20240261 Ver 1_BR-0251_Madison 67 Application_DWR 20240261v1_NCWRC Comments_20240226

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
February 26, 2024
Lori Beckwith
U.S. Army Corps of Engineers, Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
SUBJECT: Comments on Replacement of Madison Bridges 72, 74, and 381. BR-0251
DWR 20240261 ver.1
Dear Ms. Beckwith,
The North Carolina Department of Transportation (NCDOT) applied for a permit to replace the existing
timber bridges with similar structures on the same roadway alignments. This project will affect trout
waters. The North Carolina Wildlife Resources Commission's (NCWRC) comments are offered to help
conserve the wildlife resources affected by the project and to promote wildlife -based recreation in
accordance with 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).
Foster Creek (C Tr ORW) at Madison Bridge 72 and 74 supports naturally reproducing populations of
Rainbow Trout (Oncorhynchus mykiss). Big Laurel Creek (C Tr ORW) at Madison Bridge 381 is stocked
with trout by the NCWRC and supports some wild fish, however the trout moratorium has been waived
for recent bridge projects on this stream because trout spawning is believed to be limited. While trout
spawning may not be a concern, Eastern Hellbender (Cryptobranchus alleganiensis, NC Special Concern)
are found in Big Laurel Creek and the stream is also classified as ORW. The NCWRC would appreciate
being apprised of the construction schedule, so that the bridge area can be surveyed for hellbenders and
animals relocated as needed. A notice a few weeks before construction, or an invitation to any
preconstruction meeting, would be appreciated.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

BR-0251
Page 2 February 26, 2024
While these bridges are unlikely roosts for bats, there are records for bats including federally listed
species in the Big Laurel Creek watershed. Therefore, a pre -demolition bridge survey is recommended to
verify the absence of bats. Tree clearing should be avoided during active bat seasons and coordination
with the US Fish and Wildlife Service is recommended for listed species, when needed.
The NCWRC requests that the following conditions be included in authorizations to help conserve trout
and other aquatic resources that may be affected:
The January 1 to April 15 trout moratorium should be followed for Madison 72 and Madison 74
since construction has a reasonable potential to cause inadvertent sedimentation in trout spawning
habitat.
2. Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be adhered to for all bridges. Design Standards for Sensitive Waters
(15A NCAC 04B .0124) are recommended where practical with these bridge replacements
because waters with sensitive species will be affected.
3. In accordance with standard GC conditions, matting used in riparian areas should not contain
nylon mesh because it entangles and kills wildlife. Coir matting should be used on disturbed
stream banks that are steep or susceptible to high water. Matting should be anchored with
wooden stakes according to NCDOT specifications.
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 IO'x10'.
5. Heavy equipment needs to be well -maintained and concrete pouring needs to be closely
monitored to avoid and quickly mitigate fuel, fluid, or wet concrete losses in or near streams.
6. Sandbags, rock berms, cofferdams, or other adequately designed diversion structures should be
used where excavation or other periods of extended stream disturbance have the potential for
downstream sedimentation.
7. The natural dimension, pattern, and profiles of streams and the grades of wetlands should be
restored where temporarily impacted.
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at david.mchenrya,ncwildlife.org or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
cc: NCDEQ, DWR Laserfiche
Karina Clough, NCDOT Division 14 PDEA Engineer