20180028 Ver 1_Cover Letter_20180105

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
ROY COOPER
GOVERNOR
January 5, 2018
Ms. Lori Beckwith, NCDOT Regulatory Project Manager
U. S. Army Corps of Engineers
151 Patton Avenue, Room 208
Asheville, NC 28801-2714
7AMES H. TROGDON, III
SECRETARY
Subject: Nationwide 14 Permit Application
Replace and extend one deteriorated culvert under SR 1344 (Dillard Road) in
UT Tuckasegee River
Jackson County
State Project No. 14.204911
Dear Ms. Beckwith:
The North Carolina Department of Transportation (NCDOT) needs to replace and extend one
corrugated metal culvert (cmp) in UT to the Tuckasegee River under SR 1344 with a larger
diameter pipe and extend pipe length by five linear feet. The work is being scheduled in advance
of paving due to the poor condition of the culvert. The culvert underlies 0.15 mile section of SR
1344 that will be widened slightly to current standards. Where possible, culverts will be
embedded partly below the natural stream grade to promote bedload retention and aquatic life
passage, though the streams do not appear large enough to support fish (none seen on site visit).
The road will be closed briefly and an off-site detour will be used during the pipe replacements.
Work will occur within existing right of way. We request verification of the permit since the
project does not qualify for non-noti�cation.
Enclosed are a PCN application, preliminary jurisdiction form, a USGS quad map, photographs,
and other pertinent project information to assist in your review.
In Jackson County, Carolina northern flying squirrel (Glaucomys sabrinus coloratus), gray bat
(Myotis grisescens), Indiana bat (Myotis sodalis), Appalachian elktoe (Alasmidonta raveneliana),
spruce-fir moss spider (Microhexura montivaga), swamp pink (Helonias bullata), small whorled
pogonia (Isotria medeoloides), rock gnome lichen (Gymnoderma lineare), and northern long-
eared bat (Myotis septentrionalis, NLEB) are known from current records (or suspected to occur)
and are federally-listed as either threatened or endangered.
Mailing Address:
NC DEPARTMENT OF TRANSPORTATION
Division 14
253 Webster Road
Sylva, North Carolina 28779
Telephone:[phone]
Fax: (828)586�043
Customer Service: 1-877-368-4968
Website: www.ncdot.¢ov
Location:
NC DEPARTMENT OF TRANSPORTATION
Division 14
253 Webster Road
Sylva, North Carolina 28779

SR 1344 Culvert Maintenance Page 2 January 5, 2018
The stream at the project site are too small for Appalachian elktoe mussels, but these mussels are
found near the culvert downstream in the Tuckasegee River. The Project site is adjacent to the
river. For these reasons, strict attention will be given to using effective temporary dewatering
during old culvert extraction and new culvert bedding and placement, which typically only takes
a few hours. Disturbed streambanks adjacent to the new culverts will be seeded and stabilized
immediately following culvert installation with anchored coir matting. Also, work will be
conducted when: (1) the 24 hour weather forecast for the area predicts a<0.5 inch rain
event, and/or (2) the 48 hour weather forecast for the area predicts a>0.5 inch rain event.
With these measure, we believe the project "may affect, but not adversely affect" Appalachian
elktoe mussels.
The work will occur in existing right of way and not require tree removal, blasting, or percussive
activities. The project area is not in a"red HUC" for NLEB. And, the culvert is much too small
to be used for bat roosts. Therefore, this project should have "no effect" on gray bats, Indiana
bats, or NLEB.
There are no wetlands near the culvert, so swamp pink will not be affected. Similarly, all areas to
be disturbed are non-forested road shoulders, so small whorled pagonia habitat is absent. And,
these plants were not observed during my visit to the project area.
The Carolina northern flying squirrel, rock gnome lichen, and spruce-fir moss spider are found in
spruce-�r forests and other isolated high elevation locations in western North Carolina.
However, rock gnome lichen is an exception because it can occasionally be found at lower
elevations in deep river gorges with high humidity or on some vertical rock faces that are
periodically wet. The project area is much too low in elevation for these species and there are no
damp rock faces nearby.
Stringent erosion and sedimentation control measures will be used to minimize adverse effects of
the work on aquatic habitats due to proximity to occupied habitat for Appalachian elktoe mussels.
Habitats for other listed species appear lacking at the project sites and none of the species known
from Jackson County were observed during field visits
Work of this scope falls under NCDOT's programmatic agreement with the State Historic
Preservation Office (see attached form). The work should not have any effect on cultural
resources since it only involves replacing existing corrugated metal pipe with a similar structure
within existing disturbed right of way.
Impacts to Waters of the United States
The UT to Tuckasegee River (DWQ Class: B; Tr) to be impacted are shown on the USGS
topographic map as perennial streams. The stream at the site has a well-de�ned channel
approximately 1-2 feet in width with substrates of sand, gravel, and silt. The Tuckasegee River
meets the definition of a Traditional Navigable Water (TNV�. For these reasons, we believe the
tributaries are Relatively Permanent Waters and 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 Little Tennessee River Basin (CU 06010203). Listed below is a summary of the
proposed impacts:

SR 1344 Culvert Maintenance Page 3 January 5, 2018
Eausting Condition Proposed Condition Net Impacts
Site No. (feet)
1 36"x 41' corrugated metal 48"x 46'corrugated metal 5
pipe (cmp) pipe (cmp)
Impervious Dikes and Temporary
lA UT of the Tuckasegee River Flow Diversion Fill 60
Permits Requested
NCDOT is hereby requesting authorization under Section 404 of the Clean Water Act to proceed
with the construction project outlined above. By copy of this letter, I am asking Mrs. Marla
Chambers, Western NCDOT Review Coordinator of the North Carolina Wildlife Resources
Commission (NCWRC), to comment directly to you and I concerning the 404 Nationwide Permit
request. This application has been sent to the North Carolina Department of Environmental
Quality (DEQ), Division of Water Resources (DWR) for a written certification.
Please contact me at [phone] if you have any questions about this application or need
additional information. Your prompt review and consideration of this request will be greatly
appreciated.
Sincerely,
�'�fi�c�� �n ��ac�
Patrick J. Breedlove
Division 14 - Environmental Specialist
Enclosures
cc: Ms. Marella Buncick, Biologist, US Fish &Wildlife Service, Asheville
Mrs. Marla Chambers, Western NCDOT Review Coordinator, NCWRC, Albemarle
Mr. Kevin Barnett, Division of Water Resources — DEQ, Asheville
Mr. Jonathon Woodard, PE, District 2 Engineer, NCDOT Division 14
Mr. Reid Whitehead, Roadside Environmental Field Operations Engineer, NCDOT