U-4404 Cliffdale Rd scoping letter.pdf

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MICHAEL S. REGAN
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Environmental S. JAY ZIMMERMAN
Quality °D�"'°'�
Augusf 31, 2017
MG;M012ANDUM
'Co: Scott Pridgen, NCDOT Division 6
From: Joanne S[eenhuis, NC Division of W�ler Resources, Wilmington Offic��
Subject Scoping conuneuts on proposed improvements to Cliffdale Roacl (SR 1400) from McPherson Church
Road (SR 3267) ro Morganton Road (SIZ 140d) in Cumberland County, State WaS Project No. 390d8.1.I,
i IP U-d40�1.
Reference your correspundence dated August 22, 2017 in which you requesled commenls for the referencect projccl.
Preliminary analysis of [he project reveals the potential for mulliple impacts to streams and jurisdictional wetlands
in the projecL area. More specilically, impacfs to:
Stream N�me River Basin Strcam Classi(ication(s) Stream Index 303(d) Listing
Number
I3ranson 6rnnch Ca e Pe�r C 18-27-5-I N/A
Purther invcstignlions al a highcr resolution should bc w�dcrt�kcn to vcrify lhc prescnce of other stre�ms nnd/or
jw�isdictional wctlands in thc �rca. In thc cvent tha[ any jurisdictional arcas arc idcn[itied, the Uivision of W�[er
Resources requests [ha[ NCDO'f consider the following environmen[al issues for the proposed project
General Project Commenfs:
The environmental doeument shoulcl provide a cletniled �nd itemizecl presentation of thc proposed impacts to
wetlands �nd s�reams wi[h corresponding mnpping. If mi[igation is necessaiy ns requirecl by I SA NCAC
2I1.0506(h), it is preferable to present fl conceptu�l (if not finelized) mitiga[ion plan wi[h the environmental
documen[�tion. Appropriatc mitiga[ion plans will be requircd prior to issu�nce oY � 401 W�ter Qu�lity
Cer[itica[ion.
2. Cnvironmental impact statemen[ alterna[ives shall consider design criteria that reduce the impacts lo streams
and wetlands Fl�om slorm water runoff. "fhcse al[ernalives shall include road designs th1[ �Ilow for Ireatmenl
oF the stonn water runoff through best m�nagement practices as detliled in thc most reccnt version of thc
No�74t Cnrolinn DeEim7men[ ofTi•nnspo�•tn�ion Sloi�unvn�w• 13es/ iLlnnagen�en! Prnc[ices Ton( boa manual,
such as grassed swales, bufl'er areas, preformed scour holes, retention basins, etc.
ARer fhe selection uf the preferred alternative and prior to an issuance of thc d01 Water Quality Ceitification,
lhe NWOT is respecttidly reminded that Ihey will need to demonstrate die avoidauce and minimizatiou of
impacts to wedTnds (and streams) [o thc maximum exten[ praclical. In accordauce wi[h [hz finvirmmiental
Managemenf Conunission's Rules (IiA NCAC 211.0506[h�), mitigation will be required for impacts of
grealcr than I acrc lo wctlands. In Ihe event (ha( mitigalion is rcquired, lhe miligation plan shall be designed
to replacc appropriate losl funetions and v�lues. North Carolina Division of Mi[igation Services m�y be
availablc for assistancc wilh �vetland mitigalion.
�1Vothing Compares'" . ,
S�ale ut Notlh Carolina � flnvimnmenlal Qunlil}'
1617 Mail Scrvice Cenler � Raleigh, Nonh Cemlina 27C99-I6U

4. In accordance with the Environmental Management Commission's Rules Q SA NCAC 2H.0506[h]),
mitigation will be required for impacts of greater than 150 linear feet to any perennial stream. In the event
that mitigation is required, the mitigation plan shall be designed to replace appropriate lost functions and
values. The North Carolina Division of Mitigation Services may be available for assistance with stream
mitigation.
5. Future documentation, including the 401 Water Quality Certification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
6. The NCDWR is very concerned with sediment and erosion impacts that could result from this project. The
NCDOT shall address these concerns by describing the potential impacts that may occur to the aquatic
environments and any mitigating factors that would reduce the impacts.
7. An analysis of cumulative and secondary impacts anticipated as a result of this project is required. The type
and detail of analysis shall conform to the NC Division of Water Resource Policy on the assessment of
secondary and cumulative impacts dated April l0, 2004.
8. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, and rip rap to jurisdictional wetlands, sheams, and riparian bufFers need to be included in the
final impact calculations. These impacts, in addition to any conshuction impacts, temporary or otherwise,
also need to be included as part of the 40l Water Quality Certification Application.
9. Where streams must be crossed, the NCDWR prefers bridges be used in lieu of culverts. However, we realize
that economic considerations often require the use of culverts. Please be advised that culverts should be
countersunk to allow unimpeded passage by fish and other aquatic organisms. Moreover, in areas where high
quality wetlands or sheams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the maximum extent practicable.
10. Whenever possible, the NCDWR prefers spanning structures. Spanning structures usually do not require
work within the stream or grubbing oFthe sheambanks and do not require stream channel realignment. The
horizontal and vertical clearances provided by bridges shall allow for human and wildlife passage beneath the
structure. Fish passage and navigation by canoeists and boaters shall not be blocked. Bridge supports (bents)
should not be placed in the stream when possible.
11. Bridge deck drains shall not discharge directly into the stream. Stormwater shall be directed across the bridge
and pre-treated through site-appropriate means (grassed swales, pre-formed scour holes, vegetated buffers, etc.)
before entering the stream. To meet the requirements of NCDOT's NPDES permit NCS0000250, please refer
to the most recent version of [he North Carolina Department of Transportation Storrnwater Best Management
Practices Toolbox manual for approved measures.
l2. Sediment and erosion control measures should not be placed in wetlands or streams.
13. Borrow/waste areas should avoid wetlands to the maximum extent practicaL Impacts to wetlands in
borrow/waste areas will need to be presented in the 401 Water Quality Certification and could precipitate
compensatory mitigation.
14. The 401 Water Quality Certification application will need to specifically address the proposed methods for
stormwater management. More specifically, stormwater shall not be permitted to discharge directly into
streams or surface waters.
15. Based on the information presented in the document, the magnitude of impacts to wetlands and streams may
require a Nationwide (NW) permit application to the Corps of Engineers and wrresponding 401 Water
Quality Certification. Please be advised that a 40l Water Quality Certification requires satisfactory protection
of water quality to ensure that water quality standards are met and no wetland or stream uses are lost. Final
permit authorization will require the submittal of a formal application by the NCDOT and written concurrence
from the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and

minimization of wetland and stream impacts to the maximum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
16. If concrete is used during conshvction, a dry work area shall be maintained to prevent direct contact between
curing concrete and sheam water. Water that inadvertently contacts uncured concrete shall not be discharged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills.
17. If temporary access roads or detours are conshucted, the site shall be graded to its preconstruction contours
and elevations. Disturbed areas shall be seeded or mulched to stabilize the soil and appropriate native woody
species shall be planted. When using temporary strucWres the area shall be cleared but not grubbed. Clearing
the area with chain saws, mowers, bush-hogs, or other mechanized equipment and leaving the stumps and root
mat intact allows the area to re-vegetate naturally and minimizes soil disturbance.
18. Unless otherwise authorized, placement of culverts and other structures in waters and streams shall be placed
below the elevation of the sheambed by one foot for all culverts with a diameter greater than 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow low flow
passage of water and aquatic life. Design and placement of culverts and other shuctures including temporary
erosion conhol measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or
sheambeds or banks, adjacent to or upstream and downstream of the above structures. The applicant is
required to provide evidence that the equilibrium is being maintained if requested in writing by the NCDWR.
If this condition is unable to be met due to bedrock or other limiting features encountered during construction,
please contact the NCDWR for guidance on how to proceed and to determine whether or not a permit
modification will be required.
19. If multipie pipes or barrels are required, they shall be designed to mimic natural stream cross section as
closely as possible including pipes or barrels at flood plain elevation, floodplain benches, and/or sills may be
required where appropriate. Widening the stream channel should be avoided. Stream channel widening at the
inlet or outlet end of structures typically decreases water velocity causing sediment deposition that requires
increased maintenance and disrupts aquatic life passage.
20. If foundation test borings are necessary; it shall be noted in the dowment Geotechnical work is approved
under General 401 Certification Number 3883/Nationwide Permit No. 6 for Survey Activities.
2 L Sediment and erosion control measures sufficient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Control
Planning and Design Manual and the most recent version of NCS000250.
22. All work in or adjacent to stream waters shall be conducted in a dry work area. Approved BMP measures
from the most current version of the NCDOT Construction and Maintenance Activities manual such as
sandbags, rock berms, cofferdams and other diversion structures shall be used to prevent excavation in
flowing water.
23. While the use ofNational WeHand Inventory (NWI) maps, NC Coastal Region Evaluation of WeHand
Significance (NGCREWS) maps and soil survey maps are useful tools, their inherent inaccuracies require
that qualified personnel perform onsite wetland delineations prior to permit approval.
24. Heavy equipment should be operated from the bank rather than in stream channels in order to minimize
sedimentation and reduce the likelihood of introducing other pollutants into streams. This equipment shall be
inspected daily and maintained to prevent contamination of surface waters &om leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
25. Riprap shall not be placed in the active thalweg channel or placed in the streambed in a manner that precludes
aquatic life passage. Bioengineering boulders or structures should be properly designed, sized and installed.

26. Riparian vegetation (native hees and shrubs) shall be preserved to the maximum extent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the growing season
following completion of construction.
Thank you for requesting our input at this time. The NCDOT is reminded that issuance of a 401 Water Quality
Certification requires that appropriate measures be instituted to ensure that water quality standards are met and
designated uses are not degraded or lost. If you have any questions or require additional information, please contact
Joanne Steenhuis at (9l0) 796-7306 [e-mail].
Electronic copy only distribution:
Liz Hair, US Army Corps of Engineers, Wilmington Field Office
Jim Rerko, Division 6 DEO
Kristi Lynn Carpenter, NCDWR
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