20221394 Ver 1_BP13.R001_DWR 20221394_Bridge 274_Yancey_GP Application__NCWRC Comments_20221024

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
October 24, 2022
Lori Beckwith
U.S. Army Corps of Engineers, Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
Kevin Mitchell
NCDEQ, DWR
2090 U.S. Hwy. 70
Swannanoa, N.C. 28778
SUBJECT: Comments on GP/WQC Application for Replacement of Bridge 274 on Bradford Road
(SR 1410) over Little Creek, Yancey County (BP13.R001, SF-990274)
DWR 20221394 ver.I
Dear Ms. Beckwith and Mr. Mitchell,
The North Carolina Department of Transportation (NCDOT) applied for a General 404 Permit and 401
Certification for the subject project. I am familiar with the wildlife resources in the area and visited the
project site on October 21, 2022. Comments on the application from the North Carolina Wildlife
Resources Commission (NCWRC) are offered to help conserve the wildlife resources affected by the
project and to promote wildlife -based recreation in accordance with applicable provisions of the state and
federal Environmental Policy Acts (G.S. 113A-1through 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 existing timber bridge on SR 1410 over Little Creek (C Tr) is being replaced with a 2� 10'x7'
reinforced concrete box culvert (RCBC). Additionally, a 60" corrugated metal pipe in a tributary to Little
Creek near the bridge will be replaced and extended with an 87"x63" corrugated streel pipe arch, or
"squash pipe". There is a scour pool below the existing culvert (see photo). This pool dissipates stream
velocity, but the clean and perched condition of the culvert may impede aquatic life movements as well.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

BP13.R001 Page 2 October 24, 2022
Yancey County
Little Creek at the project site is not designated as a trout water by the NCWRC but it does support a wild
rainbow trout population. Little Creek may also support sharphead darter (Etheostoma acunceps), a
North Carolina threatened species endemic to the Nolichucky River system. The tributary to Little Creek
appears large enough to support fish, though many tributaries in the Little Creek drainage were void of
trout in 2008.
I was unable to find scoping comments, if any, from the NCWRC on this bridge replacement project.
When trout waters are affected, the NCWRC supports an evaluation and justification where conversion of
bridges to culverted crossings are pursued. In this case, my site visit affirmed that the structure (barn) and
adjoining drive were likely key factors for culvert selection here. The NCWRC does not object to the
proposed culvert provided there is documentation that a bridge, including consideration of a vertical
abutment on the west side, was evaluated and deemed not practicable.
The NCWRC recommends that the proposed project design be refined to minimize the potential for
aquatic life passage problems and stream instability. First, as generally consistent with current NCDOT
hydraulic guidance, at least one interior baffle should be added to the low flow barrel of the RCBC to
promote bedload retention and provide backwatering should the culvert not retain sediment following
high flows. The tops of the dowel pins holding the sills also should be deformed to prevent "lifting" of
these structures over time. A second recommendation is construction of a boulder sill immediately below
outlet of the site 1 culvert to promote backwatering and sediment retention. The sill should be
constructed to a height of one foot above the culvert invert and gradually slope/transition into the
downstream riffle. This area is roughly at the grade control point of the existing scour pool and will
already be excavated for the culvert extension, bedding, and/or dewatering.
In addition to incorporating, as possible, the above design refinements, the NCWRC recommends that the
following special conditions be included in authorizations to help conserve trout and other aquatic
resources affected by the project:
1. Only clean native material from the streambed, and not deeply excavated non -deposited soils
below the stream, should be used to backfill the low flow RCBC barrel. A mixture of native
material with class B and 1 is recommended if sufficient clean native material is not available.
Native material should be used to top dress any rip rap that is used or, preferably, mixed with rip
rap before placement.
Applicable measures from the current NCDOT Erosion and Sediment Control Design and
Construction Manual should be adhered to. Measures for sensitive-HQW areas are
recommended at this location. In accordance with standard GC conditions matting used in
riparian areas should not contain nylon mesh because it entangles and kills wildlife. Coir matting
should be used on disturbed stream banks that are steep or susceptible to high water and securely
anchored with wooden stakes according to NCDOT specifications.
3. Heavy equipment needs to be well -maintained and concrete pouring needs to be closely
monitored to avoid and quickly mitigate fuel, fluid, or wet concrete losses in or near streams.

BP13.R001 Page 3 October 24, 2022
Yancey County
4. Backfill placed immediately below culvert outlets should be compacted to the invert burial depth
to help prevent the material from scouring.
5. Native trees and shrubs should be planted on the banks of removed bridge approaches (Detail 7).
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at david.mchenrykncwildlife.org or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
ec: Roger Bryan, NCDOT Division 13 Environmental Officer
Site 1. Facing upstream into 60-inch culvert in UT Little Creek under Bradford Road.