BP11.R006.1_Ashe 157_NCWRC Scoping Comments.pdf

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9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
May 4,2022
Mark Johnson
NCDOT Division 11
801 Statesville Road
North Wilkesboro,NC 28659
Dear Mr. Johnson,
Subject Scoping Comments on Replacement of Bridge No. 040157 on Big Peak Creek Road over
Peak Creek,Ashe County. TIP BP11.R006.1
The North Carolina NC Department of Transportation(NCDOT)requested comments from the North
Carolina Wildlife Resources Commission(NCWRC) on impacts of the subject bridge replacement project
on fish and wildlife habitats.NCWRC biologists reviewed the information and are familiar with the
wildlife resources that may be affected by the project. The following comments are provided in
accordance with the applicable provisions of the state and federal Environmental Policy Acts(G.S. 113A-
lthrough 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).
Project-Specific Comments
Peak Creek at the bridge is classified as B Tr+but it is not designated trout water by the NCWRC. There is a
derelict ore mine upstream of the site that is continuing to impact Ore Knob Branch and Peak Creek further
downstream. Wild trout reproduction is not anticipated in Peak Creek near the bridge so the NCWRC would
waive the trout moratorium on any associated permit for the project. Despite the mine's effects,Peak Creek
may support some rare fishes such as Kanawha darter(Etheostoma kanawhae)and Kanawha minnow
(Phenacobius teretulus). Moreover,the South Fork of the New River at the confluence with Peak Creek is
classified B ORW and is designated as a National Wild and Scenic River. Therefore,the NCWRC
recommends incorporating HQW measures from the current NCDOT Erosion and Sediment Control Design
and Construction Manual into the project.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh,NC 27699-1721
Telephone: [phone] • Fax: [phone]

BP11.R006.1 Page 2 May 4,2022
Ashe County
General Comments
In trout waters,the NCWRC reviews all U.S. Army Corps of Engineers Nationwide and general permits.
The NCWRC often requests additional conservation measures to protect trout and trout habitat and may
recommend that the project require an individual permit when appreciable habitat losses or damage are
anticipated.
Bridges are typically recommended over culverts for multiple reasons. They usually require less work in
streams and do not require channel modifications,the latter of which preserves aquatic life passage and
navigation,as applicable. Larger clearances that are afforded by bridges typically accommodate human
and wildlife movements as well. Additionally, culverts often prove difficult to temporarily dewater
during construction,which leads to longer periods of disturbance and channel instability and erosion
during flooding.
NCWRC standard recommendations for bridge replacement projects of this scope include:
1. Existing structures should be replaced on existing alignment using an off-site detour or staged
construction. If the structure will be on a new alignment,then the old structure and the approach fills
should be removed to natural ground elevations and from the 100-year floodplain,as applicable.
1. Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be adhered to. Tall fescue and straw mulch must not be used in riparian
areas. Matting used in riparian areas should not contain nylon mesh because it entangles and kills
wildlife. Coir matting should be used on disturbed stream banks that are steep or susceptible to high
water and securely anchored with wooden stakes according to NCDOT specifications.
2. Temporary detours should be designed and located to avoid wetland impacts,minimize the need for
clearing, and to avoid destabilizing stream banks. Tree stumps and root mats should be left where
possible under and along temporary access roads to limit streambank disturbance and promote
regrowth of vegetation. Temporary fills should be removed to original ground elevations upon the
completion of the project. Disturbed areas should be seeded or mulched and native tree species should
be planted with a spacing of not more than 10'x10'
3. A clear strip of streambank(rip rap free) of at least 10 feet in width should remain on each side of the
channels underneath bridges to facilitate wildlife passage. The path can be constructed with a finer
stone top-dressing if hydraulic analyses or other factors require full bank plating.
4. All work in or adjacent to streams should be conducted in dry work areas. Sandbags,rock berms,
cofferdams, or other clean diversion structures should be used where possible to avoid excavation in
flowing water.
5. Only clean, sediment-free rock should be used as temporary fill(e.g. causeways)and fills should be
removed without excessive disturbance of the natural stream bottoms upon project completion.
6. Concrete pouring and heavy equipment use,including drills used for geotechnical studies, should be
closely monitored and the hoses and fittings inspected and maintained to minimize spills in waters.

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Ashe County
7. Inter-agency field scoping often helps identify constructability,traffic control,and other site-specific
issues that can affect design, and correspondingly the impacts of projects on fish and wildlife habitats.
Some issues may not be readily identified by desk-top scoping, or even in later CFI reviews. NCWRC
staff welcomes field review opportunities if desired by NCDOT and as scheduling allows.
8. Culverts used for bridge replacements must be designed to allow for aquatic life and fish passage in
accordance with current hydraulic design guidelines. This generally includes burial of a single low flow
barrel at least 1 foot below the natural streambed(measured from the natural thalweg depth)and
backfilling of the barrel with native material. If multiple barrels are required,then the high flow barrel(s)
should be placed on or near a bankfull elevation. These"flood"barrels should be reconnected to benches
and include sills on the upstream ends to restrict or divert base flow into the low barrel. Barrels with sills
should be filled with sediment to avoid standing water. If rip rap is used for backfill,then it should also
be topped with native or other finer material to facilitate wildlife passage. Alternating or notched baffles
should typically be installed in culverts that are longer than 40-50 linear feet in a manner that mimics the
existing stream pattern and profile in the culvert.
9. Culverts should be aligned with the existing channel alignment whenever possible. Widening the
stream channel must be avoided to avoid sediment aggradation.
10. Riprap should be avoided on streambeds except where bed degradation may be expected. Rip rap
placed on the streambed should be embedded or"keyed-in"to prevent or shorten the duration of
streamflow burial.
Please contact me at david.mcheMkncwildlife.org or(828)476-1966 if you have any questions about
these comments. Thank you for the opportunity to review and comment on this project. The NCWRC
looks forward to assisting as needed as the project develops further.
Cordially,
Dave McHenry,NCWRC Western DOT Coordinator
ec: Kevin Hining,NCDOT Division 11 DEO
Randy Bowers,NCDOT Division 11
Elizabeth Oliver, STV Engineers Inc.
Dave Wanucha,NCDEQ,DWR