20181249 Ver 1_Attachment 18 - Draft DEIS Lochner re DOJ comments_20181217

GENERAL RESPONSES TO JASON'S COMMENTS:
Jason made many useful comments in terms of cleaning up clunky passages of text, which
I appreciate (I didn't realize he'd be taking on the role of general editor, but that's okay).
On the other hand, some of his "general editor" corrections are simply not correct and
shouldn't be changed.
Also, in some cases he deleted simple wording and replaced it with a higher level
vocabulary — but with no justification for doing so (in other words, his edits did not
change the meaning, they were just his editorial choices). These I have not changed, in
keeping with the reader friendly approach.
Regarding what I perceive to be his primary role of checking for legal accuracy, he made
many valid points and pointed out some vague or sloppy wording that could conceivably
pose a problem later. For that, I am grateful and have made the required changes. In
other cases, however, his changes seemed pedantic and unnecessary. These have not
been changed.
Throughout the text below I have accepted the changes (using "Track Changes") that
made sense and improved the text; those that I feel would not achieve this outcome I've
left unchanged and added my reasoning in comment boxes.
-- Jeff
CHAPTER 1
Study Overview
Understanding the proposed project,
why we need to study it, and how
this kind of study is done.
This chapter is an introduction to the study being conducted
for the proposed Complete 540 project. It describes the
proposed project and explains the requirements that guide
the environmental study being conducted for it.
THE PROPOSED PROJECT
The subject of this document is the "Complete 540" project—the proposed completion of the 540 outer loop that
today partially encircles greater Raleigh. As it exists today, the 540 outer loop extends around the north and west
sides of Raleigh. From its eastern ending point, at US 64/US 264 Bypass (I-495) in Knightdale, to I-40 in Morrisville,
it is called I-540. From I-40 southward to its western ending point, at NC SS Bypass in Apex, it is called NC 540. The
Comment [JS1]: GENERAL COMMENT: In
hindsight, I feel it makes more sense to use
the footnote style of references rather than
the author-date style. I think it's more
reader friendly and easier to prepare. I have
made those changes in this document. ]ust
for my own purposes, l have highlighted
them in yellow (so [ can find them easily
later).

DRAFT
Version 2 — 4/22/15
Complete 540 project would construct the remaining segment of the 540 outer loop, around the south and east
sides of the Raleigh area.
This proposed project has been under consideration for many years. An "outer loop" around the northern half of
Raleigh, beyond what is now the I-440 Beltline, was first included on long range plans in the mid-1970s. By the
mid-1980s, the pace of development in the area led NCDOT to expand the northern outer loop idea to a full loop
around all of Raleigh.11� _ _ _ _ _ _ _ _ _ _ _ _ _
The first section of what is now I-540 connected I-40 and US 70/Glenwood Avenue. This segment opened to traffic \
in early 1997. It was then extended in stages, in a clockwise direction, to Leesville Road, in 1999; to Creedmoor
Road, in 2000; to Falls of Neuse Road, in 2001; to Capital Boulevard, in 2002; and finally, to the US 64/US 264
Bypass, in 2007. Together, these segments form what is today Interstate 540. I2 L
�
The next extension of this outer loop came with the construction of Toll NC 540, which was originally planned as I
the Western Wake Freeway. This roughly thirteen-mile segment extended from I-540 at NC 54, southwest of I-40
and west of Raleigh, southward to NC 55 Bypass in Apex. With the completion of Toll NC 540, about 60 percent of
the 540 outer loop around Raleigh is now built and open to traffic. I
As these northern segments of the 540 outer loop were being built, route location planning was underway for the
southern and eastern segments. By the mid-1990s, initial planning for this remaining segment of the 540 outer
loop had been completed and a strip of land from NC 55 eastward to I-40, south and east of Raleigh, was identified
as a possible route location for the project. A potential route location from I-40 east to US 64/US 264 Bypass (I-
495) also began to be considered by transportation planners at about this time.
As with most large-scale highway projects, the funding for the northern and western portions of the 540 outer
loop was identified well in advance — in the early and mid-1990s. Then, as now, the main source of this funding
was the US Highway Trust Fund, which is supported by the federal and state taxes placed on gasoline and other
motor fuels. Economic conditions have changed since that time, and the purchasing power of the federal and
state tax on motor fuels, which has not been raised since 1993, has substantially declined as cars have become
more fuel-efficient and the costs of steel, asphalt, and other road construction materials have increased.
Comment [NCDOJ2]: True?
Documentation?
Comment [JS3]: [ would like to switch to
an endnote style of references. [ think iYs
clearer and easier for all involved. The
\ reference material will be organized by
chapter in the references section of the
document.
Comment [JS4]: The reference for this
statement is material contained in a website
called "Wake County Roads," a site that is
filled with otherwise hard to find
information.
I communicated with the person who
Ideveloped and maintains this site - Brian
LeBlanc. He did a lot of research as a
Istudent at NCSU and seems to be able to
back up his claims fairly convincingly. Plus,
iYs not particularly earth-shattering
information to begin with.
Comment [JS5]: LeBlanc, 2014
; Comment [NCDOJ6]: True? Documented?
Comment [JS7]: The edits 1've made to
this paragraph should satisfy ]ason's
comments because they essentially say just
� what the Turnpike's enabling legislation
says.
Comment [JS8]: The reference will be to
language in the Turnpike's enabling
legislation.
- �Comment [NCDOJ9]: True? Consistent
with purpose and need? Documentation?
- Comment [NCDOJIO]: True? Consistent
with purpose and need? Documentation?
-- Comment [NCDOJ11]: True? Consistent
with purpose and need? Documentation?
Comment [JS12]: Yes, these comments are
"true" from a general planning perspective -
which is precisely the perspective we're
presenting here. And, yes, they're
consistent with the study's purpose and
need statement - a report that contains all
the required documentation. Still, ['ve
added a references at the end of both
paragraphs so that we don't have any free-
floating assertions.
^� ,�����" �F *����These changing economic conditions, coupled with the rapid growth that was occurring in the
arJa meant that construction of the southern and eastern se�ments of the 540 outer loop project could not
proceed as rapidly as had other se�ments. These conditions were also an important reason that the state's
General Assembly formed the North Carolina Turnpike Authority, and why the western portion of the 540 outer �
loop was built as a toll Iroad.� �
The sustained pace of growth and development �lin the Triangle Region, and specifically in southern and eastern
Wake County, is today intensifying the kinds of transportation needs that were first identified decades ago and
Iwhich led to the planning and construction of the northern and western portions of the 540 outer loop. In
conducting the current study, NCDOT,reexamined those needs and concluded that completion of the 540 outer
loop could help address theml. �fhe next chapter of this document explains this in more detail and describes the
main purpose of the proposed project and the specific transportation problems it could help solve.4 �
FEDERAL, STATE, AND LOCAL COOPERATION
Construction of the existing 540 outer loop was possible only after extensive coordination and cooperation among
local, state, and federal agencies. This cooperation had its beginnings in the early 1960s with the passage of the
Federal-Aid Highway Act of 1962. Under this legislation, transportation planning is conducted for entire urban
areas rather than just within city limits, and planning is a cooperative activity between states and local
communities. This set the stage for a more "metropolitan" level of planning and resulted in the creation of a new
kind of agency that would be capable of carrying out these planning functions. These agencies became known as

DRAFT
Version 2 - 4/22/15
"metropolitan planning organizations," or MPOs, and quickly became established in urban areas around the
country in order to take advantage of federal matching funds. I5� _ _ _ _ _ _ _
In the Raleigh area, the Capital Area Metropolitan Planning Organization, or CAMPO, was formed in response to
the 1962 Federal-Aid Highway Act. CAMPO's formal governing body is ee+�ise�comprised o� �elected official�
from each of the cities and towns in the greater Raleigh area. CAMPO also has a staff of professional
transportation planners who conduct the analyses needed for the organization to carry out its mission. CAMPO
staff inembers and officials work closely with NCDOT staff to determine priorities ifor the following 15 to 20 years
for funding of needed transportation projects. These priorities are reflected in CAMPO's Transportation
Improvement Program and related Idocuments.l �
The subject of this Draft Environmental Impact Statement—the Complete 540 project—is included in CAMPO's
currently adopted Long Range Transportation Plan.
LAWS AND REGULATIONS THAT GOVERN THIS STUDY
Comment [JS13]: Weiner, 1988, pp 39
Comment [JS14]: This is correct as
originally written; the proper usage is
"comprises," not "comprised of." IVo change
required.
Comment [NCDOJ15]: Who determines
the priorities - NCDOT?
Comment [JS16]: I think the modification
to this last sentence should make this
adequately clear.
Comment [JS17]: Correct as written. The
Federal-Aid Highway Act of 1968 did indeed
REQU[RE hearings. No change needed.
Comment [JS18]: Weiner, 1988, pp 64
While the Federal-Aid Highway Act of 1962 was an important milestone in terms of transportation planning, there I; Comment [NCDOJ19]: The remainder of
have been several other Federal-Aid highway bills before and after the 1962 law. One of the fundamental I this chapter summarizes NEPA and parts of
the NEPA process. This material should be
purposes of most of these laws has been to authorize federal funding for surface transportation projects. In ; taken, verbatim if possible, from a public
addition, these bills and other related legislation: �I ' source such as the FHWA website.
• authorized construction of the interstate highway system (the Federal Aid Highway Ad of 1956) II i All edits suggested should be superseded by
. created the US Department of Transportation (the US Department of Transportation Act of 1966) text from such a source.
. improved highway safety standards (the National Traffic and Motor Vehicle Safety Act of 1966) I i Comment [JS20]: It's not always possible
to include verbatim passages - they're often
. protected parks, historic sites, and wildlife areas (the US Department of Transportation Act of 1966) lengthy and not reader-friendly. This
. �se�established public Ihearings on the effects of highway projects (the Federal Aid Highway Act �! I information is important to include but it
of 1968)�6 needs to be in a summarized, reader-
Ifriendly style. [ am not changing the
meanings in doing so.
In addition to these statutes there have been several other federal laws and Executive Orders that have a direct
bearing on how state highways are planned and constructed. Many of these will be discussed in more detail as !I
they apply to later chapters in this document. One, the National Environmental Policy Act of 1969, governs the
preparation of this DEIS and is described in the paragraphs that follow. ;�
�THE NATIONAL ENVIRONMENTAL POLICY ACTII �
�fhe National Environmental Policy Act, or "NEPA," serves as our nation's basic charter for protection of the
environment.� Among other things, it has established the way in which federally funded highway projects are
studied and how decisions are made about them �
In creating NEPA, Congress recognized "the profound impacY' of human activity "on the interrelations of all
components of the natural environment" and the "critical importance of restoring and maintaining environmental
quality." Congress further recognized "that each person should enjoy a healthful environment and that each
person has a responsibility to contribute to the preservation and enhancement of the environment." �8I
NEPA Policy
With these ideas established, Congress declared that it is the continuing policy of the federal government to use
"all practicable means and measures, including financial and technical assistance," to create and maintain
conditions under which humans and nature can exist in "productive harmony and fulfill the social, economic and
other requirements of present and future generations of Americans." NEPA states that this policy must be carried
out in cooperation with state and local governments and other concerned public and private organizations.l9l I�
NEPA Procedure
I don't know what Jason means by "public
source." What's a"private source?" 1'm
pulling most of this material - throughout
the document - from agency sources but
occasionally there is a text book or other
reference that is useful. And because it's
useful, Pm using it, as one would do with
any research paper. Also, these are not
contentious issues - it's NEPA 101. And
further still, FHWA's legal staff will be�
�Comment [JS21]: US Department of
Energy, Office of NEPA Policy and
Compliance. energy.gov/nepa/mission
Comment [JS22]: National Environmental
Policy Act of 1969; 42 U.S. Code § 4321
Comment [NCDOJ23]: Beyond the
general language concerning governmental
policy, the heart of NEPA is that agencies
must consider the environmental imp 2
Comment [JS24]: 1 have added a
paragraph that [ originally left out: NEPA's
stated purpose. Having added that, it puts
the next two paragraphs in context. [�
Comment [JS25]: ibid

DRAFT
Version 2 — 4/22/15
NEPA required that regulations be established to tell federal agencies what they must do to achieve the goals of
the Act. These regulations were developed by the Council on Environmental (luality (CE(1), which was established
in tandem with NEPA, ,��' ",,,� *"� �*,*� �� �F F��'��,'I',,.a The President and federal agencies share responsibility
for implementing these regulations so that NEPA achieves its policy objectives.
Under the CEQ regulations, federal agencies prepare a detailed assessment of the environmental effects of major
proposed government projects that would significantly affect the quality of the environment. This assessment,
called an Environmental Impact Statement, or EIS, addresses the following:
. the purpose of and need for the proposed action�
• the environmental impact of the proposed action�
. �adverse effects that could not be avoided if the project is implemented and measures that could
mitigate such effects� �
. reasonable alternatives to the proposed action� \
. the relationship between short-term uses of the environment and the maintenance and
enhancement of long-term productivity, and
. �irreversible and irretrievable commitments of resources that would be involved in the proposed
action. 1�l( �\
NEPA states that before the environmental document is prepared, the federal agency proposing the project "shall �
consult with and obtain the comments of any Federal agency which has jurisdiction by law or special expertise with
respect to any environmental impact involved." NEPA also states that the views of the appropriate Federal, State,
and local agencies be made available to the President, the Executive Office Council on Environmental Quality and
the public, and that these views must accompany the proposal throughout review processes. (More information
about the government agency coordination and public review requirement can be found in Chapter 6.)
THE NEPA PROCESS
The basic steps established by NEPA include the following:
1. Purpose and Need — This first step documents what the proposed project is intended to accomplish. In so
doing, an area's transportation problems are identified, needs are established, and a formal project purpose is
declared. These actions help focus the study on solutions that will help solve the specific transportation problem.
This sets limits on the type and location of possible reasonable alternative solutions to address the identified
transportation problem.
2. Affected Environment — The next step is to gain an understanding of the communities and natural features in
the area that could be affected by the proposed project. This step is necessary before the various project
alternatives can be compared in terms of their benefits and consequences.
3. Alternatives — Once an area's transportation problems have been identified, various ways of addressing those
problems can be developed and examined to determine whether they would meet the established purpose of the
project. These ways of addressing the problems are known as alternatives. Any alternatives that do not meet the
projecYs purpose are dropped from further consideration—before any additional resources are spent on their
development. Other alternatives may be eliminated if they don't rank well in terms of costs, benefits, or impacts.
4. Environmental Consequences — The alternatives that are found to meet the project's purpose are then /
analyzed to determine how they would affect the natural and human environment. These environmental
consequences are generally referred to as the projecYs "impacts" or "effects" •••" �" ,�� �„�^^,.m^ ���+�- ��rol�l
I11� Each alternative's impacts can also be compared against a measure of how well the alternative would meet the �
— — — — — — — — — — — — — — —
Comment [JS26]: They do have the status
of federal law*, and I think it's important to
say so. My source for this is Lynton
Caldwell, a professor who was one of the
"principal architects" of NEPA. The specific
reference is:
Caldwell, Lynton K. "[mplementing Policy
Through Procedure: [mpactAssessmentand
the National Environmental Policy Act
(NEPA)" [n Environmental Methods Review:
Retool ing lm pact Assessmen t for the New
Century, Porter and Fitipaldi, eds.,
International Association for [mpact
Assessment. Fargo, ND 1998 (page 11).
*although [ should have written "statutory"
instead of "federal" and will do so in the
update to this section.
Comment [JS27]: The CEQ regulations say
«any"...
Comment [JS28]: The CEQ regulations say
��any" ...
Comment [JS29]: Regulations For
Implementing The Procedural Provisions Of
The National Environmental Policy Act. 40
CFR 1500-1508.
Comment [JS30]: They are indeed
synonymous under NEPA, see citation
below.
Comment [JS37]: Regulations For
Implementing The Procedural Provisions Of
The National Environxnental Policy Act. 40
CFR 1508.8 - Effects.

DRAFT
Version 2 — 4/22/15
project's purpose, which can be thought of as the project's benefits. Measures are also identified that would
mitigate unavoidable impacts.
By documenting the results of these four basic steps in a written statement, and by making that statement
available for review and comment by governmental officials and the public, the NEPA process gives decision-
makers the type and quality of information needed to make informed decisions about where and how to
implement the project, or whether to proceed with it at all.
Each of these steps is explained in more detail in various chapters of this document.
COORDINATION BEfWEEN GOVERNMENTAGENCIES
Coordination between federal agencies is an important part of the NEPA process. CEQ regulations require that the
federal agency proposing the project must use "a systematic, interdisciplinary approach" and must "consult with
and obtain the comments of any Federal agency which has jurisdiction by law or special expertise with respect to
any environmental impact involved." Also, because NEPA applies to all federal agencies and because a significant
project or action may require action by two or more agencies, each of these agencies must ensure their own
compliance with NEPA for that project. To avoid duplication of effort, coordination between the two agencies is
helpful, sometimes including designating "cooperating" agencies or joint agency decision making.
In the case of highway projects, the Federal Highway Administration (FHWA) and state Departments of
Transportation routinely coordinate proposed projects with many other federal, state, and local agencies. These
often include the US Army Corps of Engineers, the US Environmental Protection Agency, the US Department of the
Interior (Fish and Wildlife Service), the US Coast Guard, and others. Likewise, there are various state agencies
charged with enforcing certain federal and state laws that apply to major projects.
Each of the agencies with responsibility for a proposed project are contacted early in the NEPA process and are
involved in the four main steps explained in the previous section. Working closely together helps these agencies
ensure compliance with the laws established for the protection of the natural and human environment. In
addition, as described earlier, other statutes and local regulations require that the proposing agency coordinate
with state and local officials. For the Complete 540 project the FHWA and the NC Department of Transportation
have conducted such coordination, along with the close cooperation of the Capital Area Metropolitan Planning
Organization (CAMPO) (see Chapter 6 for more detail).
PUBLIC INVOLVEMENT GOALS AND OPPORTUNITIES
NEPA and other federal laws require that the agency proposing the project provide opportunities for meaningful
public involvement. Members of the public or other stakeholders who might be affected by the project or have an
interest in it are notified of the proposal and given the opportunity to comment on the findings contained in the
Draft EIS. Over the years, public involvement opportunities have been expanded and now project agencies begin
public involvement early in the NEPA process, long before the Draft EIS has been prepared. The ways in which
agencies engage with the public has been expanded as well.
�fhis expanded public involvement effort now meets several objectives. First, it e+�s�+e�k�a�informs the public k+as
,",�'� „• ,�^^^« that the project has been proposed and is being studied. It further explains the goals and
objectives of the study itself. It also seeks information about the study area ;t�:# and how the project could affect
*`��m *"� �������*",� �` those who actually live and work in the area. It also ensures that members of the public
have aaer�-,!at�—�r.d�-� e,3�- ��_� ability to review the findings of the study, to ask questions about the project,
to understand the assumptions upon which the project's purpose and impact assessment are based, and to
provide comments about the project.L
Comment [JS32]: This paragraph, like
others in the document, suffers from having
/ been modified in response to various
comments. As a result, I agree that it now
could be more tightly written. I disagree,
however, with Jason's edits - they dilute the
message too much. Below is my rewritten
paragraph.

DRAFT
Version 2 — 4/22/15
This expanded public involvement effort now includes several obiectives. One is to ensure the public is aware that
the prolect has been proposed and a studv is bein� undertaken, and that this information is delivered early in the
studv process. Another is to receive information from those who live and work in the studv area about how the
proiect mi�ht affect them. And still another obiective is to ensure the public stays informed about the studv's
progress and can provide comments and ask questions about the proposed proiect's location and desi�n before
final decisions are made.
All public comments made about the proposed project are considered, and, when warranted, the project proposal
is modified in response to comments made. Regardless of whether public comments alter the project proposal,
comments made or questions asked receive responses and are documented in the Final EIS for review by federal
agencies. All substantive comments are addressed before the Final EIS is approved. Chapter 6 provides more detail
about how the public has been involved in the proposed project so far.

DRAFT
Version 2 - 4/22/15
CHAPTER 2
The Purpose of the Proposed Project
Understanding why the project has been
proposed and the problems it would help solve.
This chapter describes the proposed project ���' ������*� :�r��m�• ��
a�eu�� I why lit is needed and the problems it is intended to address. It also
explains the project's primary purpose and how that information is used
to develop alternative ways of ineeting area transportation needs.
AN INTRODUCTION TO PURPOSE AND NEED
�nl important � �f ni�nn .,�-.. �� i,r,.,., �part of this EIS is the ^�"purpose and need
statement " about the prolect. Preparation of this statement is an early step in the environmental study process
and is the foundation upon which additional development of the project is based. The purpose and need
statement � m���t��* "��� �� * spells out why the proposed project—with its ;�"�T..,�.���� costs and environmental
impacts—is being pursued. In other words, it establishes the rationale for the project and demonstrates the
problems that would result without it.
There are many advantages in clearly stating the project's purpose and t-k�need�'","�,�"� �",' ���•���^ILThese �
include: atlevwag-statin a shared understanding of the area's transportation problems and possible solution�
guiding development and evaluation of reasonable alternatives to meet the project purpose; ensuring project
decisions are legally defensible; and justifying project impacts and costs.
NEED
In purpose and need analyses, "need" describes the transportation problems the proposed project is intended to
address, which then forms the foundation for the purpose section of the statement. The need section establishes
evidence of current or future transportation problems or deficiencies and justifies the commitment of resources
and impacts to the environment. I
PURPOSE I
Based on ^��,��,T�.��,"'� these needs, the purpose section �*,*�� ,.,"„ *"� ������' �� "���rt ��������' " describes /
positive intended outcomes ,��' �� �*"� �"���*",��I �hat will address the documented needs. The state�
purpose of the project is required in order to develop and evaluate potential solutions to address the needs. It is /'
important that the statement of project purpose be 1) comprehensive enough to allow for a range of reasonable
alternatives and 2) specific enough to provide a reasonable limit to the range of all possible alternatives�.�,' /
Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint
dfld USlllg COPTIft1011 52f152. I12I �
Comment [JS33]: I disagree with Jason's
comment and suggest we keep it as is.
IComment [JS34]: R seems Jason missed
the idea that this introduction is intended to
not be project-specific - it is intended to
� I give a general sense of what the topic is
about,thusprovidingcontextforthe
Icurrent study. This is important, showing
that the current study is not an ad hoc effort.
I I agreed with some of Jason's comments,
particularly his softening of declarative
statements; others (where he seemed to
have miss the point) I do not want to
change.
Note: You cannot open an FHWA web page
on Purpose and Need without reading about
how important it is. And for good reason -
iYs fundamental to NEPA. [ would prefer we
don't shy away from that.
I understand Jason's desire to avoid
language that could seem like a
commitment, but iYs also possible to err on
the opposite end of the spectrum: by
purposely watering down the language of
the regulations, which, in effect, misstates
them
Comment [JS35]: This correct as [
originally wrote it.
Comment [JS36]: This is correct as I
originally wrote it.
Comment [JS37]: Jason's comments water
down the meaning of this paragraph too
much, in my opinion. My wording is based
Ion various FHWA and AASHTO guidance
materials, and is more reader friendly. 1 feel
it should remain as is.
Comment [JS38]: This sentence was taken
directly from FHWA guidance documents. [
have added a sentence, with its reference, to
/ help clarify this point.
, Comment [NCDOJ39]: This sentence is
% almost meaningless. Is reasonableness the
metric for both 1 and 2?
Comment [JS40]: Center for
Environmental Excellence by AASHTO
(American Association of State Highway and
Transportation Officials). Defining the
Purpose and Need and Determining the
Range ofAlternatives for Transportation
Projects. 2007, pp 5.

DRAFT
Version 2 — 4/22/15
Primary Purposes — In developing statements of purpose and need, two different kinds of purposes are possible.
A primary purpose is the "driver" of the project and reflects the fundamental reason the project is being pursued.
There can be one or more primary purposes. Any proposed transportation alternative that does not achieve the
primary purpose would be deemed unreasonable and thus eliminated from further consideration.
Secondary Purposes — Secondary purposes (often referred to as "other desirable outcomes") are additional
purposes that are desirable, but are not the core purpose of the project. They may not by themselves justify
eliminating alternatives based on not meeting the purpose of the project but they could factor into eliminating
alternatives based on other issues. Secondary purposes could also be considered in selecting a preferred
alternative.
PURPOSE OF THE COMPLEfE 540 PROJECT
Two primary purposes have been established for the Complete 540 project, based on general transportation
problems in the Raleigh area and specific, more localized needs. The first purpose is to improve mobility within or
through the study area during peak travel periods. The second purpose is to reduce forecast congestion on the
existing roadway network within the project study area.
A secondary purpose of the project is to improve system linkage in the regional roadway network by completing
the 540 outer loop around the greater Raleigh area—a goal that has been sought by area planners for more than
40 years. It is expected that construction of this remaining 540 link would benefit local commuters living south and
east of Raleigh as well as motorists making longer trips through the Triangle Region to and from points south and
east.
The transportation problems that form the basis for these project purposes, and the specific needs that stem from
those problems, are summarized in the paragraphs that follow.
TRANSPORTATION PROBLEMS IN THE RALEIGH AREA
Compared to other metropolitan areas around the country, the Triangle Region of Raleigh, Durham, and Chapel
Hill has been growing in population and associated land development at a rapid pace. The population of the
Raleigh-Cary metropolitan area, composed of Wake, Johnston and Franklin counties, has grown by over 52 percent
since 2000, making it the nation's second fastest-growing metro area.I13L
Within the Raleigh metropolitan area, much of this growth is taking place in southern and eastern Wake County
and in western Johnston County. Communities such as Cary, Apex, Holly Springs, Fuquay-Varina, Garner, Clayton,
and Knightdale have all seen exceptionally high growth rates since 2000, despite the significant downturn in
economic activity in the wake of the 2008 recession. Population projections point to continued rapid population
growth in the Raleigh area. The North Carolina Office of State Budget and Management anticipates that the
Raleigh area's population will expand by another 50 percent over the next two decades.114� �
Comment [JS47]: US Census Bureau,
2015a
�Comment [JS42]: NC Office of State
Budget and Management, 2014
Comment [NCDOJ43]: Do studies shaw
' II that the project primarily will "keep pace"
I� or will "induce growth."
Comment [JS44]: Again, this paragraph is
not meant to be project specific, iYs a simple
statement of fact, included for the lay citizen
who might need to be reminded that with
land development comes the need for public
services, and that roads are a part of those
services. Seems self-evident to all of us, but
perhaps not to others. So it's not a matter of
"studies show," ... it's just urban planning
101.
As land is developed to accommodate these kinds of population increases, public services, utilities and
infrastructure must also be expanded. These include such things as police and fire stations, medical facilities, and
schools, along with water lines, sewer lines, treatment plants, and electrical and communication utilities. Another
important element is the transportation system, which must also be expanded to keep pace �ith the Ineeds �Of new
communities.
�fhe health of a region's economy depends on many factors, with transportation being one of the most important.
Compared to other parts of the state and nation, the Triangle Region has a robust and diversified economy and is
considered one of the nation's strongest by some of the most respected local and national business organizations.
For example, both Bloomberg Businessweek (Bloomberg Business, 2014) and Forbes magazine (Forbes, 2014)
identify the Raleigh-Cary metropolitan area as an area that routinely attracts people and companies from other

DRAFT
Version 2 — 4/22/15
parts of the country. The Triangle Region consistently ranks among the top five areas for job growth, livability, and
general economic attractiveneslsl. _
SPECIFIC TRANSPORTATION NEEDS IN THE STUDY AREA
As mentioned earlier, the first step in identifying a purpose statement for a transportation project is to explore in
detail the transportation problems that are known to exist or are anticipated in the area. The next step is to use
that information to state specific needs that are going unmet in the area. Once an area's needs are clearly
identified, ways to address those needs can be developed and studied. The needs that have led to the
development of the proposed Complete 540 project are described in the paragraphs that follow.
1. More Route Choices
Much of the growth that has occurred in the Triangle Region over the past few decades has been in developments
that include mostly low-density, single-family residences. One outcome of this kind of land use is the heavy
burden it places on local roads. These single-family developments are often have few connection points to the
area's larger roadway network, meaning that vehicles leaving the development are all funneled onto the same
limited number of roads. The traffic congestion this creates becomes worse when there are long distances
between residential areas and employment locations, with several of these developments all needing to access the
same roadwaysl.L
As suburban development continues, the burden on the existing roadway network increases. The result can be an
excessive amount of lindirect travel because often there are few or no roads connecting these developments. In
other words, motorists need to drive distances are much farther than would be the case if these developments '
were better connected by local streets. This also results in high levels of traffic congestion on the area's principal
roads and intersections during daily peak travel timesl•I �
As noted by the Capital Area Metropolitan Planning Organization (CAMPO), the Triangle Region "is one of the
nation's most sprawling regions, and current forecasts project both continued outward growth and infill
development in selected locations, most notably in the central parts of Raleigh, Durham and Chapel Hill. A key
challenge for our transportation plans is to match our vision for how our communities should grow with the
transportation investments to support this growth."I15I
Therefore, because of the growth that has occurred and is expected to occur in the future, one need in the area is
to improve mobility by reducing indirect travel �and Iproviding additional route choices for those who live or work
in, or travel through, the study area. �
The majorjob center in the Triangle Region is the Research Triangle Park (RTP), home to more than 170 companies
and public institutions that employ over 50,000 workers. More than 25 percent of workers in the Raleigh area
commute to jobs in RTP.I16�Other important employment and retail centers are scattered across the Triangle
Region, including Raleigh-Durham International Airport and the nearby Brier Creek area, downtown Raleigh, the
North Carolina State University Centennial Campus in west Raleigh, the Crabtree Valley area in north Raleigh, and
the Crossroads area in southeast Cary.
Comment [JS45]: The intent was to add
evidence to the continuing need for
transportation projects. ButIseeJason's
point and will delete this paragraph.
Comment [NCDOJ46]: Why is this here?
Is economic health a primary or secondary
purpose of the project? If not, it should be
deleted.
Comment [JS47]: I accepted Jason's edits
to this paragraph and did some additional
re-writing to clarify the points being made -
again, iYs Planning 101, for the elucidation
of those who may not have been exposed to
these ideas before.
Comment [NCDOJ48]: What is indirect
travel?
Comment [JS49]: I have modified this
paragraph in an attempt to succinctly define
"indirect travel"
Comment [JS50]: CAMPO, 2009
- ' Comment [NCDOJ51]: Still don't know
what this is.
Comment [JS52]: 1 hope 1 have made an
adequate clarification above.
Comment [JS53]: RTP, 2014
Most travel in the Raleigh area is by private automobile. Nearly 90 percent of area residents' travel to work is by
car, and in nearly 90 percent of those trips, travelers drive alone.117� Most development in the Raleigh area has Comment [JS54]: US Census Bureau,
been and continues to be at low densities, leading to long distances between homes and jobs, retail destinations, 2015b
and other activity centers. In addition, there are few transit options in the area, particularly in the rapidly growing
areas south and east of Raleigh.
Residents of the rapidly growing communities in southern and eastern Wake County and western Johnston County
are currently dependent on certain existing roadways to reach their destinations. Many of these trips are made on
I-40 and I-440, routes that already serve high volumes of traffic. They are also the key routes used by commercial
truck traffic carrying goods across the region and other long distance traffic across North Carolina and beyond.

DRAFT
Version 2 — 4/22/15
Congestion on these roadways leads to less efficient travel across the region for commercial and other long
distance traffic.
Other routes connecting southern and eastern Wake County and western Johnston County to activity centers in
the Triangle Region include east-west roads such as Ten Ten Road and NC 42 and north-south roads such as NC 55,
US 401, NC 50, and US 70. Compared to high-speed facilities such as I-40, these routes have lower posted speed
limits, traffic signals, and more stop-and-go travel conditions. These factors lead to inefficient travel to key activity
centers such as RTP, Brier Creek, and Raleigh-Durham International Airport.
2. Reducing Congestion on the Existing Roadway Network
Today, many of the roadways south and east of Raleigh are moderately to extremely congested during "rush hour"
or, more specifically, the morning and evening peak travel times. This is especially true along roads near large
activity centers such as RTP and Raleigh-Durham International Airport. These levels of congestion are expected to
worsen over the next several years.
One of the most common ways planners measure different levels of traffic congestion is known as "level of
service," or LOS. The method for determining these levels can be complicated, but the measuring system itself is
fairly simple: roadway or intersection LOS can range from "A" through "F," with A being the best condition and F
the worst condition. At level of service A, traffic is light; vehicles can move freely with no conflicts from other
vehicles. At level of service F, traffic moves very slowly and is at or near the condition commonly known as
"gridlock."
During the morning and evening peak travel times, many of the roadways south and east of Raleigh operate at
poor levels of service. These include: segments of I-40 south of central Raleigh; much of NC 42 between NC 55 and
I-40; portions of Ten Ten Road south of Apex; and, much of NC 50 south of Garner.
Estimates prepared by transportation planners at CAMPO show that by 2035, traffic volumes on area roads will be
about double what they were in 2005. This increase in traffic, along with anticipated population growth and
continuing land development, will mean that an increasing number of roadway segments and intersections will
have unacceptably low levels of service. CAMPO's 2035 Long Range Transportation Plan, and its 2040 plan, both
identify many future transportation projects that would help counter this increase in traffic congestion, including
the Complete 540 project.
To understand the specific effect the proposed project would have on area roadways in the future,, it is necessary
to determine� n�ihat planners refer to as the "No-Build" roadway network. This network is defined as all the major _- Comment [NCDOJ55]: [s it "necessary" or
roadways in the greater study area that either currently exist or are included in adopted future plans, but not isthisoneapproachthatmaybetaken?
including the proposed project. This gives a picture of what traffic conditions would be like in the future without Comment [JS56]: Yes, it is necessary.
the project. Then, the same calculations are made, but with the proposed project included. This is referred to as
the "Build" roadway network. By comparing the No-Build to the Build condition, the effect the proposed project
would have on the major roadways can be more precisely determined.
After conducting this analysis and comparing the No-Build to the Build condition, the project team concluded that
under the No-Build condition, levels of service will worsen to LOS E or F, which indicate poor conditions, on many
of the area's roadways by 2035. These include almost all segments of I-40, US 1/US 64, Ten Ten Road, NC 42, and
NC 50, and portions of NC 55. Poor levels of service mean conditions would be at or near gridlock during both the
morning and evening peak travel times.
FOR MORE DEfAILED INFORMATION
Several technical reports prepared for this study contain more detailed information on the human environment
effects described above. These include:
10

DRAFT
Version 2 — 4/22/15
IPuroose and Need Statement
Communitv Characteristics Report
Build and No-Build Traffic Analvsis Reoort
Traffic Forecast Report I
�
More information about these documents can be found in Chapter 7—Summary of Technical Reports. Chapter 7
also provides information about the ways those documents can be accessed, either in paper or electronic form.
Comment [NCDOJ57]: [s every fact and
conclusion stated above to be found in one
of these reports?
Comment [JS58]: Most of the info is found
in these reports. However, EISs can contain
original information, too, correct? So iYs not
absolutely mandatory that every assertion
in the E[S also be in some technical report.
11

DRAFT
Version 2 - 4/22/15
CHAPTER 3
The Study Area and Its Features
Understanding the important characteristics of
the area where the project would be built.
The purpose of this chapter is to describe natural, social, and built�iJ I
conditions in the area of the proposed project.
This is er�important ^��' �f'"� "'��^ � « because it establishes
a baseline or standard against which project impacts eKe-may be measured.
INTRODUCTION
Comment [NCDOJ59]: What does this
mean?
Comment [JS60]: It means everything that
is not part of the undisturbed "natural"
/ environment or the homes and businesses
and institutions in which our social lives
mostly occur. In other words, iYs basically
infrastructure. These categories are not
meant to be rigid or strictly defined. The
main reason for distinguishing them is so
that people don't think that NEPA's use of
the word "environment" only means the
natural world. Still, I will change "built
conditions" to "nhvsical features"
; �Comment [NCDOJ67]: What does this
mean?
,� Comment [NCDOJ62]: Are social
characteristics"physicalfeatures?„
Comment [JS63]: I have re-written the
second sentenceto addressJason's
comments above.
j Comment [NCDOJ64]: What information,
collected by whom?
Comment [JS65j: This phrase should
answer Jason's question.
Comment [NCDOJ66]: What key factors?
Comment [JS67]: The key factors are
explained in the chapter. I don't think it
flows, or is necessary, to explain them in the
introduction.
Having established the purpose of the project, the next step is to begin exploring alternative ways of achieving that
purpose. , ,
a€fee�. Before that can be done, however, it is important to understand the social characteristics, natural
environmental features, and certain phvsical features that have been built in the studv area that could be affected /
by the proposed project�•I
This chapter describes the',information that was collected by the studv team about the proiect area��and explain� _
the key factors �that could be affected by the proposed project. It is not a comprehensive inventory of all the many
natural and sociai factors �that re present; instead, it focuses on factors that have a bearing on the type of projec�
being proposed and on the factors that have an influence on the physical locations of the project alternatives. '
These include categories such as endangered species, relocations, sensitive water bodies, and others. \
Often referred to as the "affected environment" chapter, this section of an EIS helps decision-makers focus on the
projecYs key issues. It is a+}important ���� �� *"� "'�°^ � « because it sets �a baseline against which
impacts aramav be measuredl•�
This chapter begins with a description of the projecYs study area. It then presents information about the
important community characteristics and features of the natural environment in this area, followed by information
about the buil��environmen�.
THE STUDY AREA
� \
\
The general location of the proposed project is called the study area. The study area boundaries are expansive �.
enough to allow a range of reasonable alternatives to be studied. As shown on the map on page 2 of this
document, the Complete 540 study area extends between the projecYs western terminus at NC 55 Bypass in Apex �
and its eastern terminus at US 64/US 264 Bypass (I-495) in Knightdale. To the north, the study area boundary
corresponds with the southern outskirts of Raleigh and Cary; the southern boundary of the study area corresponds
to NC 42. The study area includes much of southeastern Wake County and parts of northern Johnston County. It
Comment [NCDOJ68]: What factors -
Until the last sentence of this paragraph,
these tow first paragraphs are extremely
vague.
Comment [JS69]: See my comment above.
This paragraph is intended to be just a few,
brief introductory sentences.
Comment [JS70]: IYs not just "a" baseline,
it is in fact "the" baseline. It is also part of
the NEPA process, and not some other
process, so why not be clear about it? I
suggest we leave it as it.
Comment [NCDOJ71]: Still not explained.
Comment [JS72]: I believe my edits above
now explain it.
12

DRAFT
Version 2 — 4/22/15
also includes parts of eight incorporated cities and towns—Apex, Holly Springs, Cary, Fuquay-Varina, Garner,
Raleigh, Knightdale, and Clayton—along with many unincorporated communities.
LAND USE AND POPULATION CHARACTERISTICS
The way the landscape has been developed and is being used and the communities that are found in the study
area may affect where a new highway such as the proposed 540 could be located. These elements of the human
environment are summarized below.
Suburban Development
As recently as the early 1990s, much of the land in the study area was rural or undeveloped. The most common
development in the study area was in the form of farms and other agricultural activities. Non-farm residences
were widely scattered, often on large rural lots. Starting generally about 20 years ago, this pattern began to
change, with suburban-style residential developments increasingly replacing agricultural or vacant land. Today,
suburban development is the dominant land use throughout much of the study area.
Although there are variations to the pattern, a common set of characteristics defines this suburban development.
These developments are dominated by single-family, detached homes, many of which are relatively large in size
compared to the typical housing built in the area in previous decades. The residents of these homes have been
highly dependent on the individual automobile. For example, nearly all the trips to work made in the study area
(93 percent) between 2009 and 2013 were by car.118� Another common characteristic is a system of local streets Comment [JS73]: US Census Bureau,
that are typically contained within each individual development, with few connections to larger, regional roads 2015a
(commonly called "arterials").
��',' Commercial and office land uses�ese �tend �to either be spread out along the major arterials, with
access provided to each individual parcel, or are clustered in "plaza" style developments at the intersections of
major roads. These plaza-style developments tend to have large parking areas near the roadways, with the
commercial structures placed along the rear of the parcels. Major commercial arterials in the study area include
NC 55 Bypass, US 401, US 70 Business, and NC 42 near I-40. Major commercial intersections include Holly Springs
Road at Sunset Lake Road, Ten Ten Road at Kildare Farm Road and Holly Springs Road, US 70 Business at White
Oak Road, Timber Drive at NC 50, and Rock Quarry Road at Battle Bridge Road.
Although suburban residential, commercial, and office development predominate, there are small areas of light
industrial land uses in the study area as well. These are located in an area near the I-40 interchange at US 70
Business, along US 401, and near the western project terminus area, at NC 55 Bypass.
These land uses are not spread evenly throughout the study area. Much of the suburban development has
occurred west of US 401 in the vicinity of the existing communities of Holly Springs, Fuquay-Varina, Apex, and Cary.
In the north-central portion of the study area, in and around the town of Garner, there are pockets of older, higher
density development, generally north of Timber Drive. There are also pockets of farming and undeveloped tracts,
generally located near NC 42 between US 401 and NC 50, and throughout the area east of I-40.
Development continues to be planned and built in the study area at a relatively rapid rate, but the characteristics
of these developments are changing. Many of the community leaders in the study area are now promoting
developments that are not solely residential, with a trend towards mixed-use, higher density, clustered
development at major intersections and interchanges.
Most of the existing higher density developments in the study area are located near NC 55, along US 401, along US
70 Business, and near the I-40 interchange at NC 42. These tend to be smaller apartment complexes and
townhouse developments. In response to strong regional and national trends, local governments are planning for
an increasing percentage of new residential construction to be of this multi-family, higher density variety.
Comment [JS74]: With the exception of
deleting the word "common,,, I think it is
better to keep this sentence as originally
written.
13

DRAFT
Version 2 — 4/22/15
In addition to shifting the type of land development to more mixed uses, most of the smaller communities that
ring the study area are seeking to maintain or build upon the "small town" or traditional "main street"
characteristics that have historically been present in their downtown core areas.
Parks and Recreation Facilities
Parks and recreation facilities are important components of the overall community fabric and, for purposes of
highway planning, they are alse�e+�sideKedoften designated as protected land uses. '^��Section 4(f) of
the US Department of Transportation Act of 1966, states that public parks and recreation facilities �cannot in
most cases, be disrupted by highway projects unless it can be shown that there are no feasible and prudent
alternatives to doing so. Given that it is hundreds of square miles in size, the Complete 540 study area contains \
many small parks and recreation facilities that are protected in this waV•
�fhere are several notable park facilities in the study area. A string of linked smaller parks in the community of
Garner together comprise a large area of parkland. These smaller parks include: South Garner Park, Thompson
Park, White Deer Park (which is planned for expansion), and Lake Benson Park. In addition, the planned Bryan
Road Nature Park is intended to connect to Centennial Park by way of the Mahler's Creek Greenway. The Town of
Cary's Middle Creek School Park, which connects to several existing and planned greenways, comprises another
large area of parkland in the study vicinity. Another substantial park facility is Clemmons Educational State Forest,
a park and conservation site on Old US 70 at the Wake-Johnston county border, northeast of Clayton. The Neuse
River Trail is a 28-mile long greenway trail adjacent to the Neuse River, to the east of Raleigh. A notable planned
facility is Southeast Regional Park, a county park that Wake County plans to construct near NC 42 and Barber
Bridge Road, in the Willow Springs area. Another notable planned facility is Sunset Oaks Park, which the Town of
Holly Springs plans to construct in the Sunset Oaks neighborhood. Each of these parks are or have the potential to
be protected bv the Section 4(f) Irequirements� �
Historic Properties and Districts
Like recreation facilities, historic properties or districts e€�er�ma qualify �for protection, under Section 4(f) of the
US DOT Act or Section 106 of the Historic Preservation Act of 1966, or both. In order to be protected by these
statutes, properties or districts must be listed on the US Department of the Interior's National Register of Historic
Places or be determined to be eligible for listing on the National Register. In some cases, local historic sites or
districts may not be eligible for National Register listing but are still considered important enough to be considered
in locating new highways.
Other than the downtown areas of Fuquay-Varina and Garner, there is only one large-sized historic district in the
study area that is on the National Register—a 338-acre rural historic district located on both sides of Sunset Lake
Road in Fuquay-Varina.
Several other, smaller properties are currently listed on the National Register, but they are scattered throughout
the study area, with no concentrated locations. For the purposes of studies such as the one being conducted for
the Complete 540 project, properties that are not listed on the National Register but have been found to be
eligible for listing are treated as if they were listed. The listed and eligible properties found in the study area are
discussed in more detail in Chapter 5 of this document.
Other Public or Semi-Public Land Uses
There are several other public or semi-public land uses and facilities that, while not protected by regulations, could
influence the location of a new highway. These include hospitals and other medical facilities, emergency service
locations (for example, police and fire stations), educational facilities, places of worship, military installations,
prisons, or other large public holdings. Given the size of the Complete 540 study area and the large number of
people that live within it, these types of public or semi-public land uses are numerous and scattered throughout
Comment [NCDOJ75]: Always? Or "they
may be considered..:'
Comment [NCDOJ76]: [s this true of
every park - private, town, county, state or
federal? Does this statement not sweep too
broadly?
Comment [JS77]: ]ason was correct: this
section was worded too broadly. [ have
adjusted the wording accordingly.
- - Comment [NCDOJ78]: Given the prior
paragraph, this implies that all of these
parks are section 4(� resources. Are they?
Comment [JS79]: Adding this sentence
should address Jason's comment, above.
Comment [JS80]: Well ... they almost
always qualify, correct? [ suggest we keep it
as is for the sake of being more accurate.
14

DRAFT
Version 2 — 4/22/15
the area. For example, there are dozens of public K-12 and private schools and numerous places of worship
scattered throughout the study area.
Notable properties in these categories include:
. the main campus of Wake Technical Community College, which is located on US 401 in
unincorporated Wake County, between the towns of Garner and Fuquay-Varina.
. Randleigh Farm—a large tract on Battle Bridge Road jointly owned by Wake County and the City of
Raleigh intended for use as a planned development.
. NC State University/USDA property, a planned development located along US 70 Business, near
Wake/Johnston county line (this property is currently the NC Central Crop Research Station).
• a large area owned by City of Raleigh east of Randleigh Farm, which includes a police training facility
and the Neuse River Wastewater Treatment Plant.
• the Dempsey E. Benton Water Treatment Plant, on NC 50 in Garner.
ECONOMIC CHARACTERISTICS
The Raleigh area has a robust and diversified economy and includes many of the State's largest employers. These
include numerous universities, Research Triangle Park, and state government. Other important area components
of the area's employment mix include biotechnology, information technology, higher education, and health care.
The North Carolina Department of Commerce-Division of Employment Security (DES) projects that the Capital Area
Workforce Development Board (WDB) area, which includes Wake and Johnston counties, will gain 112,810 jobs
between 2010 and 2020, an increase of 21.5 percent. Local planners also anticipate continued job growth in the
project area and many jurisdictions anticipate that commercial land uses will make up a growing share of local land
uses.
Income Levels
The median household income in the project study area is somewhat higher than median household incomes in
Wake or Johnston County and is much higher than the state's median household income. A smaller percentage of
study area residents have incomes below the federally defined poverty IeveI.I19L Likewise, homes in the study area
have a higher median value than in either county or the state as a whole. Incomes are generally higher along the
study area's western side, in southern Cary, Apex, and Holly Springs. Some parts of the study area, however, are
characterized by lower incomes, higher rates of poverty, less homeownership, and lower home values. These
areas are generally concentrated along the north central and northeastern edges of the study area (in Garner,
southeast Raleigh, and Knightdale) and in central Clayton.
Racial/Ethnic Percentages
The racial and ethnic makeup of the study area is similar to the overall makeup of Wake and Johnston Counties.
About 33 percent of residents of the study area self-identify as members of minority racial or ethnic groups.
Minority populations in the study area are more concentrated at its northern edge, in Garner, southeast Raleigh,
and Knightdale. Hispanic residents are concentrated in Garner, Clayton, Knightdale, and near US 401. About five
percent of study area residents are classified by the US Census Bureau as having limited English language
proficiency�++Na= most of these individuals �ei+�gare panish�-speakers. 20I �
NATURAL ENVIRONMENT CHARACTERISTICS
In addition to the study area's various land use characteristics, there are also natural environment elements that
can affect where a new highway such as the proposed project could be located. These include rivers, streams and
Comment [JS87]: US Census Bureau,
2015a
Comment [JS82]: I think the sentence
flows better as originally written.
Comment [JS83]: US Census Bureau,
2015b
15

DRAFT
Version 2 — 4/22/15
lakes; wetland areas; and areas with federally protected plant or animal species, and other protected areas. These
elements of the natural environment are summarized below and are described in much greater detail in the
study's Natural Resources Technical Report.
PHYSICAL SETTING OF THE STUDY AREA
The Complete 540 study area is located in North Carolina's piedmont region, which is described as the area of
gently rolling hills separating the coastal plain from the Appalachian Mountains. Elevations in the study area range
from 140 to 460 feet above sea level. The study area itself lies mainly within the Neuse River basin, with a small
portion extending to the Cape Fear River basin at the far western edge of the study area.
Area Rivers, Streams, Lakes
There are no natural lakes in the region; all water bodies with substantial surface areas are "impounded," formed
by dams on rivers and streams. The principal rivers and streams in the study area include the Neuse River, Swift
Creek, Middle Creek, and Little Creek. These are shown on the "Water Resources" map on page 33. Large
expanses of floodplain are not present in the study area; however, narrow bands of floodplain areas are found
along stream edges.
Neuse River — The Neuse River is the largest river in the study area and is an important water resource. The reach
of the Neuse River within the study area has been identified by the NC Wildlife Resource Commission (NCWRC) as
an Anadromous Fish Spawning Area. An anadromous fish species is a species that is born in fresh water, spends
most of its life in the sea, and then returns to fresh water to spawn. Anadromous Fish Spawning Areas are
portions of rivers or streams designated by NCWRC as places where spawning of anadromous fish has been
documented through direct observation of spawning, capture of running ripe females, or capture of eggs or early
larvae.
Although it supports these fish populations, the Neuse River in the study area also is listed on the North Carolina
2014 Final 303(d) list of impaired waters due to high copper Ievels.I2l�See "Water Resource Protection," on the Comment [JS84]: NCDENR 2015
facing page for additional information.) The portion of the Neuse River in the study area for this project is
classified as Class C waters, which include secondary recreation, fishing, wildlife, fish consumption, aquatic life
including propagation, survival and maintenance of biological integrity, and agriculture.
Development within the Neuse River basin is subject to the Neuse River Buffer Rules, administered by the NC
Department of Natural Resources-Division of Water Resources (NCDENR-DWR). These rules require development
within the Neuse River basin to maintain minimum 50-foot buffers along each side of streams.
Swift Creek (including Lake Benson and Lake Wheeler) — Swift Creek is an important water body in the study area
and includes two impounded areas that form Lake Benson and Lake Wheeler.
As shown on the map on the following page, in the Complete 540 study area, Swift Creek has been classified as
Water Supply III (WS-III), which is defined as waters used as sources of water supply for drinking, culinary, or food
processing purposes. Like the Neuse River, these waters are also protected for Class C uses. A management plan
is in place for Swift Creek and its impounded water bodies (Lake Wheeler and Lake Benson). This plan established
the boundaries of the Swift Creek Watershed Critical Area. It also established strict limitations on development
within the Watershed Critical Area.
In addition to these water supply protections, portions of Swift Creek in the study area are on the North Carolina
2014 Final 303(d) list of impaired waters due to "impaired benthic integrity," which refers to the biological
condition of la stream�
Portions of Swift Creek in the study area also support populations of the dwarf wedgemussel, a species of mussel
listed by US Fish and Wildlife Service (USFWS) as endangered. (See page 35 for more detail.)
Comment [JS85]: Jason wanted to change
this to "creek bottom;' but that is incorrect.
16

DRAFT
Version 2 - 4/22/15
Development within Swift Creek WS-III watershed is limited by watershed protection policies, which limit
development densities near Swift Creek, within Wake County's 1990 Swift Creek Land Management Plan area.
This plan identifies a Watershed Critical Area immediately surrounding Lake Wheeler, Lake Benson, and Swift
Creek between these two lakes. Development is limited to very low densities within the Critical Area.
Little Creek— Little Creek is located near Clayton, in northern Johnston County, where it flows into Swift Creek. It
is on the North Carolina 2014 Final 303(d) list due to impaired benthic integrity and a poor fish community. Little
Creek is classified as Class C waters.
Middle Creek and Terrible Creek— Middle Creek and Terrible Creek are two streams in the western part of the
study area. Portions of both are on the North Carolina 2014 Final 303(d) list of impaired waters. Middle Creek is
on the list due to impaired benthic integrity and a poor fish community. Terrible Creek, which flows into Middle
Creek, is on the list due to impaired benthic integrity. Both Middle Creek and Terrible Creek are classified as Class
C waters.
Beddingfield Creek — Beddingfield Creek is in the eastern part of the study area, where it flows into the Neuse
River. It is on the North Carolina 2014 Final 303(d) list due to impaired benthic integrity. Beddingfield Creek is
classified as Class C waters.
Wetlands
The Clean Water Act (CWA) defines wetlands as "areas that are inundated or saturated by surface or groundwater
at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence
of vegetation typically adapted for life in saturated soil conditions." Wetlands generally include swamps, marshes,
bogs, and similar areas. Pockets of small wetlands are scattered throughout the area and are mainly associated
with rivers and streams.
An initial analysis of wetland type, quality, and location was made for the entire study area by consulting the
National Wetlands Inventory (NWI) database, which is maintained by the USFWS. More precise mapping of
potentially impacted wetlands was done through on-the-ground field work, conducted by qualified biologists, to
determine the precise location of CWA wetlands. These more detailed determinations are described in Chapter 5
of this document.
Upland Areas (Terrestrial Communities and ForestsJ
Aside from rivers, streams, floodplains, and wetland areas, most of the study area's "upland" areas consist of land
that is classified as "maintained/disturbed" (such as lawns, roadway shoulders and ditches, etc.) or
"agriculture/pasture" land (according to NC OneMap classifications). In addition, the study area also contains a
large amount of forested land.
Other Notable Areas /
Several sites are designated by the North Carolina Natural Heritage Program (NHP) as NHP Natural Areas. This
designation doesn't afford any special protectionl, but does indicate that the site is lunique from an ecological '/
perspectivel. II of the NHP Natural Areas in the study area are listed in the Community Impact Assessment Report. 1
Most of these sites are associated with or near Swift Creek, Middle Creek, or the Neuse River�.L � '
Protected Species
An important consideration in the Complete 540 study is making sure that the requirements of the Endangered
Species Act of 1973 are met. The purpose of this legislation is to protect and recover imperiled species and the
ecosystems upon which they depend. The USFWS and the National Marine Fisheries Service have the
responsibility of administering the Act. These agencies maintain a list of species that have been determined to be
endangered with extinction or are threatened and may become endangered.
Comment [NCDOJ86]: What does this
mean? That it is not subject to any
regulation due to its status as an NHP
Natural Area?
Comment [NCDOJ87]: Really - unique?
That seems unlikely.
Comment [JS88]: ['m aware that the
word "unique" means "unlike any other." Its
misuse is one of my pet peeves, and seems
to be one of Jason's, too. Occasionally, an
incorrect usage of "unique" slips through,
however, as happened here.
Comment [JS89]: 1 agree with Jason. I will
delete references to protection and instead
include text the following text:
A NHP natural area is an area of land or
water that is important for the conservation
of the natural biodiversity of North Carolina.
The IVatural Heritage Program identifies
these natural areas based on biological
surveys. Identification of these natural areas
is based on ecological and biological
information, rather than property
boundaries.22
17

DRAFT
Version 2 — 4/22/15
Several endangered plant and animal species are listed as loccurring in either Wake or Johnston counties. These
include:
Red-cockaded woodpecker (Picoides borealis) — This species typically occupies open, mature stands of southern
pines, particularly longleaf pine. It excavates cavities for nesting and roosting in living pine trees, aged 60 years or
older.
Tar River spinymussel (Elliptio steinstansana) — In North Carolina, this species is found in the rivers and streams of
the Neuse River and Tar River basins.
Michaux's sumac (Rhus michauxii) — This plant is found in the inner Coastal Plain and Piedmont regions of North
Carolina. It grows best in areas where disturbances have created open areas.
Northern long-eared bat (Myotis septentrionalis) — This species was listed as a federally threatened species in April
2015. It is found primarily in western North Carolina, but scattered loccurrences lexist in central and eastern North
Carolina.
Of particular importance to the Complete 540 project is the dwarf wedgemussel (Alasmidonta heterodon) which is
found in the rivers and streams of the Neuse River watershed and could be directly affected by the proposed
project.
PHYSICAL CHARACTERISTICS
Comment [JS90]: ]ason wanted to change
"occurring" to "present;' but that changes
the meaning. [ realize that "occurring" is not
likely to be as reader-friendly, but I think we
should just let it stand.
Comment [JS91]: Again, Jason suggests
we change this to "populations;' or some
such. Even though "occurrences" isn't
paMicularly reader friendly, 1 think it's more
accurate to leave it as is.
In addition to the study area's various land use characteristics and natural environment elements, there are also
various human-made, or "built," structures �that can affect where a new highway such as the proposed 540 could . Comment [NCDOJ92]: [s this the "built
be located. These include such things as other highways, water and sewer plants, various power stations and conditions"referredtobefore?
power lines, fuel transmission pipelines, underground storage tanks, as well as areas that have been found to be Comment [JS93]: Yes,butthe earlier
contaminated with hazardous materials. These elements of the built environment are summarized below and are references have nowbeen re-written. This
described in much greater detail in the study's Community Impact Assessment Report, Utilities Impact Report, and should now make sense here, without
Geo-Environmental Report (see list of reports at the end of this chapter for a full list of source materials.) modification.
HIGHWAYS
Because the proposed 540 project would be a limited-access highway, with access to and from it only allowed at
interchange on and off ramps, the location of other major roads that would intersect with 540 is an important
consideration. These include the following:
• NC 55 Bypass • Holly Springs Road
• Bells Lake Road • US 401
• Old Stage Road • NC 50
• I-40 • White Oak Road
• Old Baucom Road • US 70 Business
• Auburn Knightdale Road • Poole Road
• US 64/US 264 Bypass (I-495)
These intersecting roads are important because *'�� '���' �� '���' F�•constructing interchanges can result in
various impacts, and because of potential changes in traffic patterns, and ^�«�"'� �",�T�� �� land uses, around
them.
DRINKING WATER AND WASTE WATER TREATMENT FACILITIES
Facilities that purify drinking water or treat wastewater are typically owned and operated by local or regional
governments and ,�� �"�������" �`require substantial public investment. Because they represent a type of land use
that would be expensive and potentially disruptive to relocate, they are best avoided when seeking routes for new
18

DRAFT
Version 2 — 4/22/15
roads such as the proposed 540 project. The major wastewater treatment facilities in the study area include the
following:
City of Raleigh Dempsey E. Benton Water Treatment Plant — This facility is located on NC 50 in Garner; it also has
an associated bio-solids treatment facility on Wrenn Road near I-40.
City of Raleigh Neuse River Wastewater Treatment Plant — This facility is located on Battle Bridge Road, in the far
eastern portion of the study area.
Western Wake Regional Water Reclamation Facility — This facility is located just west of study area and is jointly
operated by Cary, Apex, Holly Springs, and Morrisville.
South Cary Water Reclamation Facility — This facility is located on West Lake Road, east of Holly Springs.
Town of Apex Water Reclamation Facility — This facility is located on Pristine Water Drive, near the extreme
western edge of the project.
Town of Clayton Little Creek Water Reclamation Facility — This facility is located on Durham Street, in Clayton.
ELECTRICITY AND FUELS GENERATION AND DISTRIBUTION
Although power plants, large power lines, and fuel pipelines are more often privately owned than are water
facilities, they still represent large, expensive built structures that would be costly and potentially disruptive to
relocate. Therefore, as with water facilities, they are best avoided when developing new highways.
In the Complete 540 study area there are two electric power substations—one on Battle Bridge Road and another
on Ten Ten Road near Sauls Road. There are also several large powerlines that traverse the study area.
Underground, there are two natural gas pipelines that cross the study area.
The Complete 540 study area also includes a solar field managed by the City of Raleigh. This facility is the Neuse
River Solar Farm, located on a 30-acre tract at the corner of Battle Bridge Road and Brownfield Road in the eastern
part of the study area.
COMMUNICATIONS FACILITIES AND DISTRIBUTION LINES
Another factor in locating new highways is the presence of communication towers. The Complete 540 study area
contains several such towers in various locations. One particularly noteworthy installation is a group of three
towers located along US 70 Business, just north of Clayton. These towers are important because they include
warning sirens for the Shearon Harris Nuclear Power Plant (west of Holly Springs), Federal Aviation Administration
air traffic control communications equipment, and cell phone transmission facilities. Given these functions,
relocation to accommodate a highway would be costly and potentially disruptive. As a result, its presence is a
factor in developing various route location options.
CONTAMINATION SITES, HAZARDOUS MATERIALS, AND LANDFILLS
The built environment also includes sites that either store hazardous materials or have been designated as
contaminated, as well as landfill sites. Facilities that store hazardous materials are located throughout the study
area, mainly along major roads. These sites include gas stations, former gas stations, auto repair and salvage
facilities, and dry cleaners. No large scale contamination sites are known to exist in the study area.
There are three landfills in the study area. The South Wake Landfill is located just south of the existing end of NC
540, at NC 55 Bypass in Apex. The Buffaloe Landfill is located on the west side of US 401, about a mile south of US
70 Business. There is also a construction and demolition debris landfill on Brownfield Road south of Battle Bridge
Road.
MORE DEfAILED INFORMATION
19

DRAFT
Version 2 - 4/22/15
ISeveral technical reports prepared for the Complete 540 study contain much greater detail on the information
presented in this chapter, as noted below: L �
Community Features
• Community Characteristics Report
• Community Impacts Assessment Report
• Historic Architectural Resources Survey Report
Natural Environment
• Natural Resources Technical Report
. Indirect and Cumulative Effects Report
. Freshwater Mussel Survey Report
• Freshwater Mussel Environmental Baseline Reports
. Dwarf Wedgemussel Viability Study: Phase I Report
Physical Features
. Geo-Environmental Report
• Utility Impact Report
. Community Impacts Assessment Report
More information about these documents can be found in Chapter 7—Summary of Technical Reports. Chapter 7
also provides information about the ways those documents can be accessed, either in paper or electronic form.
Comment [NCDOJ94]: This chapter
contains a great deal of factual information
- is all of it to be found in these reports?
Comment [JS95]: Most of the info is
indeed found in these reports. However, the
EISs do contain original information, too,
correct? SoiYs notabsolutely mandatory
that every assertion in the EIS also be in
some technical report.
20

DRAFT
Version 2 — 4/22/15
CHAPTER 4
Alternatives for Meeting the
Project Purpose
Understanding the various options that were- developed to
meet the project purpose.
This chapter describes the various transportation options� e��s� I I
that were examined to meet the project purpose while keeping community and environmental effects to a
minimum. This includes a description of the methods used to decide which alternatives
should be carried forward for detailed analysis and which should be dismissed.
�
Comment [NCDOJ96]: Alternatives is
defined somewhat differently in the text
below.
Comment [JS97]: Our intent was to
introduce the word "alternatives" as it is
used in transportation studies. 1 guess 1
don't see how relating the word to the idea
of "options" is erroneous or how it is
substantively different from the text below.
I think we should keep it as is.
INTRODUCTION
As described in Chapter 2, area transportation needs were identified and two specific purposes for the proposed
project were established: to improve mobility within or through the study area during peak travel periods and to
reduce forecast congestion on the existing roadway network within the project study area. Chapter 3 described
the next step in the study, which was to gather information about the social, natural, and physical environment in
the study area. T����..n• �Chapter 4 describes how these two sets of information were used •�ro-�;,=.in �the Comment [JS98]: Ithinkweshoulddelete
process of deciding what type of transportation improvements would best achieve the project purpose and where the word "current;' but leave the rest as
they should be located. These different ways of ineeting the project purpose are called "alternatives." originallywritten.
IDENTIFICATION OF ALTERNATIVES
It is important to start with a wide range of alternatives, both in terms of the kind of transportation improvement
that might be used and where they would be implemented. This wide range of alternatives avoids focusing on one
type of assumed solution when there might be others that would better meet the project purpose. For this
reason, non-highway options, or "concepts;' may be considered as along with highway options. These may include
approaches such as altering the demand for the use of existing roads, changing how the existing roadway system is
managed, or introducing or enhancing mass transit.
The identification of alternative solutions is an important stage in the NEPA process. FHWA states that identifying
and analyzing alternatives is the key to ensuring that project decisions are made in an informed, objective manner.
SCREENING OF ALTERNATIVES
Once a wide range of alternatives has been identified, they each need to be analyzed. The ones that look most
promising can then be studied more closely while those with less merit can be dropped from further consideration.
21

DRAFT
Version 2 — 4/22/15
Because there is always a very wide range of possible alternatives at the beginning, some can be dismissed early in
the process, while others require more investigation before their benefits and impacts can be compared.
Ultimately, by eliminating some alternatives and combining others, a range of reasonable alternatives is
established.
This process of analysis and comparison, followed by decisions on which alternatives to drop and which to keep, is
called "screening." Typically, several rounds, or "iterations," of screening are conducted, depending on the
number and type of alternatives developed for any given project. The reason for using an iterative screening
process is to avoid the need to do extensive, detailed analysis of each alternative when some can be dismissed for
�,��.�",�'�fundamental Ireasons. For example, the first screening typically is concerned only with whether any of
the alternatives initially identified would ae�meet the purpose of the project. As described in Chapter 2 of this
document, any alternative that would not meet the project's established purpose or purposes is dropped at this
stage—there is no reason to continue studying an alternative if it would not achieve the primary purpose of the
project.
The next screen typically consists of an initial review of the remaining alternatives, comparing how well, or to what
degree, they would meet the projecYs purposes, and the extent to which they would negatively affect the area's
social, natural, or physical features. In this second screen, these comparisons are based on relatively general
information about each alternative's benefits and impacts. The least favorable alternatives are dismissed; those
that remain are then studied in more detail, and another screen is conducted, based on that new benefit-impact
information. Using this process, the most detailed level of analysis, which is the most costly and time consuming
to conduct, is required for only a small number of reasonable alternatives that meet the project purpose. These
are referred to as "detailed study alternatives," or DSAs.
The screening process includes reviews by federal, state, and local agencies and the public. During the first
iteration, agency representatives provide comments about the ability of each alternative to meet the projecYs
purposes. In subsequent rounds of screening, agency representatives provide comments on each alternative's
potential impacts. The public is informed about the nature and location of the alternatives and provides
comments about �—the alternatives ��' ,ff^�* *"^ *"'^^� *"^„ , ^^�' ,"^ +,I I This information
becomes part of the data used in screening alternatives.
THE NO-BUILDALTERNATIVE
Comment [JS99]: While "more basic" may
not win any awards for elegance in
\ phrasing, [ think it's better, and more
accurate, than just saying "for fundamental
reasons" I think we should keep it as is.
Comment [JS100]: The word "not" is the
proper wording here. IVo change.
Comment [JS701]: I think the idea I was
getting at is lost with Jason's edits. I would
like to change it to say: The public is
informed about ... and is asked to comment
about how the alternatives could affect the
area from the perspective of those who live
and work there.
Comment [JS102]: Let's just say, "...to find
the best way of ineeting ..."
The screening process is intended to find the �:"�'.eo timal �ay of ineeting the project purpose—in other
words, an alternative that would maximize benefits while minimizing impacts. This is known as the "Buil�
alternative. Selection of a Build alternative does not mean that the proposed project will be approved, however.
First, it must be determined that the costs of the Build alternative in dollars and environmental impacts are an
acceptable trade-off for the benefits it would bring. Because it is possible that those costs will be found
unacceptable, the option of not implementing the project—known as the "no projecY' or "No-Build" alternative—
is considered a viable alternative throughout i�this tudy. The No-Build alternative can be ruled out ealy�after
the Build alternative's effects are studied, presented to the public and governmental agencies, and comment�
from them are received and considered. In addition, the No-Build alternative provides a baseline against which the
benefits, costs and impacts of Build alternatives can be compared.
THE COMPLEfE 540 PROCESS
Although for some studies there are valid reasons to deviate from this process, this was not the case on the
Complete 540 project, and alternatives development and screening took place as described above. This began
with the exploration of alternative "concepts" or possible non-highway solutions for meeting the project's
purposes, along with initial identification of possible highway alternatives. These were then subjected to a series
of screenings. At the end of this screening process, the study's DSAs (detailed study alternatives) were agreed
upon and further detailed studies were conducted for them.
Comment [JS103]: This is intended to be a
generic description, thus "the study" is
correct.
Comment [JS104]: I think it is correct to
say "only after:'
22

DRAFT
Version 2 — 4/22/15
The steps that resulted in the designation of the DSAs are described in the remaining sections of this chapter. The
more detailed impact assessment conducted for the DSAs is the subject of the following chapter.
THE INITIAL SET OF CONCEPTS
Three alternative concepts other than roadway construction were considered:
Transportation Demand Manaqement (TDMJ Contept —TDM includes strategies designed to reduce the need or
"demand" that individuals have to use the roadway system itself. If people need to use their cars and trucks less
often, mobility for those remaining on the roads will improve, and traffic congestion will diminish. Examples of
TDM include techniques to increase ride-sharing, to achieve staggered work hours at larger employment centers,
and to promote working at home (telecommuting).
Transportation System Management (TSMJ Concept — TSM measures typically consist of low-cost, minor
improvements to roadways to increase the capacity or efficiency of the overall roadway system. Examples of these
kinds of improvements include coordinating traffic signals at intersections, installing turn lanes at intersections,
and limiting the number of access points on various roadway segments.
Mass Transit/Multi-Modal Contept — The Mass Transit option would expand bus and rail passenger service in the
project area, resulting in fewer cars and trucks needing to use the existing roadway system. The Multi-Modal
option would combine expanded transit service with all of the roadway projects included in CAMPO's 2035 Long
Range Transportation Plan, but excluding the Complete 540 project.
In addition to these non-roadway alternatives, several different roadway options were considered. These
included:
Making upgrades and other improvements to existing roadways — This alternative differs from the TSM concept
in that it would not be limited to smaller improvements but would involve major reconstruction of extensive
portions of existing roads in the study area. Three combinations of existing roadways having the greatest potential
to meet the project purposes were examined. Each of these combinations would require widening some of the
larger roads in the study area (such as I-40 and the area's US Routes) to twelve lanes, and widening other area
roads to six lanes, some of which would require frontage or service roads.
Combination, or 'hybrid," options — This concept would combine upgrading certain existing roadways, as
described above, with some completely new construction in other areas. Three options having the greatest
possibility of ineeting the project purposes were examined. One of these three would construct a new, limited-
access facility in the western portion of the study area (west of I-40) and would improve existing roads in the
eastern portion. The other two would reverse this pattern, upgrading existing roads west of I-40 and building a
new facility east of I-40.
Construction of an entirely new highway — This option would construct a completely new, limited-access facility.
It would be similar in design to the existing segments of 540, with access to and from the highway provided using
on and off ramps at interchanges.
A"No-Build" alternative was also ��*�"��' .,R.��"��'considered.l I This option is based on the assumption that the Comment [JS105]: No ... a no-build
transportation network in the study area will continue to develop as called for in CAMPO's 2035 Long-Range network is indeed "established.,,
Transportation Plan, but without the Complete 540 project included.
SCREENING THE INITIAL CONCEPTS
As described earlier, the objective of the first screening is to identify concepts that meet the projecYs primary
purposes. To do this, measures of effectiveness were established for each purpose. A very general summary of
these measures is described here. A much more detailed description of the full analysis can be found in the
Complete 540 study's "Alternative Development and Analysis Report."
23

DRAFT
Version 2 — 4/22/15
Screeninq Measures
IFor the first primary purpose—improving mobility—two screening measures were used. One defined mobility in
terms of average speeds of vehicles on major roads in the study area. If a concept would substantially improve
these average speeds on these roads, it would be judged as having improved mobility. The other measure looked
at travel times for commuters between major origins and destinations in and around the study area. If a concept
would result in a substantial reduction in commuting times, it was also defined as improving mobility�.L
�
For the second primary purpose—reducing traffic congestion on area roads—three screening measures were
applied. These measures were:
• a calculation of the total number of "vehicle hours" of travel on the major roadways in and around the study
area--a reduction in the total number of vehicle hours on this roadway network is an indication of reduced
congestion.
. a calculation of the total number of "vehicle miles" traveled on roads that are carrying more traffic than they
were designed for (or that will reach this condition in the futureu)--reduction in the total number of miles
vehicles are traveling on these roads is also an indication of reduced congestion. �
. applying the "vehicle hours" of travel calculation to this same set of roads that are or will in the future be
beyond their capacity--reduction in vehicle hours traveled on these roads is an indication of reduced
congestion.
Public and Agency Review
As part of the screening process, the initial alternative concepts and their screening measures were presented to
the public and to regulatory agencies for their review and comment. Public presentations were done at a series of
informal public meetings conducted by the study team (NCDOT and FHWA) in September of 2010; the study team
met with local, state, and federal agency representatives in the summer and fall of 2010�.I
Results of the Screening of Initial Alternative Concepts
A combination of ^��m�-'��' ��-' �� '��'qualitative and quantitative� �methods was used to assess the
effectiveness of each alternative. A summary of the results for each is described below. �
Trensportation Demand Management — After applying the screening measures, the study team concluded that
the TDM concept would not meet either of the projecYs primary purposes. In order to achieve increased mobility
and reduced congestion, as many as 60 percent of commuters who currently drive their own vehicles to work
would need to permanently switch to options such as carpooling, vanpooling, or telecommuting (working from
home). iBecause there is no evidence to suggest this is attainable in the Triangle Region,I�fDM would not be able to
reduce congestion or increase mobility.l2 It would therefore not meet the project purpose and was dropped from
further consideration. �
Transportation System Management —^� ,*� ��� rnnn �ti„ � a„ « ..�� a,.,, «�.,. fM�2 TSM
concept of making minor improvements on area roads to improve efficiency would not meet either of the projecYs
primary purposes. While TSM improvement can increase speeds on freeways, expressways, and major arterial
roads, these types of roadways account for only a small percentage of the total miles of congested roadways in the
study area. Even if all TSM-eligible facilities in the study area were improved, these improvements would not
result in c� �•�'„ ',•rt�si nifican Ireductions in forecast traffic congestion. Because TSM improvements
would not meet the project purpose, it was dropped from further consideration.
Mass Transit/Multi-Modal Improvements —'^ �^^'., ^^ *"^ ���^^^ ^^ ^�^�� �^ ^'The mass transit/multi-modal
concept,'"^ �'"�'„'^,^, �^^�'���'^�' +",""�� �^^�^^'�lalso would not meet the projecYs purposes. As explained in
the Complete 540 Study's Alternatives Development and Analysis Report, neither existing nor forecast ridership
levels are high enough to remove enough vehicles from the roadway network to affect average speeds. For
example, there would need to be a twelve-fold increase in the number of buses serving the roadway network in
Comment [NCDOJ106]: Why not lay out
the l�t primary purpose screening measures
in the same way as the 2�a?
Comment [JS707]: I'm not sure what
Jason is suggesting. This description is right
out of the Purpose and Need Statement and
reflects how the screening was done.
Comment [NCDOJ108]: What future - the
indefinite future or within a specific period?
Comment [JS109]: I suggest changing this
to: "... will reach this condition within the
planning horizon."
Comment [JS110]: Note: This paragraph
has been changed to incorporate the one
that originally followed it. Per Jason's
comments, I have deleted the original
sentences about the outcomes of these
reviews.
Comment [JS171]: I feel it's no less
accurate -- and much more reader friendly --
to say numerical and non-numerical.
- Comment [NCDOJ112]: Is there any
evidence to suggest this is NOT attainable?
Comment [JS113]: No, but these
assertions are all documented in the
� Purpose and Need Statement. I will add a
reference to that document.
Comment [JS774]: Reference the P&N
statement
Comment [JS115]: I would like to keep
this transition phrase.
Comment [JS176]: We've been instructed
to not use the word "significant,"
Comment [JS117]: I think we should keep
this opening sentence as originally written.
24

DRAFT
Version 2 — 4/22/15
the vicinity of the project to carry enough passengers to have a meaningful effect on traffic congestion and
mobility. �fhere is no evidence to suggest, however, that expansion in transit service to this degree would be
feasible from the perspective of cost, infrastructure, or anticipated use by the projecYs design year of 2035�_24
�cause the mass transit/multi-modal concept would not meet the purpose of the project, it was dropped from \
further consideration. \�
Constructing upgrades and other improvements to existing roadways — When the screening measures were
applied to the several combinations developed for this concept, the result was that while each would provide
some improvement in mobility and some reduction in local roadway congestion, the level of benefit was minimal,
and would not compare favorably with the remaining concepts. As a result, the study team determined it was
prudent to dismiss this concept from further consideration.
Combination or "hybrid" options — As mentioned above, three hybrid options having the greatest potential to
meet the project purposes were examined. These options would combine new construction with the upgrading of
some of the study area's existing roads. After applying the screening measures to each of these, the study team
found that one would not achieve either of the projecYs primary purposes. Another would achieve the purpose of
decreasing traffic congestion, but it would not improve mobility. As a result, each of these hybrid options was
dismissed from further consideration. The third hybrid option was found to achieve both of the primary purposes
and, as a result, it was retained for further development and evaluation. This option would upgrade two roads
between NC 55 and I-40 to six lanes (Jessie Drive and Ten Ten Road) and would construct a new, limited-access
facility from I-40 to I-495.
Construction of an entirely new highway — Applying the screening measures to the new highway concept, the
study team found that it would achieve both of the project's primary purposes, improving mobility and reducing
congestion. Compared with the other concepts, the new highway concept provided the largest decrease in average
travel times and the largest reductions in congestion on the local roadway system. As a result, this option was
retained for further development and evaluation.
The No-Build or no project concept was retained as a baseline for comparing to the Build concepts as they were
developed in more detail.
DEVELOPMENT OF PRELIMINARY CORRIDOR ALTERNATIVES
With the first screening completed, the next step was to develop the new highway and hybrid concepts at a
greater level of detail, laying out wide "corridors" within which the new and expanded roadways could be built.
For this study, corridors were established at 1,000 feet in width. These corridors were then screened to see which
should be developed at a greater level of detail and which should be dismissed. The actual roadway would
typically require less than half the width of the 1,000-foot corridor, which allows room for shifts and adjustments
later, once a smaller number of possible corridors had been selected.
Even though the corridors are much wider than the actual road would be, a certain amount of engineering
precision is required when developing them. For example, they cannot be drawn with curves so sharp that a
limited-access highway could not be built within them. Likewise, extra room is needed in the corridors, beyond the
standard 1,000-foot width, to account for the land that would be needed to build the interchanges required at
locations where the new road would cross major existing roadways.
To establish this level of precision, the basic features of the project's likely design were established. Although
these features could change later in the study, for planning purposes it was assumed that the new highway
segments would have six lanes, divided by a 70-foot wide median. For the areas where existing roads would be
improved, it was assumed that various existing two and four lane roads (Jessie Drive and Ten Ten Road, for the
most part) would be widened to six lanes and would have additional restrictions on access.
INITIAL SET OF CORRIDOR LOCATIONS
Comment [NCDOJ118]: Is there evidence
to suggest that such expansion is NOT
feasible?
� Comment [JS7 79]: This is from the P&N
� Statement. I'll add a reference.
� Formatted: Highlight
Formatted: Highlight
Formatted: Highlight
25

DRAFT
Version 2 — 4/22/15
A large number of corridors were identified and studied. This began with development of numerous small
segments spanning various parts of the study area, typically between two of the area's existing major roadways.
The segments could be connected in a variety of ways to make what are known as "end-to-end" corridors—
complete alternatives that span the beginning and end points of the project. Each of these corridors began at NC
55 Bypass in Apex, where the existing NC 540 ends, and each corridor ended at US 64/US 264 Bypass (I-495) in
Knightdale, where the existing I-540 currently ends.
Numerous individual segments were developed by the study team. Their locations were based on a review of the
community, environmental, and physical features in the study area (as described in the previous chapter of this
document). The relatively large number of segments that were developed could be connected in many different
ways, and resulted in hundreds of possible end-to-end corridor alternatives.
The study team then compiled preliminary information about the potential effects of each alternative on the study
area's social, environmental, and physical features. These features included wetlands, streams, floodplains,
endangered species, and social features such as potential relocations of homes and businesses. At this stage in the
process, these features were based on pre-existing information that was collected, reviewed, and placed on study
mapping.
Using this information, the study team identified the segments that were very similar and determined which
among them would have lower negative effects on the study area's social, environmental, and physical features.
Unlike the first screening of the initial alternative concepts, which focused on whether the various broad concepts
would meet the project purposes, this evaluation was intended to eliminate alternatives based on their potential
effects on social, environmental, and physical features. When comparing two or more similar segments spanning
the same part of the study area, the study team eliminated the segments with more potential to negatively affect
these features. The segments that remained could be combined in various ways to form nine end-to-end corridor
alternatives.
The study team then prepared more detailed information about the potential impacts of each of these nine
corridor alternatives. To calculate these impacts, a general, or preliminary, roadway design was established in
each corridor. These designs were based on a standardized width of 300 feet, which would be the approximate
width of the actual roadway and its associated border areas (which include drainage ditches, side slopes, etc.). The
designs also included the areas needed for interchanges, access roads, and other elements that go beyond the
basic roadway width.
With these general roadway designs in each corridor, their effects, or "impacts," could be calculated and
compared. The impact categories included overall roadway length, wetlands, streams, floodplains, endangered
species, and social categories, such as potential relocations. At this stage in the process, these categories were
based on secondary or pre-existing information that was collected, reviewed, and placed on study mapping.
In the fall of 2010, the study team presented this information to regulatory agencies, local governments and to the
public. At that time, the corridor information was displayed as color-coded corridor segments as well as
numbered, end-to-end corridors (those corridors are shown in the map above). In reviewing the various corridors
and segments, the public, local governments, and agency representatives made several comments and
suggestions. Some of these resulted in changes to the corridor alternatives, with various new segments being
added to avoid or minimize impacts to resources, and some segments dropped from further consideration due to
high potential impacts without offsetting benefits. Also dropped from further consideration was the hybrid
concept -- a combination of new construction and the upgrading of certain existing roads—which would have
required a very large number of residential relocations and resulted in substantial impacts to wetlands without
offering an offsetting relative advantage over other options under consideration.
The new set of corridors that emerged was then subject to additional review and analysis. Based on the comments
and suggestions made during additional agency, government, and public reviews, including a round of public
26

DRAFT
Version 2 — 4/22/15
information meetings in the fall of 2013, the corridors under consideration were further modified and the impact
assessments were updated. Public, governmental and agency input helped to identify a set of alternatives to be
studied in much greater detail. These studies would include more precise engineering of the preliminary designs
and labor-intensive work in the study area to officially demarcate or otherwise identify the exact locations of
social, environmental, and physical features. These alternatives are referred to as "detailed study alternatives," or
DSAs.
After this process was complete, ten corridor segments were selected for detailed study. The various
combinations of these segments result in seventeen end-to-end DSAs. Each of the ten corridor segments has a mix
of benefits and constraints, which are summarized below. They are described in greater detail in the next chapter
of this document.
Corridor Segments West of I-40
Orange Corridor Segment — The main advantage of this segment is that it follows a corridor that was identified
and set aside as a protected corridor by NCDOT for this project in the mid-1990s. As a result, development activity
has been limited within the protected corridor for nearly two decades. Because of its long-term protected status,
local governments and the public have expressed a great deal of support for this option, and many of the study
area's communities have factored it into their adopted future land use plans.
A disadvantage is that this corridor would cross a portion of Swift Creek that may be important for the continued
Isurvival of the federally protected dwarf wedgemussel lin this waterbody�. In addition, there are more acres of
wetlands within this corridor than some of the other options, based on preliminary information from the USFWS's \
National Wetlands Inventory (NWI) mapping.
Lilac Corridor Segment — This option diverges from the Orange Corridor segment near Sauls Road. It was
developed to reduce potential effects to NWI-mapped wetlands. However, a notable disadvantage of the Lilac
Corridor segment is that is crosses several established residential neighborhoods and would require a large
number of relocations. Another disadvantage is that it would directly affect a biosolids sprayfield that treats water
from the Dempsey Benton Water Treatment Plant. Like the Orange Corridor segment, the Lilac Corridor segment
also has the disadvantage that it would cross the portion of Swift Creek important to �the continued survival of the �
dwarf wedgemussel-sa�a+val.
Purple and Blue Corridor Segments — Although these segments have been assigned two different colors (because
various earlier combinations of segments were discarded), they function as one corridor segment. This corridor is
farther south than the other options under consideration. For this reason, the Purple and Blue Corridor segments
may better serve traffic in growing areas near Fuquay-Varina than the other corridors. Also, the route created by
connecting the Purple and Blue Corridor segments to the Lilac Corridor segment would have fewer acres of NWI
wetlands than a similar route using the Orange Corridor segment to connect to the Lilac Corridor segment.
Despite these benefits, the Purple and Blue Corridor segments have two notable disadvantages. First, they form a
route that would cross heavily developed areas in eastern Holly Springs. Also, by bringing the projecYs route this
far south in the study area, these corridors may create pressure to approve new development in rural southern
Wake County and in Harnett County, some of which could be in conflict with local, approved land use plans.
Officials from Wake County, Holly Springs, and Fuquay-Varina have each expressed their opposition to this route.
They have also been strenuously opposed by many area homeowners associations and individual members of the
public.
Red Corridor Segment — The Red Corridor segment forms a potential route that is the farthest north of all the
corridor segments. There are two key reasons why this option is under consideration. The first is that it is the only
segment that would cross Swift Creek upstream of the Lake Benson dam, meaning it would be upstream of the
Comment [NCDOJ120]: Is "survival" the
accurate term? [ though the USFWS said
"the habitat provided by Swift Creek is
identified as essential for the recovery of the
species in the Neuse River basin (USFWS,
1993)." That is not the same thing as
"survival>"
Comment [JS121]: The management plan
uses the word "survival." 1 have added "the
continued" before the word, and added "in
this waterbody" at the end of the sentence.
These qualifiers should address ]ason's
comments.
Comment [JS122]: I made this
modification to address Jason's comment
below.
Comment [NCDOJ123]: Same as above
comment.
27

DRAFT
Version 2 — 4/22/15
crucial habitat for the federally endangered dwarf wedgemussel. The second reason is that it crosses fewer acres
of NWI-mapped wetlands than any of the other options.
The Red Corridor segment also has several key disadvantages. It crosses a heavily developed area in the town of
Garner, including several established subdivisions. It also crosses several park and recreational resources in this
area. It is the only corridor that would cross the Swift Creek Water Supply Watershed Critical Area. The Red
Corridor segment is formally opposed by the Town of Garner and Wake County and has been strongly opposed by
many area homeowners associations and individual members of the public.
Corridor Segments East of 1-40
Green and Mint Green Corridor Segments — The key advantage of both of these segments is that they would
avoid a substantial public land use: the Clemmons State Educational Forest. A key disadvantage is that they would
both likely require alterations to a group of three important communications towers near US 70 Business. As
noted in the previous chapter, these include warning sirens for the Harris nuclear power plant (west of Holly
Springs), Federal Aviation Administration air traffic control communications equipment, and cell phone
transmission facilities. Given these functions, relocation to accommodate a highway would be costly and
potentially disruptive.
These two options differ in their potential effects on another public investment: the Randleigh Farm property,
which is a development being pursued jointly by the City of Raleigh and Wake County. The Green Corridor
segment bisects this property, while the Mint Green Corridor segment shifts these impacts to the east, closer to
the edge of the property, which would likely be less disruptive.
Tan Corridor Segment — The Tan Corridor segment was developed in an attempt to avoid the disadvantages
associated with the Green and Mint Green segments. It would shift the impacts to the Randleigh Farm property
even farther to the east than the Mint Green Corridor segment, further reducing disruption to existing
development plans compared to the Mint Green Corridor segment. Another advantage of this segment is that it
would avoid the communication towers near US 70 Business.
Because the Tan Corridor segment would cross various existing subdivisions, it has the potential to be disruptive to
a larger number of property owners than other options under consideration in this area. It would also need to
cross the northwest corner of Clemmons State Educational Forest expansion property.
Brown Corridor Segment — This segment would have the advantage of completely avoiding the Randleigh Farm
property and avoiding the communication towers near US 70 Business. Another advantage is that it would allow
the road to cross the Neuse River at a more favorable location than the other options, giving the Brown Corridor
segment the potential to minimize effects to the river and associated natural features. Due to the angle at which it
would cross Auburn-Knightdale Road, the Brown Corridor segment's interchange design in this location would
require fewer acres of land than the other segments.
The key disadvantages of the Brown Corridor segment are that it would directly affect a biosolids sprayfield that is
part of the Neuse River Wastewater Treatment Plant and would directly affect a City of Raleigh police training
facility located on Battle Bridge Road. It would also need to cross the northwest corner of Clemmons State
Educational Forest expansion property.
Teal Corridor Segment — This is a short segment that would connect the southern part of the Green Corridor
segment to the northern part of the Brown Corridor segment. The resulting combination of segments would have
several advantages: it would completely avoid the Randleigh Farm property, would also cross the Neuse River in a
more favorable location, allowing a smaller interchange footprint at Auburn-Knightdale Road, and would avoid
crossing the Clemmons State Educational Forest.
28

DRAFT
Version 2 — 4/22/15
The key disadvantages of the route formed by the Teal Corridor segment are that it would likely disrupt the
important communication towers near US 70 Business, and would affect the Neuse River Wastewater Treatment
Plant bio-solids sprayfield and the City of Raleigh police training facility.
NDCf STEPS
With these ten corridor segments and seventeen end-to-end corridors established as DSAs, the next step was to
refine them even further and then perform one last screening to determine the preferred route location for the
proposed Complete 540 project. This would be known as the "Build" alternative and would be the route location
and design that would be compared against the "No-Build" or no project option. The next chapter of this
document, "Expected Benefits and Impacts of Each Alternative" describes the additional refinements made and
the detailed fieldwork that was conducted to fully understand the impacts each would have on the social, natural,
and physical environment.
MORE DEfAILED INFORMATION
More detailed information on the alternatives development and screening can be found in the Complete 540
project's Alternatives Development and Analvsis Report.
More information about this document can be found in Chapter 7—Summary of Technical Reports. Chapter 7 also
provides information about the ways this document can be accessed, either in paper or electronic form.
29

Page 3: [1] Comment [JS20] Jeff Schlotter 5/8/2015 1:28:00 PM
It's not always possible to include verbatim passages - they're often lengthy and not
reader-friendly. This information is important to include but it needs to be in a
summarized, reader-friendly style. I am not changing the meanings in doing so.
I don't know what Jason means by "public source." What's a"private source?" I'm pulling
most of this material - throughout the document - from agency sources but occasionally
there is a text book or other reference that is useful. And because it's useful, I'm using it, as
one would do with any research paper. Also, these are not contentious issues - it's NEPA
101. And further still, FHWA's legal staff will be reviewing it. I hope we can defer to their
judgement.
Page 3: [2] Comment [NCDOJ23] NCDOJ 4/30/2015 1:01:00 PM
Beyond the general language concerning governmental policy, the heart of NEPA is that
agencies must consider the environmental impacts of a decision before the decision is
made. The rest of this language is potentially misleading and editorial.
Page 3: [3] Comment [JS24] Jeff Schlotter 5/8/2015 1:25:00 PM
I have added a paragraph that I originally left out: NEPA's stated purpose. Having added
that, it puts the next two paragraphs in context. I believe all these paragraphs are
important. It's important for average citizens to have at least a basic idea about what NEPA
is and why it was created. I am paraphrasing, but not by much. As I noted above, it's not
always possible to just paste the legislation verbatim. And finally, I question Jason's
contention that this information is "potentially misleading" and "editorial." It's only as
misleading as the law itself would be. And it's "editorial" in the same way that the entire
document, or any summary document is "editorial." Someone always has to choose what
goes in and what stays out. I think I've made a good decision here.