BR-0102_84037_Stokes_NCWRC comments

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n North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
September 23, 2022
Daniel Dagenhart, PE
NCDOT Division 9 Bridge Program Manager
373 Silas Creek Parkway
Winston-Salem, NC 27127
Subject Scoping Comments on Replacement of Bridge No. 84037 on NC 268 (Lynchburg Road)
over Big Creek, Stokes County. TIP BR-0102
Dear Mr. Dagenhart,
Division 9 of the North Carolina Department of Transportation (NCDOT) invited comments from the
North Carolina Wildlife Resources Commission (NCWRC) on the subject bridge replacement project.
NCWRC biologists reviewed the project information and are familiar with the fish and wildlife resources
in the area. I also visited the project site on September 9, 2022. The following comments are offered to
help conserve wildlife resources affected by the project and to promote wildlife -based recreation in
accordance with the applicable provisions of the state and federal Environmental Policy Acts (G.S. 113A-
lthrough 113-10; 1 NCAC 25 and 42 U.S.C. 4332(2)(c), respectively), the Clean Water Act of 1977 (33
U.S.C. 466 et seq.) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-
667d).
General Comments
NCWRC standard recommendations for bridge and culvert replacement projects of this scope include:
1. New bridges or other channel spanning structures are recommended because they typically require
minimal if any stream impacts. The clearances of bridges allow for human access and wildlife
passage, fish passage, and navigation by boaters. Unlike bridges, culverts can prove difficult to
dewater during construction, which can lead to extended periods of channel instability and erosion.
2. Bridge deck drains should not discharge directly into streams.
3. Live concrete should not be allowed to contact water in or discharging to streams.
4. If possible, bridge supports (bents) should not be placed in stream channels.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be implemented and maintained during construction. Matting used in
riparian areas should not contain nylon mesh because it entangles and kills wildlife. Coir matting
should be used on unstable stream banks that are steep or susceptible to high water and matting
should be securely anchored with wooden stakes according to NCDOT specifications.
6. Temporary detours and access roads should be designed and located to avoid wetland impacts, to
minimize clearing, and avoid destabilizing stream banks. Tree stumps and root mats should be left
where possible under and along temporary access roads to limit streambank disturbance and promote
regrowth of vegetation. Temporary fills should be removed to original ground elevations upon the
completion of the project. Disturbed areas should be seeded, or mulched, and native tree species
should be planted with a spacing of 10'x10'.
7. A clear strip of streambank (rip rap free) of 10 feet in width should remain on each side of the
channel underneath bridges to facilitate wildlife passage. Smaller widths are also beneficial where
there are narrow abutment setbacks. Alternatively, a "wildlife path" can be constructed with a top -
dressing of finer stone if full bank plating is required. These measures should also incorporate any
ditch line plating.
8. NCDOT biologists should be notified about streams that contain threatened or endangered species.
Special measures to protect these sensitive species may be required. NCDOT should also contact the
U.S. Fish and Wildlife Service for information on requirements of the Endangered Species Act as it
relates to the project.
9. All work in or adjacent to streams should be conducted in dry work areas. Sandbags, cofferdams, or
other clean diversion structures should be used where possible to avoid excavation in flowing water.
10. Heavy equipment should be operated from the banks rather than in stream channels to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams.
11. Only clean, sediment -free rock should be used as temporary fill (causeways) and fill material should
be removed with minimal disturbance of the natural stream bottom when construction is completed.
12. During geotechnical investigations, equipment should be inspected daily and maintained to prevent
contamination of surface waters from leaking fuels, lubricants, and hydraulic fluids.
The following recommendations apply to corrugated pipes, reinforced concrete pipes, or concrete box
culvert structures:
1. Culverts and pipes must be designed to allow for aquatic life passage in accordance with current
NCDOT Guidelines for Drainage Studies and Hydraulic Design. This typically includes burial of a
single low flow barrel at least 1 foot below the natural streambed and backfilling with native material.
If multiple barrels are required, then the high flow barrel(s) should be placed on or near a bankfull
elevation. These "flood" barrels should be reconnected to benches and include sills on the upstream
ends to restrict or divert base flow into the low barrel. Barrels with sills should be filled with
sediment to avoid standing water. If rip rap is used for backfllling, then it should also be topped with
native or other finer material to facilitate wildlife passage. In accordance with NCDOT Guidelines

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for Drainage Studies and Hydraulic Design, alternating or notched baffles should typically be
installed in base flow culverts that are steep or longer than 40-50 linear feet in a manner that mimics
the existing stream flow pattern and profile.
2. Riprap should be minimized on banks and avoided on streambeds except where bed scour may be
expected. Rip rap placed on the streambed should be embedded or "keyed -in" to prevent or shorten
the duration of subsurface streamflow.
3. If multiple pipes or cells are used, then at least one pipe or box should be designed to remain dry
during normal flows to allow for wildlife passage.
4. Culverts or pipes should be aligned with the existing channel alignment whenever possible. Channel
widening should be avoided. Stream channel widening at the inlet or outlet end of structures typically
decreases water velocity, disrupts aquatic life passage, and causes sediment deposition that requires
increased maintenance.
Replacement of the existing bridge or culvert in the same location with road closure is typically
recommended to minimize impacts. If road closure is not feasible, then a temporary detour should be
designed and located to avoid wetland impacts, minimize the need for clearing, and avoid destabilizing
stream banks. If the structure will be on a new alignment, then the old structure and the approach fills
should be 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. NCDOT
should restore the area to wetlands if the area reclaimed was previously wetlands.
Project -Specific Comments
This project will affect aquatic habitat that supports a high diversity of species including, in part, notched
rainbow mussel (State Threatened, Villosa constricta), riverweed darter (State SR Etheostoma
podostemoneand), and bigeye jumprock (State Threatened, Moxostoma ariommum). This creek also likely
supports James spinymussel (US Endangered Pleurobema collina). The confluence of Big Creek and the Dan
River is only about 0.1 mile downstream of the bridge. The river has the highest rating for natural areas
(exceptional) from the NC Natural Heritage program due to its support of James spinymussel and several
other rare aquatic species. The Dan River was also designated by the NC General Assembly as a state trail in
2021.
Due to the high diversity of rare and sensitive species in this watershed, the NCWRC requests that NCDOT
follow the Design Standards for Sensitive Watersheds (15A NCAC 04B .0124) during the design and
construction of this project. Also, the NCWRC desires the opportunity to relocate mussels from the project
footprint, as deemed necessary, if NCDOT would please advise the NCWRC reasonably in advance of
construction, preferably at least two months. My contact information can be used in any contract notes,
"green sheet commitments", or other project documentation to help alert staffs and contractors about
coordination needs.
The NCWRC is interested in developing waterway access areas along the Dan River. Access near bridge
840037 was pursued but was ultimately not provided or possible at 84017 on NC 89 when it was replaced

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several years ago. While an access on 84037 would not be ideal as a take-out for boaters using the Dan River,
it could nonetheless have value particularly as a put -in location. And, as currently proposed, 840037 will be
shifted and thus potentially result in available right-of-way. Steep high banks could limit the ability to
develop access here. Nevertheless, the NCWRC respectfully requests the opportunity to explore this
possibility further in coordination with the NCDOT.
Tricolor bats (Perimyotis subflavis) have been documented in the area and other bat species, including the
northern long-eared bat (US Threatened Myotis septentrionalis), may occur in the region as well. Evidence of
bat usage of the bridge was not noted during my field visit, but a more thorough survey is recommended. The
NCWRC supports efforts to minimize riparian tree clearing and avoidance of clearing during active bat
seasons as may be subscribed for the project through Endangered Species Act Section 7 consultation.
Thank you for the opportunity to review and provide comments on this project. Please contact me at
david.mchenrykncwildlife.org or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
ec: Amy Euliss, NCDOT Division 9 PDEA Engineer
Lauren Wilson, US Fish and Wildlife Service
Dave Wanucha, NCDEQ Division of Water Resources
Andy Williams, US Army Corps of Engineers
Joanna Salvucci, Three Oaks Engineering