20110101 Ver 1_Complete File_20051028

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MICHAEL F. EASLEY
GOVERNOR
MEMORANDUM
TO:
FROM:
SUBJECT:

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
October 24, 2005
Ms. Nicole Thomson
Marie Sutton
Project Development & Environmental Analysis Branch
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LYNDO TIPPETT
SECRETARY
Replacement of Bridge No. 51 on US 264 over Broad Creek, Beaufort
County, Federal Aid Project No. BRSTP-264(24), State Project No.
8.1151601, TIP No. 4413
The Project Development & Environmental Analysis Branch of the Division of Highways
has begun studying the proposed replacement of Bridge No. 51. The project is included in the
current Transportation Improvement Program (TIP) and is currently scheduled for right of way
acquisition in fiscal year 2007 and construction in fiscal year 2008.
The proposed project will replace Bridge No. 51 on US 264 over Broad Creek.
Alternatives typically considered include on-site detours, realignment of the road, or an off-site
detour where one is available. Due to environmental issues and cost considerations, we are having
to strongly consider off-site detours on more projects than ever before. Please include any
comments you may have on the subject bridge replacement, particularly about off-site detours if
available.
This is a Federal-Aid project and any comments will be used in the preparation of a
Categorical Exclusion evaluating environmental impacts of the proposed project. It is desirable
that any comments be received by November 26, 2005 so that they can be used in the preparation
of this document.
If you have any questions concerning the project, please contact Marie Sutton at (919) 733-
7844, ext. 262.
Attachment
MAILING ADDRESS:
NC DEPARTMENT OF TRANSPORTATION
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS
1548 MAIL SERVICE CENTER
TELEPHONE: [phone]
FAX: [phone]
WFR.CITF• wmw M!'. nnT nor
LOCATION:
TRANSPORTATION BUILDING
1 SOUTH WILMINGTON STREET
RALEIGH INC
NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
US 264
Replace Bridge No. 51 over
Broad Creek
Beaufort County, North Carolina
TIP NO. B-4413
PROJECT LOCATION MAP
Not to Scale FIGURE 1
Scoping Comments for Bridge Replacements

t/
TIP Bride Count Road/Stream Comments
4415 21 Beaufort NC 32 / Pungo Cr. Channelized stream w/ broad flooplain under bridge. May be
room for on-site detour on E side of bridge w/ minimal
buffer impacts if necessary. Could restore small portion of
flood-plain on N side w/ longer bridge.
4428 140 Beaufort Sr 1626 / UT Canal w/ high steep banks on both sides. May not be suitable
for on-site detour due to private property and buffer/wetland
issues. Longer bridge would not significantly restore
flood lain due to high banks.
4413 51 Beaufort US 264 / Broad Cr Feature appears to be channelized extension of Broad Cr.
Moderate flow. On-site detour may be difficult because of
buffer/wetland issues.
4417 59 Beaufort NC 99 / Jack Creek Bridge too low for boat access other than canoe/jon boat.
Higher bridge would allow for better boat access. On-site
detour may be possible but could run into CAMA/buffer
issues. Channel much wider on both sides of bridge. They
may have brought in fill to allow for shorter bridge?? Longer
bridge could allow for restoration of original channel.
4416 76 Beaufort NC 33 / none Bridge crosses C&N railway ...no stream resent
4604 13 Pitt SR 1753 / Indian Channelized stream w/ strong flow. High banks w/ dirt paths
Wells Swp running along either side. Longer bridge would not
significantly help to restore floodplain/wetlands due to
incised channel and steep banks.
4531 36 Greene SR 1343 / Little Current bridge has deck drains, 6 sets of bents w/ 4 in the
Contentnea Cr. channel. Recommend a longer bridge to restore wetland
floodplain. Also fewer bents in the channel and no drains on
bridge
48 Greene SR 1432 / Wheat Current bridge single bent mid channel. No flow, duckweed
465 Swp on water. Longer bridge could restore wetland area,
- articular) on W side.
4568 67 Lenoir SR 1515 / Falling Low flow. Extensive wetlands/floodplain on both sides of
Cr. bridge. Could restore lots of wetland area w/ longer bridge.
On-site detour not good here due to wetlands and buffers
4570 79 Lenoir SR 1544 / Gum Extensive swamp on N side. Longer bridge could open up
Swam Cr. more wetland area on N side. Higher round on S side.
4565 42,43 Lenoir US 70 / Neuse R. Twos an bridge would allow for on-site detour.
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December 8, 2005
MEMORANDUM
To: Marie Sutton
Project Development and Environmental Analysis Branch
NC Department of Transportation
From: Nicole Thomson
Transportation Permitting
NC Division of Water Quality
Subject: Comments on Various Bridge Replacements, B-4415, B4428, B-4413, B-4416 and B-
4417 in Beaufort County,
B-4604 in Pitt County,
B-4531 and B-4533 in Greene County,
B-4468, B4570 and B-4565 in Lenoir County
In reply to your correspondence dated October 24, 2005 (received October 28, 2005) in which you
requested comments for the referenced projects, the NC Division of Water Quality has the following
comments:
L ProiectAvecific Comments
B-4415 Bridge No. 21 over Pungo Creek, Beaufort Co.
1. Pungo Creek are class SC; NSW waters of the State. DWQ is very concerned with sedimentation
and erosion impacts that could result from this project. DWQ recommends that highly protective
sedimentation and erosion control BMPs be implemented to reduce the risk of nutrient runoff to
Pungo Creek. DWQ requests that road design plans provide treatment of the storm water runoff
through best management practices as detailed in Best Management Practices for the Protection
of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A NCAC 2H .1006.
2. This project is within the Tar-Pamlico River Basin. Riparian buffer impacts should be avoided
and minimized to the greatest extent possible. Refer to 15A NCAC 2B .0259 for a table of
allowable uses.
B-4428 Bridge No. 140 over Canal UT to Pantexo Creek, Beaufort Co.
1. Canal UT to Pantego Creek are class C; Sw; NSW waters of the State. DWQ is very concerned
with sedimentation and erosion impacts that could result from this project. DWQ recommends
that highly protective sedimentation and erosion control BMPs be implemented to reduce the risk
of nutrient runoff to Canal UT to Pantego Creek. DWQ requests that road design plans provide
treatment of the storm water runoff through best management practices as detailed in Best
Management Practices for the Protection of Surface Waters. Refer to 15A NCAC 2B .0224(2)
and 15A NCAC 2H. 1006.
One
N hCarolina
Transportation Permitting Unit NawrW111
1650 Mail Service Center, Raleigh, North Carolina 27699.1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / Internet: htto://h2o.enr.state.nc.us/ncwetlands
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
2. This project is within the Tar-Pamlico River Basin. Riparian buffer impacts should be avoided
and minimized to the greatest extent possible. Refer to 15A NCAC 2B .0259 for a table of
allowable uses.
B-4413 Bridge No. 51 over Broad Creek, Beaufort Co.
1. Broad Creek are class SC; NSW waters of the State. DWQ is very concerned with sedimentation
and erosion impacts that could result from this project. DWQ recommends that highly protective
sedimentation and erosion control BMPs be implemented to reduce the risk of nutrient runoff to
Broad Creek. DWQ requests that road design plans provide treatment of the storm water runoff
through best management practices as detailed in Best Management Practices for the Protection
of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A NCAC 2H .1006.
2. This project is within the Tar-Pamlico River Basin. Riparian buffer impacts should be avoided
and minimized to the greatest extent possible. Refer to 15A NCAC 2B .0259 for a table of
allowable uses.
B-4417 Bridge No. 59 over Jack Creek, Beaufort Co.
1. Jack Creek are class SC; NSW waters of the State. DWQ is very concerned with sedimentation
and erosion impacts that could result from this project. DWQ recommends that highly protective
sedimentation and erosion control BMPs be implemented to reduce the risk of nutrient runoff to
Jack Creek. DWQ requests that road design plans provide treatment of the storm water runoff
through best management practices as detailed in Best Management Practices for the Protection
of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A NCAC 2H. 1006.
2. This project is within the Tar-Pamlico River Basin. Riparian buffer impacts should be avoided
and minimized to the greatest extent possible. Refer to 15A NCAC 2B .0259 for a table of
allowable uses.
B-4416 Bridge No. 76 over C & N Railway, Beaufort Co.
There is no stream feature present at this site. DWQ has no specific comments regarding this project.
B-4604 Bridge No. 13 over Indian Wells Swamp, Pitt Co.
1. Indian Wells Swamp are class C; Sw; NSW waters of the State. DWQ is very concerned with
sedimentation and erosion impacts that could result from this project. DWQ recommends that
highly protective sedimentation and erosion control BMPs be implemented to reduce the risk of
nutrient runoff to Indian Wells Swamp. DWQ requests that road design plans provide treatment
of the storm water runoff through best management practices as detailed in Best Management
Practices for the Protection of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A
NCAC 2H. 1006.
This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
B-4531 Bridge No 36 over Little Contentnea Creek, Greene Co.
1. Little Contentnea Creek are class C; Sw; NSW waters of the State. Little Contentnea Creek is on
the 303(d) list for impaired use for aquatic life due to impaired biological integrity and low
dissolved oxygen. DWQ is very concerned with sedimentation and erosion impacts that could
result from this project. DWQ recommends that the most protective sedimentation and erosion
control BMPs be implemented to reduce the risk of nutrient runoff to Little Contentnea Creek.
DWQ requests that road design plans provide treatment of the storm water runoff through best
management practices as detailed in Best Management Practices for the Protection of Surface
Waters. Refer to 15A NCAC 2B .0224(2) and 15A NCAC 2H .1006.
2. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
B-4533 Bridge No. 48 over Wheat Swamp Creek, Greene Co.
1. Wheat Swamp Creek are class C; Sw; NSW waters of the State. DWQ is very concerned with
sedimentation and erosion impacts that could result from this project. DWQ recommends that
highly protective sedimentation and erosion control BMPs be implemented to reduce the risk of
nutrient runoff to Wheat Swamp Creek. DWQ requests that road design plans provide treatment
of the storm water runoff through best management practices as detailed in Best Management
Practices for the Protection of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A
NCAC 2H. 1006.
2. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
B-4568 Bridge No. 67 over Falling Creek, Lenoir Co.
1. Falling Creek are class C; Sw; NSW waters of the State. DWQ is very concerned with
sedimentation and erosion impacts that could result from this project. DWQ recommends that
highly protective sedimentation and erosion control BMPs be implemented to reduce the risk of
nutrient runoff to Falling Creek. DWQ requests that road design plans provide treatment of the
storm water runoff through best management practices as detailed in Best Management Practices
for the Protection of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A NCAC 2H
.1006.
2. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
B-4570 Bridge No. 79 over Gum Swamp Creek, Lenoir Co.
1. Gum Swamp Creek are class C; Sw; NSW waters of the State. DWQ is very concerned with
sedimentation and erosion impacts that could result from this project. DWQ recommends that
highly protective sedimentation and erosion control BMPs be implemented to reduce the risk of
nutrient runoff to Gum Swamp Creek. DWQ requests that road design plans provide treatment of
the storm water runoff through best management practices as detailed in Best Management
Practices for the Protection of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A
NCAC 2H. 1006.
2. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
B-4565 Bridges No. 42 and 43 over Neuse River, Lenoir Co.
1. Neuse River are class C; NSW waters of the State. DWQ is very concerned with sedimentation
and erosion impacts that could result from this project. DWQ recommends that highly protective
sedimentation and erosion control BMPs be implemented to reduce the risk of nutrient runoff to
Neuse River. DWQ requests that road design plans provide treatment of the storm water runoff
through best management practices as detailed in Best Management Practices for the Protection
of Surface Waters. Refer to 15A NCAC 2B .0224(2) and 15A NCAC 2H. 1006.
2. This project is within the Neuse River Basin. Riparian buffer impacts should be avoided and
minimized to the greatest extent possible. Refer to 15A NCAC 2B .0233 for a table of allowable
uses.
A General Comments Regarding Bride Replacement Proiects
1. If corrugated metal pipe arches, reinforced concrete pipes, or concrete box culverts are used to replace
the bridge, then DWQ recommends the use of Nationwide Permit No. 14 rather than Nationwide
Permit 23.
2. If the old bridge is removed, no discharge of bridge material into surface waters is preferred. Strict
adherence the Corps of Engineers guidelines for bridge demolition will be a condition of the 401
Water Quality Certification.
3. DWQ prefers spanning structures. Spanning structures usually do not require work within the stream
and do not require stream channel realignment. The horizontal and vertical clearances provided by
bridges allows for human and wildlife passage beneath the structure, does not block fish passage, and
does not block navigation by canoeists and boaters.
4. Bridge deck drains should not discharge directly into the stream; stormwater should be directed
across the bridge and pre-treated through site-appropriate means (grassed swales, pre-formed scour
holes, vegetated buffers, etc.) before entering the stream. Please refer to NCDOT Best Management
Practices for the Protection of Surface Waters.
5. Live concrete should not be allowed to contact the water in or entering into the stream. Concrete is
mostly made up of lime (calcium carbonate) and when in a dry or wet state (not hardened) calcium
carbonate is very soluble in water and has a pH of approximately 12. In an unhardened state concrete
or cement will change the pH of fresh water to very basic and will cause fish and other
macroinvertebrate kills.
6. If possible, bridge supports (bents) should not be placed in the stream.
7. DWQ prefers offsite detours where possible.
8. If temporary access roads or detours are constructed, they should be removed back to original ground
elevations immediately upon the completion of the project. Disturbed areas should be seeded or
mulched to stabilize the soil and native tree species should be planted with a spacing of not more than
10'x10'. If possible, when using temporary structures the area should be cleared but not grubbed.
Clearing the area with chain saws, mowers, bush-hogs, or other mechanized equipment and leaving
the stumps and root mat intact, allows the area to re-vegetate naturally and minimizes disturbed soil.
9. A clear bank (rip rap-free) area of at least 10 feet should remain on each side of the steam underneath
the bridge.
10. Sedimentation and erosion control measures sufficient to protect water resources must be
implemented prior to any ground disturbing activities. Structures should be maintained regularly,
especially following rainfall events.
11. Bare soil should be stabilized through vegetation or other means as quickly as feasible to prevent
sedimentation of water resources.
12. All work in or adjacent to stream waters should be conducted in a dry work area. Sandbags, rock
berms, cofferdams, or other diversion structures should be used where possible to prevent excavation
in flowing water.
13. Heavy equipment should be operated from the bank rather than in stream channels in order to
minimize sedimentation and reduce the likelihood of introducing other pollutants into streams. This
equipment should be inspected daily and maintained to prevent contamination of surface waters from
leaking fuels, lubricants, hydraulic fluids, or other toxic materials.
III General Comments if Renlaciniz the Bridge with a Culvert
1. The culvert must be designed to allow for aquatic life and fish passage. Generally, the culvert or pipe
invert should be buried at least 1 foot below the natural streambed (measured from the natural
thalweg depth). If multiple barrels are required, barrels other than the base flow barrel(s) should be
placed on or near stream bankfull or floodplain bench elevation (similar to Lyonsfield design). These
should be reconnected to floodplain benches as appropriate. This may be accomplished by utilizing
sills on the upstream end to restrict or divert flow to the base flow barrel(s). Sufficient water depth
should be provided in the base flow barrel during low flows to accommodate fish movement. If
culverts are longer than 40-50 linear feet, alternating or notched baffles should be installed in a
manner that mimics existing stream pattern. This should enhance aquatic life passage: 1) by
depositing sediments in the barrel, 2) by maintaining channel depth and flow regimes, and 3) by
providing resting places for fish and other aquatic organisms. In essence, the base flow barrel(s)
should provide a continuum of water depth and channel width without substantial modifications of
velocity.
2. If multiple pipes or cells are used, at least one pipe or box should be designed to remain dry during
normal flows to allow for wildlife passage.
3. Culverts or pipes should be situated along the existing channel alignment whenever possible to avoid
channel realignment. Widening the stream channel should be avoided. Stream channel widening at
the inlet or outlet end of structures typically decreases water velocity causing sediment deposition that
requires increased maintenance and disrupts aquatic life passage.
4. Riprap should not be placed in the active thalweg channel or placed in the streambed in a manner that
precludes aquatic life passage. Bioengineering boulders or structures should be professionally
designed, sized, and installed.
In most cases, we prefer the replacement of the existing structure at the same location with road closure.
If road closure is not feasible, a temporary detour should be designed and located to avoid wetland
impacts, minimize the need for clearing and to avoid destabilizing stream banks. If the structure will be
on a new alignment, the old structure should be removed and the approach fills removed from the 100-
year floodplain. Approach fills should be removed down to the natural ground elevation. The area
should be stabilized with grass and planted with native tree species. Tall fescue should not be used in
riparian areas. If the area that is reclaimed was previously wetlands, NCDOT should restore the area to
wetlands. If successful, the site may be used as wetland mitigation for the subject project or other
projects in the watershed.
Thank you for requesting our input at this time. The DOT is reminded that issuance of a 401 Water
Quality Certification requires that appropriate measures be instituted to ensure that water quality
standards are met and designated uses are not degraded or lost. If you have any questions or require
additional information, please contact Nicole Thomson at [phone].
cc: Mr. Bill Biddlecomb, US Army Corps of Engineers, Washington Field Office
Mr. Gary Jordan, USFWS
Mr. Travis Wilson, NCWRC
Mr. Steve Sollod, NC DCM
Mr. Garcy Ward, NCDWQ Washington Regional Office
Central Files
File Copy
CACorrespondence\Scoping Comments\B-4415, 4428, 4413, 4417, Beaufort co. etc.doc
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
November 3, 2005
Marie Sutton
North Carolina Department of Transportation
Project Development and Environmental Analysis
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Ms. Sutton:
This letter is in response to your request for comments from the U.S. Fish and Wildlife Service (Service)
on the potential environmental effects of the proposed replacement of Bridge No. 51 on US 264 over
Broad Creek, Beaufort County, North Carolina (TIP No. B-4413). These comments provide scoping
information in accordance with provisions of the Fish and Wildlife Coordination Act (16 U.S.C. 661-
667d) and section 7 of the Endangered Species Act (ESA) of 1973, as amended (16 U.S.C. 1531-1543).
For bridge replacement projects, the Service recommends the following general conservation measures to
avoid or minimize environmental impacts to fish and wildlife resources:
I . Wetland, forest and designated riparian buffer impacts should be avoided and minimized to the
maximum extent practical;
2. If unavoidable wetland or stream impacts are proposed, a plan for compensatory mitigation to
offset unavoidable impacts should be provided early in the planning process. Opportunities to
protect mitigation areas in perpetuity via conservation easements, land trusts or by other means
should be explored at the outset;
3. Off-site detours should be used rather than construction of temporary, on-site bridges. For
projects requiring an on-site detour in wetlands or open water, such detours should be aligned
along the side of the existing structure which has the least and/or least quality of fish and wildlife
habitat. At the completion of construction, the detour area should be entirely removed and the
impacted areas be planted with appropriate vegetation, including trees if necessary;
4. Wherever appropriate, construction in sensitive areas should occur outside fish spawning and
migratory bird nesting seasons. In waterways that may serve as travel corridors for fish, in-water
work should be avoided during moratorium periods associated with migration, spawning and
sensitive pre-adult life stages. The general moratorium period for anadromous fish is February 15
- June 30;
New bridges should be long enough to allow for sufficient wildlife passage along stream
corridors;
6. Best Management Practices (BMP) for Protection 01'Surfacc Waters should be implemented;
7. Bridge designs should include provisions for roadbed and deck drainage to flow through a
vegetated buffer prior to reaching the affected stream. This buffer should be large enough to
alleviate any potential effects from run-off of storm water and pollutants;
8. The bridge designs should not alter the natural stream and stream-bank morphology or impede
fish passage. To the extent possible, piers and bents should be placed outside the bank-full width
of the stream;
9. Bridges and approaches should be designed to avoid any fill that will result in damming or
constriction of the channel or flood plain. If spanning the flood plain is not feasible, culverts
should be installed in the flood plain portion of the approach to restore some of the hydrological
functions of the flood plain and reduce high velocities of flood waters within the affected area.
Section 7(a)(2) of the Endangered Species Act requires that all federal action agencies (or their designated
non-federal representatives), in consultation with the Service, insure that any action federally authorized,
funded, or carried out by such agencies is not likely to jeopardize the continued existence of any
federally-listed threatened or endangered species. A biological assessment/evaluation may be prepared to
fulfill the section 7(a)(2) requirement and will expedite the consultation process. To assist you, a county-
by-county list of federally protected species known to occur in North Carolina and information on their
life histories and habitats can be found on our web page at httn://nc-cs.fws.gov/es/count?html .
The North Carolina Natural Heritage Program (NCNHP) database indicates an occurrence of the federally
threatened bald eagle (Hallaeelus leucocenhalus) less than two miles to the southeast of the project site.
The use of the NCNHP data should not be substituted for actual field surveys if suitable habitat for any
species listed for Beaufort County occurs near the project site. The NCNHP database only indicates the
presence of known occurrences of listed species and does not necessarily mean that such species are not
present. It may simply mean that the area has not been surveyed. If suitable habitat occurs within the
project vicinity for any listed species, surveys should be conducted to determine presence or absence of
the Species.
if you determine that the proposed action may affect (i.e., likely to adversely affect or not likely to
adversely affect) a listed species, you should notify this office with your determination, the results of your
surveys, survey methodologies, and an analysis of the effects of the action on listed species, including
consideration of direct, indirect, and cumulative effects, before conducting any activities that might affect
the species. If you determine that the proposed action will have no effect (i.e., no beneficial or adverse,
direct or indirect effect) on listed species, then you are not required to contact our office for concurrence.
We reserve the right to review any federal permits that may be required for this project, at the public
notice stage. Therefore, it is important that resource agency coordination occur early in the planning
process in order to resolve any conflicts that may arise and minimize delays in project implementation. In
addition to the above guidance, we recommend that the environmental documentation for this project
include the following in sufficient detail to facilitate a thorough review of the action:
1. A clearly defined and detailed purpose and need for the proposed project;
2. A description of the proposed action with an analysis of all alternatives being considered,
including the "no action" alternative;
A description of the fish and wildlife resources, and their habitats, within the project impact area
that may be directly or indirectly affected,
4. The extent and acreage of waters of the U.S., including wetlands, that are to be impacted by
filling, dredging, clearing, ditching, or draining. Acres of wetland impact should be
differentiated by habitat type based on the wetland classification scheme of the National
Wetlands Inventory (NWI). Wetland boundaries should be determined by using the 1987 Corps
of Engineers Wetlands Delineation Manual and verified by the U.S. Army Corps of Engineers;
5. The anticipated environmental impacts, both temporary and permanent, that would be likely to
occur as a direct result of the proposed project. The assessment should also include the extent to
which the proposed project would result in secondary impacts to natural resources, and how this
and similar projects contribute to cumulative adverse effects;
6. Design features and construction techniques which would be employed to avoid or minimize
impacts to fish and wildlife resources, both direct and indirect, and including fragmentation and
direct loss of habitat;
7. If unavoidable wetland or stream impacts are proposed, project planning should include a
compensatory mitigation plan for offsetting the unavoidable impacts.
The Service appreciates the opportunity to comment on this project. Please continue to advise us during
the progression of the planning process, including your official determination of the impacts of this
project. If you have any questions regarding our response, please contact Mr. Gary Jordan at (919) 856-
4520, cxt. 32.
(ie Pete B 'amin
Ecological Services Supervisor
cc: William Wescott, USACE, Washington, NC
Nicole Thomson/6444, r een, NCDWQ, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
Chris Militscher, USEPA, Raleigh, NC