20051608 Ver 1_Other Agency Comments_20040709

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 9, 2004
Gregory J. Thorpe, Ph.D.
North Carolina Department of Transportation
Project Development and Environmental Analysis
1548 Mail Service Center
Raleigh, North Carolina 27699-1548
Dear Dr. Thorpe:
This letter is in response to your request for comments from the U.S. Fish and Wildlife Service
(Service) on the potential environmental impacts of the proposed replacement or refurbishment
of Bridge No. 60 on US 70 Business over the Trent River in Craven County, North Carolina (TIP
No: B-2532). These comments provide scoping information in accordance with provisions of the
Fish and Wildlife Coordination Act (16 U.S.C. 661-667d) and section 7 of the Endangered
Species Act (ESA) of 1973, as amended (16 U.S.C. 1531-1543).
Recent aerial photography reveals the highly disturbed nature of the project area. Very little
terrestrial habitat remains. However, aquatic habitat value is significant. For bridge replacement
projects, the Service recommends the following general conservation measures to avoid or
minimize environmental impacts to fish and wildlife resources:
Wetland, forest and designated riparian buffer impacts should be avoided and minimized
to the maximum extent practical;
2. If unavoidable wetland impacts are proposed, every effort should be made to identify
compensatory mitigation sites in advance. Project planning should include a detailed
compensatory mitigation plan for offsetting unavoidable wetland impacts. Opportunities
to protect mitigation areas in perpetuity via conservation easements, land trusts or by
other means should be explored at the outset;
Off-site detours should be used rather than construction of temporary, on-site bridges.
For projects requiring an on-site detour in wetlands or open water, such detours should be
aligned along the side of the existing structure which has the least and/or lowest quality
of fish and wildlife habitat. At the completion of construction, the detour area should be
entirely removed and the impacted areas should be planted with appropriate vegetation,
including trees if necessary;

4. Wherever appropriate, construction in sensitive areas should occur outside fish spawning
and migratory bird nesting seasons. In waterways that may serve as travel corridors for
fish, in-water work should be avoided during moratorium periods associated with
migration, spawning and sensitive pre-adult life stages. The general moratorium period
for anadromous fish is February 15 -June 30;
New bridges should be long enough to allow for sufficient wildlife passage along stream
corridors;
6. Best Management Practices (BMP) for Protection of Surface Waters should be
implemented;
7. Bridge designs should include provisions for roadbed and deck drainage to flow through
a vegetated buffer prior to reaching the affected stream. This buffer should be large
enough to alleviate any potential effects from run-off of storm water and pollutants;
8. The bridge designs should not alter the natural stream and stream-bank morphology or
impede fish passage. To the extent possible, piers and bents should be placed outside the
bank-full width of the stream;
9. Bridges and approaches should be designed to avoid any fill that will result in damming
or constriction of the channel or flood plain. If spanning the flood plain is not feasible,
culverts should be installed in the flood plain portion of the approach to restore some of
the hydrological functions of the flood plain and reduce high velocities of flood waters
within the affected area.
There are five federally protected species listed for Craven County: the bald eagle (Haliaeetus
leucocephalus), leatherback sea turtle (Dermochelys coriacea), West Indian manatee (Trichechus
manatus), red-cockaded woodpecker (Picoides borealis) and sensitive jointvetch (Aeschynomene
virginica). Information about the habitats in which these species are often found is provided on
our web site, http://endangered.fws.gov/ . It appears that no habitat exists in the project vicinity
for the red-cockaded woodpecker. The North Carolina Natural Heritage Program (NCNHP)
database indicates two historical occurrences of sensitive jointvetch in the project area.
Although their current presence is questionable due to the developed nature of the site, this
should be verified with a field survey during the flowering season if any habitat remains for the
species. The NCNHP database also indicates a 1994 occurrence of the West Indian manatee in
the project vicinity. The Service's "Guidelines For Avoiding Impacts To The West Indian
Manatee" should be fully implemented to avoid effects to this species. These recently revised
guidelines can be found at the following website: http://nc-es.fws.gov/mammal/mammal.html .
Surveys should also be conducted for bald eagles and nests if any habitat exists within cone-half
mile radius of the project site. Any survey documentation must include methodologies and
results.
We reserve the right to review any federal permits that maybe required for this project, at the
public notice stage. Therefore, it is important that resource agency coordination occur early in
the planning process in order to resolve any conflicts that may arise and minimize delays in
project implementation. In addition to the above guidance, we recommend that the
environmental documentation for this project include the following in sufficient detail to
facilitate a thorough review of the action:

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1. A clearly defined and detailed purpose and need for the proposed project;
2. A description of the proposed action with an analysis of all alternatives being considered,
including the "no action" alternative;
3. A description of the fish and wildlife resources, and their habitats, within the project
impact area that maybe directly or indirectly affected;
4. The extent and acreage of waters of the U. S., including wetlands, that are to be impacted
by filling, dredging, clearing, ditching, or draining. Acres of wetland impact should be
differentiated by habitat type based on the wetland classification scheme of the National
Wetlands Inventory (NWI). Wetland boundaries should be determined by using the 1987
Corps of Engineers Wetlands Delineation Manual and verified by the U.S. Army Corps
of Engineers;
5. The anticipated environmental impacts, both temporary and permanent, that would be
likely to occur as a direct result of the proposed project. The assessment should also
include the extent to which the proposed project would result in secondary impacts to
natural resources, and how this and similar projects contribute to cumulative adverse
effects;
6. Design features and construction techniques which would be employed to avoid or
minimize impacts to fish and wildlife resources, both direct and indirect, and including
fragmentation and direct loss of habitat;
7. If unavoidable wetland or stream impacts are proposed, project planning should include a
detailed compensatory mitigation plan for offsetting the unavoidable impacts.
The Service appreciates the opportunity to comment on this project. Please continue to advise us
during the progression of the planning process, including your official determination of the
impacts of this project. If you have any questions regarding our response, please contact Mr.
Gary Jordan at [phone], ext. 32.
Sincerely,
~` ~~
John Hammond
Ecological Services Acting Supervisor
cc: Mike Bell, USACE, Washington, NC
Nicole Thomson, NCDWQ, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
Chris Militscher, USEPA, Raleigh, NC