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NEPA comments on MCB DEIS


June 4, 20 10

Ms. Jennifer Harris, P.E.
North Carolina Turnpike Authority
5400 Glenwood Avenue, Suite 400
Raleigh, North Carolina 27612

SUBJECT: Federal Draft Environmental Impact Statement for the Mid-Cumtuck Bridge Study,
Currituck and Dare Counties, North Carolina; TIP Project No.: R-2576; FHW-E40830-NC; CEQ
No.: 201001 16

Dear Ms. Harris:

The U.S. Environmental Protection Agency Region 4 (EPA) has reviewed the subject document and is commenting in accordance with Section 309 of the Clean Air Act and Section 102(2)(C) of the National Environmental Policy Act (NEPA. The North Carolina Turnpike  Authority (NCTA), a division of the North Carolina Department of Transportation (NCDOT), and the Federal Highway Administration (FHWA) are proposing to construct a new multi-lane, 7  to 7.5-mile bridge and access roads and interchanges across Currituck Sound between US 158 in Currituck County and NC 12 in Dare County. There are five alternatives being considered with two hurricane evacuation improvement options and two mainland bridge approach options.
NCTA and FHWA also studied an ‘improve existing’ roadway alternative (i.e., ER2) at the request of numerous State and Federal agencies.
The NCTA and FHWA are utilizing the agency coordination process under SAFETEALU Section 6002. The new bridge alternatives are proposed as a toll facility. The existing roads alternative that was studied in the DEIS (i.e., ER2) is not currently funded. EPA provided detailed project scoping comments, conceptual alternatives refinement report comments, and statement of purpose and need and alternatives screening report comments to the NCTA in letters dated August 3,2007, December 14,2007, and May 5,2008, respectively.
EPA’s primary environmental concerns regarding the Clean Water Act remain unresolved. Detailed technical review comments are attached (See Attachment A).  EPA has rated the proposed bridge alternatives MCB2 and MCB4 as ‘EO-2’, Environmental Objections with additional information being requested for the final document (Attachment B includes EPA’s Summary of Rating Definitions and Follow-up Action. EPA’s review has identified: significant environmental impacts to jurisdictional waters of the U.S. that
should be avoided in order to adequately protect the environment, potential degradation of water quality to Currituck Sound, severe impacts to fish and wildlife resources, and indirect and cumulative effects within the project study area. Further, we believe that the proposed action might cause significant environmental degradation under the Clean Water Act and Section
404(b)( 1 ) Guidelines.  Internet Address (URL)
NCTA and FHWA need to further demonstrate that the environmental impacts to jurisdictional waters of the U.S. can be further avoided and minimized and potentially mitigated for and that water quality is not further degraded as a direct result of this project and its associated indirect and cumulative impacts. NCTA and FHWA should consider substantial changes to the recommended alternative or consideration of some other project alternative, including the improvement to existing roadway facilities. Alternative MCB2lC 1IA might be environmentally acceptable provided that impacts from floodplain encroachment can be fully and appropriately addressed prior to the FEIS, all storm water from the new bridge can be collected and treated with minimal impacts to jurisdictional resources, construction does not involve any dredging, and all wetland impacts can be first avoided and n~ini~nizeadn d that adequate compensatory mitigation is found. Compensatory mitigation should be ‘in-kind’ and with the same hydrologic catalog~~inugni t.
E P A ~ I SbOe lieves that Alternative ER2 is a reasonable and feasible alternative and its potential impacts can be addressed through additional avoidance and minimization measures.  EPA believes that ER2 should be designated as the environmentally preferred alternative and meets the proposed project’s purpose and need by providing the appropriate balance of impacts to the benefits and costs Mr. Cliristoper Militscher of my staff will continue to work with you and FHWA and other agencies on the continued environmental coordination activities for this project. Please feel free to contact Mr. Militscher at (919) 856-4206 should you have specific questions
concerning EPA’s comments.
Heinz J. Mueller, Chief
NEPA Program Office
cc: J. Sullivan, FHWA
K. Jolly, USACE
B. Wrenn, NCDENR
G. Tliorpe, NCDOT
wIAttachmei~tsA and B
Attachment A
DEIS Detailed Review Comments
Mid-Currituck Bridge Study
Currituck and Dare Counties
General Comments
The DEIS is presented in a revised format from the recommended format found at 40
CFR Section 1502.10. Page v of the DEIS Preface includes a statement concerning Chapter 3,
the Affected Environment and Environmental Consequences and as well as the potential shortand
long-term beneficial and adverse effects (if any) of the detailed study alternatives. EPA
believes that this major Federal action that could involve the construction of a new bridge and
other coastal infrastructure improvements in the cost range of $595.5 million $1,065.1 million
will have potential short-term and long-term adverse effects on the natural and human
environment. The average cost range of the new bridge alternatives and options appears to be
approximately $750 to $800 million based upon the information on Page xxi of the DEIS.
EPA could not find a specific discussion in the DEIS concerning the long-term
maintenance costs of a new 7 to 7.5-mile bridge facility over Currituck Sound. Major
infrastructure along the Outer Banks and the coastal plain of North Carolina is periodically
damaged by severe storms and hurricanes. Maintenance costs associated with the existing
project study area roadways and bridges has been expressed by F H W A ‘N~C~D~OT as a major
concern for more than a decade. Shrinking transportation dollars and increased maintenance and
repair costs for infrastructure in areas that are very vulnerable to severe weather conditions such
as high winds and storm surges and salt air and water should be a very important consideration
for decision-makers. NCDOT Division 1 officials have routinely expressed their concerns at
other project meetings for maintaining existing roadways and bridges. .Adding more than 7 miles
of new infrastructure in this area will further strain existing transportation resources.
Pages xii and xiii of the DEIS include other transportation projects proposed in the study
area. EPA understood from the NCDOT project management that for R-2545 and R-2544, US
64 including the new bridge over the Alligator River, only the bridge is funded and the 20-miles
of widening and new location sections between Columbia and Manteo are currently unfunded.
Appendix A, Comments and Coordination does not include copies of specific agency letters
following Turnpike Ellviroilmental Agency Coordination (TEAC) meetings.
Project Purpose and Need
The DEIS presents three primary project needs, including the need to improve traffic
flow in the study area roadways such as US 158 and NC 12, the need to reduce travel time for
persons traveling between the Outer Banks and Currituck County mainland, and the need to
substantially reduce evacuation times from the Outer Banks. EPA has previously commented on
some of the project purpose and need issues during scoping and the Turnpike Environmental
Agency Coordination (TEAC) process. EPA continues to have substantial environmental
concerns regarding the documented need for a new crossing of Currituck Sound and the detailed
study alternatives (DSAs) presented in the DEIS that include a new bridge. The traffic flow and
travel time benefits froin a new bridge crossing do not in the long-term outweigh the direct
adverse effects to the natural environment, including wildlife, coastal wetlands, and water
quality. Table 2-3 of the DEIS attempts to capture some of the travel benefits of the detailed
study alternatives of ER2, MCB2 and MCB4 compared to the No-build. In addition, this table
also tries to capture the 2035 Hurricane Evacuation Benefit in clearance times between the
EPA does not believe that there have been any documented hurricane evacuation
problems in this area of the Outer Banks in modern times using the existing roadway system.
EPA understands the State’s desired goal of reducing hurricane evacuation clearance times to the
18-hour goal. Planning and designing a roadway system based upon this desired goal should be a
consideration but not a finite decision point in the preferred alternative selection process. There
are other areas of the Outer Banks that potentially cannot meet this 18-hour goal even if a new
bridge is constructed over Currituck Sound. EPA in its review of the September 2005 North
Carolina Department of Transportation State Hurricane Evacuation Study found only two
Category 3 hurricanes in ‘modern times’ (post 1930) that directly hit the Outer Banks. On
September 16, 1933, Hurricane #13 hit the Outer Banks and there were reportedly 21 died, many
of wl~omd ied from inland flooding. On September 1, 1993, Hurricane Emily resulted in
160,000 persons being evacuated. Two surfers reportedly died from drowning after they
apparently refused to evacuate the island.
Other reduced strength hurricanes have historically either brushed near the Outer Banks
or made landfall further south in North Carolina and traveled north up the coastal plain towards
Virginia. Some of these lesser strength hurricanes caused extensive flooding and storm surge
damage along the Outer Banks and in inland areas (e.g. Category 2 Hurricane Isabel on
September 18, 2003; only 45% reportedly evacuated from the Outer Banks). Considering that
most documented fatalities during hurricanes involve drowning in flooded low-lying areas,
transportation agencies should consider other planning initiatives as evacuated persons from the
Outer Banks move inland. Many of the evacuation routes in the coastal plain traverse low-lying
areas, rivers and streams. During one NCDOT presentation on hurricane evacuation in 2008,
NCDOT used hurricane evacuation pictures from Texas (i.e., Hurricane Rita) as the
documentation for traffic congestion problems. The September 2005 NCDOT State Hurricane
Evacuation Study contains no photographs or other direct evidence of past evacuation problems
in North Carolina. EPA does agree that reducing hurricane evacuation clearance times in general
is a desirable goal and should be reasonably weighed against other costs, benefits and adverse
environmental effects. Local planning and early warning appear to be important components to
effective hurricane evacuation, including the consideration of minimizing new development
along isolated and remote areas of barrier islands.
The DEIS includes information on the funding of the project and estimated costs on
pages xxi and xxii. According to this section, only the toll, new bridge alternatives have a
potential to be filnded. DSA ER2 cannot be funded through toll revenues or the Public Private
Partnership agreement. Furthermore, the $15 million per year provided by the N.C. General
Assembly cannot be applied to DSA ER2 per the DEIS, only DSAs MCB2 and MCB4. The
DEIS does not indicate if the N.C. Board of Transportation considers R-2576, Mid-Currituck
Bridge Study project to be a priority project under its current priority plans and what funding
could be made available for DSA ER2 if it is selected as the preferred alternative. NCTA
officials have stated during TEAC meetings that ER2 is not a ‘feasible’ alternative as it cannot be
fil~ideda s a toll project.
Detailed Study Alternatives and Options
Tlie DEIS includes DSAs ER2, MCB2 and MCB4 with the followi~igo ptions: MCB2lC 1 ,
MCB2lC2, MCB4lC 1 and MCB4lC2. Option C 1 includes a northern connection and
interchange on [lie barrier island side of Currituck County and Option C2 includes a southern,
longer connection and interchange near Albacore Street. Option C2 is actiially a 7.5-mile bridge.
The DEIS also states tliat the bridge over Currituck Sound for C1 Option is approximately 7.0
miles in lengtli ((Page 2-10). From past TEAC meetings, there was reference to the new bridge
being approximately 5 to 7 miles long. MCB2 provides greater improvements to local roadways
and MCB4 provides more limited improvements. The specific improvements imder each DSA
are included in Section 2 of the DEIS. The A and B designation refers to the mainland approach
road options of the new bridge.
EPA recognizes that MCB2 includes the existing road improvements similar to ER2, but
the informati011 contained 011 page xxi of the DEIS is confusing. For example, the range of cost
difference between ER2 and MCB2lBlCl is $416.1 to $523.4 million vs. $800.1 to $970.2
million, respectively. The DEIS does not specifically state the cost of a 7-mile or 7.5-mile
bridge. The range of costs for a new bridge might be from $384.0 to $446.8 million. Similarly,
the other MCB2 alternatives would indicate that a new 7-mile bridge over Currituck Sound
would cost approxiniately $400 to $500 million dollars. These figures do not correlate well with
the information contained in Table 2-4 where the costs are broken down for each DSA.
Construction costs for the bridge alternatives under Option A range from $619.3 to $845.7
million, and construction costs for bridge alternatives under Option B range between $5 13.4 and
$726.3 million. These figures exclude mitigation, right of way and utility costs. There is great
variability in tlie actual bridge costs as presented in the DEIS and it is unclear as to the cost
differences between Option C1 which is approximately 7.0 miles in length and Option C2 which
is 7.5 miles in length. Therefore, EPA requests that the FEIS include clarification as to the actual
costs of a new bridge.
Option B wo~~nlodt include a toll plaza at the US 158 interchange and the bridge
approach would be placed on fill within Maple Swamp. Option A wo~~plldac e a toll plaza
within the US 158 interchange. The mainland approach road would include a bridge over Maple
Swamp. Similarly to Options C1 and C2, the costs between these two options are not clearly
identified in the DEIS. It is also unclear if the costs for the longer bridge over Maple Swamp
i~~idOerp tion A are added to the C1 and C2 lengths.
The DEIS indicates that the new Mid-Currituck Bridge would be a two-lane facility and
discusses some of tlie travel and other considerations on Page 2-1 7. The difference between a
two-lane facility and four-lane facility is estimated at approximately $120 million. The cost
estimation details are not included in the DEIS. Superstructure supports, materials, and
construction costs would be expected to be proportionally greater with a four-lane facility.
Detailed cost assumptions and estimations should be included in the FEIS.
Human and Natural Environmental Impacts
The DElS iiicludes a comparison of key impacts in Table S-1 and in other sections of the
document. Soine of these impact assumptions and categories are not meaningful or have not
been shown to be a relevant issue for the comparison of alternatives. For example, outdoor
advertising signs are listed as a key impact with 29 signs for ER2 and 6 or 16 signs for the
MCB2 or MCB4 alternatives and the respective options. FHWA and NCDOT routinely relocate
outdoor advertizing signs for widening and new location projects. The relocation of gravesites is
also highlighted as a major difference between the alternatives and a key impact. The relevance
of this ‘key impact’ is not identified in the DEIS.
The residential relocatioiis between the alternatives are generally similar and range
between 5 and 8 with 10 vacation rental units. Business relocations are also generally ill the
same magiiitude of impact with between 5 and 8. The summary table also includes impacts with
no third outbound lane for hurricane evacuation. The impacts range from 2 to 6 by not including
this third lane. The DEIS includes discussions with access changes to neighborhoods and
businesses. The access changes appear to be a reasonable expectation considering the scope and
magnitude of the proposed improvements.
Total wetland impacts are 7.2 acres, 40.3 acres, 44.9 acres, 42.4 acres, 47.0 acres, 36.6
acres, 41.1 acres, 38.7 acres, and 43.2 acres for Alternatives ER2, MCB2/Cl/A, MCB2/Cl/B,
MCB2/C2/A, MCB2/C2/B, MCB4/Cl/A, MCB4/Cl/B, MCB4/C2/A and MCB4/C2/B,
I-espectively. The bridge alternatives also have the highest impacts to SAVs with 18.8 acres for
MCB2/Cl, 23.3 acres for MCB21C2, 18.8 acres for MCB4/C1 and 23.3 acres for MCB41C2.
Based on the magnitiide difference in wetland and other water resource impacts, EPA believes
that ER2 is the environmental preferred alternative and appears to be the Clean Water Act
Section 404 Least Environmentally Damaging Practicable Alternative (LEDPA).
The impacts to water quality are expected to be very significant. The DEIS does not fully
address the fact that water quality in Currituck Sound has declined substantially in the last
several decades due to primarily an increase in turbidity and nutrient loading from non-point
source runoff. Nursery areas for Blueback hemng and Alewife have not been recognized since
the 1980’s. Coastal niarslies around Currituck Sound waters have been lost to erosion or invaded
with exotic plant and animal species. In addition to development, other hun1an activities such as
agricultural and silviculture have potentially impacted overall water quality ill the sound and
caused subseq~~eidiet cline in ecosystem and habitat function. Section addresses aquatic
wildlife in Currituck Sound and Section discusses Submerged Aq~iaticV egetation
(SAV). For purposes of differentiating the impacts between the alternatives, Section is
inadequate for fully addressing the magnitude of impacts to water habitat. In addition to the
direct loss of SAVs and shading effects, the new bridge pilings would also potentially allow for
the introduction of other organisms not typically found in a shallow water estuary. The DEIS
states that: “011 the other hand, organisms could be attracted to bridge pilings as a reef
structure”. I11 the appropriate ecosystem, reef structures can aid and provide potential habitat.
The DEIS does not rcference appropriate studies or supportingdocumentatio~i that bridge pilings
would be beneficial to the Currituck Sound ecosystem. Considering the loss of essential fish
habitat and othcr 11atural fi~nctionsf rom past and current human activities, EPA co~isiders
additional losscs to SAVs to be a critical issue. EPA does not consider runoff from construction,
including increased turbidity, siltation and sedimentation in aquatic habitat arcas to be a
‘minimal’ effect. The discussion concerning the impacts from the bridge construction
alternatives versus the existing roadway improvements does not provide the pi~blica nd resource
and permitting agencies a reasonable comparison of impacts to aquatic habitat. Shading is
expected to impact 14.5 to 17.8 acres of aquatic bottom. Bridge foundations are expected to
directly impact 4.3 to 5.5 acres of SAVs. Contrary to the italicized coininent at Section 3.3.4,
construction impacts may not be temporary but could become permanent considering the existing
water quality problc~iisin Curritilck Sound.
Section of the DEIS provides more relevant information concerning the potential
impacts from noise, turbidity and siltation. The DEIS acknowledges that non-mobile species
such as clams could suffer long-term impacts from construction related siltation. However, the
DEIS does not adequately assess the issue of recovering populations of benthic organisms after
construction is co~npletedo r what practicable measures that NCTA would take to minimize
turbidity generated during bridge construction. Potential construction techniques of the bridge
are discussed in Section 2.4. EPA believes that only the ‘top-down’ method of construction
would be acceptable. Dredging between 53,000 cubic yards and 61,000 cubic yards based upon
other proposed methods described in Section 2.4 would not be environmentally-sound.
Furthermore, the DEIS does not describe the proposed site suitability and location of dredged
spoils. The DEIS does not specifically reference if the potential impacts of 25 or 17 acres to
acli~aticb ottom are included in summary tables. Also, the discussion concerning the approximate
4 acres of impact from the dock construction is not explained fully in reference to the summary
impact table.
NCTA and FHWA propose to build the bridge simultaneously from both sides using both
US 158 and NC 12 with construction meeting in the middle. Moving large construction
equipment and materials via NC 12 would potentially be very disruptive to local residents and
have a substantial impact to local traffic. This issue is not discussed in the DEIS.
Alternatives MCB2 and MCB4 involve the construction of the new bridge across
Currituck Sound and will traverse Maple Swamp on the mainland side. Maple Swainp is
designated as a Significant Natural Heritage Area (SNHA). Option A would involve the
bridging of Maple Swamp. Option B would involve filling the wetlands of Maple Swamp. EPA
recommends bridging this entire high quality system.
The DEIS addresses different stormwater treatment options from the deck drains for the
bridge alternatives. EPA believes that a full collection and treatment system is needed for any of
the bridge alternatives. Untreated roadway runoff into Currituck Sound will filrther degrade this
resource that is already stressed from human activities, including residential and cominercial
development. Bridge draii~ageo ptions are specifically discussed on Pages 2-25 to 2-27 of the
DEIS. EPA stroi~glyr ecommends Option 1 of the three options identified for collecting and
treating bridge drainage. A direct discharge of bridge stormwater through deck drains into
Currituck Sound is not eiivironiiientally sound and will continue to accelerate water quality
degradation problcms.
The disci~ssionc oncerning invasive species control at Section 3.3.5 is not adequate. The
FEIS should cite cxaniples of past successes using NCDOT’s Best Management Practices
(BMPs) for management of invasive plant species in coastal areas. To EPA’s knowledge, there
are few or no long-tenn and cost-effective successes to controlling invasive plants such as
Pliragmites once they become introduced or established through disruptive activities such as
construction. NCDOT’s BNIPs on such coastal wetland mitigation sites such as Mashoes Road
for controlling Phragniites have been very costly and in the long-term ineffective in eliminating
this damaging species.
The DElS very generally discusses borrow site material needed for fill. The DEIS does
not address the specific locations of any proposed borrow sites or any impacts associated with
tliese potential locations. For pi~lposeso f assessing the potential indirect impacts from borrow
sites needed for the proposed project alternatives, the DEIS does not provide adequate details
and defers to the final design stages; additional information should be provided in the FEIS.
The DEIS includes consideration for on-site wetlands mitigation by removal of Aydlett
Road. However, this coi~lpensatorym itigation of potentially 9.1 acres is only being offered for
the bridge alte~nativcst hat would fill existing Maple Swamp. From direct field observations,
there are extensive invasive plant species immediately adjacent to Aydlett Road. The
management and control of invasive plant species would need to be thoroughly addressed should
this mitigation be pilrsued at a future date. Compensatory mitigation is also addressed on Pages
3-46 and 3-48 of the DEIS. A conceptual mitigation plan is not included in the DEIS, and should
be included iii tlie FEIS.
Floodplain Issues
The DEIS includes statements that the new highway will involve significant
encroachment in floodplain areas but it also states that with respect to floodplain highway
encroachment, it is tlie policy of the FHWA to avoid significant encroachment since they would
be considered a significant alteration to a water course by Currituck County (Pages 3-74 and 3-
75). Page 3-72 states that “should MCB2lB or MCB4B be selected for implementation,
additional studies would be conducted during the final design so adverse floodplain
impacts.. ..could be avoided or minimized, as well as affects to groundwater hydrology,
l~ydrologicacl liaracteristics of Maple Swamp, and supported ecological functions”. EPA
believes that these studies should be completed prior to the issuance of a FEIS. Furthermore,
Option A (i.e., Bridging Maple Swamp) should be considered in combination with the removal
of Aydlett Road. The floodplain impact is estimated at 22.1 acres on the mainland (Page 3-72).
For alternatives MCB2lA and MCB4/A7 the impact to the 100-year floodplain would be a total of
10.4 acres. Reference to a project commitment is also made on Page 3-74 with the mitigation
measures deteniiiiiation followi~igf inal design. The DEIS does not provide any suggestion of
how these significaiit floodplain encroachment impacts can be minimized. Considering severe
storms and stor~ns urge, the past history of flooding, the accelerated development in the project
stitdy area and increases in impervious surfaces, and the potential for sea level rise, any
floodplain cncroaclimcnt will significantly increase flooding events. EPA does not concur with
tlie statement conccl-ning floodplain impacts for MCB2lA and MCB4lA on Pagc xxiii.
Sea Lcvel Rise
The DEIS includes a discussion of sea level rise in Section 3.4.4 and defers decisions on
road and bridgc elevations needed to accommodate potential sea level rise to final design.
Raising the grade of tlie roadways to accommodate sea level rise estimates will iiicrease f i l l
heights and create additional inipacts to jurisdictional water resources. EPA does not agree that a
Mid-Curriti~ck Bridge would be a useful asset in reducing the impact of sea level rise on the
project’s area road system. Conversely, bridge alternatives are expected to iiicrease floodplain
cncroachment with no minimization measures being proposed. Sea level rise will only
exacerbate flooding and storm surge issues. The statement that a Mid-Curritiick Bridge could
‘stay in service LIP to 75 years’, is not reasonable nor is there a reference to other similar bridge
structures in thc coastal plaiii that have lasted that period of time without significant repairs or
replacement. EPA does not concur with the suggestion that a breach in the islalid at the
CurritucklDare Coi~ntyli ne coiild be addressed through a new bridge and tlie conclusions of this
section of the DEIS do iiot appear to be adequately supported by the documentatioii.
Fish and Wildlifc linpacts
EPA defers specifically to the U.S. Fish and Wildlife Service, N.C. Wildlife Resources
Co~nmissiona iid otlier resource agencies concerning the potentially significant impacts to fish
and wildlife. EPA co~icul-fsu lly with the comments contained in the May 25, 2010, letter froin
the U.S. Department of Interior to NCTA and the May 21, 2010, memorandum from the N.C.
wildlife Resources Commission to Ms. Melba McGee, NCDENR. 011ly alternative ER2 does
not represent a sigiiificant impact to fish and wildlife resources, including acli~atico rganisms aiid
fish, migratory birds, aiid terrestrial species. The discussion contained in the sunimary impacts
table is not a reasonable representation of the differences in the impacts between the alternatives.
The bridge alter~iativesr epresent a major or severe impact to wildlife species, including direct
impacts from habitat loss, habitat fragmentation and indirect and cumulative effects.
liiaccuracies coiiceiliing endangered and threatened species should be addressed in the FEIS.
Farmland Impacts
The DEIS describes the potential impacts to farmlands in Section 3.1.12. The discussion
is not based i~polia n actual fill1 analysis and determination of prime, unique and State and locally
important fariiila~~diusi der Title 7 Code of Federal Regulations (CFR) Part 658 but on soil types.
Tlie assessment did iiot include completed Form AD-1006 or Form NRCS-CPA-106. MCB2lA
and MCB4lA would affect approximately 37 acres of prime farmland g& and 72 acres of State
and locally important far~nland& . MCB2JB and MCB4lB would impact approximately 76
acres of prime fannlaiid soils and 41 acres of State and locally important farnlland g&. The
DEIS does not provide a relevant discussion of North Carolina’s initiatives in protecting
faniilands from coiitiiiued losses to development. The DEIS does not address if Curritiick
County is participating in the Voluntary Agricultural District (VAD) program. The DEIS does
not indicate if these potei~tial farmland losses will impact the specific operations of current
agriculture and what economic impact that may result. The DEIS on Page 3- 19 does reference
another 2009 report that includes a copy of the Farmland Conversion Impact Rating form CPA-
106. Table S-1 Co~nparisono f Key Impacts does not include any specific faimland impact
category. Contin~lcd farmland losses in North Carolina is an important socio-economic issue and
tlie DEIS attempts to categorize the potential loss from this proposed project as being
inconsequential (e.g., “….this is less than 0.01 percent of all farmland soils in Currituck
Lndirect and Cum~rlativeIm pacts ‘
EPA has previously expressed concerns for the indirect and cumulative impacts from the
proposed bridgc altci-natives. The DEIS discusses indirect and cumulative effects in Section 3.6.
EPA continucs to have environmental concerns for the proposed project bridge alternatives. The
statement contained ill SLiinmary impact table on Page xx includes the desire by Currituck
County that the bridge alternatives are desired because the potential developn~enta t the bridge’s
interchange and along US 158. There are significant wetland areas and other low-lying
floodplain areas where this development is desired. Referencing Page 3-88 of the DEIS, EPA
does not concur with the statement concerning the type and density of developmei~ct ompared to
the ‘No-build alternative’ and the bridge alternatives. ‘The lack of transportation iinprovements
~lndit s constraint on development’ statement included on Page 3-89 is not accurate or supported
by actual development facts. This area has been developing at an accelerated pace until the
major eco~lon~diocw n turn in 2009. This has been occurring for more than a decade and without
any transportation inlproveinents and with some seasonal congestion. EPA does not agree with
the assessment of poteiltial development in the Carova area. The FEIS should address these
issues further.
Environnientiil I~iipacot f the Action
LO-Lack of Objections
The EPA review has not identified any potential environmental impacts requiring substantive changes to
the proposal. The review may have disclosed opportunities for application of mitigatiou nleasures that
could be acconlplished with no more than minor changes to the proposal.
EC-Environmental Concerns
The EPA review has identified environmental impacts that should be avoided in order to frilly protect the
environment. Corrective nleasures may require changes to the preferred alternative or application of
mitigation nleasures that can reduce the environmental impacts. EPA would like to work with the lead
agency to reducc these impacts.
EO-Environmental Objections
The EPA review has identified significant environmental impacts that must be avoided in order to provide
adequate protection for the environment. Corrective measures may require substantial changes to the
preferred alternative or consideration of some other project alternative (including the no action alternative
or a new alternative). EPA intends to work with the lead agency to reduce these impacts.
EU-Environmentallv Unsatisfactoly
The EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are
unsatisfactory li.0111 the standpoint of public health or welfare or environmental quality. EPA intends to
work with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected
at the final EIS sate, this proposal will be recommended for referral to the CEQ.
Adequacy of the I~iipactS tatenlent
Categorv 1 -Adequate
The EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alterative
and those of the alternatives reasonably available to the project or action. No further analysis or data
collecting is necessary, but the reviewer may suggest the addition of clarifying language or information.
Cate~orv2 -Insufficient Information
The draft EIS does not contain sufficient information for the EPA to hlly assess the environmental impacts
that should be avoided in order to hlly protect the environment, or the EPA reviewer has identified new
reasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS,
which could reduce the environmental impacts of the action. The identified additional information, data.
analyses, or discussion should be included in the final EIS.
Category 3-Inadequate
EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts
of the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of
the spectrum of alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the
potentially significant environmental impacts. EPA believes that the identified additional information, data
analyses, or discussions are of such a magnitude that they should have full public review at a draft stage.
EPA does not believe that the draft EIS is adequate for the purposes of the NEPA andlor Section 309
revlew. and thus should be formally revised and made available for public comment in a supplemental or
revised draft EIS. On the basis of the potential significant impacts involved, this proposal could be a
candidate for referral to the CEQ.
‘From EPA Manlinl 1640 Policy and Procedures for the Review of the Federal Actions Impacting the Environnien~

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