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We have reviewed the proposed report of the chief of Engineers and the final environmental impact statement for Savannah Harbor, Chatham County, Georgia. Several general comments are provided for your consideration. We concur that the Chief's plan is the right solution, provided the tide gate is taken out of operation and New cut is filled prior to or concurrent with the harbor deepening. Recent studies by the Fish and Wildlife Service have documented significant impacts of the tide gate - New Cut project. During low flow periods, salinity is displaced almost 6 miles upstream in Little Back River. Brackish water is frequently introduced into Savannah National wildlife Refuge waterfowl impoundments, thus, degrading much of this valuable habitat. Over 4,000 acres of tidal freshwater marsh on Savannah refuge have been converted to brackish and saline marsh. Tidal freshwater marsh is rare and of higher value to waterfowl and other wildlife. Production of striped bass eggs in the Savannah River estuary has declined by 95 percent since the tide gate was put in operation in 1977.

Salinity in forner spawning areas is elevated above levels avoided by aduit spawners. Also, diversion of tidal flows through New cut speeds the seaward transport of striped bass eggs and larvae into areas with toxic salinity. U.S. Army Corps of Engineers (Corps) model studies indicate that deepening Savannah Harbor by 4 feet, as proposed in the subject reports, would increase salinity approximately one part per thousand upstream of u.s. Highway in. This increase would further degrade striped bass spawning areas, convert additional freshwater tidal marsh to brackish marsh, and reduce waterfowl management potential on Savannah refuge. Such impacts are unacceptable when considered with the already severe impacts of the tide gate project.

The recent commitment by the Corps to close New Cut and take the tide gate out of operation will result in environmental benefits (to Savannah refuge and other natural resources) that exceed projected adverse impacts from deepening Savannah Harbor.

sincerely,

Action Allen

Ionathan P. Deason
DArector
derice of Environmental Artairs

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This is in response to your letter of October 22, 1991, in which
you transmitted the proposed report of the Chief of Engineers,
the report of the district engineer, and final environmental
impact statement (FBIS) on Savannah Harbor, Georgia. We have
reviewed the reports and FEIS and have no comments to offer.
Please update your records to reflect the following change for
the Water Resources Coordinator from (G-MEP-1) to (G-MEP-3).
Also, please change the distribution to 2 copies instead of the
4 which are currently being forwarded for review.
Thank you for providing the opportunity for review of these
reports.

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Pursuant to Section 309 of the Clean Air Act and Section 102 (2)(C) of the National Environmental Policy Act (NEPA), EPA, Region IV has reviewed the subject document which describes the various plans to solve navigation problems at Savannah Harbor. The recommended design will involve deepening the entrance channel from 40 to 44 feet, deepening the main channel from 38 to 42 feet up to Kings Island Turning Basin, and deepening Kings Island Turning Basin from 38 to 42 feet. Additionally, authorization was issued pursuant to Section 1135 of the Water Resources Development Act of 1986, as amended, to close New Cut and permanently discontinue operation of the Back River tide gate. As a result of the Section 1135 modifications, an environmental assessment is being prepared to address the new without-project conditions and any changes this could have on the environmental impacts of the proposed deepening project. As we and other involved parties have noted in previous correspondence, there are a number of environmental uncertainties associated with this proposal which were not amenable to empirical inspection and/or accurate prediction by the computer model. Hence, any changes will only become evident after construction via monitoring. Nevertheless, the Section 1135 changes address the major, obvious concerns which we had about the project and were instrumental in removing our original reservations to this proposal. It is our understanding that design specifications for this work are complete and that the actual construction is imminent. Due to these modifications, we have nothing to add to our initial observations on this project. If we can be of further assistance, Dr. Gerald Miller (404-347-3776) will serve as initial point of contact on matters pertaining to NEPA. Ms. Catherine Fox or Mr. Bob Howard should be contacted (404-347-1740) regarding the 103 evaluation criteria. Sincerely yours,

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SAVANNAH HARBOR, GEORGIA

REPORT OF THE CHIEF OF ENGINEERS, DEPARTMENT OF THE ARMY

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1. I submit for transmission to Congress my report on improvements to the existing navigation project at Savannah Harbor, Georgia. It is accompanied by the reports of the District and Division Engineers and the Board of Engineers for Rivers and Harbors. These reports are in partial response to resolutions adopted by the Committee on Public Works of the United States Senate on 10 July 1972 and the Committee on Public Works of the United States House of Representatives on 12 October 1972. The study resolutions requested a review of the reports on Savannah Harbor, Georgia, published in House Documents 226 and 263, 89th Congress, and previous reports, with a view to determining whether the existing project should be modified in any way at the present time to accommodate present and prospective future commerce, both military and civilian. Preconstruction engineering and design activities for the Savannah Harbor project are being continued under authority provided by the io July 1972 and 12 October 1972 resolutions. 2. The District and Division Engineers considered various plans to solve the navigation problems at Savannah Harbor. The reporting officers recommend deepening of the navigation channels. The recommended modifications include deepening the Bar Channel to -44 feet; the Jetties Channel to -42 feet; Kings Island Turning Basin to -42 feet and the main Harbor Channel to -42 feet up to river nile 19.5 at Savannah Harbor. 3. Washington level review indicates that the recommended plan for deepening the Bar Channel, the Jetties Channel, the Main Harbor Channel, and Kings Island Turning Basin in accordance with the selected plan in the District Engineer's report is technically sound, economically justified as a locally preferred plan, and environmentally acceptable. The proposed project and cost-sharing requirements recommended in the District Engineer's report comply with applicable U.S. Army Corps of Engineers planning procedures and regulations.

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