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Home My WebLink About20090995 Ver 1_Information Letter_20091016® North Carolina Wildlife Resources Commission Gordon Myers, Executive Director September 25, 2009 Mr. Kevin S. Rose Environmental Compliance Specialist USDOT-Federal Highway Administration Eastern Federal Lands Highway Div. 21400 Ridgetop Circle Sterling, Virginia 20166-6511 RE: HFPP-15 (Project PRA-BLRI 2H13, J16), Blue Ridge Parkway, Pre-Construction Notification, Avery, Burke, Caldwell & Watauga Counties, DWQ No. 20090995 Dear Mr. Rose: This correspondence is in response to your letter of September 15, 2009 and the attached Pre- Construction Notification (PCN) concerning the referenced Blue Ridge Parkway (BRP) roadway improvements project. Biologists with the North Carolina Wildlife Resources Commission (NCWRC) are familiar with habitat values in the area. The NCWRC is authorized to comment and make recommendations which relate to the impacts of this project on fish and wildlife pursuant to Clean Water Act (CWA) of 1977, North Carolina Environmental Policy Act, US National Environmental Policy Act, Endangered Species Act (16 U. S. C. 1531-1543; 87 Stat 884), the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d) and/or Federal License of Water Resource Project Act (Federal Power Act-16 U.S.C. 791a et seq.) as applicable. The project includes milling and resurfacing a portion of the BRP between Milepost (MP) 298.6 and MP 317.5 (Section 2H & 2J). Various pavement improvement activities will be performed. Road shoulder, stone, concrete, drainage, guardrail, signage, re-striping and miscellaneous activities are indicated. Associated drainage activities will recondition (repair/replace) culverts, inlets, end-sections, headwalls and ditching. Please be advised that the US Army Corps of Engineers and the NC Division of Water Quality will receive copies (electronically) of this letter so that our comments and recommendations will be available for use by permitting agencies as applicable for CWA Section 404 Permits and Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721 Telephone: (919) 707-0220 • Fax: (919) 707-0028 i Blue Ridge Parkway Retrofits Page 2 September 25, 2009 CWA Section 401 Certifications. Based on our review of the CWA PCN application attached to your letter, the following streams, headwaters and fisheries can or will be affected by the project: Stream Classification Wild Trout Species Present • Boone Fork • Green Mountain Creek • Dixon Creek • Little Wilson Creek • Wilson Creek • Linn Cove Branch • Stack Rock Creek • Stacy Creek* • Camp Creek • Linville River • UT Linville River C-Trout, ORW C C C-Trout, ORW B-Trout, ORW B-Trout, ORW C-Trout, ORW C-Trout C C-Trout C-Trout (same as river) Brown, Rainbow None indicated None indicated Brook, Brown Brook, Brown, Rainbow Brook, Brown, Rainbow Brown Brown Brown Brown None indicated The project is indicated to affect 116.1 linear feet of stream, including 61.7 linear feet of Stacey Creek. Although direct impacts are not indicated for the other streams, project proponents should strive to protect downstream trout habitats from direct and indirect impacts. Listed and rare species issues do not appear to be relevant concerns since the footprint of the BRP will not be modified by this project. Based on our review of the submittal, we will not object to the project as proposed providing the following recommendations are followed: 1. Any instream work and land disturbance within the 25-foot trout buffer zone (intermittent and perennial waters) should be prohibited during the trout spawning season of October 15 through April 15 for streams supporting wild trout populations (as indicated above). This moratorium is necessary to protect the egg and fry stages of trout from off-site sedimentation and turbidity. (Note: Based on the information submitted, it appears that only Stacy Creek* and its trout buffers will be directly affected by the resurfacing project.) 2. When replacing culverts in CWA jurisdictional waters (to the maximum extent practicable) culverts 48" diameter or larger should be buried a foot into the streambed. Culverts less than 48" diameter should be buried to a depth equal to or greater than 20% their size to allow for aquatic life passage. These measurements should be based on natural thalweg depths. Aquatic life passage should be assured during low flow or drought conditions. Where practicable, riprap or rock used in channels should not interfere with aquatic life movement during low flow conditions. 3. As applicable for specific stream classifications, sediment and erosion control measures should adhere to the design standards for sensitive watersheds (15A NCAC 4B .0124). Dlire Ridge Parkway Retrofits Page 3 September 25, 2009 4. It is preferred that only autochthonous (native) plants be used for the project although annual oats, wheat or other annual grain plants may be used for quick growing "nursery" plantings or in disturbed pre-established manicured lawn areas. Disturbed streambanks should be replanted with autochthonous (native) plants like silky dogwood, rhododendron, dog hobble, mountain pepperbush, paw paw, red maple, silky willow, tag alder, black willow, sycamore, river birch, or other native woody species. 5. If any concrete will be used, work must be accomplished so that wet concrete does not contact stream water. 6. Heavy equipment should be operated from the bank rather than in the stream channel in order to minimize sedimentation and reduce the likelihood of introducing other pollutants into the stream. 7. Temporary or permanent native herbaceous vegetation should be established on all bare soils within any affected 25-foot trout buffer zones within five (5) days of ground disturbing activities to provide short term erosion control and long term site stabilization. 8. Natural fiber matting is recommended over straw mulch that can slip and plastic matting that can impinge and entrap small animals. Please be advised that we routinely recommend stormwater management for development projects, including parking lots and other impervious areas. Stormwater management should maintain, to the extent possible, pre development hydrograph conditions. Low Impact Development (LID) techniques are encouraged. LID measures and practices information can be found at www.lowimpactdevelopment.org, http://www.epa.gov/owow/nvs/lid/lidnatl.pdf and http://www.stormwatercenter.net/. Please visit the NCWRC website for additional insights and environmental concerns relative to secondary and cumulative development impacts (http•//www.newildlife.org/pg07 WildlifeSpeciesCon/pgM impacts.ydf). In addition, you may find http://www.nwf.org of interests as the National Wildlife Federation is involved with climate change issues that are indicated to affect people and wildlife. Thank you for the opportunity to review and comment on this project during the early planning stages. If you have any questions regarding these comments, please contact me at 336-769-9453. Sincerely, Ron Linville Habitat Conservation Coordinator E-copy: Steve Chapin, Liz Hair, USACOE-ARO Kevin Barnett, Linda Wiggs, DWQ-ARO Sue Homewood, Amy Euliss, DWQ-WSRO