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United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
January 23, 2002
Mr. William D. Gilmore, P.E., Manager
NCDOT
Project Development and Environmental Analysis Branch
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Mr. Gilmore:
Thank you for your letter of November 7, 2001, requesting information from the U.S. Fish and
Wildlife Service (Service) for the purpose of evaluating the potential environmental impacts of
the proposed widening of SR 1780 (Estes Drive) from SR 1772 (Greensboro Street) to NC 86,
Chapel Hill/Carrboro, Orange County, North Carolina (TIP No. U-2909). This report provides
scoping information and is provided in accordance with provisions of the Fish and Wildlife
Coordination Act (FWCA) (16 U.S.C. 661-667d) and section 7 of the Endangered Species Act
(ESA) of 1973, as amended (16 U.S.C. 1531-1543). This report also serves as initial scoping
comments to federal and state resource agencies for use in their permitting and/or certification
processes for this project.
The North Carolina Department of Transportation (NCDOT) proposes to widen Estes Drive from
SR 1780 to NC 86. There will be one stream crossing and one railroad crossing. Alternatives to
be investigated include 3-lane, 4-lane, and 5-lane divided, as well as a possible alternative to
utilize Williams Street in a "split-arterial" scenario. The following recommendations are
provided to assist you in your planning process and to facilitate a thorough and timely review of
the project.
Generally, the Service recommends that wetland impacts be avoided and minimized to the
maximum extent practical as outlined in Section 404 (b)(1) of the Clean Water Act Amendments
of 1977. In regard to avoidance and minimization of impacts, we recommend that proposed
highway projects be aligned along or adjacent to existing roadways, utility corridors, or
previously developed areas in order to minimize habitat fragmentation and encroachment. Areas
exhibiting high biodiversity or ecological value important to the watershed and region should be
avoided. Crossings of streams and associated wetland systems should use existing crossings
and/or occur on a structure wherever feasible. Where bridging is not feasible, culvert structures
that maintain natural water flows and hydraulic regimes without scouring, or impeding fish and
wildlife passage, should be employed. Highway shoulder and median widths should be reduced
through wetland areas. Roadway embankments and fill areas should be stabilized by using
appropriate erosion control devices and techniques. Wherever appropriate, construction in
sensitive areas should occur outside fish spawning and migratory bird nesting seasons.
Of
The National Wetlands Inventory (NWI) map of the Chapel Hill 7.5 Minute Quadrangle does not
show significant wetland resources, except for one intermittent stream, in the specific work area.
However, while the NWI maps are useful for providing an overview of a given area, they should
not be relied upon in lieu of a detailed wetland delineation by trained personnel using an
acceptable wetland classification methodology.
We reserve the right to review any federal permits that may be required for this project, at the
public notice stage. Therefore, it is important that resource agency coordination occur early in
the planning process in order to resolve any conflicts that may arise and minimize delays in
project implementation.
In addition to the above guidance, we recommend that the environmental documentation for this
project include the following in sufficient detail to facilitate a thorough review of the action:
1. A clearly defined and detailed purpose and need for the proposed project,
supported by tabular data, if available, and including a discussion of the project's
independent utility;
2. A description of the proposed action with an analysis of all alternatives being
considered, including the upgrading of existing roads and a "no action"
alternative;
3. A description of the fish and wildlife resources, and their habitats, within the
project impact area that may be directly or indirectly affected;
4. The extent and acreage of waters of the U.S., including wetlands, that are to be
impacted by filling, dredging, clearing, ditching, or draining. Acres of wetland
impact should be differentiated by habitat type based on the wetland classification
scheme of the National Wetlands Inventory (NWI). Wetland boundaries should
be determined by using the 1987 Corps of Engineers Wetlands Delineation
Manual and verified by the U.S. Army Corps of Engineers (Corps);
5. The anticipated environmental impacts, both temporary and permanent, that
would be likely to occur as a direct result of the proposed project. The assessment
should also include the extent to which the proposed project would result in
secondary impacts to natural resources, and how this and similar projects
contribute to cumulative adverse effects;
6. Design features and construction techniques which would be employed to avoid
or minimize the fragmentation or direct loss of wildlife habitat value;
7. Design features, construction techniques, or any other mitigation measures which
would be employed at wetland crossings and stream channel relocations to avoid
or minimize impacts to waters of the United States; and,
f
8. If unavoidable wetland impacts are proposed, we recommend that every effort be
made to identify compensatory mitigation sites in advance. Project planning
should include a detailed compensatory mitigation plan for offsetting unavoidable
wetland impacts. Opportunities to protect mitigation areas in perpetuity,
preferably via conservation easement, should be explored at the outset.
The enclosed list identifies the federally-listed endangered and threatened species, and Federal
Species of Concern (FSC) that are known to occur in Orange County. The Service recommends
that habitat requirements for these federally-listed species be compared with the available habitat
at the project site. If suitable habitat is present within the action area of the project, biological
surveys for the listed species should be conducted. Environmental documentation should include
survey methodologies and results.
FSC's are those plant and animal species for which the Service remains concerned, but further
biological research and field study are needed to resolve the conservation status of these taxa.
Although FSC's receive no statutory protection under the ESA, we would encourage the NCDOT
to be alert to their potential presence, and to make every reasonable effort to conserve them if
found. The North Carolina Natural Heritage Program should be contacted for information on
species under state protection.
The Service appreciates the opportunity to comment on this project. Please continue to advise us
during the progression of the planning process, including your official determination of the
impacts of this project. If you have any questions regarding these comments, please contact Tom
McCartney at 919-856-4520, (Ext. 32).
Sincerely,
arland B. Pardue, Ph.D.
Ecological Services Supervisor
Enclosure
cc: COE, Raleigh, NC (Eric Alsmeyer)
NCDWQ, Raleigh, NC (John Hennessy)
NCDNR, Creedmoor, NC (David Cox)
EPA, Atlanta, GA (Ted Bisterfeld)
FWS/R4:TMcCartney:TM:01/23/02:919/856-4520 extension 32:\U-2909.tip