SR 1115 (4)

U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 4 RALEIGH OFFICE
TERRY SANFORD FEDERAL COURTHOUSE
310 NEW BERN AVENUE
RALEIGH, NORTH CAROLINA 27601
Date: June 14, 2009
Dr. Gregory .I. Thorpe, Ph.D.
Manager, Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
SUBJECT: EPA Review Comments on the Environmental Assessment (GA) for R-
3430, SR 1001 Widening (Connelly Springs Road), Caldwell County,
North Carolina
Dear Dr. 'Thorpe
The U.S. Environmental Protection Agency Region.4 (EPA) has reviewed the
subject. document and',is commenting -in aecordance;.witli•Section 309.of the Clean Air
Aci and Section .102(2)(C) of the NationaLl-nvironinental-1'olicy_Act(NEPA), .; The;
North Carolina Department, of'rransportation(NCDO'I').and the Federal ,Highway-,_
Administration (FHWA) propose to widen SR 1.001 (Connelly Springs Road) from SR
I 1 15 to SlZ 1933, in Caldwell County for an approximate distance of 7.1 miles.
SR 1001 is classified as a minor urban arterial on the N.C. Highway Functional
Classification System. 'rhe proposed project will widen the existing roadway to a 48-toot
curb and gutter section with a 23-foot median. The design speed is identified as 50 miles
per hour (mph) and the posted speed expected to be 45 mph. EPA notes that NCDOT
and FI IWA do not propose any control of access along the new 7.1-mile multi -lane route.
EPA's project tiles and records do not indicate that this proposed project was
placed into the NEPA/Section 404 Merger 01 Process. EPA could find no information in
the FA indicating that the U.S. Army Corps of Engineers (USACE) and the North
Carolina Division of Water Quality (NCDWQ) had been contacted concerning the
Merger 01 screening criteria or the reasons not to include this proposed project into
Process 11. Widening Projects. Estimated impacts to jurisdictional waters of the U.S. arc
expected to require the issuance of an Individual Permit (IP) by the USACE.
The impact summary table on Page, i i i of the EA does not includewyhich,type of
widening is; preferred,byrNCD00' (i.e., Uast side, west side, or, symmetrical). -,Impacts to
luiisdictional.streamsare esumaled,ai,l 1,80,_Iiiicar-fect.with-most ofthe impact to linear7ec
perennial unnamed tributaries (UTs) to Gunpowder Creek at 1,030 t. Also

referring to the summary table, noise receptor impacts are presented in a range from 122
to 186 depending on the alternative chosen. EPA is unclear which alternative is preferred
and what the differences are for the key environmental impact indicators.
The summary impact table includes a `0' acre impact for prime farmlands. EPA
could not identify any discussion in the EA concerning prime farmlands or agricultural
lands. Although most of the project appears to be urban/suburban in nature from the
figures, it would be appropriate to discuss why impacts to prime farmlands are estimated
to be zero and what is the significance of prime farmlands under the Farmland Protection
Policy Act of 1981.
NCDOT's relocation report indicates that there will be 97 total relocations for the
project, including residences, businesses and non-profit organizations. EPA
acknowledges the comments in the EA regarding the importance of SR 1001 to the Town
of Cajah's Mountain. EPA is also uncertain as to why a 23-foot median is needed
throughout the project. Figure 2, Sheet I of 14 depicts the beginning of the proposed
project. From the aerial photograph, this area appears to be very rural and there is no
cross roads shown. EPA is not certain as to why this location was chosen as the southern
logical termini. EPA recommends that NCDOT further explore specific avoidance and
minimization measures for jurisdictional streams in the project study area.
EPA acknowledges that NCDOT and FHWA have included a qualitative
assessment on Mobile Source Air Toxics (MSATs) in the EA. The EA contains similar
2006 FFI WA interim guidance information on MSATs as what has been included in other
NEPA documents for other projects.
Summary
EPA does not have any environmental objections to the proposed project.
lowever, EPA recommends that the project be placed in the Merger 01 process at the
appropriate concurrence point. Specific avoidance and minimization measures for
impacts to jurisdictional streams need to be further identified. Please include Ms. Kathy
Matthews of EPA's Wetlands Section on future meeting notices. EPA also requests a
copy of the FONSI when it becomes available. Thank you for the opportunity to
comment.
Sincerely, / y.
Christopher A. Militscher, REM, CHMM
Merger Team Representative
NEPA Program Office
For: Heinz.l. Mueller, Chief
EPA Region 4 NEPA Program Office

® North Carolina Wildlife Resources Commission
TO: Melba McGee, Environmental Coordinator
Department of Environment and Natural Resources
FROM: Marla Chambers, Western NCDOT Permit Coordinator 7)%a2L CAm.m&�
Habitat Conservation Program, NCWRC
DATE: June 1, 2009
SUBJECT: Review of the Environmental Assessment for NCDOT's proposed project to
widen SR 1001 (Connelly Springs Road) to a four -lane divided facility from SR
1115 (Dry Ponds Road) to SR 1933 (Lenoir Southwest Boulevard), Caldwell
County. TIP No. R-3430. DENR Project No. 09-0316, due 06/01/2009.
The North Carolina Department of Transportation (NCDOT) has submitted for review an
Environmental Assessment (EA) 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)), the Fish and Wildlife Coordination Act (48 Stat. 401, as amended;
16 U.S.C. 661-667d), and the Clean Water Act of 1977 (33 U.S.C. 466 et seq.).
The NCDOT proposes to widen SR 1001 (Connelly Springs Road)•to a four -lane divided facility
from SR 1115 (Dry Ponds Road) to SR 1933 (Lenoir Southwest Boulevard), for a total length of
approximately 7.1 miles. The project is currently unfunded. We.prefer a `best -fit' alternative
that not only focuses on minimizing displacement impacts, but also jurisdictional impacts.
It appears that the majority of the roadway is situated on a ridge and will impact four streams for
a total of 1,180 linear feet of stream. These streams include an unnamed tributary (UT) to
Stafford Creek and three UT's to Gunpowder Creek. The majority of the impacts, approximately
630 linear feet, are to stream S2A (an UT to Gunpowder Creek), which is parallel and adjacent to
the existing roadway. We recommend investigating relocation of the stream to minimize
impacts. Most of the project is within a protected water supply, therefore sediment and erosion
control measures will adhere to the Design Standards for Sensitive Watersheds. Alternatives to
the proposed curb and gutter should be investigated to provide better stormwater treatment.
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

R-3430, SR 1001 (Connelly Springs Road)
UT's to Gunpowder & Stafford Creeks, Caldwell Co. - 2 - June 1, 2009
Widening the road from two lanes to a four -lane divided facility will make crossing the roadway
much more difficult for wildlife and has the potential to increase the rate of collisions with
wildlife. We recommend that NCDOT investigate accidents along'SR 1001 that involve
wildlife, such as vehicle collisions with deer, and identify areas of habitat fragmentation
affecting small and large wildlife species in the project area. Wildlife crossings may be
appropriate to improve safety for drivers and reconnect populations fragmented by the highway.
NCWRC is also concerned about indirect and cumulative impacts to area waterways, wildlife
habitat, and water quality. The Indirect and Cumulative Effects section was very brief and
indicated the project may accelerate the rate of development and impact the character of existing
residential neighborhoods. It did not indicate if land use plans or ordinances were in effect to
manage growth or protect natural resources, other than Watershed Protection Regulations for the
water supply. 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 (Booth 1991, Taylor 1993).
We encourage NCDOT and local officials to protect water quality and habitat through the use of
Low Impact Development (LID) techniques, growth management, and other mitigation efforts.
Partial control of access should be considered to reduce indirect impacts. Information on Low
Impact Development practices and measures can be found at www:lowimpactdevelooment.ora,
httl)://www.epa.gov/owow/nos/lid/lidnatl.pd and htto://www.stonnwatereeliter.net/. 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 Terrestrial Wildlife
Resources and Water Quality (NCWRC 2002).
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].
cc: Marella Buncick, USFWS
Amy Euliss, NCDWQ
Literature Cited:
Booth, D. 1991. Urbanization and the natural drainage system -impacts, solutions, and
prognoses. Northwest Environmental Journal. 7(1):93-118..
NCWRC (North Carolina Wildlife Resources Commission). 2002. Guidance Memorandum to
Address and Mitigate Secondary and Cumulative Impacts to Aquatic and Terrestrial
Wildlife Resources and Water Quality. NCWRC, Raleigh. Available:
http://www.ncwildlife.org/pg07_WildlifeSpeciesCon/pg7c3_impacts.pdf. (February
2003).
Schueler, Tom. 1994. The Importance of Imperviousness. Watershed Protection Techniques.
1:3 (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.