20211102 Ver 1_17BP.11.R.122_DWR 20211102v1_Bridge 27_Avery_GP Application__NCWRC Comments_20230126

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

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

January 26, 2023

Lori Beckwith
U.S. Army Corps of Engineers, Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801

Dave Wanucha
NCDEQ, DWR
450 Hanes Mill Road, Suite 300
Winston Salem, NC 27105

SUBJECT: Comments on GP/WQC Application for Replacement of Bridge 27 on US 221 over
Linville River, Avery County (WBS 17BP.11.R.122)
DWR 20211102 ver.1

Dear Ms. Beckwith and Mr. Wanucha,

The North Carolina Department of Transportation (NCDOT) applied for a General 404 Permit and 401
Certification for the subject project. North Carolina Wildlife Resources Commission (NCWRC) staff are
familiar with the wildlife resources in the project area but were unable to conduct a site visit or find prior
comments on this project. Comments on the application from the NCWRC are offered to help conserve
the wildlife resources affected by the project and to promote wildlife-based recreation in accordance with
applicable 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).

The project involves replacing the bridge on US 221 over the Linville River (B Tr) using causeways and
an on-site temporary detour. The new permanent bridge will have interior bents situated near the edge of
the river. NCDOT intends to remove the old bridge bents “in-the-wet” without installing causeways.

17BP.11.R.122 Page 2 January 26, 2023
Avery County
There are records for northern long-eared bat (NLEB, Myotis septentrionalis, US Endangered), little
brown bat (Myotis lucifugus, NC Significantly Rare), and eastern small-footed bat (Myotis leibii, NC
Special Concern) along the Linville River downstream of the project area. Tree clearing will be required
for the detour and utility relocations, though as noted in the application most of the affected vegetation
appears unsuitable for bat roosting. NCDOT has proposed a biological conclusion of “may affect not
likely to adversely affect” for NLEB.

The Linville River at the project site is designated by the NCWRC as a “hatchery supported” trout water.
In addition to this “put-and-take” fishery, the river also supports a naturally reproducing brown trout
(Salmo trutta) population. Although the trout designation extends upstream of the bridge, public access
to the river is limited.

Maintenance and possible improvements of parking for fishing access at the bridge are requested, and
would be much appreciated, by the NCWRC. The existing shoulder pull-off/parking on Pineola Baptist
Church Road is the furthest upstream stocking point on the Linville River. While the main portion of this
pull-off appears beyond the project footprint, the proposed guardrail may shorten it. The NCWRC would
appreciate consideration of this as well as improvements to an additional area. For example, it may be
possible to place, or leave in place, gravel within the newly acquired right-of way gravel southeast of the
intersection of US 221 and Tuttle Lane to accommodate a vehicle or two.

The NCWRC requests that the following conditions be included in authorizations to help conserve trout
and other aquatic resources affected by the project:
1. As noted in the application, the October 15 to April 15 trout moratorium should be followed for
land-disturbing activity within the trout buffer.
2. Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be adhered to. In accordance with standard GC conditions, 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.
Matting should be anchored with wooden stakes according to NCDOT specifications.
3. Heavy equipment needs to be well-maintained and concrete pouring needs to be closely
monitored to avoid and quickly mitigate fuel, fluid, or wet concrete losses in or near streams.
4. Removal of vegetation in riparian areas and wetlands should be minimized. Riparian vegetation
should be replanted where possible, such as within temporary detours following construction.
5. Sandbags, rock berms, cofferdams, or other diversion structures should be used where excavation
or other periods of extended stream disturbance has the potential for downstream sedimentation.
6. The natural dimension, pattern, and profiles of streams and the grades of wetlands should be
restored where temporarily impacted.

Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at or [phone] if you have any questions about these comments.
17BP.11.R.122 Page 3 January 26, 2023
Avery County
Cordially,

Dave McHenry, NCWRC Western DOT Coordinator

ec: Kevin Hining, NCDOT Division 11 Environmental Supervisor