20140718 Ver 2__20191003

1�1 North Carolina Wildlife Resources Commission 0
Gordon Myers, Executive Director
October 3, 2019
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Savannah Creek Restoration
Savannah Creek, Jackson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to repair 800 ft of a stream restoration project on Savannah Creek in Jackson County.
Our comments on this application are offered for your consideration under provisions of the
Clean Water Act of 1977 (33 U.S.C. 466 et. seq.) and Fish and Wildlife Coordination Act (48
Stat. 401, as amended; 16 U.S.C. 661-667d).
Wild trout reproduction should not be impacted by project activities and a trout moratorium is
not needed for the project. However, this portion of Savannah Creek is in the Tuckasegee River
Aquatic Habitat, a natural area rated Exceptional by the NC Natural Heritage Program due to the
richness of rare and listed species it supports, including Appalachian Elktoe (Alasmidonta
raveneliana, US and NC Endangered), Rainbow (Villosa iris, NC Threatened), Eastern
Hellbender [Cryptobranchus alleganiensis, US Federal Species of Concern (FSC), NC Special
Concern (SC)], Wavyrayed Lampmussel (Lampsilis fasciola, NC SC), and Wounded Darter
(Etheostoma vulneratum, US FSC, NC SC)
The application proposes to stabilize unstable reaches of a previously restored reach of the
Savannah Creek by repairing two rock vanes, installing a riprap toe and brush mattress, sloping
the bank, and planting riparian vegetation. According to Andrew Bick, work will be performed
from the bank as much as possible, and when working directly on the bank near the water's edge
(e.g., bank tie-ins, brush mattress), on-site materials will be used to create temporary diversion
structures immediately above work areas to divert flow. 1-2 fords will be used to move
equipment to the left bank; if possible, an existing ford should be used for this work but if a new
ford is needed, it will be located within a cobble -dominated portion of the stream and equipment
will only take one roundtrip through the ford.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Savannah Creek Restoration Page 2 October 3, 2019
Savannah Cr, Jackson County
We offer the following recommendations to minimize impacts to the aquatic community:
1. In -channel work should be accomplished as quickly as possible and vigilance used in
sediment and erosion control during site preparation, construction, and clean up. Disturbed
areas should be seeded, mulched and/or matted as soon as possible, preferably at the end of
each work day.
2. Work should be done at low flows.
3. We support diverting flows around in -channel work areas especially at the bank tie in
locations to reduce the risk of fine sediment liberation and loss.
4. Any erosion control matting used should be free of nylon or plastic mesh, as this type of
mesh netting frequently entangles wildlife and is slow to degrade, resulting in a hazard that
may last for years.
Thank you for the opportunity to review and comment on this project. Please contact me at
[phone] if you have any questions about these comments.
Sincerely,
Andrea Leslie
Mountain Region Coordinator, Habitat Conservation Program
ec: Andrew Bick, Headwaters Engineering
Kevin Mitchell, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service