HomeMy WebLinkAbout20140698 Ver 2_NCWRC Comments_20150909
North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
TO: Steve Kichefski, NCDOT Coordinator
Asheville Regulatory Field Office, USACE
FROM: Marla Chambers, Western NCDOT Coordinator
Habitat Conservation Program, NCWRC
DATE: September 8, 2015
SUBJECT: Review of NCDOT’s Modification application for Section 404 and 401 permits to
impact unnamed tributaries to Triplett Creek as part of their project to improve
SR 1526B (Sampson Road), Watauga 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) and a 401 Water
Quality Certification from the NC Division of Water Resources (NCDWR). 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 pave and upgrade an additional section of SR 1526B (Sampson Road),
which includes two additional pipe culvert crossings carrying unnamed tributaries to Triplett
Creek (Class C; Trout), one on new location due to elimination of a sharp curve. This extension
of the project will permanently impact 145 linear feet (lf) of stream for the pipes and 20 lf for
riprap stabilization. Temporarily impacts total 80 lf for dewatering the work areas. There is
potential for Brook Trout to occur downstream of the project vicinity, however we will not
require a trout moratorium. We do recommend that special attention be paid to install and
maintain sediment and erosion control to prevent off-site sedimentation.
In addition, 3.8 acres of terrestrial clearing is proposed. We are concerned with road paving
projects that have significant terrestrial impacts. These projects typically upgrade lightly
traveled, low-speed roadways to specific standards with wide travel lanes, shoulders and ditch
lines, often straightening curves and removing adjacent hillsides. Greater amounts of tree and
Mailing Address:
N.C. Wildlife Resources Commission • 1701 Mail Service Center • Raleigh NC 27699-1701
Telephone:
(919) 707-0010
SR 1526B, Sampson Rd.
UTs to Triplett Creek, Watauga Co. 2 September 9, 2015
vegetation removal and earthmoving activities constitute greater wildlife habitat destruction and
increase the likelihood of sediment entering the waterways. While the road design standards are
intended to improve safety, we are concerned that the increased traffic and higher speeds will
have a negative effect on the safety of motorists, pedestrians and wildlife along these types of
roadways. We encourage NCDOT to use context sensitive designs to minimize aquatic and
terrestrial impacts and address safety issues in upgrading gravel roads. Smaller, less intrusive
projects will have the added benefit of reducing construction and right-of-way costs.
NCWRC does not object to the issuance of the Section 404 and 401 permits provided that the
following conditions are implemented:
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. Backfill materials should be obtained from upland sites.
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.
SR 1526B, Sampson Rd.
UTs to Triplett Creek, Watauga Co. 3 September 9, 2015
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.
Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at marla.chambers@ncwildlife.org or (704) 982-
9181.
cc: Amy Chapman, NCDWR
Dave Wanucha, NCDWR
Heath Slaughter, NCDOT