2023-10-06_NCWRC Comments_BR-0251_Madison 72, 74. 381, 500_Scoping

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]

October 6, 2023

Nick Pierce
Project Engineer
North Carolina Department of Transportation, Structures Management Unit
1581 Mail Service Center
Raleigh, NC 27699-1534

Subject BR-0251 Scoping Comments on Madison County Timber Bridge Replacements:
 Bridge 072, carrying Foster Creek Road (SR 1341) over Foster Creek
 Bridge 074, carrying Foster Creek Road (SR 1341) over Foster Creek
 Bridge 381, carrying Jarrett Cove Road (SR 1339) over Big Laurel Creek
 Bridge 500, carrying Buckner Branch Road (SR 1336) over Big Laurel Creek

Dear Nick,

The North Carolina Department of Transportation (NCDOT) invited comments on the subject bridge
replacements. These timber bridges will be replaced, in place, with comparable new timber structures.
The roads these bridges carry do not have outlets, so off-site detours are not possible. North Carolina
Wildlife Resources Commission (NCWRC) staff are familiar with the project areas. These comments are
offered to conserve wildlife resources affected by the projects and to promote wildlife-based recreation in
accordance with the 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).

Standard Comments (NOTE specific recommendations follow)
NCWRC standard recommendations for bridge replacement projects of this scope include:
1. Live concrete should not be allowed to contact water in or discharge to streams.
2. If possible, bridge supports (bents) should not be placed in stream channels.
BR-0251 Page 2 October 6, 2023

3. Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be implemented and maintained during construction. Matting used in
riparian areas should not contain nylon mesh because it entangles and kills wildlife. Coir matting
should be used on unstable stream banks that are steep or susceptible to high water and matting
should be securely anchored with wooden stakes according to NCDOT specifications.
4. Temporary detours and access roads should be designed and located to avoid wetland impacts, to
minimize clearing, and 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 10’x10’.
5. NCDOT biologists should be notified about streams that contain threatened or endangered species.
Special measures to protect these sensitive species may be required. NCDOT should also contact the
U.S. Fish and Wildlife Service for information on requirements of the Endangered Species Act as it
relates to the project.
6. All work in or adjacent to streams should be conducted in dry work areas. Sandbags, cofferdams, or
other clean diversion structures should be used where possible to avoid excavation in flowing water.
7. Heavy equipment should be operated from the banks rather than in stream channels to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams.
8. Only clean, sediment-free rock should be used as temporary fill (causeways) and fill material should
be removed with minimal disturbance of the natural stream bottom when construction is completed.

Staged construction is recommended for timber bridge replacement to minimize the amount of stream
disturbance. Temporary detours should be designed and located to avoid wetland impacts, minimize the
need for clearing, and avoid destabilizing stream banks. If the structure will be on a new alignment, then
the old structure and the approach fills should be removed from the 100-year floodplain. Approach fills
should be removed down to the natural ground elevation. The area should be stabilized with grass and
planted with native tree species. NCDOT should restore the area to wetlands if the area reclaimed was
previously wetlands.

Specific Comments
Madison Bridge 72
Foster Creek (C Tr ORW) supports naturally reproducing populations of Rainbow Trout (Oncorhynchus
mykiss). To protect trout spawning, adherence to the January 1 to April 15 moratorium is recommended
for stream and buffer disturbance for any permits that may be required. Eastern Hellbender
(Cryptobranchus alleganiensis, NC Special Concern) are found in Big Laurel Creek downstream of the
bridge but are unlikely to be in Foster Creek. NWCRC biologists intend to assess the habitat conditions
near Madison Bridge 72 soon. In addition to standard recommendations, erosion control measures under
Design Standards in Sensitive Waters (see part (d) of 15A NCAC 04B .0124) are encouraged in the
BR-0251 Page 3 October 6, 2023

project design and construction, as practical, given the watershed’s ORW classification and to help ensure
protection of trout and other aquatic habitats.

Madison Bridge 74
Foster Creek (C Tr ORW) supports naturally reproducing populations of Rainbow Trout (Oncorhynchus
mykiss). To protect trout spawning, adherence to the January 1 to April 15 moratorium is recommended
for stream and buffer disturbance for any permits that may be required. Eastern Hellbender
(Cryptobranchus alleganiensis, NC Special Concern) are found in Big Laurel Creek downstream of the
bridge but are unlikely to be in Foster Creek. NWCRC biologists intend to assess the habitat conditions
near Madison Bridge 74 soon. In addition to standard recommendations, erosion control measures under
Design Standards in Sensitive Waters (see part (d) of 15A NCAC 04B .0124) are encouraged in the
project design and construction, as practical, given the watershed’s ORW classification and to help ensure
protection of trout and other aquatic habitats.

Madison Bridge 381
Big Laurel Creek (C Tr ORW) is stocked with trout by the NCWRC and supports some wild fish,
however NCWRC biologists have waived the trout moratorium for recent bridge projects on this stream
because trout spawning is believed to be limited. The trout moratorium should be waived for Madison
381. While trout spawning may not be a concern, Eastern Hellbender (Cryptobranchus alleganiensis, NC
Special Concern) are found in Big Laurel Creek and the stream is classified as ORW. Therefore, erosion
control measures under Design Standards in Sensitive Waters (see part (d) of 15A NCAC 04B .0124) are
encouraged in the project design and construction, as practical. In addition, the NCWRC would
appreciate being apprised of the construction schedule, once known, so that the bridge area can be
surveyed for hellbenders and animals moved as needed. A notice a few weeks before construction, or an
invitation to any preconstruction meeting, is requested. My contact information can be used in any
communications with construction staff (e.g., green sheet commitments, contract notes,…).

Madison Bridge 500
Big Laurel Creek (C Tr ORW) is stocked with trout by the NCWRC and supports some wild fish,
however NCWRC biologists have waived the trout moratorium for recent bridge projects on this stream
because trout spawning is believed to be limited. The trout moratorium should be waived for Madison
381. While trout spawning may not be a concern, Eastern Hellbender (Cryptobranchus alleganiensis, NC
Special Concern) are found in Big Laurel Creek and the stream is classified as ORW. Therefore, erosion
control measures under Design Standards in Sensitive Waters (see part (d) of 15A NCAC 04B .0124) are
encouraged in the project design and construction, as practical. In addition, the NCWRC would
appreciate being apprised of the construction schedule, once known, so that the bridge area can be
surveyed for hellbenders and animals moved as needed. A notice a few weeks before construction, or an
invitation to any preconstruction meeting, is requested. My contact information can be used in any
communications with construction staff (e.g., green sheet commitments, contract notes,…).

BR-0251 Page 4 October 6, 2023

Please contact me at [e-mail] or [phone] if you have any questions about
these comments. Thank you for the opportunity to review and comment on these projects. The NCWRC
looks forward to assisting as needed as the project develops further.

Cordially,

Dave McHenry, NCWRC Western DOT Coordinator

Cc: Adam Archual, Gannett Fleming
Yates Allen and Karina Clough, NC Department of Transportation, Division 13 Environmental