20191362 Ver 2_WRC Comments_20220722

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
July 22, 2022
Eric Alsmeyer
Regulatory Division Office
US Army Corps of Engineers, Wilmington District
3331 Heritage Trade Drive, Suite 105, Wake Forest, NC 27587
Amy Chapman
NCDEQ Division of Water Resources, Transportation Permitting
512 N. Salisbury St., Archdale Building, 12th floor
Raleigh, NC 27604
SUBJECT: Comments on Application for Replacement of Stanley County Bridge No. 162 on SR
1923 over Hardy Creek, Stanly County
WBS 1713P.R.10.133, DWR 20291362 ver.2
Dear Mr. Alsmeyer and Ms. Chapman,
The North Carolina Department of Transportation (NCDOT) applied for a 404 Permit and 401
Certification for the subject project. North Carolina Wildlife Resources Commission (NCWRC) staffs are
generally familiar with the wildlife resources in the area. Comments on the application from the 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 existing bridge will be replaced with a new cored slab structure. Most of the anticipated stream
impact is for temporary dewatering. The existing concrete abutments will be cut-off approximately one
foot above the streambed elevation; class II rip rap will extend from these shortened abutments to the new
bridge caps. There also is a roadside stream that will be shifted south to accommodate the new wider
bridge and approaches. A detail for the channel change was not noted in the drawings but an unarmored
channel alignment is shown.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

1713P. R. 10. 13 3 Page 2 July 22, 2022
Stanley County
A mussel survey conducted for this project in 2022 was negative. Creeper mussel (Strophitus undulatus,
NC Threatened) and unidentified Elliptio sp. mussel were collected in Hardy Creek in 2001 but those
records are from more than a mile downstream of this bridge. Hardy Creek periodically dries up at the
bridge as well. Therefore, the construction should not directly harm rare mussels provided effective best
management practices for erosion control are used during construction.
This project includes full armoring of the stream banks under the bridge. As a general practice, the
NCWRC recommends avoiding this to encourage wildlife that otherwise avoid rocky terrain to cross
roadways under bridges. Where full armoring is needed, for instance when deep scour is a concern, some
of the rip rap should be top -dressed with native streambed materials and/or smaller stone and aggregate to
create a functional pathway for wildlife. The proposed bridge will only be 3-4 feet above the streambed
and will likely experience high scour flows, particularly during the relatively frequent overtopping that is
predicted. Therefore, the NCWRC is not recommending the preceding wildlife passage measures in this
situation.
While effects of the project on wildlife resources are not expected to be appreciable, the NCWRC
nonetheless recommends incorporation the following measures to help ensure effects are minimal:
1. The channel change should be lined on either side with coir matting that is secured with wooden
stakes or rebar in accordance with NCDOT specifications. Other types of matting are often too
light to resist flood flows. And, matting with nylon mesh should not be used as it can entangle
and kill wildlife, often for several years.
2. The bottom of the channel change should be lined with natural stone harvested from the old
channel, if suitable. Embedded rock sills or similar grade control are recommended (and may be
already planned) if the slope will make the channel prone to scour.
Thank you for the opportunity to review this project. Please contact me at av d n chenry(�r)ncwildlife.or
or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
ec: Joel Howard, NCDOT Division 10 DEO