20110023_Other Agency Comments_20081016

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® North Carolina Wildlife Resources Commission
MEMORANDUM
TO Melba McGee
Office of Legislative and Intergovernmental Affairs, DENR
FROM Travis Wilson, Highway Project Coordinator
Habitat Conservation Program y
DATE October 16, 2008
SUBJECT North Carolina Department of Transportation (NCDOT) Finial Environmental
Impact Statement (FEIS) and Draft Section 4(f) Evaluation for the proposed
replacement of Herbert C Bonner Bridge, in Dare County, North Carolina TIP
No B-2500 SCH Project No 09-0078
Staff biologists with the N C Wildlife Resources Commission have reviewed the subject
FEIS and are familiar with habitat values in the project area The purpose of this review was to
assess project impacts to fish and wildlife resources Our comments are provided in accordance
with certain provisions of the National Environmental Policy Act (42 U S C 4332(2)(c)) and the
Fish and Wildlife Coordination Act (48 Stat 401, as amended, 16 U S C 661-667d)
NCDOT proposes to replace the Herbert C Bonner Bridge across Oregon Inlet in
conjunction with addressing problematic areas located on NC 12 from the southern terminus of
the existing bridge to the community of Rodanthe The FEIS identifies the preferred alternative
as the Phased Approach/Rodanthe Bridge Alternative The preferred alternative proposes
maintaining NC 12 within the existing easement by constructing bridges as needed in multiple
phases, as well as replacing the bridge over Oregon Inlet parallel to the existing structure
The phased approach alternative has been promoted as an alternative that will allow barrier
island processes to take place by elevating the roadway and permitting the shoreline to progress
inland while "passing" underneath the bridge structure We remain concerned with the
uncertainty of the impacts associated with an elevated roadway located waterward of the dune
line These concerns are outlined in earlier comments dated March 16, 2007 More specifically
Mailing Address- Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]
.
Bonner Bridge Page 2 10/16/2008
the Indirect and Cumulative Impact (ICI) assessment does not address this topic It is necessary
to understand, to the greatest degree possible, the situation of the roadway to the shoreline with
the formation of new inlets Furthermore the ICI does not fully address the extent of indirect
impacts to wildlife associated with the migration of the shoreline toward the elevated structures
In addition, section 2 10 2 5 states " after the issuance of the Record of Decision for this
project, NCDOT will confine future NC 12 maintenance to the existing NC 12 easement "
Further in this section it is then stated "Availability of funds recognizes that future funding
analyses indicate that funding availability will continue to limit how much can be built at one
time and the need for phasing " Both philosophies are not possible If beach erosion is
accelerated or funding continues to be inadequate, the only option will likely be hardening the
shoreline and therefore significantly impacting habitat within the project area
The document adequately address potential impacts and conservation measures for the
construction of the preferred alternative, however several question remain from our March 16,
2007 comments on the phased approach alternatives, as well as the FEIS We anticipate
continued participation in the 404/NEPA Merger process for this project Thank you for the
opportunity to comment If we can be of any further assistance please call me at [phone]
cc Gary Jordan, U S Fish and Wildlife Service, Raleigh
Brian Wrenn, DWQ, Raleigh
Bill Biddlecome, USAGE, Raleigh
Chris Militscher, EPA
Cathy Brittmgham, DCM