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Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E. Director
Division of Water Quality
October 15, 2004
MEMORANDUM
TO: Dion Viventi, Project Development Engineer, NCDOT-PDEA
FROM: Brian L. Wrenn, NC DWQ -A-V)
SUBJECT: DWQ Comments on Improvements to NC 105 from US 221 in Avery County to SR 1107
in Watauga County, Avery and Watauga Counties, TIP Project No. R-2566, State Project
No. (WBS) 37512.1.1
In reply to the request for comments on the referenced project, preliminary analysis of the project
indicates that the following water resources in Hydrologic Units 03-08-30, 04-02-01, and 05-07-01 would
be impacted:
Stream Name River Basin Stream Classification Stream Index Number
Linville River Catawba C; Tr 11-29-(1)
Big Grass Creek Catawba C, Tr 11-29-3
Little Grass Creek Catawba C; Tr;,ORW 11-29-2
Watauga River Watauga B;H W 8-(16)
Green Ridge Branch Watauga C ' 8-3
Mood Mill Creek Watauga C; Tr 8-5
Valle Creek Watauga - C; Tr 8-4
Spice Bottom Creek Watau a C; Tr 8-5-1
Lance Creek Watauga C; Tr 8-8-(2)
Laurel Fork Watauga C; Tr 8-10
Hayes Branch Watauga C 8-10-3-1
Hodges Creek New C; Tr + 10-1-4-4-1
Winkler Creek New WS-II; Tr; H W; CA 10-1-4-(2)
Any impacts to these streams, unnamed tributaries to these streams, wetlands, or open water bodies
associated with the referenced project would require a 401 Water Quality Certification from the NC
Division of Water Quality (DWQ). DWQ has the following comments regarding the development of the
environmental assessment for the referenced project:
Project Specific Comments
• Several of the named streams in the project area are classified as WS-II, Outstanding Resource
Waters, High Quality Waters, or Critical Area waters of the State. DWQ is very concerned with
sedimentation and erosion impacts that could result from this project. The proposed environmental
assessment should address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the impacts. DWQ requests that
alternatives developed for the proposed environmental assessment consider design criteria that reduce
the impacts to streams and wetlands from storm water runoff. These alternatives should include road
designs that allow for treatment of the storm water runoff through best management practices as
detailed in Best Management Practices for the Protection of Surface Waters.
NWone?Caro ma
Transportation Permitting Unit ptthCaroliin
1650 Mail Service Center, Raleigh, North Carolina 27699.1650 Aa
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: 919-733-1786/ FAX 919-733-6893/ Internet: htt?://h2o.enr.state.nc.us/ncwetiands
• Several of the named streams in the project area are classified as Trout waters. DWQ is very
concerned with sedimentation and erosion impacts that could result from this project. The proposed
environmental assessment should address these concerns by describing the potential impacts that may
occur to the aquatic environments and any mitigating factors that would reduce the impacts.
• The environmental document should provide a detailed and itemized presentation of the proposed
impacts to wetlands and streams with corresponding mapping. If mitigation is necessary as required
by 15A NCAC 211.0506(b)(6), it is preferable to present a conceptual (if not finalized) mitigation plan
with the environmental documentation. Appropriate mitigation plans will be required prior to
issuance of a 401 Water Quality Certification.
General Comments
• When practical, the DWQ requests that bridges be replaced on the existing location with road
closure. If a detour proves necessary, remediation measures in accordance with the NCDWQ
requirements for General 401 Certification No. 3366/Nationwide Permit No. 33 (Temporary
Construction, Access and Dewatering) must be followed.
After the selection of the preferred alternative and prior to an issuance of the 401 Water Quality
Certification, the NCDOT is respectfully reminded tha?they will need to demonstrate the avoidance
and minimization of impacts to wetlands and streams t .the maximum extent practical.
In accordance with the Environmental Management Commission's Rules { 15A NCAC
2H.0506(b)(6) 1, mitigation will be required for impacts of greater than 150 linear feet to any single
perennial stream and for impacts of greater than 1 acre to any wetlands. In the event that mitigation
is required, the mitigation plan should be designed to replace appropriate lost functions and values.
In accordance with the Environmental Management Commission's Rules (15A NCAC 211.0506
(h)(3) 1, the NC Ecosystem Enhancement Program may be available for use as stream mitigation.
• DWQ prefers replacement of bridges with bridges.
• Any new culverts must be countersunk to allow unimpeded fish and other aquatic organisms
passage through the crossing.
• If foundation test borings are necessary; it should be noted in the document. Geotechnical work is
approved under General 401 Certification Number 3027/Nationwide Permit No. 6 for Survey
Activities.
• Sediment and erosion control measures should not be placed in wetlands.
• Borrow/waste areas should avoid wetlands to the maximum extent practicable. Impacts to wetlands
in borrow/waste areas could precipitate compensatory mitigation.
• The 401 Water Quality Certification application will need to specifically address the proposed
methods for storm water management. More specifically, storm water will not be permitted to
discharge directly into the creek. Instead, storm water should be designed to drain to a properly
designed storm water detention facility/apparatus.
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• While the use of National Wetland Inventory (NWI) maps and soil surveys is a useful office tool,
their inherent inaccuracies require that qualified personnel perform onsite wetland delineations
prior to permit approval.
Thank you for requesting our input at this time. The DOT is reminded that issuance of a 401 Water
Quality Certification requires that appropriate measures be instituted to ensure that water quality
standards are met and designated uses are not degraded or lost. If you have any questions or require
additional information, please contact Brian L. Wrenn at 919-733-5715.
pc: John Thomas, USACE Raleigh Field Office
Chris Militscher, USEPA
Marella Buncick, USFWS, Asheville Field Office
Marla Chambers, NCWRC
File Copy
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STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
MICHAEL F. EASLEY
GOVERNOR
September 7, 2004
MEMORANDUM TO:
FROM:
Mr. Brian Wrenn
Division of Water Quality/Wetlands
WR..ANDS / 401 GROOF
SFF 0 2004
WA1'r:k U(JAIJI Y SECTION
LYNDo TIPPETT
SERI; FARY
Gregory ?. Ph. D., Director
Project Development and Environmental Analysis Branch
SUBJECT: Start of Study Letters for R-2566, NC 105 from US 221 in Avery
County to SR 1107 (NC 105 Bypass) in Boone, Watauga County,
State Project No. (WBS) 37512. 1.1
The Project Development and Environmental Analysis Branch has begun studying the
proposed improvements to NC 105 from US 221 in Avery County to SR 1107 (NC 105 Bypass)
in Boone, Watauga County. The project is included in the 2004-2010 North Carolina
Transportation Improvement Program and is scheduled for right of way in fiscal year 2010 and
post year construction.
The project proposes to widen NC 105 to multi-lanes from US 221 to SR 1107 in Boone.
We would appreciate any information you might have that would be helpful in evaluating
potential environmental impacts of the project. If applicable, please identify any permits or
approvals which may be required by your agency. Your comments will be used in the
preparation of a state funded Environmental Assessment. This document will be prepared in
accordance with the State Environmental Policy Act. It is desirable that your agency respond by
November 1, 2004 so that your comments can be used in the preparation of this document.
If you have any questions concerning the project, please contact Dion J. Viventi, Project
Development Engineer, of this Branch at (919) 733-7844, Ext. 255. Please include the TIP
Project Number in all correspondence and comments.
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Attachment (-eve t T C &,
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MAILING ADDRESS: TELEPHONE: 919-733-3141
NC DEPARTMENT OF TRANSPORTATION FAX: 919-733-9794
PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS
1548 MAIL SERVICE CENTER WEBSITE: WWW. NCDOT.ORG
RALEIGH NC 27699-1548
IU-I-0
LOCATION:
TRANSPORTATION BUILDING
1 SOUTH WILMINGTON STREET
RALEIGH NC