20190397_WRC Comments_20161212

North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director

December 9, 2016

M E M O R A N D U M

TO:
Jamille Robbins
Human Environment Section, NCDOT

FROM:
Marla Chambers, Western NCDOT Coordinator
Habitat Conservation Program, NCWRC

SUBJECT:
Review of the Environmental Assessment document for NCDOT’s proposal to
improve NC 105 from Clark’s Creek Road (SR 1136) near Foscoe to NC 105
Bypass (SR 1107) in Boone, Watauga County. TIP No. R-2566B.

The North Carolina Department of Transportation has submitted for review an Environmental
Assessment document for the subject project. Staff biologists with the North Carolina Wildlife
Resources Commission 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 improve NC 105 from Clark’s Creek Road (SR 1136) near Foscoe to
NC 105 Bypass (SR 1107) in Boone. NCWRC submitted scoping comments, dated February 18,
2010, on the larger R-2566 project from Linville in Avery County to Boone in Watauga County.
The project has been shortened to the B section in light of traffic forecasts. Our comments were
included in the EA document. We concur with the project commitments to use Design Standards
in Sensitive Watersheds and to adhere to the trout moratorium from October 15 to April 15.
NCDOT is in formal consultation with the USFWS for this project regarding the federally
Endangered Virginia big-eared bat and Threatened northern long-eared bat.

The Watauga River (Class B; Tr; HQW) runs parallel to NC 105 along the southern half the
project and Laurel Fork (Class C; Tr) runs parallel along the northern portion. The Watauga

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

R-2566B, NC 105 FOSCOE TO BOONE 2 DECEMBER 9, 2016
WATAUGA R. & LAUREL FORK, WATAUGA CO.
River supports a significant population of hellbender (Federal Species of Concern and State
Special Concern) and a portion of it, approximately from Old Shull’s Mill Road northward, is
designated a Significant Natural Heritage Area. The EA also indicates that the Watauga River is
on the 303(d) list of impaired waters for turbidity throughout the project area. Both waterways
support Brown and Rainbow Trout.

NCWRC has participated in the Merger process for the development of this project. As the
Environmental Assessment pointed out, the Merger Team “agreed to make the fewest
improvements possible to meet the project purpose and need, which could result in a varying
typical section or make no improvements along a portion of the 5.5-mile corridor” of the B
section. Current preliminary design proposes no improvements to the southernmost 1-mile
section, widening to 3 lanes (one northbound, two southbound) between Old Shull’s Mill Road
and Broadstone Road, and widening to a 4-lane divided facility for the northern portion of the
project. The widened sections are also proposed to have 6-foot paved shoulders to meet a
secondary purpose of improving bicycle facilities.

While we agree with using a “Best Fit” alignment for the project, we are not yet convinced that
the typical sections of the preliminary design are truly making the fewest improvements possible
and minimizing impacts along the corridor. Current design (with a 25-foot buffer around slope
stakes) is anticipated to impact 0.2 acres of wetlands and 3,270 linear feet of stream at the 19
stream crossings. We are particularly concerned about portions of the proposed 3-lane section
where the Watauga River is in closer proximity to the roadway and steep mountainous terrain
occurs on the opposite side of the road. We recommend avoiding or minimizing impacts to the
river floodplain and natural vegetated buffer that protects water quality and serves as habitat and
a travel corridor for wildlife. We also recommend avoiding or minimizing cuts into the
mountainsides to prevent additional sediment sources and to preserve habitat and aesthetic
qualities.

The Citizens Plan for Watauga (2009) identifies NC 105 as the “Grandfather Gateway” to Boone
and calls for it to be an economic and aesthetic entranceway to Boone, according to the EA. The
Watauga County Parks and Recreation Comprehensive System-wide Plan (2010) includes the
proposed Laurel Creek-Watauga River Trail, which runs parallel to NC 105 and along the
Watauga River. Avoiding impacts to the mountainsides and riparian corridor along the river
appear to be in line with the local plans.

Traffic data presented in the EA show that the only road segments of the project that are
predicted to be at an unacceptable level of service for certain time periods in the design year
2040 are north of Broadstone Road, which is proposed to be widened to a 4-lane divided
roadway. One intersection in the proposed 3-lane portion and one intersection where no
improvements are planned are predicted to have an unacceptable LOS in 2040 in both the No-
Build and Build scenarios for certain times of day or week. We assume extra turn lanes or adding
signalization could improve intersection LOS, however the data for the road sections appears to
indicate that additional capacity is not required for acceptable LOS. The second southbound lane
of the 3-lane section would serve as a passing lane and therefore may provide some benefit. We
recommend that the third lane be discontinued in areas where the space between the river and the
mountainside narrows, such as the stretch south of Broadstone Road.

R-2566B, NC 105 FOSCOE TO BOONE 3 DECEMBER 9, 2016
WATAUGA R. & LAUREL FORK, WATAUGA CO.

Our scoping comments indicated that wildlife crossings should be provided along the project to
reduce habitat fragmentation and improve safety. Other than the bridge over the Watauga River,
which will be replaced with another bridge, no other stream crossing has been shown to be
feasible or practicable to be replaced with a bridge during project development to this point.
Existing culverts are proposed to be replaced with larger culverts or extended. Crash data in the
EA did not address collisions with wildlife. We request additional investigation into this issue
that identifies any wildlife collision hotspots to help determine the need for formal wildlife
crossings. Minimizing the project footprint by reducing the typical section in certain areas may
improve safety by minimizing these types of crashes.

The brief Indirect and Cumulative Effects sections of the EA indicated that the rate of population
growth within the study area between 1990 and 2000 exceeded the rate of both the county and
state for that timeframe. A growing tourism sector and second home market is expected to
continue to support residential and commercial development. The proposed project construction
would more than double the amount of impervious surface associated with NC 105. Due to
topographic constraints, future development in the area is expected to “remain relatively modest”
and “mainly consist of in-fill development which is expected to add to the total amount of
impervious surfaces near the Watauga River.” The document states “the proposed project will
notably contribute to cumulative impacts to water quality in the absence of stormwater
management regulations requiring Best Management Practices”. We believe that stormwater
treatment and other low-impact design measures will be important for both the direct impacts of
the project and future development to protect important sensitive resources.

We continue to recommend context sensitive solutions to minimize impacts to aquatic and
terrestrial resources along the project and ensure compatibility with the natural and human
environment of the area. Further minimization of the footprint and impacts should be pursued for
all portions of the project. We encourage NCDOT and local officials to work together and to use
low impact development techniques to maximize the management of storm water quantity and
quality in the project area. Information on LID measures can be found at
www.lowimpactdevelopment.org, http://www.epa.gov/owow/nps/lid/lidnatl.pdf and
http://www.stormwatercenter.net/. Other important protective measures can be found in the
Guidance Memorandum to Address and Mitigate Secondary and Cumulative Impacts to Aquatic
and Terrestrial Wildlife Resources and Water Quality at
http://www.ncwildlife.org/portals/0/Conserving/documents/2002_GuidanceMemorandumforSec
ondaryandCumulativeImpacts.pdf

Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at [e-mail] or (704) 982-
9181.

Cc: Marella Buncick, USFWS
Cynthia Van Der Wiele, USEPA
Dave Wanucha, NCDWR
Steve Kichefski, USACE