portion (RP)
Urban Portion (UP)
na 2-lane shoulder (RP)
3-lane curb & gutter
(UP)
Residential Relocations Total 1
Business Relocations Total 1
Farm Relocations Total 0
Non-Profit Relocations Total 0
Minority Relocations Total 0
Total Relocations Total 2
Hazardous Material (UST) Sites Each 4
Wetlands' Acres 01
2
Streams' Linear Feet 920
Ponds' Acres <001
Federally - Protected Species Species 0
Maintained /
Disturbed 101
Terrestrial Communities' Montane Oak /
Hickory Forest 1 9
Christmas Tree
Plantation 0
Prime Farmlands Each 0
23CFR772 Noise Category B2 Impacted Receptors 18
Substantial Noise Level Increase > 10
dB Impacted Receptors 0
Air Quality
Carbon Monoxide Concentration NAAQS Standard3 7 1
Architectural Resources Eligible Properties 1
Section 4(f) Resources Acres 04
Archaeological Resources Eligible Properties 0
Construction Cost Million Dollars $345
Right of Way Cost Million Dollars $46
Total Project Cost Million Dollars $805
NOTES
1 Impact calculations based on slope stake lines plus 25 feet
2 Noise Activity Category B exterior, equivalent sound level of approximately 67 dBA
3 National Ambient Air Quality Standards maximum CO permitted for 1-hr Ave = 35 ppm
VI. COORDINATION AND COMMENTS
A. Circulation of the Environmental Assessment
The Environmental Assessment (EA) was approved by the Federal Highway
Administration and the North Carolina Department of Transportation, Division of Highways on
August 8, 2007 The EA identified four build alternates under consideration for the project, with
Build Alternate 4 being the preferred action
The approved EA was circulated to the following federal, state, regional and local
governments and agencies for review and comment An asterisk (*) indicates a written response
was received Copies of the correspondence are included in Appendix 9 of this document
U S Army Corps of Engineers - Raleigh Regulatory Field Office (USACE)
* U S Fish and Wildlife Service- Asheville Field Office (USFWS)
* U S Environmental Protection Agency
* NC Department of Administration, NC State Clearinghouse
NC Department of Public Instruction
* N C Department of Cultural Resources - State Historic Preservation Office
* N C Department of Environment and Natural Resources
* Division of Water Quality (DWQ)
Division of Soil and Water Conservation
Division of Forest Resources
Division of Parks and Recreation
Division of Intergovernmental Affairs
Division of Marine Fisheries
Winston-Salem Regional Office
N C Wildlife Resources Commission
Ashe County Administration
Ashe County Board of Education
Ashe County Administration
* Town of Jefferson
* High County Rural Planning Organization
B. Comments Received on the Environmental Assessment
1. United States Environmental Protection Agency
Comment: The U S Environmental Protection Agency Region 4 (EPA) has reviewed the
subject document and is commenting 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 (FHWA) are proposing various improvements to NC 88
from NC 194 to US 221 Business in Jefferson, Ashe County for an approximate
distance of 16 miles
The proposed project has been in the NEPA/Section 404 Merger 01 process and
EPA notes the following concurrence point (CP) milestones CP 1 Purpose and
Need signed 12/13/01, CP 2 Alternatives to be Carried Forward for Detailed
Study signed 3/15/05, and CP 2A Bridging and Alignment Review also signed
3/15/05
The Merger 01 team concurred on four build alternatives for detailed study
Alternatives 1, 2 and 3 all widen the roadway to at least 3 lanes with a shoulder
section in the rural western portion of the project Alternative 1 maintains the
shoulder section throughout and Alternatives 2 and 3 utilize a 3-lane and 5-lane
curb and gutter section, respectively, in the eastern `urban' portion of the project
EPA will concur with NCDOT's recommendation for Alternative 4 being the
`Least Environmentally Damaging Practicable Alternative - LEDPA' (Preferred),
which greatly reduces impacts to terrestrial and aquatic resources and reduces or
avoids many of the human resource environmental impacts Estimated impacts to
jurisdictional streams and wetlands for Alternative 4 are 920 linear feet and 0 1
acres, respectively
Response: Comments noted
Comment: Little Buffalo Creek, classified "Class C waters, Tr +", its unnamed tributaries
(UT's) and UT's of Naked Creek, classified "Class C waters,+", will be impacted
by the proposed project These streams eventually flow to the New River, a
nationally designated Wild and Scenic River Despite the "+" classification of
these waters, which identifies waters subject to a special management strategy to
protect downstream Outstanding Resource Waters (ORW), both Little Buffalo
Creek and Naked Creek below the Town of Jefferson's Wastewater Treatment
Plant (east of the project) are listed on the 303(d) list of impaired waters Due to
the current impairment and downstream sensitive resources, EPA is requesting
that NCDOT consider the highest quality sediment and erosion control measures
The use of the most recent `experimental/mountain' Best Management Practices
(BMPs) as was presented to the Merger Interagency representatives on September
27, 2007, is a possible example of the strict soil erosion and control measures that
might be needed The NCDOT-funded research to North Carolina State
University includes the use of `coconut fiber logs', `straw wattles', `PAM' and
other innovative soil erosion and sediment control techniques to remove clays and
other fine particles from entering nearby waterways during construction
Response: Comments noted Naked Creek was on the 2004 Final Impaired Water List, but
was not listed on the 2006 Final List Therefore this site does not warrant the
highest sediment and erosion control measures (Design Standards in Sensitive
Watersheds) Little Buffalo Creek is listed on the 2006 Final Impaired Water List
for the following reasons impervious surface, WWTP NPDES, urban
runoff/storm sewers, and minor municipal point sources Design Standards in
Sensitive Watersheds should not be required for the 303(d) listing at this site
because the listing is not for sediment However, Design Standards in Sensitive
Watersheds will be required for the Little Buffalo Creek crossing, because it is
classified as a Trout Water
While NCDOT has been very pleased with the findings of the research for the
experimental mountain erosion and sedimentation control best management
practices (EM BMPs), NCDOT is concerned that mandating the use of this BMP
may present issues for the overall effectiveness of erosion and sedimentation
control plan for this project NCDOT has a limited knowledge of how this BMP
will perform during various flow rates with suspended sediment loads
Mandating the use of a BMP that is not fully evaluated raises some concerns that
could potentially impact the environment if used incorrectly
Comment: EPA will continue to stay actively involved in the Merger 01 process for this
project EPA also recommends that NCDOT and other primary agencies consider
a combined CP 3 LEDPA and CP 4 Avoidance and minimization meeting for
efficiency and streamlining purposes EPA acknowledges the FHWA interim
generic guidance on Mobile Source Air Toxics (MSATs) that has been included
in the EA (Pages 33 to 38) Due to the limited scope of the proposed project, its
location and the existing air quality in the project study area, EPA does not
believe that MSATs are a significant environmental issue EPA acknowledges the
project environmental commitments ("Green sheets") and requests that the
`Experimental/Mountam' erosion and sediment control BMPs cited above are
incorporated into the Finding of No Significant Impact (FONSI) The updated
Traffic Noise Analysis (using TNM 2 5) per the Green Sheet commitment should
also be included in the FONSI as well
Response: Comments noted Both the Traffic Noise Analysis and Air Analysis reports were
updated in May of 2008 The Noise Analysis report was performed using the
FHWA traffic Noise Model software (TNM 2 5) to predict future noise levels and
impacted receptors for NCDOT's recommended alternative, Build Alternate 4 A
summary of the findings of these reports are provided in part VII F of this
document, while the full reports are in Appendix 8
NCDOT would prefer not to incorporate the `Experimental/Mountain' erosion
and sediment control BMPs (EM-BMPs), into the FONSI for the reasons given
under the previous response NCDOT will continue to evaluate the EM BMPs
and determine its best use and fit on a project, however, to the greatest extent
practicable, NCDOT will incorporate the EM BMPs The overall goal of the
erosion and sedimentation control plan is to provide the best protection utilizing
the most efficient means necessary NCDOT will continue to keep EPA informed
of our progress and the selection of which BMPs are best suited for this particular
project
Comment: EPA recognizes that the NCDOT included some relevant and excellent
photographs, tables, and figures in the EA that facilitated our review and provides
the public with a much clearer understanding of the proposed project and the
important environmental resources that have been identified in the project study
area Please also include Ms Kathy Matthews of EPA's Wetlands Section for
future coordination on avoidance and minimization efforts, and hydraulic and
permit review meetings EPA requests a copy of the FONSI when it becomes
available
Response: Comments noted
2. Department of Cultural Resources - State Historic Preservation Office
Comment: No comment
3. North Carolina Department of Environment and Natural Resources
a. Division of Water Quality
Comment: This office has reviewed the referenced document dated August 8, 2007 The
Division of Water Quality (DWQ) is responsible for the issuance of the Section
401 Water Quality Certification for activities that impact Waters of the U S ,
including wetlands It is our understanding that the project as presented will
result in impacts to jurisdictional wetlands, streams, and other surface waters
The DWQ offers the following comments based on review of the aforementioned
document
This project is being planned as part of the 404/NEPA Merger Process As a
participating team member, the NCDWQ will continue to work with the team
Response: Comment noted
Comment: Little Buffalo Creek and its tributaries are class C Tr waters of the State DWQ
recommends that the most protective sediment and erosion control BMPs be
implemented to reduce the risk of turbidity violations in trout waters In addition,
all disturbances within trout buffers shall be conducted in accordance with NC
Division of Land Resources and NC Wildlife Resources Commission
requirements
Response: The most protective sediment and erosion control (Design Standards in Sensitive
Watersheds) will be used for the Little Buffalo Creek and its unnamed tributaries
impacted by the project Although the Little Buffalo Creek and its tributaries are
designated as Trout Waters, the North Carolina Wildlife Resources Commission
has indicated that trout do not exist in the project area Therefore, a moratorium
on in-stream or land-disturbing activities is not required
Comment: The environmental document shall provide a detailed and itemized presentation of
the proposed impacts to wetlands and streams with corresponding mapping If
mitigation is necessary as required by 15A NCAC 2H 0506(h), it is preferable to
present a conceptual (if not finalized) mitigation plan with the environmental
documentation Appropriate mitigation plans will be required prior to issuance of
a 401 Water Quality Certification
Response: A detailed and itemized presentation of the proposed impacts to wetlands and
streams with corresponding mapping was presented in the EA document A
summary of the estimated impacts by NCDOT's recommended alternate, Build
Alternate 4 (also chosen as the LEDPA), are provided in Table 1 Both the Little
Buffalo Creek and the Little Buffalo UT-B appear to be under the 150 foot linear
threshold at which compensatory mitigation is typically required Estimated impacts
to Naked UT-A by Build Alternate 4 appear to exceed the 150 Imear foot threshold
Impacts to Little Buffalo UT-A may not require compensatory mitigation because it
7
is a small intermittent stream Compensatory mitigation requirements for Naked
UT-A may be satisfied by using natural channel design to relocate the parallel
reaches of these streams outside the project fill limits
Total wetland impacts for Build Alternate 4 are less than 1/3 acre and should not
require compensatory mitigation Proposed impacts to the pond are less than 0 1
acre and may not require compensatory mitigation
Compensatory mitigation for wetland and stream losses may be required where
avoidance and minimization of impacts are not possible Mitigation requirements
will be dependent upon final road plans A detailed mitigation plan will be
developed during the permit coordination phase of the project
Comment: Environmental assessment alternatives shall consider design criteria that reduce
the impacts to streams and wetlands from storm water runoff These alternatives
shall include road designs that allow for treatment of the storm water runoff
through best management practices as detailed in the most recent version of NC
DWQ Stormwater Best Management Practices, such as grassed swales, buffer
areas, preformed scour holes, retention basin, etc
Response: Comments noted NCDOT will incorporate the most current and appropriate Best
Management Practices (BMPs) approved by DWQ for stormwater runoff into the
project design
Comment: After the selection of the preferred alternative and prior to an issuance of the 401
Water Quality Certification, the NCDOT is respectfully reminded that they will
need to demonstrate the avoidance and minimization of impacts to wetlands (and
streams) to the maximum extent practical In accordance with the Environmental
Management Commission's Rules 115A NCAC 2H 0506(h)), mitigation will be
required for impacts of greater than 1 acre to wetlands In the event that
mitigation is required, the mitigation plan should be designed to replace
appropriate lost functions and values The NC Ecosystem Enhancement Program
may be available for use as wetland mitigation
Response: NCDOT has selected the asymmetrical widening (best-fit) alternative as the
preferred alternative, which incorporates avoidance and minimization of impacts
to streams and wetlands to the greatest extent practicable NCDOT will provide
all appropriate documentation to DWQ prior to issuance of a 401 Water Quality
Certification
Comment: In accordance with the Environmental Management Commission's Rules 115A
NCAC 2H 0506(h)}, mitigation will be required for impacts of greater than 150
linear feet to any single perennial stream In the event that mitigation is required,
the mitigation plan should be designated to replace appropriate lost functions and
values The NC Ecosystem Enhancement Program may be available for use as
wetland mitigation
Response: Comment noted It is anticipated that the project will impact a total of 888 linear
feet of five perennial streams NCDOT will provide all appropriate documentation
to DWQ prior to issuance of a 401 Water Quality Certification
Comment: Future documentation, including the 401 Water Quality Certification Application
should continue to include an itemized listing of the proposed stream and wetland
impacts with corresponding mapping
Response: Comment noted
Comment: DWQ is very concerned with sediment and erosion impacts that could result from
this project NC DOT shall address these concerns by describing the potential
impacts that may occur to the aquatic environments and any mitigating factors
that would reduce the impacts
Response: This issue was discussed in detail on page 46, Section 8 3 3 5 "Summary of
Anticipated Impacts to Water Resources" in the EA document As the project
continues to move through the merger process, these mitigating factors discussed
in the EA will continue to be refined and finalized for this specific project
Comment: NC DOT is respectfully reminded that all impacts, including but not limited to,
bridging, fill, excavation and clearing to jurisdictional wetland, streams, and
riparian buffers need to be included in the final impact calculations These
impacts, in addition to any construction impacts, temporary or otherwise, also
need to be included as part of the 401 Water Quality Certification Application
Response: Comment noted All anticipated impacts to wetlands, streams, and riparian
buffers (if applicable) will be included in the 401 Water Quality Certification
Application
Comment: Where streams must be crossed, the DWQ prefers bridges be used in lieu of
culverts However, we realize that economic considerations often require the use
of culverts Please be advised that culverts shall be countersunk to allow
unimpeded passage by fish and other aquatic organisms Moreover, in areas
where high quality wetlands or streams are impacted, a bridge may prove
preferable When applicable, DOT should not install the bridge bents in the
creek, to the maximum extent practicable
Response: There are no existing or proposed bridges within the limits of the proposed action
There are three existing culverts within the project Two of these existing culverts
will be replaced as part of the proposed action for the project
Comment: Sediment and erosion control measures shall not be placed in wetlands or streams
Response: NCDOT's BMPs for Protection of Surface Waters and Sedimentation Control
guidelines will be followed during project construction
9
Comment: Borrow/waste areas shall avoid wetlands to the maximum extent practical
Impacts to wetlands in borrow/waste area will need to be presented in the 401
Water Quality Certification and could precipitate compensatory mitigation
Response: Comment noted All anticipated impacts to wetlands, streams, and riparian
buffers (if applicable) will be included in the 401 Water Quality Certification
Application
Comment: The 401 Water Quality Certification application will need to specifically address
the proposed methods for stormwater management More specifically, stormwater
shall not be permitted to discharge directly into streams or surface waters
Response: NCDOT will provide all appropriate documentation to DWQ prior to issuance of
a 401 Water Quality Certification
Comment: Based on the information presented in the document, the magnitude of impacts to
wetlands and streams may require an Individual Permit (IP) application to the
Corps of Engineers and corresponding 401 Water Quality Certification Please be
advised that a 401 Water Quality Certification require satisfactory protection of
water quality to ensure that water quality standards are met and no wetland or
stream uses are lost Final permit authorization will require the submittal of a
formal application by the NCDOT and written concurrence from the NCDWQ
Please be aware that any approval will be contingent on appropriate avoidance
and minimization of wetland and stream impacts to the maximum extent practical,
the development of an acceptable stormwater management plan, and the inclusion
of appropriate mitigation plans, where appropriate
Response: Comment noted The proposed project will result in impacts to surface waters In
accordance with Section 404 of the Clean Water Act (33 U S C 1344), it is
anticipated an Individual Permit according to CFR 330 5(A) will be required from
the US Army Corps of Engineers NCDOT will apply for IP 404 and EP 401
Avoidance and minimization of wetland and stream impacts will be to the
maximum extent possible NCDOT will provide all appropriate documentation to
DWQ prior to issuance of a 401 Water Quality Certification
Comment: If concrete is used during construction, a dry work area shall be maintained to
prevent direct contact between curing concrete and stream water Water that
inadvertently contacts uncured concrete shall not be discharged to surface waters
due to the potential for elevated pH and possible aquatic life and fish kills
Response: Comment noted All BMPs for Protection of Surface Waters will be implemented
during project construction
Comment: If temporary access roads or detours are constructed, the site shall be graded to its
preconstruction contours and elevations Disturbed areas shall be seeded or
mulched to stabilize the soil and appropriate native woody species shall be
10
planted When using temporary structures the area shall be cleared but not
grubbed Clearing the area with chain saw, mowers, bush-hogs, or other
mechanized equipment and leaving the stumps and root mat intact allows the area
to re-vegetate naturally and minimizes soil disturbance
Response: Comment noted
Comment: Placement of culverts and other structures in waters, streams, and wetlands shall
be placed below the elevation of the streambed by one foot for all culverts with a
diameter greater than 48 inches, and 20 percent of the culvert diameter for
culverts having a diameter less than 48 inches, to allow low flow passage of water
and aquatic life Design and placement of culverts and other structures including
temporary erosion control measures shall not be conducted in a manner that may
result in dis-equilibrium of wetlands or streambeds or banks, adjacent to or
upstream and of the above structures The applicant is required to provide
evidence that the equilibrium is being maintained if requested in writing by
DWQ If this condition is unable to be met due to bedrock or other limiting
features encountered during construction, please contact the NC DWQ for
guidance on how to proceed and to determine whether or not a permit
modification will be required
Response: Comment noted Appropriate culvert and structure placement procedures will be
observed
Comment: If multiple pipes or barrels are required, they shall be designed to mimic natural
stream cross section as closely as possible including pipes or bands at food plain
elevation and/or sills where appropriate Widening the stream channel shall be
avoided Stream channel widening at the inlet or outlet end of structures typically
decreases water velocity causing sediment deposition that requires increased
maintenance and disrupts aquatic life passage
Response: Comment noted Appropriate pipe and culvert designs will be implemented
Comment: If foundation test borings are necessary, it shall be noted in the document
Geotechmcal work is approved under General 401 Certification Number
3494/Nationwide Permit No 6 for Survey Activities
Response: Comment noted NCDOT does not anticipate foundation test borings for this
project
Comment: Sediment and erosion control measures sufficient to protect water resources must
be implemented and maintained in accordance with the most recent version of
North Carolina Sediment and Erosion Control Planning and Design Manual and
the most recent version of NCS000250
Response: Comment noted Appropriate sediment and erosion control measures will be
implemented
Comment: All work in or adjacent to stream waters shall be conducted in a dry work area
Approved BMP measures from the most current version of NCDOT Construction
and Maintenance Activities such as sandbags, rock berms, cofferdams and other
diversion structures shall be used to prevent excavation in flowing water
Response: Comment noted NCDOT will implement the most current BMP measures during
construction
Comment: While the use of National Wetland Inventory (NWI) maps, NC Coastal Region
Evaluation of Wetland Significance (NC-CREWS) maps and soil survey maps are
useful tools, their inherent inaccuracies require that qualified personnel perform
onsite wetland delineations prior to permit approval
Response: Comment noted Wetlands were delineated by qualified personnel in the 2002
Natural Resources Technical Report and the wetland delineation was re-verified
on May 13, 2008 by the USACE The verification is valid for 5 years %
Comment: Heavy equipment shall be operated from the bank rather than in streams in order
to minimize sedimentation and reduce the likelihood of introducing other
pollutants into streams This equipment should be inspected daily and maintained
to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials
Response: Comment noted NCDOT will implement the most current BMP measures during
construction
Comment: Riprap shall not be placed in the active thalweg channel or placed in the
streambed in a manner that precludes aquatic life passage Bioengineering
boulders or structures shall be properly designed, sized and installed
Response: Comment noted All appropriate measures will be taken to protect stream and
aquatic life
Comment: Riparian vegetation (native trees and shrubs) shall be preserved to the maximum
extent possible Riparian vegetation must be reestablished within the construction
limits by the end of the growing season following completion of construction
Response: Comment noted All appropriate measures will be taken to preserve and
reestablish riparian vegetation to the extent possible
12
b. North Carolina Wildlife Resources Commission
Comments: The North Carolina Department of Transportation (NCDOT) has submitted for
review an Environmental Assessment (EA) document for the subject project
Staff biologist with the North Carolina Wildlife Resources Commission
(NCWRC) have reviewed the information provided and are participating in the
Merger 01 process for this project These comments are provided in accordance
with the provisions of the National Environmental Policy Act (42
U S C 4332(2)(c)) and the Fish and Wildlife Coordination Act (48 Stat 401, as
amended, 16 U S C 661-667d)
The NCDOT proposes to widen approximately 16 miles of NC 88 to a multilane
facility from NC 194 to US 221 Business in the Town of Jefferson The Merger
Team agreed on four build alternatives for detailed study Alternative 1, 2 and 3
all widen the roadway to at least 3 lanes with a shoulder section in the rural
western portion of the project Alternative 1 maintains the shoulder section
throughout, Alternative 2 and 3 use a 3-lane and 5-lane curb and gutter section,
respectively, in the eastern urban portion of the project Alternative 4, the safety
improvement alternative, includes 3-lanes in the urban section and realignment of
an S-curve and the intersection of NC 88 and NC 194 Alternate 4 was developed
when it was determined that capacity improvements were not warranted The
area has been growing more slowly than originally anticipated, about four to five
percent per year
NCWRC agrees with NCDOT's recommendation of Build Alternative 4,
which greatly reduces impacts to terrestrial and aquatic resources and
reduces or avoids many human environmental impacts Little Buffalo Creek,
classified "C, Tr +", its unnamed tributaries (UT's) and UT's of Naked Creek,
classified "C,+", will be impacted by the project These streams eventually flow
to the New River, a nationally designated scenic river Despite the "+"
classification of these waters, which identifies waters subject to a special
management strategy to protect downstream Outstanding Resource Waters
(ORW), both Little Buffalo Creek and Naked Creek below the Town of
Jefferson's Wastewater Treatment Plant (east of the project) are listed on the
303(d) list of impaired waters Green floater (Lasmigona subviridis), Federal
Species of Concern (FSC) and state Endangered (E) logperch (Percill o
caprodes), state threatened (T), seep mudalia (Leploxis dilarma), state T,
Kanawha minnow (Phenacobtus tereulus), FSC and state Special Concern (SC),
sharpnnose darter (P oxyrhynchus), state SC spike (Elliptio dclatata), state SC,
Kamawha darter (Etheostomaa kanawhae) state Significantly Rare (SR), and
tonguetied minnow (Exoglossum laurae), state SR, may occur in or downstream
of the project area Trout reproduction is not expected in the project area,
however, due to current impairment and downstream sensitive resources, highest
quality sediment and erosion control measures should be employed and strictly
enforced
13
Response: Comments noted Naked Creek was on the 2004 Final Impaired Water List, but
was not listed on the 2006 Final List Therefore this creek and its UTs do not
warrant the highest sediment and erosion control measures (Design Standards in
Sensitive Watersheds) Little Buffalo Creek is listed on the 2006 Final Impaired
Water List for the following reasons impervious surface, WWTP NPDES, urban
runoff/storm sewers, and minor municipal point sources Design Standards in
Sensitive Watersheds should not be required for the 303(d) listing at this site
because the listing is not for sediment However, Design Standards in Sensitive
Watersheds will be required for the Little Buffalo Creek and its UTs, because it is
classified as a Trout Water
Comments: We have concerns regarding the acidic nature of soils in the area Most of the
soils in the project study area were described as being strongly acidic to very
strongly acidic and that the erosion hazard is severe on exposed areas A plan to
address this issue and prevent acidic runoff from entering aquatic habitats will be
needed for the construction of this project
Response: NCDOT is proposing that shoulders and fills in the areas affected by acidic soils,
within the project, be constructed with a minimum of 6 inches of soil capable of
supporting vegetation per our construction contract special provision SP2R45
The soil will have a pH ranging from 5 5 to 6 8 On cut sections containing acidic
soil, NCDOT proposes an addition application of 2 tons of limestone per acre to
raise the underlying soils pH
The department places a high priority on quick vegetative establishment and
adheres to the Sedimentation and Pollution Control Act's 21 day requirement to
provide ground cover Repair and supplemental seeding and topdressing
throughout the life of the project will insure a good stand of vegetation
NCDOT will also be including sediment and erosion control measures which
adhere to the Design Standards for Sensitive Watersheds, where appropriate
These measures will be strictly maintained until project completion to avoid
impacts to downstream aquatic resources
Comments: Although we believe the potential for induced development with Alternative 4 is
relatively low, the natural environment was not mentioned in the very brief
Indirect and Cumulative Impacts section The section did indicate a positive
effect on future industrial development activity and improved accessibility to
unused tracts of land It also indicated the project will affect the character of the
residential community in the urban portion, possibly increasing commercial uses
How these changes and trends might affect water quality and the sensitive natural
resources downstream should be addressed in the FONSI Increased impervious
coverage, pollutant input, and storm water runoff can have significant negative
impacts to streams and aquatic resources Measures to protect the water quality
and natural resources from construction and uncontrolled development should be
presented NCDOT, NC Division of Water Quality, and local officials should
14
work together to ensure protective measures are in place prior to project
construction
Response: Comments noted An update of the ICE analysis was conducted to address the
indirect and cumulative effects this project would have on the natural
environment The findings and conclusions of this update are given in part VII C
of this document (see Appendix 5 for the full report)
4. Town of Jefferson
Comment: The project is in agreement with the goals and objectives of this agency's
program
Response: Comment noted
5. High County Rural Planning Organization
Comment: The project is in agreement with the goals and objectives of this agency's
program
Response: Comment noted
C. Comments Received During and Subsequent to the Public Hearing
The ACOE Public Notice was posted on November 15, 2007 and comments were accepted
through December 17, 2007 The only written public comment received during this period was
from a Mr E T Weaver This was the same written comment received from Mr Weaver during
the Combined Public Hearing and is presented below
Following the circulation of the Environmental Assessment, an informal Combined Public
Hearing was held on November 29, 2007 at the Ashe County High School located on Campus
Drive in West Jefferson (see Appendix 1 for the notice and handout from the hearing)
Approximately 41 people attended Four build alternates were presented at the hearing for
comments The typical section presented for NCDOT's preferred alternate (Build Alternate 4),
consisted of a three-lane shoulder section for the realignment of the NC 88 and NC 194
intersection and a three-lane curb and gutter section from the urban portion (from Lawson Lane
to US 221 Business) The majority of the citizens in attendance, including the Town of Jefferson
preferred Build Alternate 4 A total of six written comments were received, two by the same
citizen Three written comments supported Build Alternate 4 because it had fewer relocatees and
included curb and gutter One written comment (from E T Weaver) preferred Build Alternates
1, 2 or 3, and expressed concerns regarding the NC 88 and US 221 Business intersection
including improving the sight distance, truck turning radius and flooding during large storms
One written comment preferred Build Alternate 3, but supported Build alternate 4 if a climbing
lane was added from Dogget Road to the crest of a hill near Mount Patty Christian Union Church
(approximately Station 55+00) A summary of the written comments and responses to them are
included in Appendix 2 (Post Hearing Minutes)
15
A conversation with property owner Talmadge S Shepherd indicated that a gas station
formerly operated at the property he owns at 1586 Highway NC 88 West in West Jefferson This
previously unknown UST site is discussed more in part VII E 3 of this document and has been
added to the Project Commitments under the Geotechnical Engineering-GeoEnvironmental
Section part It has also been included in Table 1 - Summary of Impacts for Build Alternate 4
The Town of Jefferson had several verbal comments at the public meeting, but did not
submit any written comments During the CP 2A Revised portion of the Merger Team Meeting
in April 2008, the High Country RPO introduced comments by the Town The Town's
comments consisted of the following statements
The town would like to see a sidewalk on the north side of the roadway extending from
US 221 Business to the city limits/Locust Grove Drive
The urban section (3-lane with curb and gutter) should extend out to the city
limits/Locust Grove Drive
• The design should focus the widening on the north side near the US 221 Business
intersection, if possible
The second comment in particular led to several agencies at the merger meeting wanting to
know the specific reason for this request, since it appeared that implementation of this comment
would increase impacts to the natural environment
On May 14, 2008 a meeting was held at the Ashe County Government Complex in
Jefferson, NC The meeting included NCDOT personnel, Town of Jefferson and Ashe County
officials along with the High Country RPO The meeting was held to address the second
comment mentioned above, along with several other issues that had emerged on the project The
other issues included requests from the Town of Jefferson concerning sidewalks, focusing
widening of NC 88 on the north side near the US 221 and a proposed pedestrian crossing at
McFarland Publishing Only the extension of the 3-lane curb and gutter section and focusing
widening of NC 88 on the north side are discussed here See part VII A of this document for a
discussion on the sidewalks and part VII B for a discussion on the pedestrian crossing
The Town of Jefferson officials were asked the purpose of their request that the 3-lane curb
and gutter section be extended to the city limits/Locust Drive After discussion of the terminus
for the curb and gutter section, the Town officials concurred that the proposed end of the 3-lane
curb and gutter section at Lawson Lane was sufficient
Town Officials were asked their reasons for requesting that the widening of NC 88 focus
on the north side of NC 88 near the US 221 Business intersection The reason given was to limit
impacts to the business in the southwest quadrant of the intersection When advised that further
shifts north could not be accommodated because of increased impacts to a stream, wetland and
Section 4(f) property, they concurred on current alignment
16
D. Project Coordination
1. NEPA 404 Merger Coordination
At the time the EA was completed, Concurrence Points 1, 2 and 2A (CP1, 2 and 2A) had
been approved and signed Since the signing of CP 2A, NCDOT developed an additional
alternative, Build Alternative 4 (also called the safety improvement alternative and Design
Option 10 in the EA) Build Alternative 4 was developed by NCDOT when it was determined
that capacity improvements were not specifically warranted for the more rural portion of the
project study area and includes the following
• Realignment of the intersection of NC 88 and NC 194
• Realignment of the S-curve between Locust Grove Drive and Lawson Lane
• Center turn lane between Lawson Lane and US 221 Business
• Upgrading the facility to current standards with 12-foot lanes
• Pedestrian crossing for McFarland Publishing Company
• Resurfacing the entire length of the project
The Merger Process Team met on April 22, 2008 to discuss three Concurrence Points
• CP 2A Revised - Additional Alternative to Carry Forward
• CP 3 - Least Environmentally Damaging Practical Alternative (LEDPA)
• CP 4A - Avoidance and Minimization on the LEDPA
CP 2A was revisited to formally introduce Build Alternative 4 to the merger team as
NCDOT's recommended alterative Concurrence was reached by the merger team that Build
Alternate 4 should be carried forward (CP 2A Revised) and it was selected as the LEDPA (CP
3) The team also concurred that avoidance and minimization had been achieved on the LEDPA
(CP 4A) All three concurrence points were signed at this meeting (see Appendix 4 for signed
concurrence forms)
As mentioned in part VI C above, the High Country RPO introduced comments from the
Town of Jefferson Based on these comments, a separate meeting between NCDOT personnel
and the Town of Jefferson was held on May 14, 2008 to resolve this and other outstanding
issues These issues are discussed in following parts of this document VI C above, part VII A
part VII B
VII. REVISIONS TO THE ENVIRONMENTAL ASSESSMENT
A. Sidewalks
At the time the EA was completed, the Town of Jefferson was still developing a Pedestrian
Plan that included recommendations for a sidewalk on one side of NC 88 within the town limits
A project commitment was included in the EA that NCDOT would continue to coordinate with
the Town of Jefferson regarding their plan and sidewalk Differences between a sidewalk
request submitted at the April Merger Meeting (see part VI C) by the local RPO and a finalized
17
letter from the Town dated May 1, 2008 (see Appendix 3) were resolved at the May 14, 2008
meeting (see part VI C) The final resolution for the sidewalks from this meeting was that the
sidewalks would be installed on the south side of NC 88 from the intersection of North Main
Street to the Town limits and ending at the 3-lane curb and gutter section at Lawson Lane The
Town also requested that the north side of NC 88 provide an adequate road shoulder and
driveway curb cut that will accommodate a sidewalk when installed in the future NCDOT
agreed to these resolutions and funding for the sidewalks would be in accordance with the
NCDOT Pedestrian Policy Guidelines Final terms and conditions for sidewalk installation on
the project will be finalized in a municipal agreement between NCDOT and the Town of
Jefferson prior to project construction
B. Pedestrian Crossing at McFarland Publishing
In the EA, a pedestrian crossing at McFarland Publishing was included as part of the
improvements for NCDOT's recommended alternate, Build Alternate 4 A project commitment
was also included in the EA that NCDOT would study the type of pedestrian access needed at
the site In the Town of Jefferson's letter dated May 1, 2008 requesting sidewalks, the Town
also requested the installation of signage at McFarland Publishing on NC 88 to provide a safer
pedestrian crossing Delays in the study and differences between Division 11 and the Bike and
Pedestrian Division on the specifics of the pedestrian crossing, led to this issue being addressed
at the May 14, 2008 meeting The final resolution for this issue (which was agreed upon by Bike
and Pedestrian Division, Division 11, and the Town of Jefferson) was as follows
• The speed limit would be lowered from 45 to 35 mph
• A triangular pedestrian crossing sign would be installed on the westbound side of NC 88
(the eastbound side did not warrant a sign because of the reduced speed from steep grade
and long sight distance )
• No crosswalk markings would be installed
• No further studies or pedestrian counts were required at this time
• The Division would implement these changes within the next couple of months and
would continue to monitor the situation
C. Updated Indirect and Cumulative Effects (ICE)
The NC Wildlife Resources Commission commented that the ICE portion of the EA stated
very little on how the proposed project would impact the natural environment and needed to be
addressed in the FONSI An update of the ICE analysis was completed in May 2008 to address
the indirect and cumulative effects this project would have on the natural environment A
summary of the findings and conclusions of this update are given below (see Appendix 5 for the
full report)
Indirect Effects
There are some upward growth trends, primarily in the form of second home development
and a limited amount of increased industrial development in Jefferson which are encouraged by a
lenient public policy environment There is a moderate supply of developable land adjacent to
the project, but terrain serves as a constraint in this mountainous community A 303(d) listed
18
impaired Trout stream, Little Buffalo Creek, is adjacent to the project Job growth is forecast to
be moderate However, population growth is forecast to be quite low Most importantly, the
limited scope of this project which is primarily restricted to existing location, and very limited
travel time savings, will greatly inhibit change in land use effects associated with this project
Therefore, indirect effects will be very minor such that the threat to downstream water quality
will be very limited
Cumulative Effects
Cumulatively, direct project impacts associated with this project are being avoided,
minimized, or mitigated, consistent with programmatic agreements with natural resource and
permitting agencies Indirect effects in the form of change in land use, or new growth, will be
very minimal Therefore, cumulative effects associated with this project will be very low
D. Cultural Resources
1. Historic Architecture: Final Section 4f Evaluation
A Draft Section 4(f) Evaluation was included in the EA document for the Joseph Benjamin
Neal Property This evaluation included documentation that the Federal Highway
Administration (FHWA) and State Historic Preservation Office (SHPO) had concurred on a call
of "No Adverse Effect" for Build Alternate 4 A Final Section 4(f) Evaluation was to be
prepared and presented after the Draft Section had been circulated and reviewed Copies of this
document were sent out for distribution on September 13, 2007, with a request that all comments
be received by November 2, 2007 All comments have been received and there were no
comments on the Draft Section 4(f) Evaluation
Since it appeared that the Joseph Benjamin Neal Property might qualify for a de mmimis
finding, this project was added to the Assessment of Effects Meeting held on July 21, 2008 to
finalize this determination After reviewing impacts to the property by Build Alternate 4
(NCDOT's recommended alternate and LEDPA) at this meeting, the FHWA stated their intent to
make a de minimis finding on this Section 4(f) resource based on SHPO's concurrence on a "No
Adverse Effect" determination See FHWA comment on signed Concurrence Form for
Assessment of Effects in Appendix 6
E. Environmental Effects
1. Federally Protected Species
In the EA, Swamp pink (Helonias bullata) and Virginia spiraea (Spiraea virginaana) were
the only federally protected species identified with potential habitat within the project area The
survey for Swamp pink had a biological conclusion of No Effect and is still valid, while the
survey for the Virginia spiraea has expired The project was re-surveyed for Virginia spiraea on
May 15, 2008 The updated report for that survey had a biological conclusion of No Effect, but
Habitat Present A copy of this updated survey is in Appendix 7
2. Permits
Impacts to jurisdictional surface waters are anticipated from the proposed project As a
result, construction activities will require permits and certifications from various regulatory
19
agencies in charge of protecting the water quality of public water resources In accordance with
Section 404 of the Clean Water Act (33 U S C 1344), it is anticipated an Individual Permit
according to CFR 330 5(A) will be required from the US Army Corps of Engineers
Due to various changes and delays in the project, the five-year U S Army Corps of
Engineers (USACE) Jurisdictional Verification has expired (in September 2007) The USACE
re-verified the jurisdictional delineations associated with this project on May 13, 2008 and the
verification is valid for another 5 years The stream impact quantities presented here are
preliminary and the final permit drawings will determine final impacts
3 Hazardous Material (Underground Storage Tank [UST] Facilities)
In the EA, UST Site 3 - Carolina Printing Supply (see Figure 3 Sheet 3 of 3) was included
as one of the sites that the GeoEnvironmental Section of the Geotechmcal Engineering Unit
would need to investigate in the Project Commitments NCDOT's recommended alternate
(Build Alternate 4) does not impact the property Since this site will not be impacted, it has been
removed from the Project Commitments and is not included in Table 1 Summary of Impacts for
Build Alternate 4
Through a conversation with property owner Talmadge S Shepherd at the Combined
Public Hearing, it was discovered that a previously unknown site that operated USTs is located
on the project Mr Shepherd stated that a gas station formerly operated at the property he owns
at 1586 Highway NC 88 West in West Jefferson The property owner did not know if the USTs
were still in place or had been removed This property is located on the east side of NC 88-194,
approximately 200 feet north of the existing NC 88 and NC 194 intersection The site is
currently a residence and church (see UST Site 5 - Maranatha Church on Figure 3, Sheet 1 of 3)
Additional right of way was to be acquired at this site Based on a recommendation from
Division 11 Right of Way, Roadway Design has eliminated this additional right of way at the
property Since NCDOT's recommended alternate (Build Alternate 4) will no longer impact this
site, it was not included in the Project Commitments for the for the GeoEnvironmental Section to
conduct a site assessment on nor was it included in Table 1 - Summary of Impacts for Build
Alternate 4
F. Updated Highway Traffic Noise Analysis and Air Quality Analysis
The EA document contained a project commitment that the Noise and Air Quality Group
would conduct and updated Traffic Noise Analysis (using TNM 2 5) after the "Date of Public
Knowledge" as defined in the NCDOT Traffic Noise Abatement Policy Both the Traffic Noise
Analysis and Air Analysis reports were updated in May of 2008 The Noise Analysis report was
performed utilizing the FHWA traffic Noise Model software (TNM 2 5) to predict future noise
levels and impacted receptors for NCDOT's recommended alternative, Build Alternate 4 A
summary of the findings of these reports are provided in part VII F of this document, while the
full reports are in Appendix 8
20
Hijihway Traffic Noise
Introduction
In accordance with Title 23 Code of Federal Regulations Part 772, Procedures for Abatement
of Highway Traffic Noise and Construction Noise (Title 23 CFR 772), each Type I highway
project must be analyzed for predicted traffic noise impacts Type I projects are proposed
Federal or Federal-aid highway projects for construction of a highway on new location or
improvements of an existing highway which significantly changes the horizontal or vertical
alignment or increases the vehicle capacity Traffic noise impacts are determined from the
current procedures for the abatement of highway traffic noise and construction noise found in
Title 23 CFR 772, which also includes provisions for traffic noise abatement measures
When traffic noise impacts are predicted, examination and evaluation of alternative noise
abatement measures must be considered for reducing or eliminating these impacts A copy
of the unabridged version of the full technical report entitled Traffic Noise Analysis - NC 88
from NC 194 to US 221 Business can be viewed in Room 464, the Transportation Building, 1
South Wilmington Street, Raleigh
Traffic Noise Impacts and Noise Contours
The maximum number of receptors in each project alternative predicted to become impacted
by future traffic noise is shown in the table below The table includes those receptors
expected to experience traffic noise impacts by either approaching or exceeding the FHWA
Noise Abatement Criteria or by a substantial increase in exterior noise levels
Predicted Traffic Noise Impacts by Segment*
Traffic Noise Impacts
BUILD Residential Churches/Schools Businesses Total
NC 88 from
NC 194 to 5 0 0 5
Lawson Lane
NC 88 from
Lawson Lane to 1 0 1 2
US 221 Bus
NO BUILD Residential Churches/Schools Businesses Total
NC 88 from
NC 194 to 7 0 0 7
Lawson Lane
NC 88 from
Lawson Lane to 8 0 0 8
US 221Bus
*Per TNM®2 5 and in accordance with 23 CFR Part 772
The maximum extent of the 72- and 67- dBA noise level contours measured from the center
of the proposed roadway is less than forty-three (<43) feet and fifty-four (54) feet,
21
respectively Both of these maximum noise level contour distances occur along the NC 88
Build Alternative
Traffic Noise Abatement Measures
Measures for reducing or eliminating the traffic noise impacts were considered for all
impacted receptors in each alternative The primary noise abatement measures evaluated for
highway projects include highway alignment changes, traffic system management measures,
buffer acquisition and noise barriers For each of these measures, benefits versus costs,
engineering feasibility, effectiveness and practicability, land use issues, and other factors
were included in the noise abatement considerations
Substantially changing the highway alignment to minimize noise impacts is not considered a
viable option for this project due to engineering and/or environmental factors Traffic system
management measures are not considered viable for noise abatement due to the negative
impact they would have on the capacity and level of service of the proposed roadway Costs
to acquire buffer zones for impacted receptors will exceed the NCDOT abatement threshold
of $35,000 per benefited receptor, causing this abatement measure to be unreasonable
Noise Barriers
Noise barriers include three basic types vegetative barriers, earthen berms and noise walls
These structures act to diffract, absorb and reflect highway traffic noise For this project, the
cost of acquiring additional right of way and planting sufficient vegetation is estimated to
exceed the NCDOT abatement threshold of $35,000 per benefited receptor Also, for this
project, earthen berms are not found to be a viable abatement measure because the additional
right of way, materials and construction costs are estimated to exceed the NCDOT abatement
threshold of $35,000 per benefited receptor
This project will maintain uncontrolled or limited control right of way access, meaning that
most commercial establishments and residences will have direct access connections to the
proposed project, and all intersections will adjoin the project at grade Businesses, churches
and other related establishments require accessibility and high visibility Noise barriers do
not allow uncontrolled access, easy accessibility or high visibility, and would therefore not
be acceptable abatement measures for this project Based on the Traffic Noise Analysis,
traffic noise abatement is not recommended for this project because no impacted noise
receptors meet the reasonable and feasible criteria in the NCDOT Traffic Noise Abatement
Policy
Summary
Based on this preliminary study, traffic noise abatement is not recommended and no noise
abatement measures are proposed This evaluation completes the highway traffic noise
requirements of Title 23 CFR Part 772 No additional noise analysis will be performed for
22
this project unless warranted by a significant change in the project scope, vehicle capacity or
alignment
In accordance with NCDOT Traffic Noise Abatement Policy, the Federal/State governments
are not responsible for providing noise abatement measures for new development for which
building permits are issued after the Date of Public Knowledge The Date of Public
Knowledge of the proposed highway project will be the approval date of the Finding of No
Significant Impact (FONSI) For development occurring after this date, local governing
bodies are responsible to insure that noise compatible designs are utilized along the proposed
facility
Air Quality Analysis
Vehicles are a mayor contributor to decreased air quality because they emit a variety of
pollutants into the air Changing traffic patterns are a primary concern when determining the
impact of a new highway facility or the improvement of an existing highway facility New
highways or the widening of existing highways increase localized levels of vehicle
emissions, but these increases could be offset due to increases in speeds from reductions in
congestion and because vehicle emissions will decrease in areas where traffic shifts to the
new roadway Significant progress has been made in reducing criteria pollutant emissions
from motor vehicles and improving air quality, even as vehicle travel has increased rapidly
A copy of the unabridged version of the full air quality technical report entitled Aar Quality
Analysis - NC 88 from NC 194 to US 221 Business can be viewed in Room 464, the
Transportation Building, 1 South Wilmington Street, Raleigh
Recently, concerns for air toxics impacts are more frequent on transportation projects during
the NEPA process Transportation agencies are increasingly expected by the public and
other agencies to address MSAT impacts in their environmental documents as the science
emerges Mobile Source Air Toxics (MSATs) analysis is a continuing area of research
where, while much work has been done to assess the overall health risk of air toxics, many
questions remain unanswered In particular, the tools and techniques for assessing project-
specific health impacts from MSATs are limited These limitations impede FHWA's ability
to evaluate how mobile source health risks should factor into project-level decision-making
under the National Environmental Policy Act (NEPA) Also, EPA has not established
regulatory concentration targets for the six relevant MSAT pollutants appropriate for use in
the project development process FHWA has several research projects underway to more
clearly define potential risks from MSAT emissions associated with transportation projects
While this research is ongoing, FHWA requires each NEPA document to qualitatively
address MSATs and their relationship to the specific highway project through a tiered
approach 1 The FHWA will continue to monitor the developing research in this emerging
field A qualitative analysis of MSATs for this project appears in its entirety in the project
Air Quality Analysis report
The project is located in Ashe County, which has been determined to comply with the
National Ambient Au Quality Standards The proposed project is located in an attainment
23
area, therefore, 40 CFR Parts 51 and 93 are not applicable This project is not anticipated to
create any adverse effects on the air quality of this attainment area
US DOT, Federal Highway Administration memorandum, "Interim Guidance on Air
Toxic Analysis in NEPA Documents", February 3, 2006
VIII. BASIS FOR FINDING OF NO SIGNIFICANT IMPACT
Based upon a study of the proposed project documented in the Environmental Assessment
and upon comments received from federal, state and local agencies and the public, it is the
finding of the North Carolina Department of Transportation and the Federal Highway
Administration that this project will not have a significant adverse impact upon the human or
natural environment The project is not controversial from an environmental standpoint No
significant impacts to natural, ecological, cultural, or scenic resources are expected The
proposed project is consistent with local plans and will not disrupt any communities In view
of the above evaluation, it has been determined a Finding of No Significant Impact is
applicable for this project Therefore, neither an Environmental Impact Statement nor further
environmental analysis will be required
24
FIGURES
Figure 1 - Vicinity Map
Figure 2 - Project Location Map
Figure 3 - Preferred Alternate Map (Sheet 1 of 3)
Figure 3 - Preferred Alternate Map (Sheet 2 of 3)
Figure 3 - Preferred Alternate Map (Sheet 3 of 3)
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APPENDIX 1
Combined Public Hearing Notice and
Handout
NOTICE OF A PUBLIC HEARING
FOR THE PROPOSED WIDENING OF NC 88
FROM NC 194 TO US 221 BUSINESS IN JEFFERSON
TIP Project No U-3812
Ashe County
The North Carolina Department of Transportation (NCDOT) will hold the
above Design Public Hearing on November 29, 2007 between the hours of 4 00
p m and 7 00 p m at the Ashe County High School Cafeteria, 184 Campus
Drive, West Jefferson, 28694 Interested individuals may attend at their
convenience during the above stated hours Please note there will be no formal
presentation
NCDOT proposes to improve safety on NC 88 and improve a link between
NC 194 and the Town of Jefferson There will be four alternatives presented
during the hearing The project calls for correcting a restricted roadway with poor
horizontal and vertical alignment The project is about 1 6 miles in length
The purpose of this workshop is for NCDOT representatives to provide
information, answer questions, and accept written comments regarding the
location and design of this project Preliminary designs for these alternatives will
be presented at the hearing for public comments Additional right of way and the
relocation of homes and businesses will be required for this project
A map setting forth the design of the project and a copy of the
environmental document - Environmental Assessment (EA) and Draft Section
4(f) Evaluation - are available for public review at the Town of Jefferson, 302
East Main Street, Jefferson, 28640, and the NCDOT County Maintenance Office,
296 Buffalo Road, West Jefferson, 28694
Anyone desiring additional information may contact Ms Kimberly Hinton,
Human Environment Unit, 1583 Mail Service Center, Raleigh, NC 27699-1583,
phone [phone], fax [phone] or email khinton@dot state nc us
NCDOT will provide auxiliary aids and services under the Americans with
Disabilities Act for disabled persons who wish to participate in this hearing
Anyone requiring special services should contact Ms Hinton as early as possible
so that arrangements can be made
rLOt µo TH
X NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
o Z
"OF S4?.?cfD?
NC 88
From NC 194 to US 221 Business in Jefferson
TIP PROJECT U-3812
WBS Element 34977 1 1
Ashe County
Design Public Hearing
Ashe County High School Cafeteria
184 Campus Drive, West Jefferson, 28694
400 PMto700PM
November 29, 2007
PURPOSE OF PROJECT
The purpose of this project is to improve safety and improve a link between NC
194 and the existing multilane section in the Town of Jefferson The need is based
upon correcting poor roadway conditions and poor horizontal and vertical alignment
There are four Build Alternatives proposed for this project
NC 88 is a vital part of the 2002 Jefferson-West Jefferson Transportation Plan
NC 88 is noted as a major thoroughfare and is recommended for widening to improve
safety and increase traffic carrying ability It is a connecting link between NC 194 and
the Town of Jefferson
PURPOSE OF PUBLIC HEARING
Today's hearing is one step in the Department of Transportation's procedure for
making the public a part of the project development process The North Carolina
Department of Transportation (NCDOT) is soliciting your views on the location and
design of the proposed construction
NCDOT's planning and environmental studies on the above project are
presented in the environmental document - Environmental Assessment (EA) and Draft
Section 4(f) Evaluation For the last 30 days, copies of this report and today's hearing
map have been available for public review at the Town of Jefferson, 302 East Main
Street, Jefferson, 28640, and the NCDOT County Maintenance Office, 296 Buffalo
Road, West Jefferson, 28694
YOUR PARTICIPATION
You are encouraged to participate by voicing your comments Several
representatives of the North Carolina Department of Transportation are present They
will be happy to talk with you, explain the design to you and answer your questions
You may write your comments or questions on the comment sheet and leave it with one
of the representatives or mail them by December 17, 2007
Please note there will be no formal presentation
Those wishing to submit written material may do so to
Ms Kimberly D Hinton, Senior Public Involvement Officer
NCDOT - Human Environment Unit
1583 Mail Service Center, Raleigh, NC 27699-1583
PHONE [phone] FAX [phone]
Email khinton(cDdot state nc us
for the review and approval of the previously mentioned activities to ensure that each
Federal Aid Project is designed, constructed and maintained to Federal Aid Standards
NEED FOR THE PROJECT
NC 88 has substandard roadway width with sharp curves, inadequate sight
distance and poor horizontal and vertical alignment NC 88 is a narrow undivided
highway It has overhanging trees, roadside vegetation, sight obstructions, skewed
approaches into NC 194 and mountainous topography NCDOT is proposing to widen
and reduce the roadway curvature to reduce the potential for rear-end, angle, and left-
turn collisions that make up 76% of the crashes from 2004 to 2007
PROJECT DESCRIPTION
The NCDOT, Division of Highways, proposes to improve NC 881n Ashe County
from NC 194 to US 221 Business in the Town of Jefferson (See Figure) The proposed
project will widen and upgrade the 1 6-mile, two-lane roadway to current standards with
12-foot lanes Project calls for realigning NC 88 & NC 194 and the S-curve between
Locust Grove Drive and Lawson Lane, resurfacing the entire project, and the Town of
Jefferson is recommending sidewalks in its Pedestrian plan currently underway
There are four proposed Build Alternatives for this project They are described
below
• Build Alternative #1 - Three (3) lane shoulder section along the entire project
• Build Alternative #2 - Three (3) lane shoulder section in the rural portion &
Three (3) lane curb and gutter section in the Urban Portion
• Build Alternative #3 - Three (3) lane shoulder section in the rural portion &
Five (5) lane curb and gutter section in the Urban Portion
• Build Alternative #4 - Safety Improvements - NCDOT Recommended with a
Three (3) lane curb and gutter section in the Urban Portion
Urban Portion = NC 194 to Lawson Lane
Rural Portion = Lawson Lane to US 221 Business
Table Summa of Impacts
Category Units Alt I Alt 2 Alt 3 Alt 4
Project Length Miles 1 6 1 6 1 6 1 6
Residential Relocations Total 14 24 29 1
Business Relocations Total 4 4 6 1
Farm Relocations Total 0 0 0 0
Non-Profit Relocations Total 1 1 1 0
Minority Relocations Total 2 2 4 0
Total Relocations Total 19 29 36 2
Hazardous Material (UST) Sites Each 4 4 4 2
Wetlands Acres 02 02 02 0 1
Streams Linear Feet 2035 2070 2115 920
Ponds Acres 0 02 0 02 0 02 <001
Federally - Protected Species Species 0 0 0 0
Maintained /
Disturbed 250 244 256 101
Terrestrial Communities Montane Oak /
Hickory Forest 80 81 84 1 9
Christmas Tree
Plantation 26 26 26 0
Prime Farmlands Each 0 0 0 0
23CFR772 Noise Category B Impacted Receptors 18 18 21 18
Substantial Noise Level Increase > 10 dB Impacted Receptors 0 0 0 0
Air Quality
Carbon Monoxide Concentration NAAQS Standard (2) 71 7 1 71 7 t
Architectural Resources Eligible Properties 1 1 1 1
Section 4(f) Resources Acres 1 0 08 1 1 04
Archaeological Resources Eligible Properties 0 0 0 0
Construction Cost Million Dollars $ 9 1 $91 $ 100 $39
Right of Way Cost Million Dollars $ 100 $ 109 $ 11 8 $46
Total Project Cost Million Dollars $ 19 1 $200 $218 $85
NOTES
1 Noise Activity Category B exterior, equivalent sound level of approximately 67 dBA
2 National Ambient Air Quality Standards maximum CO permitted for 1-hr Ave = 35 ppm
I
I
B 76 8
1
4 12 12 12 4
FDPS a FDPS
tr
RAD
POINT
08 02 02 08
EXISTING E X?SEC11pj4 I - - - - - - - - - I 6 i 1 T
GROUND SE r 24 EXISTING PAVEMENT
GRADE TO THIS LINE 11 W?GR
(Alternate 1)
(Alternate 2 - Rural Portion) (Alternate 3 - Rural Portion)
(Alternate 4 - Rural Portion)
EXISTING
GROUND
I
I
40 FACE to FACE
9 12 12 12 8 '
1 # 1
I DINT SEE X"SEC
02 02 _
24 EXISTING PAVEMENT
.
14 W
17 TO THIS LINE
(Alternate 2 - Urban Portion)
EXISTING
1 GROUND
e
EXISTING
GROUND
I
I
64 FACE I. FACE
12 12 12 12 12 8 '
1 1 0 1 1
O Ni SEE y,,S
02 02
r 24 EXISTING PAVEMENT
GRADE TO THIS LINE 14 Wdh Guardmd
(Alternate 3 - Urban Portion)
40 FACE to FACE
I
VAR 6 VAR 11 TO 12 VAR 11 TO 12 VAR 11 TO 12' VAR' 6'
TO 8 Ll TO 8
I GRADE
POINT
02 02
EXISTING EE x'SEG?ION - - - - - ?- - - - - -
GROUND S -
22 TO 24 EXISTING PAVEMENT
GRADE TO THIS LINE
(Alternate 4 - Urban Portion)
EXISTING
GROUND
EXISTING
GROUND
SEE X/SEG10N
COMMENT SHEET
NC 88
NC194 to US 221 Business in Jefferson
Design Public Hearing - November 29, 2007
TIP Project U-3812
NAME
ADDRESS
Ashe County
COMMENTS AND/OR QUESTIONS.
Comments may be mailed by December 17, 2007
Kimberly D Hinton, Senior Public Involvement Officer
Human Environment Unit
N C Department Of Transportation
1583 Mail Service Center
Raleigh, NC 27699-1583
Telephone [phone]
FAX [phone]
email khinton@dot state nc us
APPENDIX 2
Post Hearing Minutes

MICHAEL F EASLEY
Govt RNoR
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MEMO TO FILE (U-3812)
FROM Jay A Bennett, P J
State Roadway D sign n ineer
DATE January 31, 2008
SUBJECT Project No 34977 1 1, Tip No U-3812
F A Project No STP-88(2) Ashe County - Division 11
Widening of NC 88 from NC 194 to US 221 Business
Post Hearing Meeting Minutes
DECEIVED
Division of Hiqhways
FEB 0 4 1008
?- v nob cbon
prole Development and
iEnvimnmentol Ana ;;CC Branch
LYNDOI1PPr"S
SFC RI I ml
The Combined Public Hearing for U-3812, NC 88 from NC 194 to US 221 Business
was held on November 29, 2007 at the Ashe County High School in Jefferson
Approximately 41 citizens and town officials attended the hearing The following
DOT employees were present for the post hearing meeting held on January 25,
2008 and discussed the impacts from the citizens comments
Art McMillan, NCDOT, Highway Design Branch
Jay A Bennett, NCDOT, Roadway Design `
Dewayne Sykes, NCDOT, Roadway Design
Jimmy Goodnight, NCDOT, Roadway Design
Steve Kendall, NCDOT, Roadway Design
Thomas Burns, NCDOT, Roadway Design
Sara Meadows, NCDOT, Roadway Design
Linwood Stone, NCDOT, PD&EA
Jamille Robbins, NCDOT, PD&EA
Gene Tarasico, NCDOT, Project Development
Cathryn P Harris, NCDOT, Right of Way
Executive Summary
The NCDOT prefers Build Alternate #4 as shown at the public hearing This
alternate impacts fewer property owners both residences and businesses, causes
less disruption to the community, impacts fewer jurisdictional areas, has the least
impact to the 4F Property, Joseph Neal House, and is the most economical
alternative This alternate will operate at LOS D in the design year
U-3812 Post Hearing Meeting Minutes
Page 2
January 31, 2008
Build alternate #4 includes the following recommendations to NC 88
Realign the skewed intersection of NC 88 and NC 194
o Improve the NC 88/US 221 Business intersection sight distance and radii
® Realign the curves between Locust Grove Drive and Lawson Lane
Add a center turn lane between Lawson Lane and US 221 Business
Provide 12' lanes
® Provide a pedestrian crossing for McFarland Publishing Company
Resurface the enure length of the project
The majority of the citizens in attendance, including the Town prefer Budd Alternate 4
Summary of written comments received during and after the Public Hearing are as
follows
1 Comment One (1) written comment from Lonnie and Mary Jones They prefer
Budd Alternative #4 because of the proposed curb and gutter
Actron Comment noted
2 Comment One (1) written comment each from Toy Campbell and Jim Payne
They prefer Budd Alternative #4 because it has fewer relocatees
Action Comment noted
3 Comment Five (5) written comments from E T Weaver He prefers Budd
Alternative #1, 2 or 3 Other comments are as follows
® Road improvements and more parking would stimulate local economy
and attract new industry
The sight distance at the intersection of NC 88 and US 221 Business
needs improvements
The truck turning radius at NC 88 and US 221 Business does not
allow for large trucks (logging) to turn the corner without crossing into
the on-coming lane forcing traffic to either back up or stop while the
trucks turns
® Traffic is congested and creates safety hazards during manufacturing
plant shift changes
® Flooding occurs during large storms at the intersection of NC 88 and
US 221 Business
Action The sight distance and turning radii at the NC 88 and US 221 Business
intersection will be reviewed during the final design The Hydraulics Unit will be
made aware of Mr Weaver's concerns about the flooding in the area
4 Comment Three (3) written comments from Charles King His comments are
as follows
U-3812 Post Hearing Meeting Minutes
Page 3
January 31, 2008
© Start the protect at the traffic light in Jefferson Do not go east of the
light to relocate business, homes, and parking
® Build Alternative #4, but add a climbing lane frorn the Doggett Road
intersection to the crest (Approx Sta 55+00)
® Try to make the most improvements from McNeil Road to the
intersection of NC 88 and NC 194
Action No additional right of way will be acquired east of NC 88/US 221
Business Intersection
According to AASHTO and the protected truck and traffic counts, a climbing
lane should be considered from approximate station 29+00 to approximate
station 55+00 on the eastbound lane Preliminary studies indicate a 25-mph
speed reduction is expected for a typical heavy truck
The estimated additional natural resource impacts are as follows
Perennial streams 130 LF
Intermittent streams 105 LF
Montane oak hickory forest 2 93 AC
Christmas tree farm 0 07 AC
Based on preliminary designs, the construction cost for the climbing lane is
estimated to be an additional $1,500,000 Additional right of way costs were
not estimated, however, 5 to 6 additional relocatees are anticipated
If the climbing lane is added, the merger team must review the plans and the
additional impacts Because of the additional relocatees and natural
environment impacts, Division 11 does not recommend a climbing lane Also,
McFarland Publishing Company has indicated that they would relocate if any
widening is proposed beyond that shown for Budd Alternate 4 Since
preliminary studies indicate the Level of Service (LOS) will not improve
significantly with this climbing lane, Roadway Design is also in agreement that
this lane is not justified
The current schedule is as follows
R/W 10/2009 (TIP R/W 2010)
LET 10/2011 (TIP LET 2012)
If there are any questions or comments concerning these minutes, please contact me
or Jimmy Goodnight, PE at 919-250-4016
JSG/sem
cc Meeting Attendees
Michael Pettyjohn, PE
APPENDIX 3
Town of Jefferson Request
Town of Jefferson
ALDERMEN
L F Anderson, Jr
Charles Caudill
Bluferd Eldreth
Mark Johnston
Max Yates
302 East Main Street
PO Box 67
Jefferson, NC 28640
Phone [phone]
Fax [phone]
Tax ID #i 56-0896625
MAYOR
Dana Tugrnan
TOWN MANAGER
Cathy L Howell
FINANCE OFFICER
Carol E Winebarger
May 1, 2008
Mr Eugene Tarascio, P E, Project Development Engineer
NC Department of Transportation
Project Development and Environmental Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
Mr Tarascio
RE Sidewalk Construction
NC 88 Traffic Improvements
Town of Jefferson
The Town of Jefferson would like to participate with NCDOT for the construction of a
sidewalk in conjunction with NCDOT's effort for the planned roadway improvements along
NC 88 located in Jefferson The Town requests that the sidewalk be constructed on the south
side of NC 88 beginning at the intersection of North Main Street traveling west to the Town
limits and ending at Locust Grove Street The Town also requests that the north side of NC 88
provide an adequate road shoulder and driveway curb cuts that will accommodate a sidewalk
when installed in the future It is my understanding the Town would be required to match 20%
of the actual cost for the construction of the sidewalk In addition the Town would like to
request the installation of signage at McFarland on NC 88 to provide a safer pedestrian
crossing at the existing business
We look forward to working with NCDOT on this project Should you have any
questions, please feel free to call
Sincerely,
&J-?J? ?L "Ji
Cathy L Howell
Town Manager
APPENDIX 4
Signed NEPA Merger Process
Concurrence Forms
SECTION 404 / NEPA MERGER PROCESS CONCURRENCE -WRELMEN F
CONCURRENCE POIN 1 2 1 R-L% 1SLD MM1110N kL 1L 1 LRN % I AL 1 O C AARX 1.ORNIVA RD
NC 88 ImproNement Stud)
From NC 194 to US 221 Business in Jetterson
NCDOT Highm a,* Dv* nsion 11
Ashe Count)
NCDOI I IP Project No U-3812
Federal Project Number S I P-88(2)
State Pi oject No 8.1711501
TIP Description The North Carolina Depamnent of Transportation proposes to widt-n appnoxundtel,, 1 6 mules of
NC 88 to a multi-lane facllrty from \C 194 to LS 221 Business to the To Aii of Jetlerson in Ashe Count}
Additional Altername to Carry ForAard I he Merger Process I cam tact an April 22 2008 to dis,.usi a new altem ti\ e to
carry forward Design Option 111 (Build 'tcrnate 4 in the. C ? document) formal prescntahon of thts new alternate to the
Merger Pioces, Train was required, because it was de\clopcd after concurrence at the original '_A meeting Build A ternate
4 w as added after further studies of the other alternate,, indicated that 't appeared to address the purpou and need for the
p*olect while substantiall-. reducing the impacts to the human and gatural en\tmnnients
The Team concurred that the followutR altematiNe should be carried ton\ard in this proposed action
Build k1ternate a (Design Option 10). %lilelt includes the following nmprurements to NC 88
• Realignment of the intersection of NC 88 and NC 194
• Realignment of the S-curie between I ocuet Oro%e Drne and t awson 1 sine
• Centel turn lane between 1 awson Lane and L S 221 Business
• Ung idm, the ficiht} to current stand irds with 1'-foot lams
• Pedestrian crossing for MLF at land PLibhsh1112 Compan\
• RcsurfdLing the c.ntuc. length of the project
tI- S ACE
-- -- -\It,ntL K 'i mhe , U, tc
Chn•tup4r Mttttu.htr Date
1 l
\tar(t I?C h t t b_ fit,
i=? iern? Tit t?uu C!„?
t-SFtikS /Y/"Os
tt IR?iB (3llCl?ll D?t?
NCDVvQ
I) n to 1 1? atm? -t?iht Da,r
\CDC
SECTION 403 / NEP k MERGER PROC ESS CONCLRRFNCE kGREENIF.NT
CONCURRENCE POINT 3 LF 1ST ErX IRONNIIATAJ DAMAGING PRSC 11C WLF, ALTERN MN E
(LFDPa)
NC 88 Improvement Studl
From NC 194 to US 221 Business ui Jettetson
NCDOT Highway Division 11
Ashe County
NCDOT TIP Project No L'-3812
Federal Project Numbet STP-88(2)
State Project No 8 1711501
7 IP Desct tptton 1hL North Carolina Department of Transportation propose, to tN IdLn approNinwtLly 1 6 mill, of
M 8K tc a nrtilu-lanL fa..tlity from NC 194 to US 221 T3ucnte:, 111 thL FU\tn of J1,t1cn0n ut A.hL C oUn(V
Least Ln%tronmenta11) Damaging Practical Utentatne (LL DP 1) 1 hL tiILILL r Prue„ Team met on April 22 2008 to
,e1LLt a LFDP X front the tour build alternate, pre,ented in the utLruer pacl,Lt 1 he FLdtn U011LtIRLCf it] at the toIlouln? build
ahernam e I, the I 1-DPA
Build kiternate a (Design Option ill) «hich Include, OIL lollo,.Niniv impromement, to NC 88
• RLallgnntent of tilt: Inter,ection of NC SS and NC 194
• RLalignmcnt of the S-cui\e betr\,Len f ocuct (rrm. e I)rn,- a,id l t,on I arL
• Center turn lane IDLteNeen t att con 1 tile and tA 221 131.1,111L,,,
• Upending, the faLtlltX to Lunent swridards m ith 12-foot late,
• PLdL,tnan cio,sung for MJ,i land Publishing C omp.n ,
• R,,uifacittg the enure length tit th(. prolLLt
DACE
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SECTION 404 ! INFPA VERGER PROCESS CONCURRENCE A(,REELv.tE-1%1-g,
CONC t RRLNCI' POM -IA XN OiD-kNTCE aVD iNIIN1Ml -kTION
NC 88 Improvenient Stud3
From NC 194 to US 231 Business to Jefferson
NC DOT Highway Division I1
-she County
NC DOT TIP Project No L-3812
Federal Project Number STP-88(2)
State Project No . 8 1711501
TIP Desci tptton The \vrtli C amhna Denartment of I ransportanon propose, n, tctdcn apptovnnateIN 1 n miles of
\C. 83 to a multi-lane factitt} from NC. 193 to US 221 13u,tnL„ in the I own of Ieffenon to a,he Countv
ANoidance and MLntnueatton The Merger Prvee,. Team met on %prtl'_2 2004 and concurlLd on the V oidaneL and
Minimization for the Least Fnuronmentally Damaging Practlcabie Uternat]'VL Awtdantc, and Minimization area, are
de,crtbed to the mer_cr packet and in the ,tttnutec of the meeting ( oncurrence I'outt -l \ of the Sc. aon 404 NEP \ ate r
process has been fitllilled `
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APPENDIX 5
Updated Indirect and Cumulative
Effects Report
To Gene Tarascio, PE, PDEA
From: Steve Gurganus, AICP, HEU
Re Memo update of ICE analysis for U-3812 Ashe
Date: 21 May 2008
Executive Summary
This memo is an update of the Indirect and Cumulative Effects analysis for U-
3812 Ashe which was previously submitted as part of the Community Impact
Assessment prepared by Parsons Bnnckerhoff for the project in May 2002
It will evaluate the scope of the project, change in accessibility, population and
growth trends, water and sewer service, public policy, development regulations,
market conditions and notable natural environmental features
In summary, the scope of this project is limited mostly to existing location with a
purpose and need relating to safety improvements and system linkage There
will be no change in accessibility, and no access to areas that do not have
existing access Travel time savings will be minimal
While retirement and second home development is increasing in Ashe County,
forecasted population growth is very low and forecasted fob growth is low to
moderate
The area dust northwest of downtown Jefferson is identified as an area for
industrial growth by Jefferson officials, but that area is already easily accessed
via Northwest Drive, off of NC 88 Land supply is relatively abundant, but the
mountainous terrain would constrain large scale projects outside of this area to
some extent Water and sewer availability is available along NC 88 west of
Jefferson to McFarland Publishing, as well as in the Town of West Jefferson,
slightly less than one mile south of NC 88 and accessible via NC 94 and also
Doggett Road The West Jefferson wastewater treatment facility is located on
Clearwater Drive off of Doggett Road south of the project
The overall market for development is moderate, mostly represented by
increased second home and retirement developments Other recent growth
includes stores and services associated with home construction and
improvement The preferred alternative will greatly limit relocations, nonetheless
market pressures are not sufficient to result in wholesale redevelopment, whether
commercially or residentially, along the NC 88 corridor in the foreseeable future
Public policy is less stringent in general, with an absence of land use or
comprehensive plans in Jefferson or West Jefferson West Jefferson reported
that the town had initiated a process to develop a land use plan, but the draft is in
the preliminary stages
Notable natural features in the area include the 303(d) impaired stream listing for
Little Buffalo Creek and the popular Mount Jefferson State Park
Findings & Conclusions
Indirect Effects
In conclusion, there are some upward growth trends in the ICE study area for U-
3812, primarily in the form of second home development and a limited amount of
increased industrial development in Jefferson Jefferson and West Jefferson
encourage new development due to recent plant closings and job losses with a
lenient public policy environment There is a moderate supply of developable
land adjacent to the project, but terrain serves as a constraint in this mountainous
community A 303(d) listed impaired Trout stream is adjacent to the project Job
growth is forecast to be moderate However, population growth is forecast to be
quite low Most importantly, the limited scope of this project which is primarily
restricted to existing location, and very limited travel time savings, will greatly
inhibit change in land use effects associated with this project Therefore, indirect
effects will be very minor such that the threat to downstream water quality will be
minimal
Cumulative Effects
Cumulatively, direct project impacts associated with this project are being
avoided, minimized, or mitigated, consistent with programmatic agreements with
natural resource and permitting agencies Indirect effects in the form of change
in land use or new growth will be minimal Therefore, cumulative effects
associated with this project will be very low
Indirect & Cumulative Effects Analysis & Update
Project Scope
The project will widen approximately 1 6 miles of NC 88 from NC 194 to US 221
in the town of Jefferson The widening is limited to adding a shoulder section on
mostly existing location from NC 194 to Lawson Lane just outside of downtown
Jefferson, NC (rural portion), and incorporating a 3-lane curb and gutter section
from Lawson Lane to East Main Street in downtown Jefferson (urban section) At
the request of the Town of Jefferson, NCDOT is currently evaluating extending
the 3-lane section a few hundred feet further away from the center of town The
minor realignment of the intersection of NC 88 and NC 94 will be on new
location, as will be the straightening of an "S" curve on the project,
Purpose & Need
2
The purpose and need of the project is to improve safety on NC 88, and improve
system linkage from NC 194 to the existing multilane section in the Town of
Jefferson
ICE & Demographic Study Area
The ICE & Demographic Study Area (DSA) for this project is comprised of US
Census Tract (CT) 9704, Block Group (BG) 3, and Census Tract 9705, Block
Group 2 CT 9704, BG 3 encompasses the western terminus of the project at
NC 194 south of NC 88, and the eastern half of West Jefferson CT 9705, BG 2
encompasses the area north of NC 88 from NC 194 and east to include the
western half of Jefferson
Other Transportation and Infrastructure Projects in the Area
R-2915 is the only other notable transportation project programmed and
foreseeable in the area R-2915 is the widening of US 221 from US 421 in
Watauga County, to NC 88 in Jefferson The two southern-most sections of the
project from US 421 to north of the South Fork of the New River -- south of West
Jefferson -- are funded for construction starting in 2013 The more northern
sections are unfunded, but environmental studies are underway The funding
and construction of the northern portions are not sufficiently foreseeable to be
considered in this analysis
Neither West Jefferson nor Jefferson appear to have any municipal infrastructure
projects such as water and sewer underway or planned
Time Horizon
The time horizon for the project extends to 2030, based on population projections
for the area by the NC State Data Center at the Office of State Budget and
Management
Transportation Impact Causing Activity
Limited travel time savings of less than one minute is the transportation impact
causing activity for this project A transportation causing activity is the factor
associated with a project that can result in a transportation related indirect effect
in the form of change in land use Travel time savings of less than five minutes
are generally considered much less likely to result in an indirect effect
Population & Housing
US Census ID 1990
population 2000
population Change % Change
CT 9704, BG 3 615 709 94
CT 9705, BG 2 1063 974 -89
rDSA 1678 1683 5 .003%
While US Census data indicates virtually no growth in the more focused study
area for this report as compared to the larger DSA as reported in the 2002 CIA,
3
housing data nonetheless indicated a 15% increase in new dwellings This
anomaly may relate to an increase in seasonal housing but could not be
confirmed by local planners
The county population for Ashe increased by 3569 persons between 1990 and
July, 2006, for a growth rate of 1 % -- compared to a growth rate for the state of
North Carolina of 21 3% The county is projected to grow from 25,778 in July
2006 to 29,684 in July 2029, for a total of 5,207 persons, for a growth rate of
08%
Economic Growth Trends
North Carolina Comprehensive Economic Data (CEDs) studies indicate fob
growth forecast at 1 6% for the period 2006 to 2016 for the northwest region of
North Carolina The reports set goals for improving water and sewer
infrastructure in West Jefferson and Jefferson, but local planners reported no
specific expansion plans at the time of this report
Water $ Sewer
Water and sewer is available along NC 88 west of Jefferson to McFarland
Publishing, as well as in the Town of West Jefferson, slightly less than one mile
south of NC 88, and accessible via NC 94 and Doggett Road The West
Jefferson wastewater treatment facility is located on Clearwater Drive off of
Doggett Road south of the project West Jefferson's water source is individual
and municipal wells Jefferson's water source is unknown at the time of this
memo, but is also thought to be wells Both Jefferson and West Jefferson
reported limited water distribution facilities According to CEDs reports, West
Jefferson has 25% or more remaining capacity Jefferson is currently at 92%
capacity Expansion plans could not be determined at the time of this report
Sewer service is limited to only 1152 of the county's almost 26,000 residents
Notable Features
Notable natural features in the area include the NC Division of Water Quality
303(d) impaired stream listing for Little Buffalo Creek, a Class C Trout stream
which parallels NC 88 from NC 194 to Doggett Road According to GIS data,
however, the stream may be delisted if new regulatory controls are successful
The popular Mount Jefferson State Park is located east of West Jefferson and
south of Jefferson, dust east of US 221 bypass
Development Regulations
According to local planners, neither Jefferson, West Jefferson, nor Ashe County
have comprehensive or current land use planning in place However, both
Jefferson and West Jefferson reported having zoning West Jefferson planners
indicated that a draft comprehensive plan was being developed Neither
Jefferson nor West Jefferson have Extra-Territorial Jurisdictions Jefferson's
town limits on the west side of town extend to near Ashley Farm Road, dust east
of Hickory Hills Road
4
Market for Development
Land is abundant in this area, but mountainous terrain can limit location and
project scope An area in northwest Jefferson has been identified for increased
industrial development, but no new projects are being planned at present The
preferred alternative will greatly limit relocations, nonetheless market pressures
are not sufficient to result in wholesale redevelopment, whether commercially or
residentially, along the NC 88 corridor in the foreseeable future
The Jefferson town manager referenced the new Hickory Hills subdivision being
developed west of Jefferson off of NC 88 She indicated that Jefferson would
likely extend water and sewer to service this development
Development pressures are otherwise low, although second home development
continues in various locations in the county Existing and new development has
resulted in support services, stores, and shopping centers, such as the new
Lowe's Home Improvement and Wal-Mart stores on US 221 bypass between
West Jefferson and Jefferson
Findings & Conclusions
Indirect Effects
In conclusion, there are some upward growth trends, primarily in the form of
second home development and a limited amount of increased industrial
development in Jefferson which are encouraged by a lenient public policy
environment There is a moderate supply of developable land adjacent to the
project, but terrain serves as a constraint in this mountainous community A
303(d) listed impaired Trout stream is adjacent to the project Job growth is
forecast to be moderate However, population growth is forecast to be quite low
Most importantly, the limited scope of this project which is primarily restricted to
existing location, and very limited travel time savings, will greatly inhibit change in
land use effects associated with this project Therefore, indirect effects will be
very minor such that the threat to downstream water quality will be very limited
Cumulative Effects
Cumulatively, direct project impacts associated with this project are being
avoided, minimized, or mitigated, consistent with programmatic agreements with
natural resource and permitting agencies Indirect effects in the form of change
in land use, or new growth, will be very minimal Therefore, cumulative effects
associated with this project will be very low
5
APPENDIX 6
June 27, 2006 Concurrence Form for
Assessment of Effects with Signed De
Minimus Finding Added
Federal Aid # STP- 88(2) TIP# U-3812 County Ashe
CONCURRENCE FORM FOR ASSESSMENT OF EFFECTS
Project Description Widen NC 88 from US 221 Business to NC 194
On June 27, 2006 representatives of the
X North Carolina Department of Transportation (NCDOT)
X Federal Highway Administration (FHWA)
X North Carolina State Historic Preservation Office (HPO)
? Other
Reviewed the subject project and agreed
? There are no effects on the National Register-listed property/properties located within
the project's area of potential effect and listed on the reverse
? There are no effects on the National Register-eligible property/properties located within
the project's area of potential effect and listed on the reverse
? There is an effect on the National Register-listed property/properties located within the
project's area of potential effect The property/properties and the effect(s) are listed on
the reverse
There is an effect on the National Register-eligible property/properties located within the
project's area of potential effect The property/properties and effect(s) are listed on the
reverse
Signed
Representative, NCDOT Date
a__e,d L, 7.-ZI VG
FHWA, for the Division Administrator, or other Federal Agency Date
?. 11 b Lp
Representative, HPO Da \e
tate Historic Preservation Officer Date
Federal Aid # STP- 88(2) TIP# U-3812
Properties within the area of potential effect for which t
National Register-listed (NR) or determined eligible (D
County Ashe
COMMAYY,?t_,?
1 y o kS0 +0
Al? I * ?__ ? _5 LI-;Z-6:?L
A1+. 10 1s v16 u-) A 14.4
Properties within the area of potential effect for which there is an effect Indicate property status
(NR or DE) and describe the effect
c??t/ emirs E ?G?
# , ?D -- Ile
was /Aal
Reason(s) why the effect is not adverse (if applicable)
- frt/,/.1 /!/ al ? j Gc G-? ?Yt? j'd
'
Ira. (< < e U
WO_4/mv? 44_0a_?
??s+r
?Ain

O'T ( 3 L)'Lo)
Initialed NCDOT FHWA __) L HPO
FHkNA intends to use SHPO's concurrence as a
basis of a "de mimmis" finding for the following 7- - X71
properties, pursuant to Section 4(f) TnSP/Jti , kfi , 1 If0 s t
APPENDIX 7
Updated Survey Report for Swamp
Pink (Helonias bullata)and Virgina
spiraea (Spiraea viYginiana)
STArr
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F EASLEY
GOVERNOR
MEMORANDUM TO Gene Tarscio, Project Development Engineer
FROM Brett Feulner, Environmental Specialist
SUBJECT Protected Species Update for U-3812
Ashe County
Jefferson - NC 88 from NC 194 to US 221 BUS
This memo serves to update the status of the federally protected species for the above referenced
prod ect
Species Virginia spiraea, (Spiraea virginiana)
Survey Date 05/15/2008
Habitat Description/ Survey Information Scour areas in Little Buffalo Creek
Length of Survey 0 5 Person Hours
Biological Conclusion No Effect, but Habitat Present
Principal Investigators (please see attachment for qualifications)
Brett Feulner
Jeff Hemphill
Jeremy Learner
If you have any questions, please contact Brett Feulner at bmfeulner@dot state nc us or 919-715-
1488
May 15, 2008
LYNDo TIPPETT
SECRETARY
MAILING ADDRESS
NC DEPARTMENT OF TRANSPORTATION
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS
1 598 MAIL SERVICE CENTER
RALEIGH NC 27699 1598
TELEPHONE [phone]
FAX [phone]
WEBSITE WWW DOH DOT ST4TE NC US
LOCATION
2725 CAPITAL BLVD
PLB SUITE 240
RALEIGH NC, 27604
Qualifications of Principal Investigators
Investigator Brett Feulner
Education B S Forest Management, North Carolina State University, May 2001
Experience Environmental Biologist, N C Dept of Transportation Feb 2003-present
Environmental Specialist, Landmark Design Group, Raleigh, NC, June 2001-December 2002
District Forester, Resource Management Service, New Bern, NC, January 1999-December 1999
Investigator Jeff Hemphill
Education BS, Forest Resource Management, Ohio State University,
Experience Environmental Specialist, NCDOT, March 2004 - present
Environmental Scientist, R D Zande & Associates, Columbus, OH, June 1991-January 2004
Investigator Jeremy Leamer
Education B S , Natural Resource Management, UNC-Asheville, May 2000
Expenence Environmental Senior Technician, NCDOT, February 2007-present
Erosion Control Technician, Durham County Engineering, February 2005-June, 2006
Staff Scientist, WK Dickson, December 2003-February 2005
Environmental Scientist, MAA, September, 2001 A6 November 20021
Naturalist, Kiawah Island Resort, SC, Summer Intern, 1998
APPENDIX 8
Updated Traffic Noise Analysis
& Air Analysis Reports

71 _ D
TRAFFIC NOISE ANALYSIS
NC 88 from NC 194 to US 221 Business
Ashe County
WBS Element No 34977 1 1 3
TIP Project No U-3812
Prepared for
North Carolina Department of Transportation
Project Development and Environmental Analysis Branch
Submitted By
Human Environment Unit
Traffic Noise & Air Quality Group
May 8, 2008
TRAFFIC NOISE ANALYSIS
NC 88 from NC 194 to US 221 Business
Ashe County
WBS Element No 34977 1 1 3
TIP Project No U-3 812
Prepared for
North Carolina Department of Transportation
Project Development and Environmental Analysis Branch
Submitted By
Human Environment Unit
Traffic Noise & Air Quality Group
4? ae???
Gre ory S rth, PE
Traffic Noise & Air Quality Supervisor
1 4 44?2
Ric Cox
Traffic N /ise Engineer
Executive Summary
The North Carolina Department of Transportation proposes to widen NC 88 from NC 194 to US
221 Business in Ashe County NC 88 is mostly a two lane facility from Lawson Lane to NC 221
Business and is proposed to be widened to a three lane facility (one lane in each direction with a
center turn lane)
Traffic noise impacts are an unavoidable consequence of transportation projects, especially in
areas where there are no previous traffic noise sources A Traffic Noise Analysis was performed
utilizing the FHWA Traffic Noise Model software (TNM 2 5) to predict future noise levels and
impacted receptors along the proposed alignments
Based on this analysis, seven noise impacts are predicted to occur with the widening of NC 88
Two (2) receivers will be acquired as nght-of-way Noise mitigation was considered for all
traffic noise impacts identified in this analysis Based on this analysis and in accordance with
the NCDOT Traffic Noise Abatement Policy, traffic noise abatement measures are not
considered feasible or reasonable for this project Consequently, no noise abatement is
recommended, and no noise abatement measures are proposed
Please note that this noise analysis utilized only Preliminary Plans The number of traffic noise
impacts for the Build Alternative may change if the Final Plan alignment vanes from that found
on the Preliminary Plans
This evaluation completes the highway traffic noise requirements of Title 23 CFR Part 772
Unless a major project change develops, such as that noted in the previous paragraph, no
additional noise reports will be necessary for this project
Table of Contents
1 0 Introduction
20 Characteristics of Noise
30 Noise Abatement Criteria
40 Ambient Noise Levels
50 Procedure for Predicting Future Noise Levels
60 Traffic Noise Impacts and Noise Contours
70 Traffic Noise Abatement Measures
7 1 Highway Alignment Selection
72 Traffic System Management Measures
7 3 Noise Barriers
74 Other Mitigation Measures Considered
80 Do Nothing Alternative
90 Construction Noise
10.0 Summary
Page
1
1
1
3
4
5
7
8
8
9
9
10
10
10
11
List of Tables
Table 1 Hearing Sounds Bombarding Us Daily Page 2
Table 2 Noise Abatement Criteria 3
Table 3 Ambient Noise Levels (Leq) 4
Table 4 Approximate # of Impacted Receptors 6
Table 5 Predicted Substantial Noise Level Impacts 7
Table 6 Predicted Leq Noise Levels and Noise Contours 8
List of Figures
Figure 1 Project Area Map and Ambient Measurement Sites Page 11
Appendix
Traffic Noise Exposures Build Alternative Al
No-Build Alternative A3
III
1.0 INTRODUCTION
The North Carolina Department of Transportation proposes to widen NC 88 from NC 194 to
US 221 Business in Ashe County NC 88 is mostly a two lane facility from Lawson Lane to NC
221 Business and is proposed to be widened to a three lane facility (one lane in each direction
with a center turn lane)
20 CHARACTERISTICS OF NOISE
Noise is basically defined as unwanted sound It is emitted from many sources including
airplanes, factories, railroads, power generation plants, and highway vehicles Highway noise, or
traffic noise, is usually a composite of noises from engine exhaust, drive train, and tire-roadway
interaction
The magnitude of noise is usually described by its sound pressure Since the range of sound
pressure vanes greatly, a logarithmic scale is used to relate sound pressures to some common
reference level, usually the decibel (dB) Sound pressures described in decibels are called sound
pressure levels and are often defined in terms of frequency-weighted scales (A, B, C, or D)
The weighted-A decibel scale is used almost exclusively in vehicle noise measurements because
it places the most emphasis on the frequency range to which the human ear is most sensitive
(1,000-6,000 Hertz) Sound levels measured using a weighted-A decibel scale are often
expressed as dBA Throughout this report, all noise levels will be expressed in dBA's
Several examples of noise pressure levels in dBA are listed in Table 1, which indicates that most
individuals in urbanized areas are exposed to fairly high noise levels from many sources as they
go about their daily activities The degree of disturbance or annoyance of unwanted sound
depends essentially on three things
1) The amount and nature of the intruding noise
2) The relationship between the background noise and the intruding noise
3) The type of activity occurring when the noise is heard
Over time, particularly if the noises occur at predicted intervals and are expected, individuals
tend to accept the noises that intrude into their lives Attempts have been made to regulate many
of these types of noises including airplane noise, factory noise, railroad noise, and highway
traffic noise In relation to highway traffic noise, methods of analysis and control have
developed rapidly over the past few years
3 0 NOISE ABATEMENT CRITERIA
The Federal Highway Administration (FHWA) has developed Noise Abatement Cntena (NAC)
and procedures to be used in the planning and design of high1A ays to determine whether highway
I
TABLE 1
HEARING SOUNDS BOMBARDING US DAILY'
140 Shotgun blast let 30m away at takeoff PAIN
Motor test chamber HUMAN EAR PAIN THRESHOLD
130 --------------------------------------------------------- ------------------------------ -
Firecrackers
120 Severe thunder pneumatic jackhammer
Hockey crowd
Amplified rock music UNCOMFORTABLY LOUD
110 --------------------------------------------------------- ------------------------------
----------
Textde loom
100 Subway train elevated train, farm tractor
Power lawn mower, newspaper press
Heavy city traffic, noisy factory LOUD
90 --------------------------------------------------------- -----------------------------------------
D Diesel truck 65 km/h at 15m away
E 80 Crowded restaurant, garbage disposal
C Average factory vacuum cleaner
I Passenger car 80 km/h at 15m away MODERATELY LOUD
B 70 --------------------------------------------------------- -----------------------------------------
E Quiet typewriter
L 60 Singing birds, window air-conditioner
S Quiet automobile
Normal conversation average office QUIET
50 --------------------------------------------------------- -----------------------------------------
Household refrigerator
Quiet office VERY QUIET
40 --------------------------------------------------------- ----------------------------------------
Average home
30 Dripping faucet
Whisper at 1 5m away
20 Light rainfall rustle of leaves
AVERAGE PERSON' S THRESHOLD OF HEARING
Whisper JUST AUDIBLE
10 ---------------------------------------------------------- -----------------------------------------
0
THRESHOLD FOR ACUTE HEARING
' World Book, Rand McNally Atlas of the Human Body, Encyclopedia America, "Industrial Noise
and Hearing Conversation" by J B Olishrfski and E R. Harford (Researched by N Jane Hunt and
published to the Chicago Tribune to an illustrated graphic by Tom Heinz )
noise levels are or are not compatible with various land uses These abatement cntena and
procedures are set forth in Title 23 Code of Federal Regulations Part 772, Procedures for
Abatement of Highway Traffic Noise and Construction Noise (23 CFR 772) A summary of the
noise abatement criteria for various land uses is presented in Table 2 The Leq, or equivalent
sound level, is the level of constant sound which in a given situation and time period has the
same energy as does time varying sound In other words, the fluctuating sound levels of traffic
noise are represented in terms of a steady noise level with the same energy content
2
TABLE 2
NOISE ABATEMENT CRITERIA I
CRITERIA FOR EACH FHWA ACTIVITY CATEGORY
HOURLY A-WEIGHTED SOUND LEVEL - DECIBELS (dBA)
Activity
Category

Leq(h)

Description of Activity Category

57 Lands on which serenity and quiet are of extraordinary significance and serve an
A (Exterior) important public need and where the preservation of those qualities are essential if the
area is to continue to serve its intended purpose
B 67 Picnic areas, recreation areas, playgrounds, active sports areas, parks,
(Exterior) residences, motels, hotels, schools, churches, libraries, and hospitals
C 72 Developed lands, properties, or activities not included in Categones
(Exterior) A or B above
D - Undeveloped lands
E 52 Residences, motels, hotels, public meeting rooms, schools, churches,
(Interior) libraries, hospitals, and auditoriums
Title 23 Code of Federal Regulations (CFR) Part772, U S Department of Transportation,
Federal Highway Administration
CRITERIA FOR SUBSTANTIAL INCREASE `
HOURLY A-WEIGHTED SOUND LEVEL - DECIBELS (dBA)
Existing Noise Level Increase in dBA from Existing
in Leq(h) Noise Levels to Future Noise Levels
<= 50 >= 15
51 >= 14
52 >= 13
53 >= 12
54 >= 11
>= 55 >= 10
North Carolina Department of Transportation Traffic Noise
Abatement Policy (09/02/04)
40 AMBIENT NOISE LEVELS
Ambient noise measurements were taken in the vicinity of the project to determine ambient
(existing) noise levels for the identified land uses The purpose of this noise level information
was to quantify the existing acoustic en,,ironment and to provide a base for assessing the impact
of noise level increases The existing Leq noise levels in the project area, measured 50 feet from
the edge of pavement ranged from 63 dBA to 64 dBA A background noise level of 45 dBA was
determined to be used in areas where traffic noise is not the predominant source The ambient
measurement locations are shown in Figure 1 and described in Table 3
The existing roadway and traffic conditions were used with the most current traffic noise
prediction model to calculate existing noise levels for comparison with noise levels actually
measured The calculated existing noise levels averaged less than 2 dBA difference from the
measured noise levels for the locations where noise measurements were obtained Hence, the
computer model is a reliable tool in the prediction of noise levels Differences in dBA levels can
be attributed to "bunching" of vehicles, low traffic volumes, and actual vehicle speeds versus the
computer's "evenly-spaced" vehicles and single vehicular speed
TABLE 3
AMBIENT NOISE LEVELS (Leq) 1
NOISE
SITE LOCATION DESCRIPTION LEVEL
(dBA)
1 NC 88 Approximately 110' West of McNeil St at
Jehovah's Witness Church paved 64

2 NC 88 Approximately 1400' East of SR 1153 at
Unnamed Business Gravel 63
1 Ambient noise level sites were measured at 50 feet from the edge of pavement
of the nearest lane of traffic
50 PROCEDURE FOR PREDICTING FUTURE NOISE LEVELS
In general, the traffic situation is composed of a large number of variables that describe different
cars driving at different speeds through continually changing highway configurations and
surrounding terrain Due to the complexity of the problem, certain assumptions and
simplifications must be made to predict highway traffic noise The procedure used to predict
future noise levels in this study was the FHWA-produced Traffic Noise Model software
(TNM 2 5)
The TNM traffic noise prediction model uses the number and type of vehicles on the planned
roadway, their speeds, the physical characteristics of the road (curves, hills, depressed, elevated
etc ), noise receptor location, receptor height above the roadway, and, if applicable bamer type,
barrier ground elevation, and bamer top elevation
In this regard, it must be noted that only preliminary alignment information was available for use
in this noise analysis The project proposes widening NC 88 from NC 194 to US 221 Business
in Ashe County Peak hour design and level-of-service (LOS) C volumes were compared, and
the volumes resulting in the noisiest conditions were used with the proposed posted speed limits
Hence, during all other time periods, the noise levels will be no greater than those indicated in
this report Only those existing natural or man-made barriers were included in setting up the
model All roadway sections and proposed intersections were assumed to be flat and at-grade
Thus, this analysis represents the "worst-case" topographical conditions
The noise predictions made in this report are highway-related noise predictions for the traffic
conditions during the 2030 Design Year being analyzed The Leq traffic noise exposures
associated for this project are listed in the Appendix Information included in these tables consist
of listings of all receptors in close proximity to the project, their ambient and predicted noise
levels, and the estimated noise level increase for each
60 TRAFFIC NOISE IMPACTS AND NOISE CONTOURS
A land use is considered impacted by highway traffic noise when exposed to noise levels
approaching or exceeding the FHWA noise abatement criteria and/or predicted to sustain a
substantial noise increase The NCDOT Traffic Noise Abatement Policy defines a traffic noise
impact occurs when the predicted traffic noise levels either
(a) Approach or exceed the FHWA noise abatement criteria (with "approach" meaning
within 1 dBA of the Table 2 value), or
(b) Substantially exceed the existing noise levels as shown in the lower portion of
Table 2
Consideration for noise abatement measures must be given to receptors that fall in either
category
The number of receptors in each activity category, for each section, that are predicted to become
impacted by future traffic noise are shown in Table 4 These receptors are noted in terms of
those receptors expected to experience traffic noise impacts by either approaching or exceeding
the FHWA NAC or by a substantial increase in exterior noise levels Based on this analysis and
under Title 23 CFR Part 772, seven residences are predicted to be impacted due to highway
traffic noise in the project area
Table 5 exhibits the exterior traffic noise level increases for the identified receptor by roadway
section There are no substantial noise level impacts anticipated due to this project
The predicted noise level increases for this project range up to +6 dBA The amount of
substantial noise level impacts for each roadway section can be found in Table 5 When real-life
noises are heard, it is barely possible to detect noise level changes of 2-3 dBA A 5-dBA change
is more readily noticeable
TABLE 4
APPROXIMATE # OF IMPACTED RECEPTORS
ACCORDING TO TITLE 23 CFR PART 772
BUILD ALTERNATIVE ACTIVITY CATEGORY
A B C D E
NC 88 from NC 194 to Lawson Lane 0 5 0 0 0
NC 88 from Lawson Lane to US 221 Business 0 2 0 0 0
TOTAL 0 7 0 0 0

NO-BUILD ALTERNATIVE ACTIVITY CATEGORY
A B C D E
NC 88 from NC 194 to Lawson Lane 0 7 0 0 0
NC 88 from Lawson Lane to US 221 Business 0 8 0 0 0
TOTAL 0 15 0 0 0
In accordance with the NCDOT 2004 Traffic Noise Abatement Policy, Federal and State
governments are not responsible for providing noise abatement measures for new development
where building permits are issued within the noise impact area of a proposed highway after the
`Date of Public Knowledge" The Date of Public Knowledge of the location of a proposed
highway project will be the approval date of the final environmental document For
development occurring after this public knowledge date, local governing bodies are responsible
to ensure that noise compatible designs are utilized along the proposed facility
With the proper information on future traffic noise contours and predicted noise levels, the local
authorities can prevent further development of incompatible activities and land uses with the
TABLE 5
PREDICTED SUBSTANTIAL NOISE LEVEL IMPACTS
EXTERIOR NOISE
SUBSTANTIAL IMPACTS
BUILD ALTERNATIVE LEVEL INCREASE NOISE LEVEL DUE TO
<9 10-14 > 15 INCREASE
1 BOTH

dBA
dBA
dBA 2
CRITERIA
NC 88 from NC 194 to Lawson Lane 21 0 0 0 0
NC 88 from Lawson Lane to US 221

Business 31 0 0 0
0
TOTALS 52
J

0
7

0

0

0

EXTERIOR NOISE
SUBST
ANTIAL IMPACTS
NO-BUILD ALTERNATIVE LEVEL INCREASE NOISE
LEVEL DUE TO
<9 10-14 > 15 INCREASE
1 BOTH
2
dBA dBA dBA CRITERIA
NC 88 from NC 194 to Lawson Lane 22 0 0 0 0
NC 88 from Lawson Lane to US 221

Business 32 0 0 0 0
TOTALS 54 0 0 0 0
predicted noise levels of an adjacent highway The maximum extent of the 72-dBA noise level
contours, measured from the center of the proposed roadways, is less than thirty-seven feet
(<37') The maximum extent of the 67-dBA noise level, measured from the center of the
proposed roadways, is fifty-four feet (54') Contour information and predicted future noise
levels are shown by roadway sections in Table 6 This information should assist local authorities
in exercising land use control over the remaining undeveloped lands adjacent to the roadway
within local junsdiction
7 0 TRAFFIC NOISE ABATEMENT MEASURES
If traffic noise impacts are predicted, examination and evaluation of alternative noise abatement
measures for reducing or eliminating the noise impacts must be considered Consideration for
noise abatement measures must be given to all impacted receptors There are three predicted
impacted receptors due to highway traffic noise in the project area The following discussion
addresses the applicability of these measures to the proposed project
TABLE 6
PREDICTED Leq NOISE LEVELS
and NOISE CONTOURS

BUILD ALTERNATIVE MAXIMUM PREDICTED
Le NOISE LEVELS dBA 1
q MAXIMUM
CONTOUR
DISTANCES'
50 ft 100 ft 200 ft 72 dBA 67 dBA
NC 88 from NC 194 to Lawson Lane 66 60 54 <37 54
NC 88 from Lawson Lane to US 221 Business 64 58 54 <43 43

NO-BUILD ALTERNATIVE MAXIMUM PREDICTED
Le NOISE LEVELS dBA 1
q MAXIMUM
CONTOUR
DISTANCES'
50 ft 100 ft 200 ft 72 dBA 67 dBA
NC 88 from NC 194 to Lawson Lane 66 60 54 <37 54
NC 88 from Lawson Lane to US 221 Business 65 59 53 <37 43
7.1 Highway Alignment Selection
Highway alignment selection involves the horizontal or vertical orientation of the proposed
improvements in such a way as to minimize impacts and costs The selection of alternative
alignments for noise abatement purposes must consider the balance between noise impacts and
other engineering and environmental parameters For noise abatement, horizontal alignment
selection is primarily a matter of siting the roadway at a sufficient distance from noise sensitive
areas Changing the highway alignment is not a viable alternative for noise abatement on this
project
72 Traffic System Management Measures
Traffic system management measures, which limit vehicle type, speed, volume and time of
operations, are often effective noise abatement measures For this project, traffic management
measures are not considered appropriate for noise abatement due to their effect on the capacity
and level-of-service of the proposed facility
Past project experience has shown that a reduction in the speed limit of 10 mph would result in a
noise level reduction of approximately 1 to 2 dBA Because most people cannot detect a noise
reduction of up to 3 dBA, and because reducing the speed limit would reduce roadway capacity,
it is not considered a viable noise abatement measure This and other traffic system management
measures, including the prohibition of truck operations, are not considered to be consistent with
the project's objective of providing a high-speed, limited-access facility
73 Noise Barriers
Physical measures to abate anticipated traffic noise levels are often applied with a measurable
degree of success on fully controlled facilities by the application of solid mass, attenuable
measures strategically placed between the traffic sound source and the receptors to effectively
diffract, absorb, and reflect highway traffic noise emissions Solid mass, attenuable measures
may include earth berms or artificial abatement walls
The project will maintain uncontrolled or limited control of access, meaning most commercial
establishments and residents will have direct access connections to the proposed roadway, and all
intersections will adjoin the project at grade For a noise barrier to provide sufficient noise
reduction, it must be high enough and long enough to shield the receptor from significant
sections of the highway Access openings in the barrier severely reduce the noise reduction
provided by the barrier It then becomes economically unreasonable to construct a barrier for a
small noise reduction Safety at access openings (driveways, crossing streets, etc ) due to
restricted sight distance is also a concern Furthermore, to provide a sufficient reduction, a
bamer's length would normally be eight times the distance from the barrier to the receptor For
example, a receptor located fifty feet from the barrier would normally require a barrier four
hundred feet long An access opening of forty feet (10 percent of the barrier length) would limit
its noise reduction to approximately 4 dBA Consequently, this type of control of access
effectively eliminates the consideration of berms or noise walls as noise mitigation measures
Additionally, businesses, churches, and other related establishments located along a particular
highway normally require accessibility and high visibility Solid mass, attenuable measures for
traffic noise abatement would tend to disallow these two qualities, and thus, would not be
acceptable abatement measures in this case
74 Other Mitigation Measures Considered
The acquisition of property in order to provide buffer zones to minimize noise impacts is not
considered a feasible noise mitigation measure for this project The cost to acquire impacted
receptors for buffer zones would exceed the allowed abatement cost of $35,000 per benefited
receptor The use of buffer zones to minimize impacts to future sensitive areas is not
recommended because this could be accomplished through land use control
The use of vegetation for noise mitigation is not considered reasonable for this project, due to the
substantial amount of right-of-way necessary to provide effective vegetative barriers FHWA
research has shown that a vegetative barrier must be approximately one hundred feet (100') wide
to provide a 3-dBA reduction in noise levels In order to provide a 5-dBA reduction, substantial
amounts of additional right-of-way, are required The cost of the additional right-of-way and to
plant sufficient vegetation is estimated to exceed the abatement cost of $35,000 allowed per
benefited receptor Noise insulation was also considered, however, no public or non-profit
institutions were identified that would be impacted by this project
8 0 AO NOTHING" ALTERNATIVE
The traffic noise impacts for the "do nothing" or "no-build" alternative was also considered If
the proposed widening does not occur, fifteen receptors are anticipated to approach or exceed the
FHWA NAC These receptors could anticipate experiencing an increase in exterior noise levels
of approximately 1 dBA As previously noted, it is barely possible to detect noise level changes
of 2-3 dBA A 5-dBA change in noise levels is more readily noticed
90 CONSTRUCTION NOISE
The mayor construction elements of this project are expected to be earth removal, hauling,
grading, and paving General construction noise impacts, such as temporary speech interference
for passers-by and those individuals living or working near the project, can be expected
particularly from paving operations and from the earth moving equipment during grading
operations However, considering the relatively short-term nature of constniction noise, these
impacts are not expected to be substantial The transmission loss characteristics of nearby
natural elements and man-made structures are believed to be sufficient to moderate the effects of
intrusive construction noise
10 0 SUMMARY
Traffic noise impacts are an unavoidable consequence of transportation projects especially in
areas where there are no previous traffic noise sources All traffic noise impacts identified in this
analysis were considered for noise mitigation Based on these preliminary studies, traffic noise
abatement is not recommended, and no noise abatement measures are proposed This evaluation
completes the highway traffic noise requirements of Title 23 CFR Part 772 Unless a mayor
project change develops, no additional noise reports are necessary for this probe
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AIR QUALITY ANALYSIS
NC 88 From NC 194 To US 221 Business
Ashe County
WBS Element No 34977 1 1 3
TIP Project No U-3 812
Prepared for
North Carolina Department of Transportation
Project Development and Environmental Analysis Branch
Submitted By
Human Environment Unit
Traffic Noise & Air Quality Group
Gdkfor)A Smith, PE
Traffic Noise & Air Quality Supervisor
Bobby Du
Air Quality Engineer
Table of Contents
1.0 Introduction Page 1
2.0 Air Quality Analysts 1
3.0 Attainment Status 1
4.0 Carbon Monoxide 1
5.0 Ozone & Nitrogen Dioxide 2
6.0 Particulate Matter & Sulfur 2
70 Lead 2
80 Mobile Source Air Toxics 3
9.0 Burning of Debris Summary 9
100 Summary 9
List of Figures
Figurel Vehicle Miles Traveled (VMT) vs Mobile Source 4
Air Toxics Emissions (MSAT), 2000-2020
Figure 2 Project Location Map 10
I
1 0 Introduction
The North Carolina Department of Transportation proposes to widen NC 88 to a mutilane
facility from NC 194 to US 221 Business The multilane facility will consist of a three-
lane curb and cutter section in urban portion which will be from Lawson Lane to US 221
Business, and realignment of an S-curve and the intersection of NC 88 and NC 194 in the
rural portion from NC 194 to Lawson Lane
20 Air Quality Analysis
Air pollution originates from various sources Emissions from industry and internal
combustion engines are the most prevalent sources The impact resulting from highway
construction ranges from intensifying existing air pollution problems to improving the
ambient air quality Changing traffic patterns are a primary concern when determining
the impact of a new highway facility or the improvement of an existing highway facility
Motor vehicles emit carbon monoxide (CO), nitrogen oxide (NO), hydrocarbons (HC),
particulate matter, sulfur dioxide (S02), and lead (Pb) (listed in order of decreasing
emission rate)
30 Attainment Status
The project is located in Ashe County, which has been determined to comply with the
?National Ambient Air Quality Standards The proposed project is located in an
attainment area, therefore, 40 CFR Parts 51 and 93 are not applicable This project is not
anticipated to create any adverse effects on the air quality of this attainment area
41) Carbon Monoxide
automobiles are considered the major source of CO in the project area In order to
determine the ambient CO concentration at a receptor near a highway, two concentration
components must be used local and background The local concentration is defined as
the CO emissions from cars operating on highways in the near vicinity (i e , distances
,,ti ithin 400 feet) of the receptor location The background concentration is defined by the
,North Carolina Department of Environment, Health and Natural Resources as "the
concentration of a pollutant at a point that is the result of emissions outside the local
? icinity, that is, the concentration at the upwind edge of the local sources "
This project is located in a CO attainment area, therefore no CO microscale analysis Vk as
performed
5 0 Ozone & Nitrogen Dioxide
Automobiles are regarded as sources of hydrocarbons and nitrogen oxides
Hydrocarbons and nitrogen oxides emitted from cars are earned into the atmosphere
where they react with sunlight to form ozone (03) and nitrogen dioxide (N02)
Automotive emissions of HC and NOx are expected to decrease in the future due to the
continued installation and maintenance of pollution control devices on new cars
However, regarding area-wide emissions, these technological improvements maybe offset
by the increasing number of cars on the transportation facilities of the area
The photochemical reactions that form ozone and nitrogen dioxide require several hours
to occur For this reason, the peak levels of ozone generally occur ten to twenty
kilometers downwind of the source of hydrocarbon emissions Urban areas as a whole
are regarded as sources of hydrocarbons, not individual streets and highways The
emissions of all sources in an urban area mix in the atmosphere, and, in the presence of
sunlight, this mixture reacts to form ozone, nitrogen dioxide, and other photochemical
oxidants The best example of this type of air pollution is the smog that forms in Los
Angeles, California
60 Particulate Matter & Sulfur
Automobiles are not regarded as significant sources of particulate matter (PM) and sulfur
dioxide (S02) Nationwide, highway sources account for less than seven percent of
particulate matter emissions and less than two percent of sulfur dioxide emissions
Particulate matter and sulfur dioxide emissions are predominantly the result of non-
highway sources (e g, industrial, commercial, and agricultural) Because emissions of
particulate matter and sulfur dioxide from automobiles are very low, there is no reason to
suspect that traffic on the project will cause air quality standards for particulate matter
and sulfur dioxide to exceed the NAAQS
70 Lead
Automobiles without catalytic converters can burn regular gasoline The burning of
regular gasoline emits lead as a result of regular gasoline containing tetraethyl lead,
which is added by refineries to increase the octane rating of the fuel Newer cars with
Catalytic converters burn unleaded gasoline, thereby eliminating lead emissions Also,
the United States Environmental Protection Agency (EPA) has required the reduction in
the lead content of leaded gasoline The overall average lead content of gasoline in 1974
was approximately 0 53 gram per liter By 1959, this composite average had dropped to
0 003 gram per liter The Clean Air Act Amendments of 1990 made the sale, supply or
transport of leaded gasoline or lead additives unlawful after December 31, 1995
Because of these reasons, it is not expected that traffic on the proposed project will cause
the NAAQS for lead to be exceeded

8 0 Mobile Source Air Toxics
In addition to the criteria air pollutants for which there are National Ambient Air Quality
Standards (NAAQS), EPA also regulates air toxics Most air toxics originate from
human-made sources, including on-road mobile sources, non-road mobile sources (e g,
airplanes), area sources (e g , dry cleaners) and stationary sources (e g , factories or
refineries)
Mobile Source Air Toxics (MSATs) are a subset of the 188 air toxics defined by the
Clean Air Act The MSATs are compounds emitted from highway vehicles and non-road
equipment Some tonic compounds are present in fuel and are emitted to the air when the
fuel evaporates or passes through the engine unburned Other toxics are emitted from the
incomplete combustion of fuels or as secondary combustion products Metal air toxics
also result from engine wear or from impurities in oil or gasoline
The EPA is the lead Federal Agency for administering the Clean Air Act and has certain
responsibilities regarding the health effects of MSATs The EPA issued a Final Rule on
Controlling Emissions of Hazardous Air Pollutants from Mobile Sources in 66 FR 17229
(March 29, 2001) This rule was issued under the authority in Section 202 of the Clean
Air Act In its rule, EPA examined the impacts of existing and newly promulgated mobile
source control programs, including its reformulated gasoline (RFG) program, its national
low emission vehicle (NLEV) standards, its Tier 2 motor vehicle emissions standards and
gasoline sulfur control requirements, and its proposed heavy duty engine and vehicle
standards and on-highway diesel fuel sulfur control requirements Between 2000 and
2020, FHWA projects that even with a 64 percent increase in VMT, these programs will
reduce on-highway emissions of benzene, formaldehyde, 1,3-butadiene, and acetaldehyde
by 57 percent to 65 percent, and will reduce on-highway diesel PM emissions by 87
percent, as shown in Figure 1
As a result, EPA concluded that no further motor vehicle emissions standards or fuel
standards were necessary to further control MSATs The agency is preparing another
rule under authority of CAA Section 202(1) that will address these issues and could adjust
the full 21 and the primary 6 MSATs
FIGURE 1
U S ANNUAL VEHICLE MILES TRAVELED (VMT)
vs
MOBILE SOURCE AIR TOXICS (MSAT) EMISSIONS, 2000-2020
VhTr
(trillions/year)
6
0P1.4DE]G .E-%
rvm itle?y'k .Fz%'
Emissions
(tons/year)
200,000
100 000
4cce cvae t ,de '62%,
1.3-lowvese wx%.
?0101eh ro3%
0
2000
Notes For on-road mobile sources Emissions factors were generated using
MOBILE6 2 MTBE proportion of market for oxygenates is held constant, at 50%
Gasoline RVP and oxygenate content are held constant VMT Highway Statistics
2000, Table VM-2 for 2000, analysis assumes annual growth rate of 2 5% "DPM
+ DEOG" is based on MOBILE6 2-generated factors for elemental carbon, organic
carbon and S04 from diesel-powered vehicles, with the particle size cutoff set at
10 0 microns
Cnavailable Information for Project Specific MSAT Impact Analysis
This FONSI includes a basic analysis of the likely MSAT emission impacts of this
project However, available technical tools do not enable us to predict the project-
spr,cific health impacts of the emission changes associated with the alternatives in this
FONSI Due to these limitations, the following discussion is included in accordance with
CEQ regulations (40 CFR 1502 22(b)) regarding incomplete or unavailable information
Information that is Unavailable or Incomplete: Evaluating the environmental and
health impacts from MSATs on a proposed highway project would involve several key
elements, including emissions modeling, dispersion modeling in order to estimate
ambient concentrations resulting from the estimated emissions, exposure modeling in
order to estimate human exposure to the estimated concentrations, and then final
determination of health impacts based on the estimated exposure Each of these steps is
encumbered by technical shortcomings or uncertain science that prevents a more
complete determination of the MSAT health impacts of this project
2005 2010 2015 2020
• Emissions The EPA tools to estimate MSAT emissions from motor vehicles are
not sensitive to key variables determining emissions of MSATs in the context of
highway projects While MOBILE 6 2 is used to predict emissions at a regional
level, it has limited applicability at the project level MOBILE 6 2 is a tnp-based
model--emission factors are projected based on a typical trip of 7 5 miles, and on
average speeds for this typical trip This means that MOBILE 6 2 does not have
the ability to predict emission factors for a specific vehicle operating condition at
a specific location at a specific time Because of this limitation, MOBILE 6 2 can
only approximate the operating speeds and levels of congestion likely to be
present on the largest-scale projects, and cannot adequately capture emissions
effects of smaller projects For part iculate matter, the model results are not
sensitive to average trip speed, although the other MSAT emission rates do
change with changes in trip speed Also, the emissions rates used in MOBILE 6 2
for both particulate matter and MSATs are based on a limited number of tests of
mostly older-technology vehicles Lastly, in its discussions of PM under the
conformity rule, EPA has identified problems with MOBILE6 2 as an obstacle to
quantitative analysis
These deficiencies compromise the capability of MOBILE 6 2 to estimate MSAT
emissions MOBILE6 2 is an adequate tool for projecting emissions trends, and
performing relative analyses between alternatives for very large projects, but it is
not sensitive enough to capture the effects of travel changes tied to smaller
projects or to predict emissions near specific roadside locations
• Dispersion. The tools to predict how MSATs disperse are also limited The
EPA's current regulatory models, CALINE3 and CAL3QHC, were developed and
validated more than a decade ago for the purpose of predicting episodic
concentrations of carbon monoxide to determine compliance with the NAAQS
The performance of dispersion models is more accurate for predicting maximum
concentrations that can occur at some time at some location within a geographic
area This limitation makes it difficult to predict accurate exposure patterns at
specific times at specific highway project locations across an urban area to assess
potential health risk The NCHRP is conducting research on best practices in
applying models and other technical methods in the analysis of MSATs This
work also will focus on identifying appropriate methods of documenting and
communicating MSAT impacts in the NEPA process and to the general public
Along with these general limitations of dispersion models, FHWA is also faced
with a lack of monitoring data in most areas for use in establishing project-
specific MSAT background concentrations
• Exposure Levels and Health Effects. Finally, even if emission levels and
concentrations of MSATs could be accurately predicted, shortcomings in current
techniques for exposure assessment and risk analysis preclude us from reaching
meaningful conclusions about project-specific health impacts Exposure
assessments are difficult because it is difficult to accurately calculate annual
concentrations of MSATs near roadways, and to determine the portion of ayear
that people are actually exposed to those concentrations at a specific location
These difficulties are magnified for 70-year cancer assessments, particularly
because unsupportable assumptions would have to be made regarding changes in
travel patterns and vehicle technology (which affects emissions rates) over a 70-
year period There are also considerable uncertainties associated with the existing
estimates of toxicity of the various MSATs, because of factors such as low-dose
extrapolation and translation of occupational exposure data to the general
population Because of these shortcomings, any calculated difference in health
impacts between alternatives is likely to be much smaller than the uncertainties
associated with calculating the impacts Consequently, the results of such
assessments would not be useful to decision makers, who would need to weigh
this information against other project impacts that are better suited for quantitative
analysis
Summary of Existing Credible Scientific Evidence Relevant to Evaluating the
Impacts of MSATs Research into the health impacts of MSATs is ongoing For
different emission types, there are a variety of studies that show that some either are
statistically associated with adverse health outcomes through epidemiological studies
(frequently based on emissions levels found in occupational settings) or that animals
demonstrate adverse health outcomes when exposed to large doses
Exposure to toxics has been a focus of a number of EPA efforts Most notably, the
agency conducted the National Air Toxics Assessment (NATA) in 1996 to evaluate
modeled estimates of human exposure applicable to the county level While not intended
for use as a measure of or benchmark for local exposure, the modeled estimates in the
NATA database best illustrate the levels of various toxics when aggregated to a national
or State level
The EPA is in the process of assessing the risks of various kinds of exposures to these
pollutants The EPA Integrated Risk Information System (IRIS) is a database of human
health effects that may result from exposure to various substances found in the
environment The IRIS database is located at http //www epa gov/ins The following
toxicity information for the six prioritized MSATs was taken from the IRIS database
Weight of Evidence Characterization summanes This information is taken verbatim
from EPA's IRIS database and represents the Agency's most current evaluations of the
potential hazards and toxicology of these chemicals or mixtures
• Benzene is characterized as a known human carcinogen
• The potential carcinogenicity of acrolein cannot be determined because the
existing data are inadequate for an assessment of human carcinogenic potential
for either the oral or inhalation route of exposure
• Formaldehyde is a probable human carcinogen, based on limited e., idence in
humans and sufficient evidence in animals
s 1, 3-butadiene is characterized as carcinogenic to humans by inhalation
• Acetaldehyde is a probable human carcinogen based on increased incidence of
nasal tumors in male and female rats and laryngeal tumors in male and female
hamsters after inhalation exposure
• Diesel exhaust (DE likely to be carcinogenic to humans by inhalation from
environmental exposures Diesel exhaust as reviewed in this document is the
combination of diesel particulate matter and diesel exhaust organic gases
• Diesel exhaust also represents chronic respiratory effects, possibly the primary
noncancer hazard from MSATs Prolonged exposures may impair pulmonary
function and could produce symptoms, such as co) is ugh, phlegm, and chronic
bronchitis Exposure relationships have not been developed from these studies
There have been other studies that address MSAT health impacts in proximity to
roadways The Health Effects Institute, a non-profit organization funded by EPA,
FHWA, and industry, has undertaken a mayor series of studies to research near-roadway
MSAT hot spots, the health implications of the entire mix of mobile source pollutants,
and other topics The final summary of the series is not expected for several years
Some recent studies have reported that proximity to roadways is related to adverse health
outcomes --particularly respiratory problems' Much of this research is not specific to
MSATs, instead surveying the full spectrum of both criteria and other pollutants The
FHWA cannot evaluate the validity of these studies, but more importantly, they do not
provide information that would be useful to alleviate the uncertainties listed above and
enable us to perform a more comprehensive evaluation of the health impacts specific to
this project
Relevance of Unavailable or Incomplete Information to Evaluating Reasonably
Foreseeable Significant Adverse Impacts on the Environment, and Evaluation of
Impacts Based Upon Theoretical Approaches or Research Methods Generally
Accepted in the Scientific Community. Because of the uncertainties outlined above, a
quantitative assessment of the effects of air toxic emissions impacts on human health
cannot be made at the project level While available tools do allow us to reasonably
predict relative emissions changes between alternatives for larger projects, the amount of
MSAT emissions from each of the project alternatives and MSAT concentrations or
exposures created by each of the project alternatives cannot be predicted with enough
accuracy to be useful in estimating health impacts (As noted above, the current
emissions model is not capable of serving as a meaningful emissions analysis tool for
smaller projects ) Therefore, the relevance of the unavailable or incomplete information
is that it is not possible to make a determination of whether any of the altemati-ves would
have "significant adverse impacts on the human environment "
' South Coast Air Quality Management District, Multiple Air Toxic Exposure Study-II (2000), Highway
Health Hazards, The Sierra Club (2004) summanzmg 24 Studies on the relationship between health and air
quality), NEPA's Uncertainty to the Federal Legal Scheme Controlling Air Pollution from Motor Vehicles,
Environmental Law Institute 35 ELR 10273 (2005) with health studies cited therein
This document provides a quantitative analysis of MSAT emissions relative to the
various alternatives and acknowledges that some of the project alternatives may result in
increased exposure to MSAT emissions in certain locations, although the concentrations
and duration of exposures are uncertain, and because of this uncertainty, the health
effects from these emissions cannot be estimated
As discussed above, technical shortcomings of emissions and dispersion models and
uncertain science with respect to health effects prevent meaningful or reliable estimates
of MSAT emissions and effects of this project However, even though reliable methods
do not exist to accurately estimate the health impacts of MSATs at the project level, it is
possible to qualitatively assess the levels of future MSAT emissions under the project
Although a qualitative analysis cannot identify and measure health impacts from MSATs,
it can give a basis for identifying and comparing the potential differences among MSAT
emissions-if any-from the various alternatives The qualitative assessment presented
below is derived in part from a study conducted by the FHWA entitled A Methodology
for Evaluating Mobile Source Aar Toxic Emissions Among Transportation Project
Alternatives, found at
www fhwa dot gov/environment/airtoxic/msatcompare/msatemissions htm
For each alternative in this FONSI, the amount of MSATs emitted would be proportional
to the vehicle miles traveled, or VMT, assuming that other variables such as fleet mix are
the same for each alternative The VMT estimated for each of the Build Alternatives will
likely be slightly higher than that for the No Build Alternative, because the additional
capacity increases the efficiency of the roadway and attracts rerouted trips from
elsewhere in the transportation network The increased VMT would lead to higher
MSAT emissions for the action alternative along the highway corridor, along with a
corresponding decrease in MSAT emissions along the parallel routes The emissions
increase is offset somewhat by lower MSAT emission rates due to increased speeds,
according to EPA's MOBILE6 emissions model, emissions of all of the priority MSATs
except for diesel particulate matter decrease as speed increases The extent to which
these speed-related emissions decreases will offset VMT-related emissions increases
cannot be reliably projected due to the inherent deficiencies of technical models
Because the estimated VMT under each of the Alternatives are nearly the same, it is
ekpected there would be no appreciable difference in overall MSAT emissions among the
vanous alternatives Also, regardless of the alternative chosen, emissions will likely be
lower than present levels in the design year as a result of EPA's national control programs
that are projected to reduce MSAT emissions by 57 to 87 percent between 2000 and
2020 Local conditions may differ from these national projections in terms of fleet mix
and turnover, VMT growth rates, and local control measures However, the magnitude of
the EPA-projected reductions is so great (even after accounting for VMT growth) that
MSAT emissions in the study area are likely to be lower in the future in nearly all cases
The additional travel lanes contemplated as part of the project alternatives will have the
effect of moving some traffic closer to nearby homes, and businesses therefore, under
each alternative there may be localized areas where ambient concentrations of h1SAT
8
could be higher under certain Build Alternatives than the No Build Alternative The
localized increases in MSAT concentrations would likely be most pronounced along the
new alignment segments and along the sides of existing roadways where asymmetrical
widening occurs However, as discussed above, the magnitude and the duration of these
potential increases compared to the No-build alternative cannot be accurately quantified
due to the inherent deficiencies of current models In sum, when a highway is widened
and, as a result, moves closer to receptors, the localized level of MSAT emissions for the
Build Alternative could be higher relative to the No Build Alternative, but this could be
offset due to increases in speeds and reductions in congestion (which are associated with
lower MSAT emissions) Also, MSATs will be lower in other locations when traffic
shifts away from them However, on a regional basis, EPA's vehicle and fuel regulations,
coupled with fleet turnover will, over time, cause substantial reductions that, in almost all
cases, will cause region-wide MSAT levels to be significantly lower than today
9.0 Burning of Debris
During construction of the proposed project, all materials resulting from clearing and
grubbing, demolition or other operations will be removed from the project, burned or
otherwise disposed of by the Contractor Any burning done will be done in accordance
with applicable local laws and ordinances and regulations of the North Carolina SIP for
air quality in compliance with 15 NCAC 2D 0520 Care will be taken to insure burning
will be done at the greatest distance practical from dwellings and not when atmospheric
conditions are such as to create a hazard to the public Burning will be performed under
constant surveillance Also during construction, measures will be taken to reduce the
dust generated by construction when the control of dust is necessary for the protection
and comfort of motorists or area residents This evaluation completes the assessment
requirements for air quality of the 1990 Clean Air Act Amendments and the NEPA
process, and no additional reports are necessary ,
10 0 Summary
Vehicles are a major contributor to decreased air quality because they emit a variety of
pollutants into the air Changing traffic patterns are a primary concern when determining
the impact of a new highway facility or the improvement of an existing highway facility
New highways or the widening of existing highways increase localized levels of vehicle
emissions, but these increases could be offset due to increases in speeds from reductions
in congestion and because vehicle emissions will decrease in areas where traffic shifts to
the new roadway Significant progress has been made in reducing criteria pollutant
emissions from motor vehicles and improving air quality, even as vehicle travel has
increased rapidly
The project is located in Ashe County, which complies with the National Ambient Air
Quality Standards This project will not add substantial new capacity or creating a
facility that is likely to meaningfully increase emissions Therefore it is not anticipated
to create any adverse effects on the air quality of this attainment area
9
APPENDIX 9
Comments Received from Federal,
State, and Local Agencies
t
f
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yr d... SrnrF
- A u
North Carolina
R GCcc: I V E 101' 416(1 Of Hj('i14Ways
rC r 1 r Zap
t7rvc??ns;t „c.tlo?
Department of Administration P tewopm stand
En"m mental Analyses Branch
Michael F Easley, Governor Britt Cobb, Secretary
October 15, 2007
Mr Gregory Thorpe
N C Dept of Transportation
Project Dev & Env Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
Dear Mr Thorpe
Re SCH File # 08-E-4220-0082, EA, Proposed Widening of NC 88 from US 221 Business in
Jefferson to NC 194 an Ashe County, TIP 4U-3812
The above referenced environmental impact information has been submitted to the State Clearinghouse
under the provisions of the National Environmental Policy Act According to G S 11)A-10, when a
state agency is required to prepare an environmental document under the provisions of federal law, the
environmental document meets the provisions of the State Environmental Policy Act Attached to this
letter for your consideration are the comments made by agencies in the course of this review
If any further environmental review documents are prepared for this project, they should be forwarded to
this office for intergovernmental review
Should you have any questions, please do not hesitate to call
Sincerely,
a•
Attachments
cc Region D
Mailing Address
1301 Mail Service Center
Raleigh, NC 2 7699- 1 30 1
Ms Chrys Baggett
Environmental Policy Act Coordinator
Telephone [phone]
Fax [phone]
State Courier 451 01 00
e moll Chrvs Bnggett @ncmod net
Location Address
I t6 West loves Street
Raleigh North Carolina
An Equal Oppo'f may/Ajfirmatrve Anon Employer
-;A"
NCDENR
North Carolina Department of Environment and Natural Resour-es
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NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
STATE NUMBER 08-E-4220-0082
DATE RECEIVED 09/14/2007
AGENCY RESPONSE 10/09/2007
REVIEW CLOSED 10/14/2007
CLEARINGHOUSE COORD
REGION D COG
P 0 BOX 1820
BOONE NC
REGION D
REVIEW DISTRIBUTION
CC&PS - DEM, NFIP
DENR LEGISLATIVE AFFAIRS
DEPT OF AGRICULTURE
DEPT OF CUL RESOURCES
DEPT OF TRANSPORTATION
REGION D COG

r r,
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PROJECT INFORMATION
APPLICANT N C Dept of Transportation
TYPE National Environmental Policy Act
ERD Environmental Assessment
DESC Proposed Widening of NC 88 from US 221 Business in Jefferson to NC 194 in Pshe
C^e-ty, TIP #U-3812
CPJSS-REFERENCE NUMBER 02-E-4220-0344
Toe attacnieo project has been submitted to the N C State Clearinghouse for
in-ergo,,ernmental review Please review and submit your response by the aoove
i-ici_atec date to 1301 Mail Service Center, Raleigh NC 27699-1301
if acd t-oval review time is needed, please contact this office at [phone]
,?S -A '-ESi-T OF THIS REVIEW ThE FOLLOWING IS SUBMITTED
U NG COMMENT
IV `OMMENTS L\TTkCHED
DATE / -67
F02
REQUEST FOR REVIEW
Please review the attached notification and indicate your response If your agency requires additional information, contact the
applicant directly or call High Country Council of Governments' Clearinghouse Please submit your response to the address below by
the due date indicated
Phone [phone]

'r
r
SCH Number 08-E-4220-0082 Date 09-20-07 Response Date 10-05-07
Please Sign and Return
This Page Only To
High Country Council of Governments
Clearinghouse Coordinator
P O Box 1820
Boone, NC 28607
1 / ?'?YR
ric r
Reviewers
Cathy Howell, Town Manager, Town of Jefferson
Dan k1cMillan Ashe County Manager
lztspollst This agency has reviewed the notification and offers the following recommendation (Check appropriate
response/more than one can be checked)
\,i Comment
F n or ible
The project is in agreement with the goals and objectives of this agency s programs
t nla? orable The project is not in agreement with the goals and objectives of this agency s programs
PotLlit i-1l Problem (s) Identify
C nmments
Re%iewed br
hJme
yr! , /7:` ??,,y?r1JF
?n
r?
Agency
Date
i=
k

REQUEST FOR REVIEW

Pl,,ase ievtew the attached notification and indicate your response If your agency requires additional information, contact the
applicant directly or call High Country Council of Governments Clearinghouse Please submit your response to the address below by
the due date indicated
Phone [phone]
SCH Number 08-E-4220-0082 Date 09-20-07 Response Date 10-05
Please Sign and Return
This Page Only To
High Country Council of Governments
Clearinghouse Coordinator
P O Box 1820
Boone, NC 28607 '-??-
-
Al
? r
nr c.r
1i1r J t ? JJl
Reviewers vl?
Cathv Howell, Town Manager, Town of Jefferson
A Dan McMillan, Ashe County Manager _
?J
S
Response This agency has reviewed the notification and offers the following recommendation (Check appropriate
t response/more than one can be checked)
No Comment
I i%orable The project is in agreement with the goals and objectives of this agency's programs
l ntdN arable The project is not m agreement with the goals and objectives of this agency's programs
Potential Problem (s) Identify
C nmments
i
3
Re% iewed by
Name Agency Date
? )A-7
l01
US ENVIRONMENTAL PROTECTION AGENCY
REGION 4 RALEIGH OFFICE
TERRY SANFROD FEDERAL COURTHOUSE
310 NEW BERN AVENUE
RALEIGH, NORTH CAROLINA 27601
Date October 11, 2007
Dr Gregory J Thorpe, PhD
Manager, Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
SUBJECT EPA Review Comments of the Federal Environmental Assessment and
Draft Section 4(0 Evaluation for U-3812, NC 88 Improvements, Jefferson,
Ashe County
Dear Dr Thorpe
The U S Environmental Protection Agency Region 4 (EPA) has reviewed the
subject document and is commenting 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 (FHWA) are proposing various improvements to NC 88 from NC 194 to
US 221 Business in Jefferson, Ashe County for an approximate distance of 1 6 miles
The proposed project has been in the NEPA/Section 404 Merger 01 process and
EPA notes the following concurrence point (CP) milestones CP 1 Purpose and Need
signed 12/13/01, CP 2 Alternatives to be Camed Forward for Detailed Study signed
3/15/05, and CP 2A Bridging and Alignment Review also signed 3/15/05
The Merger 01 team concurred on four build alternatives for detailed study
Alternatives 1, 2 and 3 all widen the roadway to at least 3 lanes with a shoulder section in
the rural western portion of the project Alternative 1 maintains the shoulder section
throughout and Alternatives 2 and 3 utilize a 3-lane and 5-lane curb and gutter section,
respectively, in the eastern `urban' portion of the project NCDOT developed Altemativ e
4, the safety improvement alternative, that includes 3-lanes in the urban section and
realignment of an S-curve and the intersection of NC 88 and NC 194 Alternative 4 was
developed by NCDOT when it was determined that capacity improvements were not
specifically warranted for the more rural portion of the project study area
EPA will concur with NCDOT's recommendation for Alternative 4 being the
`Least Environmentally Damaging Practicable Alternative - LEDPA' (Preferred), w hick
greatly reduces impacts to terrestrial and aquatic resources and reduces or avoids man} of
the human resource environmental impacts Estimated impacts to junsdictional stre,ims
and wetlands for Alternative 4 are 920 linear feet and 0 1 acres, respectively
Little Buffalo Creek, classified "Class C waters, Tr +", its unnamed tributaries
(UT's) and UT's of Naked Creek, classified "Class C waters +", will be impacted by the
proposed project These streams eventually flow to the New River, a nationally
designated Wild and Scenic River Despite the "+" classification of these waters, which
identifies waters subject to a special management strategy to protect downstream
Outstanding Resource Waters (ORW), both Little Buffalo Creek and Naked Creek below
the Town of Jefferson's Wastewater Treatment Plant (east of the project) are listed on the
303(d) list of impaired waters Due to the current impairment and downstream sensitive
resources, EPA is requesting that NCDOT consider the highest quality sediment and
erosion control measures The use of the most recent `expenmental/mountain' Best
Management Practices (BMPs) as was presented to the Merger Interagency
representatives on September 27, 2007, is a possible example of the strict soil erosion and
control measures that might be needed The NCDOT-funded research to North Carolina
State University includes the use of `coconut fiber logs', `straw wattles', `PAM' and
other innovative soil erosion and sediment control techniques to remove clays and other
fine particles from entering nearby waterways during construction
EPA will continue to stay actively involved in the Merger 01 process for this
project EPA also recommends that NCDOT and other primary agencies Consider a
combined CP 3 LEDPA and CP 4 Avoidance and minimization meeting for efficiency
and streamlining purposes EPA acknowledges the FHWA interim generic guidance on
r Mobile Source Air Toxics (MSATs) that has been included in the EA (Pages 33 to 38)
Due to the limited scope of the proposed project, its location and the existing air quality
in the project study area, EPA does not believe that MSATs are a significant
environmental issue EPA acknowledges the project environmental commitments
("Green sheets") and requests that the `Experimental/Mountain' erosion and sediment
control BMPs cited above are incorporated into the Finding of No Significant Impact
(FONSI) The updated Traffic Noise Analysis (using TNM 2 5) per the Green Sheet
commitment should also be included in the FONSI as well
EPA recognizes that the NCDOT included some relevant and excellent
photographs, tables, and figures in EA that facilitated our review and provides the public
with a much clearer understanding of the proposed project and the important
environmental resources that have been identified in the project study area Please also
include Ms Kathy Matthews of EPA's Wetlands Section for future coordination on
avoidance and minimization efforts, and hydraulic and permit review meetings EPA
requests a copy of the FONSI when it becomes available If you have any questions
please feel free to call me at 919-856-4206 Thank you for the opportunity to comment
jP
? ,f
M
Cc C Coleman, FHWA
S McClendon, USACE
J Hennessy, NCDWQ
Sincerely,
Christopher A Militscher, REM, CHMM
Merger Team Representative
NEPA Program Office
For Heinz J Mueller, Chief
EPA Region 4 NEPA Program Office