20201818 Ver 1_WRC Comments_20220325

® North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
March 25, 2022
Andy Williams
Regulatory Division Office
US Army Corps of Engineers, Wilmington District
3331 Heritage Trade Drive, Suite 105, Wake Forest, NC 27587
Dave Wanucha
NCDEQ, DWR
450 Hanes Mill Road, Suite 300
Winston Salem, NC 27105
Dear Mr. Williams and Mr. Wanucha,
SUBJECT: Comments on GP/WQC Application for replacement of Rowan County Bridge No. 248
on SR 1211 over Grants Creek
17BP.9.R.82, DWR 20201818 ver.1
The North Carolina Department of Transportation (NCDOT) Division 9 applied for a General 404 permit
and WQC to replace Rowan County Bridge No. 248 on SR 1211 over Grants Creek using a triple
reinforced concrete box. I visited the project site on March 24, 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-Ithrough 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 typically recommends replacement of bridges in -kind partly due to difficulties bypassing
stream flow for extended periods for culvert excavation, forming, and pouring. The NCWRC is pleased
that NCDOT will be able to accommodate an off -site detour here, which should help expedite
construction and thereby limit the number of storm events and possible over -topping that may occur.
Dewatering for this project may also be particularly challenging due to the convergence of the two
streams immediately upstream. If temporary piping is used, the NCWRC recommends that the design (or
proposal by the contractor if a dewatering plan is not prepared) include the maximum capacity
conveyances that are possible.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

17BP.9.R.82 Page 2 March 25, 2022
Rowan County
A single low flow barrel, versus the dual proposed, is generally preferred due to the potential for debris
accumulation and channel destabilization from mid -channel obstructions. However, the NCWRC does
not have a major concern with a permit variance in this situation since the flow split may not be
problematic with the two channels converging at the inlet.
Of potentially more concern is the streambed grade change that the culvert will handle after the sewer line
is repositioned. The exposed concrete cover and rip rap fill for the existing sewer line is providing grade
control (see photograph 3 of delineation materials). Although the SNIP indicates little difference between
the stream and culvert slopes, the SNIP also indicates there will be appreciable velocity increases, which
is expected with a design showing a culvert slope of 1.5% versus —0.5% upstream and downstream. The
culvert may not retain bedload fully even with the sills due to this condition. Therefore, the NCWRC
recommends that, in this situation, NCDOT proceed with placing rip rap in the low flow barrels, as
referenced as a potential in the application. Also as noted, this rip rap should be top -dressed with native
material even though it would likely be embedded quickly anyway due to the sandy sediments coming
down Grants Creek.
There is limited wildlife passage under the existing bridge (mostly opossum, ironically), partly due to
limited dry bank. The high flow barrel and backfilling may increase usage. The NCWRC appreciates the
incorporation of this design, and inclusion of low-cost rip rap -free benches under bridges, to further
reduce human -wildlife interactions.
The NCWRC requests that the following specific comments and recommendations also be incorporated
into the permit construction work to further conserve fish and wildlife habitats:
1. Heavy equipment must be well -maintained and concrete pouring closely monitored to avoid and
quickly mitigate fuel, fluid, or wet concrete losses in or near streams.
2. Sandbags, rock berms, cofferdams, or other diversion structures should be used where excavation
or other periods of extended stream disturbance has the potential for downstream sedimentation.
These structures should have the maximum capacity possible to reduce the likelihood of
overtopping during floods.
3. The natural dimension, pattern, and profiles of streams and the grades of wetlands should be
restored where temporarily impacted.
4. 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.
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: Amy Euliss, NCDOT Division 9 DEO