20181597 Ver 1_Email_20181206

Carpenter,Kristi
From:Riffey, Deanna
Sent:Thursday, December 06, 2018 2:12 PM
To:'[e-mail]'; Steenhuis, Joanne
Cc:Herndon, T. Mason; Rivenbark, Chris
Subject:RE: \[External\] Bridge 47 B 4438
Attachments:B-4438_CE_Checklist_Final_Signed_12112017.pdf; PA 15-02-0012 Brunswick Survey Required
Form.pdf; PA 15-02-0012 Brunswick No NRHP Archaeological Sites Present Form.pdf
Good Afternoon,

See below for answers to your questions/comments. It took a little longer than expected. Hopefully we have addressed your
concerns. I know that you guys are working on this to get it back soon and have just got back these comments. If you could
provide an estimate of when the permit may be issued for us to relay to our contracts department, we would very much appreciate
it. They are trying to work out the details to keep the project on the January let date.

Thank you for your help,
Deanna

Deanna Riffey
Environmental Program Consultant
Environmental Analysis Unit
North Carolina Department of Transportation

919 707 6151 office
[e-mail]

Mail
1598 Mail Service Center Raleigh, NC 27699-1598

Physical Address
1020 Birch Ridge Drive Raleigh, NC 27610

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

-----Original Message-----
From: Rivenbark, Chris
Sent: Tuesday, November 27, 2018 8:58 AM
To: Shaver, Brad E CIV USARMY CESAW (US) <[e-mail]>
Cc: Herndon, T. Mason <[e-mail]>; Steenhuis, Joanne <[e-mail]>; Riffey, Deanna
<[e-mail]>
Subject: RE: \[External\] Bridge 47 B 4438

Thank you both for looking at this so quickly. I can answer #3 by confirming no jurisdictional impacts due to utilities. We usually
don't mention utilities if we're not proposing impacts.

I'll ask Deanna to respond to the other items.

Chris Rivenbark
NCDOT- Environmental Analysis Unit
[phone]

-----Original Message-----
From: Shaver, Brad E CIV USARMY CESAW (US) <[e-mail]>
Sent: Tuesday, November 27, 2018 8:40 AM
To: Rivenbark, Chris <[e-mail]>
Cc: Herndon, T. Mason <[e-mail]>; Steenhuis, Joanne <[e-mail]>
Subject: \[External\] Bridge 47 B 4438

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Chris,

Joanne and I have complied our additional information requests below regarding Bridge 47 replacement. This project is over a half
acre of wetland impact therefore thoughtful responses need to be returned to address the justification necessary for our decision
documents.

1. The project proposes to construct the new bridge to the east side of the existing bridge. There is no information or
description provided that the old bridge will be removed. Whether or not the DOT uses the removal for mitigation (as they are
proposing DMS mitigation) a description of the old bridge removal should be included in the application package.

NCDOT: The CE for the project indicated that the existing bridge and approaches will be removed once traffic is shifted to the new
alignment section (see attached - Section E: New Alignment). It is anticipated that the bridge will be removed from the top down
(no need for causeway or work trestle) and the piles will be removed by pulling them out with a crane. If piles break or cannot be
pulled out then they will be cut off below the mudline.

2. In addition, there is no justification provided as to why the new bridge is to be constructed on the east side. The west side
looks to have less wetlands. Please provide justification as to why the bridge needs to be placed on the east side. During the
scoping meeting it was noted that the project has a WRC Bear Sanctuary on the West side but projects have expanded to the side
of WRC game lands in the past. When Deanna sent this project out for comment months ago this was the same response
returned at that time. The NCDOT needs to show why moving the project to the West side, which appears to have fewer wetlands,
is not practicable.

NCDOT: NCDOT proposes to relocate Bridge No. 47 over Juniper Swamp on NC 211 in Brunswick County. The preferred
alternative relocates the bridge to the northeast of the existing structure. This is the preferred alternative for several reasons.

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1) Wetland impacts will be 0.78 acres for the preferred alternative on the northeast side. Wetland impacts were estimated, from
the NRTR, to be 0.45 acres for a southwest side alternative. However, this estimate did not include final design or utility
relocations, which could increase wetland impacts associated with the southwest side alternative. Once all affects were
accounted, final wetland impacts between the two alternatives (northeast and southwest) would likely be comparable.

2) In addition, the Juniper Creek Gamelands occur on the southwest side of the existing bridge. The gamelands include a Bear
Sanctuary and Green Swamp Nature Preserve Impacts to NCWRC gamelands would require approval from the NCWRC Board
and could be subject to a Section 4(f) evaluation. Section 4(f) of the US Department of Transportation Act of 1966 prohibits the
use of publicly owned land or historic properties for transportation projects unless there is no feasible and prudent alternative to
that use, and the action includes all possible planning to minimize harm to the property. Authorization to impact a Section 4(f)
property is not guaranteed when another viable alternative is available, and the costs associated with pursuing such authorization
may not have resulted in a different preferred alternative outcome.

3) The proposed route was discussed as the preferred alternative at the Field Scoping Meeting held on April 27, 2015, which was
attended by USACE and NCDWR. No concerns were raised by the review agencies following the Field Scoping Meeting. The
Categorical Exclusion (CE) for the proposed project was signed on December 11, 2017 (see attached). The CE document
identified the selected preferred alternative and was distributed to the regulatory review agencies. No concerns were raised on
the selection of the preferred alternative as identified in the CE document.

3. No utility drawings are provided. Will there be no impacts due to utilities. If not please provide a statement indicating this,
otherwise provide the utility drawings with the proposed impacts.

NCDOT: See answer from Chris R above.

4. Please provide a justification to the increased width of the road and therefore the amount of wetland impacts.

NCDOT: It was indicated at the FSM to use 12’ lanes per Roadway. The design criteria was also approved for the use of 12’
lanes. Lane widths are determined based on road classification, amount of traffic and design speed. This roadway requires 12’
lanes per AASHTO and NCDOT Roadway Guidelines.

5. "IS THE PROJECT AREA KNOWN FOR POTENTIAL INDIAN, COLONIAL, OR OTHER ARCHAEOLOGICAL SITES: Yes",
the preceding statement was taken from the Field Scoping Sheet (May 2015). The PCN indicates no what has changed since the
scoping meeting. If things have changed or further investigations have occurred indicating otherwise, please provide this
supportive information in the response.

NCDOT: The scoping meeting was held earlier in the process and that could be the reason a yes was given. The CE indicated
there were no National Register of Historic Places Eligible or listed archeological sites present or affected. I have attached two
reports to show the study area information and the results of the site review. The bridge project will not impacts significant
archeological resources.

If you have any questions about the list above please don't hesitate to give one or both of us a call,

Brad

________________________________

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