20221675 Ver 1_Email about bottomless culvert_20230615 (4)

Baker, Caroline D
From: Homewood, Sue
Sent: Thursday, June 15, 2023 8:49 AM
To: Dailey, Samantha J CIV USARMY CESAW (USA); Williams, Kim
Cc: Matthew Mobley; Nick Bushon; Ryan Xu; Hoy, Arnie
Subject: RE: [External] RE: [Non-DoD Source] Fwd: Northlake St Extension; Action ID#
SAW-2022-01661 & DWR Project # 20221675
Hello Kim,
Based on the determination by the USACE, if no 404 is required then there is no requirement for a 401 from DWR. For
use of NWP33, I encourage you to review the thresholds and conditions of 401 General Certification 4260 to determine
if the project is eligible for use of the General Certification or would trigger the need for an Individual 401.
I would also like to provide some other comments for your consideration based on the Divisions long experience with
bottomless culverts.
Because of shading impacts, vegetation along the streams banks under the culvert is often
unsustainable. Especially when the area has been temporarily disturbed. I caution you to carefully consider
whetherjute matting will be sufficient to stabilize the stream banks in this area.
Destabilization of stream banks can lead to water quality violations from over widening, erosion of the channel
under the culvert and/or upstream or downstream, and potential sedimentation impacts downstream. Stream
destabilization can lead to undermining of footings of the culvert when they are not tied into bedrock.
The permittee and/or landowner would be responsible for resolving any water quality violations that result from
culvert installation. In addition, any culvert repairs required due to destabilization would be cumulative with
other impacts within the project and mitigation may be required for any future impacts due to
repairs/restoration.
Thanks,
Sue Homewood (she/her/hers)
401 & Buffer Permitting Branch
Division of Water Resources
[e-mail] please note my new email address
336 813 1863 mobile
919-707-3679 office
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Dailey, Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Sent: Tuesday, May 30, 2023 10:27 AM
To: Williams, Kim <[e-mail]>; Homewood, Sue <[e-mail]>
Cc: Matthew Mobley <[e-mail]>; Nick Bushon <[e-mail]>; Ryan Xu <[e-mail]>
Subject: [External] RE: [Non-DoD Source] Fwd: Northlake St Extension; Action ID# SAW-2022-01661 & DWR Project #
20221675

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Hi Kim,
Based on the information in your email, it does appear the arched culvert would not be installed below the ordinary high
water mark; and would not require a permit from our office. Further, this office concurs with the use of a non -notifying
NWP 33 for the temporary impacts required to facilitate the culvert installation. You may proceed with your project as
proposed.
Please let me know if you have any additional questions.
Sam Dailey (she/her)
Chief, Charlotte Regulatory Field Office
U.S. Army Corps of Engineers, Wilmington District
8430 University Executive Park Drive, Suite 615
Charlotte, NC 28262
Email: [e-mail]
Cell: [phone]
From: Roden Reynolds, Bryan K <Bryan.K.Roden [e-mail]>
Sent: Tuesday, May 30, 2023 10:00 AM
To: Williams, Kim <[e-mail]>; Roden Reynolds, Bryan K <Bryan.K.Roden [e-mail]>;
Homewood, Sue <[e-mail]>
Cc: Matthew Mobley <[e-mail]>; Nick Bushon <[e-mail]>; Ryan Xu <[e-mail]>; Dailey,
Samantha J CIV USARMY CESAW (USA) <[e-mail]>
Subject: RE: [Non-DoD Source] Fwd: Northlake St Extension; Action ID# SAW-2022-01661 & DWR Project # 20221675
Good morning Ms. Williams,
Thank you for reaching out to the Corps regarding this project. I no longer work for the Wilmington District; therefore I
CC'd Ms. Sam Dailey (Charlotte Field Office Chief) as she can determine which PM in the CFO will be handling this project
going forward.
Thank you and have a great day.
Thanks,
Bryan Roden -Reynolds
Sent with BlackBerry Work
(www.blackberrv.com)
From: Williams, Kim <[e-mail]>
Date: Friday, May 26, 2023 at 8:19 PM
To: Roden Reynolds, Bryan K <Bryan.K.Roden [e-mail]>, Homewood, Sue <[e-mail]>
Cc: Matthew Mobley <[e-mail]>, Nick Bushon <[e-mail]>, Ryan Xu <[e-mail]>
Subject: [Non-DoD Source] Fwd: Northlake St Extension; Action ID# SAW-2022-01661 & DWR Project # 20221675

Hi Bryan and Sue
You may recall in February we obtained Section 404/401 permits for the Northlake Street Extension project to impact a
stream and wetlands associated with road crossings within the site. As an avoidance/minimization measure, the
applicant also plans to span two stream crossings with bottomless culverts. We have a question about one of these
bottomless culverts - specifically the smaller culvert under Backpacker Way per the screenshot below:
YI®�VN'
4 A /
CDOT typically requires a project to adhere to expensive bridge guidelines once a span exceeds 20 feet. The City
previously determined that the applicant could use a larger culvert span for this crossing and bury the structure to stay
under this 20' (exposed) threshold, which is what was originally planned.

LIMITS OF CAST -IN -PLACE RETAINING WALI
(BY OTHERS)
17'-10"
EXPOSED SPAN*
CONTECH ALUMINUM STRUCTURAL
PLATE SINGLE RADIUS PIPE ARCH,
OR APPROVED EQUAL
R=12'-
//
EXISTING) L
GROUND
100-YEAR-T�-
WSE (TYP) t4*
CONCRETE FOOTING
(BY OTHERS)
23'-0"
SPAN*
SECTION B-B
3'-6"
EXPOSED RISE* -
RISE*
OTH
However, CDOT recently determined that they would be looking at TOTAL span (not the exposed span) and anything
over 20' would be subject to their bridge guidelines. Because of the costs associated with these guidelines, the engineer
is evaluating options to reduce the crossing width. One option is to use an aluminum culvert with footings not tied to
bedrock. But they also need to maintain the smaller vertical rise (no more than +/- 3.5') to accommodate the sewer and
storm crossings in this area. In order to do that, the contractor would need to take the stream banks down to the
ordinary high water line:
MSE WAi
LIMiIS OF CASI-IIN 'L
(BY OTHERS)
(B" OTI
19'
S'A
CONItCH ALUMINUM SIRUCIURAL
'LATE SINGLE RADIUS PIPE ARC-i,
OR APPROVED FOUAI
R=10'-3-1/2"
LXIS IINO�
GROUNDIQU
SE YEAR WSE (TYP)
(�
CONCRETE FOOTING
(BY OTHERS)
SECTION B-B
SCALE: 1" = 50'
6,-4
RISE
NO GRADING BELOW
ORDINARY HIGH
WATER LINE
4

Once the culvert is installed, they can restore the banks to pre -construction elevations and then stabilize them with jute
matting.
It's my understanding that the ordinary high water line is the jurisdictional limit of a stream. Therefore, this option
would not be considered an impact. Can you review this information and let me know if you agree? Additionally, if the
contractor did need to temporarily grade down below the OHWL to install the footers, could that be a non -notifying
authorization under a NWP 33/GC 4260? Temporary impacts would be 75 LF of stream.
Let me know what you think.
Thanks so much!
Kim
Kim Williams I Section Manager
Davey Resource Group, Inc.
Direct: 910-452-0001 x 1908 1 Cell: 910.471.5035 1 Fax: [phone]
3805 Wrightsville Ave., Suite 15 1 Wilmington, NC 28403