2023-09-28_NCWRC Comments_BR-0250_Avery 149,Caldwell 252 and Watauga 231_Scoping

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n North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
September 28, 2023
Nick Pierce
Project Engineer
North Carolina Department of Transportation, Structures Management Unit
1581 Mail Service Center
Raleigh, NC 27699-1534
Subject Scoping Comments on Replacement of Avery Bridge 149, Watauga Bridge 231, and
Caldwell Bridge 252. BR-0250
Dear Nick,
The North Carolina Department of Transportation (NCDOT) invited comments on the subject bridge
replacements. These timber bridges will be replaced, in place, with comparable new timber structures.
The roads these bridges carry do not have outlets, so off -site detours are not possible. North Carolina
Wildlife Resources Commission (NCWRC) staff are familiar with the project areas. These comments are
offered to conserve wildlife resources affected by the projects 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).
Standard Comments (NOTE specific recommendations follow)
NCWRC standard recommendations for bridge replacement projects of this scope include:
1. Live concrete should not be allowed to contact water in or discharge to streams.
2. If possible, bridge supports (bents) should not be placed in stream channels.
3. 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.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

BR-0250 Page 2 September 28, 2023
4. 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'.
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.
6. 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.
7. 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.
8. 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.
Staged construction is recommended for timber bridge replacement to minimize the amount of stream
disturbance. Temporary detours 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.
Specific Comments
Avery Bridge 149
Horse Creek (WS-V Tr) supports naturally reproducing populations of Brown Trout (Salmo Trutta) and
Rainbow Trout (Salvelinus oncorhynchus). To protect trout spawning, adherence to the October 15 to
April 15 moratorium is recommended for stream and buffer disturbance for any permits that may be
required. Eastern Hellbender (Cryptobranchus alleganiensis, NC Special Concern) are found in the
North Toe River downstream of the bridge but are unlikely to be in Horse Creek. NWCRC biologists
intend to assess the habitat conditions near Avery 149 soon. In addition to standard recommendations,
erosion control measures under Design Standards in Sensitive Waters (see part (d) of 15A NCAC 04B
.0124) are encouraged in the project design and construction, as practical, to help ensure protection of
trout and aquatic habitats.
Watauga Bridges
Norris Fork (C Tr+) supports naturally reproducing populations of Brown Trout (Salmo Trutta) and
Brook Trout (Salvelinus fontinalis). To protect trout spawning, adherence to the October 15 to April 15
moratorium is recommended for stream and buffer disturbance for any permits that may be required.

BR-0250
Page 3 September 28, 2023
Kanawha Darter (Etheostoma kanawhae) and Tonguetied Minnow (Exoglossum laurae), both with
significantly rare status, are found in Meat Camp Creek downstream. In addition to standard
recommendations, erosion control measures under Design Standards in Sensitive Waters (see part (d) of
15A NCAC 04B .0124) are encouraged in the project design and construction, as practical, to help ensure
protection of trout and aquatic habitats.
Caldwell Bridge 252
UT Zacks Fork (C) does not support trout and so a spawning moratorium is unnecessary. Only standard
comments should be considered here.
Please contact me at david.mchenrygncwildlife.org or [phone] if you have any questions about
these comments. Thank you for the opportunity to review and comment on these projects. The NCWRC
looks forward to assisting as needed as the project develops further.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
Cc: Adam Archual, Gannett Fleming
Kevin Hining, NC Department of Transportation, Division 11 DEO