2200563 Ver 1_WRC Comments_20220506

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director

Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

May 3, 2022

Eric Alsmeyer
Regulatory Division Office
US Army Corps of Engineers, Wilmington District
3331 Heritage Trade Drive, Suite 105, Wake Forest, NC 27587

Donna Hood
NCDEQ, DWR
610 East Center Avenue, Suite 301, Mooresville, NC 28115

Dear Mr. Alsmeyer and Ms. Hood,

SUBJECT: Comments on 404/401 Application for Brawley School Road Widening (SR 1100)
Iredell County
R-3833C, WBS 34554.1.3, DWR 20220563 ver.1

The North Carolina Department of Transportation (NCDOT) Division 12 applied for a 404 Permit and
401 Certification for stream and wetland impacts to widen a section of Brawley School Road (SR 1100)
in Iredell County. I visited the project site on May 2, 2022. Comments on the application from the North
Carolina Wildlife Resources Commission (NCWRC) are offered in accordance with applicable provisions
of the state and federal Environmental Policy Acts (G.S. 113A-1 through 113-10; 1 NCAC 25 and 42
U.S.C. 4332(2)(c), respectively), the Clean Water Act of 1977 (33 U.S.C. 466 et seq.), and the Fish and
Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661-667d).

The project will impact a UT to the Catawba River (Lake Norman, WS IV B CA) for the replacement and
extensions of dual corrugated metal pipes (CMP) with a two-cell reinforced concrete box (RCBC). This
stream has fair-good quality aquatic and riparian habitats upstream of the project area despite the urban
setting. Also proposed are the relocation of two small stream channels on the north side of the road. The
CMPs are functioning well and currently passing aquatic life and wildlife along the forested stream
corridor. The stream to the northwest of the proposed RCBC (Site 1) was dry when I visited. The stream
R-3833C Page 2 May 3, 2022
Iredell County
to the NE of the proposed RCBC (Site 3) and dry detention basin was flowing and supports fish, though
habitat is poor due to past realignment/s.

The proposed embedment (“key-in”) of the rip rap on the channel relocations alone may not restore
surface flow of the streams because of class II lining. The possibility of realigning the stream at Site 3
around the proposed energy dissipator basin should be considered if it would allow the use of smaller
sized, or less, channel protection. Class II rip rap also would impede wildlife use in the high flow barrel
of the RCBC, and on the benches, though the sandy bedload of the UT may ultimately fill in some
interstitial spaces over time.

The NCWRC recommends that the following be incorporated into the project and authorizations to help
conserve wildlife resources.
1. Class II rip rap that is used in high flow barrels, on floodplain benches, and the channel relocation
at site 3 should be top-dressed with native streambed materials and/or smaller stone and aggregate
to facilitate wildlife passage and avoid burial of low stream flows. Current NCDOT Hydraulic
Unit guidance includes this prescription for high flow barrels.
2. In accordance with standard GC conditions matting with nylon mesh should be avoided near
streams particularly around the stream by the dry detention basin and stream relocations which
will themselves attract wildlife.
3. Rip rap placed for bank stabilization should be limited to the banks below the high-water mark
and vegetation should be used for stabilization above the high-water elevation wherever
practicable.
4. Removal of vegetation in riparian areas and wetlands should be minimized. Banks on stream
relocations and abandoned roadways should be reforested where there are not conflicts such as
permanent access and routine maintenance needs. This may include the north side of Site 1
between the relocated channel and the CA and UT.

Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at [e-mail] or [phone] if you have any questions about these comments.

Cordially,

Dave McHenry, NCWRC Western DOT Coordinator

ec: Bryan Sowell, PE NCDOT Division 10 Project Engineer
Jeff Wyatt, NCDOT Division 10 DEO