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HomeMy WebLinkAbout20010001 Ver 1_Complete File_20001227TO: Steve Lund, USACOE Asheville Field Office FROM: Ron Linville, Regional Coordinator Habitat Conservation Program DATE: March 28, 2001 SUBJECT: North Carolina Department of Transportation (NCDOT), Bridge No. 80, Clark's Creek, TIP B-3262, SRI 136, Temporary Construction Dykes, Watauga County ;S5ve-d O 3 0I. 000 1 These comments are provided in accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d) and the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; NCAC 25). The NCDOT is not modifying their previous design for this project. They are proposing to use temporary impervious dykes during the construction of footings for the bottomless culvert. We do not object to the use of the dykes provided aquatic life passage is not negatively impacted and the stream is restored to original contours or natural geomorphic conditions upon project completion. Our previous recommendations for this project should be followed. Thank you for the opportunity to review and comment on this project during the planning stages. If you have any questions regarding these comments, please contact me at 336/769-9453. Cc: Lindsey Riddick, NCDOT Cynthia Van Der Wiele, DWQ TO: Steve Lund, USACOE Asheville Field Office FROM: Ron Linville, Regional Coordinator Habitat Conservation Program DATE: January 30, 2001 SUBJECT: North Carolina Department of Transportation (NCDOT), Bridge No. 80 Clarks Creek, TIP B-3262, SR 1136, Watauga County These comments are provided in accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d) and the North Carolina Environmental Policy Act (G.S. 113A-1 through 113A-10; NCAC 25). The NCDOT proposes to modify their previous plan to install a double barrel culvert at this location. They now plan to install a bottomless culvert (20.0' wide by 7.0' high). Removal of the existing bridge should not impact waters. We do not object to the project as proposed in the letter of January 23, 2001 from Mr. William D. Gilmore, PE. NCDOT will avoid the trout moratorium period of November 1 through April 15. The dimension, pattern, and profile of the stream above and below the project should not be modified. As appropriate, the NCDOT should follow any pertinent recommendations previously made by North Carolina Wildlife Resources Commission concerning this project. 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. Cc: Lindsey Riddick, NCDOT ST p'ellssbFo. STATE OF NORTH CAROLINA DEPARTMENT OF TRANSPORTATION JAMES B. HUNT JR. GOVERNOR December 21, 2000 U.S. Army Corps of Engineers Asheville Field Office 151 Patton Ave., Room 143 Asheville, NC 28801 ATTENTION: Mr. Steve Lund NCDOT Coordinator Dear Sir: DAVID MCCOY SECRETARY SUBJECT: Watauga County, Replacement of Bridge No. 80 over the Clarks Creek on SR 1136. TIP No. B-3262, State Project No. 8.2751001, Federal Aid Project No. MABR7-1136(1). Attached for your information is a copy of the project planning report for the subject project. Bridge No. 80 will be replaced with a two-barrel (each barrel 8.0-foot by 7.0-foot) reinforced concrete box culvert 50 feet north of the existing structure. Traffic will be maintained on the existing structure during construction. There will be 120.0 feet of new approach work to the east and 150.0 feet of new approach work to the west. Pavement width on the approaches will be 20.0 feet including two 10.0-foot travel lanes. Additionally, there will be 6-foot grassed shoulders to accommodate curve widening. No jurisdictional wetlands will be affected by the recommended alternative. All standard procedures and measures will be implemented to avoid or minimize environmental impacts. All practical Best Management Practices (BMP's) will be included and properly maintained during project construction. The NCDOT will follow all project commitments outlined in the "green sheet" of the approved Categorical Exclusion. Additionally, as noted on page 10 of the referenced document, there will be no fill associated with the removal of bridge number 80. NCWRC has commented that Clark's Creek is a Hatchery Supported Designated Public Mountain Trout Waters. The following will be implemented to minimize impacts to aquatic resources: • Where concrete is used, work will be accomplished so that wet concrete does not contact stream water. • Where possible, heavy equipment should be operated from the bank rather than in the stream channel to minimize sedimentation and reduce the likelihood of introducing other pollutants into the stream. MAILING ADDRESS: TELEPHONE: 919-733-3141 LOCATION: NC DEPARTMENT OF TRANSPORTATION FAX: 919-733-9794 TRANSPORTATION BUILDING PROJECT DEVELOPMENT AND ENVIRONMENTAL ANALYSIS 1 SOUTH WILMINGTON STREET 1548 MAIL SERVICE CENTER WEBSITE: WWW.DOH.DOT.STATE.NC.US RALEIGH NC RALEIGH NC 27699-1548 . ,r Temporary or permanent herbaceous vegetation should be planted on all bare soil within 15 days of completion of ground disturbing activities to provide long-term erosion control. • In-stream work and land disturbance within the 25-foot buffer zone will be prohibited during the rainbow trout spawning season of November 1 through April 15. • Existing trees along the stream will preserved to the extent possible. The project is being processed by the Federal Highway Administration as a "Categorical Exclusion" in accordance with 23 CPR 771.115(b). Therefore, we do not anticipate requesting an individual permit but propose to proceed under a Nationwide Permit in accordance with 33 CFR 330 Appendix A (B-23) issued 13 December 1996, by the Corps of Engineers. The provisions of Section 330.4 and Appendix A (C) of these regulations will be followed in the construction of the project. We anticipate that 401 General Water Quality Certification No. 3107 (Categorical Exclusion) will apply to this project, and are providing one copy of the CE document to the North Carolina Department of Environment and Natural Resources, Division of Water Quality, for their review. Since this project occurs in a designated trout county, a copy of this document is also being provided to the N.C. Wildlife Resources Commission for their review. If you have any questions or need any additional information, please contact Mr. Lindsey Riddick at (919) 733-7844 extension 304. Sincerely, /?- William D. Gilmore, PE, Manager Project Development and Environmental Analysis Branch CC: w/attachment w/o attachment Mr. David Franklin, USACE, Wilmington Mr. John Dorney, Division of Water Quality Mr. Ron Linville, NCWRC Mr. Tim Rountree, PE, Structure Design Mr. John Alford, PE, Roadway Design Mr. Calvin Leggett, PE, Programming and TIP Ms. Debbie Barbour, PE, Highway Design Mr. David Henderson, PE, Hydraulics Mr. Don Lee, Roadside Environmental Mr. R.C. McCann, PE, Division 1 I Engineer Mr. John Williams, PE Watauga County Bridge No. 80 on SR 1136 Over Clarks Creek Federal Project MABRZ-1136 (1) State Project 8.2751001 TIP No. B-3262 11 ?j CATEGORICAL EXCLUSION U. S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION AND N. C. DEPARTMENT OF TRANSPORTATION DIVISION OF HIGHWAYS APPROVED: `7/, F - Z4--?l Date ?or William D. Gilmore, P. E., Manager Project Development and Environmental Analysis Branch g--2G-9Y ??' ? ?L.? Date Nicholas Graf, P. E. Division Administrator, FHWA Watauga County Bridge No. 80 on SR 1136 Over Clarks Creek Federal Project MABRZ-1136 (1) State Project 8.2751001 TIP No. B-3262 CATEGORICAL EXCLUSION August 1999 Documentation Prepared in Project Development and Environmental Analysis Branch By: ``, x.111111111,11// ` od.N CARO/,',,/ DFESS/00,0 SEAL ?•' 022552 I it PA, 6q4?0_5 Date John L. Williams, P. E. Project Planning Engineer to 8-// f9 Wq ti e- X71 a Date Wayne lliott Bridge Project Planning Engineer, Unit Head S-24-99 Date Lubin V. Prevatt, P. E., Assistant Manager Project Development and Environmental Analysis Branch PROJECT COM UTMENTS Watauga County Bridge No. 80 on SR 1136 0 0 0 011 Over Clarks Creek Federal Project MABRZ-1136 (1) State Project 8.2751001 TIP No. B-3262 Geotechnical A section 6 permit will be required for the foundation investigations necessary on this project. The investigation will include test borings in soil and/or rock for in-site testing as well as obtaining samples for laboratory testing. This may require test borings in streams and/or wetlands. Resident Engineer/ Roadway Design Best Management Practices for Bridge Demolition will be followed during design and construction of the project. - - NCWRC has commented that Clark's Creek is a Hatchery Supported Designated Public Mountain Trout Waters. The following will be implemented to minimize impacts to aquatic resources: i • Where concrete is used, work will be accomplished so that wet concrete does not contact stream water. • Where possible, heavy a juipment will be operated from the bank rather than in the stream channel to minimize sedimentation and reduce the likelihood of introducing other pollutants into the stream. • Temporary or permanent herbaceous vegetation should be planted on all bare soil within 15 days of completion of ground disturbing activities to provide long-term erosion control. • In-stream work and land disturbance within the 25-foot buffer zone will be prohibited during the rainbow trout spawning season of November 1 through April 15. • Existing trees along the stream will be preserved to the extent possible Hydraulic Design Unit The Hydraulic Design Unit will coordinate the design of the proposed box culvert and any associated stream realignment with NCWRC during the design phase. Structure Design Unit This project must be reviewed under Section 26a of the Tennessee Valley Authority (TVA) Act. The final bridge plans, hydraulic analysis of the effects of the replacement structure on the 100-year flood elevation, and notice of compliance with the Historic Preservation Act of 1966 will be forwarded to TVA for approval. Programming & TIP Branch Project Let date should be scheduled such that the contractors time will be optimized regarding the November 1 through April 15 in water moratorium. Page 1 of 1 Watauga County Bridge No. 80 on SR 1136 Over Clarks Creek Federal Project MABRZ-1136 (1) State Project 8.2751001 TIP No. B-3262 Bridge No. 80 is located in Watauga County over Clarks Creek. It is programmed in the Draft 2000-2006 Transportation Improvement Program (TIP) as a bridge replacement project. This project is part of the Federal Highway Bridge Replacement and Rehabilitation Program (HBRRP) and has been classified as a "Categorical Exclusion". No substantial environmental impacts are expected. 1. SUMMARY OF RECOMMENDATIONS Bridge No. 80 will be replaced as recommended in Alternate 1 with a new structure on new alignment 50 feet north of the existing structure (see Figure 2A). The new structure will be a 2-barrel (each barrel @ 8 x 7-foot) reinforced concrete box culvert. Traffic will be detoured offsite during construction. There will be 120 feet of new approach work to the east and 150 feet of new approach work to the west. The pavement width on the approaches will be 20 feet including two 10-foot lanes. Additionally there will be 6-foot grass shoulders to accommodate curve widening. Based on preliminary design, the design speed will be approximately 20 mph. The estimated cost of the project is $326,000 including $300,000 in construction costs and $26,000 in right of way costs. The estimated cost shown in the Draft 2000- 2006 TIP is $255,000. III. ANTICIPATED DESIGN EXCEPTIONS A design exception will be required. The design speed for this project will be approximately 20 mph. The road does not have a posted speed limit and is therefore subject to statutory 55 mph. The alignment in the project vicinity is typical of SR 1136. During the period October 93 though September 96, the bridge and approaching alignment have no recorded accidents. Analysis of the alternates indicates that any significant improvement of the alignment would be very difficult to achieve given the topography and subsequently result in heavier environmental impacts and higher project costs. IV. EXISTING CONDITIONS SR 1136 is classified as a Rural Local Route in the Statewide Functional Classification System. It is located approximately 2 miles south of Valle Crucis, N. C. Currently the traffic volume is 600 vehicles per day (VPD) and projected at 900 VPD for the year 2020. There is no posted speed limit in the vicinity of the bridge. The road serves primarily local residential and agricultural traffic. The existing bridge was completed in 1963. It is composed of a one-span timber and steel superstructure. The deck is 30 feet long and 18 feet wide. The substructure is composed of two end abutments; one made of concrete the other of timber. There is approximately 10 feet of vertical clearance between the floorbeams of the bridge deck and streambed. There is room for one lane of traffic on the bridge. According to Bridge Maintenance Unit records, the sufficiency rating of the bridge is 23.8 out of a possible 100. Presently the bridge is posted with weight restrictions of 8 tons for single vehicles and 17 tons for truck-tractor semi-trailers. Vertical alignment is poor in the project vicinity. The bridge lies in the middle of a horizontal curve with an operating speed of less than 20 mph. The pavement width on the approaches to the existing bridge is 16 feet. Shoulders on the approaches of the bridge are approximately 4 feet wide. The Traffic Engineering Branch indicates that no accidents have been reported during the period October 93 through September 96 in the vicinity of the project. There are 2 daily school bus crossings over the studied bridge. According to the Transportation Director for Alleghany County closing the road would not be a major burden. Bell South Telephone has an aerial cable along the west side of SR 1136. Blue Ridge Electric Membership Corporation has an electrical service approximately 325 feet north of the existing bridge. V. PROPOSED ALTERNATIVES There are two "build" options considered in this document as follows: Alternate 1) (Recommended) Replace Bridge No. 80 with a new two-barrel box culvert on a location 50 feet north of the existing structure. Traffic will be detoured offsite during construction. Design has determined that maintaining traffic onsite is not possible due to lack of a staging area for construction equipment. The design speed would be approximately 20 mph. Alternate 2) Replace Bridge No. 80 with a new 2-barrel box culvert on a location approximately 150 feet north of the existing structure. Traffic would be maintained on the existing bridge during construction. The design speed will be approximately 20 mph. "Do-nothing" is not practical; requiring the eventual closing of the road as the existing bridge completely deteriorates. Rehabilitation of the existing deteriorating bridge is neither practical nor economical. Replacing Bridge No. 80 on the same location was considered but discarded. The reasoning was that Alternate 1 has virtually the same environmental impacts and monetary cost and an improved alignment compared with the replace in place alternate. VI. ESTIMATED COST (Table 1) COMPONENT Recommended ALTERNATE 1 ALTERNATE 2 Reinforced Concrete Box Culvert Bridge Removal Roadway & Approaches *65,000 5,000 126,000 **106,000 5,000 174,000 Mobilization & Miscellaneous 59,000 86,000 Engineering & Contingencies 45,000 79,000 Total Construction $ 300,000 450,000 Right of Way $ 26,000 $ 57,000 Total Cost $ 326,000 $ 507,000 * two barrels @ 8x7 feet, 80 feet long ** two barrels @ 8x7 feet, 130 feet long VII. DETOUR (ROAD USER COSTS) An offsite detour would include SR 1112 and NC 105. Road users would have to travel an average of 2.4 miles more than their normal route along SR 1136. The road closure would last approximately one year. The total additional costs incurred by road users would be approximately $131,000. VIII. RECOMMENDED IMPROVEMENTS Bridge No. 80 will be replaced as recommended in Alternate 1 with a new structure on new alignment 50 feet north of the existing structure (see Figure 2A). The new structure will be a 2-barrel (each barrel @ 8 x 7-foot) reinforced concrete box culvert. Traffic will be detoured offsite during construction. There will be 120 feet of new approach work to the east and 150 feet of new approach work to the west. The pavement width on the approaches will be 20 feet including two 10-foot lanes. Additionally there will be 6-foot grass shoulders to accommodate curve widening. Based on preliminary design, the design speed should be approximately 20 mph. Alternate I is recommended because it has the lowest cost and least environmental impact of the alternates considered. While Alternate 2 offers an improved alignment, the improvement is worth neither the excessive cost nor the impact to the home 200 feet south of the bridge. The Division concurs in the recommendation. IX. ENVIRONMENTAL EFFECTS A. GENERAL This project is expected to have an overall positive impact. Replacement of an inadequate bridge will result in safer traffic operations. This project is considered to be a "Categorical Exclusion" due to its limited scope and insignificant environmental consequences. This bridge replacement will not have a substantial adverse effect on the quality of the human or natural environment by implementing the environmental commitments listed in Section II of this document in addition to use of current NCDOT standards and specifications. The project is not in conflict with any plan, existing land use, or zoning regulation. No change in land use is expected to result from construction of this project. There are no hazardous waste impacts. No adverse effect on families or communities is anticipated. Right-of-way acquisition will be limited. No adverse effect on public facilities or services is expected. The project is not expected to adversely affect social, economic, or religious opportunities in the area. There are no publicly owned parks, recreational facilities, or wildlife and waterfowl refuges of national, state, or local significance in the vicinity of the project. This project will not impact any resource protected by Section 4(f) of the DOT act. The proposed bridge replacement project will not raise the existing flood levels or have any significant adverse effect on the existing floodplain. Utility impacts are considered to be low for the proposed project. B. AIR AND NOISE This project is an air quality "neutral" project, so it is not required to be included in the regional emissions analysis and a project level CO analysis is not required. The project is located in Watauga County, which has been determined to be in compliance with the National Ambient Air Quality Standards. 40 CFR part 51 is not applicable, because the proposed project is located in an attainment area. This project is not anticipated to create any adverse effects on the air quality of this attainment area. The project will not substantially increase traffic volumes. Therefore, it will not have substantial impact on noise levels. Temporary noise increases may occur during construction. C. LAND USE & FARMLAND EFFECTS In the vicinity of this project, Watauga County has no zoning. This project will impact no soils considered to be prime or important farmland. D. HISTORICAL EFFECTS & ARCHAEOLOGICAL EFFECTS On March 11, 1997, the State Historic Preservation Office reviewed the subject project. Subsequently, they determined that an architectural survey would be required. An archaeological survey was requested and subsequently performed yielding no significant sites. The SHPO concurs with FHWA that the project is not likely to affect any resources of historical significance (see attachments). E. NATURAL RESOURCES PHYSICAL RESOURCES Regional Characteristics The proposed project lies near the Watauga County line in western North Carolina, 6.0 miles southwest of Boone. The project area lies within the Blue Ridge Physiographic Province. Elevations in the project area are approximately 2800 feet National Geodetic Vertical Datum (NGVD). The topography of the project vicinity is characterized by steep slopes ending in incised streams and/or narrow to broad, relatively flat floodplains. The stream banks of Clark's Creek within the project area are steep at the bridge but become more gently sloping further north. The project vicinity is a combination of residential, rural, and agricultural areas. Soils A published soil survey for Watauga County was not available; available soil maps were obtained from the NRCS office. According to the available mapping, the detailed map units within the project area include Congaree cobbly fine sandy loam (0 to 2 % slopes); Halewood stony clay loam, eroded hilly phase (15 to 30 % slopes); Halewood stony clay loam, eroded steep phase (30 to 60 % slopes); Stony colluvium (Tusquitee and Tate soil materials, 2 to 30 % slopes); Stony rough land (Ashe and Porters soil materials, 30 to 60 % slopes); and Tate loam, undulating phase (2 to 7 % slopes). Congaree cobbly fine sandy loam (Cs): nonhydric soil with moderate to moderately rapid permeability. Cobbles and gravel are common in the profile. A small area of this soil type is mapped at the northern end of the project area. Halewood stony clay loam, steep phase (Hf): nonhydric soil with medium to high surface runoff. Soil is moderately erodible if not protected. Rock fragments in the profile are common. A small area of this soil type is mapped in the western portion of the project area, west of SR 1136. Halewood stony clay loam, eroded steep phase (Hg): nonhydric soil with high to very high surface runoff. Soil is erodible if not protected. Rock fragments in the profile are frequent. This soil is mapped north of the SR 1136 bridge, between Clark's Creek and SR 1136, in a broad floodplain now serving as pasture. This soil is also mapped east of SR 1136. Stony colluvium (Sb): nonhydric soil; surface runoff is medium to high and permeability is moderate to moderately rapid. The erosion hazard is very little to 5 moderate. The profile contains stones and is derived from local alluvial or colluvial materials. This soil type is mapped just north and south of the bridge. The soil north of the bridge is currently pasture and the soil south of the bridge is covered by saplings, shrubs, and forbs. Stony rough land (Sd): nonhydric soil; surface runoff is high to very high. The erosion hazard is moderate to great. A large number of loose stones and outcrops of bedrock occur in the profile. This soil type is mapped in the area of two residences along the south side of SR 1136. Tate loam, undulating phase (Tc): nonhydric soil; surface runoff is medium to low. The erosion hazard is negligible. This soil type is mapped east of the Congaree cobbly fine sandy loam described above. This area consists of pasture along both sides of Clark's Creek. Site index is a measure of soil quality and productivity. The site index for these soil types was not obtained as a published soil survey was not available. Water Resources This section contains information concerning water resources likely to be impacted by the proposed project. Water resource assessments include the physical characteristics likely to be impacted by the proposed project (determined by field survey), best usage classifications, and water quality aspects of the water resources. Probable impacts to surface waters are outlined, as well as the means to minimize impacts. Physical Characteristics of Surface Waters The project is located in the Watauga River basin. One surface water resource, Clark's Creek, will be impacted by the proposed project. Clark's Creek originates approximately 1.4 miles south of the project area on Nettle Knob. The creek flows north approximately 2.4 miles to its confluence with Dutch Creek, which is a tributary to the Watauga River. Clark's Creek is approximately 10.0 to 15.0 feet in width within the project area and has a moderate streamflow. The substrate of the creek consists of cobbles, sand, and silt. At the time of the field survey, the creek averaged 11 inches in depth. The creek flows northeast and is mainly straight. During the site visit the water was clear with minimal suspended sediment. Riparian vegetation, consisting mostly of young deciduous trees and shrubs, exists along the creek banks south of the bridge. North of the bridge, the vegetation has been cleared for pasture and the banks are grassy. The floodplain appears to be seasonally flooded along some areas of the bank. Best Usage Classification Surface waters in North Carolina are assigned a classification by the Division of Water Quality (DWQ) that is designed to maintain, protect, and enhance water quality within the state. Clark's Creek (Index # 8-12-2) is classified as a Class C waterbody. 6 Class C water resources are used for aquatic life propagation and survival, fishing, wildlife, secondary recreation, and agriculture. No waters classified as High Quality Waters (HQW), Water Supplies (WS-I of WS-II), or Outstanding Resource Waters (ORW) occur within 1 mile if the project study area. Water Quality This section describes the water quality of the water resources within the project area. Potential impacts to water quality from point and nonpoint sources are evaluated. Water quality assessments are based upon published resource information and field study observations. General Watershed Characteristics Nonpoint source runoff from agricultural land is likely to be the primary source of water quality degradation to the water resources located within the project vicinity. The surrounding vicinity appears to be primarily residential and forested land with some small areas of cropland. Nutrient loading and increased sedimentation from agricultural runoff and forestry affects water quality. Inputs of nonpoint source pollution from private residences within the project area may also contribute to water quality degradation. Benthic Macroinvertebrate Ambient Network The Benthic Macroinvertebrate Ambient Network (BMAN), established in 1982 and managed by the DWQ, is part of an on-going ambient, long-term, water-quality monitoring program. The program has established fixed water-quality monitoring stations for selected benthic macroinvertebrates. No BMAN stations have been established along Clark's Creek Point Source Dischargers Point source discharges in North Carolina are permitted through the National Pollutant Discharge Elimination System (NPDES) program administered by the DWQ. All facilities who discharge to surface waters are required to obtain a permit. There are no known permitted point source dischargers to Clark's Creek within the project vicinity. Summary of Anticipated Impacts Any action which affects water quality can adversely affect aquatic organisms. Temporary impacts during the construction phases may result in long-term impacts to the aquatic community. Replacing an existing structure in the same location with an off-site detour is the preferred environmental approach. Bridge replacement on a new location will result in more severe impacts. Therefore, based on environmental impacts, Alternate I is the preferred alignment. Physical impacts will be the most severe at the point of bridge replacement. Project construction may result in the following impacts to surface water resources: increased sediment loading and siltation as a consequence of watershed vegetation removal, erosion/and or construction decreased light penetration/water clarity from increased sedimentation changes in water temperature with vegetation removal changes in the amount of available organic matter with vegetation removal increased concentration of toxic compounds from highway runoff, construction activities and construction equipment, and spills alteration of water levels and flows due to interruptions and/or additions to surface and groundwater flow from construction increased scouring of the existing channel due to increased water flows from the stormwater runoff associated with curb and gutter systems Construction impacts may not be restricted to the communities in which the construction activity occurs. Efforts should be made to ensure that no sediment leaves the construction site. NCDOT's Best Management Practices for the Protection of Surface Waters should be followed during the construction phase of the project. BIOTIC RESOURCES Terrestrial and aquatic communities are included in the description of biotic resources. Living systems described in the following sections include communities of associated plants and animals. These descriptions refer to the dominant -flora and fauna in each community and the relationship of these biotic components. Descriptions of the terrestrial systems are presented in the context of plant community classifications. These classifications follow Schafale and Weakley (1990) where possible. Representative animal species which are likely to occur in these habitats (based on published range distributions) are also cited. Scientific nomenclature and common names (when applicable) are used for the plant and animal species described. Subsequent references to the same species are by the common name only. Terrestrial Communities The two terrestrial communities identified within the project area are man- dominated and upland forest. Dominant faunal components associated with these terrestrial areas are described below. Many species are adapted to the entire range of habitats found along the project alignment but may not be mentioned separately in each community description. 8 Man-Dominated Community The man-dominated community includes the road shoulders and residential lawns where regular maintenance occurs and the pasture which appears to be regularly grazed or mowed. This community also includes areas which are not regularly maintained including the embankments and the transition areas between the road shoulders and the forested areas Many plant species are adapted to the disturbed and regularly maintained areas. The species observed in this community type within project area include various grasses such as fescue and ryegrass, as well as wild onion, dandelion, and white clover. In areas which are disturbed but not regularly maintained, weedy species and shrubs are invading. Black locust, goldernrod, and blackberry are present in these areas. There is a small seep within the floodplain on the east side of Clark's Creek north of the bridge. This area occurs in the pasture at the toe of the slope, which is at the base of the embankment of SR 1136. The area is approximately 20 to 30 feet wide and 75 feet long. Vegetation in this area consists of fescue, as well as soft rush, and sedge which is regularly grazed or mowed. The ground was saturated to the surface, and the soils consisted of a dark gray (10 YR 4/1) clay loam. The animal species present in these disturbed habitats are opportunistic and capable of surviving on a variety of resources, ranging from vegetation (flowers, leaves, fruits, and seeds) to both living and dead faunal components. Numerous songbirds such as the house sparrow, northern mockingbird, cardinal, common grackle, and eastern kingbird are common in these habitats. A black-capped chickadee was observed in the area. The areas associated with the pasture may be utilized by white-tailed deer, white- footed mouse, Virginia opossum, American toad, and rat snake. Species such as red- tailed hawk and American kestrel may utilize these open areas for hunting. Upland Forest This community occurs to the west of Clark's Creek south of Bridge No. 80, and to the east and west of SR 1136. The community west of Clark's Creek occurs on a steep, rocky slope. The canopy is comprised of American beech, southern red oak, and black oak. Great rhododendron dominates the shrub layer and Christmas fern is present in the herbaceous layer. West of SR 1136, species present include eastern hemlock, eastern white pine, and black cherry. These areas have been subject to some disturbance associated with the adjacent residential and agricultural areas. If undisturbed, this community may eventually resemble the Montane Oak-Hickory Forest as described in Schafale and Weakley (1990). A variety of species likely utilizes these upland communities. Birds may include blue-gray gnatcatcher, Acadian flycatcher, tufted titmouse, northern flicker, eastern wood 9 peewee, white-breasted nuthatch, and purple finch. Other species may include eastern chipmunk, striped skunk, grey treefrog, Fowler's toad, copperhead, eastern box turtle, and five-lined skink. Aquatic Communities Clark's Creek is a second order stream with good water clarity. Upstream of the bridge, the stream is high gradient with rapids and step-pools formed from the cobble and boulder substrate. Downstream of the bridge, the stream becomes a lower gradient stream with an associated floodplain. The riparian community contains mostly tree and shrub species upstream of the bridge. Much of the vegetation has been removed downstream of the bridge and the banks are mostly grassy with a few shrubs. Watauga County is designated as a "trout" county by the North Carolina Wildlife Resources Commission (WRC). Approximately 1.0 miles downstream is Dutch Creek, which is a trout creek managed by WRC. Clark's Creek provides habitat for a variety of species of fish. According to Joseph Mickey, the District 7 Biologist for the WRC, this portion of Clark's Creek was last sampled in February, 1992. Fish species found during the sampling effort include wild rainbow trout, stocked brook trout, stone roller, black nosed dace, and creek chub. During a limited field survey for benthic macroinvertebrate species, only one snail (Class Gastropoda), whose species could not be identified, was found in Clark's Creek. It is likely that the diversity of the macrobenthic community would be greater during warmer months. Reptiles and amphibians which inhabit the upland forest community also utilize the aquatic community. Other species may include queen snake, marbled salamander, southern two-lined salamander, and southern leopard frog. Summary of Anticipated Impacts Project construction will have various impacts to the previously described terrestrial and aquatic communities. Any construction activities in or near these resources have the potential to impact biological functions. This section quantifies and qualifies potential impacts to the natural communities within the project area in terms of the area impacted and the plants and animals affected. Temporary and permanent impacts are considered here along with recommendations to minimize or eliminate impacts. Bridge No. 80 is composed entirely of timber and steel with the exception of a concrete abutment. It should be possible to remove all components of the bridge without dropping them into Waters of the U.S. Therefore, there will be no fill resulting from the demolition of Bridge No. 80. 10 Terrestrial Communities Terrestrial communities in the project area will be impacted by project construction from clearing and paving and loss of the terrestrial community area along SR 1136. Estimated impacts are derived based on the project lengths of 150 feet for Alternate 1 and 350 feet for Alternate 2; with an study corridor width of 80 feet. Table 2 details the potential impacts to terrestrial communities by habitat type. Please note that impacts are based on the entire study corridor width, and that actual loss of habitat will likely be less. Table 2 Estimated Area Impacts to Terrestrial Communities Community Impacted Area in acres Alternate 1 Alternate 2 Disturbed 0.11 0.40 Upland Forest 0.03 0.02 Total Impacts 0.14 0.42 Destruction of natural communities along the project alignment will result in the loss of foraging and breeding habitats for the various animal species which utilize the area. Animal species will be displaced into surrounding communities. Adult birds, mammals, and some reptiles are mobile enough to avoid mortality during construction. Young animals and less mobile species, such as many amphibians, may suffer direct loss during construction. Plants and animals found in these upland communities are generally common throughout western North Carolina. Impacts to terrestrial communities, particularly in locations having steep to moderate slopes, can result in the aquatic community receiving heavy sediment loads as a consequence of erosion. Construction impacts may not be restricted to the communities in which the construction activity occurs, but may also affect downstream communities. Efforts should be made to ensure that no sediment leaves the construction site. If Alternate 2 were selected, the existing bridge would be removed and adjacent land would be revegetated following construction Aquatic Communities Impacts to aquatic communities include fluctuations in water temperatures due to the loss of riparian vegetation. Shelter and food resources, both in the aquatic and terrestrial portions of these organisms' life cycles, will be affected by losses in the terrestrial communities. The loss of aquatic plants and animals will affect terrestrial fauna which rely on them as a food source. Temporary and permanent impacts may result to aquatic organisms from increased sedimentation. Aquatic invertebrates may drift downstream during construction and recolonize the disturbed area once it has been stabilized. Sediments have the potential to affect fish and other aquatic life in several ways, including the clogging and abrading of gills and other respiratory surfaces; affecting the habitat by scouring and filling-in pools and riffles; altering water chemistry; and smothering different life stages. Increased sedimentation may cause decreased light penetration through an increase in turbidity. Wet concrete should not come into contact with surface water during bridge construction, as this may affect stream water quality by increasing runoff. Potential adverse effects can be minimized through the implementation of NCDOT Best Management Practices for Protection of Surface Waters. JURISDICTIONAL TOPICS This section provides inventories and impact analyses for two federal and state regulatory issues: Waters of the U.S. (including wetlands) and rare and protected species. Waters of the United States Wetlands and surface waters fall under the broad category of "Waters of the United States" as defined in 33 CFR 328.3 and in accordance with provisions of Section 404 of the Clean Water Act (33 U.S.C. 1344), and are regulated by the U.S. Army Corps of Engineers (USACE). Any action that proposes to dredge or place fill material into surface waters or wetlands falls under these provisions. Characteristics of Wetlands and Surface Waters Within the project area, there is a small seep within the floodplain east of Clark's Creek, north of the bridge. This area occurs in the pasture at the base of the embankment of SR 1136. The area is 20 to 30 feet wide and 75 feet long, however, only the southern tip, which is about 23 feet long, of this seep is within the study corridor of Alternate 2. Therefore, total wetland size which would be impacted is 0.01 acres. Clark's Creek meets the definition of surface waters. Clark's Creek is therefore classified as Waters of the United States. The channel ranges from approximately 10 to 15 feet wide within the project area. The banks on the south side of the bridge are approximately 4 ft high and consist of rock outcrops and vegetation. On the north side of the bridge, the banks are lower, l to 2 feet, with a floodplain within a grassy pasture. 12 Summary of Anticipated Impacts Approximately 0.01 acres of wetlands would be impacted by Alternate 2. No permanent impacts to wetlands will occur from Alternate 1. Project construction cannot be accomplished without infringing on surface waters. Anticipated surface water impacts fall under the jurisdiction of the USACE and DWQ. Within the project area, Clark's Creek is 15 feet wide. Assuming a 80 feet wide study corridor for both alternates, the construction of either bridge will impact 0.03 acres and 80 linear feet of surface waters. The actual length of the stream impacts will be likely be less, depending on final design plans. Permits Impacts to jurisdictional wetlands and surface waters are anticipated from the proposed project. Permits and certifications from various state and federal agencies may be required prior to construction activities. Construction is likely to be authorized by provisions of CFR 330.5 (a) Nationwide Permit (NWP) No. 23 which authorizes activities undertaken, assisted, authorized, regulated, funded, or financed in whole or in part, by another Federal agency or department where that agency or department has determined that, pursuant to the Council on Environmental Quality Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act: the activity, work, or discharge is categorically excluded from environmental documentation because it is included within a category of actions which neither individually nor cumulatively have a significant effect on the human environment; and that the Office of the Chief Engineer has been furnished notice of the agency's or department's application for the categorical exclusion and concurs with that determination. This project will also require a 401 Water Quality Certification or waiver thereof, from DENR prior to issuance of the NWP 23. Section 401 of the Clean Water Act requires that the state issue or deny water certification for any federally permitted or licensed activity that results in a discharge into Waters of the U.S. In addition, the project is located in a designated "trout" county where NCDOT is required to obtain a letter of approval from the WRC. Avoidance, Minimization, Mitigation Since this project will likely be authorized under a Nationwide permit, mitigation for impacts to surface waters is may or may not be required by the USACE. In accordance with the Division of Water Quality Wetland Rules [15A NCAC 211 .0506 13 (h)] "Fill or alteration of more than one acre of wetlands will require compensatory mitigation; and fill or alteration of more than 150 linear feet of streams may require compensatory mitigation. Since the wetland and stream impacts are lower than these designated thresholds, compensatory mitigation should not be required. Rare and Protected Species Some populations of plants and animals are declining either due to natural forces or due to their inability to coexist with man. Rare and protected species listed for Watauga County, and any likely impacts to these species as a result of the proposed project construction, are discussed in the following sections. Federally Protected Species Plants and animals with federal classification of Endangered (E), Threatened (T), Proposed Endangered (PE), and Proposed Threatened (PT) are protected under provisions of Section 7 and Section 9 of the Endangered Species Act of 1973, as amended. The Fish and Wildlife Service (FWS) lists five federally protected species for Watauga County as of May 1999. These species are listed in Table 3. Table 3 Federally Protected Species for Watauga County Scientific Name Common Name Federal Status Clemmys muhlenbergii Bog turtle TS/A Glaucomys sabrinus coloratus Carolina northern flying squirrel E Geum radiatum Spreading avens E Houstonia montana Roan Mountain bluet E Liatris helleri Heller's blazing star T Notes: "E" Denotes Endangered (a species that is threatened with extinction throughout all or a significant portion of its range) "T" Denotes Threatened (a species that is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range) "T S/A" Denotes Similarity of Appearance (a species that is listed as threatened due to similarity of appearance with other rare species). 14 A brief description of the characteristics and habitat requirements of each species, along with a conclusion regarding potential project impact, follows. Clemmys muhlenbergh (Bog turtle) Threatened due to Similarity of Appearance Vertebrate Family: Emydidae Federally Listed: 1997 The bog turtle is a small freshwater turtle reaching a maximum carapace length of 4.5 inches. These turtles have a domed carapace which is weakly keeled and is light brown to ebony in color. The scutes have a lighter-colored starburst pattern. The plastron is brownish-black with contrasting yellow or cream areas along the midline. This species is distinguished by a large conspicuous orange, yellow, or red blotch on each side of the head. The bog turtle is semi-aquatic and is typically found in freshwater wetlands characterized by open fields, meadows, or marshes with slow moving streams, ditches, and boggy areas. The bog turtle is also found in wetlands in agricultural areas subject to light to moderate livestock grazing which helps to maintain an intermediate stage of succession. During the winter, this species hibernates just below the upper surface of mud. Mating occurs in May and June, and the female deposits two to six eggs in sphagnum moss or sedge tussocks in May, June or July. The diet of the bog turtle is varied consisting of beetles, lepidopteran and caddisfly larvae, snails, millipedes, pondweed and sedge seeds, and carrion. The southern population of the bog turtle is listed as Threatened due to Similarity of Appearance to the northern population, therefore, the southern population is not afforded protection under Section 7 of the Endangered Species Act. There is a small wetland area or seep in the project area, however, this area is regularly maintained and the vegetation was closely cropped or grazed. This seep is not associated with a slow moving stream or ditch, rather, it occurs as a seasonally wet area at the base of a slope. A search of the NHP database found no occurrence of the bog turtle in the project vicinity. Glaucomys sabrinus coloratus (Carolina northern flying squirrel) Endangered Vertebrate Family: Sciurdiae Federally Listed: 1985 The Carolina northern flying squirrel is a small mammal weighing about 95 to 140 g (3 to 5 oz). The adult squirrel is gray with a reddish or brownish wash on the back, and a grayish white to white underside. It has a large flap of skin along either side of its body which is connected at the wrist in the front and at the ankle in the rear. The skin flaps and its broad flattened tail allow the northern flying squirrel to glide from tree to tree. It is a solely nocturnal animal with large dark eyes. 15 There are several isolated populations of the northern flying squirrel in the western part of North Carolina along the Tennessee border. This squirrel is found above 5000 feet in the vegetation transition zone between hardwood and coniferous forests. Both forest types are used to search for food and the hardwood forest is used for nesting sites. The squirrel can subsist on lichens and fungi throughout much of its range, however, the diet can also include seeds, buds, fruits, and insects. Biological Conclusion: No Effect No habitat exists in the project area for the Carolina northern flying squirrel. The project area is characterized by agricultural and residential areas at an elevation of 2800 feet; this species occurs above 5000 feet. A search of the NHP database found no occurrence of the Carolina northern flying squirrel in the project vicinity. It can be concluded that the project will not impact this endangered species. Geum radiatum (Spreading avens) Endangered Plant Family: Rosaceae Federally Listed: 1990 Spreading avens is a perennial herb having stems with an indefinite cyme of bright yellow radially symmetrical flowers. Flowers of spreading avens are present from June to early July. Spreading avens has basal leaves which are odd-pinnately compound; terminal leaflets are kidney shaped and much larger than the lateral leaflets, which are reduced or absent. Spreading avens is found only in the North Carolina and Tennessee section of the Southern Appalachian Mountains. Spreading avens occurs on scarps, bluffs, cliffs and escarpments on mountains, hills and ridges. Known populations of this plant has been found to occur at elevations from 5060 to 5800 feet. Other habitat requirements for this species include full sunlight and shallow acidic soils which contain a composition of sand, pebbles, humus, sandy loam and clay loam. Most populations are pioneers on rocky outcrops. The substrate at all the population sites is composed of various igneous, metamorphic, and metasedimentary rocks Biological Conclusion: No Effect No habitat exists in the project area for spreading avens. The elevation of the project area is approximately 2800 feet and known populations occur above 5000 feet. A search of the NHP database found no occurrence of spreading avens in the project vicinity. It can be concluded that the project will not impact this endangered species. 16 Houstonia montana (Roan Mountain bluet) Endangered (=Hedyotis purpurea var. montana) Plant Family: Rubiaceae Federally Listed: 1990 Roan Mountain bluet is a cespitose perennial herb with erect or ascending, unbranched or weakly terminally branched stems to 8 inches tall from a basal winter rosette. Cauline leaves are opposite, sessile and ovate, 0.3 to 1.2 inches long and 0.6 to 0.2 to 0.5 inches wide. Flowers are reddish purple and funnel-shaped. The inflorescence is few flowered, with flowers occurring from late May through August, with peak flowering in June and July. There is considerable disagreement among the experts concerning whether the Roan Mountain bluet belongs to the Hedyotis or Houstonia genus, and whether it is a variety or deserves a full species ranking. Roan Mountain bluet grows on rocky exposures at high elevations of 4600 to 6270 feet. Bedrock geology is critical for the growth of this species. All sites are on mafic (i.e. basic) rock, which contrasts with most other high elevation rocky-summit sites, which are typically on felsic or acidic rock. The plants typically grow in gravel- filled pockets found on north or northwest facing cliff ledges, or on talus slopes associated with outcrop exposures on the south or southwest slopes of mountain balds. Most sites are kept moist by frequent fog, mid-elevation clouds, or summer thunderstorms. Biological Conclusion: No Effect No habitat exists in the project area for Roan Mountain bluer The elevation of the project area is approximately 2800 feet and this species occurs above 4600 feet. A search of the NHP database found no occurrence of Roan Mountain bluet in the project vicinity. It can be concluded that the project will not impact this endangered species. Liatris helleri (Heller's blazing star) Threatened Plant Family: Asteraceae Federally Listed: 1987 Heller's blazing star is a perennial herb with an erect stem growing from a cormlike rootstock. The stiff stems are purple near the base turning to green, and are strongly ribbed and angulate. Both basal and cauline leaves are numerous, decreasing in size upward. The leaves are long and narrow, with those at the base 8 to 12 inches in length. The stems reach up to 16 inches in height and are topped by a showy spike of lavender flowers 0.3 to 8 inches long. Flowering occurs from July through September. 17 Heller's blazing star typically occurs on sandy soil on rocky summits, cliffs, ledges and rocky woods at high elevation (3500 to 6000 feet). The plants grow in humus or clay loams on igneous and metasedimentary rock. Soils are generally acidic (pH 4) and shallow. Sites occupied by the Heller's blazing star are generally exposed to full sun. Biological Conclusion: No Effect No habitat exists in the project area for Heller's blazing star. The elevation of the project area is approximately 2800 feet and this species occurs above 3500 feet. A search of the NHP database found no occurrence of Heller's blazing star in the project vicinity. It can be concluded that the project will not impact this threatened species. Federal Species of Concern and State Listed Species Federal Species of Concern (FSC) are not legally protected under the Endangered Species Act and are not subject to any of its provisions, including Section 7, until they are formally proposed or listed as Threatened or Endangered. Table 4 includes FSC species listed for Watauga County and their state classifications. Organisms which are listed as Endangered (E), Threatened (T), or Special Concern (SC) by the North Carolina Natural Heritage Program list of Rare Plant and Animal Species are afforded state protection under the State Endangered Species Act and the North Carolina Plant Protection and Conservation Act of 1979; however, the level of protection given to state listed species does not apply to NCDOT activities. Table 4 Federal Species of Concern and NC Protected Species for Watauga County Scientific Name Common Name NC Status Habitat present Cryptobranchus alleganiensis Hellbender Sc Yes Dendroica cerulea Cerulean warbler SR No Neotoma magister* Alleghany woodrat SC No Phenocobius teretulus Kanawha Minnow SC No Sorex palustris punctulatus* Southern water shrew SC No Sylvilagus obscurus* Appalachian cottontail SR No Lasmigona subviridus Green floater E Yes Speyeria diana Diana fritillary butterfly SR No Abies fraseri Fraser fir C No Cardamine clematitis Mountain bittercress C No 18 Delphinium exaltatum Tall larkspur E-SC No Euphorbia purpurea* * Glade spurge C No Geum geniculatum Bent avens T No Juglans cinerea Butternut W5 Yes Lilium grayi Gray's lily T-SC No Poa paludigena* Bog bluegrass E No Notes: Source: Amoroso and LeGrand; 1995 Weakley, 1995 T - Threatened, E - Endangered, SC - Special Concern, SR - State Rare, C-Candidate, W5- rare because of severe decline * - Denotes a historic record (The species was last observed in the county more than 50 years ago.) ** - Denotes an obscure record (The date and/or location of observation is uncertain.) A review of the Natural Heritage Program data base of rare species and unique habitats revealed no occurrences of any FSC or state protected species within the project area. Surveys for these species were not conducted during the site visit. There was a reported occurrence of bleeding heart (Dicentra eximia), which is listed as a state Candidate species, approximately 0.4 miles downstream of the project area. 19 FIGURES _ ii f '• 2 ..-. 1 1312 rO 2 - N `D 11 17 '+- 1408 -'; W T 1313 `r O 1 ` - ? ' 1155 2 Villas W % 1311 -•, a 1 9 MAST O 121 GA rv 1 75 116 O 1165 N 194 1177 `• S 1120 `321 ••\ `? / 1117 O ?"?•, ? 1115 421 8 9 1119 1 122' 1170 % V . 11129 03 p M.,4r 1113 l 1164 A _ 6 ROCKY FACE , 4 5 "-k s 1128 . •. 'tpt Valle Cru s 1 i 1130 ! i Q• 1152 1160 1 1135 . 1132 ? 112 ; O 'ry 11 i i h 3i 11 ' 1122 1169 Brid N 80 3 'L' ;lc' • v? 5 '. 1? 1 i ge o. Mathes!, 113 3 1130 :- -A R777 v C. i? 1138 E?_ • 1 134 1 13 i ,r A? ?? ` .?\ 1 16B 1580 ,.. ? (Z' 1 16 c? •- 1 A r. _ 1 Fan 1 I IDDc r I ? Studied Detour W ;ATfA UGA 1odd u ..?.e.us 4 ' t y?Yf 1??6 or No1?N c?`L North Carolina Department of Transportation Division of Highways Planning & Environmental Branch or rMMS? Watauga County Replace Bridge No. 80 on SR U36 Over Clarks Creek M262 Figure 1 is i CENTER OF BRIDGE FACING EAST 4 NORTH FACE OF BRIDGE ATTACHMENTS ® North Carolina Wildlife Resources Commission 512 N. Salisbury Street, Raleigh, North Carolina 27604-1188, 919-733-3391 Charles R. Fullwood, Executive Director MEMORANDUM TO: John L. Williams, Project Planning Engineer Planning and Environmental Branch, NCDOT FROM: Stephanie E. Goudreau, Eastern Mt. Region Coordinator Habitat Conservation Program DATE: April 7, 1997 SUBJECT: Scoping comments for replacement of Bridge #80 along SR 1136 over Clark's Creek, Watauga County, TIP #B-3262. This correspondence responds to a request by you for our review and preliminary comments regarding the subject project. Clark's Creek is a tributary to Dutch Creek, which is Hatchery Supported Designated Public Mountain Trout Water. According to our records, Clark's Creek supports wild rainbow trout. The North Carolina Department of Transportation is proposing to replace the existing bridge with a new bridge. We have the following recommendations for minimizing impacts to fisheries resources: I) lnstream work and land disturbance within the 25-foot wide buffer zone should be prohibited during the rainbow trout spawning season of November 1 through April 15 to protect the egg and fry stages of trout. 2) If concrete will be used, work must be accomplished so that wet concrete does not contact stream water. This will lessen the chance of altering the stream's water chemistry and causing a fish kill. 3) 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. 4) Temporary or permanent herbaceous vegetation should be planted on all bare soil within 15 days of ground disturbing activities to provide long-term erosion control. If seeding is done after 1 October 1997, then the NCDOT should return after I April 1998 to reseed if necessary. 5) Trees along the stream should be preserved as much as possible to provide shade and nutrient input to the stream. Thank you for the opportunity to review and comment during the early stages of this project. If you have any questions regarding these comments, please contact me at 704/652-4257. e,,. AATF o ???t rf t?3 s t' North Carolina Department of Cultural Resources James B. Hunt Jr., Governor Betty Ray McCain, Secretary April 4, 1997 Nicholas L. Graf Division Administrator Federal Highway Administration Department of Transportation 310 New Bern Avenue Raleigh, N.C. 27601-1442 Re: Bridge 80 on SR 1136 over Clark's Creek, Watauga County, B-3262, Federal Aid Project MABRZ-1136(1), State Project 8.2751001, ER 97-8348 Dear Mr. Graf: Division of Archives and History Jeffrey J. Crow, Director On March 11, 1997, Debbie Bevin of our staff met with North Carolina Department of Transportation (NCDOT) staff for a meeting of the minds concerning the above project. We reported our available information on historic architectural and archaeological surveys and resources along with our recommendations. NCDOT provided project area photographs and aerial photographs at the meeting. Based upon our review of the photographs and the information discussed at the meeting, we offer our preliminary comments regarding this project. In terms of historic architectural resources, we are aware of no historic structures located within the area of potential effect. We recommend that no historic architectural survey be conducted for this project. A survey for archaeological resources should be conducted for replacement of the bridge on a new location. Having provided this information, we look forward to receipt of either a Categorical Exclusion or Environmental Assessment which indicates how NCDOT addressed our comments. The above comments are made pursuant to Section 106 of the National Historic Preservation Act of 1966 and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106, codified at 36 CFR Part 800. 109 East Jones Street • Raleigh, North Carolina 27601-2807 ?0;?Y ? Nicholas L. Graf 4/4/97, Page 2 Thank you for your cooperation and consideration. If you have questions concerning the above comment, please contact Renee Gledhill-Earley, environmental review coordinator, at 919/733-4763. Sincerely, / Da Brook Deputy State Historic Preservation Officer DB:slw cc: ?/ H. F. Vick B. Church T. Padgett 10 North Carolina Department of Cultural Resources James B. Hunt Jr., Governor Betty Ray McCain, Secretary July 9, 1998 Nicholas L. Graf Division Administrator Federal Highway Administration Department of Transportation 310 New Bern Avenue Raleigh, N.C. 27601-1442 Re: Replacement of Bridge 80 on SR 1 136 over Clarks Creek, Watauga County, Federal Aid Project MABRZ-1136(1), State Project 8.2751001, TIP B-3262, ER 98-9251 Dear Mr. Graf: Division of Archives and History Jeffrey J. Crow, Director /?v E I V EO JUL 13 1998 2 HIGH:"JA?S ,?? Thank you for your letter of June 12, 1998, transmitting the archaeological survey report by Thomas J. Padgett concerning the above project. During the course of the survey no sites were located within the project area. Mr. Padgett has recommended that no further archaeological investigation be conducted in connection with this project. We concur with this recommendation since this project will not involve significant archaeological resources. - The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR Part 800. Thank you for your cooperation and consideration. If you have questions concerning the above comment, please contact Renee Gledhill-Earley, environmental review coordinator, at 919/733-4763. Sincerely, David Brook Deputy State Historic Preservation Officer DB:slw cc: L-4. D. Gilmore T. Padgett 109 East Jones Street • Raleieh, North Carolina 27601-2807 ???