20171150 Ver 1_Percussive Information_20170908

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
ROY COOPER JAMES H. TROGDON, III
GOVERNOR SECRETARY

Mailing Address:
NC DEPARTMENT OF TRANSPORTATION
Division 14
253 Webster Road
Sylva, North Carolina 28779
Telephone: [phone]
Fax: [phone]
Customer Service: 1-877-368-4968

Website: www.ncdot.gov
Location:
NC DEPARTMENT OF TRANSPORTATION
Division 14
253 Webster Road
Sylva, North Carolina 28779

September 8, 2017

Ms. Lori Beckwith, NCDOT Regulatory Project Manager
U. S. Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, NC 28801-2714

Subject: Nationwide 14 Permit Application
Replace Bridge No. 90 on SR 1152 (Upper Whitewater Road) over
Thompson River (Labeled Bear Camp Creek on plans), Transylvania County
WBS Element No. 17BP.14.R.125

Dear Ms. Beckwith:

The North Carolina Department of Transportation (NCDOT) requests written verification to
replace the timber bridge number 90 over the Thompson River in Transylvania County with a 3-
sided (bottomless) 32’W x 3’H x 43’L reinforced concrete culvert. NOTE, the plans have the
stream, Thompson River, mislabeled as Bear Camp Creek. An off-site detour will be used
during construction. This project does not qualify for non-notification because of the combined
amount of rip rap upstream and downstream of the culvert and the rip rap that should be needed
in the culvert to stabilize the stream channel. As a bottomless structure, the natural stream bottom
will remain under the structure and thereby maintain existing aquatic organism passage.
Compensatory mitigation is not proposed for this bottomless structure.

The U.S. Fish and Wildlife Service and North Carolina Natural Heritage Program databases were
checked for records of threatened and endangered species in Transylvania County. The Carolina
Northern Flying Squirrel (Glaucomys sabrinus coloratus), Appalachian Elktoe (Alasmidonta
raveneliana), Mountain Sweet Pitcher Plant (Sarracenia rubra ssp. jonesii), Small Whorled
Pogonia (Isotria medeoloides), Spreading Avens (Geum radiatum), Swamp Pink (Helonias
bullata), Virginia Spiraea (Spiraea virginiana), Rock Gnome Lichen (Gymnoderma lineare),
Northern Long-eared Bat (Myotis septentrionalis, NLEB), and Gray Bat (Myotis grisescens) are
listed as either threatened or endangered and are known from current records or anticipated to
occur in the county.

Thompson River is too small and cold to support Appalachian Elktoe mussels. This mussel is not
known to occur in the Savannah River watershed downstream of the bridge. Therefore, the
bridge replacement work will not affect this mussel species.

Bridge 90, Transylvania County Page 2 September 8, 2017

Virginia Spiraea occurs along some rocky, flood-scoured riverbanks in gorges. Gravel and rock
bar habitat for this plant is not present. Swamp Pink and Mountain Sweet Pitcher Plant are found
in some wetlands in the region, but there are no wetlands in the project area.

Carolina Northern Flying Squirrel, Rock Gnome Lichen, and Spreading Avens are found in
isolated high-elevation habits, though Rock Gnome Lichen can occur at lower elevations within
deep river gorges. The project area is much too low in elevation for these species. There is a
spray cliff a short distance downstream of the bridge, but the cliff has an eastern and open
exposure and is not in a gorge where Rock Gnome Lichen has sometimes been found. A survey
of the bridge and rocks near the bridge was conducted within construction limits and outside
limits along the upper portion of the cliff, but this plant was not found. Also, there are no records
of these species within a mile of the project site.

Small Whorled Pogonia usually occurs in open, dry, deciduous woods, often second growth,
though it can occur in more varied habitats provided there is ample sunlight reaching the forest
floor. The project site is bordered by forest, but it appears unsuitable for Small Whorled Pagonia
due to a thick mid-story cover of rhododendron. The construction work should also only impact a
limited amount of forested area near to the road.

Gray bats usually roost in caves or in/on structures year-round while NLEB only winter in caves
or mines. During warm seasons NLEB usually roost on/in structures, under the shaggy bark of
live trees such as white oaks, sycamores, and hickories, or in cavities or under the loose peeling
bark of dead trees. This project should not require blasting, but it will require the removal of
approximately 20 trees, possibly some short-term (periodically over 1-2 weeks) jack-hammering
for footer construction, and demolition of an old timber bridge. There was no evidence of bats or
roosting on the bridge during the field scoping and later survey work; absence of bats will be
confirmed prior to demolition. The bridge is not situated in a “red HUC” where known NLEB
maternity roosts and/or hibernacula are a concern and it is several miles from the nearest “red
HUC”. Therefore, the project is consistent with Section 4(d) rule, codified at 50 C.F.R. §
17.40(o) and effective February 16, 2016.

This project is limited in scope and habitat for listed species appears absent or far enough from
the bridge to not be affected. For these reasons and those discussed above, we recommend a “no
effect” determination for threatened and endangered species.

This project was reviewed by NCDOT’s Human Environment Unit in 2013 for potential affects to
historical architecture and archaeology. It was determined that no survey was required for either
historical architecture or archaeology.

Impacts to Waters of the United States

The Thompson River (labeled Bear Camp Creek on plans) (DWR Class: C Tr) is shown on the
USGS topographic map as a perennial stream. The channel is approximately 25 feet in width
with a substrate primarily composed of cobble, gravel and bedrock. The Thompson River flows
to Lake Jocassee/Toxaway River, which meets the definition of a Traditional Navigable Water.
For these reasons, we believe Thompson River is a Relatively Permanent Water and is under the
jurisdiction of the U.S. Army Corps of Engineers. In order to construct the project, it will be
necessary to impact waters of the United States in the French Broad River Basin (HUC
06010105). The impacts for the replacement of Transylvania Bridge No. 90 are listed in the table
below.

Bridge 90, Transylvania County Page 3 September 8, 2017

Site No. Existing Condition Proposed Condition Net Impact
Site 1 Streambanks and
Timber Bridge
Rip rap banks upstream,
under, and downstream of
new bottomless culvert
110’
Site 1A Free Flowing Stream
and Streambanks
Temporary Impervious Dikes
and Flow Diversion 125’

Permits Requested

NCDOT is hereby requesting authorization under Section 404 of the Clean Water Act to proceed
with the construction project outlined above. We request that Ms. Marla Chambers, Western
NCDOT Review Coordinator, with the North Carolina Wildlife Resources Commission
(NCWRC) comment directly to you concerning the 404 Nationwide Permit action. I also request
from Mr. Kevin Barnett with the North Carolina Department of Environment Quality (DEQ),
Division of Water Resources (DWR) authorization for the project under Section 401 of the Clean
Water Act.

Please contact me at [phone] or Mr. Josh Deyton, PE, at [phone] if you have any
questions about the application or project or need additional information. I greatly appreciate
your prompt attention to these requests.

Sincerely,

Dave McHenry
Division 14 Environmental Program Supervisor

Enclosures

cc: Amy Chapman, Division of Water Resources – DEQ, Raleigh
Kristi Carpenter, Division of Water Resources – DEQ, Raleigh
Kevin Barnett, Division of Water Resources – DEQ, Asheville
Marella Buncick, Biologist, US Fish and Wildlife Service, Asheville
Marla Chambers, Western NCDOT Review Coordinator, NCWRC
Joshua B. Deyton, PE, Division 14 Bridge Management Engineer, NCDOT
Reid Whitehead, Roadside Environmental Field Operations Engineer, NCDOT

9/8/2017