20210344 Ver 1_USACE comments_questions_20210616

Wanucha, Dave
From:Beckwith, Loretta A CIV USARMY CESAW (USA) <[e-mail]>
Sent:Thursday, May 27, 2021 1:24 PM
To:Hining, Kevin J
Cc:Wanucha, Dave; Matthews, Monte K CIV USARMY CESAW (USA)
Subject:\[External\] USACE comments/questions re PCN for Bridge 122 in Ashe Co.
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.

Kevin,

I reviewed the PCN for Bridge No. 122 in Ashe County and have the following comments and
questions.

1. 1. We will process this project under NWP 14 vs. a NWP 3.
2.
2. Please detail how NCDOT has avoided and/or minimized impacts, to include temporary impacts, to
waters of the U.S. by (a) exploring the option of removing the center bent without the need for the
currently proposed footprint of causeway fill, and (b) detailing NCDOT’s plan to keep the culverts free
of debris. Note that keeping the culverts free of debris is required by NWP general condition #14
(Proper Maintenance) which notes that, “Any authorized structure or fill shall be properly maintained,
including maintenance to ensure public safety and compliance with applicable NWP general
conditions, as well as any activity-specific conditions added by the district engineer to an NWP
authorization.”
3.
3. As noted in the PCN, NCDOT acknowledges the following: “Paddler Safety - While pipes in the
causeway pose a potential safety issue with recreational river users, there is very limited traffic on the
North Fork New River. The closest public access is approximately 8 miles upstream and there are no
outfitters on the North Fork New River, so usage is low. While the South Fork New River is a popular
floating area and is only 1/4 mile below Ashe 122, the likelihood of paddlers venturing up the North
Fork New River is extremely low due to the swift current and several riffles/drops in elevation
between the South Fork New River and Ashe 122.”
4.
The PCN also notes the following:
1

- Portions of the causeway will not be installed until needed, and will be removed immediately once
that portion of the project is complete.
- NCDOT will “…put up a sign at the NC HWY 16 access asking individuals to look out for workmen
and to make themselves seen before paddling under the Ashe 122 bridge.”
- Also, all staff working on the bridge will be instructed to look out for river users and to halt any work
overhead when river users are observed near or under the bridge.

Please detail NCDOT’s consideration of practicable alternatives to constructing the causeways in the
proposed configuration/extent of fill which requires the extensive use of culverts, especially in light of
NCDOT’s acknowledgment of the “…potential safety issue with recreational river users.”

5. 4. Based on the size of the watershed, please provide the hydraulic data/analysis that was conducted
to ensure that causeway material would not be disturbed/washed downstream by high flow events
and that the causeways themselves will not cause erosion or scour during high flow events.

6. 5. Is NCDOT willing to place a sign upstream of the bridge (a distance that is sufficient to allow a user
to exit the river safely), that (a) can be clearly seen and (2) notes the hazard ahead?

7. 6. Please note that, if authorized, special conditions concerning the removal of all material and
equipment from the causeways prior to expected high flow events will most likely be included in any
verification letter we issue for this project. We would also condition the verification to include signage
and halting work if river users are observed, as NCDOT has proposed. Finally, the typical conditions
used when causeways are involved would be included.

Once these issues are resolved, I’ll coordinate the PCN with the NPS for WSRA coordination, and
the USFWS for ESA consultation.

Thank you,

Lori

Lori Beckwith
Regulatory Project Manager
U.S. Army Corps of Engineers
Wilmington District
Asheville Regulatory Field Office
828-271-7980, ext. 4223

2

3