20210392 Ver 3_11C.195108_DWR 20210392v3_Justus Road_MWP 14 modification__NCWRC Comments_20231009

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
October 9, 2023
Lori Beckwith
U.S. Army Corps of Engineers, Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801
Dave Wanucha
NCDEQ, DWR
450 Hanes Mill Road, Suite 300
Winston Salem, NC 27105
SUBJECT: Comments on NWP 14 Modification for Justus Road (SR 1137), Watauga County
(IIC.095108), DWR 20210392 ver.3
Dear Ms. Beckwith and Mr. Wanucha,
The North Carolina Department of Transportation (NCDOT) applied for a modification of its permit and
certification for the subject project. Comments on the application from the North Carolina Wildlife
Resources Commission (NCWRC) are offered to 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 NCWRC supports the NCDOT replacing the undersized hydraulic structures placed in Clark Creek.
The proposed bottomless pipes, with much higher capacity, should help ensure passage of aquatic life in
the stream, including the wild brown trout (Salmo trutta).
The NCWRC also supports the stringent sediment and erosion control measures specified for the project.
Use of polyacrylamides (PAM) with ditch -line checks and use of matting or fiber matrix ground covers
and 7-day ground cover establishment in the trout buffer zones are likely necessary to prevent soil losses
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

11C.095108 Page 2 October 9, 2023
Watauga County
from the project. This project includes a considerable amount of ground disturbance, so these measures
will be particularly important to protecting water quality in Clark Creek during construction.
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
cc: Kevin Hining, NCDOT Division 11 Environmental Supervisor