20091149 Ver 1_US74/NC130 Interchange (4)_20081010

Department of Environment and Natural Resources
Project Review Form
Project Number: 09-0097 County: Columbus
Due Date: 11/03/2008
Date Received: 10/07/2008
Protect Description: Proposed interchange at the instersection of US 74/NC 130 (Andrew Jackson Hwy ) and NC 242
(Hanes Lennon Hwy) in Columbus County TIP No R-4900
is Project is emg reviewed as inoicatea oeiow
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
v/ 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]
#4@4eOt'l
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Proposed Interchange at the Intersection of
US 74/NC 130 (Andrew Jackson Highway)
and NC 242 (Haynes Lennon Highway)
Columbus County
Federal Aid Project NHF-74(78)
WBS Element 40224.1.1
TIP PROJECT R-4900
ADMINISTRATIVE ACTION
FINDING OF NO SIGNIFICANT IMPACT
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
AND
N.C. DEPARTMENT OF TRANSPORTATION
Submitted Pursuant to 42 U.S.C. 4332(2)(c)
APPROVED:
% d ?--/RF"Gregory ate J. Thorpe, Ph.D., Manager
Project Development and Environmental Analysis Branch, NCDOT
9/3%g
of 'A
Date _ ?? John F. Sullivan III, P.E., Division Administrator
ederal Highway Administration
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Proposed Interchange at the Intersection of
US 74/NC 130 (Andrew Jackson Highway)
and NC 242 (Haynes Lennon Highway)
Columbus County
WBS Element 40224.1.1
TIP PROJECT R-4900
Finding of No Significant Impact
September 2008
Documentation Prepared in Protect Development and Environmental Analysis Branch by:
Kristine O. Graham, P.E.
Project flammng Engineer
Project Development
q/8/2o08
Supervisor, Eastern Region
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PROJECT COMMITMENTS
Proposed Interchange at the Intersection of
US 74/NC 130 (Andrew Jackson Highway)
and NC 242 (Haynes Lennon Highway)
Columbus County
WBS Element 40224.1.1
TIP PROJECT R-4900
COMMITMENTS DEVELOPED THROUGH PROJECT DEVELOPMENT AND DESIGN
Roadway Desien/Division 6 Construction
NCDOT will use 3 1 slopes in all wetland areas for this project
Division 6 Construction
NCDOT will minimize the clearing performed within the linuts of the ramp located in the
southwest quadrant of the interchange
R-4900 Finding of No Significant Impact Page 1 of 1
September 2008
TABLE OF CONTENTS
1. TYPE OF ACTION ...........................................................................................................1
11. DESCRIPTION OF PROPOSED ACTION ...................................................................1
III. PREFERRED ALTERNATIVE .......................................................................................2
IV. SUMMARY OF IMPACTS ..............................................................................................2
V. ACTIONS REQUIRED BY OTHER AGENCIES .........................................................4
VI. COORDINATION AND COMMENTS ..........................................................................5
A Circulation of the Environmental Assessment (EA) 5
B Comments Received on the EA 5
1 U S Environmental Protection Agency 5
2 U S Fish & Wildlife Service 11
3 NC Division of Environmental Health 11
4 NC Wildlife Resources Commission 12
5 NC Division of Water Quality 12
C Public Involvement 16
VII. REVISIONS TO ENVIRONMENTAL ASSESSMENT .............................................. 17
A Purpose and Need 17
B Development of Alternatives 17
C Avoidance and Minimization 17
VIII. ADDITIONAL INFORMATION .........................................................
......................... 19
A 11
Merger Process Coordination 19
B Air Quality - Mobile Source Air Toxics 19
IX. ONLY PRACTICABLE ALTERNATIVE FINDING ................................................. 20
X. BASIS FOR FINDING OF NO SIGNIFICANT IMPACT .......................................... 21
TABLES
Table 1 R-4900 Resource Impacts
APPENDICES
Appendix A Figures
• Figure 1 Vicinity Map
• Figure 2 Potential Prime Farmland Impacts
Appendix B Comments from Federal, State, and Local Agencies
Appendix C Merger Process Forms
3
Appendix D USFWS Concurrence Letter

Proposed Interchange at the Intersection of
US 74/NC 130 (Andrew Jackson Highway)
and NC 242 (Haynes Lennon Highway)
Columbus County
WBS Element 40224.1.1
TIP PROJECT R-4900
FINDING OF NO SIGNIFICANT IMPACT
Prepared by the Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1. TYPE OF ACTION
This is a Federal Highway Administration (FHWA) admunistrative action, Finding
of No Significant Impact (FONSI)
The FHWA has determined this protect will not have any significant impact on
the environment This FONSI is based on the Federal Environmental Assessment (EA),
which has been independently evaluated by the FHWA and determined to aiiequately and
accurately discuss the environmental issues and impacts of the proposed project The EA
provides sufficient evidence and analysis for determining that an Environmental Impact
Statement is not required The FHWA takes full responsibility for the accuracy, scope,
and content of the EA
II. DESCRIPTION OF PROPOSED ACTION
The NCDOT, in consultation with the Federal Highway Administration (FHWA),
• proposes to convert an existing at-grade intersection to an interchange at the intersection
of US 74/NC 130 and NC 242 near Evergreen in Columbus County The total length of
the project is approximately at 0 8 mile The existing intersection will be upgraded to a
modified diamond configuration interchange with ramps and loops located in the
• northeast and southwest quadrants A new 235-foot long, 40-foot wide bridge will be
constructed over US 74

According to the approved 2009-2015 State Transportation Improvement Program
(STEP), right-of-way acquisition for the project is scheduled to begin in Federal Fiscal
Year (FFY) 2009, with construction to begin in FFY 2010 The current estimated total
cost is approximately $10,434,000, which includes $70,000 for right-of-way acquisition,
$9,700,000 for construction, and $664,000 for nutigation
M. PREFERRED ALTERNATIVE
Several alternatives were evaluated in the EA, including the "no-build"
alternative, a standard diamond configuration interchange, and a modified diamond
configuration interchange The modified diamond alternative was shown at the public
hearing as the preferred alternative due to the fact that it impacts the least amount of
wetlands and surface waters while still providing the necessary transportation and safety
improvements
IV. SUMMARY OF IMPACTS
Adverse impacts to the human and natural environments were nummized for the
proposed project through alternative -selection and design shifts within the two build
alternatives No adverse effect on the air quality of the surrounding area is anticipated as
a result of the project The proposed project will not adversely impact any historic
structures eligible for or listed on the National Register of Historic Places or any known
archaeological sites eligible for listing in the National Register The project will not
involve any relocation of residences or businesses The project will impact
approximately 9 40 acres of wetlands and 366 linear feet of streams No Environmental
Justice issues were identified The Biological Conclusions for the wood stork is May
affect-Not likely to Adversely Affect Table 1 below gives a comprehensive list of
resources and the impacts associated with each
2
Table 1: R-4900 Resource Impacts
Resource Impacts
Length 0 8 mile
Railroad Crossings 0
Schools 0
Recreational Areas and Parks 0
Churches 0
Cemeteries 0
Major Utility Crossings 0
-
National Register Eligible Properties 0
Archaeolo cal Sites 0
Federally Listed Species within Corridor 1*
100-Year Flood lam Crossings I
Prime Farmland 74 4 acres
Terrestrial Forest Impacts 13 4 acres
Residential Relocations 0
Business Relocations 0
Hazardous Material Sites 0 `
Wetland Impacts 9 4 acres
Stream Crossings I
Stream Impacts 366 linear feet
Water Supply Watershed Protected Areas 0
Substantial Noise Impacts 0
Wildlife Refuges and Game Lands 0
Section 4(f) Impacts (Historic) 0
Low Income Population Impacts None
Minority Population Impacts None
Construction Cost $9,700,000
Right-of-Way Cost $70,000
Mitigation Cost $664,000
Total Project Cost $10,434,000
* This project may affect, but is not likely to adversely affect the wood stork
3

r r
•
•
V. ACTIONS REQUIRED BY OTHER AGENCIES

An Individual Pernut will be required from the U S Army Corps of Engineers •
due to impacts to jurisdictional wetlands and surface waters
A Water Quality Certification is required from the North Carolina Division of
Water Quality Section

4

VI. COORDINATION AND COMMENTS
A. Circulation of the Environmental Assessment (EA)
The FHWA approved the EA on March 13, 2008 The approved EA was
circulated to the following federal, state, and local agencies for review and comments
An asterisk (*) indicates a written response was received from the agency Copies of the
correspondence received are included in Appendix B of this document Responses to
substantial comments are noted below in Section B
U S Army Corps of Engineers - Regulatory Division -
* U S Environmental Protection Agency
* U S Fish and Wildlife Service
National Marine Fisheries Service
N C Department of Cultural Resources - Division of Archives and History
N C Division of Coastal Management
* N C Division of Environmental Health
N C Division of Marine Fisheries
* N C Division of Water Quality
N C State Clearinghouse
* N C Wildlife Resources Commission
B. Comments Received on the EA
1. U.S. Environmental Protection Agency
COMMENT: "EPA is recommending that NCDOT and FHWA consider an EA Re-
evaluation before a final NEPA decision is made EPA has substantial
environmental concerns regarding the magnitude of impacts to
jurisdictional wetlands and streams in light of the limited scope of this
proposed project Avoidance and minimization efforts under Section
404(b)(1) Guidelines have not been adequately demonstrated We
recommend that tins project be placed into the NEPA/Section 404
Merger 01 process at Concurrence Point 1 (Purpose and Need) "
RESPONSE: NCDOT met with the FHWA, USACE, and DWQ in October 2007 At
that time, the team agreed that the project did not need to go through the
Merger process NCDOT plans to examine and respond to all of the
EPA's comments thoroughly Significant effort was made to avoid and
minimize impacts to the wetlands on this project without comprorrusmg
the safety or the utility of the design, including changing the original
5
design from a standard interchange to a modified diamond Given that
this intersection is not only listed in the North Carolina Highway Safety
Improvement Program, but that it has the highest seventy index and
number of crashes of all listed intersections in Columbus County, the
need for this project in terms of safety improvements is evident
COMMENT: "Based upon a three year crash and safety analysis performed between
2002 and 2005, this intersection experienced 11 total crashes (no
fatalities) with 8 of the 11 being angle crashes The EA does not provide
a comparison to a statewide average for a similar facility "
RESPONSE: Comparisons to the Statewide Crash Average for crash rates at
intersections do not exist This data is only available for individual
sections of roadway
COMMENT: "The EA does not provide a traffic comparison to other intersections and
interchanges along US 74 (e g , the intersection of Strawberry Boulevard
and US 74 INC 130 in Columbus County, the intersection of Macedonia
Church Road and US 74/NC 130 in Columbus County or the intersection
of US 74 and NC 130 and NC 72 in Robeson County) Table 4 is not
compared to other sirrular type facilities and improvements so it is
difficult for EPA to understand the significance the traffic measure in
passenger cars/nule/lane between 2005 and 2030 when compared to the
`No-build' or other alternatives The traffic information concenung the
`seconds/vehicle' at the different turning movements between 2005 and
2030 does not provide a substantial justification for the project This
data is not compared to any other intersection or interchange along
US 74 so its significance can not be measured against other comparative
locations "
RESPONSE: The capacity analysis in the EA was meant to provide justification for
the project Its purpose was to show the secondary benefits that an
interchange would have on capacity
COMMENT: "From a traffic flow standpoint, EPA is unclear as to why the 2005/2030
projections for NC 242 increase from 1,200 vpd in 2005 to 2,100 vpd in
2030 but the US 74 mainline (i e, The Strategic Highway Comdor-
SHC) does not increase as much (i e, 11,000 vpd to 19,000 vpd) EPA
would expect that the increases along the SHC #24 (US 74) would be
much greater than a rural, two-lane intersecting roadway "
RESPONSE: The actual increase in vehicles per day (vpd) along US 74/NC 130 is
8,000 versus a 900 vpd increase for NC 242
COMMENT: "EPA does not fully understand how traffic along NC 242 is expected to
increase from 1,200 vpd to 2,100 vpd when the overall population trend
6
is not increasing in rural areas of North Carolina and Columbus
County "
RESPONSE: The traffic on NC 242 is mainly through traffic which does not originate
in Evergreen/Columbus County and is independent of the population
trends in this area Due to the population growth in North Carolina in
general and the growing popularity of North Carolina's coastal areas for
tourists, it is logical that through traffic in this area would be increasing
COMMENT: "Local transportation officials note that the US 74/1-74 initiative is not
likely to occur during the current planning horizon, and therefore, this
proposed action should be sevarated from decision-making on the I-74
corridor EPA does not concur with this finding and that the proposed
project should be evaluated for independent utility and as part of the
entire SHC "
RESPONSE: US 74 between Charlotte and Wilmington is designated as Strategic
Highway Corridor (SHC) # 24 The entire corridor is as follows
US 74 between I-277 in Charlotte (Mecklenburg County) to the
Cape Fear Memorial Bridge in Wilmington (New Hanover
County)
This corridor connects the Charlotte-Monroe area, Rockingham,
Lumberton, and Wilmington, a length of approximately 198 miles US
74 between Rockingham and Bolton is part of Congressional High
Priority Route # 5, connecting Michigan to South Carolina (Interstates
73/74) and is designated as a future interstate This corridor is also the
primary route for motorists traveling between the beaches and ports in
the Wilmington area, North Carolina's largest city (Charlotte), and
beyond to the North Carolina mountains US 74 is ultimately envisioned
as a Freeway, according to the SHC Vision Plan
The decision to upgrade this intersection to an interchange conforms to
the vision for this Strategic Highway Corridor Though there are no
projects currently denoted in the STIP to upgrade this section of US 74
to an interstate, NCDOT plans to improve the access points as funding
becomes available
COMMENT: "The EA does not provide a specific comparison to other intersections
between the interchange at NC 41 in Robeson County and the US
74/NC130-US 76 split northeast of Chadbourn "
RESPONSE: The main motivation behind the choice of this particular intersection is
the safety concern Not only is the US 74/NC 130 and NC 242
intersection included in the North Carolina Highway Safety
7
Improvement Program (NCHSIP), it has the highest number of crashes
and greatest seventy index of all intersections on US 74 in both
Columbus and Robeson Counties Three other intersections on US 74
are included in the NCHSIP, including NC 211, SR 1574 (Strawberry
Boulevard), and SR 2210 (Old Kingsdale Road), but neither of these
have an equivalent number of crashes or seventy index The project has
independent utility and improvements to address the safety problem are
appropriate
COMMENT: "In EPA's review of the traffic data, both the current and future
conditions, a full diamond interchange was not justified based on an
acceptable LOS for eastbound and westbound turning movements (2005
LOS A & 2030 LOS B) and potentially increased project costs "
RESPONSE The primary purpose of putting an interchange at this location was to
increase the safety of the traveling public, not to increase capacity
Though this interchange will improve the traffic flow in this area, the
project was not justified solely on the basis of capacity needs
COMMENT: "The evaluation of a full range of alternatives was not provided in the
EA, including other traffic system management (TSM) measures (e g ,
Full signalization), increased turning lane options, improved line-of-
sight options and roadway improvements for NC 242 and US 74
NCDOT should examine what other improvements could be made to
address these deficiencies without constructing an entire new
interchange "
RESPONSE: US 74 is a Strategic Highway Corridor (SHC) and the vision for this
highway is to upgrade it to a freeway Several options, including
signalization and traffic calming techniques, were considered as
potential alternatives to construction, but were dismissed as viable
options because they would not permanently solve the safety problem
In addition, they were not in line with the long term vision for this
facility
COMMENT: "The EA did not provide a `systemic' evaluation of nearby traffic routes
and other intersections along US 74/NC 130 that would represent a
comparative analysis for other potential interchange locations that would
have potentially less environmental (i e , natural resource) impacts "
RESPONSE: Because the US 74 facility has not been fully funded for an upgrade to
interstate standards, smaller individual projects have been prioritized to
address the more immediate needs of this facility In this case, the high
number of accidents at this US 74/NC 130 and NC 242 intersection were
determined to be urgent The project as currently scoped is meant to
8
correct a safety problem, yet not preclude the future improvements that
will convert this stretch of US 74 into an interstate
COMMENT: "EPA does not agree that the preference for a modified diamond
interchange over a standard or full diamond interchange is substantiated
`avoidance and nummization' (i e , 9 4 acres of wetlands and 366 linear
feet of stream impact vs 12 7 acres of wetlands and 119 linear feet of
stream impact, respectively) EPA requests that NCDOT and FHWA
consider and exarrune a full range of reasonable alternatives prior to
making a NEPA decision "
RESPONSE: For this particular project, the modified diamond and standard diamond
alternatives were the only reasonable and feasible alternatives that would
meet the necessary design standards required by FHWA
COMMENT: "Terrestrial forest impacts are not included in either Table S-1 or Table
1 EPA also notes that the Coastal Plain Bottomland Hardwoods,
Cypress-Gum Swamp and Pine Flat are included in the estimates (i e,
142, 2 15, and 6 74 acres, respectively) EPA cannot ascertain the
difference between the summation of these wetland type forest
communities and the projected jurisdictional wetland impacts of 9 4
acres "
RESPONSE: There will be 13 4 acres of terrestrial forest impacts within the project
limits
COMMENT: "There is no Farmland Protection Policy Act (FPPA) analysis
concerning potential impacts to farmlands that may be prime, unique or
of statewide or local importance EPA requests that- a prime farmland
analysis per FPPA and Title 7 Code of Federal Regulations (CFR) Part
657 be performed "
RESPONSE: A prime farmland analysis has been performed by NCDOT's Human
Environment Unit and is included in Appendix A (see Figure 2) The
analysis indicates that the total acreage of potentially affected prime
farmland in the project study corridor is 45 01 acres However, the
actual impact to prime farmland will be significantly less than this since
the construction footprint is much smaller than the study area corridor
COMMENT: "EPA notes that there may be an effect (May Affect-Not Likely to
Adversely Affect) on the endangered Wood Stork (Mycterca americana)
According to the U S Fish and Wildlife Service (FWS) representative,
NCDOT had not asked for a concurrence on this determination This
determination and consultation with FWS should be completed before a
final NEPA decision is made for the proposed project "
9
RESPONSE: Comment noted This will be performed by the Natural Environment
Unit
COMMENT: "Considering the scope of the proposed project, EPA has substantial
environmental concerns for impacts to jurisdictional waters of the U S
EPA disagrees with the statement on Page 30 of the EA that, `avoidance
of the stream and wetlands is not possible due to the presence of these
resources in all quadrants surrounding the US 74/NC 130 and NC 242
intersection "
RESPONSE: Comment noted More details are given in Section VII C of this FONSI
COMMENT: "Regarding the discussion on minimization on Page 30, EPA does not
believe that NCDOT has demonstrated compliance with Section
404(b)(1) Guidelines The EA does not discuss the minimization efforts
to bridge wetlands, utilize engineering controls such as retaining walls or
the steepening of side slopes in wetland areas "
RESPONSE: Comment noted More details are given in Section VII C of this FONSI
COMMENT: "The discussion concerning compensatory mitigation is also vague and
not consistent with Section 404(b)(1) Guidelines (Page 34 " will be
requested [EEP] to provide off-site mitigation to satisfy the federal
Clean Water Act compensatory mrtrgatron requirements for this project
if necessary ") EPA could not ascertain any reason why compensatory
mitigation would not be necessary for 9 4 acres of jurisdictional wetland
impacts "
RESPONSE: Comment noted
COMMENT: "EPA recommends that NCDOT and FHWA consider re-evaluating the
transportation benefits of this project as currently designed versus the
significant impacts to jurisdictional wetlands and streams "
RESPONSE: Comment noted By upgrading this intersection to an interchange,
NCDOT will be improving the safety conditions faced by the traveling
public at this location This site has a history of collisions and resultant
injuries and needs improvement NCDOT will mitigate for the impacted
wetlands and streams
COMMENT: "EPA does not concur with the decision concerning indirect and
cumulative impacts in Section 3 g of the EA EPA requests that this
issue be further examined by NCDOT before a final NEPA decision is
made "
10
RESPONSE: Comment noted Indirect and cumulative impacts for this project are
being reevaluated by the Human Environment Unit and will be included
as part of the permit application
2. U. S. Fish & Wildlife Service
COMMENT: "For a project of this scope, 9 4 acres of wetland impacts is significant
However, it appears that the recommended alternative (modified
diamond interchange) and efforts to avoid and minimize impacts to
wetlands have reduced the impact to the extent practical"
RESPONSE: Comment noted
COMMENT: "Since the project area is already affected by the existing intersection,
wildlife habitat impacts will be limited to the direct loss within the
project footprint No significant additional habitat fragmentation effects
are expected "
RESPONSE: Comment noted
COMMENT: "There are six federally protected species listed for Columbus County -
red-cockaded woodpecker (Picoides borealis), wood stork (Mycteria
Americana), shortnose sturgeon (Acipenser brevirostrum), Waccamaw
silverside (Menidia extensa), Cooley's meadowrue (Thalictrum cooleyi),
and rough-leaved loosestnfe (Lysimachia asperulaefolia) NCDOT has
determined that the project will have no effect on all these species
except the wood stork NCDOT has determined that the project may
affect, but is not likely to adversely affect the wood stork The Service
has not yet been requested to concur with this determination At this
time we do not have any concerns regarding federally listed species "
RESPONSE: NCDOT has requested and received concurrence from the USFWS on
the determination of effect on the wood stork (See Appendix D)
COMMENT: "The Service believes that this FEA adequately addresses the existing
fish and wildlife resources, the waters and wetlands of the United States,
and the potential impacts of this proposed project on these resources "
RESPONSE: Comment noted
3. NC Division of Environmental Health
COMMENT: "If existing water lines will be relocated during the construction, plans
for the water line must be submitted to the Division of Environmental
11
Health, Public Water Supply Section, Technical Services Branch, 1634
Mail Service Center, Raleigh, North Carolina 27699-1634, (919) 733-
2321 "
RESPONSE: Comment noted
4. NC Wildlife Resources Commission
COMMENT: "During final design NCDOT should consider options such as reducing
median widths, steepened side slopes, and `tightening' acceleration and
deceleration ramps to minimize impacts to stream and wetlands where
practicable At this time we concur with the EA for this project "
RESPONSE: Comment noted _ _
5. NC Division of Water Ouality
COMMENT: "This project is being planned with input from DWQ and other resource
agencies As a participating team member, the NCDWQ will continue
to work with the team "
RESPONSE: Comment noted
COMMENT: "Cow Branch is class C, Sw, waters of the State DWQ is concerned
with sediment and erosion impacts that could result from this project
DWQ recommends that highly protective sediment and erosion control
BMPs be implemented to reduce the risk of nutrient runoff to these
waters DWQ requests that road design plans provide treatment of the
storm water runoff through best management practices as detailed in the
most recent version of NC DWQ Stormwater Best Management
Practices "
RESPONSE: Comment noted Best management practices are a standard procedure
for NCDOT designs
COMMENT: "Environmental assessment alternatives should consider design criteria
that reduce the impacts to streams and wetlands from storm water
runoff These alternatives should 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 basins, etc "
12
RESPONSE: As more detailed design is developed, NCDOT will be better suited to
incorporate Best Management Practices into the design
COMMENT: "After the selection of the preferred alternative and pnor 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: Comment noted Through the meetings with decision agencies and the
decision to modify the project design, NCDOT has shown its efforts to
avoid and minirnize impacts to wetlands and streams
COMMENT: "In accordance with the Environmental Management Commission's
Rules { 15A 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 designed
to replace appropriate lost functions and values The NC Ecosystem
Enhancement Program may be available for use as stream mitigation "
RESPONSE: If mitigation is required, NCDOT will consider onsite mitigation options
or will coordinate with the NC Ecosystem Enhancement Program for use
as stream mitigation
COMMENT: "Future documentation, including the 401 Water Quality Certification
Application, should continue to include an itemized listing of the
proposed wetland and stream impacts with corresponding mapping "
RESPONSE: This information will be included in the permit application
COMMENT: "DWQ is very concerned with sediment and erosion impact that could
result from this project NCDOT should 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: Please see pages 27-31 of the EA regarding potential impacts to aquatic
communities, wetlands and streams and the procedures NCDOT uses to
avoid, nururruze, and mitigate impacts to them
COMMENT: "An analysis of cumulative and secondary impacts anticipated as a result
of this project is required The type and detail of analysis should
13
conform to the NC Division of Water Quality Policy on the assessment
of secondary and cumulative impacts dated April 10, 2004 "
RESPONSE: Page 19 of the EA gives a qualitative explanation of indirect and
cumulative impacts More details will be submitted as part of the permit
application
COMMENT: "NCDOT is respectfully reminded that all impacts including but not
limited to, bridging, fill, excavation and clearing, to jurisdictional
wetlands, 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
COMMENT: "Where streams must be crossed, the DWQ prefers bridges used in lieu
of culverts However, we realize that economic considerations often
require the use of culverts Please be advised that culverts should 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: Comment noted The currently proposed alignment of the interchange
will avoid the existing culvert under US 74, therefore, no improvements
will be necessary
COMMENT: "Sediment and erosion control measures should not be placed in
wetlands or streams "
RESPONSE: Comment noted
COMMENT: "The 401 Water Quality Certification application will need to
specifically address the proposed methods for stormwater management
More specifically, stormwater should not be permitted to discharge
directly into streams or surface waters "
RESPONSE: The application will address the proposed methods for stormwater
management Stormwater will not be pernutted to discharge directly
into streams or surface waters
COMMENT: "Based on the information presented in the document, the magnitude of
impacts to wetlands and streams may require an individual permit
application to the Corps of Engineers and corresponding 401 Water
14
Quality Certification Please be advised that a 401 Water Quality
Certification requires 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 subrmttal 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 mimmization 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
COMMENT: "If concrete is used during construction, a dry work area should be
maintained to prevent direct contact between curing concrete and stream
water Water that inadvertently contacts uncured concrete should not be
discharged to surface waters due to the potential for elevated pH and
possible aquatic life and fish kills "
RESPONSE: Comment noted
COMMENT: "If temporary access roads or detours are constructed, the site shall be
graded to its preconstruction contours and elevations Disturbed areas
should be seeded or mulched to stabilize the soil and appropriate native
woody species should be planted When using temporary structures the
area should be cleared but not grubbed Clearing the area with chain
saws, mowers, bush-hogs, or other merchandized equipment and leaving
the stumps and root mat intact allows the area to revegetate naturally and
nunmuzes soil disturbance "
RESPONSE: Comment noted
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
COMMENT: "Heavy equipment should be operated from the bank rather than in
stream channels in order to mininuze sedimentation and reduce the
likelihood of introducing other pollutants into streams This equipment
should be inspected daily and maintained to prevent contarnmation of
surface waters from leaking fuels, lubricants, hydraulic fluids, or other
toxic materials "
15
RESPONSE: Comment noted
COMMENT: "Riprap should not be placed in the active thalweg channel or placed in
the streambed in a manner that precludes aquatic life passage
Bioengineenng boulders or structures should be properly designed, sized
and installed "
RESPONSE: Comment noted
COMMENT: "Riparian vegetation (native trees and shrubs) should be preserved to the
maximum extent possible Riparian vegetation must be reestablished
within the construction limits of the project by the end of the growing
season following completion of construction "
RESPONSE: Comment noted ,
C. Public Involvement
Following the circulation of the Environmental Assessment, an informal
combined Public Hearing was held on May 27, 2008 at Evergreen Elementary School in
Evergreen, NC Approximately 19 citizens were present for the hearing, the majority of
whom expressed support for this project Verbal feedback from local residents present at
the hearing provided compelling evidence of the high number of dangerous collisions that
occur at this location
16

• VII. REVISIONS TO ENVIRONMENTAL ASSESSMENT
A. Purpose and Need
• The primary purpose of the project is to improve the safety at this intersection
From April 2005 to March 2008, this intersection experienced thirteen total crashes, none
of which were fatal Of the thirteen reported crashes, ten were angle crashes In addition,
the intersection of US 74/NC 130 and NC 242 is listed in the North Carolina Highway
• Safety Improvement Program (HSIP) as-the most potentially hazardous intersection in
. Columbus County and the 13th most potentially hazardous intersection in the state with a
seventy index of 20 9 and a total of 39 crashes in the last ten years The Highway Safety
Improvement Program focuses on potentially hazardous locations and hazardous features
• analysis Every two years, NCDOT produces a Potentially Hazardous Location listing to
inventory hazardous locations on North Carolina roads These locations are submitted to
field engineers for on-site investigation, further analysis, and recommendation of
engineering countermeasures to address the safety problems Included in the safety
• program are locations with crashes involving intersections, interchanges, bridges,
pedestrians, wet pavement conditions, and night-time crashes

• B. Development of Alternatives
US 74 is a Strategic Highway Corridor The vision for this highway is to upgrade
it to a freeway Several options, including signalizauon and traffic calming techniques
were considered as potential alternatives to construction, but were dismissed as viable
options because they would not permanently solve the safety problem In addition, they
were not in line with the long term vision for this facility
The alternatives were narrowed down to two different design options a standard
diamond interchange and a modified diamond interchange Both of these alternatives
would serve to improve the safety conditions at this intersection and would be in
accordance with the future plans for this facility Due to the number of wetlands that
• would be impacted under the standard diamond configuration, the modified diamond was
chosen to be the least environmentally damaging practicable alternative
C. Avoidance and Minimization

Avoidance

As noted in the Environmental Assessment, complete avoidance of the stream and
wetlands is not possible due to the presence of these resources in three of the quadrants
. surrounding the US 74/NC 130 and NC 242 intersection

Signalization and traffic calming techniques were considered as potential
avoidance measures, but were dismissed as viable options because they would not
permanently solve the safety problems In addition, they were not in line with the long
term vision for this facility
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Minimization Efforts
• The standard diamond interchange was revised to a modified diamond
interchange The ramp in the northwest quadrant was eliminated to reduce
impacts to a gum-cypress swamp wetland that had a higher quality rating than the
one in the northeast quadrant The ramp in the southeast quadrant was also
eliminated in order to nunumze wetland impacts
• The alignment of the proposed interchange was shifted away from the existing
alignment in order to maintain traffic during construction and to prevent the
existing culvert under US 74 from being affected Impacting the culvert would
lead to greater impacts to the stream and adjacent wetlands
• A two span bridge is currently proposed for the interchange, as opposed to a
single span bridge A single span bridge would avoid constructability issues that
stem from placing a bridge pier in the vicinity of the existing culvert, however,
the depth of the bridge superstructure (girders) and the height of the fill would be
increased, thus increasing the horizontal footprint of the roadway fill in the
wetland areas Also, with a two span bridge, the lateral ditch to the south that
runs parallel to US 74 can be spanned
• Based upon NCDOT's site investigation, the culvert on NC 242 at Cow Branch
was used as a control to begin the construction limits The proposed roadway
improvements along NC 242 begin south of the existing culvert, which eliminates
the need for a culvert extension in this environmentally sensitive area
• Although 2 1 slopes in a wetland area are NCDOT's standard, the soils on this
site are sandy NCDOT is using 3 1 slopes in all wetland areas for this project,
which is standard practice for projects east of I-95
• The ramps and loops on this design have been tightened to reduce impacts to the
wetlands on this site
• Compensatory mitigation will be required for the wetland impacts on this project
In the STEP, $664,000 has been allotted for mitigation costs This amount is a
placeholder and does not reflect the actual cost of mitigation
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VIII. ADDITIONAL INFORMATION
A. Merger Process Coordination
NEPA/404 Merger is a process to streamline the project development and
permitting processes To this effect, the Merger process provides a forum for appropriate
agency representatives to discuss and reach consensus on ways to facilitate meeting the
regulatory requirements of Section 404 of the Clean Water Act during the NEPA/SEPA
decision-making phase of transportation projects
The Merger process allows agency representatives to work more efficiently
(quicker and comprehensive evaluation and resolution of issues) by providing a common
forum for them-to discuss and find ways to comply with key elements of their agency's
mission The merger process helps to document how competing agency mandates are
balanced during a shared decision-making process, which results in agency
representatives reaching a "compronuse based decision" to the regulatory and individual
agency mandates
The NEPA/404 Merger Team for this project is comprised of the following
agencies U S Army Corps of Engineers, U S Fish & Wildlife Service, Fnvironmental
Protection Agency, National Marine Fisheries Service, N C Division of Water Quality,
N C Wildlife Resources Commission, N C State Historic Preservation Office, Lumber
River RPO, and N C Department of Transportation
Although this project was not originally placed in the Merger process, it was
decided by members of the Merger Team to place this project in at Point 4A due to the
significant number of wetland impacts A NEPA/ 404 Merger Team Meeting to reach
concurrence on Concurrence Point 4A, Avoidance and Minimization, and Concurrence
Point 4B, the 30% Hydraulic Review, was held on August 20, 2008 The immnuzation
efforts agreed to are listed in Section VII C of this document
B. Air Ouality - Mobile Source Air Toxics
Concerns for air toxics impacts are beconung 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 asses 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
linutations 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
19

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 (as according to
USDOT's Federal Highway Administration memorandum, "Interim Guidance on Air
Toxic Analysis in NEPA Documents," from February 3, 2006) 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 as an addendum to the project Air
Quality Analysis report, which can be viewed at the PDEA Branch Office on the 4t' floor
of the NCDOT Transportation Building in downtown Raleigh at 1 South Wilmington
Street
IX. ONLY PRACTICABLE ALTERNATIVE FINDING
Executive Order 11990, "Protection of Wetlands," established as a national policy
to avoid, to the extent possible, adverse impacts on wetlands and to avoid direct or
indirect support of new construction wherever there is a practicable alternative
NCDOT was unable to totally avoid wetlands because of the extent of wetlands in
the project area It was determined there is no practicable alternative to°the proposed
construction in wetlands and that the proposed action includes all practicable measures to
rrunirruze harm to wetlands which may result from such use Minimization efforts are
described in greater detail in Section VII C
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X. BASIS FOR FINDING OF NO SIGNIFICANT IMPACT
Based upon a study of the impacts of the proposed project, as documented in the
EA, and upon comments received from federal, state, local agencies, and the general
public, it is the finding of the NCDOT 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, social, ecological, cultural,
or scenic resources are expected The proposed project is consistent with local plans and
will not disrupt any communities The project has been extensively coordinated with
federal, state, and local agencies In view of the above evaluation, it has been determined
that a FONSI is applicable for this project Therefore, neither an Environmental Impact
Statement nor further environmental analysis is required
The following people may be contacted for additional information regarding this
proposal
Mr Gregory J Thorpe, Ph D
Manager
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, NC 27699-1548
[phone]
Mr John F Sullivan, III, P E
Division Administrator
Federal Highway Administration
310 New Bern Avenue, Suite 410
Raleigh, NC 27601-1418
[phone]
KOG/tmc
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Appendix A
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Appendix B
Comments from Federal, State,
and Local Agencies
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Attachment"A'
Proposed Interchange at US 74/NC 130 and NC 242
Columbus County
TIP# R-4900
Specific EA Comments
Purpose and Need
Currently, the intersection at US 741NC 130 and NC 242 is not a fully signalized
(i e , Flashing yellow lights on US 74/NC 130 and stops signs at NC 242). Page'9 of the
EA states that the current intersection is un-signalized The purpose and need for this
proposed interchange is to increase safety at this intersection and to allow for future
upgrade of US 74 to interstate standards (Page ii) The EA further describes in Section H
accidents, capacity (Level of Service-LOS) and an interstate initiative as the need for the
proposed project (Page 3)
Based upon a three-year crash and safety analysis performed between 2002 and
2005, tlus intersection experienced I ltotal crashes (no fatalities) with 8 of the 11 being
angle crashes The EA does not provide a comparison to a Statewide average for a
similar facility
The EA provides several tables concerning capacity analysis in Section E Traffic
volumes for US 74/ NC 130 are approximately 11,000 vehicles per day (vpd) in 2005 and
are forecasted to be 19,000 vpd in 2030 The EA also explains that the current
intersection is the main intersection for accessing the Town of Evergreen Current (2005)
LOS at the intersection is A, A, C and C for the main turning movements between
roadways However, 2030 projections indicate that the LOS will be B, B, F and F, with
the failing movements for the northbound and southbound turrung movements onto US
74 Table 2 also provides a in and p in conditions and delays in seconds per vehicle
The EA also provides an interchange analysis using a modified diamond
interchange (Table 3) and a modified diamond interchange ramp unction analysis (Table
4) LOS will be A for 2005 and 2030 under all conditions with a modified diamond
interchange Unfortunately, the EA does not provide a traffic comparison to other
intersections and interchanges along US 74 (e g , The intersection of Strawberry
Boulevard and US 74/NC 130 in Columbus County, the intersection of Macedonia
Church Road and US 74/NC 130 in Columbus County or the intersection of US 74 and
NC 130 and NC 72 in Robeson County) Table 4 is not compared to other similar type
facilities and improvements so it is difficult for EPA to understand the significance the
traffic measure in passenger cars/mile/lane between 2005 and 2030 when compared to the
`No-build'or other alternatives The traffic information concerning the `seconds/vehicle' at
the different turning movements between 2005 and 2030 does'not provide a substantial
justification for the project This data is not compared to any other intersection or
interchange along US 74 so its significance can not be measured against other
comparative locations
I
Figures 2A and 2B in the EA provide the estimated average annual daily traffic
(AADT) with truck, DHV and directional percentages for 2005 and 2030 From Figure
2A, it appears that there is almost twice the number turning movements at the intersection
of NC 242 and SR 1574 (Strawberry Boulevard) than there is at US 74/NC 130 and NC
242 From a traffic flow standpoint, EPA is unclear as to why the 2005/2030 projections
for NC 242 increase from 1,200 vpd in 2005 to 2,100 vpd in 2030 but the US 74 mainline
(i e , The Strategic Highway Corridor-SHC) does not increase as much (i e , 11,000 vpd
to 19,000 vpd) The 100 vpd is a substantial increase in the 2030 design year between a
multi-lane US highway (i e , A SHC) and a two lane undivided facility (i e , NC 242)
EPA would expect that the increases along the SHC #24 (US 74) would be much greater
than a rural, two-lane intersecting roadway
The project study area is extremely rural and the nearest `big town is Chadbourn,
NC The EA provides population growth in Table 5 for North Carolina, Columbus
County and Whiteville According to the EA and population characteristics presented,
Columbus County experienced a 0 4% decrease in population between 2000 and 2005
EPA does not fully understand how traffic along NC 242 is expected to increase from
1,200 vpd to 2,100 vpd when the overall population trend is not increasing in rural areas
of North Carolina and Columbus County The population of the Town of Evergreen is
estimated to be less than 2,500 persons (www Qreatschools net/city/Evei green/NC)
It is expected that some time in the future that US 74 will be upgraded to
interstate standards Part of the rationale for this proposed project is to prepare the US
74/NC 130 corridor for future designation as Interstate 74 (Page 19 of the EA) Local
transportation officials note that the US 74/1-74 initiative is not likely to occur during the
current planning horizon, and therefore, this proposed action should be seyarated from
decision-making on the I-74 comdor EPA does not concur with this finding and that the
proposed project should be evaluated for independent utility and as part of the entire
SHC The EA does not provide a specific comparison to other intersections between the
interchange at NC 41 in Robeson County and the US 74/NC 130-US 76 split northeast of
Chadbour i On NCDOTs SHC website, the I-74 Feasibility Study for Brunswick and
Columbus Counties does not include NC 242 (i proposed e a interchange and the
of the Feasibility iStudyudy
area is approximately 3-4 miles from
begins near US 701 just west of Whiteville, N C )
EPA believes that additional data and information is required to support the side purpose and need for this proposed interchange Dbefoze a final I?TEA should PA dec ? on isr
providing this information to EPA and other agencies
made for the project
Detailed Study Alternatives
The EA indicates that 3 alternatives were considered, including the`No-build'
alternative, a standard diamond configuration modified diamond was deve oped in respons a
interchange The EA states that the to the

`kgnificant number of wetlands located in the immediate protect vicinity' In EPA's review
of the traffic data, both the current and future conditions, a full diamond interchange was
not justified based on an acceptable LOS for eastbound and westbound turning
movements (2005 LOS A & 2030 LOS B) and potentially increased project costs
The evaluation of a full range of alternatives was not provided in the EA,
including other traffic system management (TSM) measures (e g, Full signalization),
increased turning lanes options, and improved line-of-sight options and roadway
improvements for NC 242 and US 74 From the photographs provided in Figure 4A, the
Facing north' photograph, there appears to be a change of elevation at US 74 (crest in the
roadway) that would make crossing traffic movements potentially unsafe However,
there could be options and alternatives that would reduce concerns for safety (i e ,
Accidents) at this intersection that were not fully considered The NCDOT recognizes
this issue on Page 11 of the EA as the proposed design speed for NC 242 will be 50 mph
due to the seventy of the horizontal curve radius and the constraints of the vertical
alignment NCDOT should examine what other improvements could be made to address
these deficiencies without constructing an entire new interchange
• The EA did not provide a `systemid evaluation of nearby traffic routes and other
• intersections along US 74/NC 130 that would represent a comparative analysis for other
potential interchange locations that would have potentially less environmental (i e ,
Natural resource) impacts The limitation of the project study area appears`to have `pre-
. determined the range of alternatives studied in detail EPA does not agree that the
preference for a modified diamond interchange over a standard or full diamond
interchange is substantiated `avoidance and minimization' (i e , 9 4 acres of wetlands and
366 linear feet of stream impact vs 12 7 acres of wetlands and 119 linear feet of stream
impact, respectively)
EPA requests that NCDOT and FHWA consider and examine a full range of
re--sonable alternatives prior to making a NEPA decision
• Protect Impacts
The EA includes summary tables (S-1 and 1) and a description of the project
impacts to human and natural resources Terrestrial forest impacts are not included in
either Table S-1 or Table 1 Table 8 on Page 26 of the EA includes an estimated area of
terrestrial communities within the project area The estimates in this table are based on
the length and width of the entire study area Table 8 also provides the maximum
potential impacts to terrestrial communities by habitat type EPA notes that Coastal Plain
Bottomland Hardwoods, Cypress-Gum Swamp and Pine Flat are included in the
• estimates (i e , 142, 2 15 and 6 74 acres, respectively) EPA cannot ascertain the
• difference between the summation of these wetland type forest communities and the
projected jurisdictional wetland impacts of 9 4 acres EPA notes the comments on Page
25 of the EA regarding the `entire community of Cypress-Gum Swamp' within the project
. study area is jurisdictional wetlands and `portions of the Pine Flat are within jurisdictional
i wetlands'
I 1 A
Table 8 also indicates that there are 2 83 acres of impact to `cropland and 2 73
acres to `maintained-disturbed areas Tables S-1 and 1 indicate that there is 0 impact to
prime farmlands There is no Farmland Protection Policy Act (FPPA) analysis
concerning potential impacts to farmlands that may be prime, unique or of State-wide or
local importance Page 14 of the EA provides general statistical information on the
importance of agriculture and agribusiness in Columbus County EPA requests that a
prime farmland analysis per FPPA and Title 7 Code of Federal Regulations (CFR) Part
657 be performed
EPA notes that there may be an affect (May Affect-Not Likely to Adverse Affect)
on the endangered Wood Stork (Myctena americana) According to the U S Fish and
Wildlife Service (FWS) representative, NCDOT has not asked for a concurrence on this
determination This deterrmnation and consultation with FWS should be completed
before a final NEPA decision is made for the proposed project
The EA indicates that there will be 9 4 acres of jurisdictional wetland impacts and
366 linear feet of stream unpact Considering the scope of the proposed project, EPA has
substantial environmental concerns for impacts to jurisdictional waters of the U.S
Furthermore, EPA disagrees with the statement on Page 30 of the EA that, `avoidance of
the stream and wetlands is not possible due to the presence of these resources in all
quadrants surrounding the US 74/NC 130 and NC 242 intersection' Please,refer to the
aforementioned discussion on detailed study alternatives and the limited project study
area
Regarding the discussion on minimization on Page 30, EPA does not believe that
NCDOT has demonstrated compliance with Section 404(b)(1) Guidelines The EA
discuss not discuss the minimization efforts to bridge wetlands, utilize engineering
controls such as retaining walls or the steepening of side slopes in wetland areas The
`Green Sheetg', project commitments is `blank and NCDOT states that there are currently
no special commitments for this project NCDOT includes the change of the `initial
design' of a full diamond interchange into a modified diamond configuration as its only
minimization measure
The discussion concerning compensatory mitigation is also vague and not
consistent with Section 404(b)(1) Guidelines (Page 31 "-will be requested [EEP] to
provide off-site mitigation to satisfy the federal Clean Water Act compensatory
mitigation requirements for this project if necessary') EPA could not ascertain any
reason why compensatory mitigation would not be necessary for 9 4 acres of
junsdictional wetland impacts This project as currently planned will require an
Individual Permit (IP) under Section 404 and compensatory mitigation is required unless
avoidance and minirmzation measures significantly reduce or eliminate the estimated
impacts
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EPA recommends that NCDOT and FHWA consider ie-evaluating the
transportation benefits of this project as currently designed verses the significant impacts
to jurisdictional wetlands and streams
EPA does not concur with the discussion concerning indirect and cumulative
impacts to Section 3 g of the EA Construction of a new interchange at this location
could promote localized development in and around the new interchange With two of
the quadrants relatively un-impacted from the modified diamond configuration there
could be development pressure to site new businesses in these areas and along the main
roadways Indirect and cumulative impacts to the wetlands and water quality to Cow
Branch could result from increased development EPA requests that this issue be further
examined by NCDOT before a final NEPA decision is made
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh North Carolina 27636-3726
Apnl 3, 2008
Gregory J Thorpe, PhD
Project Development and Environmental Analysis
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Dr Thorpe
This letter is in response to your request for comments from the U S Fish and Wildlife Service
(Service) on the Federal Environmental Assessment (FEA) for the proposed interchange at the
intersection of US 74/NC 130 (Andrew Jackson Highway) and NC 242 (Hanes Lennon
Highway) in Columbus County, North Carolina (TIP No R-4900) These comments are
provided in accordance with provisions of the National Environmental Policy Act (42 U S C
4332(2)(c) and section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U S C
1531-1543)
For a project of tlus scope, 9 4 acres of wetland impacts is significant However, it appears that
the recommended alternative (modified diamond interchange) and efforts to avoid and minimize
impacts to wetlands have reduced the impact to the extent practical Since the project area is
already affected by the existing intersection, wildlife habitat impacts will be limited to the direct
loss within the project footprint No significant additional habitat fragmentation effects are
expected

There are six federally protected species listed for Columbus County - red-cockaded
. woodpecker (Picoides borealis), wood stork (Mycteria americana), shortnose sturgeon
(Acipenser brevirostrum), Waccamaw silverside (Meradia extensa), Cooley's meadowrue
• (Thalictrum cooley:), and rough-leaved loosestnfe (Lysimachia asperulaefolia) NCDOT has
determined that the project will have no effect on all these species except the wood stork
• NCDOT has determined that the project may affect, but is not likely to adversely affect the wood
• stork The Service has not yet been requested to concur with this determination At this time we
do not have any concerns regarding federally listed species
•
. The Service believes that this FEA adequately addresses the existing fish and wildlife resources,
• the waters and wetlands of the United States, and the potential impacts of this proposed project
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APR a 9 loos
on these resources The Service appreciates the opportunity to review this project If you have
any questions regarding our response, please contact Mr Gary Jordan at [phone], ext 32
Sincerely,
AILA,
`'- Pete Bent in
Field Supervisor
cc Chns Mihtscher, USEPA, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
Richard Spencer, USACE, Wilmington, NC
John Sullivan, FHWA, Raleigh, NC
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If
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL HEALTH
Inter-Agency Project Review Response
Project Name US DOT & NC DOT
Project Number
08-0284
County
Columbus
Type of Project Proposed interchange at
the intersection of US
74/NC 130 (Andrew
J ks H ) an dNC242

The applicant should be advised that plans ac on wv (Hanes Lennon Hwy)
and specifications for all water system
improvements must be approved by the Division of Environmental Health prior to the
award of a contract or the initiation of construction (as required by 15A NCAC 18C
0300et seq) For information, contact the Public Water Supply Section, (919)
733-2321
? This project will be classified as a non-community public water supply and must comply
with state and federal drinking water monitoring requirements For more information the
applicant should contact the Public Water Supply Section, [phone] -1
? If this project is constructed as proposed, we will recommend closure of feet of
adjacent waters to the harvest of shellfish For information regarding the shellfish
sanitation program, the applicant should contact the Shellfish Sanitation tection at (252)
726-6827
? The soil disposal area(s) proposed for this project may produce a mosquito breeding
problem For information concerning appropriate mosquito control measures, the
applicant should contact the Public Health Pest Management Section at [phone]
? The applicant should be advised that prior to the removal or demolition of dilapidated
structures, an extensive rodent control program may be necessary in order to prevent the
migration of the rodents to adjacent areas For information concerning rodent control,
contact the local health department or the Public Health Pest Management Section at
[phone]
? The applicant should-be advised to contact the local health department regarding their
requirements for septic tank installations (as required under 15A NCAC 18A 1900 et
sep ) For information concerning septic tank and other on-site waste disposal methods,
contact the On-Site Wastewater Section at [phone]
? The applicant should be advised to contact the local health department regarding the
sanitary facilities required for this project , -
If existing water lines will be relocated during the construction, plans for the water line
relocation must be submitted to the Division of Environmental Health, Public Water
Supply Section, Technical Services Branch, 1634 Mad Service Center, Raleigh, North
Carolina 27699-1634, [phone]
® For Regional and Central Office comments, see the reverse side of this form
Jim McRight PWSS 4/2/08
Reviewer Section/Branch Date
. 1
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURC
DIVISION OF ENVIRONMENTAL HEALTH
Project Number
08-0284
County
Columbus
Inter-Agency Project Review Response
Project Name US DOT & NC DOT Type of Project
comments provided by
? Regional Program Person
® Regional Supervisor for Public Water Supply Section
? Central office program person
Proposed mterchan _ at
the intersection of US
741NC 130 (Andrew
Jackson Hwyl and NC 242
(Hanes Lennon Hwy)
Date 4/02/2008
Name Debra Benoy- Wilmington RO
Telephone number
Program within Division of Environmental Health
? Public Water Supply

'I V
APR o
NY, 4 ?008
Other, Name of Program
Response (check all applicable)
No objection to project as proposed
? No comment
? Insufficient information to complete review
? Comments attached

-? - X08

toll

Public Water Supply Section
Environmental Review Coordinator for the
Division of Environmental Health
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MEMORANDUM

William G Ross Jr Secretary
North Carolina Department of Environment and Natural Resources

lI
Coleen Sullins, Director
Division of Water Quality
VEC-? ' Wa
l
April 3, 2008
To Melba McGee, DENR Office of Legislative and Intergovernmental Affairs
From Rob Ridings, Division of Water Quality, Transportation Permitting Umt4??
Subject Comments on the Environmental Assessment related to proposed interchange at the
intersection of US 74/NC 130 and NC 242, Columbus County, Federal Aid Project No
NHF-74(78), State Project No 40224 1 1, TIP No R4900, DENR Clearinghouse No
08-0284
This office has reviewed the referenced document dated received March 31, 2008 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
Project Specific Comments:
I This project is being planned with input from DWQ and other resource agencies As a participating
team member, the NCDWQ will continue to work with the team
2 Cow Branch is class C, Sw, waters of the State DWQ is concerned with sediment and erosion
impacts that could result from this project DWQ recommends that highly protective sediment and
erosion control BMPs be implemented to reduce the risk of nutrient runoff to these waters DWQ
requests that road design plans provide treatment of the storm water runoff through best management
practices as detailed in the most recent version of NC DWQ Stormwater Best Management Practices
General Comments:
w 1 The environmental document should 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
2 Environmental assessment alternatives should consider design criteria that reduce the impacts to
streams and wetlands from storm water runoff These alternatives should 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,
0 buffer areas, preformed scour holes, retention basins, etc
• 3 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
•ansportation Permitting Unit
IP50 Mail Service Center Raleigh North Carolina 27699-1650
2321 Crabtree Boulevard Suite 250 Raleigh, North Carolina 27604
done 919 733 1786 / FAX [phone] / internet htta //h2o enr state nc us/ncvvetlands
Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
i
and minimization of impacts to wetlands (and streams) to the maximum extent practical In
accordance with the Environmental Management Commission's Rules (15A NCAC 2H 0506(h)),
mitigation will be required for impacts of greater than I 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
4 In accordance with the Environmental Management Commission's Rules (15A 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 designed to
replace appropriate lost functions and values The NC Ecosystem Enhancement Program may be
available for use as stream mitigation
Future documentation, including the 401 Water Quality Certification Application, should continue
to include an itemized listing of the proposed wetland and stream impacts with corresponding
mapping
DWQ is very concerned with sediment and erosion impacts that could result from this protect NC
DOT should address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the impacts
An analysis of cumulative and secondary impacts anticipated as a result of this project is required
The type and detail of analysis should conform to the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004
NC DOT is respectfully reminded that all impacts, including but not limited to, bridging, fill,
excavation and clearing, to jurisdictional wetlands, 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
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 should 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
10 Sediment and erosion control measures should not be placed in wetlands or streams
1 1 Borrow/waste areas should avoid wetlands to the maximum extent practical Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could
precipitate compensatory mitigation
12 The 401 Water Quality Certification application will need to specifically address the proposed
methods for stormwater management More specifically, stormwater should not be permitted to
discharge directly into streams or surface waters
13 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

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corresponding 401 Water Quality Certification Please be advised that a 401 Water Quality
. Certification requires 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
•
14 Whenever possible, the DWQ prefers spanning structures Spanning structures usually do not
require work within the stream or grubbing of the streambanks and do not require stream channel
realignment The horizontal and vertical clearances provided by bridges allow for human and
• wildlife passage beneath the structure, do not block fish passage and do not block navigation by
canoeists and boaters

• 15 Bridge deck drains should not discharge directly into the stream Stormwater should be directed
across the bridge and pre-treated through site-appropriate means (grassed swales, pre-formed scour
holes, vegetated buffers, etc ) before entering the stream Please refer to the most current version of
• NC DWQ Stormwater Best Management Practices
16 If concrete is used during construction, a dry work area should be maintained to prevent direct
contact between curing concrete and stream water Water that inadvertently contacts uncured
S concrete should not be discharged to surface waters due to the potential for elevated pH and
possible aquatic life and fish kills

. 17 If temporary access roads or detours are constructed, the site shall be graded to its preconstruction
contours and elevations Disturbed areas should be seeded or mulched to stabilize the soil and
i appropriate native woody species should be planted When using temporary structures the area
should be cleared but not grubbed Clearing the area with chain saws, 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
•
18 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
S 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 down stream 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
19 If multiple pipes or barrels are required, they should be designed to mimic natural stream cross
section as closely as possible including pipes or barrels at flood plain elevation and/or sills where
appropriate Widening the stream channel should 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

20 If foundation test borings are necessary, it should be noted in the document Geotechnical work is
approved under General 401 Certification Number 3494/Nationwide Permit No 6 for Survey
Activities
21 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
22 All work in or adjacent to stream waters should be conducted in a dry work area Approved BMP
measures from the most current version of NCDOT Construction and Maintenance Activities
manual such as sandbags, rock berms, cofferdams and other diversion structures should be used to
prevent excavation in flowing water
23 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
24 Heavy equipment should be operated from the bank rather than in stream channels 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
25 Riprap should 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 should be properly
designed, sized and installed
26 Riparian vegetation (native trees and shrubs) should be preserved to the maximum extent possible
Riparian vegetation must be reestablished within the construction limits of the project by the end of
the growing season following completion of construction
The NCDWQ appreciates the opportunity to provide comments on your project Should you have any
questions or require any additional information, please contact Rob Ridings at [phone]
cc Richard Spencer, US Army Corps of Engineers, Wilmington Field Office
Clarence Coleman, Federal Highway Administration
Jim Rerko, Division 6 Environmental Officer
Kathy Matthews, Environmental Protection Agency
Travis Wilson, NC Wildlife Resources Commission
Ken Averitte, DWQ Fayetteville Regional Office
File Copy
.?Mrr "'W
49r
4' ?01 c
L S CIA
q
r4r

11%
,51 North Carolina Wildlife Resources Commission FQ
MEMORANDUM
TO Melba McGee
Office of Legislative and Intcrgovernmlental Affairs, DENR
FROM Travis Wilson, Highway Project Coordinator
Habitat Conservation Program
DAVE- April 23, 2008
SUBJECT North Carolina Department of Transportation (NCDOT) Environmental
Assessment (EA) for the proposed Interchange it the Intersection of US 74/NC
130 and NC 242, Columbus County, Norte Caiolina TIP No R-4900, SCH
Project No 08-0284
Staff biologists with the N C Wildlife Resources Commission have reviewed the subject
EA and are familiar with habitat values in the project area The purpose of this review was to
assess project impacts to fish and wildlife resources. Our comments are provided in accordance
with certain provisions of the National Envi.-orunen:al 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)
NCDOT proposes an interchange at the intersection of US 74/NC 130 and NC 242
NCDOT has identified a modified diamond interchange as their preferred alternative. According
to documentation in the EA this alternative design minirize impacts to wetlands within the
project area
During final design NCDOT should consider options such as reducing median widths,
steepened side slops, acid "tightening" acceleiation and deceleration ramps to minimize impacts
to stream and wetlands where practicable At this tune we acncur with the EA for this project
Thank you for the opportunity to comment If we can be of any further assistance please call me
at [phone].
Mailing Address, Division of Inland Fisheries • 1721 Mail Service Center • RaleigXi, NC 27699-1721
Telephone: [phone] - Fax: [phone]
fR ?C1Hrl a.'RC07cc TC QC cr Orara7 /C7;hra

Memo 2 Apnl 23, 2008

cc Gary Jordan, U S Fish and Wildlife Service, Raleigh
Rob Ridings, DWQ, Raleigh
Richard Spencer, U S Ann) Corps of Engineers, Wilmington
Chris Militscher, EPA

r

00 30Vd 6EB68ZS616 89 ST 800Z/EZ/00

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Appendix C
Merger Process Forms
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t f
Merzer Project Team Meeting Agreement
Concurrence Point No. 4A: Avoidance and Minimization
Project Name & Description:
TIP Project No.:
Proposed Interchange at the Intersection
of US 74/NC 130 (Andrew Jackson Highway)
and NC 242 (Haynes Lennon Highway) near
Evergreen, Columbus County
R-4900
Federal Aid Project No.:
WBS Element:
NHF-74(78)
40224.1.1
The Merger Project Team has concurred on this date of August 20, 2008, on the following
measures for Avoidance and Minimization for TIP Project R-4900
Avoidance
As noted in the Environmental Assessment, complete avoidance df the stream and
wetlands is not possible due to the presence of these resources in three of the quadrants
surrounding the US 74/NC 130 and NC 242 intersection
Signalization and traffic calming techniques were considered as potential
avoidance measures, but were dismissed as viable options because they would not
permanently solve the safety problems In addition, they were not in line with the long
term vision for this facility Given that US 74 is planned to be upgraded to an interstate
facility with full control of access in the future, options were limited for choosing
alternatives
Minimization Efforts
• The standard diamond interchange was revised to a modified diamond
interchange ;The ramp in the northwest quadrant was eliminated to reduce
impacts to a gum-cypress swamp wetland that had a higher quality rating than the
one in the northeast quadrant The ramp in the southeast quadrant was also
eliminated in order to minimize wetland impacts
• The alignment of the proposed interchange was shifted away from the existing
alignment in order to maintain traffic during construction and to prevent the
existing culvert under US 74 from being affected Impacting the culvert would
lead to greater impacts to the stream and adjacent wetlands
1
• A two span bridge is currently proposed for the interchange, as opposed to a
single span bridge A single span bridge would avoid constructabilrty issues that
stem from placing a bridge pier in the vicinity of the existing culvert, however,
the depth of the bridge superstructure (girders) and the height of the fill would be
increased, thus increasing the horizontal footprint of the fill roadway in the
wetland areas Also, with a two span bridge, the lateral ditch to the south that
runs parallel to US 74 can be spanned
• Based upon NCDOT's site investigation, the culvert on NC 242 at Cow Branch
was used as a control to begin the construction limits The proposed roadway
improvements along NC 242 begin south of the existing culvert, which eliminates
the need for a culvert extension in tins environmentally sensitive area
• Although 2 1 slopes in a wetland area are NCDOT's standard, the soils on this
site are sandy NCDOT is using 3 1 slopes in all wetland areas for this project,
which is standard practice for projects east of I-95
• The ramps and loops on this design have been tightened to reduce impacts to the
wetlands for this site
• Compensatory mitigation will be required for the wetland impacts on this project
The $70,000 allotted for mitigation in the TIP is a placeholder and does not reflect
the actual cost of mitigation
USACE NCDOT
FHWA USFWS
NCWRC USEPA
NCDWQ 0/ NCDCR
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Appendix D
USFWS Concurrence Letter
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh. North Carolina 27636-3726
AUG 1 1 20{01 v
OFFICE OF i:rTi RA_ Et</'RTNd 1E`IT
August 11, 2008
Gregory J Thorpe, Ph.D
North Carolina Department of Transportation
Project Development and Environmental Analysis
1598 Mail Service Center
Raleigh, North Carolina 27699-1598
Dear Dr Thorpe
• This letter is in response to your letter of July 29, 2008 which provided the U S. Fish and
• Wildlife Service (Service) with the biological determination of the North Carolina Department of
• Transportation (NCDOT) that the proposed conversion of the existing at-grade intersection to a
• grade-separation at the intersection of US 74/NC 130 (Andrew Jackson Highway) and NC 242
(Hanes Lennon Highway) in Columbus County (TIP No R-4900) may affect, but is not likely to
• adversely affect the federally endangered wood stork (Myctena americans) NCDOT has also
determined that the project will have no effect on all other listed species These continents are
provided in accordance with section 7 of the Endangered Species Act (ESA) of 1973, as
• amended (16 U S C 1531-1543)
• According to information provided, a May 29, 2007 survey did not reveal any wood storks or
wood stork nests. However, during a subsequent site visit in August 2007, a wood stork was
• observed flying through the project area No foraging behavior was observed Based on
available information, the Service concurs with your determination that the proposed project may
• affect, but is not likely to adversely affect the wood stork In addition, we concur that the project
will have no effect on all other federally listed species We believe that the requirements of
• section 7(a)(2) of the ESA have been satisfied We remind you that obligations under section 7
• consultation must be reconsidered if (1) new information reveals impacts of this identified
action that may affect listed species or critical habitat in a manner not previously considered in
• this review, (2) thts action is subsequently modified in a manner that was not considered in this
• review, or (3) a new species is listed or critical habitat determined that may be affected by this
• identified action
• The Service appreciates the opportunity to review this project If you have any questions
• regarding our response, please contact Mr Gary Jordan at [phone] (Ext 32)
• Sincerely,
• s?L Pete Benjamin
Y
• Field Supervisor
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cc Richard Spencer, USACE, Wilmington, NC
Travis Wilson, NCWRC, Creedmoor, NC
Chris Militscher, USEPA, Raleigh, NC
John Sullivan, FHWA, Raleigh, NC
David Hams, NCDOT, Raleigh, NC
0