20210344 Ver 1_USACE comments_questions re PCN for Bridge 122 in Ashe Co_20210702

Wanucha, Dave
From:Hining, Kevin J
Sent:Wednesday, June 30, 2021 4:32 PM
To:Beckwith, Loretta A CIV USARMY CESAW (USA)
Cc:Wanucha, Dave; Matthews, Monte K CIV USARMY CESAW (USA)
Subject:USACE comments/questions re PCN for Bridge 122 in Ashe Co.
Attachments:Ashe_122_Revised_Permit Drawings.pdf
Hey Lori,

I’ve attached the revised permit drawings for Ashe 122. I think they are much, much better – there are now no pipes in
the causeway, and we will stay < 50% blockage of the river at all phases of the causeway. During the revision, we also
noticed a mistake in the way the impacts were tabulated. As a result, we were able to reduce the impacts since much of
the area we will be stabilizing was previously hardened.

I’ll attempt to answer each of your questions below.

1) sounds good – I’m assuming the NW 14 vs NW 3 call is because the bridge will be wider than the old one (2 lane
vs 1 lane), and/or because it will be located just upstream of the old one. I’m fine either way, but just curious
for a better understanding for future PCN’s.
2) We have removed all pipes from the causeway and shrunk the size of the causeways. Previous discussions with
you and Dave Wanucha suggested we would not have to completely surround the center bent of the old bridge
for removal. This allowed us to stay <50% of river width with our causeway without the needs for pipes. I do
not expect much if any sedimentation issues from this, as the river bottom is very rocky and sandy, with little to
no fine sediments. Any sediment that is stirred up would be from sediments already in the river, and should
settle out almost immediately.
3) Pipes have been removed from the causeways, which should greatly lower potential risks to paddlers.
4) I’m hoping the removal of the pipes and a review of the permit drawings and causeway information will provide
you what you need.
5) There is no publicly accessible way for paddlers to exit the river immediately upstream of the bridge, as it is all
private property. However, the removal of the pipes and signage at the upstream public access should greatly
reduce risks to paddlers. Also, we will require all staff working on the bridge to keep an eye out for any river
users approaching the bridge, and have them halt any work occurring over the river until river users have
moved a safe distance away.
6) I understand - sounds good.

Let me know if you need any additional information, or need me to redo the PCN. With the changes to the permit
drawings and impacts, I’m fine completely redoing the PCN if preferred (not sure how to edit it after submitting
it….). Anyhow, I’ll be more than happy to do whatever you need, and hope this will get the us rolling again.

Thanks as always,

Kevin

Kevin Hining
Division 11 Environmental Supervisor
North Carolina Department of Transportation

828-386-7202 cell
1

[e-mail]

801 Statesville Rd.
PO Box 250
North Wilkesboro, NC 28659

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From: Beckwith, Loretta A CIV USARMY CESAW (USA) <[e-mail]>
Sent: Thursday, May 27, 2021 1:24 PM
To: Hining, Kevin J <[e-mail]>
Cc: Wanucha, Dave <[e-mail]>; Matthews, Monte K CIV USARMY CESAW (USA)
<[e-mail]>
Subject: \[External\] USACE comments/questions re PCN for Bridge 122 in Ashe Co.

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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,
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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:
- 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
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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

Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
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