North Dakota Code § 24-01-36

Bridges may be built separately
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While the necessary bridges on any state highway must be construed and considered a part 
of such highway, nevertheless, such bridges may be designed, erected, and contracts awarded 
separately therefor, and such bridges may be designed, erected, and contracted irrespective of 
the time when the highway contiguous thereto has been or may have been improved. All 
necessary fills and approaches to any bridge must be construed and considered as part of such 
bridge.

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