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EFLHD NEPA Categorical Exclusion Form EFL-TM-ENV-03(05) 

VA ST FL MHN GT

Eastern Federal Lands Highway Division

NEPA Categorical Exclusion Form

Project Number: VA ST FL MHN GT Date: 3/30/2023

Project Name: Fort Gregg-Adams Sustainment Gate 

Improvements

Location: U.S. Army Garrison Fort Gregg-Adams

City of Petersburg and Prince George County, 

Virginia

CE Category 23 CFR 771.117(c)(23): Federally funded projects 

(i) That receive less than $6,000,000; or (ii) with a 

total estimated cost of not more than $35,000,000 

and federal funding comprising less than 15% of 

total estimated project cost.

See 23 CFR 771.117 for full description of CE categories, including additional requirements when applying (c)26-28.

Project Description

The Eastern Federal Lands Highway Division of the Federal Highway Administration (FHWA), 

in cooperation with the U.S. Department of Defense, Army and Virginia Department of 

Transportation, proposes to extend the second northbound travel lane for entering U.S. Army 

Garrison (USAG), Fort Gregg-Adams (formerly Fort Lee) at the Sustainment Avenue (formerly 

Mahone Avenue) Gate Access Control Point (ACP) located in Prince George County, Virginia. 

USAG, Fort Gregg-Adams plans to relocate their ACP entrance for the Sustainment Avenue 

Gate southwest of its present location along Hickory Hill Road to provide security to portions of 

the Fort not covered by the current ACP. Due to long traffic queues caused by vehicles waiting 

to enter Fort Gregg-Adams for security checks, relocation of the ACP necessitates construction 

of an additional travel lane to allow authorized vehicles to continue through the gate during peak 

hours. The proposed project will extend the existing second northbound travel lane for 

approximately 4,210 linear feet to match the existing lane configuration at both ends of Hickory 

Hill Road. 

Additional work will include milling and overlay, extensions and improvements to existing 

drainage facilities, vegetation clearing and grubbing, utility relocation, security fence relocation,

signage, striping, and other miscellaneous road work. 

Environmental Commitments and Mitigation Measures 
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• Project work shall comply with the Avoidance and Minimization Measures outlined in 

the February 5, 2018, FHWA, FRA, FTA Programmatic Biological Opinion for 

Transportation Projects within the Range of the Indiana Bat and Northern Long-eared Bat 

(NLEB):

o Tree removal is not permitted within the active season of April 1st to November

15th; 

o Tree removal is limited to that specified in the project plans. Contractors must 

understand the clearing limits and trees shall be clearly demarcated; 

o Any lighting shall use downward-facing, full cut-off lens lights, or for those 

transportation agencies using the BUG system developed by the Illuminating 

Engineering Society, be as close to 0 for all three ratings with a priority of 

"uplight" of 0 and "backlight" as low as practicable;

• Avoid vegetation clearing from April 1 – July 31 to avoid take of species protected under 

the Migratory Bird Treaty Act and state listed threatened or endangered bird species. If 

vegetation must be cleared within this window, have a qualified biologist conduct bird 

nesting surveys prior to the removal of vegetation.

• Project construction must adhere to USAG Fort Lee, Directorate of Public Works 

Environmental Special Conditions 2019, or most recent.

• All solid waste debris will be recycled to the maximum extent possible and reported 

monthly to the USAG, Fort Gregg-Adams Directorate of Public Works, Environmental 

Management Division (EMD). A Final solid waste/recycling report will be provided to 

the EMD upon completion of construction.

Summary of Section 7 of the Endangered Species Act Compliance

FHWA obtained an official species list from the U.S. Fish and Wildlife Service Information for 

Planning and Consultation (IPaC) system on 10/3/2022 and 1/9/2023. The IPaC query identified 

the following species have the potential to occur in or adjacent to the project action area:

• Northern Long-eared Bat, Myotis septentrionalis (Endangered)

• Monarch Butterfly, Danaus plexippus (Candidate)

FHWA has also assumed presence for two additional species – the Indiana bat (Endangered) and 

Tri-colored bat (Proposed Endangered) – due to positive acoustic surveys conducted at 

Petersburg National Battlefield and potions of Fort Gregg-Adams within the past five years. 

On October 19, 2022, a 6-step project review package was submitted electronically to the 

USFWS, Virginia Ecological Field Office (USFWS Consultation Code: 2022-0077713). In the 

project review package, FHWA determined the proposed action would have no effect on the 
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EFLHD NEPA Categorical Exclusion Form EFL-TM-ENV-03(05)

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Eastern Federal Lands Highway Division

NEPA Categorical Exclusion Form

Monarch butterfly as no suitable habitat is present in the project area. FHWA also determined the 

proposed project may affect, but is not likely to adversely affect the NLEB, Indiana bat, and Tricolored bat (Proposed) due to implementation of species recommended avoidance and 

minimization measures. No response from USFWS was received as of February 17, 2023. 

On February 17, 2023, the FHWA submitted a project Self-Certification Letter to the Virginia 

Ecological Field Office per the Virginia Ecological Field Office online project review process 

guidance. The Self-Certification Letter completes the project review in accordance with the 

Endangered Species Act of 1973, as amended.

Summary of Section 106 of the National Historic Preservation Act Compliance

FHWA completed a Phase I cultural resources survey of the project area of potential effect 

(APE) from 9/20/2021 to 9/27/2021. The Phase I survey identified three new multicomponent 

archaeological sites (Sites 44DW0605, 44DW0606, and 44DW0607) within or adjacent to the 

project APE. A Phase II evaluation was conducted for Site 44DW0606 from 4/4/2022 to 

4/7/2022; a Phase II evaluation was not recommended for Sites 44DW0605 and 44DW0607. 

Based on the results of the Phase II evaluation, FHWA found that Site 44DW0605 was not 

eligible for listing in the National Register of Historic Places (NRHP). Although a Phase II 

evaluation was not conducted for Sites 44DW0605 and 44DW0607, both sites lie within the 

boundaries of Petersburg II Battlefield and may contain additional information pertaining to 

Petersburg II Battlefield. As such, FHWA treated Sites 44DW0605 and 44DW0607 as 

potentially eligible for listing in the NRHP and found that the proposed project would have no 

adverse effect on Site 44DW0607 and no effect on Site 44DW0605.

Additionally, FHWA found that the proposed project would have no adverse effect on the 

Petersburg II Battlefield (VDHR 123-5025) or Petersburg National Battlefield (VDHR 123-

0071) as no contributing elements of the Petersburg II Battlefield are present within the project 

APE and Petersburg National Battlefield is located outside the project APE. 

The Virginia Department of Historic Resources concurred with FHWA’s findings and 

determinations of eligibility in a letter dated 3/1/2023. 

FHWA initiated consultation with the Chickahominy Indian Tribe, Upper Mattaponi Indian 

Tribe, Nansemond Indian Nation, Pamunkey Indian Tribe, and Rappahannock Tribe on 

3/16/2022. No Tribes responded to the consultation initiation. 

On 1/25/2023, FHWA submitted the results of the combined Phase I Identification and Phase II 

Evaluation report and project finding of no adverse effect determination to the Chickahominy 

Indian Tribe, Upper Mattaponi Indian Tribe, Nansemond Indian Nation, Pamunkey Indian Tribe, 

and Rappahannock Tribe. The Pamunkey Indian Tribe responded on 1/27/2023, that they did not 
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have any comments. No other Tribes have responded to FHWA’s finding of no adverse effect or 

results of the combined Phase I/II report as of the date of this CE. 

Additional Agency Coordination and Compliance

FHWA has worked in close coordination with the Virginia Department of Transportation, City of 

Petersburg, Prince George County, and U.S. Army Garrison, Fort Gregg-Adams throughout the 

NEPA process and all stages of preliminary engineering.

FHWA also coordinated with state-level biological resource agencies as a courtesy. On 1/9/2023, 

FHWA requested a project review through the Virginia Department of Conservation and 

Recreation’s (DCR) Natural Heritage Data Explorer Web Service. The results found that 

portions of the project area are immediately adjacent to Ecological Core(s) C4 and C5 in the 

Virginia Natural Landscape Assessment. Ecological Cores C4 and C5 are the lower-ranked 

ecological core natural areas, ranked as moderate and general, respectively. DCR recommends 

avoiding impacts to ecological core areas, particularly those ranked at C1 (outstanding) and C2 

(very high). 

The Virginia Department of Game and Inland Fisheries – Fish and Wildlife Information Service 

(VaFWIS) geographic database was used to identify state listed endangered or threatened species 

which may occur in the project area. The database identified six state listed species which have 

the potential to occur in the project area, including, the little brown bat, tri-colored bat, 

Rafinesque’s eastern big-eared bat, peregrine falcon, loggerhead shrike, and Bachman’s 

Sparrow. Best Management Practices, such as seasonal restrictions to vegetation clearing, will be 

implemented as practicable to avoid or minimize adverse impacts to state listed species. 

Public Outreach and Involvement

FHWA will follow the Virginia Department of Transportation’s (VDOT) procedures for a Notice 

of Willingness. FHWA will place legal a notice in the Richmond Times Dispatch per VDOT’s 

Governance Document on Document Availability Requirements for Public Hearings (PCE and 

CE), approved on 4/29/2021. The notice will run two times one week apart. 
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EFLHD NEPA Categorical Exclusion Form EFL-TM-ENV-03(05)

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Eastern Federal Lands Highway Division

NEPA Categorical Exclusion Form

Categorical Exclusion Recommendation:

On the basis of the environmental impact information in the statutory compliance file, with 

which I am familiar, I believe the project should be categorically excluded from further NEPA 

analysis.

____________________________________ ________________

Kim Campo-Allen

Environmental Protection Specialist

Eastern Federal Lands Highway Division

Federal Highway Administration

Date

Categorical Exclusion Determination:

On the basis of the environmental impact information in the statutory compliance file, with 

which I am familiar, I am categorically excluding the described project from further NEPA 

analysis. The project meets the 23 CFR 771.117(a) definition of a categorical exclusion. No 

unusual circumstances per 23 CFR 771.117(b) apply.

____________________________________ ________________

Kevin S. Rose

Environmental Team Leader

Eastern Federal Lands Highway Division

Federal Highway Administration

Date
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Appendix A: Environmental Checklist

Section 7 of the Endangered Species Act:

• Are Federally-listed species potentially present in the study area? ☒Yes, see Notesi ☐No

If Yes, effects determination:

☒No Effect ☒May Affect, Not Likely to Adversely Affect ☐May Affect, Likely to Adversely 

Affect 

Section 106 of the National Historic Preservation Act:

• Are historic properties known to be present in the study area? ☒Yes ☐No

If Yes, will they be impacted by the project? ☒Yes ☐No

• Will previously undisturbed ground be disturbed?

☒Yes ☐No

• Effects determination:

☐No Historic Properties Affected ☒No Adverse Effect ☐Adverse Effect, MOA Executed

• Was tribal consultation completed? ☒Yes ☐No

Water and Wetlands:

• Section 404 of the Clean Water Act

Are impacts to Waters of the US anticipated? ☒Yes ☐No

If Yes, approval anticipated:

☒Nationwide Permit (NWP) ☐Regional General Permit ☐Individual Permit 

• Section 401 of the Clean Water Act

☒NWP certified by State ☐Individual Certification 

• Section 402 of the Clean Water Act (National Pollutant Discharge Elimination System)

Will the land disturbance threshold likely be exceeded to require a permit and SWPPP?

☒Yes ☐ No

• Is post-construction stormwater management review/approval anticipated? ☒Yes ☐No 

• ☒Project is consistent with Executive Order 11990, Protection of Wetlands

Floodplains:

• Is the project in a FEMA floodplain?

☐Yes ☒No ☐ Floodplain not mapped

• ☒ Project is consistent with Executive Order 11988, Floodplain Management

Section 4(f) of the USDOT Act:

• Does the project meet the Section 4(f) exemption for Federal lands transportation facilities under 

Section 1119(c)(2) of MAP-21, 23 U.S.C. 138(a)? ☐Yes ☒No

• Is there a use of a Section 4(f) property in the study area? ☐Yes ☒No

If Yes, De Minimis Finding:☐ Programmatic:☐ Individual 4(f): ☐

Section 6(f) of the Land and Water Conservation Fund:
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• Was the property purchased with grant funds from the Land and Water Conservation Fund?

☐Yes ☒No

• If Yes, was documentation of approval from National Park Service Director received for the

conversion or replacement of 6(f) property? ☐Yes ☐No

Coastal Zone Management Act of 1972:

• Is the project in a Coastal Zone? ☒Yes ☐No

• If yes, will a Federal Consistency Review be completed? ☒Yes ☐No

Right of Way:

• Is the project completely within the transportation facility’s right-of-way? ☐Yes ☒No

• If no, will the project require relocations or easements? ☒Yes ☐No

Hazardous Waste and Materials:

• Are hazardous materials or contamination exceeding regulatory thresholds (as set by U.S. EPA,

County Environmental Health, etc.) present? ☐Yes ☒No

• If Yes, is the nature and extent of the hazardous materials or contamination fully

known? ☐Yes ☐No, plan for securing information provided in Notes

Section 7(a) of the Wild and Scenic Rivers Act:

• Are there Wild and Scenic Rivers? ☐Yes ☒No ☐Eligible

If Yes, has review by the river-administering agency been completed? ☐Yes ☐No

Clean Air Act:

• Is the project in a non-attainment area? ☐Yes ☒No

If Yes, is the project on the Transportation Improvement Program(TIP)/State Implementation 

Plan(SIP)? ☐ Yes ☐No

Highway Traffic and Construction Noise Regulations:

• ☒ The proposed project is a Type I project (highway on a new location, substantial horizontal or

vertical alteration, new through or auxiliary lanes). Noise analysis is required.

• ☐ The proposed project is a Type II project (retrofit for noise abatement).

• ☐ The proposed project is a Type III project (noise analysis not required).

• ☐ Does not apply.

Environmental Justice and Title IV Act:

• Is an Environmental Justice population, as identified in Executive Order 12898, present?

☒Yes, explanation provided in Notesii section ☐No

• Will the project induce disproportionately high and adverse impacts to minority, low income, or

special groups? ☐Yes, additional analysis is needed ☒No

Farmland Protection Policy Act for Highway Projects:

• Does the project displace, require acquisition of, or require an easement from farmland?

☐Yes ☒No

Greenhouse Gas Emissions and Climate Change
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• Have greenhouse gas (GHG) emissions and climate change considerations been integrated into the 

planning, design, acquisition and/or construction processes? ☒Yes ☐No Comments: See below.

• Have GHG emissions or reductions been quantified for the expected lifetime of the action?

☐Yes ☒No Comments: The purpose of the proposed project is to reduce traffic queuing times 

caused by vehicles entering Fort Gregg-Adams’s Sustainment Gate ACP for security checks. The 

proposed project does not increase the number of vehicles entering Fort Gregg-Adams at the 

Sustainment Gate ACP and is not expected to induce development in the project area. 

A 2020 Transport Energy/Emission Research report from Australia (https://www.transport-eresearch.com/_files/ugd/d0bd25_8f1b26917f384fa4a554c57c099cb776.pdf) found that passenger 

vehicles idle more than 20 percent of their drive time. The report found that engine idling contributes 

up to 8 percent of total carbon dioxide emissions over the journey, depending on the vehicle type, and 

2 percent of total NOx emissions. While newer vehicles may come equipped with stop-start 

technology to reduce engine idling, older vehicles do not. 

The proposed project will reduce idle time for queued vehicles entering Fort Gregg-Adams at the 

Sustainment Gate ACP. Temporary increases in GHG emissions would occur during project 

construction due to the presence of construction vehicles and equipment, but impacts will be 

minimized by implementing best management practices during project construction to reduce 

emissions generated from construction vehicles and equipment. 

• Does the project consider biogenic carbon dioxide sources, carbon stock, and the project’s overall 

carbon footprint? ☐Yes ☒No Comments: N/A

• Does the project include resilience and adaptation measures to address climate change? 

☐Yes ☒No Comments: N/A

Does the project affect any other resources not listed above? Explain below and list anticipated 

permits:

Additional anticipated permits: Virginia Pollutant Discharge Elimination System CGP; Virginia Erosion and

Sediment Control (ESC) and Stormwater Management (SWM) Plan review and approval.

i Federally-listed species per U.S. Fish and Wildlife Service’s IPaC: Northern Long-Eared Bat (Myotis 

septentrionalis), Monarch Butterfly (Danaus plexippus).

ii Per the Environmental Protection Agency’s Environmental Justice Screening Tool, the City of 

Petersburg has a higher-than-average population of low income, limited education, and minority 

households. The project area provides access to some neighborhoods off Armistead and Breckenridge 

Avenues, but the project area is not predominately residential. Disproportionate or adverse impacts to 

these populations would not occur as a result of the proposed project.