20231521 Ver 1_HB-0002 - Haywood County - NCWRC Scoping Comments_20231108

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
March 10, 2022
Michael Turchy
NCDOT Environmental Coordination and Permitting — Western Team Leader
Environmental Analysis Unit
1598 Mail Service Center
Raleigh, NC 27699-1598
Dear Mr. Turchy,
Subject Scoping Comments on Replacement of NCDOT Haywood Bridge No.s:
• 430248 and 430449 on I-40 over SR 1613 (Beaverdam Road), HB-0002
• 430239 on I-40 over SR 1550 (Incinerator Road), HB-0003
• 430243 on I-40 over NC 215/Champion Drive, HB-0004
• 4300205 and 430208 on I-40 over SR 1364 Coleman Mountain Road, HB-0005
• 430126 on I-74 Westbound Ramp over I-40, HB-0006
The North Carolina Wildlife Resources Commission (NCWRC) received the request from the North
Carolina Department of Transportation (NCDOT) for scoping comments on the subject bridge
replacements. I reviewed the information and visited several of the sites on March 9, 2022. Comments
from the NCWRC on the projects are offered in accordance with the applicable provisions of the state and
federal Environmental Policy Acts (G.S. 113A-I through 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).
Bat Potential
Recent surveys have identified bat roosting on several roadway structures in northern Haywood County.
Like the subject bridges, most of the structures were large bridges with concrete decks and typically,
though not always, over or near large water bodies. Observations ranged from individuals to groups of
big brown bats (Eptesicus fuscus) and gray bats (Myotis grisescens) and most recently an individual
Indiana bat (Myotis sodahst). The structures included, in part, I-40 bridge numbers 430142, 430159,
430183, and 430236, US 23/74 bridge numbers 4430155 and 430107, US 19 bridge number 430160, US
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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Haywood County
276 bridge numbers 430195/200 and 430186, and NC 215 bridge number 430445. Therefore, it is
possible that the proposed projects could have effects on bats that may be present, most notably due to
disturbance during seasonal roosting on the structure(s). To assess bat usage and reduce potential effects
of the projects on bats in general the NCWRC recommends incorporating the following measures into the
development and construction of the projects:
1) Surveys should be conducted or updated, as needed, of all bridges and use by listed bats or groups
of any species of bats coordinated further with USFWS and NCWRC staffs. Of the three bridges I
surveyed, only one (1-113-0005) appeared to have possible guano accumulation on a cap, but I
could not get close enough to the top of the interior bent to verify if this material may be
structural debris.
2) Clearing of suitable roost trees for widening or temporary detours should be avoided from April 1
to October 15 to protect Indiana bats (recently found on 430195 on US 276) and any other tree
roosting bats that may be in the area.
3) Direct illumination of riparian areas (e.g., Beaverdam Creek near HB-0002) should be avoided or
minimized as practical during spring -fall construction.
Wildlife Passage
Appreciable wildlife activity around HB-0004 and HB-0006 is not anticipated due to their proximity to
development or location in a confined interchange. On the site visits there was some evidence of wildlife
passage under 1-113-0005, and to a lesser extent under both HB-0002 and 1-113-0003. Only small mammal
tracks were noted. Current passage by wildlife under these bridges may be limited due to the high deck
noise, the adjoining roadways, low bridge heights near the end bents, and relatively narrow and steeply
sloped abutment fills.
Although wildlife use currently appears low at 1-113-0002, HB-0003, and 1-113-0005, these projects are
situated in more rural areas with nearby forested habitats that harbor wildlife. Increased harvest and
roadkill frequency on I-40 (personal observation) suggest that there is a growing population of whitetail
deer in the region. Moreover, the elk herd that was established in the Cataloochee Valley in the Great
Smoky Mountains National Park has been expanding its range, particularly into the Jonathon Creek and
Fines Creek watersheds near 1-113-0005. Tracking studies and anecdotal observations have documented
major seasonal movements by these elk, often traveling along roadways and as far as South Carolina.
Vehicle collisions with elk occur.
For the reasons above, the NCWRC recommends including design accommodations to facilitate wildlife
passage under the new structures and mitigate the habitat fragmentation from I-40. Potential future
widening of 1-40 (TIP No. 1-6054), which will presumably be factored into the sizing of some of the
structures, make it particularly relevant to evaluate and address wildlife passage mitigation and
opportunities with these projects.
Modern structures with higher barrier rails may inherently improve wildlife passage at the sites by
reducing the deck noise associated with the existing structures. New bridges are recommended for the

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Haywood County
replacements to maximize the area for wildlife passage either on benches situated on sloped abutments or
widened and unpaved shoulder extensions. If vertical abutments/MSE walls such as those being designed
for other currently developing I-40 bridge replacements are pursued, then they should be setback from
widened shoulder areas rather than effectively reduce the existing bridge spans. Other primary
considerations include avoiding rip rap -free "wildlife paths" under the bridges, or, where plating is
necessary, using smaller aggregate to "choke -out" the rip rap gaps. NCWRC would welcome an
opportunity to help NCDOT refine the bridge design and wildlife accommodation elements as warranted
as the projects develop further.
Stream Impact
There is a long structural plate culvert under I-40 immediately west of HB-0002 that aside from its last 10
feet or so appears to be in good condition. It is tar coated, and no bats were noted when I visited. Should
this culvert get maintained with the project, then we recommend that some rip rap get added to the outlet
to backwater the pipe, possibly by leaving a portion of any work pad that is used during pipe re -lining.
The pipe has a low slope and would likely pass aquatic life better if the existing small outlet perch was
addressed. Note that trout are not expected in the vicinity of this stream and so the NCWRC would waive
any trout moratorium requirement for permitted work there. Stream impacts do not appear relevant at
any of the other projects.
Standard Bridge Recommendations (partial)
In addition to considering the preceding specific comments, we recommend that the following partial list
of standard recommendations for bridge replacements below also be incorporated into the project where
possible to help conserve wildlife habitats.
1. Spanning structures are typically preferred over culverts. Spanning structures usually require no
or less work within the stream and do not require stream channel realignment. The horizontal and
vertical clearances provided by bridges allow for human and wildlife passage beneath the
structure and typically do not impede fish passage and navigation by canoeists and boaters.
Culverts often present more difficult and extended dewatering needs that lead to channel
instability and erosion during flooding.
2. Bridge supports (bents) should not be placed in the stream if possible.
3. 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. Leaving the stumps and root mats intact allows the area to revegetate naturally
and minimizes disturbed soil.
4. A clear bank (rip rap free) area of at least 10 feet should remain on each side of the stream
underneath the bridge to facilitate wildlife passage.
5. NCDOT should coordinate with the U.S. Fish and Wildlife Service for information on
requirements of the Endangered Species Act and possible implications for the project.

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Haywood County
6. All work in or adjacent to streams 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.
7. Heavy equipment should be operated from the bank rather than in stream channels to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams.
8. Only clean, sediment -free rock should be used as temporary fill (causeways) and fills should be
removed without excessive disturbance of the natural stream bottom when construction is completed.
9. Heavy equipment should be inspected daily and maintained to prevent contamination of surface
waters from leaking fuels, lubricants, hydraulic fluids, or other toxic materials.
10. Inter -agency field scoping often helps identify constructability, traffic control, and other site -specific
issues that can affect design, and correspondingly the impacts. Some issues may not be readily
identified in scoping or even later CFI reviews. NCWRC staff would welcome the opportunity to
participate in a field review of this project, as scheduling allows, if later deemed warranted by
NCDOT.
Please contact me at david.mchenrykncwildlife.org or [phone] if you have any questions about
these comments. Thank you for the opportunity to review and comment on these projects. We look
forward to assisting further and as needed as the projects develop.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
ec: Katherine Etchison, NCWRC
Holland Youngman, USFWS
Lauren Wilson, USFWS
Erin Cheely, NCDOT ECAP, EAU