20110713 Ver 1_Other Agency Comments_20081203

United States Department of the
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
December 1, 2008
Ms Tracy A Walter
Project Development and Environmental Analysis Branch
North Carolina Department of Transportation
1551 Mail Service Center
Raleigh, North Carolina 27699-1551
Dear Ms Walter
Interior
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Subject Bridge Replacement No 31 on SR 1308 over Brush Creek, Yancey County, North
Carolina (TIP No B-4851)
We have reviewed the Natural Resources Technical Report for the, subj ectr bridge replacement
project and are providing the following comments in accordance with,the National
Environmental Policy Act (42 U S C 4332(2)(c)) (NEPA), Fish and Wildlife Coordination Act,
as amended (16 U S C 661-667e), Migratory Bird Treaty Act (16 U S C 703, et seq ) (MBTA),
and section 7 of the Endangered Species Act of 1973, as amended (16 U S C 1531-1543)
Fish and Wildlife Resources - The information provided for this project does not include a
detailed description of the structure that will replace the existing bridge When more information
is available regarding environmental effects and design specifications, we can offer more
substantive comments We strongly recommend that the existing bridge be replaced with a
bridge, and we request that the NEPA document for this project address an alternative of
replacing the existing bridge with a new one If an alternative other than the replacement of the
existing bridge with a new bridge is chosen (such as replacing the existing bridge with a culvert),
we request that the NEPA document include the rationale for that alternative
We recommend that the new bridge design include provisions for the roadbed and deck drainage
to flow through a vegetated buffer prior to reaching Brush Creek This buffer should be large
enough to alleviate any potential effects from the runoff of storm water and pollutants The
bridge design 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 stream The
bridge and approaches should be designed to avoid any fill that will result in the damming or
constriction of the channel or floodplain To provide for terrestrial wildlife passage, the new
bridge design should span beyond the waterway so that unsubmerged land is also bridged If
bank stabilization is necessary, we recommend that the use of riprap be minimized and that a
riprap-free buffer zone be maintained under the bridge to allow for wildlife movement If
spanning the floodplam is not feasible, culverts should be installed in the floodplam 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 sediment should be in place prior to any ground-disturbing
activities Wet concrete should never be allowed to come into contact with the water
Equipment should be inspected daily to ensure that there are no equipment leaks that could enter
the lake Construction material should not enter the water during demolition of the existing
bridge and construction of the new bridge In most cases we prefer that a bridge be replaced in
place by constructing the new bridge through staged construction or by detouring traffic to
existing off-site routes
When reseeding/revegetating disturbed areas, we strongly recommend that only native plant
species be used or, if an adequate seed source cannot be found, that noninvasive species (such as
annual rye) be used until native plants can reestablish themselves While many of the exotic
plant species typically used in erosion-control and reclamation efforts have proven beneficial to
some wildlife species, we now know that the invasive nature of these species outweighs any
short-term erosion-control or wildlife benefits they may provide Exotic species, including tall
fescue (native to Eurasia), Korean and Sericea lespedeza (eastern Asia species), redtop (a
Eurasian species), Sudan grass and Bermuda grass (native to Africa), and Kentucky bluegrass
(native to Eurasia and northern Canada), choke out native vegetation and often result in
monocultures that prove to be of little benefit to wildlife and can be very detrimental to the
ecosystem as a whole
Migratory Birds - The MBTA (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 the bridge and any
other migratory bird nesting habitat within the project area during the migratory bird nesting
season--March through September If migratory birds are discovered nesting in the project
impact area, including on the existing bridge, 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 bridge 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 bridge 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 - This project is located about 500 meters from the confluence of
Brush Creek and the North Toe River, which is occupied designated critical habitat for the
federally endangered Appalachian elktoe (Alasmidonta ravenehana) We have reviewed the
habitat assessment and mussel survey report for the Appalachian elktoe The information you
provided states that the North Carolina Natural Heritage Program (NCNHP) lists known
populations of the Appalachian elktoe in the North Toe River within 1 mile both upstream and
downstream of the Brush Creek confluence The project area was surveyed on September 25,
2007, and no individuals were found A 4-foot waterfall, which is likely a barrier to dispersal
from the North Toe, is located about 300 meters downstream of the bridge The NCNHP also
has records for the federally endangered Virginia spiraea (Spiraea virginiana) within 1 mile of
the project area However, suitable habitat does not exist in the project study area The NCDOT
has committed to using design standards for sensitive watersheds due to known locations of the
Appalachian elktoe and Virginia spiraea in proximity to the project In addition, stringent
measures to control sedimentation and erosion should be implemented for this project to preserve
water quality We have reviewed the habitat assessment for the federally endangered Virginia
big-eared bat (Corynorhinus townsendu virginianus) Good foraging habitat is present near the
project area, and several landowners have confirmed the presence of mines close to the project
The bridge is not the type preferred by bats for roosting, and no evidence of bats roosting on the
bridge was found To minimize impacts to foraging habitat, we recommend removing as little
vegetation as possible from the project area
If we can be of assistance or if you have any 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 Number 4-2-09-037
Sincerely,
W ?' ?L?
Brian P C e
6l-1- Field Supervisor
CC
Mr David Baker, Asheville Regulatory Field Office, U S Army Corps of Engineers, 151 Patton
Avenue, Room 208, Asheville, NC 28801-5006
Ms Marla J Chambers, Western NCDOT Permit Coordinator, North Carolina Wildlife
Resources Commission, 12275 Swift Road, Oakboro, NC 28129
Mr Brian Wrenn, North Carolina Division of Water Quality, Central Office, 2321 Crabtree
Boulevard, Suite 250, Raleigh, NC 27604