20240642 Ver 1_BP14.R010_bridge 79_Eagle Fork Creek_Clay_NCWRC Comments_20240509

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
May 9, 2024
Crystal Amschler
U.S. Army Corps of Engineers, Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
SUBJECT: Comments on Application for Replacement of Bridge 79 on SR 1171 over Eagle Fork
Creek, Clay County. BP14.R010
DWR 20240642 ver.1
Dear Mrs. Amschler,
The North Carolina Department of Transportation (NCDOT) applied for a permit for the subject project.
The North Carolina Wildlife Resources Commission's (NCWRC) comments are offered to help conserve
wildlife resources in the project area and to promote wildlife -based recreation in accordance with
applicable provisions of 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 new cored slab structure will be downstream of the existing bridge. The new bridge will be relatively
low to the water (10-yr elevation), and extensive bank armoring is thereby proposed to address potential
scour.
Eagle Fork Creek (C Tr) supports a wild Rainbow Trout (Onchorynchus mykiss) population. Therefore,
NCWRC fish biologists believe that the short trout moratorium should apply to the proposed bridge work.
In addition to trout, Eastern Hellbender (Cryptobranchus alleganiensis, NC Special Concern) are found in
portions of the Shooting Creek watershed and may be found at the bridge site. The NCWRC would
appreciate being apprised of the construction schedule, once known, so that the bridge area can be surveyed
for hellbenders and any animals moved, as needed. A notice a few weeks before construction, or an invitation
to any preconstruction meeting, is requested.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

BP14.R010 Page 2 May 9, 2024
Clay County
This bridge was surveyed for bats in September 2023 and no evidence was found. The NCWRC
recommends that tree removal be avoided during the applicable active bat season as prescribed by the US
Fish and Wildlife Service.
The NCWRC requests that the following conditions be included in authorizations to minimize impacts of
the project on trout resources and trout fishing:
1. The January 1 to April 15 trout moratorium will be followed since construction has a reasonable
potential to cause inadvertent sedimentation in trout spawning habitat downstream of the bridge.
2. Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be adhered to. Design Standards in Sensitive Waters (15A NCAC
04B .0124) are recommended as practical in the project's erosion control design because a
watershed with sensitive species will be affected. Subpart D of the rule describes measures that
can apply to bridge replacement projects where sediment basins are not needed, or practical.
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. Removal of vegetation in riparian areas and wetlands should be minimized. Trees should be
planted on portions of old roadway alignment that are in the trout buffer zone and beyond the new
road mowing pattern.
5. Sandbags, rock berms, cofferdams, or other adequately designed diversion structures should be
used where excavation or other periods of extended stream disturbance has the potential for
downstream sedimentation.
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at david.mchenrykncwildlife.org or [phone] if you have any questions about these comments.
Sincerely,
Dave McHenry, NCWRC Western DOT Coordinator
cc: Rob Ridings, NCDEQ,DWR
Patrick Breedlove, NCDOT Division 14 PDEA Engineer
Chad Plemmons, NCDOT Division 14 Environmental Specialist II