20110932 Ver 1_Other Agency Comments_20080306

O~PQ~MENT `Op • _ United States Department of the Interior

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FISH AND WILDLIFE SERVICE
MygcH 3 ~$a9 Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
March 6, 2008

Mr. Hank Schwab
Bridge Project Planning Engineer
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1548 Mail Service Center
Raleigh, North Carolina 27699-1548

Dear Mr. Schwab:

Subject: Review of Bridge Replacement Projects (Group No. 59) in Catawba County (TIP
No. B-4456), Cleveland County (TIP No. B-4468), Gaston County (TIP Nos. B-4517
and B-4519), Iredell County (TIP No. B-4553), and Rutherford County (TIP
No. B-4632), North Carolina

We have reviewed the subject bridge replacement projects and are providing the following
comments in accordance with the National Environmental Policy Act (42 U.S.C. 4332(2)(c)); the
Fish and Wildlife Coordination Act, as amended (16 U.S.C. 661-667e); and section 7 of the
Endangered Species Act of 1973, as amended (16 U.S.C. 1531-1543) (Act).

Fish and Wildlife Resources - The information provided for these six projects does not include
detailed descriptions of the structures that will replace the existing bridges. We recommend that,
if possible, structures be replaced in place, with an off-site detour, rather than using temporary
structures near the existing bridges. This will minimize the amount of riparian vegetation that
must be removed and, in general, reduce the amount of disturbance to the streams. We
recommend that each new bridge design include provisions for the roadbed and deck drainage to
flow through a vegetated buffer prior to reaching the affected stream. This buffer should be
large enough to alleviate any potential effects from the runoff of storm water and pollutants. The
bridge designs should not alter the natural stream or the stream-bank morphology or impede fish
passage. Any piers or bents should be placed outside the bank-full width of the streams. The
bridges and approaches should be designed to avoid any fill that will result in the damming or
constriction of the channel or floodplain. Bridges crossing wildlife movement corridors are often
sites of road kill collisions and habitat fragmentation. A riprap-free area of at least 10 feet
should remain on each side of the stream underneath the bridge to maintain connectivity for
terrestrial wildlife. If spanning the floodplain is not feasible, culverts should be installed in the

floodplain portion of the approaches in order to restore some of the hydrological functions of the
floodplain and reduce high velocities of floodwaters within the affected areas. Measures to
control erosion and sedimentation should be in place prior to any ground-disturbing activities.
Wet concrete should never be allowed to come into contact with a stream. When the categorical
exclusions are prepared and more information is available regarding environmental effects, we
can then offer more substantive comments.

Migratory Birds - The Migratory Bird Treaty Act (16 U.S.C. 703-712) prohibits the taking,
killing, possession, transportation, and importation of migratory birds (including the bald eagle),
their eggs, parts, and nests, except when specifically authorized by the Department of the
Interior. To avoid impacts to migratory birds, we recommend conducting a visual inspection of
each of the bridges and any other migratory bird nesting habitat within the impact area during the
migratory bird nesting season--March through September. If migratory birds are discovered
nesting in the impact area, including on the existing bridges, the North Carolina Department of
Transportation (NCDOT) should avoid impacting the nests during the migratory bird nesting
season (March through September). If birds are discovered nesting on the bridges during years
prior to the proposed construction date, the NCDOT, in consultation with us, should develop
measures to discourage birds from establishing nests on the bridges by means that will not result
in the take of the birds or eggs, or the NCDOT should avoid construction and demolition
activities during the nesting period.

Federally Listed Species - We have reviewed the Natural Resources Technical Reports for the
subject bridge replacement projects and the evaluation of impacts to federally protected species.
Based on the lack of habitat and negative survey information, we agree with the determinations
of "no effect" to federally listed species for these projects. We are providing the following
project-specific comments.

Cleveland County - B-4468 - Bridge No. 144 over Sandy Run Creek on
SR 1327 (our Log Number 4-2-08-115). Both alternatives will generate
114 linear feet of culvert impacts to an unnamed tributary of Sandy Run Creek
and 0.3 acre of permanent impacts to mesic mixed forest. Additional temporary
impacts of 0.2 acre to mesic mixed forest are associated with Alternate B due to
the construction of a temporary bridge as an on-site detour. Due to reduced
impacts, we prefer Alternate A.

Gaston County - B-4517 - Bridge No. 49 over Crowder's Creek on SR 1104
(our Log Number 4-2-08-116). Because of the reduced amount of permanent and
temporary impacts to plant communities and jurisdictional waters, we prefer
Alternate A for this bridge, which will be replaced at its current location while
maintaining traffic with an off-site detour.

Iredell County - B-4553 - Bridge No. 312 over Fourth Creek on SR 2308
(Elmwood Road) (our Log Number 4-2-08-118). We prefer Alternate A due to
temporary impacts associated with on-site detours for Alternates B and C.

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We believe the requirements under section 7(c) of the Act are fulfilled. However, obligations
under section 7 of the Act must be reconsidered if. (1) new information reveals impacts of this
identified action that may affect listed species or critical habitat in a manner not previously
considered, (2) this action is subsequently modified in a manner that was not considered in this
review, or (3) a new species is listed or critical habitat is determined that may be affected by the
identified action.

If you have questions about these comments, please contact Mr. Troy Wilson of our staff at
828/258-3939, Ext. 226. In any future correspondence concerning this project, please reference
our log numbers as assigned above and/or the following:

Catawba County (TIP No. B-4456) - our Log Number 4-2-08-114,
Gaston County (TIP No. B-4519) - our Log Number 4-2-08-117, and
Rutherford County (TIP No. B-4632) - our Log Number 4-2-08-119.

Sin rely,

Brian P. Cole
Field Supervisor

cc:
Ms. Marla J. Chambers, Western NCDOT Permit Coordinator, North Carolina Wildlife
Resources Commission, 12275 Swift Road, Oakboro, NC 28129
Ms. Polly Lespinasse, Mooresville Regional Office, North Carolina Division of Water Quality,
610 East Center Avenue, Suite 301, Mooresville, NC 28115
Mr. Brian Wrenn, North Carolina Division of Water Quality, Central Office, 2321 Crabtree
Blvd., Suite 250, Raleigh, NC 276040