NCDMF Response to CPE Letter

MEMORANDUM:

TO: Heather Coats, NCDCM Beach & Inlet Management Project Coordinator

FROM: James Harrison, NCDMF Fisheries Resource Specialist

SUBJECT: Beach Nourishment Projects, Dare County

DATE: 30 August 2021

A North Carolina Division of Marine Fisheries (DMF) Fisheries Resource Specialist has
reviewed the letter submitted by Coastal Protection Engineering (CPE), dated 17 August
2021, in response to DMF comments submitted regarding the Town of Kitty Hawk’s CAMA
Major Permit application. In that letter, CPE provided direct responses to the
recommendations included in DMF’s response to the CAMA application. Below, DMF
provides responses to those submitted by CPE.

Requested Monitoring Protocol #1: Pre- and post-placement surveys of benthic
species (biodiversity and abundance).

CPE provided a wealth of information and resources in their response to this request. As
noted by CPE, there have been numerous studies that have been conducted to observe the
impacts of beach nourishment projects on benthic communities. CPE’s conclusion was that
the request for a pre-construction survey paired with two post-construction monitoring
events would most likely result in statistically insignificant results. Additionally, CPE noted
that their belief is that the monitoring is not necessary as the effects of the proposed
activity are widely known.

Conducting dredging and nourishment operations during the warmer, more biologically
productive months is not typical, and the requested monitoring would provide site-specific
data needed to assess recovery rates. It is expected that these nourishment projects will
continue over time, and will likely continue to include requests to be completed during the
time of the year that is typically covered by the moratoria requested by various resource
agencies. Intertidal beach benthic monitoring has not been conducted at these beach sites
previously and recovery rates are known to vary among sites and projects due to multiple
factors. DMF believes that conducting these surveys would provide useful, site-specific
information that can be utilized and reviewed during subsequent nourishment projects at
the various Dare County locations, and the results of the requested benthic monitoring

would provide the resource agencies a clearer understanding of how the proposed work
impacts the local benthic communities. Having this information readily available may also
help to expedite the review process for future nourishment project requests. Furthermore,
the results of this monitoring could be combined with the monitoring completed for the
Nags Head nourishment project to provide a better description of how this system
responds to nourishment projects as a whole.

Additionally, many of the benthic species present in these areas are prey species for
various commercially, recreationally, and ecologically important species. This is
particularly true for recreational species found in the nearshore areas in Dare County.
Having information pertaining to prey biodiversity and abundance can aid in furthering the
scientific understanding of these species and their habits.

Taking the above into consideration, DMF still believes that the requested benthic
monitoring at the placement locations would provide useful information and should be
included as a permit requirement. Although this monitoring was not included in all
previous Dare County nourishment project permits, it was a permit requirement for the
Nags Head nourishment (Permit No. 45-10). Therefore, DMF believes this request is
consistent with what has been previously required for beach nourishment projects.

Requested Monitoring Protocol #2: Turbidity plume monitoring.

DMF is amenable to DCM granting a permit without a condition requiring turbidity
monitoring. However, DMF believes that a condition could be included similar to the
language in CPE’s response – if DMF or DCM raises concerns regarding turbidity levels
during the proposed project, a turbidity monitoring regime could be implemented. If DMF
or DCM staff is available to observe the project and notes excessive turbidity increases
associated with the project, the permit should include a requirement for the work to
coordinate with the agencies on remedying the situation.

Requested Monitoring Protocol #3: Habitat surveys at the disposal locations.

CPE indicated in their response that it is expected that the beach will respond with similar
slopes, intertidal areas, and nearshore subtidal areas as during previous nourishment
projects. DMF agrees with this response, and is amenable to DCM removing this protocol
from the permit.

Requested Monitoring Protocol #4: Monitoring for dead fish and crabs along
placement areas.

The applicants have agreed to noting dead fish and/or crabs at the fill locations on a daily
basis throughout the duration of the project. The observer will record the date, time, and
location of each specimen, and make note of the species and measurements (if possible).
Observers aboard the dredging vessel will also make note of any dead species observed
during dredging. Due to the nature of dredging, species identification and measurements
are likely not possible.

Requested Monitoring Protocol #5: Noise monitoring.

The letter from CPE indicated that the noise generation associated with beach nourishment
projects, such as those proposed for Dare County, is already well understood. Therefore,
CPE believes that noise monitoring is not needed. DMF is amenable to DCM permitting the
proposed projects without including a noise monitoring requirement.

Thank you for consideration of our comments. Please contact Jimmy Harrison at (252)
948-3835 (office) or [phone] (mobile – preferred), or at
[e-mail] with any further questions or concerns.