20141169 All Versions_USFWS Comments_20071016

QPP<ME"? otiF~y United States Department of the Interior

w V O FISH AND WILDLIFE SERVICE
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Raleigh Field Office
~'4RCH Post Office Box 33726
Raleigh, North Carolina 27636-3726
October 16, 2007

Mark Pierce, PE
Project Development and Environmental Analysis
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548

Dear Mr. Pierce:

As you are aware, the U.S. Fish and Wildlife Service (Service) is a participating member of the
Merger 01 Process Team for the proposed improvements to US 17 in Jones and Onslow Counties
(TIP No. R-2514). For some time now, the Service, along with the North Carolina Wildlife
Resources Commission (NCWRC), has been requesting that the North Carolina Department of
Transportation (NCDOT) construct an ecologically functional wildlife underpass along a section
of US 17 between Maysville and Pollocksville in Jones County. This letter summarizes the need
and justification for the underpass.

The Service participates in a 13-member partnership known as the Onslow Bight Conservation
Forum (OBCF). The NCDOT is also a participating member of the OBCF. Mr. Lyndo Tippett,
Secretary of Transportation, signed the partnership's Memorandum of Understanding (MOU) on
behalf of the NCDOT on July 1, 2003. Goal 5 of the MOU is:

To promote the establishment of landscape corridors and buffers, between and adjacent
to existing public and private conservation lands to enhance long-term wildlife
population viability and genetic exchange and to ensure land management flexibility,
respectively;

The Croatan National Forest (CNF) abuts the existing US 17 on the east side, while Hofmann
State Forest (HSF) and other conservation lands exist to the west of US 17, though not
immediately adjacent to the road. The OBCF has identified the area between CNF and HSF as a
potential conservation corridor in which to link the two public conservation lands. Without this
connection, we fear that the proposed multi-lane facility and future development will isolate the
wildlife in the CNF. This isolation will likely, among other things, lead to genetic homogeneity
in black bears and many other wide-ranging wildlife species. Genetic homogeneity due to
habitat fragmentation has been documented to preclude long-term viability of many wildlife
species.

As you know, The Nature Conservancy (TNC) has been negotiating with Weyerhaeuser to
purchase an interest in an approximately 2,400 acre parcel between the CNF and HSF, which
would essentially connect the two public conservation lands. However, without a wildlife

t crossing under US 17, the connection would be effectively severed. The Service believes this to

be the last/best chance to fulfill the OBCF's goal 5 at this location.

On August 28, 2007, staff from the Service, NCWRC, TNC, NCDOT and the North Carolina
Department of Environment and Natural Resources met to discuss a preliminary design of a
single wildlife underpass developed by NCDOT. The design is modeled after the three
successful wildlife underpasses constructed on US 64 in Washington County. Preliminary
monitoring data demonstrate substantial use of the US 64 crossings by several species of
wildlife.

This design involves an elevated bridge on both the northbound and southbound lanes of the
proposed US 17. The two bridges would allow 120 feet of opening at the base and a minimum
of 10 feet of vertical clearance. The precise location of the crossing is restricted to an
approximately one-mile stretch of US 17 where the CNF abuts the road. Ten-foot high chain-
link fencing will need to be erected for approximately one-half mile in both directions of the
crossing along both sides of the road to "funnel" wildlife through the crossing. In addition, a
series of small culverts would also be placed along the approach fill to allow passage of smaller
animals.

The Service believes that in addition to providing an ecological corridor between two public
conservation lands, the wildlife crossing will provide significant benefits to the traveling public.
There are over 500,000 documented deer-vehicle collisions a year in the US, plus an unknown
number of undocumented collisions. In addition, a large source of black bear mortality is
attributed to vehicle collisions. A black bear was recently killed on the road very near the
proposed location for the wildlife passage. The Service believes that the wildlife crossing with
the associated fencing will greatly diminish the potential for wildlife-vehicle collisions in this
area, thus reducing human fatalities and injuries.

The Service understands that the wildlife underpass has a significant cost. However, as a
member of the Merger Team for this project, the Service has previously agreed to environmental
compromises which have reduced bridge lengths and bridging costs for the entire project. In
addition, the Service has agreed to eliminate alternatives that had fewer environmental impacts
(e.g. wetland impacts). In a presentation to NCDOT management on July 30, 2007, the Service
and NCWRC gave specific examples of compromises we made with regards to our trust
resources which included cost savings that were more than enough money to pay for the wildlife
underpass. The Service and the NCWRC did this with the intention to focus on our most
important environmental issue - the wildlife underpass which would make the ecological
corridor between CNF and HSF viable.

Again, the Service requests that NCDOT construct the aforementioned wildlife underpass on US
17. While the OBCF MOU does not legally obligate NCDOT to any specific action, we stress
that goal 5 will never be recognized at this location without the wildlife underpass. We believe
that the NCDOT, in concert with TNC, has a wonderful opportunity to create an ecological
benefit which will enhance wildlife populations at the landscape scale, serve to minimize the
wildlife habitat fragmentation effects of the transportation corridor, and to make US 17 a safer
road to travel on.

e ~

If you have any questions regarding this letter, please contact Mr. Gary Jordan at (919) 856-
4520, ext. 32.

/Sincere y,

~ r
Pete B ' min
Field Supervisor

cc: Chris Militscher, USEPA, Raleigh, NC
Travis Wilson, NCWRC, Creedmoor, NC
David Wainwright, NCDWQ, Raleigh, NC
William Wescott, USACE, Raleigh, NC