20111101_Memorandum of Understanding_20090416

A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
April 16, 2009
MEMORANDUM
To: Melba McGee, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs
From: Brian Wrenn, Division of Water Quality, Transportation Permitting Unit
Subject: Comments on the Finding of No Significant Impact related to proposed widening of SR
1006 (Howard Gap Road) from existing US 64 to Existing SR 1539, Henderson County,
Moving Ahead Project MA14181R.
This office has reviewed the referenced document dated March 13, 2009. The NC Division of Water
Quality (NCDWQ) 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. NCDWQ
offers the following comments based on review of the aforementioned document:
Project Specific Comments:
NCDWQ has no specific comments for this project at this time.
General Comments:
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 21-1.0506(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.
3. 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 Stormwater Best Management Practices, such as grassed swales, buffer
areas, preformed scour holes, retention basins, etc.
4. 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 (15A NCAC 2H.0506(h)),
Transportation Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
Location: 2321 Crabtree Blvd., Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone]
Internet: http:llh2o.encstate.nc.ustacwedandsl
NorthCarolina
Naturally
An Equal Opportunity 1Affirmative Action Employer
mitigation will be required for impacts of greater than 1 acre to wetlands. In the event that ;
mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and
values. The NC Ecosystem Enhancement Program may be available for use as wetland mitigation.
5. 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 shall be designed to
replace appropriate lost functions and values. The NC Ecosystem Enhancement Program may be
available for use as stream mitigation.
6. Future documentation, including the 401 Water Quality Certification Application, shall continue to
include an itemized listing of the proposed wetland and stream impacts with corresponding
mapping.
7. NCDWQ 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.
8. An analysis of cumulative and secondary impacts anticipated as a result of this project is required.
The type and detail of analysis shall conform to the NC Division of Water Quality Policy on the
assessment of secondary and cumulative impacts dated April 10, 2004.
9. NC DOT is respectfully reminded that all impacts, including but not limited to, bridging, fill,
excavation and clearing, and rip rap 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.
10. Where streams must be crossed, NCDWQ 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.
11. Whenever possible, NCDWQ 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 shall allow for human and
wildlife passage beneath the structure. Fish passage and navigation by canoeists and boaters shall
not be blocked. Bridge supports (bents) shall not be placed in the stream when possible.
12. Bridge deck drains shall not discharge directly into the stream. Stormwater shall 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
NCDWQ's Stormwater Best Management Practices.
13. Sediment and erosion control measures shall not be placed in wetlands or streams.
14. Borrow/waste areas shall 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.
15. 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.
16. Based on the information presented in the document, the magnitude of impacts to wetlands and
streams may require a Nationwide permit application to the Corps of Engineers and 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.
17. 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.
18. 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 planted. When using temporary structures the area shall
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.
19. 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 down stream of the
above structures. The applicant is required to provide evidence that the equilibrium is being
maintained if requested in writing by NCDWQ. If this condition is unable to be met due to bedrock
or other limiting features encountered during construction, please contact NCDWQ for guidance on
how to proceed and to determine whether or not a permit modification will be required.
20. If multiple pipes or barrels are required, they shall be designed to mimic natural stream cross section
as closely as possible including pipes or barrels at flood plain elevation, floodplain benches, and/or
sills may be required 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.
21. If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3687/Nationwide Permit No. 6 for Survey
Activities.
22. 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. .
23. 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
manual such as sandbags, rock berms, cofferdams and other diversion structures shall be used to
prevent excavation in flowing water.
24. 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.
25. Heavy equipment shall 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 shall be inspected daily and maintained to prevent contamination of surface waters from
leaking fuels, lubricants, hydraulic fluids, or other toxic materials.
26. 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.
27. Riparian vegetation (native trees and shrubs) shall 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 Brian Wrenn at 919-733-5715.
cc: Dave Baker, US Army Corps of Engineers, Asheville Field Office
Clarence Coleman, Federal Highway Administration
Mark Davis, Division 14 Environmental Officer
Chris Militscher, Environmental Protection Agency (electronic copy only)
Marla Chambers, NC Wildlife Resources Commission
Mike Parker, NCDWQ Asheville Regional Office
File Copy
Department of Environment and Natural Resources
Project Review Form
Project Number: 09-0258 County: Henderson Date Received: 03/24/2009
Due Date: 4/22/2009
Project Description: Finding of No Significant Impact - SR 1006, Howard Gap Road, From US 64
to SR 1539 (Jackson Road). WBS Element 38629, Project MA14181 R
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
_
? Wildlife - DOT
Solid Waste Mgmt
Raleigh Land Quality Engineer _
_
Forest Resources
Radiation Protection
Washington _ _
_
Land Resources
Other
Wilmington _ _
- Parks & Recreation
Winston-Salem
_ Water Quality
/.,Water Quality - DOT-•,

Air Quality
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]
MHy?U
2009
vP I

SR 1006
(Howard Gap Road)
From US 64 to SR 1539 (Jackson Road)
Henderson County
WBS Element 38629
North Carolina Moving Ahead Project MA14181R
ADMINISTRATIVE ACTION
FINDING OF NO SIGNIFICANT IMPACT
In compliance with the North Carolina
State Environmental Policy Act OF 1971
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS

Or Tit
APPROVED:
3-i3-o9
Date
Mark Davis, Division 14 Environmental
Mqn > 5 206, 3 ;_ r

SR 1006
(Howard Gap Road)
From US 64 to SR 1539 (Jackson Road)
Henderson County
"S Element 38629
North Carolina Moving Ahead Project AIA14181R
ADMINISTRATIVE ACTION
FINDING OF NO SIGNIFICANT IWACT
January 2009
Documentation Prepared by TGS Engineers:
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David G. Modli Jr. P D. PE .•••O?,?H C??q O?q
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Planning Engineer .??? ?•?; 1, d
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PROJECT COMMITMENTS
SR 1006
(Howard Gap Road)
From US 64 to SR 1539 (Jackson Road)
Henderson County
WBS Element 38629
North Carolina Moving Ahead Project MA14181R
Highway Division 14
In addition to the Nationwide Permit No. 14, the General Nationwide Permit Conditions,
Section 404 Only Conditions, Regional Conditions, State Consistency Conditions, Best
Management Practices for the Protection of Surface Waters, NCDOT's Guidelines for
Best Management Practices for Bridge Demolition and Removal, General Certification
Conditions and Section 401 Conditions of Certification, the following special
commitments have been agreed to by NCDOT:
The proposed project is located in the Tennessee Valley Authority's (TVA) Land
Management District. If the bridge is replaced along existing alignment, as proposed, an
approval under Section 26a of the TVA Act will not be needed. However, TVA will
review final bridge design plans to confirm this determination.
The on-site, temporary detour to be utilized during the replacement of Bridge No. 222
will be immediately north of and parallel to existing Howard Gap Road.
GREEN SHEET
MA14181R ENVIRONMENTAL ASSESSMENT
January 2009
PAGE 1 OF 1
TABLE OF CONTENTS
Page
1. TYPE OF ACTION .............................................................................. I
11. DESCRIPTION OF PROPOSED ACTION .........................................2
111. SUMMARY OF ENVIRONMENTAL IMPACTS .............................4
IV. ACTIONS REQUIRED BY OTHER AGENCIES ..............................6
V. COORDINATION AND COMMENTS ..............................................7
A. Circulation of Environmental Assessment ................................. 7
B. Written Comments Received on Environmental Assessment.... 7
Vl. REVISIONS TO ENVIRONMENTAL ASSESSMENT ...................10
A. Recommended Alternative ....................................................... 10
B. Revisions to the Environmental Assessment ............................ 1 1
VII. ONLY PRACTICABLE ALTERNATIVE WETLAND FINDING.. 13
VIII. BASIS OF FINDING OF NO SIGNIFICANT IMPACT ..................14
TABLES
Table S-1. Summary of Potential Impacts ................................................... 5
Table 1. STIP Projects Complementing SR 1006 Improvements.......... 10
FIGURES
1. Project Vicinity Map
2A, 2B. Existing Conditions
SR 1006
(Howard Gap Road)
From US 64 to SR 1.539 (Jackson Road)
Henderson County
WBS Element 38629
North Carolina Moving Ahead Project N A1418IR
ADMINISTRATIVE ACTION
FINDING OF NO SIGNIFICANT IMPACT
In compliance with the North Carolina
State Environmental Policy Act OF 1971
Prepared by
NORTH CAROLINA DEPARTMENT OF TRANSPORTATION
DIVISION OF HIGHWAYS
DIVISION 14
1. TYPE OF ACTION
This is a North Carolina Department of Transportation (NCDOT) administrative action in
compliance with the State Environmental Policy Act of 1971, Finding of No Significant
impact.
The NCDOT has determined this project will not have any significant impact on the
human and natural environment. This FONSI is based on the Environmental Assessment
(EA), which has been evaluated by the NCDOT and determined to adequately 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 NCDOT takes full responsibility for the accuracy, scope
and content of the EA. '
11. DESCRIPTION OF THE PROPOSED ACTION
The North Carolina Department of Transportation (NCDOT), Division of Highways,
proposes to widen SR 1006 (Howard Gap Road) in Henderson County from US 64 to
Jackson Road (SR 1539) just south of Fletcher, a distance of 7.15 miles. The proposed
project is to widen the existing 20-foot pavement to 24 feet paved roadway with 2-foot,
full depth, paved shoulders. The total shoulder width will be 6 feet in cut and 6 feet in
till except where additional width is needed for guardrail. The cut ditch will be 8 feet
wide. Three bridges, Nos. 22, 40 and 222, will- be replaced as part of the proposed
widening in order to provide a uniform project width. In three selected sections,
excessively sharp curves will be improved to meet design speed standards. (Figure 1)
Current travel demand (AADT) on SR 1006 within the project limits ranges between
6,300 and 9,000 vehicles per day and is expected to increase to 12,500 to 17,400 vehicles
per day in 2030.
There are currently four signalized intersections in the study corridor: (1) US 64 EB, (2)
US 64 WB, (3) Naples Road, and (4) Fletcher Elementary School Driveway. With
existing 2005 traffic, these intersections operate at Level of Service (LOS) A or B. With
the exception of Brookside Camp Road, LOS C, the remaining eighteen unsignalized
intersections operate at LOS A. Once SR 1006 is improved to a standard two-lane cross
section with left-turn lanes at selected intersections, the unsignalized intersection are
expected to operate at LOS A or B with 2025 traffic with the exception of Brookside
Camp Road, LOS F. The signalized intersections at US 64 are expected to operate at
LOS F; Naples Road, LOS C; and Fletcher Elementary School Driveway, LOS B. With
2025 traffic, turn lanes will be required at US 64 EB and WB, SR 1513 (Nix Road), SR
1622 (North Clear Creek Road), SR 1503 (Clear Creek Road) and SR 1539 (Jackson
Road). Currently Brookside Camp Road is a 4-way stop controlled intersection. Future
improvements should include signalization and appropriate turn lanes.
Based on a detailed traffic analysis, five of the eighteen unsignalized intersections in the
studied corridor were found to warrant an exclusive left turn lane. These locations are at
SR 1513 (Nix Road), SR 1622 (North Clear Creek Road), SR 1503 (Clear Creek Road),
SR 1528 (Brookside Camp Road) and SR 1539 (Jackson Road).
Within Henderson County, SR 1006 functions as a Collector roadway, providing an
alternative travel corridor to I-26 between Hendersonville and Fletcher. In addition,
within the studied corridor, there are seven (7) churches, two (2) hospitals, two (2) health
care providers, three (3) schools, and a fire and rescue facility. In reality, the Howard
Gap Road corridor is a fully developed linear community. Currently a major new
subdivision is being constructed across from the Fletcher Elementary School. The
improvement of Howard Gap Road to a standard two-lane roadway with usable shoulders
will be in keeping with its function as a Collector roadway and will provide a safer cross
section for the traveling public.
2
The total crash rate on SR 1006 within the project study area is 374 accidents per 100
million vehicular miles (mvm) traveled. This crash rate is slightly higher than both the
statewide average of 341 accidents per mvm for secondary roads and the Division 14 rate
for secondary roads of 372 accidents per mvm. There were no fatal crashes during the
three-year reporting period from 1/2001 through 12/2003. Of the 159 reported accidents,
46 involved hitting a fixed object, 26 involved rear end collisions, 25 involved left turns,
16 involved running off the road and 10 involved sideswipes. A wider roadway with
usable shoulders should help prevent a portion of the accident types cited above.
There are three (3) school facilities in the study corridor. The Fletcher Elementary
School is one of the Henderson County Public Schools and relies on school busses to
transport a majority of its students. An improved roadway cannot help but benefit school
traffic and contribute to the safety of the community's children.
The total cost estimates for the widening of Howard Gap Road are given below. The
costs include right of way and construction costs (2007 dollars) but do not account for
any wetland or stream mitigation costs.
Right of Way $ 1,500,000
Construction
Part A 4,800,000
Part B 6,300,000
Total $ 12,600,000
The proposed project is an approved project in the North Carolina Moving Ahead
Program. Right of way is currently scheduled to be completed in State Fiscal Year 2009,
and construction is scheduled for State Fiscal Year 2010.
3
III. SUMMARY OF ENVIRONMENTAL IMPACTS
This project will not have a significant impact to farmland. Based on review of aerial
photography, the proposed project will not impact farm operations. The project will not
split any farm operations or displace any facilities used for farming operations.
Acquisitions will occur contiguous to existing claimed right of way. Access to farming
operations will not be permanently impacted.
This project is a minor widening project, generally about the centerline of the existing
roadway. There are no anticipated relocatees. There are no recorded right of ways along
the proposed project; however, NCDOT will claim back-to-back of existing maintained
ditches. The proposed right of way is 60 feet. The owners of the minor right of way
needed along each side of Howard Gap Road will be compensated. The project is not
expected to cause change in the economic condition of the project study area.
The project as proposed will not generate environmental justice issues. This project is
anticipated to create no relocatees. No low-income or minority populations are being
affected by disproportionately high or adverse impacts.
This project is not anticipated to create any permanent adverse effects on the air quality
of this attainment area or to cause permanent noise impacts.
NCDOT biologists Anne Burroughs, Matt Haney, and N. Medlin visited the project on
February 15 and 16, 2007. All streams that were evaluated were located within the
French Broad River Basin. Howard Gap Road in the project area crosses several
unnamed small streams and ditches. The lack of suitable instream habitat and the fact
that no mussels of any species were found during this or prior surveys indicate that the
Appalachian elktoe and oyster mussel do not occur in the project footprint. This is further
supported by the lack of records in the area for either of these species in the N.C. Natural
Heritage Program and N.C. Wildlife Resources Commission databases. Given this
information, construction of the proposed project will have no effect on the Appalachian
elktoe or the oyster mussel.
Jurisdictional wetlands in the project study area total 0.115 acres as shown in Table] 4 in
the Environmental Assessment This total would be the maximum wetland acreage to be
impacted by the proposed project.
There are no impacts to historic architectural or archaeological resources.
4
Table S-1. Summary of Potential Impacts
Recommended Alternative
Length (mi.) 7.15 miles
Railroad Crossings None
Residential Relocations None
Business Relocations None
Major Utility Crossings None
Septic Fields Impacted 2
Historic Sites None
Archaeological Sites None
Cemeteries None
Wetland Impacts 0.115 acres
Stream Impacts 376
100-year Floodplain Crossings One, Clear Creek
Water Supply Watershed Crossings None
Hazardous Spill Basin Areas None
Trout Waters None per NC WRC
Impacted Noise Receptors None
Federally Protected Species No Impacts
State Listed Species No Impacts
Prime, Unique and Important Farmland NA
Low Income Population Impacts None
Minority Population Impacts None
Construction Cost (millions) 11.1
Right of Way Cost (millions) 1.5
Total Cost (millions) 12.6
W. ACTIONS REQUIRED BY OTHER AGENCIES
Because impacts to jurisdictional surface waters and wetlands are anticipated, in
accordance with provisions of Section 404 of the Clean Water Act (33 U.S.C 1344), a
permit will be required from the U. S. Army Corps of Engineers (USACE) for the
discharge of dredged of fill material into "Waters of the United States." Due to the scope
of the proposed project, the USACE has determined that the project may be permitted
with a Nationwide Permit No. 14.
The proposed project is located in the Tennessee Valley Authority's (TVA) Land
Management District. If the bridge is replaced along existing alignment, as proposed, an
approval under Section 26a of the TVA Act will not be needed. However, TVA will
review final bridge design plans to confirm this determination.
A North Carolina Division of Water Quality (DWQ) Section 401 Water Quality
Certification is required prior to the issuance of the Section 404. Section 101
Certification allows surface waters to be temporarily impacted for the duration of the
construction or other land manipulations, and ensures that the state's water quality
standards will not be violated.
6
V. COORDINATION AND COMMETNS
A. Circulation of the Environmental Assessment
The NCDOT approved the State EA on September 22, 2008. The approved EA was
circulated to the following federal, state and local agencies for review and comments by
the NCDOT. An asterisk (*) indicates a written response was received from the agency.
Copies of the correspondence received are included in Appendix A of this document.
Responses to substantial comments are noted in Section B of this Chapter.
United States Army Corps of Engineers - Wilmington and Asheville
United States Environmental Protection Agency
*United States Fish and Wildlife Service
United States Forest Service - Asheville
Tennessee Valley Authority - Environmental Management
*North Carolina Wildlife Resources Commission
Henderson County Fire Marshall
Land of Sky Rural Planning Office
*North Carolina State Clearinghouse
B. Written Comments Received on the Environmental Assessment
United States Fish and Wildlife Service
Comment: The Fish and Wildlife Service expresses concern that the indirect and
cumulative effects have not be adequately addressed and desires the application of
low impact development techniques along the project corridor.
Response: The proposed project is a safety project that will widen an existing
20-foot pavement to 24 feet of pavement with 2-foot paved shoulders almost
exclusively along the existing alignment. No additional capacity will be created.
The roadway will create no further inducements for development. A significant
portion of the current undeveloped land is owned by the Asheville Agricultural
School and Mountain Sanitarium and is likely to remain undeveloped. With
respect to LID development techniques, development outside the right of way is
governed by regulations and ordinances that are the purview of local officials.
With reference to the NCDOT'approved screening methodology (Purple Book),
this project would not have moved past the initial screening relative to an indirect
and cumulative effects study.
2. North Carolina Wildlife Resources Commission
Comment: The North Carolina Wildlife Resources Commission commented
on fishery resources and rare aquatic life. "In it we describe the fishery resources,
7
important game fish, and rare aquatic life that may be negatively impacted by the
project".
Response: As was described in the EA, NCDOT biologists Anne Burroughs,
Matt Haney, and N. Medlin visited the project on February 15 and 16, 2007. All
streams that were evaluated were located within the French Broad River Basin.
Howard Gap Road in the project area crosses several unnamed small streams and
ditches. The lack of suitable instream habitat and the fact that no mussels of any
species were found during this or prior surveys indicate that the Appalachian
elktoe and oyster mussel do not occur in the project footprint. This is further
supported by the lack of records in the area for either of these species in the N.C.
Natural Heritage Program and N.C. Wildlife Resources Commission databases.
Given this information, construction of the proposed project will have no effect
on the Appalachian elktoe or the oyster mussel.
Comment: Further comments expressed concern "the potential secondary and
cumulative effects and that additional regulations or ordinances are necessary to
adequately protect water quality in this watershed".
Response: This project is a safety project that proposes to widen I Toward Gap
Road from an existing 20-foot pavement to a 24-foot pavement with 2-foot paved
shoulders. Development regulations and ordinances are the purview of local
officials.
Comment: Finally, as pointed out, there is a typo within the third paragraph on
page 26 of the EA under Indirect and Cumulative Impacts.
Response: The correct sentence should be "The most significant period of
change was between 1993 and 2003 .11
3. North Carolina Department of Environment and Natural Resources
(Clearinghouse)
Comment: Individual locations of estimated stream impacts were requested by
the Division of Water Quality.
Response: It is estimated that a total of 376 linear feet of stream bank will be
impacted by the proposed project at the following individual locations:
Station 46+85 14 feet
Station 122+54 22 feet
Station 231+64 12 feet
Station 232+55 20 feet
Station 290+21 40 feet
Station 291+42 105 feet
Station 292+04 75 feet
8
Station 316+77 336 feet
Station 318+86 28 feet
Station 374+00 24'feet
Total 376 feet
4. Division of Emergency Management, Office of Geospatial and Technology
Management (Clearinghouse)
Comment: The Office of Geospatial and Technology Management requested
clarification relative to flood studies related to this project.
Response: A full flood study will be conducted at Clear Creek in conjunction
with the design of the proposed new bridge. Depending on the results, a no-rise
certification or the approval of a Conditional Letter of Map Revision will be
obtained. The bridge over Featherstone Creek has been completed under
NCDOT Bridge Replacement Project B-3662 as a separate project. No additional
flood studies will be undertaken at this location. As stated, Beyers Creek does not
have a defined floodplain and its floodplain is not regulated under the Flood
Insurance Program. A flood study is not required although a prudent bridge
design will be undertaken.
9
VI. REVISIONS TO ENVIRONMENTAL ASSESSMENT
A. Recommended Alternative
The Recommended Alternative is to widen SR 1006 (Howard Gap Road) in Henderson
County from US 64 to Jackson Road (SR 1539) just south of Fletcher, a distance of 7.15
miles. The proposed project is to widen the existing 20-foot pavement to 24 feet paved
roadway with 2-foot, full depth, paved shoulders. The total shoulder width will be 6 feet
in cut and 6 feet in fill except where additional width is needed for guardrail. The cut
ditch will be 8 feet wide. Three bridges, Nos. 22, 40 and 222, will be replaced as part of
the proposed widening in order to provide a uniform project width. In three selected
sections, excessively sharp curves will be improved to meet design speed standards.
(Figures 1, 2A and 213).
Table 1. Summary of Recommended Alternative
Criteria 2-Lane Rural Undivided
Type of Terrain Rolling
Design Vehicle WB-50
Design Speed
Sta 1 1+12 to Sta 169+95 50 mph
Sta 193+40 to Sta 272+30 40 mph
Sta272+30 to Sta 301+00 30 mph
Sta 301+00 to Sta 376+40 40 mph
Minimum Radius of Curvature 758 fr., 444 ft., 214 fr., 444 ft
Maximum Grade 9 percent, 10 percent, 10 percent, 10 percent
Number of Lanes Two
Pavement Width 12 feet
Shoulder Width 6 feet
Paved Shoulder Width 2 feet
Right-of-Way Width 60 feet
Access Control None
Level of Service C
Relocations None
Maximum Wetland Impacts 0.115 acres
Stream Impacts 376 If
The total cost estimates for the widening of Howard Gap Road are given below. The
costs include right of way and construction costs but do not account for any wetland or
stream mitigation costs.
10
Right of Way $ 1,500,000
Construction
Part A 4,800,000
Part B 6,300,000
Total S 12,600,000
B. Revisions to the Environmental Assessment
Comments received from the agencies that benefit from clarification to the
Environmental Assessment are noted below.
1. Section B.3.c. Anticipated Impacts to Water Resources, p. 39
Individual locations of estimated stream impacts were requested by the Division of Water
Quality. It is estimated that a total of 376 linear feet of streambank will be impacted by
the proposed project at the following individual locations:
Station 46+85 14 feet
Station 122+54 22 feet
Station 231+64 12 feet
Station 232+55 20 feet
Station 290+21 40 feet
Station 291+42 105 feet
Station 292+04 75 feet
Station 316+77 36 feet
Station 318+86 28 feet
Station 374+00 24 feet
Total 376 feet
2. Section D.3. Protected Species, reference p. 53
The North Carolina Wildlife Resources Commission commented on fishery resources and
rare aquatic life. NCDOT biologists Anne Burroughs, Matt Haney, and N. Medlin visited
the project on February 15 and 16, 2007. All streams that were evaluated were located
within the French Broad River Basin. Howard Gap Road in the project area crosses
several unnamed small streams and ditches. The lack of suitable instream habitat and the
fact that no mussels of any species were found during this or prior surveys indicate that
the Appalachian elktoe and oyster mussel do not occur in the project footprint. This is
further supported by the lack of records in the area for either of these species in the N.C.
Natural Heritage Program and N.C. Wildlife Resources Commission databases. Given
this information, construction of the proposed project will have no effect on the
Appalachian elktoe or the oyster mussel.
Further comments from the NCWRC expressed concern "the potential secondary and
cumulative effects and that additional regulations or ordnances are necessary to
adequately protect water quality in this watershed". This project is a safety project that
proposes to widen Howard Gap Road from an existing 20-foot pavement to a 24-foot
pavement with 2-foot paved shoulders. Development regulations and ordnances are the
purview of local officials.
Finally, as pointed out by the NCWRC, there is a typo within the third paragraph on page
26 of the EA under Indirect and Cumulative Impacts. The correct sentence should be
"The most significant period of change was between 1993 and 2003 11
3. Section E, Flood Studies, reference p.60
The Office of Geospatial and Technology Management requested clarification relative to
flood studies related to this project. As stated in the EA, a full flood study will be
conducted at Clear Creek in conjunction with the design of the proposed new bridge.
Depending on the results, a no-rise certification or the approval of a Conditional Letter of
Map Revision will be obtained. The bridge over Featherstone Creek has been completed
under NCDOT Bridge Replacement Project B-3662 as a separate project. No additional
flood studies will be undertaken at this location. As stated in the comments, Beyers
Creek does not have a defined floodplain and its floodplain is not regulated under the
Flood Insurance Program. A flood study is not required although a prudent bridge design
will be undertaken.

I2
1D
VII. ONLY PRACTICABLE ALTERNATIVE WETLAND FINDING
Executive Order 11990, "Protection of Wetland," 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 able to minimize impacts to wetlands, estimated to be a maximum of 0.115
acres, because the project involves widening an existing roadway and wetlands are
located on both sides of the existing alignment. Strategic placement of the right-of-way
limits and the use of a "best fit" alignment have minimized the impacts to wetlands.
It was determined there is no practicable construction alternative to the proposed
construction in wetlands and that the proposed action includes all practicable measures to
minimize harm to wetlands which may result from such use.
13

VIII. 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 the review 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, will
not disrupt any communities, and is supported by local officials and residents. The
project has been 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 person may be contacted for additional information regarding this project:
Mr. Mark Davis
Environmental Supervisor
NCODT Division 14
253 Webster Road
Sylva, North Carolina
[phone]
a
14
01/30/2009 12:33 N,= - 918285e&4043
No.00G P02
"T RECFI V Fb
United States Department of the Interior JAN 3 0 2009
FISH AND WUDLIFF SERVICE
Asheville Field Office
100 Street RECEIVED
Aahevillc, Nor North Grolioa 28801
December 30, 2008 Division of Highwaya
JAN 0 6 7009
Dr. Gregory J. Thorpe, Manager
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1549
Dear Dr. Thorpe:
r+etorsin4m
PMOd DeWoMW and
t-i!!A?nT?t7't?' ?.'I6joro o??
Subject: Review of State Environmental Assessment for SR 1006 (Howard Gap Road), From
US 64 to SR 1539 (Jackson Road), Henderson County, North Carolina (WBS Element
38629, Division 14;.NC Moving Ahead,Prcject No. MA14181 R)
As requested by, the North Carolina Department of. Transportation (NCDOT), we have reviewed
the Errvironmental Assessment (EA).for the subject project. Our comments are provided in
accordance with the National Environmental Policy Act (42 U.S.C: 4332(2)(c)) (NEPA); the
Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); section 7 of the
Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543); and the Migratory Bird
Treaty Act (16 U.S.C. 703, et seq.),
The NCDOT proposes to widen Howard dap Road (SR ) 006) in Henderson County from US 64
near Hendersonville to Jackson Road (SR 1539) near Fletcher, for a project length of 7.15 miles.
The project as proposed includes widening the existing road to increase the lane and shoulder
widths of this two-lane facility, replacing three bridges, and improving three sectlons with
excessively sharp curves to meet design speed standards.
We are concerned about the potential secondary and cumulative impacts of this project We
remind you that when you are assessing the potential impacts of this project, secondary (i.e.,
housing developments, commercial development) and cumulative impacts must be taken into
account Any future development that will. occur or that will be at a higher density as a result of
the availability of the subject road improvement is considered.an indirect effect under NEPA.
indirect (or secondary) effects are caused by the action and are later in time or.farther removed in
distance; but are still reasonably.foreseeable. Indirect effects include growth-inducing effects
and other effects related to induced changes in the pattern of land use, pop* elation density or
growth rate; and related effects on air and water. and other natural systems. including ecosystems.
0,i30i20Q9 12:33 NCDCTT -) 918285864043 NO. 006 9W
Cumulative impacts on the environment result from the incicmeiiial impact of the action when
added to other past, present, and reasonably foreseeable future actions regardless of what agency
(federal or nonfederal) or person undertakes such'other actions. Cumulative impacts can result
from individually minor but collectively significant actions that take place over a period of time.
We do not believe the "Indirect and Cumulative Impacts" section of the EA adequately addresses
the potential impacts to aquatic resources that are likely to occur as a result of this project. We
recommended that the FA include a more comprehensive analysis of secondary and cumulative
impacts along with the measures that will be initiated to minimize and avoid these negative
effects to fish and wildlife resources- We believe additional measures are necessary to
adequately protect water quality in this watershed. Increases in development (residential,
commercial, and industrial) made possible by the availability of this road improvement will
result in concomitant increases in impervious surface area and thus a similar relational increase
in storm-water runoff. Rest management practices can reduce, but not eliminate, pollutant
loadings of common storm-water pollutants. Designs that collect runoff and allow it to infiltrate
the soil have the highest documented pollutant-removal efficiency, eliminating nearly all lead,
zinc, and solids and more than 50 percent of total phosphorous. Ponds and wetlands, which
allow contaminants to settle out of the water column or be broken down by sunlight and
biological activity, can remove more than 70 percent of bacteria,
Other ways to prevent and/or minimize the secondary and cumulative impacts of development
can be found in the North Carolina Wildlife Resources Commission's publication entitled
"Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to
Aquatic and Terrestrial Wildlife Resources and Water Quality," which we support and encourage
you to use. It can be accessed via the Internet at:
hup.11www.newddlife.nrg/pgo7 wildlirespeciereon/pK7c3_impacrstpdf
impervious SerfacesaAw-Impact-Development (LID) Techniques - The expansion of
urban/suburban areas creates impervious surfaces (such as roofs, muds, and parking lots) that collect
pathogens, metals, sediment, and chemical pollutants and quickly transmit them (via storm-water
runoff) to receiving waters. According to the Environmental Protection Agency, this
nonpoint-source pollution is one of the major threats to water quality in the United States, posing
one of the greatest threats to aquatic life, and is also linked to chronic and acute illnesses in human
populations from exposure through drinking water and contact recreation. Increased storm-water
runoff also directly damages aquatic and riparian habitat, causing stream-bank and stream-channel
scouring. In addition, impervious surfaces reduce groundwater recharge, resulting in even lower
than expected stream flows during drought periods that can ioduce potentially catastrophic effects
for fish, mussels, and other aquatic life. Accordingly, we recommend that all new developments,
regardless of the percentage of impervious surface area they will create, implement storm-water
retention and treatment measures designed to replicate and maintain the hydrograph at the
preconstruction condition in order to avoid any additional impacts to habitat quality within the
watershed.
We recommend the use of LID techniques, such as reduced road widths, grassed swales in place
of curb and gutter, rain gardens, and wetland retention areas, for retaining and treating
01/30/2009 12:33 NGDOT ? 91n285%,3043 N0.006 P04
c
storm-water runoff rather than the more traditional measures, such as large retention ponds, etc.
These designs often cost less to install and significantly reduce environmental impacts,from
residential development.
Where detention ponds are used, storm-water outlets should drain through a vegetated area prior
to reaching any natural stream or wetland area. Detention structures should be designed to allow
for the slow discharge of storm water, attenuating the potential adverse effects of storm-water
surges; thermal spikes; and sediment, nutrient, and chemical discharges. Also, because the
purpose of storm-water-control measures is to protect streams ad wetlands, no
storm-water-control measures or best management practices should be installed within any
stream (perennial or intermittertt), wetland, or riparian area.
We also recommend that consideration be given to the use of pervious materials (i.e„ pervious
concrete, inter] ocking/open paving blocks, etc.) for the construction of roads, driveways,
sidewalks, etc. Pervious surfaces minimiie changes to the hydrology of the watershed and can
be used to facilitate groundwater recharge. Pervious materials are also less likely to absorb and
store heat and allow the cooler soil below to cool the pavement (thus preventing heated water
from entering adjacent waterways). Additionally, pervious concrctc requires less maintenance
and is less susceptible to freeze/thaw cracking due to large voids within the concrete
Invasive Exotic Species - We are concerned with the introduction and spread of invasive exotic
species in association with the proposed project. Without active management, including the
revegetation of disturbed areas with native species, the project corridor will likely be sources of
(and a corridor for) the movement of invasive exotic plant species. Exotic species are a major
contributor to species depletion and extinction, second only to habitat loss. Exotics are a factor
contributing to the endangered or threatened status of more than 40 percent of the animals and
plants on the Federal List ojEndangered and Threatened ll rldlife and Plants.' it is estimated
that at least 4,000 exotic plant species and 2,300 exotic animal species are now established in the
United States, costing more than $130 billion a year to control.' Additionally, the
U.S. Government has many programs and laws in place to combat invasive species (see
www. invasivespecies.gov) and thus cannot spend money to counter these efforts. SpeeificaUy,
Section 2(a)(3) of Executive Order 13112 - Invasive Species (February 3, 1999) directs federal
agencies to "not authorize, .fund, or carry out actions that it believes are likely to cause or
promote the introduction or spread of invasive species in the United States or elsewhere,"
Despite their short-term erosion-control benefits, many exotic species used in soil stabilization
seed mixes are persistent once they are established, thereby preventing the reestablishment of
native vegetation. Many of these exotic plants are also aggressive invaders of nearby natural
areas, where they are capable of displacing already-established native species. Specifically,
stands of Japanese knotweed (Polygonwn carpidatum), an aggressive and invasive nonnative
plant, occur along the road and in floodplain and riparian areas in the project area Japanese
'D. S. Wilcove, D. Rothstein, 7. Dubow, A. Mlllips, and E. Losos. 1998- Quantifying threats to impcnted
in the United States. MoScicnce 48:607-615 species
.
ID. Pirnerml, L. Lach, R. Zuniga, and D. Monism. 2000. Enviroamental end economic coats otnoniedigenouc
species in the United Scores. Bio$cimce 50:53-65.
'Lists of invasive exotic plants can be found ar http--//www,ensppc. cog/ and hap-//www, irn+4.rrvp,urg/eastern/trs/On
the Intemm
01i30i2009 1233 NCDDT i 91e2eS064043 WM06 D05
knotweed can quickly form dense thickets that exclude native vegetation and greatly alter the
natural riparian ecosystem. This species could potentially be spread by construction activities.
We recommend that the NCDOT suppress the knotweed within their tight-of-way and that any
Japanese knotweed material disturbed through construction activities be buried within the project
boundaries, in till or waste areas below the depth of the topsoil.
Stream Crossings - We recommend that spanning structures be used for all permanent roadway
crossings of streams and associated wetlands. All stream crossings should be made
perpendicular to the stream We recommend bridges that span the entire floodplain because it is
important for streams to have access/connectivity to the floodplain. Bridges that span the stream
and floodplain are the best option because they rainimi2e impac-s to aquatic resources, al low for
the movement of aquatic organisms, and eliminate the need to place fill in streams and
floodplain. Bridges should be designed and constructed so that no piers or bents are placed in
the stream, and approaches and abutments should not constrict the stream channel. Fooodplain
culverts must be installed if fill is placed in the floodplain for bridge construction.
If bridges are not possible and culverts are the only option, we suggest using bottomless culverts.
Bottomless culverts do not need to be buried, thereby preserving the natural creek substrate and
not disturbing the streambed. Any type of culvert that is used should be sufficiently sized to
mimic the natural stream functions and habitats located at the crossing site; allew forwatcr
depth, volume (flow}, and velocity levels that will permit aquatic organism passage; and
accommodate the movement of debris and bed material during bank-full events. Widening the
stream channel must be avoided. Consideration should be given to minimum water depth during
low-flow/dry periods when designing culvert placement. Sufficient water depth should be
maintained during low flows to accommodate fish movement. Water depth inside the culvert
must be adequate for fish to be completely immersed and not scraping the bottom. The culvert
should be designed and installed at the same slope as the stream grade to maintain an acceptable
water velocity for fish passage, and the stream substrate characteristics should be retained within
the culvert. Where feasible, we recommend the use of multiple barrels (other than the base-flow
barrel), placed on or near stream bank-full or floodplain bench elevation in order to
accommodate floodwaters within the stream corridor. These should be reconnected to floodplain
beaches as appropriate. This may be accomplished by using sills on the upstream end to restrict
nr divert flow to the base-flow barrel(s). If the culvert is longer than 40 linear feet, alternating or
notched baffles should be installed in a manner that in Dues the existing str°am pate-- -r is
should enhance the passage of aquatic life by: (a) depositing sediment in the barrel,
(b) maintaining channel depth and flow regimes, and (c) providing resting places for Fish and
other aquatic organisms.
The proper planning, design, and installation of stream crossings provide year-round aquatic
organism passage and preserve healthy streams. We recommend the following website for
additional information regarding stream crossing activities:
http. //www.stream fs fed us/frrhring/polnrere, hrml.
We request that you please provide a copy of the "Finding of No Significant Impact.,, If we can
be of assistance or if you have any questions about these comments, please contact Mr, Troy
4
01/30/2009 12:33 t<DUT i 91e2e5964043 40.006 P06
Wilson of our staff at 828/258-3939, Ext. 226. In any future correspondence concerning this
project, please reference our Log Number 4-2,09-065.
S' ely,
j , y.,,
Brian P. Cole
Field Supervisor
cc:
Mr. David Baker, Asheville Regulatory Field Office, U.S. Army Corps of Engineers, 15I Patton
Avenue, Room 206, Asheville, NC 28801-5006
Ms. Marla J. Chambers, Western NCDOT Permit Coordinator, North Carolina Wildlife
Resources Commission, 12275 Swift Road, Oakboro, NC 28129
Mr. Brian Wrenn, North Carolina Division of Water Quality, Central Office, 2321 Crabtree
Boulevard, Suite 250, Raleigh, NC 27604
5
16;0112009 29:43 NCDIJT - 912225864043
North Carolina
Department of Administration
Michael F. Easley, Governor Britt Cobb, Secretary
December 8, 2008
Mr. Gregory Thorpe
NCDOT
Project Development & Env. Analysis
1548 Mail Service Center
Raleigh, NC 27699-1548
NO. Olu D0?
Re: SCH File #t 09-E-4220-0114; EA; NC Moving Ahead Project, SR 1006 (Howards Gap RD)
from SR 1539 (,Jackson Road) S of Fletcher to US 64 Henderson; 4MA14181R in
Henderson County
Dear Mr. Thorpe:
The above referenced environmental information bas been reviewed through the State Clearinghouse
under the provisions of the North Carolina Environmental Policy Act.
Attached to this letter are comments made by the Department of Environment and Natural Resources
(DENR) and other agencies in the course of this review. These concerns should be adequately addressed
either in a supplemental document or in a Finding of No Significant impact and submitted to the
Clearinghouse for farther review and comment.
Thant: you for your cooperation.
Sincerely,
Valerie W. McMillan, Director
State Envirorunental Policy Act
Attachments
oc: Region B
RECEIVE[)
JAN 2 0 2008
TGS ENGINEERS
Mailing Address: Telephone. [phone] Loco@nn Address:
116 West Jones Sgeer
1701 Mail ser`=Ccnw F,. (M)131-957)
Ralel2Ji, NC 27699.1301 Stet; Canner P. 51.01-'0 Rol ehh, Nom, Carolina
c-mud "011111 .. mcmlllna Q' O.nc.V,
A" Egvof Oppo.mn%p='1Iffll an?e /'1011 E',PlWer
1 ;/01/2009 09:43 NCDOT 4 918285864043
NCDENR
North Caroiina'Department of Environment and Natural Resources
Michael F. Easley, Govemor
MEMORANDUM
TO:
PROM:
R&:
DAIT-':
Valerie McMillan
State Clearinghouse
Melba McGee
project Review coordinator
1,10. 014 003
William G. Ross Jr., secretary
o9-Gil4 EA for the Proposed Widening of SR 1006 Howard Gap
Road in Henderson County
December 5, 2000
The Department of Environment and Natural Resources has reviewed the
proposed project.
There continue to he a number ofconcerns that need to be addressed
prior to finalizing project plane. We aek that the Aepartment of
Transportation work directly with our commenting agencies during the NEPA
Merger Process. This will help avoid delays at the permit phase.
Thank you for the opportunity to comment on this project.
Attachments
1601 Mail Service Center, Raleigh, North Carolina 27699.1601
Phone. [phone] FAX. [phone] Internet. www.enr.state nc.us/ENRI
An Ejal Oypo,p my I Afrmwl,t Acton Fmploye, 50%Amyood 110%Puss Consumer Pape,
Noe rthCarolina
ullaily
16(012009 09:43
r
NCDOT -) 918285864043 NO.014
;D svgllam G. P.oss JI.. Secretary
Nonn Carolina Department or cnvironmenl and Natural Resources
dC1 ?? Coleen H Sullins, Director
DEC 2008 y Division otwater Quality
24,2008
D4EMORANDUM --&I 11 `-1
To: Melba McGee, Environmental Coordinator, Office of Legislative and Intergovernmental
Affairs QQ????
From: Brian Wrenn, Division of Water Quality, Transportation Permitting Unit dJ"
Subject Comments on the State Environmental Assessment related to proposed the proposed
widening of SR 1006 (Howard Gap Road) from US 64 to SR 1539 in Henderson County,
Moving Ahead Project No. MA14181R, WBS No. 38629, State Clearinghouse Project
No. 09-0114.
This office has reviewed the referenced document dated September 22, 2006. 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, su-eerrs, end other surface waters. The DWQ
offers the following comments based on review of the aforementioned document:
Project Specific Comments:
In section B.3 c Anticipated Impacts to Water Resources, the discussion provides the total proposed
stream impacts. However, there is no presentation of data that provides the anticipated stream
impacts by impact site or crossing. This data should be provided in Section B.3.c. This comment
was also made in the September 7, 2004 comments subm tied for this project (see Appendix C of the
subject document).
General Comments:
1. Environmental impact statement 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 basins, etc.
?. In accordance with the Environmental Management Convrussion's Rules (I 5A NCAC 2H.0506(h)),
mitigation will be required for impacts of greater than 150 linear feet to any single perennial strearn.
In the event that mitigation is required, the mitigation plan shall be designed to replace appropriate
lost functions and values. The NC Ecosystem Enhancement Program may be available for use as
stream mitigation.
3. Future documentation, including the 401 Water Quality Certification Application, shall continue to -
include an itemized listing of the proposed wetland and sh-cam impacts with corresponding mapping.
P04
No?nhCero ins
?Vatran?l?
Tmn5,I UOn ParroA n9 Unit
1650 Aiv Service center. R21e5r?, horn Camllna 27699-1550
2321 Crabtree eoule.ard, Sulie 250. Raleigh. Noah Carolina 27604
Pnonf. 9197}}-17651iA7:919-73}599711n1emaC h110'flh2o Znr 54Bte.oc.vSlnLwe;lantl9
6n ?OWltrpCORUniblF7urnelbc Action F.mpbyfr-50°h PacyCeoPa%Fcst Consuacr PEaO?

vegetated buffers, etc.) before entering the stream. Please refer to the most current vernon of NC
DWQ Stormwater Best Management Practices.
15. 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 shall not be discharged to surface waters due to the potential for elevated pE and possible
aquatic life and fish kills. .
16. if temporary access roads or detours are constructed, the site shall be graded to its preconstmction
contours and elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and
appropriate native woody species shall be planted. When using temporary structures the area shall
be cleared but not grubbed. Clearing the area with chain saws, mowers, bush-hogs, or other
mechanized equipment and leaving the skimps and root mat intact allows the area to re-vegetate
naturally and minimizes soil disturbance.
17. 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 [hart 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
tctnnorrarv 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 tmable io 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
18. If multiple pipes or barrels are required, they shall 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.
19. If foundation test borings are necessary, it shall be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3494/Nationwide Permit No. 6 for Survey
Activities.
20. 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- -
21. 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 manual
such as sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent
excavation in flowing water.
22. While the use of National Wetland Inventory (NWT) 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.

0 North Carolina Wildlife Resources Commission
TO: Melba McGee, Environmental Coordinator
Office of Legislative and Intergovernmental Affairs, DENR
FROM: Marla Chambers, Western NCDOT Permit Coordinator
Habitat Conservation Program, NCWRC
DATE: December 2, 2008
SUBJECT: Review of the State Environmental Assessment for the proposed widening of
Howard Gap Road (SR 1006) from US 64 to Jackson Road (SR 1539), Henderson
County. North Carolina Moving Ahead Project No. MA 141818 OLIA Project
No. 09-0114, due 121312008.
North Carolina Department of Transportation (NCDOT) has submitted for review a State
Environmental Assessment (EA) document for the subject project. Staff biologists with the
North Carolina Wildlife Resources Commission (NCWRC) have reviewed the information
provided. 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).
NCDOT proposes to widen Howard Gap Road (SR 1006) from US 64 near Hendersonville to
Jackson Road (SR 1539) near Fletcher; for a project length of 7.15 miles. The project includes
increasing the lane width and shoulder width of this two-lane facility, replacing three bridges,
and improving three sections with excessively sharp curves. Streams that cross the project study
area are Clear Creek and four of its unnamed tributaries (IJTs), Featherstone Creek, Byers Creek
and seven of its UTs, Cushion Branch and two of its UTs, and two UTs of Mud Creek. All of
these have been issued a Best Usage Classification of C, however Clear Creek and Mud Creek
are on the State's 303(d) fist of impaired waters.
NCWRC submitted scoping comments for this project, dated September 7, 2004, which are
included in an appendix of the EA document. In it we describe the. fishery resources, important
game fish, and rare aquatic life that may be negatively impacted by the project. We state that our
major concern is the potential secondary and cumulative effects and that additional regulations or
Mailing Address: Division of lnlmd Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
Howud Gap Road (sR 1006)
t on co. - 2 - Dec®be` 2, 2008
Enu
ordinances are necessary to adequately protect water quality in this watershed. We
recommended that the EA include a study of secondary and cumulative impacts and measures
that are in place or will be initiated to minimize and off set adverse effects on fish and wildlife
resources. None of this was addressed in the very short Indirect and Cumulative Impacts section
of the EA- This section indicated that continued growth in the corridor and a change from a
semi-Waal setting to a more suburban setting is likely to occur. There was no analysis of the
cumulative effects on the environment from this and other area projects and activities or how
secondary development facilitated by this project may impact fish and wildlife resources, water
quality, or open space. No measures to avoid or minimize these negative effects were presented.
We also noted that there is an apparent typo regarding dates in the third paragraph of this section.
The document describes the highly developed nature of most of the project study area and how
the forested land occurs in small, fragmented pockets. Approximately 31% of the study area is
covered by impervious surfaces. Numerous studies have shown that when 10-15% of a
watershed is converted to impervious surfaces, there is a serious decline in the health of
receiving waters (Schueler 1994) and the quality of fish habitat and wetlands are negatively
impacted (13ooth 1991, Taylor 1993). Negative effects on water quality have akeady occurred,
as evidenced by the impaired streams in the vicinity of the project. Sediment and erosion control
measures should adhere to the design standards for sensitive watersheds and stotmwater
treatment from the roadway should be maximized to protect downstream sensitive resources and
minimize further degradation of water quality.
We strongly recommend that the local officials require strict storrnwater controls for
development in the vicinity and use low impact development techniques to manage stormwater
quamity and quality. Information on low impact development practices and measures can be
found at www low impaadevelopment.ore htty //www epa uov/owow/npsAi llidnatl d and
htt://wwwstormwatercenter_net . We encourage NCDDT and local officials to use non-
impervious materials to construct sidewalks, parking lots, and other facilities. In addition,
adequate analysis of secondary and cumulative impacts and commitments to minimize impacts
should be developed and presented prior to submitting a permit application for the project.
Measures to mitigate secondary and cumulative impacts can be found in the Guidance
Memorandum to Address and Mitigate Secondary and Cumulative Impacts to Aquatic and
Ter, estrial Wildlife Resources w7d Water Ouahty (NCWRC 2002). protection of the area's
narirral resources and water quality will not only benefit fish and wildlife, but can have a positive
effect on tourism and the quality of He of area residents.
Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at [phone].
Literature Cited:
Booth, D. 1991. Urbanization and the natural -drainage system-impacts, solutions, and
prognoses. Northwest Environmental Joumal_ 7(l):93-118.
NCWRC (North Carolina Wildlife Resources Commission). 2002. Guidance Memorandum to
Address and Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial
rw.uia vue
16/01/2009 09:4, NCDOT 4 9192e6064041-
I JoTw,i Gap Rond (SR 1006) De bm 2, 2008
H?dason Co. -3-
Wildlife Resources and Watei Qualify NCWRC, Raleigh. Available:
http://www.nmildlife.org/pg07_WildlifeSpeciesCon/pa7c3_impacts.pdF. (February
2003).
Schueler, Tom. 1994_ The Importance of Imperviousness. Watershed Protection Techniques.
13 (pp100-111).
Taylor, B.L. 1993. The influences of wetland and watershed morphological characteristics and
relationships to wetland vegetation communities. Masters thesis. Dept. of Civil
Engineering. University of Washington. Seattle, WA
ce: Marella Buncick, USFWS
Brian Wrenn, NCDWQ
Mike Parker, NCDWQ
Angie Rodgers, NCNB P

DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL HEALTH
Inter-Agency Project Review Response
J/
Project Number
09-0114
county
Henderson
Project Name NC-DOT/Division of Type of Project NC Moving Ahead Proiect-
Hipbways SR 1006 owards Gs Rd
from SR 15-19 (Jackson Rd)
to US 64: tdMA1418111.
Comments provided by:
? Regional Program Person
® Regional Supervisor for Public Water Supply Section
? Central Office program person
Name TimAdams-AshevilleRO Date 10/3012008
Telephonenumdr??pb
Program within Division of Environmental Health:
? Public Water Supply
? Other, Name of Program:
Response (check all applicable):

? Comments attached
© See comments below
1-) -74".116 ? No objection to project as proposed

? No comment
? Insufficient information to complete review
DEC 2008
Ser:; _
Public Water Supply Section Environmental Review Coordinator for the
Division of Environmental Health
lb/L91?G19U'7 ?7: °+? rvuuu i ? oloeo.?ooervu ---
-j
rV DE C 2008 Project Number
DEPARTMENT , ON EJAND os-o?1a
NATUR fES;1f?ES 4 County
DIVISION OF EN RONMENTA3EALTH Henderson
Inter-Agency
Project Name NC-DOT/Divieion of Type of Project NC Moving Ahead Protecr-
Hiphwavs SR 1006 (Howards Gan)id)
from SR 1539 (Jackson
to US 64; tlMA1418M
? The applicant should be advised that plans 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].
? 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 Section at (252)
726-6827.
(] The soli 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, a 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
??/IaY relocation must be submitted to the Division of Environmental Health, Public Water
Supply Section, Technical Services Branch, 1634 Mail Service Center, Raleigh, North
Carolina 27699-1634, [phone].
® For Regional and Central Office comments, see the reverse side of this form.
Jim McRlght PWSS 10/30/08
Reviewer SeoionlBranch Date
'' Vy LVyI Vl NORTH CAROLINA STATE CLEARINGHOUSE
DEPARTMENT OF ADMINISTRATION
INTERGOVERNMENTAL REVIEW
OCT „
27oA
%7 (Qc STATE NUMBER: 09-E-4220-0114
Grf?
DATE RECEIVED: 10/27/2008
AGENCY RESPONSE: 12/03/2008
REVIEW CLOSED: 12/08/2000
MS RENEE GLEDHILL-FARLEY
CLEARINGHOUSE COORD
DEPT OF CUL RESOURCES
ARCHIVES-HISTORY BLDG - MSC 4617
RALEIGH NC
REVIEW DISTRIBUTION
CC&PS - DEM, GTMO 0 N& 2 oa
DENR LEGISLATIVE AFFAIRS
DEPT OF AGRICULTURE RMENED
DEPT OF CUL RESOURCES soffice
DEPT OF TRANSPORTATION
LAND OF SKY REGIONAL COUNCIL
ER o4-;,.;49
A M'?ifp-J lou(v?M
J(l(I1%rlLd'). ? ,..p5? /o-31-Og

PROJECT INFORMATION
APPLICANT= NCOOT _
TYPE: State Environmental Policy ActE tl ?i Sl R$
ERD: Environmental Assessment
DESC: NC Moving Ahead Project, SR 1006 lHowards Gap RD) from SR 1539 (Jackson Road) s of
Fletcher to US 64 Henderson; BMAI4IHIR in Henderson County
CROSS-REF?TRENCE NUMBER: 05-E-4220-0053
The attached project has been submitted to the N. C. State Clearinghouse for
intergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
If additional review time is needed, please contact this office at [phone]
AS A RESULT OF THIS REVIEW THE FOLLOWING IS SUBMITTED:
NO COMMENT
COMMEE'T?S?A?TJTACHE?D.
SIGNED BY:
DATE: Ir' /a 'C/ a
OCT 2 9 20()?
---- - ------------
NORTH CAROLINA 6TA'Th: U ILL'AtC1NL4MUUJL
DEPARTMENT OF ADMINISTRATION ??!f.L+.rt,7Tl Psi-?
INTERGOVERNMENTAL REVIEW
STATE NUMBER: 09-E-4220-0116 F02
DATE RECEIVED: 10/21/2006
AGENCY RESPONSE: 12/03/2006
REVIEW CLOSED: 12/08/2006
CLEARINGHOUSE COORD
CCSPS - DEM, GTMO
MSC 0 4116
RALEIGH NO REVIEW DISTRIBUTION

CC&PS - OEM, GTMO
1
VE AFFAIRS

r -
OENR _
LEGISLAT NOV 2008
DEPT OF AGRICULTURE, )
DEPT OF CUL RESOURCES REMIVED
?

DEPT
LAND
OF TRANSPORTATION
OF SKY REGIONAL COUNCIL
i1
?.P,
C Z??
PROJECT INFORMATION ` C?'jl Q?6`'bti°
APPLICANT- NCDOT
TYPE: State Environmental Policy Act
ERD: Environmental Assessment -
DESC: NC Moving Ahead Project, SR 1006 (HOwards Gap RD) from SR 1539 (Jackson Road) s of
Fletcher to US 64 Henderson; $MA14181R in Henderson County
CROSS-REFERENCE NUMBER.: 05-E-4220-0053
Tne attached project has been submitted to the N. C. State Clearinghouse for
;ntergovernmental review. Please review and submit your response by the above
indicated date to 1301 Mail Service Center, Raleigh NC 27699-1301.
if additional review time is needed, please contact this office.at [phone].
AS A RESULT OF THIS REVIEW THE FOLLOWING TS SUBMITTED:
NO COMMENT
® COMMENTS ATTACHED
SIGNED BY:
?/,?
DATE: 1113

r ?r ?T[,?
(o r?
North Carolina Department of Crime Control and Public Safety
Division, of Emergency Management
Office of Geospatial and Technology Management
4719 Mail Service Center • Raleigh, NC 27699-4719
Michael F. Easley 3 4 r? Bryan E. Beatty
Govemor T1 ?? Secretary
November 3, 2008 It
g1'
ti NOV 2008
Ms. Valerie McMillian
h RECEMi9
State Clearinghouse n s
N.C. Department of Administration mOA
1301 Mail Service Center
Raleigh, North Carolina 27699-1301 Z1ll Q 618
Subject: Intergovernmental Review State Number: 09-E-4220-0114
Widen Howard Gap Road (SR 1006) for 7.15 miles from US 64 to SR 1539 near
Fletcher in Henderson County
Dear Ms. Valerie McMillian:
As requested by the North Carolina State Clearinghouse, the North Carolina Department of
Crone Control and Public Safety Division of Emergency Management Office of Geospatial
and Technology Management (GTM) reviewed the 'proposed project listed above. and has
provided comments herein. It is our understanding that the NCDOT is planning to widen
Howard Gap Road from a 20-foot width to a 24-foot width as part of North Carolina Moving
Ahead Project MA 14181R. The project will cross several creeks (Clear Creek, Featherstone
Creek, Beyers Creek and several unnamed tributaries) and then terminate on the north end in
the vicinity of the Cane Creek floodplain.
The GTM has the following comments:
1) !tic shown on the.Henderson County DFIRM Panels 9652, 9661 and 9670, the
proposed project includes areas within the newly detailed studied special flood hazard
area of the Clear Creek and within its regulatory floodway. Featherstone Creek was
newly studied as a Limited Detailed stream with a delineated floodplain and
associated non-encroachment area. Cane Creek as well has a floodplain near the
project's terminus. Beyers Creek does not have a defined floodplain on recent maps,
so its floodplain is not regulated under the Flood Insurance Program. Any proposed
construction (including demolition) within the f oodway or non-encroachment areas
will require, prior to construction, approval of either a no-rise study with a no-rise
certification for projects that do not increase base flood elevation or for projects that
result in an increase in base flood elevations, the approval of a Conditional Letter of
Map Revision.
Location: 1812 Tillery Place, Suite 105 • Raleigh, NC 27604 • [phone]
An Equal Opportunity/Affirmative Action Employer
c
d
j ?6i91/2009 09: 43 HCDOT 4 918205864043
Page 2 of 2
November 3, 2005
11V. V1`, 1i-
2) Construction of the in-water facilities may involve the placement of temporary coffer
dams, trench boxes or similar svucrures to facilitate installation. If the structures are
expected to be in place during all or a part of the hurricane season (June I through
December 1), they should be considered `in-place' for the proposed condition of a no-
rise evaluation.
3) Please consult the Henderson County floodplain administrators for guidance en higher
standards for floodplaia development as defiled in local ordinances.
Thank you for your cooperation and consideration. If you have any questions concerning the
above comments, please contact me at [phone], or by email at [e-mail] or at
the address shown on the footer of this document:.
Sincerely,
Kew W. Ashe. RE., CFM
Assistant Director
c: Randy Mundt, NC NFIP State Coordinator
Localion: 1812 Tillery Place, Suite 105 • Raleigh, NC 27604 • [phone]
An Equal Opportunity/Affirm alive Action Employer
tr'ti
Sc,
IS/01/2009 8943 NCDOT ?J1Cdtl5tib4104S
c i, 12/Da/2806 0A:46 82B2516353 LAND OF SKY REGIONAL
NCa<TH CAROLINA STATE CLEARINO130vSS
L?EPART?WNT OF ADMINISTRA.T'LON
INTERC30VAI TAL PZVIZW
PAGE 02/63
STATE NUMEiBR; 09-8-4220-0114 CD2
DATE R2CEIV3D: 10/2712000
AWAY PXSPOWS2: 12/03/2008
REVIEW CLOSED; 12/06/2008
CLEAAINGHOUSF COORD REGION B
LAND OF SKY REGIONAL CODNCIL
25 HERSTAGE DRIVE
ASHEVILLE NC
R VJEW DISTRIBUTION
cC&?S - DER, CTRO
DENR LEGISLATIVE AFFAIRS
DEPT OF AGPICDLTURF.
DEPT OF COL RESOURCES
DEPT OF TRANSPORTATION
LAND OF SKY REGIONAT, COIINCIL
PROTECT INFORMPTTON
APPLICANT: N--UOT
TY?E. State Eavtron en"l Policy Act
4 ??8
FAD: Gnvironmental P.9SaS5menC
5'9 (Jacksaa 4oad1 s of
DESC: NC Moving Ahead Project. BR 1006 IHouaR? n GHande, sofrom n County
Fle-cher 70 US 64 HOndereoni 9M7:1419 -
CROSS-R2,ERENCc mamrER: 05-F.--0220-0053
The attached project hea been submitted to the N. C. State Clcaringhous above
3.ntergovornmental revi.e1a, p1p.00c rovlew and eubm3r. your reaponee by the
znaica.ad date to 1301 Mail ?4arvice C. ter, Raleigh NC 27699-1301.
If additional reviow time is needed, plea5a coated Chia office at [phone]:
AS A REaVLT OF TRI3 REVIEW THE FOLLOWING IS SUBMITTED:
? NO COMMENT
VOMMENTS ATTACHZD
+ @ @ o c,? a(} 1 lJ
S IGNFD BY: l??c
DATE: -1)11)
16/01/2009 09:43
r...` 72/04/2008 08:46
Wlfa *lta Barber
NCDUi = yI CLGJGGU?uJ ---..
8282516353 LEND OF 501 REGIOWL ?age M ?r;3/03
From Hope Bleeda r (hblaoOOrChendersOneOUntync.org]
gunk Monday, November 24, 2008 12:20 PM
To: Micinalle Barber
Ca; Anthony Starr; Jim Crafton: Wilson, Jamie R
9ub*t ER 1008 Howard Gap Road from 94 6 SR 1539 Jackson Road
Mlehajle- Thank you for sending the request fur comments on the Howard Gap Road Widening proj ??? rson
09-E-4220.01 14 to my attention. I have reviewed the eno102ad onvironmentat aeseserre
County Is pleased to note that the projed is moving ahead and supporm widening ward ? Road from further ?t
existing 20' cross section to 24 feet of paved M&May wtth 2 foot full depth paved either row or in the
.
that mt. Mark Davis writaet me regarding the posolNEW of adding bike lanes to the ry jde cxj or for in their
e
tub,re. Thank you for the opportunity V comment and pieaae forward this to 818 appaPdae eether
records.
Hope E. aleecker, AICP Transportation Planner
Henderson County Planning Department
213 15t Avenue SW
Honderoomrilte, NC 28782
58 (office)
07-4819 axt.
(fax)
882g)
hbipecker@hsndervancc)untync.org
t 7 naf7MR

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Title
EcoScience HOWARD GAP ROAD
Corporation (SR 1006)
EXISTING
OVEMENTS
IMPR
1101 Haynes Street. Suite 101
Raleigh, North Caroline 27604
Ph
1
8
8
3
33

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CONDITION S
: 9
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-
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erson
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? Fax: [phone] North Carolina

Drawn by: FIGURE
ES
Scale:
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Date:
OCT 2004
Project:
04-201

N
Source: 1999 Infrared Orthophotos
M
1000 0 1000 2000 Feet ? f `t \'?
a.-

? IfIP.
EcoScience HOWARD GAP ROAD
Corporation (SR 1006)
EXISTING
IMPR
OVEMENTS
1101 Haynes Street, Sue 101
Rale
Raleigh, North Caroline 27604

9
9
2
3
P

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ONDITIONS
h:
1
-8
8-343
? erson
oun
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y,
Fax: [phone] North Carolina

Drawn by: FIGURE
ES
Scale:
1" = 1250
'

Date: 2 B
OCT 2004
Protect:
04-201