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North Carolina Department of Environment and Natural Resources
Division of Parks and Recreation
Michael F. Easley, Governor William G. Ross Jr., Secretary Lewis R, Ledford, Director
March 10, 2005
Ms. Sue Homew d
NC DENR 'nston Salem Regional Office
Divisi f Water Quality, Water Quality Section
~'SWaughtown Street
Winston Salem, NC 27107
Dear Ms. Homewood:
The North Carolina Division of Parks and Recreation (Division) appreciates the opportunity to
comment on the proposed paving of SR 1127 (Shawnee Road). Beach Creek Bog, recently
protected by the North Carolina Division of Parks and Recreation for its unique characteristics, is
adjacent to the proposed paving project. Beech Creek Bog is considered nationally significant
and represents the first example of a southern Appalachian bog in the State Parks system. Unlike
northern bogs of glacial origin, southern Appalachian bogs form in poorly drained depressions or
on gentle slopes. Beech Creek Bog is noteworthy because both the bog itself and the
surrounding watershed show very little disturbance and contain natural communities of excellent
quality. There are a number of rare and threatened species that inhabit the bog and associated
uplands including Northern Saw-whet Owl (Aegolius acadicus), Alder Flycatcher (Empidonax
alnorum), Northern Long-eared Myotis (Myotis Septentrionalis), Least Weasel (Mustela nivalis),
Gray's Lily (Cilium grayi), Bog clubmoss (Lycopodiella inundata) and a number of rare
mollusks. The potential for impacts from the paving of SR 1127 on this unique bog complex has
led to the submission of these comments.
The Division's preferred alternative for the project would be no paving at all (keeping the entire
stretch of Shawnee Road adjacent to the bog as a "gap") since this option would result in no
change in the current volume and chemistry of runoff. In addition, this option would also
alleviate some of the secondary and commutative impact concerns associated with this project.
This option would also eliminate the use of de-icing chemicals along the stretch of road adjacent
to the bog.
1615 Mail Service Center, Raleigh, North Carolina 27699-1615 One
Phone: 919-733-4181 • FAX: 919-715-3085 • Internet: www.ncsparks.net NorthCarolina
An Equal Opportunity • Affirmative Action Employer - 50 % Recycled • 10 % Post Consumer Paper ~atura!!t~
Mr. Ms. Homewood
Page 2
March 10, 2005
Our second alternative would be to design the paving of SR 1127 to reduce the impact of de-
icing material on the Bog. Areas where splash or spray from salted roads can be transported
through air and impact sensitive vegetation. In addition, wetlands that directly adjoin roadway
ditches and that receive runoff in the form of salty snowmelt waters are also potential
management concerns. Protection of the bog is feasible attained by designing the paved section
of the road to minimize runoff directed towards the bog. The Division suggests crowning the
straight section of the road adjacent to the bog (see section A in the enclosed map). Crowning of
this section will allow sheet flow on half the road adjacent to the bog and ditching on the other
half of the road. The ditch will be discharged at its current location (located at the intersection of
sections A and B on the enclosed map)_ The next section of road should be super-elevated away
from the bog (see section B). The super elevated section should be ditched and the discharge
-point should be at the end of this section (see point C ~on the enclosed map). This discharge point
allows for the maximum distance between the discharge of stormwater and the bog.
We appreciate the Division of Water Quality's efforts to protect this unique bog community that
supports a "globally rare" ecosystem. If you have further questions regarding these comments
please don't hesitate to call me at (919) 715-8711
Sincerely,
. / ...-.-,~U~--.-
Brian L. Strong
Resource Management Specialis
cc: Heath Slaughter, DOT Environmental Officer
Walt Gravley, West District Superintendent
Larry Trivette, Elk Knob State Natural Area Superintendent
Scott Pohlman, NC Natural Heritage Program
Enclosure
February 2005
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Beech Creek Bog
State Natural Area N
Road Pavin
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