Heather Coats_JBS_Permit_Letter.pdf

TOWN OF CASWER BEACh
1100 Caswell Beach Road • Caswell Beach, NC 28465
[phone] • Fax: [phone] • Website: www.caswelibeach.org
October 28, 2021
Ms. Heather Coats
N.C. Division of Coastal Management
Beach and Inlet Management Project Coordinator
127 Cardinal Drive Ext.
Wilmington, NC 28405-3845
Dear Ms. Coats,
Recognizing that as the North Carolina Division of Coastal Management Beach and Inlet Management
Coordinator, you are responsible for reviewing permit applications for most beach and inlet project
throughout the state. As such, I am bringing forth my concerns on behalf of the Town of Caswell Beach
associated with both current and future actions regarding the dredging of Jay Bird Shoals (JBS).
Over the past five (5) years, the Town of Oak Island and the Village of Bald Head Island have considered
and completed projects that included dredging within portions of JBS. During that time, the Town of
Caswell Beach has been afforded the opportunity to review their plans and comment on concerns
regarding potential impacts to our beach from such proposed actions. Most recently, as the Town of Oak
Island considered additional dredging from within portions of JBS, the Town of Caswell Beach along
with the Village of Bald Head Island and representatives from Fort Caswell were asked to provide
feedback on the proposed project. Specifically, a meeting was held on August 7, 2019, where
representative from Oak Island presented the plan to remove approximately 1.1 million cubic yards of
sand from JBS and place it along 4 miles of oceanfront shoreline of Oak Island.
On January 30, 2020, the Town of Oak Island's consultant, Moffat & Nichol (M&N), submitted a letter to
you with a suggested protocol for monitoring Caswell Beach's oceanfront as a condition of excavating
approximately 1.1 million cubic yards from JBS. After our consultant, Coastal Protection Engineering of
North Carolina, Inc (formerly APTIM), provided comments on the protocol, a subsequent letter was
submitted by M&N, dated February 24, 2020, with revised recommendations to Item 4 of the protocol.
The protocol for monitoring laid out in the January 30 and February 24, 2020 letters were incorporated
into condition of CAMA Major Permit #31-20 issued on March 6, 2020.
As you are aware, the Town of Oak Island conducted a beach fill project in April and May 2021, which
removed approximately 885,000 cy of material from the permitted portion of JBS. Following the
construction of the project, Caswell Beach property owners expressed concerns to Town staff and
officials regarding scarping observed along the beach approximately 0.5 miles west of the of the Oak
Island Lighthouse. In August 2021, we reached out to Oak Island's consultant regarding post-

construction surveys of Caswell Beach. On September 3, 2021, The Town of Caswell Beach was
provided a project completion report for the 2020/2021 Oak Island renourishment project. We were also
informed that M & N did not plan to collect post -construction surveys until the Spring of 2022.
Additionally, we were informed that the Town had applied for and received a permit modification to
CAMA Major Permit #31-20 in April 2021 that allowed for the removal of more than 1 million additional
cubic yards in addition to the initial 1.1 million permitted by the original permit. The Town's proposed
survey schedule did not include collecting beach profile surveys along Caswell Beach between the Spring
2021 and the proposed January 2022 dredge events.
A teleconference was held on October 5, 2021, and included the Town of Oak Island, the Town of
Caswell Beach, and their respective consultants. During this meeting Caswell Beach was informed that
Oak Island would collect beach profile surveys in mid -October allowing for an evaluation of change to
the Caswell Beach oceanfront post -construction of the April/May 2021 dredging of JBS. The completion
of survey and evaluation is anticipated prior to additional dredging of JBS scheduled for January 2022
project.
While we appreciate the Town of Oak Island's assistance with data collection, we are concerned with the
fact that a modification to CAMA Major Permit 31-20 has already been issued. The original Town of
Oak Island Shoreline Monitoring Plan for Caswell Beach, agreed to by Caswell Beach, specifically
describes the action for which the Monitoring Plan would be implemented for as "excavating
approximately 1.1 million cubic yards from Jay Bird Shoals borrow area". Furthermore, in a letter sent
by our consultant to Ronnie Smith of the USACE and copied to Braxton Davis, dated November 5, 2019,
concerns regarding the limitations of the JBS borrow area modeling report. In that letter, the Town of
Caswell Beach recommended several actions including 1) limiting the permit to the 1.1 MCY (plus or
minus) needed for the current project; 2) Have the Town of Oak Island initiate monitoring of the Caswell
Beach shoreline following the initial dredging of the borrow area; 3) After sufficient time has elapse
following the initial dredging of the borrow area, use the monitoring data to calibrate the model for
sediment transport; and 4) use the calibrated model to refine plans for sediment removal from the
proposed borrow are in order to minimize potential negative impacts along the Caswell Beach Shoreline.
We are concerned that regardless of the acknowledgement by the Division in issuing CAMA Major
Permit #31-20, which requires monitoring and potentially mitigation for the causing of unintentional
effects on Caswell Beach, the Town of Caswell Beach was not directly noticed regarding the
consideration of the modification of CAMA Major Permit 31-20. Furthermore, to our knowledge, the
Town of Oak Island has not completed any of the recommendations made in the November 5, 2019 letter.
We will continue to work directly with our neighboring communities to ensure that their actions do not
adversely affect our beach. However, we ask that in the future, the Town of Caswell Beach be considered
an adjacent stakeholder and provided a direct notification of projects within JBS.
Best Regards,
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