20140039 Ver 1_Other Agency Comments_20130204

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh NC 27699-1721
Telephone: [phone] · Fax: [phone]

TO: Andrew Williams, Regulatory Project Manager
Raleigh Regulatory Field Office, USACE

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

DATE: February 3, 2014

SUBJECT: Review of NCDOT’s application for a Section 404 permit to replace Bridge No.
193 over Brier Creek on SR 2324 (Red White and Blue Road), Wilkes County,
North Carolina.

The North Carolina Department of Transportation (NCDOT) has submitted an application to
obtain a Section 404 Permit from the U.S. Army Corps of Engineers (USACE). Staff biologists
with the North Carolina Wildlife Resources Commission (NCWRC) have reviewed the
information provided. These 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.

The NCDOT proposes to replace Bridge No. 193 over Brier Creek on SR 2324 (Red White and
Blue Road) with another bridge structure on slightly different alignment. Permanent impacts
total 34 linear feet (lf) for bank armoring and temporary impacts consist of 20 lf for dewatering.
Brier Creek (Class C) is not expected to support trout; therefore, we are not requesting a trout
moratorium. Brier Creek flows into the Yadkin River just downstream, where the Brook Floater
(Alasmidonta varicosa), a Federal Species of Concern and State-listed Endangered mussel
species, occurs. To protect the sensitive resources downstream, we request that NCDOT and
their contractors take extra care to prevent offsite sedimentation.

NCWRC can concur with the issuance of the Section 404 permit provided that the following
conditions are implemented:

Bridge No. 193, SR 2324 (Red White and Blue Rd.)
Brier Creek, Wilkes County 2 February 3, 2014

1. Stringent sedimentation and erosion control measures must be implemented and
maintained on the project site until project completion to avoid impacts to downstream
aquatic resources.

2. Herbaceous vegetation shall be planted on all bare soil as soon as possible following the
completion of permanent or temporary ground disturbing activities to provide appropriate
long-term erosion control.

3. Tall fescue and straw mulch shall not be used in riparian areas. We encourage NCDOT
to utilize onsite vegetation and materials for bank stabilization when practicable. Erosion
control matting shall be used on steep slopes and for establishing permanent vegetation in
riparian areas. The matting shall be well anchored with staples or wooden stakes and,
whenever possible, include live stakes of native trees. Matting in riparian areas should
not contain plastic mesh, which can entangle and trap small animals.

4. Stormwater should be directed to buffer areas or retention basins and should not be
routed directly into the waterway.

5. The natural dimension, pattern, and profile of the waterway above and below the crossing
should not be modified by widening the channel or changing the depth of the waterway.

6. Removal of vegetation in riparian areas should be minimized. Native trees and shrubs
should be planted along the banks, as appropriate to the setting, to reestablish the riparian
zone and to provide long-term erosion control.

7. Grading and backfilling should be minimized, and tree and shrub growth should be
retained if possible to ensure long term availability of shoreline cover for fish and
wildlife.

8. Where practicable, riprap placed for bank stabilization should be limited to the banks
below the high water mark, and vegetation should be used for stabilization above the high
water elevation.

9. If concrete will be used during construction, work must be accomplished so that wet
(uncured) concrete does not contact surface waters. This will lessen the chance of
altering the water chemistry and causing a fish kill.

10. Discharging hydroseeding mixtures and washing out hydroseeders and other equipment
in or adjacent to surface waters is prohibited.

11. Heavy equipment should be operated from the bank rather than in the channel whenever
possible in order to minimize sedimentation and reduce the likelihood of introducing
other pollutants into the waterway. All mechanized equipment operated near surface
waters should be inspected and maintained regularly to prevent contamination of surface
waters from fuels, lubricants, hydraulic fluids or other toxic materials.
Bridge No. 193, SR 2324 (Red White and Blue Rd.)
Brier Creek, Wilkes County 3 February 3, 2014

Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at [phone].

cc: Heath Slaughter, NCDOT
Amy Chapman, NCDWR