20201495 Ver 1_DWR 20201495v1_Monroe_Pindell culvert_NCWRC comments_final_20231211

9 North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
December 11, 2023
Emily Greer
U.S. Army Corps of Engineers Charlotte Regulatory Field Office
8430 University Executive Park Drive, Suite 615
Charlotte, NC 28262
Sue Homewood
NCDEQ, DWR
Mooresville Regional Office
610 East Center Ave, Suite 301
Mooresville, NC 28115
Dear Emily and Sue,
SUBJECT: Comments on NWP/401 Application for Town of Monroe's Pinedell Avenue Culvert
Replacement, Union County
DWR 20201495 ver.1
The Town of Monroe applied for a 404 Permit and 401 Certification for the subject project. Comments
on the application from the North Carolina Wildlife Resources Commission (NCWRC) are offered to
conserve the wildlife resources affected by the project and to promote wildlife -based recreation in
accordance with applicable provisions of the state and federal Environmental Policy Acts (G.S. 113A-1
through 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 project will replace a box culvert, which appears similar to a girder span bridge with vertical
abutments, with a two -barrel reinforced box culvert. The project will impact Dry Fork west of Monroe.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Pinedell Ave Culvert Page 2 Decemberl1, 2023
Union County
The NCWRC supports implementing the bat conservation recommendations offered by the US Fish and
Wildlife Service. Tree clearing activities should occur outside the "active season" (April 1—December) for
the tricolored bat. Conducting tree clearing activities during the winter avoids impacting bats roosting in
trees, particularly during the maternity season (June — July). Tricolored bats are known to roost in culverts
and in bridges, including in the winter in the Piedmont of North Carolina. Therefore, the existing culvert
should be surveyed for bats within 15 days of construction. Surveys should be conducted in accordance
with the National White -nose Syndrome Decontamination Protocol and the NCWRC culvert survey
protocol.
Dry Fork is known to support Eastern Creekshell mussel (Villosa delumbis), a North Carolina
significantly rare species, and according to IPAC, the federally endangered Carolina Heelsplitter
(Lasmigona decorata) occurs within Union County. We recommend contacting the U.S. Fish and
Wildlife Service to ensure any issues related to federally listed species are addressed. The NCWRC
prefers and typically recommends the use of bridges for stream crossings to avoid potential erosion and
impediments to aquatic passage that can occur with culverts. However, in this situation the project
appears to be an in -kind replacement and the proposed structure should have a better hydraulic capacity,
and hopefully performance.
The NCWRC recommends minimizing impacts of the project on aquatic habitat in Dry Fork. The rip rap
on the streambed, if needed as proposed, should be either embedded into the channel bed or the rip rap
top -dressed with suitable natural material to prevent stream burial. This may not be necessary if the
stream has a high fine sediment load, which will quickly fill rip rap voids, or if the rip rap used is small
diameter (less than class B). Also, similar to NC Department of Transportation guidelines, the high flow
barrel should be backfilled to the sill heights with native material or topped with native material if rip rap
is used as underlayment.
Thank you for the opportunity to review and provide recommendations on this project. Please contact me
at david.mchenrya,ncwildlife.org or [phone] if you have any questions about these comments.
Cordially,
Dave McHenry, NCWRC Western DOT Coordinator
cc: O. Munzer. NCWRC Western Piedmont Habitat Conservation Coordinator