20210046 Ver 1_WRC Comments_20210312

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

July 12, 2016

M E M O R A N D U M

TO: Carla Dagnino, Western Region Environmental Program Supervisor II
Natural Environment Section, PDEA, NCDOT

FROM: Marla Chambers, Western NCDOT Coordinator
Habitat Conservation Program, NCWRC

SUBJECT: Scoping review of NCDOT’s proposed bridge replacement projects in NCDOT
Divisions 9, 11, 13 and 14; Stokes, Ashe, Surry, Yadkin, Buncombe, Madison,
McDowell, Mitchell, Rutherford, Cherokee, Clay, Haywood and Henderson
Counties. TIP Nos. B-5766, B-5823, B-5831, B-5837, B-5825, B-5833, B-5866,
B-5891, B-5883, B-5895, B-5917, B-5868, B-5875, B-5893, B-5871, B-5876, B-
5926, B-5911, B-5541, B-5900, B-5901 and B-5922.

North Carolina Department of Transportation has requested comments from the North Carolina
Wildlife Resources Commission regarding impacts to fish and wildlife resources resulting from
the subject project. Staff biologists have reviewed the information provided. The following
preliminary comments are provided in accordance with the provisions of the state and federal
Environmental Policy Acts (G.S. 113A-1through 113-10; 1 NCAC 25 and 42 U.S.C. 4332(2)(c),
respectively), the Clean Water Act of 1977 (33 U.S.C. 466 et seq.) and the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d), as applicable.

Our standard recommendations for bridge replacement projects of this scope are as follows:

1. We generally prefer spanning structures. Spanning structures usually do not require work
within the stream and do not require stream channel realignment. The horizontal and
vertical clearances provided by bridges allows for human and wildlife passage beneath
the structure, does not block fish passage, and does not block navigation by canoeists and
boaters.

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

BRIDGE PROJECTS
NCDOT DIVISION 9. 11, 13 & 14 PAGE 2 JULY 12, 2016
2. Bridge deck drains should not discharge directly into the stream.

3. Live concrete should not be allowed to contact the water in or entering into the stream.

4. If possible, bridge supports (bents) should not be placed in the stream.

5. If temporary access roads or detours are constructed, they should be removed back to
original ground elevations immediately upon the completion of the project. Disturbed
areas should be seeded or mulched to stabilize the soil and native tree species should be
planted with a spacing of not more than 10’x10’. If possible, when using temporary
structures the area should be cleared but not grubbed. Clearing the area with chain saws,
mowers, Bush Hogs, or other mechanized equipment and leaving the stumps and root mat
intact, allows the area to revegetate naturally and minimizes disturbed soil.

6. A clear bank (riprap free) area of at least 10 feet should remain on each side of the stream
underneath the bridge.

7. In trout waters, the Commission reviews all U.S. Army Corps of Engineers nationwide
and general ‘404’ permits. We have the option of requesting additional measures to
protect trout and trout habitat and we can recommend that the project require an
individual ‘404’ permit.

8. In streams that contain threatened or endangered species, Mr. Logan Williams with the
NCDOT - ONE should be notified. Special measures to protect these sensitive species
may be required. NCDOT should also contact the U.S. Fish and Wildlife Service for
information on requirements of the Endangered Species Act as it relates to the project.

9. In streams that are used by anadromous fish, the NCDOT official policy entitled “Stream
Crossing Guidelines for Anadromous Fish Passage” (May 12, 1997) should be followed.

10. In areas with significant fisheries for sunfish, seasonal exclusions may also be
recommended.

11. Sedimentation and erosion control measures sufficient to protect aquatic resources must
be implemented prior to any ground disturbing activities. Structures should be maintained
regularly, especially following rainfall events.

12. 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.

13. All work in or adjacent to stream waters should be conducted in a dry work area. Sandbags,
rock berms, cofferdams, or other diversion structures should be used where possible to
prevent excavation in flowing water.

BRIDGE PROJECTS
NCDOT DIVISION 9. 11, 13 & 14 PAGE 3 JULY 12, 2016
14. Heavy equipment should be operated from the bank rather than in stream channels in order to
minimize sedimentation and reduce the likelihood of introducing other pollutants into
streams.

15. Only clean, sediment-free rock should be used as temporary fill (causeways), and should be
removed without excessive disturbance of the natural stream bottom when construction is
completed.

16. During subsurface investigations, equipment should be inspected daily and maintained to
prevent contamination of surface waters from leaking fuels, lubricants, hydraulic fluids, or
other toxic materials.

17. If culvert installation is being considered, conduct subsurface investigations prior to structure
design to determine design options and constraints and to ensure that wildlife passage issues
are addressed.

If corrugated metal pipe arches, reinforced concrete pipes, or concrete box culverts are used:

1. The culvert must be designed to allow for aquatic life and fish passage. Generally, the
culvert or pipe invert should be buried at least 1 foot below the natural streambed
(measured from the natural thalweg depth). If multiple barrels are required, barrels other
than the base flow barrel should be placed on or near stream bankfull or flood plain bench
elevation (similar to Lyonsfield design). These should be reconnected to flood plain
benches as appropriate. This may be accomplished by utilizing sills on the upstream end
to restrict or divert flow to the base flow barrel. Silled barrels should be filled with
sediment so as not to cause noxious or mosquito breeding conditions. Sufficient water
depth should be provided in the base flow barrel during low flows to accommodate fish
movement. If culverts are longer than 40-50 linear feet, alternating or notched baffles
should be installed in a manner that mimics existing stream pattern. This should enhance
aquatic life passage: 1) by depositing sediments in the barrel, 2) by maintaining channel
depth and flow regimes and 3) by providing resting places for fish and other aquatic
organisms. In essence, the base flow barrel should provide a continuum of water depth
and channel width without substantial modifications of velocity.

2. If multiple pipes or cells are used, at least one pipe or box should be designed to remain
dry during normal flows to allow for wildlife passage.

3. Culverts or pipes should be situated along the existing channel alignment whenever
possible to avoid channel realignment. Widening the stream channel must be avoided.
Stream channel widening at the inlet or outlet end of structures typically decreases water
velocity causing sediment deposition that requires increased maintenance and disrupts
aquatic life passage.

4. Riprap should not be placed in the active thalweg channel or placed in the streambed in a
manner that precludes aquatic life passage. Bioengineering boulders or structures should
be professionally designed, sized, and installed.

BRIDGE PROJECTS
NCDOT DIVISION 9. 11, 13 & 14 PAGE 4 JULY 12, 2016

In most cases, we prefer the replacement of the existing structure at the same location with road
closure. If road closure is not feasible, a temporary detour should be designed and located to
avoid wetland impacts, minimize the need for clearing and to avoid destabilizing stream banks.
If the structure will be on a new alignment, the old structure should be removed and the approach
fills removed from the 100-year floodplain. Approach fills should be removed down to the
natural ground elevation. The area should be stabilized with grass and planted with native tree
species. Tall fescue should not be used in riparian areas. If the area that is reclaimed was
previously wetlands, NCDOT should restore the area to wetlands. If successful, the site may be
used as wetland mitigation for the subject project or other projects in the watershed.

Project specific comments:

1. B-5766, Stokes County, Bridge No. 82 over Dan River on SR 1674 (Sheppard Mill Road).
Several listed aquatic species, including the Federally Endangered James Spinymussel
(Pleurobema collina), occur in the Dan River in the project vicinity. Significant trout resources
are not expected, therefore, we are not requesting a trout moratorium for this project. Sediment
and erosion control measures should adhere to the Design Standards in Sensitive Watersheds to
minimize negative impacts to sensitive resources.

2. B-5823, Ashe County, Bridge No. 355 over South Fork New River on SR 1181 (Hartzog Ford
Road). Several listed aquatic species, including a Federally Species of Concern, Kanawha
Minnow (Phenacobius teretulus), may be present. The South Fork New River is classified High
Quality Waters and provides important fishing and recreational opportunities. We request that
NCDOT work with our agency to investigate potential public access at this site in accordance
with our agreement. Significant trout resources are not expected, therefore, we are not requesting
a trout moratorium for this project. Sediment and erosion control measures should adequately
prevent off-site sedimentation to minimize negative impacts to the sensitive resources and water
quality. Design Standards in Sensitive Watersheds is recommended.

3. B-5831, Surry County, Bridge No. 6 over NC 268, Southern Railroad and the Yadkin River on I-
77 North Bound Lane. Rare aquatic species, including the mussels Brook Floater (Alasmidonta
varicosa), Federal Species of Concern and State Endangered, and the Creeper (Stophitus
undulatus), State Threatened, may occur in the Yadkin River in the project vicinity. Significant
trout resources are not expected, therefore, we are not requesting a trout moratorium for this
project. Sediment and erosion control measures should adequately prevent off-site sedimentation
to minimize negative impacts to sensitive resources. Design Standards in Sensitive Watersheds is
recommended.

4. B-5837, Surry County, Bridge No. 129 over Flat Shoal Creek on SR 2017 (Ararat Longhill
Road). Flat Shoal Creek joins the Ararat River immediately downstream. Significant trout
resources are not expected, therefore, we are not requesting a trout moratorium for this project.
Stringent sedimentation and erosion control measures and standard recommendations should
apply.

BRIDGE PROJECTS
NCDOT DIVISION 9. 11, 13 & 14 PAGE 5 JULY 12, 2016
5. B-5825, Yadkin County, Bridge No. 35 over the Yadkin River on NC 67. Rare aquatic species,
including the mussels Brook Floater (Alasmidonta varicosa), Federal Species of Concern and
State Endangered, and the Creeper (Stophitus undulatus), State Threatened, occur in the Yadkin
River in the project vicinity. A county park exists at one end of the bridge and has a primitive
boat ramp that NCWRC is scheduled to renovate in this fiscal year. We request that NCDOT
coordinate with us early in the planning process to ensure our projects do not conflict. Significant
trout resources are not expected, therefore, we are not requesting a trout moratorium for this
project. Sediment and erosion control measures should adequately prevent off-site sedimentation
to minimize negative impacts to sensitive resources. Design Standards in Sensitive Watersheds is
recommended.

6. B-5833, Yadkin County, Bridge No. 29 over I-77 on US 21. The presence of water resources
within the project area is unclear. It appears the project drains to Sandyberry Creek, a tributary of
the Yadkin River. Significant trout resources are not expected, therefore, we are not requesting a
trout moratorium for this project. Stringent sedimentation and erosion control measures and
standard recommendations should apply.

7. B-5866, Buncombe County, Bridge No. 41 over Swannanoa River on SR 2500 (Black Mt.
Road). The Hellbender (Cytobranchis alleghanii), Federal Species of Concern and State Special
Concern, may occur. Swannanoa River is on the 303(d) list of impaired waters in the project
area. Significant trout resources are not expected, therefore, we are not requesting a trout
moratorium for this project. Sediment and erosion control measures should adequately prevent
off-site sedimentation to minimize negative impacts to sensitive resources and further
degradation of the waterway. Design Standards in Sensitive Watersheds is recommended.

8. B-5891, Buncombe County, Bridge No. 715 over Lee Creek on SR 1790 (Powell Road).
Significant trout resources are not expected, therefore, we are not requesting a trout moratorium
for this project. Stringent sedimentation and erosion control measures and standard
recommendations should apply.

9. B-5883, Madison County, Bridge No. 144 over Big Pine Creek on SR 1151 (Big Pine Road).
Brown Trout occur in the project area. A moratorium prohibiting in-stream work and land
disturbance within the 25-foot trout buffer is recommended from October 15 to April 15 to
protect the egg and fry stages of trout. Sediment and erosion control measures should adhere to
the Design Standards in Sensitive Watersheds.

10. B-5895, Madison County, Bridge No. 67 over the French Broad River and a private drive on US
25/US 70. Numerous federal and state listed aquatic species occur in the French Broad River in
the project vicinity. Significant trout resources are not expected, therefore, we are not requesting
a trout moratorium for this project. Sediment and erosion control measures should adequately
prevent off-site sedimentation to minimize negative impacts to the sensitive resources. Design
Standards in Sensitive Watersheds is strongly recommended.

11. B-5868, McDowell County, Bridge No. 267 over the Catawba River on SR 1103 (Batcave
Road). Sensitive and listed species occur downstream, including the Brook Floater (Alasmidonta
varicosa), Federal Species of Concern and State Endangered. Significant trout resources are not

BRIDGE PROJECTS
NCDOT DIVISION 9. 11, 13 & 14 PAGE 6 JULY 12, 2016
expected, therefore, we are not requesting a trout moratorium for this project. Sediment and
erosion control measures should adequately prevent off-site sedimentation to minimize negative
impacts to the sensitive resources downstream. Design Standards in Sensitive Watersheds may
be appropriate.

12. B-5875, McDowell County, Bridge No. 77 over Johns Creek on SR 1501. Significant trout
resources are not expected, therefore, we are not requesting a trout moratorium for this project.
Stringent sedimentation and erosion control measures and standard recommendations should
apply.

13. B-5893, Mitchell County, Bridge No. 19 over Cub Creek on NC 226. Cub Creek joins Cane
Creek immediately downstream, which flows into the North Toe River a short ways further
downstream. The federally Endangered Appalachian Elktoe (Alasmidonta raveneliana) occurs in
the North Toe River near the confluence, where the river is Designated Critical Habitat.
Significant trout resources are not expected, therefore, we are not requesting a trout moratorium
for this project. Sediment and erosion control measures should adhere to the Design Standards in
Sensitive Watersheds to minimize negative impacts to the sensitive resources.

14. B-5871, Rutherford County, Bridge No. 628 over Lake Lure dam and Broad River on SR 1306
(Buffalo Shoals Road). Significant trout resources are not expected, therefore, we are not
requesting a trout moratorium for this project. Stringent sedimentation and erosion control
measures and standard recommendations should apply.

15. B-5876, Rutherford County, Bridge Nos. 83 and 84 over the Second Broad River on US 74
Bypass. Significant trout resources are not expected, therefore, we are not requesting a trout
moratorium for this project. Stringent sedimentation and erosion control measures and standard
recommendations should apply.

16. B-5925, Cherokee County, Bridge No. 223 over the Hiwassee River on SR 1548 (Old Road).
Several federal and state listed aquatic species occur in the Hiwassee River in the project
vicinity. Significant trout resources are not expected, therefore, we are not requesting a trout
moratorium for this project. Sediment and erosion control measures should adhere to the Design
Standards in Sensitive Watersheds to minimize negative impacts to the sensitive resources.

17. B-5911, Clay County, Bridge No. 41 over Sweetwater Creek on SR 1302 (or SR 1303, Lance
Cove Road?). The Smoky Dace, Clinostomus sp. nov., a Federal Species of Concern and State
Special Concern fish, and a crayfish on the Watch List, occur in Sweetwater Creek, which joins
the Hiwassee River not far downstream. Several federal and state listed aquatic species occur in
the Hiwassee River. Significant trout resources are not expected, therefore, we are not requesting
a trout moratorium for this project. Sediment and erosion control measures should adequately
prevent off-site sedimentation to minimize negative impacts to the sensitive resources. Design
Standards in Sensitive Watersheds is recommended.

18. B-5541, Haywood County, Bridge No. 236 over SR 1513 on I-40. It appears that this project
may impact an unnamed tributary to the Pigeon River. The tributary joins the river
approximately one half mile downstream, where the Pigeon River is on the 303(d) list of

BRIDGE PROJECTS
NCDOT DIVISION 9. 11, 13 & 14 PAGE 7 JULY 12, 2016
impaired waters. Sediment and erosion control measures should adequately prevent off-site
sedimentation to minimize further degradation of the waterway. Design Standards in Sensitive
Watersheds may be appropriate.

19. B-5900, Haywood County, Bridge No. 382 over Dutch Cove Creek on SR 1835 (Israel Road).
Significant trout resources are not expected, therefore, we are not requesting a trout moratorium
for this project. Stringent sedimentation and erosion control measures and standard
recommendations should apply.

20. B-5901, Henderson County, Bridge No. 121 over French Broad River Overflow on NC 191. In
addition to flood relief for the French Broad River, the bridge appears to cross an unnamed
tributary, near its origin, which joins the river about one half mile downstream. State Endangered
and Threatened mussel species (Slippershell Mussel, Alasmidonta viridis, and Creeper,
Strophitus undulatus) occur in the French Broad River not far downstream. Significant trout
resources are not expected, therefore, we are not requesting a trout moratorium for this project.
Sediment and erosion control measures should adequately prevent off-site sedimentation to
minimize negative impacts to the sensitive resources downstream. Design Standards in Sensitive
Watersheds may be appropriate.

21. B-5922, Henderson County, Bridge No. 237 over Southern Railroad on SR 1545. The presence
of water resources within the project area is unclear, however the project drains to Cane Creek,
which is on the 303(d) list of impaired waters in the project area. Records indicate the Blotched
Chub, Erimystax insignis, a Federal Species of Concern and State Significantly Rare fish, may
occur. Sediment and erosion control measures should adequately prevent off-site sedimentation
to minimize negative impacts to sensitive resources and further degradation of the waterway.
Design Standards in Sensitive Watersheds is recommended.

We request that NCDOT routinely minimize adverse impacts to fish and wildlife resources in the
vicinity of bridge replacements. The NCDOT should install and maintain sedimentation control
measures throughout the life of the project and prevent wet concrete from contacting water in or
entering into these streams. Replacement of bridges with spanning structures of some type, as
opposed to pipe or box culverts, is recommended in most cases. Spanning structures allow
wildlife passage along streambanks, reducing habitat fragmentation and vehicle related mortality
at highway crossings.

If you need further assistance or information on NCWRC concerns regarding bridge
replacements, please contact me at [e-mail] or [phone]. Thank
you for the opportunity to review and comment on this project.

cc: Andrew Henderson, USFWS