in these reaches will be constructed deeper than design and on zero grade so that there will be a continuous pool between structures, having an approximate depth of 2 feet. Design to include 11 structures. Approximate surface acreage is 13 acres.

(5) Sediment removal: Sediment deposited in channel pools during construction will be removed before contract is closed.

(6) Sediment holes: Additional holes to serve as sediment traps will be provided on Chicod main ditch lateral 11, and lateral 13. A total of 10 holes having a depth of 2 feet and a length of 100 feet will be provided.

This Service has made additional field studies since our June 3, 1965, report, and the situation with respect to fish and wildlife was found to be essentially the same as presented in that report.

Of prime concern to this Service are those areas having moderate or high quality wetlands, and/or fish habitat. The areas in this watershed that would be affected by the approved work plan are Chicod Creek, from about one-half mile above State Secondary Road 1782 downstream, and Cow Swamp, a stream tributary to Chicod Creek (lateral 11) from State Secondary Road 1772 downstream. Chicod main ditch from one-half mile above SSR-1782 down and Cow Swamp from SSR-1772 down to the start of the project run through seasonally flooded bottom lands and some wooded swamp. This type wetland habitat, already in short supply, is vital to waterfowl, fur bearers, and black bear and is used as escape areas for deer and other wildlife. These stream segments provide good habitat for game fish such as redfin pickerel, warmouth, redbreast sunfish, and bluegill, as well as annual spring runs of river herring.

It is the opinion of the Service that the original mitigation measures plus the additional measures do not significantly lessen the adverse effects of the project on the ecosystem of the watershed. In addition, many of the mitigation features are dependent on operation by local sponsors if any benefits from installation of the proposals are to be realized. A followup study by the Service of constructed Soil Conservation Service projects in North Carolina has shown that frequently operation has not been accomplished as envisioned in the watershed work plan. It appears to us that the intent of Watershed Memorandum 108 is to reduce fish and wildlife losses by modifying or eliminating engineering features that are particularly destructive to these resources. The additional measures proposed during this review, although they have some merit, do not represent any deletion of stream miles of channel excavation from the original project work plan. We note with interest a statement by Mr. Kenneth Grant before the House Subcommittee on Conservation and Natural Resources: "We are reviewing and strengthening our directives to field offices to give even greater emphasis to our policy that channel improvement is used only as a last resort and is planned in a way that will enhance our environment. We are reviewing all planned channel work that has not been installed in approved projects, in order to modify or eliminate the work where it is possible and desirable under present concepts."

The impact of stream channel excavation on many aspects of the ecosystem is now a part of the records of that same congressional hearing in which Mr. Grant participated. We do not believe that stream channelization is a last resort or that it will enhance the environment in the case of the Chicod Creek watershed project as now proposed. There are many alternatives; such as selective clearing and snagging of the stream; leaving the large mast-producing trees; flood storage in small impoundments; selectively cleared floodways: flood plain insurance; and flood plain zoning. These alternatives should be carefully considered before any drastic alteration as proposed in the Chicod Creek watershed work plan is attempted.

In view of the expected impact of the approved project on fish and wildlife resources, the Service requests that the Chicod Creek watershed work plan be placed in group 3 (serious adverse effects) until the proposed stream channelization is eliminated on Chicod Creek from one-half mile above SSR-1782 bridge down, and on Cow Swamp (lateral 11) from SSR-1772 down.

We appreciate the opportunity to provide these comments and request that the Service be advised of what action is taken on this request.

Sincerely yours,

ERNEST C. MARTIN, Acting Regional Director.

U.S. DEPARTMENT OF THE INTERIOR,

FISH AND WILDLIFE SERVICE,
BUREAU OF SPORT FISHERIES AND WILDLIFE,
Atlanta, Ga., June 3, 1965.

Mr. J. P. KUYKENDALL,

State Conservationist, Soil Conservation Service,
Raleigh, N.C.

DEAR MR. KUYKENDALL: The Bureau of Sport Fisheries and Wildlife, in cooperation with the North Carolina Wildlife Resources Commission, has made a reconnaissance study of Chicod Creek watershed, Pitt and Beaufort Counties, N.C. The project is sponsored by the Pitt and Beaufort soil and water conservation districts, and the Pitt County Board of Commissioners. This letter constitutes our report, prepared and submitted in accordance with provisions of the Watershed Protection and Flood Prevention Act (68 Stat. 666), as amended. Based on data furnished by your office, the watershed contains approximately 35,100 acres of land drained by Chicod Creek and its tributaries, which flow into the Tar River (plate 1). Present land use consists of 15,600 acres of cropland, 17,170 acres of woodland, including 1,592 acres of wooded swamps, 350 acres of pasture, 400 acres of water, and 1,580 acres of miscellaneous land. Major watershed problems as set forth by your agency are flooding and inadequate drainage of agricultural lands. Project purposes will be to reduce the frequency and periodic flooding of these lands.

Proposed project plans include 2.6 miles of clearing and snagging from U.S. Highway 264 to the Tar River and 62 miles of channel excavation along Chicod Creek and its tributaries, which will necessitate clearing approximately 357 acres of wooded swamps for right-of-way and spoil disposal. Project channels will have a side slope of 1:1, depth of 5 to 7 feet below average cropland elevations, and bottom widths varying from 28 to 4 feet in the lower and upper sections of the mainstem, respectively. Stabilization measures call for planting 150 acres of grasses on spoil areas.

Chicod Creek and its tributaries constitute a typical blackwater swamp-stream complex of the coastal plain. It originates in Beaufort County and flows northward through gently rolling terrain to its confluence with the Tar River in the vicinity of Grimesland. Overflow swamp areas occur in the flood plains of Chicod Creek and its principal tributaries, Juniper Branch and Cow Swamp, except for limited areas in the upper reaches where previous channel excavation has occurred. Mixed upland hardwoods, including sweet gum, oak, dogwood, and beech, make up the vegetative zone between agricultural fields and bottomlands. Wildlife resources in the watershed include forest and farm game and fur animals, plus species of both resident and migratory waterfowl. Significant populations of quail, dove, deer, squirrel, raccoon, rabbit, and waterfowl provide the major hunting opportunity, and hunting pressure is moderate. Of the 17,170 acres of woodland in the watershed, 1,592 acres constitute good to excellent wooded swamp habitat. These areas have surface water levels which vary seasonally from a few inches to 5 feet; they contain such species as cypress, black gum, tupelo gum, water ash, sweet gum, and oaks. The wetland areas within the watershed receive moderate utilization by wood ducks for nesting and brood rearing, and provide good wintering areas for both migrant and resident ducks. Several of the above timber species produce mast which is utilized as food by a number of wildlife species, while others provide nesting and roosting facilities. In addition, borders of these swamps provide food, cover, and refuge for several forms of upland birds and mammals.

As a result of project construction, 357 acres of productive swamp habitat will be destroyed by right-of-way clearing for spoil disposal and equipment access. In addition, 500 acres of swamps will be destroyed by removal of surface water. Surface water is an essential factor in maintaining swamp environment and its removal will allow encroachment of undesirable underbrush, reduce aquatic animal habitat, eliminate swamp refuge or escape areas, and decrease duck utilization. It is expected that project construction will cause deterioration of the remaining swamp habitat by accelerating rate of runoff and will facilitate additional small, private drainage programs that will further reduce swamp habitat of importance to the wildlife resource.

Fishery resources consist of pickerel, largemouth bass, bluegill, and crappie, plus significant spring runs of herring. Fishing pressure is moderate in the upper reaches and heavy in the lower stream areas where anadromous species are seasonally present. Channelization will result in the loss of approximately 14 miles of prime fish habitat, having a surface area of about 25 acres. In addi

tion, siltation and turbidities associated with channel excavation will also detrimentally affect stream ecology and productivity within and below the project area during construction and until channels become stabilized. Project construction during the period March through July could seriously affect the annual spring run of herring by increasing siltation and turbidity in the unchannelized lower reaches.

To preserve wildlife habitat, the project work plan should provide that project design and operation should limit channel excavation to the absolute minimum needed in those areas where flood control remedial measures are necessary and include measures to permit manipulation of surface water levels where compatible with project purposes. Approximately 1 foot of water contained in these bottomland areas during the months of October through March will permit waterfowl utilization and aid in maintaining swamp environment. Such waters would be below predrainage flood levels and, therefore, should not jeopardize existing agricultural areas. This manipulation of surface water is also a desirable forestry management practice for several valuable hardwood species which produce wildlife foods.

In addition, to minimize fishery losses, channel excavation should be scheduled to avoid the months of March through July, when eggs, fingerlings and adult herring may be present in this area.

Although the above means of minimizing fish and wildlife losses were deemed incompatible with project objectives by the planning agency, local sponsors have accepted the principle of mitigating project-incurred fish and wildlife losses as a project cost. Alternate measures to minimize fish and wildlife losses have been discussed in coordination meetings attended by your office, the North Carolina Wildlife Resources Commission, and this Bureau. As a result of these meetings, your office, with the tentative acceptance of local sponsors, has agreed to include the following in the work plan for the project: One 33.2-acre greentree reservoir on Cow Swamp, one 27.8-acre green-tree reservoir on Juniper Branch, and one 20-acre fish impoundment located on a tributary of Juniper Branch (plate 1) with free access limited to shoreline areas provided by a 5-foot vertical ingress and egress. Local sponsors will cost-share construction of the two green-tree reservoirs. In addition, they will cost-share construction of the proposed fish impoundment except for the relocation cost of County Road 1760. If no solution for payment of relocation cost is found, the size of the impoundment may be reduced so that road relocation is unnecessary.

The North Carolina Wildlife Resources Commission and this Bureau endorsed the construction of the two green-tree reservoirs and the provision for manipulation of wetlands surface water. The fish impoundment is an acceptable form of providing comparable fishing opportunity and the work plan should include: (1) An access road to the shore of the impoundment for cars with enough space to turn and unload boats; and (2) provision that no fee will be charged for access to the impoundment. These conditions exist at road crossings of stream habitat which will be lost as a result of project construction, and if similar conditions are provided for in project plans, the fishing lake will be an acceptable form of mitigating the loss of a free public fishery resource.

In view of the potential project damages to fish and wildlife habitat, this Bureau recommends that:

(1) The project work plan recognize fish and wildlife losses resulting from project construction;

(2) The mitigation features proposed by your office and agreed upon by this Bureau and the North Carolina Wildlife Resources Commission be included at project cost in the final work plans.

The report has been reviewed by the North Carolina Wildlife Resources Commission, and a copy of assistant director Schwall's letter of concurrence is attached.

The efforts of your staff in the interest of fish and wildlife resources at the several coordination meetings held to discuss this project are sincerely appreciated. We request that you keep us informed as to the status of our recommendations. The North Carolina Wildlife Resources Commission and this Bureau will continue to work with you and provide any assistance needed to formulate suitable means of mitigating project-incurred wildlife losses for inclusion in the final work plan.

Sincerely yours,

Attachments 2.

WALTER A. GRESH,
Regional Director.

Mr. WALTER A. GRESH,

STATE OF NORTH CAROLINA,
WILDLIFE RESOURCES COMMISSION,

Regional Director, U.S. Fish and Wildlife Service,
Atlanta, Ga.

Raleigh, N.C., May 25, 1965.

DEAR MR. GRESH: The Bureau's proposed report, dated April 21, 1965, which concerns anticipated damages to wildlife and fisheries habitat and resources in Chicod Creek watershed in Pitt and Beaufort Counties, N.C., as a result of planned project works of improvement under Public Law 566, and which includes recommended mitigation measures, has been reviewed.

We concur in the findings of the Bureau as contained in the report and in the recommendations for mitigation.

We compliment the Soil Conservation Service and project sponsors in agreeing to some mitigation of the project-caused destruction of fish and wildlife habitat. May we emphasize the importance of free public access to the fishing lake and to the marginal shore as a necessity for mitigation.

Very truly yours,

EUGENE E. SCHWALL,
Assistant Director.

Question 10. The District Court, in Akers v. Resor, supra, noted that the SCS Watershed Memorandum 84 indicates that “Channelization should not be effected where the [primary] purpose is to bring new lands into agricultural production." (b) Does each agency specify in its environmental statements how much, if any, new lands will be brought into agricultural production with each project? Answer. The amount of new land to be brought into production is often difficult if not impossible to identify in environmental statements. Furthermore, strong differences of opinion exist between agencies as to whether or not new land is brought into agricultural production. The SCS for example consistently maintains that no new lands are brought into production as a result of drainage from channelization. This view is in conflict with the observations of our field personnel who assess the effects of SCS channelization projects.

A. D. Little's draft report also observes on page 25 that: "The factual assessment of performance effectiveness of channel modifications in removing excess water from inherently wet riparian lands was severely limited by lack of evidence of ground water tables. While the U.S. Geological Survey has carried out ground water measurement studies of a more general and regionalized nature, specific measurements in areas of probable influence of channel works evaluated by us are not available. Highly variable soil types bear importantly profiles surrounding excavated channel reaches, we had to rely on observations in the field for a general assessment of drainage performance.

"It can be inferred generally from data on changing flood plain land use, cropping patterns and crop yields, considered in conjunction with field observations and statements by landowners, that deepened and widened channels have proven successful in draining wetlands throughout the Nation. This is particularly true in the essentially flatlands where drainage was clearly the dominant problem from the agricultural producer's point of view, as distinct from flood-protection, and where the channel works were to rehabilitate prior drainage ditches rendered ineffective by obstructions, siltation, and subsidence. Performance was less clearcut in not inherently wetlands, and here the virtual inseparability of performance between removal of normally excessive and infrequently excessive surface or high-table ground water made accurate assessments impossible. Nevertheless, it was our frequent observation on at least 24 projects combining both purposes, that some substantial amount of land drainage had been carried out in the name of flood prevention. In the same and other instances, whether or not main or tributary channels in fact acted to control floods or drain lands, the secondary effect was to induce extensive on-farm land drainage because of the outlet provided."

As implied by A. D. Little above, specific measurements of ground water tables by the USGS in areas of probable influence of channel works would assist in evaluating the amount of new land likely to be brought into agricultural production.

We believe this type of basic information should be required for all environ. mental impact statements relating to channelization.