{"id":412,"date":"2010-07-20T21:02:16","date_gmt":"2010-07-21T01:02:16","guid":{"rendered":"http:\/\/www.nomcb.com\/?p=412"},"modified":"2011-09-20T18:55:15","modified_gmt":"2011-09-20T22:55:15","slug":"usepa-slams-mid-currituck-bridge-deis","status":"publish","type":"post","link":"https:\/\/www.nomcb.com\/?p=412","title":{"rendered":"USEPA SLAMS MID-CURRITUCK BRIDGE DEIS"},"content":{"rendered":"

NEPA comments on MCB DEIS<\/a><\/p>\n

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
\nREGION 4
\nSAM NUNN
\nATLANTA FEDERAL CENTER
\n61 FORSYTH STREET
\nATLANTA, GEORGIA 30303-8960<\/p>\n

June 4, 20 10<\/p>\n

Ms. Jennifer Harris, P.E.
\nNorth Carolina Turnpike Authority
\n5400 Glenwood Avenue, Suite 400
\nRaleigh, North Carolina 27612<\/p>\n

SUBJECT: Federal Draft Environmental Impact Statement for the Mid-Cumtuck Bridge Study,
\nCurrituck and Dare Counties, North Carolina; TIP Project No.: R-2576; FHW-E40830-NC; CEQ
\nNo.: 201001 16<\/p>\n

Dear Ms. Harris:<\/p>\n

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\u00a0 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\u00a0 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.
\nNCTA and FHWA also studied an ‘improve existing’ roadway alternative (i.e., ER2) at the request of numerous State and Federal agencies.
\nThe 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.
\nEPA’s primary environmental concerns regarding the Clean Water Act remain unresolved. Detailed technical review comments are attached (See Attachment A).\u00a0 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
\nshould 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
\n404(b)( 1 ) Guidelines.\u00a0 Internet Address (URL) http:\/\/www.epa.gov
\nNCTA 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,\u00a0and 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.
\nE 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.\u00a0 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
\nconcerning EPA’s comments.
\nHeinz J. Mueller, Chief
\nNEPA Program Office
\ncc: J. Sullivan, FHWA
\nK. Jolly, USACE
\nB. Wrenn, NCDENR
\nG. Tliorpe, NCDOT
\nwIAttachmei~tsA and B
\nAttachment A
\nDEIS Detailed Review Comments
\nMid-Currituck Bridge Study
\nCurrituck and Dare Counties
\nR-2576
\nGeneral Comments
\nThe DEIS is presented in a revised format from the recommended format found at 40
\nCFR Section 1502.10. Page v of the DEIS Preface includes a statement concerning Chapter 3,
\nthe Affected Environment and Environmental Consequences and as well as the potential shortand
\nlong-term beneficial and adverse effects (if any) of the detailed study alternatives. EPA
\nbelieves that this major Federal action that could involve the construction of a new bridge and
\nother coastal infrastructure improvements in the cost range of $595.5 million $1,065.1 million
\nwill have potential short-term and long-term adverse effects on the natural and human
\nenvironment. The average cost range of the new bridge alternatives and options appears to be
\napproximately $750 to $800 million based upon the information on Page xxi of the DEIS.
\nEPA could not find a specific discussion in the DEIS concerning the long-term
\nmaintenance costs of a new 7 to 7.5-mile bridge facility over Currituck Sound. Major
\ninfrastructure along the Outer Banks and the coastal plain of North Carolina is periodically
\ndamaged by severe storms and hurricanes. Maintenance costs associated with the existing
\nproject study area roadways and bridges has been expressed by F H W A ‘N~C~D~OT as a major
\nconcern for more than a decade. Shrinking transportation dollars and increased maintenance and
\nrepair costs for infrastructure in areas that are very vulnerable to severe weather conditions such
\nas high winds and storm surges and salt air and water should be a very important consideration
\nfor decision-makers. NCDOT Division 1 officials have routinely expressed their concerns at
\nother project meetings for maintaining existing roadways and bridges. .Adding more than 7 miles
\nof new infrastructure in this area will further strain existing transportation resources.
\nPages xii and xiii of the DEIS include other transportation projects proposed in the study
\narea. EPA understood from the NCDOT project management that for R-2545 and R-2544, US
\n64 including the new bridge over the Alligator River, only the bridge is funded and the 20-miles
\nof widening and new location sections between Columbia and Manteo are currently unfunded.
\nAppendix A, Comments and Coordination does not include copies of specific agency letters
\nfollowing Turnpike Ellviroilmental Agency Coordination (TEAC) meetings.
\nProject Purpose and Need
\nThe DEIS presents three primary project needs, including the need to improve traffic
\nflow in the study area roadways such as US 158 and NC 12, the need to reduce travel time for
\npersons traveling between the Outer Banks and Currituck County mainland, and the need to
\nsubstantially reduce evacuation times from the Outer Banks. EPA has previously commented on
\nsome of the project purpose and need issues during scoping and the Turnpike Environmental
\nAgency Coordination (TEAC) process. EPA continues to have substantial environmental
\nconcerns regarding the documented need for a new crossing of Currituck Sound and the detailed
\nstudy alternatives (DSAs) presented in the DEIS that include a new bridge. The traffic flow and
\ntravel time benefits froin a new bridge crossing do not in the long-term outweigh the direct
\nadverse effects to the natural environment, including wildlife, coastal wetlands, and water
\nquality. Table 2-3 of the DEIS attempts to capture some of the travel benefits of the detailed
\nstudy alternatives of ER2, MCB2 and MCB4 compared to the No-build. In addition, this table
\nalso tries to capture the 2035 Hurricane Evacuation Benefit in clearance times between the
\nalternatives.
\nEPA does not believe that there have been any documented hurricane evacuation
\nproblems in this area of the Outer Banks in modern times using the existing roadway system.
\nEPA understands the State’s desired goal of reducing hurricane evacuation clearance times to the
\n18-hour goal. Planning and designing a roadway system based upon this desired goal should be a
\nconsideration but not a finite decision point in the preferred alternative selection process. There
\nare other areas of the Outer Banks that potentially cannot meet this 18-hour goal even if a new
\nbridge is constructed over Currituck Sound. EPA in its review of the September 2005 North
\nCarolina Department of Transportation State Hurricane Evacuation Study found only two
\nCategory 3 hurricanes in ‘modern times’ (post 1930) that directly hit the Outer Banks. On
\nSeptember 16, 1933, Hurricane #13 hit the Outer Banks and there were reportedly 21 died, many
\nof wl~omd ied from inland flooding. On September 1, 1993, Hurricane Emily resulted in
\n160,000 persons being evacuated. Two surfers reportedly died from drowning after they
\napparently refused to evacuate the island.
\nOther reduced strength hurricanes have historically either brushed near the Outer Banks
\nor made landfall further south in North Carolina and traveled north up the coastal plain towards
\nVirginia. Some of these lesser strength hurricanes caused extensive flooding and storm surge
\ndamage along the Outer Banks and in inland areas (e.g. Category 2 Hurricane Isabel on
\nSeptember 18, 2003; only 45% reportedly evacuated from the Outer Banks). Considering that
\nmost documented fatalities during hurricanes involve drowning in flooded low-lying areas,
\ntransportation agencies should consider other planning initiatives as evacuated persons from the
\nOuter Banks move inland. Many of the evacuation routes in the coastal plain traverse low-lying
\nareas, rivers and streams. During one NCDOT presentation on hurricane evacuation in 2008,
\nNCDOT used hurricane evacuation pictures from Texas (i.e., Hurricane Rita) as the
\ndocumentation for traffic congestion problems. The September 2005 NCDOT State Hurricane
\nEvacuation Study contains no photographs or other direct evidence of past evacuation problems
\nin North Carolina. EPA does agree that reducing hurricane evacuation clearance times in general
\nis a desirable goal and should be reasonably weighed against other costs, benefits and adverse
\nenvironmental effects. Local planning and early warning appear to be important components to
\neffective hurricane evacuation, including the consideration of minimizing new development
\nalong isolated and remote areas of barrier islands.
\nThe DEIS includes information on the funding of the project and estimated costs on
\npages xxi and xxii. According to this section, only the toll, new bridge alternatives have a
\npotential to be filnded. DSA ER2 cannot be funded through toll revenues or the Public Private
\nPartnership agreement. Furthermore, the $15 million per year provided by the N.C. General
\nAssembly cannot be applied to DSA ER2 per the DEIS, only DSAs MCB2 and MCB4. The
\nDEIS does not indicate if the N.C. Board of Transportation considers R-2576, Mid-Currituck
\nBridge Study project to be a priority project under its current priority plans and what funding
\ncould be made available for DSA ER2 if it is selected as the preferred alternative. NCTA
\nofficials have stated during TEAC meetings that ER2 is not a ‘feasible’ alternative as it cannot be
\nfil~ideda s a toll project.
\nDetailed Study Alternatives and Options
\nTlie DEIS includes DSAs ER2, MCB2 and MCB4 with the followi~igo ptions: MCB2lC 1 ,
\nMCB2lC2, MCB4lC 1 and MCB4lC2. Option C 1 includes a northern connection and
\ninterchange on [lie barrier island side of Currituck County and Option C2 includes a southern,
\nlonger connection and interchange near Albacore Street. Option C2 is actiially a 7.5-mile bridge.
\nThe DEIS also states tliat the bridge over Currituck Sound for C1 Option is approximately 7.0
\nmiles in lengtli ((Page 2-10). From past TEAC meetings, there was reference to the new bridge
\nbeing approximately 5 to 7 miles long. MCB2 provides greater improvements to local roadways
\nand MCB4 provides more limited improvements. The specific improvements imder each DSA
\nare included in Section 2 of the DEIS. The A and B designation refers to the mainland approach
\nroad options of the new bridge.
\nEPA recognizes that MCB2 includes the existing road improvements similar to ER2, but
\nthe informati011 contained 011 page xxi of the DEIS is confusing. For example, the range of cost
\ndifference between ER2 and MCB2lBlCl is $416.1 to $523.4 million vs. $800.1 to $970.2
\nmillion, respectively. The DEIS does not specifically state the cost of a 7-mile or 7.5-mile
\nbridge. The range of costs for a new bridge might be from $384.0 to $446.8 million. Similarly,
\nthe other MCB2 alternatives would indicate that a new 7-mile bridge over Currituck Sound
\nwould cost approxiniately $400 to $500 million dollars. These figures do not correlate well with
\nthe information contained in Table 2-4 where the costs are broken down for each DSA.
\nConstruction costs for the bridge alternatives under Option A range from $619.3 to $845.7
\nmillion, and construction costs for bridge alternatives under Option B range between $5 13.4 and
\n$726.3 million. These figures exclude mitigation, right of way and utility costs. There is great
\nvariability in tlie actual bridge costs as presented in the DEIS and it is unclear as to the cost
\ndifferences between Option C1 which is approximately 7.0 miles in length and Option C2 which
\nis 7.5 miles in length. Therefore, EPA requests that the FEIS include clarification as to the actual
\ncosts of a new bridge.
\nOption B wo~~nlodt include a toll plaza at the US 158 interchange and the bridge
\napproach would be placed on fill within Maple Swamp. Option A wo~~plldac e a toll plaza
\nwithin the US 158 interchange. The mainland approach road would include a bridge over Maple
\nSwamp. Similarly to Options C1 and C2, the costs between these two options are not clearly
\nidentified in the DEIS. It is also unclear if the costs for the longer bridge over Maple Swamp
\ni~~idOerp tion A are added to the C1 and C2 lengths.
\nThe DEIS indicates that the new Mid-Currituck Bridge would be a two-lane facility and
\ndiscusses some of tlie travel and other considerations on Page 2-1 7. The difference between a
\ntwo-lane facility and four-lane facility is estimated at approximately $120 million. The cost
\nestimation details are not included in the DEIS. Superstructure supports, materials, and
\nconstruction costs would be expected to be proportionally greater with a four-lane facility.
\nDetailed cost assumptions and estimations should be included in the FEIS.
\nHuman and Natural Environmental Impacts
\nThe DElS iiicludes a comparison of key impacts in Table S-1 and in other sections of the
\ndocument. Soine of these impact assumptions and categories are not meaningful or have not
\nbeen shown to be a relevant issue for the comparison of alternatives. For example, outdoor
\nadvertising signs are listed as a key impact with 29 signs for ER2 and 6 or 16 signs for the
\nMCB2 or MCB4 alternatives and the respective options. FHWA and NCDOT routinely relocate
\noutdoor advertizing signs for widening and new location projects. The relocation of gravesites is
\nalso highlighted as a major difference between the alternatives and a key impact. The relevance
\nof this ‘key impact’ is not identified in the DEIS.
\nThe residential relocatioiis between the alternatives are generally similar and range
\nbetween 5 and 8 with 10 vacation rental units. Business relocations are also generally ill the
\nsame magiiitude of impact with between 5 and 8. The summary table also includes impacts with
\nno third outbound lane for hurricane evacuation. The impacts range from 2 to 6 by not including
\nthis third lane. The DEIS includes discussions with access changes to neighborhoods and
\nbusinesses. The access changes appear to be a reasonable expectation considering the scope and
\nmagnitude of the proposed improvements.
\nTotal wetland impacts are 7.2 acres, 40.3 acres, 44.9 acres, 42.4 acres, 47.0 acres, 36.6
\nacres, 41.1 acres, 38.7 acres, and 43.2 acres for Alternatives ER2, MCB2\/Cl\/A, MCB2\/Cl\/B,
\nMCB2\/C2\/A, MCB2\/C2\/B, MCB4\/Cl\/A, MCB4\/Cl\/B, MCB4\/C2\/A and MCB4\/C2\/B,
\nI-espectively. The bridge alternatives also have the highest impacts to SAVs with 18.8 acres for
\nMCB2\/Cl, 23.3 acres for MCB21C2, 18.8 acres for MCB4\/C1 and 23.3 acres for MCB41C2.
\nBased on the magnitiide difference in wetland and other water resource impacts, EPA believes
\nthat ER2 is the environmental preferred alternative and appears to be the Clean Water Act
\nSection 404 Least Environmentally Damaging Practicable Alternative (LEDPA).
\nThe impacts to water quality are expected to be very significant. The DEIS does not fully
\naddress the fact that water quality in Currituck Sound has declined substantially in the last
\nseveral decades due to primarily an increase in turbidity and nutrient loading from non-point
\nsource runoff. Nursery areas for Blueback hemng and Alewife have not been recognized since
\nthe 1980’s. Coastal niarslies around Currituck Sound waters have been lost to erosion or invaded
\nwith exotic plant and animal species. In addition to development, other hun1an activities such as
\nagricultural and silviculture have potentially impacted overall water quality ill the sound and
\ncaused subseq~~eidiet cline in ecosystem and habitat function. Section 3.3.4.1 addresses aquatic
\nwildlife in Currituck Sound and Section 3.3.4.2 discusses Submerged Aq~iaticV egetation
\n(SAV). For purposes of differentiating the impacts between the alternatives, Section 3.3.4.3 is
\ninadequate for fully addressing the magnitude of impacts to water habitat. In addition to the
\ndirect loss of SAVs and shading effects, the new bridge pilings would also potentially allow for
\nthe introduction of other organisms not typically found in a shallow water estuary. The DEIS
\nstates that: “011 the other hand, organisms could be attracted to bridge pilings as a reef
\nstructure”. I11 the appropriate ecosystem, reef structures can aid and provide potential habitat.
\nThe DEIS does not rcference appropriate studies or supportingdocumentatio~i that bridge pilings
\nwould be beneficial to the Currituck Sound ecosystem. Considering the loss of essential fish
\nhabitat and othcr 11atural fi~nctionsf rom past and current human activities, EPA co~isiders
\nadditional losscs to SAVs to be a critical issue. EPA does not consider runoff from construction,
\nincluding increased turbidity, siltation and sedimentation in aquatic habitat arcas to be a
\n‘minimal’ effect. The discussion concerning the impacts from the bridge construction
\nalternatives versus the existing roadway improvements does not provide the pi~blica nd resource
\nand permitting agencies a reasonable comparison of impacts to aquatic habitat. Shading is
\nexpected to impact 14.5 to 17.8 acres of aquatic bottom. Bridge foundations are expected to
\ndirectly impact 4.3 to 5.5 acres of SAVs. Contrary to the italicized coininent at Section 3.3.4,
\nconstruction impacts may not be temporary but could become permanent considering the existing
\nwater quality problc~iisin Curritilck Sound.
\nSection 3.3.4.4 of the DEIS provides more relevant information concerning the potential
\nimpacts from noise, turbidity and siltation. The DEIS acknowledges that non-mobile species
\nsuch as clams could suffer long-term impacts from construction related siltation. However, the
\nDEIS does not adequately assess the issue of recovering populations of benthic organisms after
\nconstruction is co~npletedo r what practicable measures that NCTA would take to minimize
\nturbidity generated during bridge construction. Potential construction techniques of the bridge
\nare discussed in Section 2.4. EPA believes that only the ‘top-down’ method of construction
\nwould be acceptable. Dredging between 53,000 cubic yards and 61,000 cubic yards based upon
\nother proposed methods described in Section 2.4 would not be environmentally-sound.
\nFurthermore, the DEIS does not describe the proposed site suitability and location of dredged
\nspoils. The DEIS does not specifically reference if the potential impacts of 25 or 17 acres to
\nacli~aticb ottom are included in summary tables. Also, the discussion concerning the approximate
\n4 acres of impact from the dock construction is not explained fully in reference to the summary
\nimpact table.
\nNCTA and FHWA propose to build the bridge simultaneously from both sides using both
\nUS 158 and NC 12 with construction meeting in the middle. Moving large construction
\nequipment and materials via NC 12 would potentially be very disruptive to local residents and
\nhave a substantial impact to local traffic. This issue is not discussed in the DEIS.
\nAlternatives MCB2 and MCB4 involve the construction of the new bridge across
\nCurrituck Sound and will traverse Maple Swamp on the mainland side. Maple Swainp is
\ndesignated as a Significant Natural Heritage Area (SNHA). Option A would involve the
\nbridging of Maple Swamp. Option B would involve filling the wetlands of Maple Swamp. EPA
\nrecommends bridging this entire high quality system.
\nThe DEIS addresses different stormwater treatment options from the deck drains for the
\nbridge alternatives. EPA believes that a full collection and treatment system is needed for any of
\nthe bridge alternatives. Untreated roadway runoff into Currituck Sound will filrther degrade this
\nresource that is already stressed from human activities, including residential and cominercial
\ndevelopment. Bridge draii~ageo ptions are specifically discussed on Pages 2-25 to 2-27 of the
\nDEIS. EPA stroi~glyr ecommends Option 1 of the three options identified for collecting and
\ntreating bridge drainage. A direct discharge of bridge stormwater through deck drains into
\nCurrituck Sound is not eiivironiiientally sound and will continue to accelerate water quality
\ndegradation problcms.
\nThe disci~ssionc oncerning invasive species control at Section 3.3.5 is not adequate. The
\nFEIS should cite cxaniples of past successes using NCDOT’s Best Management Practices
\n(BMPs) for management of invasive plant species in coastal areas. To EPA’s knowledge, there
\nare few or no long-tenn and cost-effective successes to controlling invasive plants such as
\nPliragmites once they become introduced or established through disruptive activities such as
\nconstruction. NCDOT’s BNIPs on such coastal wetland mitigation sites such as Mashoes Road
\nfor controlling Phragniites have been very costly and in the long-term ineffective in eliminating
\nthis damaging species.
\nThe DElS very generally discusses borrow site material needed for fill. The DEIS does
\nnot address the specific locations of any proposed borrow sites or any impacts associated with
\ntliese potential locations. For pi~lposeso f assessing the potential indirect impacts from borrow
\nsites needed for the proposed project alternatives, the DEIS does not provide adequate details
\nand defers to the final design stages; additional information should be provided in the FEIS.
\nThe DEIS includes consideration for on-site wetlands mitigation by removal of Aydlett
\nRoad. However, this coi~lpensatorym itigation of potentially 9.1 acres is only being offered for
\nthe bridge alte~nativcst hat would fill existing Maple Swamp. From direct field observations,
\nthere are extensive invasive plant species immediately adjacent to Aydlett Road. The
\nmanagement and control of invasive plant species would need to be thoroughly addressed should
\nthis mitigation be pilrsued at a future date. Compensatory mitigation is also addressed on Pages
\n3-46 and 3-48 of the DEIS. A conceptual mitigation plan is not included in the DEIS, and should
\nbe included iii tlie FEIS.
\nFloodplain Issues
\nThe DEIS includes statements that the new highway will involve significant
\nencroachment in floodplain areas but it also states that with respect to floodplain highway
\nencroachment, it is tlie policy of the FHWA to avoid significant encroachment since they would
\nbe considered a significant alteration to a water course by Currituck County (Pages 3-74 and 3-
\n75). Page 3-72 states that “should MCB2lB or MCB4B be selected for implementation,
\nadditional studies would be conducted during the final design so adverse floodplain
\nimpacts.. ..could be avoided or minimized, as well as affects to groundwater hydrology,
\nl~ydrologicacl liaracteristics of Maple Swamp, and supported ecological functions”. EPA
\nbelieves that these studies should be completed prior to the issuance of a FEIS. Furthermore,
\nOption A (i.e., Bridging Maple Swamp) should be considered in combination with the removal
\nof Aydlett Road. The floodplain impact is estimated at 22.1 acres on the mainland (Page 3-72).
\nFor alternatives MCB2lA and MCB4\/A7 the impact to the 100-year floodplain would be a total of
\n10.4 acres. Reference to a project commitment is also made on Page 3-74 with the mitigation
\nmeasures deteniiiiiation followi~igf inal design. The DEIS does not provide any suggestion of
\nhow these significaiit floodplain encroachment impacts can be minimized. Considering severe
\nstorms and stor~ns urge, the past history of flooding, the accelerated development in the project
\nstitdy area and increases in impervious surfaces, and the potential for sea level rise, any
\nfloodplain cncroaclimcnt will significantly increase flooding events. EPA does not concur with
\ntlie statement conccl-ning floodplain impacts for MCB2lA and MCB4lA on Pagc xxiii.
\nSea Lcvel Rise
\nThe DEIS includes a discussion of sea level rise in Section 3.4.4 and defers decisions on
\nroad and bridgc elevations needed to accommodate potential sea level rise to final design.
\nRaising the grade of tlie roadways to accommodate sea level rise estimates will iiicrease f i l l
\nheights and create additional inipacts to jurisdictional water resources. EPA does not agree that a
\nMid-Curriti~ck Bridge would be a useful asset in reducing the impact of sea level rise on the
\nproject’s area road system. Conversely, bridge alternatives are expected to iiicrease floodplain
\ncncroachment with no minimization measures being proposed. Sea level rise will only
\nexacerbate flooding and storm surge issues. The statement that a Mid-Curritiick Bridge could
\n‘stay in service LIP to 75 years’, is not reasonable nor is there a reference to other similar bridge
\nstructures in thc coastal plaiii that have lasted that period of time without significant repairs or
\nreplacement. EPA does not concur with the suggestion that a breach in the islalid at the
\nCurritucklDare Coi~ntyli ne coiild be addressed through a new bridge and tlie conclusions of this
\nsection of the DEIS do iiot appear to be adequately supported by the documentatioii.
\nFish and Wildlifc linpacts
\nEPA defers specifically to the U.S. Fish and Wildlife Service, N.C. Wildlife Resources
\nCo~nmissiona iid otlier resource agencies concerning the potentially significant impacts to fish
\nand wildlife. EPA co~icul-fsu lly with the comments contained in the May 25, 2010, letter froin
\nthe U.S. Department of Interior to NCTA and the May 21, 2010, memorandum from the N.C.
\nwildlife Resources Commission to Ms. Melba McGee, NCDENR. 011ly alternative ER2 does
\nnot represent a sigiiificant impact to fish and wildlife resources, including acli~atico rganisms aiid
\nfish, migratory birds, aiid terrestrial species. The discussion contained in the sunimary impacts
\ntable is not a reasonable representation of the differences in the impacts between the alternatives.
\nThe bridge alter~iativesr epresent a major or severe impact to wildlife species, including direct
\nimpacts from habitat loss, habitat fragmentation and indirect and cumulative effects.
\nliiaccuracies coiiceiliing endangered and threatened species should be addressed in the FEIS.
\nFarmland Impacts
\nThe DEIS describes the potential impacts to farmlands in Section 3.1.12. The discussion
\nis not based i~polia n actual fill1 analysis and determination of prime, unique and State and locally
\nimportant fariiila~~diusi der Title 7 Code of Federal Regulations (CFR) Part 658 but on soil types.
\nTlie assessment did iiot include completed Form AD-1006 or Form NRCS-CPA-106. MCB2lA
\nand MCB4lA would affect approximately 37 acres of prime farmland g& and 72 acres of State
\nand locally important far~nland& . MCB2JB and MCB4lB would impact approximately 76
\nacres of prime fannlaiid soils and 41 acres of State and locally important farnlland g&. The
\nDEIS does not provide a relevant discussion of North Carolina’s initiatives in protecting
\nfaniilands from coiitiiiued losses to development. The DEIS does not address if Curritiick
\nCounty is participating in the Voluntary Agricultural District (VAD) program. The DEIS does
\nnot indicate if these potei~tial farmland losses will impact the specific operations of current
\nagriculture and what economic impact that may result. The DEIS on Page 3- 19 does reference
\nanother 2009 report that includes a copy of the Farmland Conversion Impact Rating form CPA-
\n106. Table S-1 Co~nparisono f Key Impacts does not include any specific faimland impact
\ncategory. Contin~lcd farmland losses in North Carolina is an important socio-economic issue and
\ntlie DEIS attempts to categorize the potential loss from this proposed project as being
\ninconsequential (e.g., “….this is less than 0.01 percent of all farmland soils in Currituck
\nCounty”.).
\nLndirect and Cum~rlativeIm pacts ‘
\nEPA has previously expressed concerns for the indirect and cumulative impacts from the
\nproposed bridgc altci-natives. The DEIS discusses indirect and cumulative effects in Section 3.6.
\nEPA continucs to have environmental concerns for the proposed project bridge alternatives. The
\nstatement contained ill SLiinmary impact table on Page xx includes the desire by Currituck
\nCounty that the bridge alternatives are desired because the potential developn~enta t the bridge’s
\ninterchange and along US 158. There are significant wetland areas and other low-lying
\nfloodplain areas where this development is desired. Referencing Page 3-88 of the DEIS, EPA
\ndoes not concur with the statement concerning the type and density of developmei~ct ompared to
\nthe ‘No-build alternative’ and the bridge alternatives. ‘The lack of transportation iinprovements
\n~lndit s constraint on development’ statement included on Page 3-89 is not accurate or supported
\nby actual development facts. This area has been developing at an accelerated pace until the
\nmajor eco~lon~diocw n turn in 2009. This has been occurring for more than a decade and without
\nany transportation inlproveinents and with some seasonal congestion. EPA does not agree with
\nthe assessment of poteiltial development in the Carova area. The FEIS should address these
\nissues further.
\nEnvironnientiil I~iipacot f the Action
\nLO-Lack of Objections
\nThe EPA review has not identified any potential environmental impacts requiring substantive changes to
\nthe proposal. The review may have disclosed opportunities for application of mitigatiou nleasures that
\ncould be acconlplished with no more than minor changes to the proposal.
\nEC-Environmental Concerns
\nThe EPA review has identified environmental impacts that should be avoided in order to frilly protect the
\nenvironment. Corrective nleasures may require changes to the preferred alternative or application of
\nmitigation nleasures that can reduce the environmental impacts. EPA would like to work with the lead
\nagency to reducc these impacts.
\nEO-Environmental Objections
\nThe EPA review has identified significant environmental impacts that must be avoided in order to provide
\nadequate protection for the environment. Corrective measures may require substantial changes to the
\npreferred alternative or consideration of some other project alternative (including the no action alternative
\nor a new alternative). EPA intends to work with the lead agency to reduce these impacts.
\nEU-Environmentallv Unsatisfactoly
\nThe EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are
\nunsatisfactory li.0111 the standpoint of public health or welfare or environmental quality. EPA intends to
\nwork with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are not corrected
\nat the final EIS sate, this proposal will be recommended for referral to the CEQ.
\nAdequacy of the I~iipactS tatenlent
\nCategorv 1 -Adequate
\nThe EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alterative
\nand those of the alternatives reasonably available to the project or action. No further analysis or data
\ncollecting is necessary, but the reviewer may suggest the addition of clarifying language or information.
\nCate~orv2 -Insufficient Information
\nThe draft EIS does not contain sufficient information for the EPA to hlly assess the environmental impacts
\nthat should be avoided in order to hlly protect the environment, or the EPA reviewer has identified new
\nreasonably available alternatives that are within the spectrum of alternatives analyzed in the draft EIS,
\nwhich could reduce the environmental impacts of the action. The identified additional information, data.
\nanalyses, or discussion should be included in the final EIS.
\nCategory 3-Inadequate
\nEPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts
\nof the action, or the EPA reviewer has identified new, reasonably available alternatives that are outside of
\nthe spectrum of alternatives analyzed in the draft EIS, which should be analyzed in order to reduce the
\npotentially significant environmental impacts. EPA believes that the identified additional information, data
\nanalyses, or discussions are of such a magnitude that they should have full public review at a draft stage.
\nEPA does not believe that the draft EIS is adequate for the purposes of the NEPA andlor Section 309
\nrevlew. and thus should be formally revised and made available for public comment in a supplemental or
\nrevised draft EIS. On the basis of the potential significant impacts involved, this proposal could be a
\ncandidate for referral to the CEQ.
\n‘From EPA Manlinl 1640 Policy and Procedures for the Review of the Federal Actions Impacting the Environnien~<\/p>\n","protected":false},"excerpt":{"rendered":"

NEPA comments on MCB DEIS UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4 SAM NUNN ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960 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, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-412","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/www.nomcb.com\/index.php?rest_route=\/wp\/v2\/posts\/412","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.nomcb.com\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.nomcb.com\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.nomcb.com\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/www.nomcb.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=412"}],"version-history":[{"count":17,"href":"https:\/\/www.nomcb.com\/index.php?rest_route=\/wp\/v2\/posts\/412\/revisions"}],"predecessor-version":[{"id":791,"href":"https:\/\/www.nomcb.com\/index.php?rest_route=\/wp\/v2\/posts\/412\/revisions\/791"}],"wp:attachment":[{"href":"https:\/\/www.nomcb.com\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=412"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.nomcb.com\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=412"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.nomcb.com\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=412"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}