20170552 Ver 1_WRC Comments_20170522

Wanucha, Dave
From:Chambers, Marla J
Sent:Monday, May 22, 2017 4:48 PM
To:Alsmeyer, Eric C CIV USARMY CESAW (US)
Cc:Slaughter, Johnathan H; Wanucha, Dave
Subject:Chestnut Grove Rd. (SR 1324), UTs to Cobb Creek, Watauga Co.
Attachments:WatSR1324utsCobbC2017-05.docx
See attached comments. There appears to be a slight discrepancy in the impact totals, the table in the cover letter doesn’t quite
add up, about a 4 foot difference.

Marla

Marla Chambers // NCDOT Coordinator

Habitat Conservation Program

NC Wildlife Resources Commission
c/o NCDOT

206 Charter Street

Albemarle, North Carolina 28001
office: 704-982-9181
mobile: [phone]
[e-mail]

ncwildlife.org

Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
1

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� North Carolina Wildlife Resources Commission ��
MEMORANDUM
TO:
FROM:
Gordon Myers, Executive Director
May 22, 2017
Eric Alsmeyer, Regulatory Project Manager
Raleigh Regulatory Field Office, USACE
Marla Chambers, Western NCDOT Coordinator �Ut���� ���.r���Z�,-�,_�
Habitat Conservation Program, NCWRC
SUBJECT: Review of NCDOT's application for Section 404 and 401 permits to replace and
extend two pipes carrying unnamed tributaries to Cobb Creek as part of their
proposed road paving project on a portion of Chestnut Grove Road (SR 1324),
Watauga County, North Carolina.
The North Carolina Department of Transportation has submitted an application to obtain a
Section 404 Permit from the U.S. Army Corps of Engineers and a 401 Water Quality
Certification from the NC Division of Water Resources. 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-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.), the Endangered Species Ac� (16 U. S. C. 1531-1543;
87 Stat 884), and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C.
661-667d), as applicable.
The NCDOT proposes to replace and extend two pipes carrying unnamed tributaries to Cobb
Creek as part of their proposed road paving project on a portion of Chestnut Grove Road (SR
1324). Permanent stream impacts total 19 linear feet for the pipes and 201f for riprap
stabilization. Temporarily impacts tota160 lf for dewatering. Brook Trout are expected to occur
in the project area, therefore a moratorium prohibiting in-stream work and land disturbance
within the 25-foot trout buffer should apply from October 15 to April 15 to protect the egg and
fry stages of trout. Sediment and erosion control should adhere to the Design Standards in
Sensitive Watersheds and be strictly maintained.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

CHESTNUT GROVE RD. (SR 1324)
UTS TO COBB CREEK, WATAUGA CO. PAGE 2 MAY 22, 2017
Of significant concern are the terrestrial impacts; nearly two acres of trees are proposed to be
removed. We are concerned with road paving projects that have significant terrestrial impacts.
These projects typically upgrade lightly traveled, low-speed roadways to specific standards with
wide travel lanes, shoulders and ditch lines, often straightening curves and removing adjacent
hillsides. Greater amounts of tree and vegetation removal and earthmoving activities constitute
greater wildlife habitat destruction and increase the likelihood of sediment entering the
waterways. Standards appropriate for the piedmont and coastal settings may not be appropriate
for mountainous terrain. While the road design standards are intended to improve safety, we are
concerned that the increased traffic and higher speeds will have a negative effect on the safety of
motarists, pedestrians and wildlife along these types of roadways. We encourage NCDOT to use
context sensitive designs to minimize aquatic and terrestrial impacts and address safety issues in
upgrading gravel roads. Smaller, less intrusive projects will have the added benefit of reducing
construction and right-of-way costs.
NCWRC does not object to the issuance of the Section 404 and 401 permits provided that the
following conditions are implemented:
In-stream work and land disturbance within the 25-foot wide buffer zone are prohibited
during the trout spawning seasons of October 15 through April 15 to protect the egg and
fry stages of trout.
2. Sediment and erosion control measures shall adhere to the Design Standards in Sensitive
Watersheds and be strictly maintained until project completion.
3. Herbaceous vegetation shall be planted on all bare soil as soon as possible following the
completion of permanent or temporary ground disturbing activities to provide appropriate
long-term erosion control.
4. Tall fescue and straw mulch shall not be used in riparian areas. We encourage NCDOT
to utilize onsite vegetation and materials for bank stabilization when practicable. Erosion
control matting shall be used on steep slopes and for establishing permanent vegetation in
riparian areas. The matting shall be well anchored with staples or wooden stakes and,
whenever possible, include live stakes of native trees. Matting in riparian areas should
not contain plastic mesh, which can entangle and trap small animals.
5. Stormwater should be directed to buffer areas or retention basins and should not be
routed directly into the waterway.
6. The natural dimension, pattern, and profile of the waterway above and below the
crossings should not be modified by widening the channel or changing the depth of the
waterway.
7. Removal of vegetation in riparian areas should be minimized. Native trees and shrubs
should be planted along the banks, as appropriate to the setting, to reestablish the riparian
zone and to provide long-term erosion control.

CHESTNUT GROVE RD. (SR 1324)
UTS TO COBB CREEK, WATAUGA CO. PAGE 3 MAY 22, 2017
8. Grading and backfilling should be minimized, and tree and shrub growth should be
retained if possible to ensure long term availability of shoreline cover for fish and
wildlife. Backfill materials should be obtained from upland sites.
9. Where practicable, riprap placed for bank stabilization should be limited to the banks
below the high water mark, and vegetation should be used for stabilization above the high
water elevation.
10. If concrete will be used during construction, work must be accomplished so that wet
(uncured) concrete does not contact surface waters. This will lessen the chance of
altering the water chemistry and causing a fish kill.
11. Discharging hydroseeding mixtures and washing out hydroseeders and other equipment
in or adjacent to surface waters is prohibited.
12. Heavy equipment should be operated from the bank rather than in the channel whenever
possible in order to minimize sedimentation and reduce the likelihood of introducing
other pollutants into the waterway. All mechanized equipment operated near surface
waters should be inspected and maintained regularly to prevent contamination of surface
waters from fuels, lubricants, hydraulic fluids or other toxic materials.
Thank you for the opportunity to review and comment on this project. If you have any questions
regarding these comments, please contact me at marla.chambers(a�ncwildlife.org or (704) 982-
9181.
cc: Dave Wanucha, NCDWR
Heath Slaughter, NCDOT