20200451 Ver 1_WRC Comments_20200423

❑ North Carolina Wildlife Resources Commission ❑
Gordon Myers, Executive Director
April 23, 2020
Mr. David Brown
U.S. Army Corps of Engineers, Regulatory Branch
151 Patton Avenue, Room 208
Asheville, North Carolina 28801-5006
SUBJECT: Little Savannah Water and Sewer Expansion Project
Cullowhee Creek, Jackson County
Dear Mr. Brown:
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed an
application to permanently impact 10 ft and temporarily impact 220 ft of Cullowhee Creek and
temporarily impact 0.005 acre of wetland for the replacement of a sewer line 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).
Project activities should not impact wild trout reproduction, and a moratorium is not needed.
However, Cullowhee Creek is part of the Tuckasegee River Aquatic Habitat, a natural area rated
Exceptional by the NC Natural Heritage Program due to the richness of rare species it contains.
Near the project, Cullowhee Creek and the Tuckasegee River support a number of listed and rare
aquatic species, including the Sicklefin Redhorse (Moxostoma sp., US Candidate, NC
Threatened), Wavy -rayed Lampmussel [Lampsilis fasciola, NC Special Concern (SC)], Little
Tennessee Crayfish (Cambarus georgiae, NC SC), and French Broad River Crayfish (Cambarus
reburrus, US Federal Species of Concern, NC Significantly Rare). Excellent erosion and
sediment control measures are needed to minimize impacts to these important species.
The application proposes to replace an existing sewer line crossing on Cullowhee Creek. The
crossing would be installed via a trench cut in the dry. The permit application states that the dike
and bypass reach would impact 210 ft of stream; according to Mark Davis with Vaughn &
Melton, it is more likely that the actual bypass reach would be 100 to 125 ft, but the actual length
of the bypass is unknown at this time. The old sewer line, which is exposed above the stream
bed, would be removed and a new line, encased in a 20-inch steel encasement pipe, would be
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

L. Savannah Water & Sewer Expansion Page 2 April 23, 2020
Cullowhee Cr, Jackson County
installed. Although the pipe will be embedded within the stream, 0.6 ft of the pipe will be above
the bed of the stream. Stream banks would be stabilized with riprap.
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 workday.
2. 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.
3. The stream channel at the crossing location should be restored to near pre -disturbance
conditions. Channel dimensions should mimic the existing dimensions, and the stream bed
should set be at the pre-existing elevation. At least 6-8 inches of natural bed material should
be placed on top of the restored stream channel bed where possible; this bed material should
mimic that which is found in the stream bed.
4. We are concerned about the potential mortality of rare crayfish and other aquatic fauna
associated with the pump -around in Cullowhee Creek. We strongly recommend that the
bypass reach be constructed so that it impacts as short a reach as possible.
5. We strongly recommend against using riprap to stabilize the stream banks. Instead, banks
should be stabilized with a seed mix that includes a quick -growing temporary seed and native
riparian vegetation. Native woody vegetation should also be planted.
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: Mark Davis, Vaughn & Melton
Amy Annino, NC Division of Water Resources
Byron Hamstead, US Fish and Wildlife Service