20211243 Ver 1_Pre-Filing Meeting Information_20210907

o�""srA7r
r ti �4, -f1,-;
ROY COOPER y
Governor 1 u
C
MICHAEL S.REGAN '' n.,,
Secretary
LINDA CULPEPPER NORTH CAROLINA
Dire(for Environmental Quality
May 16,2019
MEMORANDUM
To: Lyn Hardison,Environmental Assistance and SEPA Coordinator o^^s
From: Dave Wanucha,NC Division of Water Resources,Winston Salem Regional Office�J�S/16/2019
Subject: Comments to Draft Environmental Assessment for Blue Ridge Parkway Projects 2D17 and 2A16,Ashe
and Alleghany Counties;National Park Service and Federal Highway Administration; SEPA/NEPA
Project No.19-0242.
Reference your electronic correspondence dated May 13,2019 in which you requested comments. The Assessment
outlines the potential for multiple impacts to streams and jurisdictional wetlands in the project area. More
specifically,impacts to:
Stream Name River Basin Stream Stream Index 303(d)Listing
Classification(s) Number
Cranberry Creek B and Tr+ 10-1-37
Big Pine Creek New C and Tr 10-9-10-4 No
Brush Creek 10-9-10
Notes: C-basic water quality standards for all fresh waters;B-recreational use;Tr is Trout waters;+is Outstanding Resource Waters(ORW)
present downstream.
The NC Division of Water Resources requests that the National Park Service(NPS)and the Federal Highway
Administration(FHWA)consider the following environmental issues for the proposed project,most of which were
previously submitted on September 5,2018 during the planning stages of your proposed projects.
General Project Comments:
1. The NCDWR recommends that the most protective sediment and erosion control BMPs be implemented to
reduce the risk of turbidity violations in Trout waters. In addition,all disturbances within trout buffers should
be conducted in accordance with NC Division of Land Resources and NC Wildlife Resources Commission
requirements.
2. In accordance with the Environmental Management Commission's Rules(15A NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 300 linear feet to any perennial stream. In the event
that mitigation is required,the mitigation plan shall be designed to replace appropriate lost functions and
values. The North Carolina Division of Mitigation Services may be available for assistance with stream
mitigation.
3. Future documentation,including the 401 Water Quality Certification Application,shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
...
1;, NorthCarolinaDepartment of Environmental Quality I DivisionofWaterResources 512 North Salisbury Street 11617 Mail Service Center I Raleigh.North Carolina 27699 1617
4
Department of ee.romrIeom Na t. 919.707.9000

4. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NPS and FHWA shall address these concerns by describing the potential impacts that may occur to the
aquatic environments and any mitigating factors that would reduce the impacts.
5. All impacts,including but not limited to,bridging,fill,excavation and clearing,and rip rap to jurisdictional
wetlands,streams,and riparian buffers need to be included in the final impact calculations. These impacts,in
addition to any construction impacts,temporary or otherwise,also need to be included as part of the 401
Water Quality Certification Application.
6. Whenever possible,the NCDWR prefers spanning structures. Spanning structures usually do not require
work within the stream or grubbing of the streambanks and do not require stream channel realignment. The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
structure.Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports(bents)
should not be placed in the stream when possible.
7. Sediment and erosion control measures should not be placed in wetlands or streams.
8. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
9. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically,stormwater shall not be permitted to discharge directly into
streams or surface waters. Please refer to the most recent version of the North Carolina Department of
Transportation Stormwater Best Management Practices Toolbox manual for approved measures.
10. Based on the information presented in the document,the magnitude of impacts to wetlands and streams may
require a Nationwide(NW)application to the Corps of Engineers and corresponding 401 Water Quality
Certification. Please be advised that a 401 Water Quality Certification requires satisfactory protection of
water quality to ensure that water quality standards are met, and no wetland or stream uses are lost. Final
permit authorization will require the submittal of a formal application by the NCDOT and written concurrence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and stream impacts to the maximum extent practical,the development of an
acceptable stormwater management plan,and the inclusion of appropriate mitigation plans where appropriate.
11. If concrete is used during construction,a dry work area shall be maintained to prevent direct contact between
curing concrete and stream water. Water that inadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
12. If temporary access roads or detours are constructed,the site shall be graded to its preconstruction contours
and elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. When using temporary structures,the area shall 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 re-vegetate naturally and minimizes soil disturbance.
13. If foundation test borings are necessary;it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 4085/Nationwide Permit No. 6 for Survey Activities.
14. Sediment and erosion control measures sufficient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Control
Planning and Design Manual.
15. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most current version of the NC Department of Transportation Construction and Maintenance
Activities manual such as sandbags,rock berms,cofferdams and other diversion structures shall be used to
prevent excavation in flowing water.

16. Heavy equipment should be operated from the bank rather than in stream channels to minimize sedimentation
and reduce the likelihood of introducing other pollutants into streams. This equipment shall be inspected
daily and maintained to prevent contamination of surface waters from leaking fuels,lubricants,hydraulic
fluids,or other toxic materials.
17. Riprap shall 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 properly designed, sized and installed.
18. Riparian vegetation(native trees and shrubs)shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
following completion of construction.
Thank you for requesting our input at this time. The NPS and FHWA are 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 Dave Wanucha at(336)776-9703 or [e-mail].
Electronic copy only distribution:
File Copy