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NOR I H CARUI INi�
EnNronmenml Qimfily
January 17,2018
To:
From:
MEMORANDUM
Sean Matuszewski, NCDOT Division 6
Joanne Steenhuis, NC Division of Water Resources, Wilming[on Regional Office ���
Subject: Scoping comme�ts on proposed widening of SR I 107 (Fistier Road) from SR I l04 (Strickla�d Bridge
Road)to NC l62 (Bingham Drive/George Owen Road)in Cumberland County, TIP U-6073.
Reference your correspondence dated llecember 21, 2018 in which you requested comments for the referenced
projecL Preliminary analysis of the projec[ reveals the potential for nwl[iple impacts to streams andjurisdictional
wetlands in the project area. More specifically, impacts to:
Stream Name River Basin Stream S[ream Index 303(d) Listing
Classification s Number
Beaver Creek Beaver Creek Pond Ca e Fear C 18-31-24-5 N/A
Further investigations at a higher resolution should be undertaken [o verify the presence of other streams and/or
jurisdictional wetlands in Ihe area. I� the event that anyjurisdictional areas are identified, the Division of Water
Resources requests tha[ NCDOT consider the following emironmental issues for the proposed project
Project Specifc Comments:
L To mee[ the requirements of NCDOT's NYDES permit NCS00025Q the road design plans shall provide
treatment of Ihe stormwater runoff through BMPs as de[ailed in the most recent version of the North Cnrdinn
Depnrhnervt ofTransportation S[a•mwnter l3est Munugement Po�actices Toolbox manual. The BMPs shoold, to
Ihe MEY, be selected and designed to reduce impacts of [he target pollutants of concern (POCs) for the
receiving waters.
General Project Comments:
2. '1'he environmental document should provide a detailed and itemized presentation of the proposed impacts to
wetlands and streams with corresponding mapping. If mitigation is necessary as required by 15A NCAC
2H.0506(h), it is preferable to present a conceptual (if not finalized) mitigatio� pla� with the environmental
documentation. Appropriate mitigation plans will be required prior to issuance of a 401 Water Quality
Certification.
3. Environmei�tal impact statement altematives shall consider design criteria that reduce the impacts [o streams
and we[lands &om storm water runof£ These alterna[ives shall include road designs that allow for treatment of
the storin wa[er runoff [hrough BMPs as detailed in the most recen[ version of the Nw�th Cui•oliim De�nrhneni
ofTransportatioiv S7ormwater Best Mmaagement Praclices Tool box manual, soch as grassed swales, buffer
areas, prefom�ed scour holes, re[ention basins, etc.
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4. After the selection of the preferred alternative and prior to an issuance of the 40l Water Quality Certification,
[he NCDOT is respectfully reminded that they will need to demonstrate the avoidance and minimization of
impacts to wetlands (and streams) to [he maximum extent practicaL In accordance with the Environmental
Management Commission's Rules (15A NCAC 2H.0506[h]), mitigation will be required for impacts of
greater than 1 acre to wetlands. In the event that mitigation is required, the mitigation plan shall be designed
to replace appropriate lost functions and values. North Cazolina Division of Mitigation Services may be
available for assistance with wetland mitigation.
5. In accordance with the Environmental Management Commissiods Rules (15A NCAC 2H.0506[h]),
mitigation will be required for impacts of geater than 3001inear 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 Cazolina Division of Mitigation Services may be available for assistance with stream
mitigation.
6. Future documentation, including the 401 Water Qualiry Certification Application, shall continue to include an
itemized listing of the proposed wetland and stream impacts with corresponding mapping.
7. 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 [he aquatic
environments and any mitigating factors that would reduce the impacts.
8. 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 10, 2004.
9. The NCDOT is respectfully reminded that all impacts, including but not limited to, bridging, fill, excavation
and clearing, and rip rap to jurisdictional wetlands, streams, and riparian buffers need to be included in the
final impact calculations. These impacts, in addition to any construction impacts, temporary or otherwise,
also need to be included as part of the 401 Water Quality Certification Application.
10. 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 streams are impacted, a bridge may prove preferable. When applicable, the NCDOT
should not install the bridge bents in the creek, to the masimum extent practicable.
11. Whenever possible, the NCDWR prefers spanning structures. Spanning structures usually do not require
work within the sVeam or grubbing of the streambanks and do not require sheam channel realignmenC 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.
12. Bridge deck drains shall not discharge directly into [he 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 NCS000250, please refer
to the most recent version of the North Carolina Department of Transpor�ation Stormwater Best Management
Practices Toolbox manual for approved measures.
13. Sediment and erosion control measures should not be placed in wetlands or streams.

14. Borrow/waste areas should avoid wetlands to the maximum extent practical. Impacts to wetlands in
borrow/was[e areas will need to be presented in the 401 Water Quality Certificatio� and could precipitate
compensatory mitigation.
l5. 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. To meet the requirements of NCDOT's NPDES permit NCS000250, please refer
to the most recent version of the North Carolina Department of Transportatron Stormwater Best Management
Practrces Toolbox manual for approved measures.
16. The DWR cannot comment on permit requirements with the limited information provided. Detailed field
delineation is required to determine the presence or absence of jurisdic[ional resources within the project
limits. In addition, NCDOT must provide an estimate to any resources located within the construction limits
of the project area before we can specifically comment on NCDWR permit eligibility. Final permit
authorization will require the submittal of a formal application by the NCDOT and written concurrence &om
the NCDWR. Please be aware that any approval will be contingent on appropriate avoidance and
minimization of wetland and stream impacts to the ma�cimum extent practical, the development of an
acceptable stormwater management plan, and the inclusion of appropriate mitigation plans where appropriate.
l7. If concrete is used during construction, a dry work area shall be maintained to prevent direct contact between
curing concrete and stream wa[er. Water that inadvertently contacts uncured wncrete shall not be dischazged
to surface waters due to the potential for elevated pH and possible aquatic life and fish kills. Concrete shall
be handled in accordance with the NPDES Construction General Permit NCGO10000.
18. If temporary access roads or detours are consuucted, the site shall be graded to its preconstruction contours
and elevations. Disturbed areas shall be seeded or mulched to stabilize [he soil and appropriate native woody
species shall be planted. When using temporary structures, the area shall be cleared but not grubbed.
Clearing the area with chain saws, mowers, bush-hogs, or other mechanized equipment and leaving the
swmps and root mat intact allows the area to re-vegetate natwally and minimizes soil distwbance.
19. Unless otherwise authorized, placement of wlverts and other structures in waters and streams shall be placed
below the elevation of the streambed by one foot for all culverts with a diameter geater than 48 inches, and
20 percent of the culvert diameter for culverts having a diameter less than 48 inches, to allow low tlow
passage of water and aquatic life. Design and placement of culverts and other structures including temporary
erosion control measures shall not be conducted in a manner that may result in dis-equilibrium of wetlands or
streambeds or banks, adjacent ro 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 feamres 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.
20. If multiple 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. SVeam 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.
2 L If foundation test borings are necessary; it shall be noted in the document. Geotechnical work is approved
under General 401 Certification Number 4085/Nationwide Permit No. 6 for Survey Activities.

22. Sediment and erosion control measures suf£icient to protect water resources must be implemented and
maintained in accordance with the most recent version of North Carolina Sediment and Erosion Con[rol
Planning and Design Manual and the most recent version of NCS000250.
23. 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.
24. While the use of National Wetland Inventory (N WI) maps, NC Coastal Region Evaluation of Wetland
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.
25. 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 i�to streams. This equipment shall be
inspected daily and maintained to prevent contamination of surface waters from leaking fuels, lubricants,
hydraulic fluids, or other toxic materials.
26. 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.
27. Riparian vegetation (native trees and shrubs) shall be preserved to the mazcimum extent possible. Riparian
vegetation must be reestablished within the construction limits of the project by the end of the gowing 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 aze met and
designated uses aze not degraded or lost. If you have any questions or require additional information, please contact
Joanne Steenhuis at [phone] or [e-mail].
Electronic copy only distribution:
Jim Rerko, NC DOT Division 6 DEO
Liz Hair, US Army Corps of Engineers, Wilmington Field Office
Kristi Lynn Carpen[er, NCDWR
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