20240353 Ver 1_BR-0252_Transylvania 133, 160, 161, and 189 Application_NCWRC Comments_20240308

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
March 8, 2024
Eric Alsmeyer
Regulatory Division Office
US Army Corps of Engineers, Wilmington District
3331 Heritage Trade Drive, Suite 105, Wake Forest, NC 27587
SUBJECT: Comments on Replacement of Transylvania Bridges 133, 160, 161, and 189. BR-0252
The North Carolina Department of Transportation (NCDOT) applied for a permit to replace the existing
timber bridges with similar structures on the same roadway alignments. This project will affect trout
waters. The North Carolina Wildlife Resources Commission's (NCWRC) comments 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-
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).
Transylvania Bridge 133
Walker Creek (C Tr) supports a naturally reproducing population of Brook Trout (Salvelinus fontinalis).
Transylvania Bridge 160
Richland Creek (C Tr) likely supports a naturally reproducing population of Brown Trout (Salmo trutta)
as does the West Fork French Broad River a short distance downstream. Eastern Hellbender
(Cryptobranchus alleganiensis, NC Special Concern) are found in the West Fork French Broad River
downstream of the bridge but are unlikely to be in Richland Creek. The river also supports French Broad
River Crayfish (Cambarus reburrus), a state Threatened species. The NCWRC would appreciate being
apprised of the construction schedule, once known, so that the bridge area can be surveyed for crayfish
and animals moved, if 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 communication with
construction staff.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

BR-0252 Page 2 March 8, 2024
Transylvania Bridge 161
Flat Creek (C Tr) likely supports a naturally reproducing population of Rainbow Trout (Onchoruynchus
mykiss) near the bridge. Brown Trout (Salmo trutta) and Eastern Hellbender (Cryptobranchus
alleganiensis, NC Special Concern) are found in the West Fork French Broad River downstream of the
bridge and may be in the lower reaches of Flat Creek as well. The river also supports French Broad
River Crayfish (Cambarus reburrus), a state Threatened species.
Transylvania Bridge 189
Shoal Creek (C Tr) likely supports a naturally reproducing population of Rainbow Trout (Onchoruynchus
mykiss) near the bridge.
Projects with on -site temporary detours could require more tree clearing than usually associated with
typical in -kind timber bridge replacements. Therefore, the NCWRC supports the proposed tree clearing
outside of active bat season. Young bats are particularly vulnerable to mortality from tree -felling during
the general May to August timeframe when they cannot fly.
The NCWRC requests that the following conditions be included in authorizations to help conserve trout
and other aquatic resources that may be affected:
1. The October 15 to April 15 trout moratorium should be followed for Transylvania 133 and 160
and the January 1 to April 15 trout moratorium should be followed for Transylvania 161 and 189
since construction has a reasonable potential to cause inadvertent sedimentation in trout spawning
habitat.
2. Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be adhered to for all bridges. Design Standards for Sensitive Waters
(15A NCAC 04B .0124) are recommended where practical with these bridge replacements
because waters with sensitive species will be affected.
3. 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.
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 IO'x10'.
5. 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.

BR-0252 Page 3 March 8, 2024
6. Sandbags, rock berms, cofferdams, or other adequately designed diversion structures should be
used where excavation or other periods of extended stream disturbance have the potential for
downstream sedimentation.
7. 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 david.mchenryAncwildlife.org or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
cc: NCDEQ, DWR Laserfiche
Patrick Breedlove, NCDOT Division 14 PDEA Engineer