20170828 SPBO signed final

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Table of Contents

ACRONYMS ..................................................................................................................... 5
CONSULTATION HISTORY ........................................................................................... 7
BIOLOGICAL OPINION ................................................................................................... 9
1. DESCRIPTION OF THE PROPOSED ACTION ........................................................ 9
1.1. Action Area ..................................................................................................... 10
1.2. Conservation Measures ................................................................................... 10
1.3. Project Timing and Duration .......................................................................... 11
2. PIPING PLOVER ....................................................................................................... 12
2.1. Status of the Species ....................................................................................... 12
2.1.1. Species Description ................................................................................... 12
2.1.2. Life History ............................................................................................... 13
2.1.3. Population Dynamics ................................................................................ 15
2.1.3.1. Northern Great Plains breeding population ....................................... 16
2.1.3.2. Great Lakes breeding population ...................................................... 18
2.1.3.3. Atlantic Coast breeding population ................................................... 21
2.1.4. Status and distribution............................................................................... 24
2.1.5. Analysis of the Species Likely to be Affected .......................................... 35
2.2. Environmental Baseline .................................................................................. 63
2.2.1. Status of the species within the Action Area ........................................... 63
2.2.2. Factors affecting the species environment within the Action Area .......... 70
2.3. Effects of the Action ....................................................................................... 86
2.3.1. Factors to be considered............................................................................ 86
2.3.2. Analyses for effects of the action.............................................................. 87
2.3.3. Species’ response to the proposed action.................................................. 88
2.4. Cumulative Impacts ........................................................................................ 88
2.5. Conclusion ...................................................................................................... 88
3. PIPING PLOVER WINTERING CRITICAL HABITAT ......................................... 89
3.1. Status of the Critical Habitat ........................................................................... 89
3.1.1. Critical Habitat Description and Status ............................................. 89
3.1.2. Analysis of the Critical Habitat Likely to be Affected ...................... 92
3.2. Environmental Baseline .................................................................................. 96
3.2.1. Status of the Critical Habitat within the Action Area ............................... 96
3.2.2. Factors Affecting Critical Habitat within the Action Area ....................... 98
3.3. Effects of the Action ..................................................................................... 100
3.3.1. Factors to be considered.......................................................................... 101
3.3.2. Analysis for effects of the action ............................................................ 101
3.4. Cumulative Effects........................................................................................ 101
3.5. Conclusion .................................................................................................... 102
4. RED KNOT ......................................................................................................... 102
4.1. Status of the Species ..................................................................................... 102
4.1.1. Species Description ................................................................................. 102
4.1.2. Life History ............................................................................................. 103
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4.1.3. Population Dynamics .............................................................................. 105
4.1.4. Status and Distribution ............................................................................ 107
4.1.5. Analysis of the Species Likely to be Affected ........................................ 108
4.2 Environmental Baseline ................................................................................ 118
4.2.1. Status of the species within the Action Area .......................................... 118
4.2.2. Factors affecting the species environment within the Action Area ........ 121
4.3. Effects of the Action ..................................................................................... 128
4.3.1. Factors to be considered.......................................................................... 128
4.3.2. Analys es for effects of the action............................................................ 129
4.3.3. Species’ response to a proposed action ................................................... 130
4.4. Cumulative Effects........................................................................................ 130
4.5. Conclusion .................................................................................................... 130
5. SEABEACH AMARANTH ..................................................................................... 131
5.1. Status of the Species/Critical Habitat ........................................................... 131
5.1.1. Species/critical habitat description ......................................................... 131
5.1.2. Life history .............................................................................................. 131
5.1.3. Population dynamics ............................................................................... 131
5.1.4. Status and distribution............................................................................. 132
5.1.5. Analysis of the Species Likely to be Affected ........................................ 133
5.2. Environmental Baseline ................................................................................ 135
5.2.1. Status of the species within the Action Area .......................................... 135
5.2.2. Factors affecting the species environment within the Action Area ........ 137
5.3. Effects of the Action ..................................................................................... 138
5.3.1. Factors to be considered.......................................................................... 138
5.3.2. Analys es for effects of the action............................................................ 138
5.3.3. Species’ response to a proposed action ................................................... 139
5.4. Cumulative Effects........................................................................................ 139
5.5. Conclusion .................................................................................................... 139
6. LOGGERHEAD, GREEN, LEATHERBACK, HAWKSBILL, AND KEMP’S RIDLEY SEA
TURTLES 140
6.1. Status of the Species/Critical Habitat .......................................................... 140
6.1.1. Species/critical habitat description ......................................................... 140
6.1.1.1. Species/critical habitat description – Loggerhead Sea Turtle .......... 140
6.1.1.1.1. Critical habitat description ..................................................... 141
6.1.1.2. Species/critical habitat description – Green Sea Turtle ................... 143
6.1.1.3. Species/critical habitat description – Leatherback Sea Turtle ......... 144
6.1.1.4. Species/critical habitat description – Kemp’s Ridley Sea Turtle .... 145
6.1.1.5. Species/critical habitat description – Hawksbill Sea Turtle ............ 146
6.1.2. Life History ............................................................................................. 147
6.1.2.1. Life History – Loggerhead Sea Turtle ............................................. 147
6.1.2.2. Life History – Green Sea Turtle ...................................................... 149
6.1.2.3. Life History – Leatherback Sea Turtle ........................................... 150
6.1.2.4. Life History – Kemp’s Ridley Sea Turtle ........................................ 150
6.1.2.5. Life History – Hawksbill Sea Turtle ............................................... 150
6.1.3. Population dynamics ............................................................................... 151
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6.1.3.1. Population dynamics - Loggerhead Sea Turtle ............................... 151
6.1.3.2. Population dynamics - Green Sea Turtle ......................................... 151
6.1.3.3. Population dynamics – Leatherback Sea Turtle .............................. 152
6.1.3.4. Population dynamics – Kemp’s Ridley Sea Turtle ......................... 153
6.1.3.5. Population dynamics – Hawksbill Sea Turtle ................................. 154
6.1.4. Status and distribution............................................................................. 154
6.1.4.1. Status and distribution – Loggerhead Sea Turtle ............................ 154
6.1.4.2. Status and distribution - Green Sea Turtle ...................................... 157
6.1.4.3. Status and distribution – Leatherback Sea Turtle ............................ 159
6.1.4.4. Status and distribution – Kemp’s Ridley Sea Turtle ....................... 160
6.1.4.5. Status and distribution – Hawksbill Sea Turtle ............................... 161
6.1.5. Analysis of the Species/Critical Habitat Likely to be Affected ................ 162
6.2. Environmental Baseline ................................................................................ 171
6.2.1. Status of Sea Turtle Species within the Action Area .............................. 171
6.2.2. Factors Affecting the Species Environment within the Action Area ...... 173
6.3. Effects of the Action ..................................................................................... 176
6.3.1. Factors to be considered.......................................................................... 176
6.3.2. Analyses for the effects of the action ...................................................... 177
6.3.3. Species response to a proposed action .................................................... 180
6.4. Cumulative Effects........................................................................................ 181
6.5. Conclusion .................................................................................................... 181
7. INCIDENTAL TAKE STATEMENT ...................................................................... 182
7.1. Amount or Extent of Take ............................................................................ 183
7.1.1. Piping Plover ........................................................................................... 183
7.1.2. Red Knot ................................................................................................. 184
7.1.3. Sea Turtles .............................................................................................. 185
7.2. Effect of the Take.......................................................................................... 187
7.3. Reasonable and Prudent Measures and Terms and Conditions .................... 187
7.4. Reporting Requirements ............................................................................... 205
7.5. Coordination of Incidental Take Statement with Other Laws, Regulations, and Policies
205
8. CONSERVATION RECOMMENDATIONS .......................................................... 206
9. REINITIATION NOTICE ........................................................................................ 207
LITERATURE CITED ................................................................................................... 208
APPENDIX A: NC Historical Sand Placement Projects ................................................ 278
APPENDIX B: Piping Plover Designated Wintering Critical Habitat Units ................. 283
APPENDIX C: Loggerhead Designated Critical Habitat Units ..................................... 292
APPENDIX D: Piping Plover and Red Knot Survey Minimum Survey Requirements . 296

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Acronyms

Act Endangered Species Act
BA Biological Assessment
BO Biological Opinion
CAFF Council Conservation of Arctic Flora and Fauna
CBRA Coastal Barrier Resources Act
CFR Code of Federal Regulations
CH Critical Habitat
CITES Convention on International Trade in Endangered Species of Wild Fauna and Flora
Corps U.S. Army Corps of Engineers
COSEWIC Committee on the Status of Endangered Wildlife in Canada
CSDR Coastal Storm Damage Reduction
DOI U.S. Department of the Interior
DTRU Dry Tortugas Recovery Unit
F Fahrenheit
FAC Florida Administrative Code
FDEP Florida Department of Environmental Protection
FEIS Final Environmental Impact Statement
FEMA Federal Emergency Management Agency
FR Federal Register
GCRU Greater Caribbean Recovery Unit
HCP Habitat Conservation Plan
IPCC Intergovernmental Panel on Climate Change
ITP Incidental Take Permit
LF Linear Feet
MHW Mean High Water
MHWL Mean High Water Line
MLLW Mean Low Low Water
MLW Mean Low Water
mtDNA Mitochondrial Deoxyribonucleic Acid
NCDCM North Carolina Division of Coastal Management
NCWRC North Carolina Wildlife Resources Commission
NGMRU Northern Gulf of Mexico Recovery Unit
NMFS National Marine Fisheries Service
NOAA National Oceanic and Atmospheric Administration
NRU Northern Recovery Unit
NWR National Wildlife Refuge
PBF Physical and Biological Feature
PCE Primary Constituent Element
PFRU Peninsular Florida Recovery Unit
SAJ South Atlantic Jacksonville
SAM South Atlantic Mobile
Service U.S. Fish and Wildlife Service
SF Square Feet
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SNBS Statewide Nesting Beach Survey
TED Turtle Excluder Device
TEWG Turtle Expert Working Group
U.S.C. United States Code
U.S. United States
USEPA United States Environmental Protection Agency

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CONSULTATION HISTORY

May 23, 2013 – The Service participated in a meeting organized by the North Carolina Division of
Coastal Management (NCDCM) to discuss a potential programmatic approach to beach nourishment
permitting. At the time, it was associated with proposal to develop 50-year projects for beach
communities.

December 19, 2013 – The Service met with representatives of the Corps, NCDCM, and others to discuss
the potential development of a Statewide Programmatic BO.

February 28, 2014 – The Service participated in a phone conference to plan for a scoping workshop to
discuss the potential for a programmatic approach with North Carolina’s beach communities. The
scoping meeting took place on March 19, 2014.

June 11, 2014 – The Service met with the Corps, NCDCM, North Carolina Wildlife Resources
Commission (NCWRC), and National Marine Fisheries Service (NMFS) to determine the scope of the
Programmatic Biological Assessment (PBA) and a timeline for requesting proposals, awarding bids, and
completing the PBA.

September 2014 through January 2015 - The Service participated in review of the Request for Proposals,
proposals and bids for development of the PBA.

March 24, 2015 – The Service participated in a “kickoff” meeting to discuss the outline of the PBA.

June 30, 2015 – The Service participated in a meeting with the Corps, NCDCM, and the consultant
concerning applicability of the PBO to regulatory and Civil Works projects.

October 2015 through September 2016 – The Service participated in reviews of the draft PBA and
various phone calls with the consultant to discuss portions of the PBA.

October 7, 2016 – The Final PBA was submitted electronically to the Service by the consultant.

November 22, 2016 – The Corps requested initiation of formal Section 7 consultation. The Service
received the letter on November 28, 2016.

February 2, 2017 – By email, the Service provided a draft of the Conservation Measures, Reasonable
and Prudent Measures (RPM), Terms and Conditions, and Conservation Recommendations, along with
draft Appendices to the Corps, BOEM, NCDCM, and NCWRC.

February 6, 2017 – The Service met with the Corps, BOEM, NCDCM, and NCWRC to discuss the draft
RPMs and Terms and Conditions. By email, the Service requested comments to the draft by February
17, 2017.

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February 16, 2017 – By email, the Corps requested an extension of time to March 10, 2017, to formulate
comments and recommend revisions to the RPMs and Terms and Conditions. The Service concurred by
email

March 10, 2017 – By email, the Corps provided comments and recommendations to the draft RPMs and
Terms and Conditions. A conference call was scheduled to discuss the recommendations.

March 27, 2017 – By email, the Service provided a second draft of the Conservation Measures,
Reasonable and Prudent Measures (RPM), Terms and Conditions, and Conservation Recommendations,
along with draft Appendix D to the Corps, BOEM, NCDCM, and NCWRC.

March 31, 2017 – The Service, the Corps, BOEM, NCWRC, and NCDCM participated in a conference
call to discuss the most recent draft of the RPMs and Terms and Conditions.

April 5, 2017 – By email, the Service provided a third draft of the Conservation Measures, Reasonable
and Prudent Measures (RPM), Terms and Conditions, and Conservation Recommendations, along with
draft Appendix D to the Corps, BOEM, NCDCM, and NCWRC.

May 1, 2017 – By email, the Corps provided final comments and recommendations to the third draft of
the draft RPMs and Terms and Conditions.

May 2, 2017 – By Email, the Service provided a final draft of the SPBO and all of the Appendices to the
Corps, BOEM, NCDCM, and NCWRC.

May 5, 2017 – By email, the Corps provided final comments and recommendations to the third draft
SPBO.

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BIOLOGICAL OPINION

INTRODUCTION

A biological opinion (BO) is the document that states the opinion of the U.S. Fish and Wildlife Service
(Service) as to whether a federal action is likely to jeopardize the continued existence of listed species or
result in the destruction or adverse modification of designated critical habitat. This BO addresses piping
plover (Charadrius melodus melodus), red knot (Calidris canutus rufa), seabeach amaranth
(Amaranthus pumilus), and the loggerhead (Caretta caretta), leatherback (Dermochelys coriacea), green
(Chelonia mydas), hawksbill (Eretmochelys imbricata), and Kemp’s ridley sea turtles (Lepidochelys
kempii). Designated critical habitat for wintering piping plovers and terrestrial critical habitat for
loggerhead sea turtles is also addressed. The BO evaluates the effects of the Action along with those
resulting from interrelated and interdependent actions, and from non-federal actions unrelated to the
proposed Action (cumulative effects), relative to the status of the species and the status of the critical
habitat to arrive at a Service opinion that the proposed action is or isn’t likely to jeopardize species or
adversely modify critical habitat. Jeopardize the continued existence of means to engage in an action
that reasonably would be expected, directly or indirectly, to reduce appreciably the likelihood of both
the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or
distribution of that species (50 CFR §402.02). Destruction or adverse modification of designated critical
habitat means a direct or indirect alteration that appreciably diminishes the value of critical habitat for
the conservation of a listed species. Such alterations may include, but are not limited to, those that alter
the physical or biological features essential to the conservation of a species or that preclude or
significantly delay development of such features (50 CFR §402.02).

1. DESCRIPTION OF THE PROPOSED ACTION

This is a Statewide Programmatic Biological Opinion (SPBO). The proposed action includes all
activities associated with the placement of compatible sediment on the oceanfront beaches of North
Carolina, encompassing the entire range of the South Atlantic Wilmington (SAW) Corps Districts. This
SPBO includes Corps Regulatory and Civil Works shore protection activities. Corps Regulatory
activities may include the involvement of other Federal agencies, such as the Department of Defense
(DoD), Bureau of Ocean Energy Management (BOEM), and the Federal Emergency Management
Agency (FEMA). The sand placement activities covered in the SPBO encompass the following (when
conducted between November 16 and April 30):

1. Sand placement on the sandy beach or dune by any non-federal public or private entity;
2. Sand placement as an associated authorization of sand extraction from the Outer Continental
Shelf (OCS) by BOEM; and
3. Sand placement funded or conducted by a Federal agency, such as Coastal Storm Damage
Reduction (CSDR) Projects, federal public assistance projects administered by FEMA or other
federal agencies, and beach disposal from Operations and Maintenance (O&M) dredging of
navigation channels (dredging is not included).

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The history of shore protection activities in North Carolina is extensive and consists of a myriad of
actions performed by local, State, and Federal entities. Future beach placement actions addressed in this
SPBO may include maintenance of these existing projects or beaches that have not experienced a history
of beach placement activities.

The Service and National Oceanic and Atmospheric Administration’s (NOAA) National Marine
Fisheries Service (NMFS) share Federal jurisdiction for sea turtles under the Act. The Service has
responsibility for sea turtles on the nesting beach. The Service and the NMFS share Federal jurisdiction
for sea turtles under the ESA. NMFS has jurisdiction for sea turtles in the marine environment. This
SPBO only addresses activities that may impact nesting sea turtles, their nests and eggs, and hatchlings
as they emerge from the nest and crawl to the sea. NMFS will assess and consult with the Corps
concerning potential impacts to sea turtles in the marine environment, including updrift and downdrift
nearshore areas affected by sand placement projects on the beach.

1.1 Action Area

The Service has described the action area to include sandy oceanfront beaches of North Carolina, for
reasons that will be explained and discussed in the “EFFECTS OF THE ACTION” section of this
consultation. The Programmatic Biological Assessment (PBA) defines currently managed shorelines in
North Carolina as those that include active projects and those that are under study. The length of
currently managed shoreline is 112 miles, but is anticipated to eventually grow to 163 miles. Based on
the current length of managed shoreline in North Carolina, the BA anticipates that sand placement
considered in this opinion will affect up to 25 miles of shoreline annually in North Carolina. However,
after major storms, increases in the annual length of sand placement are expected. In years following
major storm events, the BA states that a 250% increase in average annual sand placement can
reasonably be expected. Therefore, in post-storm years (declared disaster or Congressional Order); a
maximum length of annual sand placement is 62.5 miles (25 miles plus an additional 27.5 miles).

1.2. Conservation Measures: Corps Commitments as listed in the Final Programmatic
Biological Assessment

The following language from the PBA lists the Conservation Measures proposed by the Corps. All sand
placement projects would employ each of the following measures to reduce impacts on listed species
and critical habitats:

Piping Plover and Red Knot

1) All sand placement activities will be completed between 16 November and 30 April; thereby
avoiding the majority of the piping plover breeding season, a portion of the piping plover migration
period, and the peak red knot migration period in NC.
2) As a means of minimizing the extent and/or duration of adverse effects on habitats and benthic prey
resources, all material placed on the beach and in associated dune systems will consist of beach
compatible sediment. Beach compatible material will consist of sediments that are similar in
composition, grain size distribution, and color to the native sediments of the recipient beaches.
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3) Construction staging areas and pipeline routes will be located to avoid high-value inlet complex
habitats for piping plovers and red knots to the maximum extent practicable.
4) Temporary storage areas for construction equipment and pipelines will be located off the beach to the
maximum extent practicable.

Sea Turtles

1) All sand placement activities will be completed between 16 November and 30 April; thereby
avoiding the sea turtle nesting and hatching season in NC.
2) All material placed on the beach and in associated dune systems will consist of beach compatible
sediment that is suitable for sea turtle nesting. Beach compatible material will consist of sediments
that are similar in composition, grain size distribution, and color to the native sediments of the
recipient beaches.
3) Immediately after construction and to the maximum extent practicable prior to 1 May, surveys for
escarpments will be conducted within the limits of construction areas. Identified escarpments that
that may interfere with sea turtle nesting (>18 inches in height and ≥ 100 ft in length) will be leveled
to the natural beach profile. If it is determined that escarpment leveling is required during the
nesting season, leveling activities would be coordinated with the USFWS or NCWRC.
4) Immediately after construction and to the maximum extent practicable prior to 1 May, the limits of
construction areas will be evaluated for compaction in coordination with the USFWS and NCWRC.
If it is determined that tilling is required for sea turtle nesting habitat suitability, the construction
areas will be tilled to a depth of 36 inches. All tilling activity shall be completed prior to 1 May to
the maximum extent practicable. In the case of projects that run until the 30 April nesting window
cutoff, any tilling activities required after 1 May would be coordinated with the USFWS or
NCWRC.
5) Post-construction monitoring of sea turtle nesting activities will be conducted in sand placement
areas to assess effects on nesting. Monitoring will include daily surveys from 1 May until 15
September. Nesting data will be included in annual monitoring reports to be provided to the
NCWRC.

Seabeach Amaranth

1) All sand placement activities will be completed between 16 November and 30 April; thereby
avoiding the majority of the seabeach amaranth growing season in NC.

1.3. Project Timing and Duration

This SPBO encompasses sand placement activities that occur within the winter work window
(November 16 through April 30).

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2. PIPING PLOVER

2.1. Status of the Species

2.1.1. Species description

Listing: On January 10, 1986, the piping plover was listed as endangered in the Great Lakes watershed
and threatened elsewhere within its range, including migratory routes outside of the Great Lakes
watershed and wintering grounds (USFWS 1985). Piping plovers were listed principally because of
habitat destruction and degradation, predation, and human disturbance. Protection of the species under
the ESA reflects the species’ precarious status range-wide.

Three separate breeding populations have been identified, each with its own recovery criteria: the
Northern Great Plains (threatened), the Great Lakes (endangered), and the Atlantic Coast (threatened).
Piping plovers that breed on the Atlantic Coast of the U.S. and Canada belong to the subspecies C. m.
melodus. The second subspecies, C. m. circumcinctus, is comprised of two populations. One population
breeds on the Northern Great Plains of the U.S. and Canada, while the other breeds on the Great Lakes.
Each of these three entities is demographically independent. The piping plover winters in coastal areas
of the U.S. from North Carolina to Texas, and along the coast of eastern Mexico and on Caribbean
islands from Barbados to Cuba and the Bahamas (Haig and Elliott-Smith 2004) (Figure 1).

Piping plovers in the Action Area include individuals from all three breeding populations. Piping plover
subspecies are phenotypically indistinguishable, and most studies in the nonbreeding range report results
without regard to breeding origin. Although a 2012 analysis shows strong patterns in the wintering
distribution of piping plovers from different breeding populations (Gratto-Trevor et al. 2012),
partitioning is not complete and major information gaps persist. This BO will consider each population
separately.

North Carolina is the only state where the piping plover's breeding and wintering ranges overlap and the
birds are present year-round. Piping plovers nest above the high tide line on coastal beaches; on sand
flats at the ends of sand spits and barrier islands; on gently sloping foredunes; in blowout areas behind
primary dunes (overwashes); in sparsely vegetated dunes; and in overwash areas cut into or between
dunes. The species requires broad, open, sand flats for feeding, and undisturbed flats with low dunes
and sparse dune grasses for nesting.

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Figure 1. Distribution and range of piping plovers (base map from Haig and Elliott-Smith 2004).
Conceptual presentation of subspecies and population ranges are not intended to convey precise
boundaries.

Piping plovers from the federally endangered Great Lakes breeding population, as well birds from the
threatened Atlantic Coast and Northern Great Plains breeding populations overwinter on North Carolina
beaches. Piping plovers arrive on their breeding grounds in late March or early April. In the Great
Lakes, arrival on the breeding grounds may be mid-April to early May. Following establishment of
nesting territories and courtship rituals, the pair forms a depression in the sand, where the female lays
her eggs. Some adults leave the breeding grounds as early as July. By early September both adults and
young depart for their wintering areas.

2.1.2. Life history

The piping plover is a small, pale sand-colored shorebird, about seven inches long with a wingspan of
about 15 inches (Palmer 1967). Cryptic coloration is a primary defense mechanism for piping plovers
where nests, adults, and chicks all blend in with their typical beach surroundings.
Piping plovers live an average of 5 years, although studies have documented birds as old as 11 (Wilcox
1959) and 15 years. Plovers are known to begin breeding as early as one year of age (MacIvor 1990;
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Haig 1992). In studies with large numbers of marked interior breeding piping plovers, Saunders et al.
(2014) found that 56 percent of female Great Lakes piping plovers mated in their first season post-hatch,
while 68 percent of female yearlings mated in Saskatchewan in 2001-2006 (Gratto-Trevor et al. 2010).
Both studies found that probability of breeding in the first year was lower for males than females, but
Great Lakes males that had not bred earlier were more likely than females to recruit into the breeding
population in years two and three. Virtually all surviving Great Lakes piping plovers began breeding by
year three (Saunders et al. 2014). Piping plover breeding activity begins in mid-March when birds begin
returning to their nesting areas (Coutu et al. 1990; Cross 1990; Goldin et al. 1990; MacIvor 1990; Hake
1993). Piping plovers generally fledge only a single brood per season, but may re-nest several times if
previous nests are lost. The reduction in suitable nesting habitat due to a number of factors is a major
threat to the species, likely limiting reproductive success and future recruitment into the population
(USFWS 2009a).

Plovers depart their breeding grounds for their wintering grounds between July and late August, but
southward migration extends through November. More information about the three breeding populations
of piping plovers can be found in the following documents:

a. Piping Plover, Atlantic Coast Population: 1996 Revised Recovery Plan (USFWS 1996a);
b. 2009 Piping Plover (Charadrius melodus) 5-Year Review: Summary and Evaluation (USFWS
2009a);
c. 2003 Recovery Plan for the Great Lakes Piping Plover (Charadrius melodus) (USFWS 2003a);
d. Questions and Answers about the Northern Great Plains population of Piping Plover (USFWS
2002).
e. 2016 Draft Revised Recovery Plan for the Northern Great Plains population of Piping Plover
(USFWS 2015).

North Carolina is one of the only states in which piping plovers may be found year-round.
Piping plovers migrate through and winter in coastal areas of the U.S. from North Carolina to Texas and
in portions of Mexico and the Caribbean. Data based on five rangewide mid-winter (late January to early
February) population surveys, conducted at 5-year intervals starting in 1991, show that total numbers
have fluctuated over time, with some areas experiencing increases and others decreases. Regional and
local fluctuations may reflect the quantity and quality of suitable foraging and roosting habitat, which
vary over time in response to natural coastal formation processes as well as anthropogenic habitat
changes (e.g., inlet relocation, dredging of shoals and spits). Fluctuations may also represent localized
weather conditions (especially wind) during surveys, or unequal survey coverage. Changes in wintering
numbers may also be influenced by growth or decline in the particular breeding populations that
concentrate their wintering distribution in a given area.

Breeding and wintering plovers feed on exposed wet sand in swash zones; intertidal ocean beach; wrack
lines; washover passes; mud, sand, and algal flats; and shorelines of streams, ephemeral ponds, lagoons,
and salt marshes by probing for invertebrates at or just below the surface (Coutu et al. 1990; USFWS
1996a). They use beaches adjacent to foraging areas for roosting and preening. Small sand dunes,
debris, and sparse vegetation within adjacent beaches provide shelter from wind and extreme
temperatures. Behavioral observations of piping plovers on the wintering grounds suggest that they
spend the majority of their time foraging and roosting (Nicholls and Baldassarre 1990a; 1990b; Drake
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1999a; 1999b, Maddock et al. 2009). Studies have shown that the relative importance of various feeding
habitat types may vary by site (Gibbs 1986; Coutu et al. 1990; McConnaughey et al. 1990; Loegering
1992; Goldin 1993; Hoopes 1993). Feeding activities may occur during all hours of the day and night
(Staine and Burger 1994; Zonick 1997), and at all stages in the tidal cycle (Goldin 1993; Hoopes 1993).
Wintering plovers primarily feed on invertebrates such as polychaete marine worms, various
crustaceans, fly larvae, beetles, and occasionally bivalve mollusks found on top of the soil or just
beneath the surface (Bent 1929; Cairns 1977; Nicholls 1989; Zonick and Ryan 1996).

Piping plovers exhibit a high degree of intra- and interannual wintering site fidelity (Nicholls and
Baldassarre 1990b; Drake et al. 2001; Noel and Chandler 2008; Stucker and Cuthbert 2006). However,
local movements during winter are more common. In South Carolina, Maddock et al. (2009)
documented many cross-inlet movements by wintering banded piping plovers as well as occasional
movements of up to 11.2 mi by approximately 10 percent of the banded population. Larger movements
within South Carolina were seen during fall and spring migration.

Atlantic Coast plovers nest on coastal beaches, sand flats at the ends of sand spits and barrier islands,
gently-sloped foredunes, sparsely-vegetated dunes, and washover areas cut into or between dunes.
Plovers arrive on the breeding grounds from mid-March through mid-May and remain for three to four
months per year; the Atlantic Coast plover breeding activities begin in March in North Carolina with
courtship and territorial establishment (Coutu et al. 1990; McConnaughey et al. 1990). Egg-laying
begins around mid-April with nesting and brood rearing activities continuing through July. They lay
three to four eggs in shallow, scraped depressions lined with light colored pebbles and shell fragments.
The eggs are well camouflaged and blend extremely well with their surroundings. Chicks are precocial,
often leaving the nest within hours of hatching, but are tended by adults who lead the chicks to and from
feeding areas, shelter them from harsh weather, and protect the young from perceived predators. Chicks
remain together with one or both parents until they fledge (are able to fly) at 25 to 35 days of age.

Atlantic and Gulf Coast studies highlighted the importance of inlets for nonbreeding piping plovers.
Almost 90% of observations of roosting piping plovers at ten coastal sites in southwest Florida were on
inlet shorelines (Lott et al. 2009b). In an evaluation of 361 International Shorebird Survey sites from
North Carolina to Florida (Harrington 2008), piping plovers were among seven shorebird species found
more often than expected (p = 0.0004; Wilcoxon Scores test) at inlet versus non-inlet locations.
Wintering plovers on the Atlantic Coast prefer wide beaches in the vicinity of inlets (Nicholls and
Baldassarre 1990b, Wilkinson and Spinks 1994). At inlets, foraging plovers are associated with moist
substrate features such as intertidal flats, algal flats, and ephemeral pools (Nicholls and Baldassarre
1990a, Wilkinson and Spinks 1994, Dinsmore et al. 1998).

2.1.3. Population dynamics

The International Piping Plover Breeding Census is conducted throughout the breeding grounds every 5
years by the Great Lakes/Northern Great Plains Recovery Team of the U.S. Geological Survey (USGS).
Although there are shortcomings in the census method, it is the largest known, complete avian species
census. The 2011 survey documented 2,391 breeding pairs, with a total of 5,723 birds throughout
Canada and the U.S. (Elliot-Smith et al. 2015).
16

The most consistent finding in the various population viability analyses conducted for piping plovers
(Ryan et al. 1993; Melvin and Gibbs 1996; Plissner and Haig 2000; Amirault et al. 2005; Calvert et al.
2006; Brault 2007) indicates even small declines in adult and juvenile survival rates will cause increases
in extinction risk. A banding study conducted between 1998 and 2004 in Atlantic Canada concluded
lower return rates of juvenile (first year) birds to the breeding grounds than was documented for
Massachusetts (Melvin and Gibbs 1996), Maryland (Loegering 1992), and Virginia (Cross 1996)
breeding populations in the mid-1980s and very early 1990s. This is consistent with failure of the
Atlantic Canada population to increase in abundance despite high productivity (relative to other
breeding populations) and extremely low rates of dispersal to the U.S. over the last 15 plus years
(Amirault et al. 2005). This suggests maximizing productivity does not ensure population increases.
However, Drake et al. (2001) observed no mortality among 49 radio-marked piping plovers (total of
2,704 transmitter-days) in Texas in the 1990s. Cohen et al. (2008) also reported no mortality among a
small sample (n=7) of radio-marked piping plovers at Oregon Inlet, North Carolina in 2005-2006.

The status of piping plovers on winter and migration grounds is difficult to assess, but threats to piping
plover habitat used during winter and migration identified by the Service during its designation of
critical habitat continue to affect the species. Unregulated motorized and pedestrian recreational use,
inlet and shoreline stabilization projects, beach maintenance and nourishment, and pollution affect most
winter and migration areas. Conservation efforts at some locations have likely resulted in the
enhancement of wintering habitat.

2.1.3.1. Northern Great Plains breeding population

The Northern Great Plains plover breeds from Alberta to Manitoba, Canada and south to Nebraska;
although some nesting has occurred in Oklahoma (Boyd 1991). Currently the most westerly breeding
piping plovers in the U.S. occur in Montana and Colorado.

The decline of piping plovers on rivers in the Northern Great Plains has been largely attributed to the
loss of sandbar island habitat and forage base due to dam construction and operation. Nesting occurs on
sand flats or bare shorelines of rivers and lakes, including sandbar islands in the upper Missouri River
system, and patches of sand, gravel, or pebbly-mud on the alkali lakes of the Northern Great Plains.
Plovers do nest on shorelines of reservoirs created by the dams, but reproductive success is often low
and reservoir habitat is not available in many years due to high water levels or vegetation. Dams
operated with steady constant flows allow vegetation to grow on potential nesting islands, making these
sites unsuitable for nesting. Population declines in alkali wetlands are attributed to wetland drainage,
contaminants, and predation.
The Northern Great Plains breeding population is geographically widespread, with many birds in very
remote places, especially in the U.S. and Canadian alkali lakes. Thus, determining the number of birds
or even identifying a clear trend in the population is a difficult task. The IPPC was designed, in part, to
help deal with this problem by instigating a large effort every five years in which an attempt is made to
survey every area with known or potential piping plover breeding habitat during a two-week window
(i.e., the first two weeks of June). The relatively short window is designed to minimize double counting
if birds move from one area to another. Participation in the IPPC has been excellent on the Northern
Great Plains, with a tremendous effort put forth to attempt to survey areas during the census window
17
(Elliot-Smith et al. 2009). The large area to be surveyed and sparse human population in the Northern
Great Plains make annual surveys of the entire area impractical. Many areas are only surveyed during
the IPPC years.

Figure 2 shows the number of adult plovers in the Northern Great Plains (U.S. and Canada) for all five
IPPCs. The IPPC shows that the U.S. population decreased between 1991 and 1996, then increased in
2001 and 2006. Combined with the numbers from Canada, the IPPC numbers suggest that the
population declined from 1991 through 2001, then increased almost 58% between 2001 and 2006
(Elliott-Smith et al. 2009). The 2011 breeding census count was substantially lower than the count in
2006 (over 4,500 birds in 2006 and 2,249 in 2011) (Elliott-Smith et al. 2015). It is unknown if the
decrease in counts is an accurate accounting of the piping plover population numbers, or if birds were
not counted due to displacement from flooding in the region that made traditional habitat unsuitable.

Figure 2. The number of adults reported for the U.S. and Canada Northern Great Plains breeding
population during the International Censuses from 1991 to 2011. Data from Elliott-Smith et al. 2009,
Elliott-Smith et al. 2015, Ferland and Haig 2002, Haig and Plissner 1993, Plissner and Haig 2000.

The increase in 2006 is likely due in large part to a multi-year drought across much of the region starting
in 2001 that exposed thousands of acres of nesting habitat. The Corps ran low flows on the riverine
stretches of the Missouri River for most of the years between censuses; allowing more habitat to be
exposed and resulting in relatively high fledge ratios (USACE 2008). The Corps also began to construct
habitat using mechanical means (dredging sand from the riverbed) on the Missouri River in 2004,
providing some new nesting and foraging habitat. The drought also caused reservoir levels to drop on
many reservoirs throughout the Northern Great Plains (e.g. Missouri River Reservoirs (ND, SD), Lake
McConnaughey (NE)), providing shoreline habitat. The population increase may also be partially due to
0
500
1000
1500
2000
2500
3000
3500
4000
4500
5000
1991 1996 2001 2006 2011
Nu
m
b
e
r

o
f

A
d
u
l
t

P
i
p
i
n
g

P
l
o
v
e
r
s

International Census Year
U.S. and Canada
Combined
Prairie Canada
U.S. Northern
Great Plains
18
more intensive management activities on the alkali lakes, with increased management actions to improve
habitat and reduce predation pressures. In 2011, the count was much lower, perhaps due to extreme
flooding of nesting habitat.

While the IPPC provides an index to the piping plover population, the design does not always provide
sufficient information to understand the population’s dynamics. The five-year time interval between
IPPC efforts may be too long to allow managers to get a clear picture of what the short-term population
trends are and to respond accordingly if needed. As noted above, the first three IPPCs (1991, 1996, and
2001) showed a declining population, while the fourth (2006) indicated a dramatic population rebound
of almost 58% for the combined U.S. and Canada Northern Great Plains breeding population between
2001 and 2006. The results for 2011 indicate a similar grand population total as 2006, but a declining
population in the U.S. The larger overall population total in 2011 can be attributed to the larger numbers
of plovers observed in the Bahamas. With only five data points over 20 years, it is impossible to
determine if and to what extent the data reflects a real population trend versus error(s) in the 2011
census counts and/or a previous IPPC. The 2006 IPPC included a detectability component, in which a
number of pre-selected sites were visited twice by the same observer(s) during the two-week window to
get an estimate of error rate. This study found an approximately 76% detectability rate through the
entire breeding area, with a range of between 39% to 78% detectability among habitat types in the
Northern Great Plains.

2.1.3.2. Great Lakes breeding population

The Great Lakes plovers once nested on Great Lakes beaches in Illinois, Indiana, Michigan, Minnesota,
New York, Ohio, Pennsylvania, Wisconsin, and Ontario. Great Lakes piping plovers nest on wide, flat,
open, sandy or cobble shoreline with very little grass or other vegetation. Reproduction is adversely
affected by human disturbance of nesting areas and predation by foxes, gulls, crows and other avian
species. Shoreline development, such as the construction of marinas, breakwaters, and other navigation
structures, has adversely affected nesting and brood rearing.
The Recovery Plan (USFWS 2003a) sets a population goal of at least 150 pairs (300 individuals), for at
least 5 consecutive years, with at least 100 breeding pairs (200 individuals) in Michigan and 50 breeding
pairs (100 individuals) distributed among sites in other Great Lakes states. The Great Lakes breeding
population, which has been traditionally represented as the number of breeding pairs, has slowly
increased after the completion of the recovery plan between 2003 and 2016 (Figure 3) (Cuthbert and
Roche 2007; Cuthbert and Roche 2006; Westbrock et al. 2005; Stucker and Cuthbert 2004; Stucker et al.
2003; Cuthbert and Saunders 2013). The Great Lakes piping plover recovery plan documents the 2002
population at 51 breeding pairs (USFWS 2003a), and in 2016, 75 breeding pairs were estimated
(Cavalieri pers. comm. 2016a). Monitoring efforts in years since have documented mostly increases
with a few years of decreases. The Great Lakes annual monitoring program is an intensive survey effort
with nearly daily monitoring of active breeding locations. Fluctuations in the number of breeding pairs
between 2009 and 2016 may have been caused by weather conditions or merlin predation (Elliott-Smith
et al. 2015).

19
Figure 3. Annual Breeding Pair Estimates for Great Lakes Piping Plovers (2003-2016). Data from
Cuthbert and Saunders 2013, Cavalieri pers. comm. 2016a; 2016c.

A single breeding pair discovered in 2007 in the Great Lakes region of Canada represented the first
confirmed piping plover nest there in over 30 years. The number of nesting pairs in Canada increased to
four in 2008, six in 2011, and 15 in 2016 (Cavalieri pers. comm. 2016a; 2016d). These 15 nesting pairs
are included in the total population of 75 breeding pairs above.

The total fall population, including fledged chicks and captive-raised chicks was 310 in 2014. In 2015,
the number was estimated at approximately 325. In fall of 2016, the number is currently estimated at
approximately 330 (Cavalieri pers. comm.2016b). As winter approaches, this number is expected to be
reduced rather quickly, as hatch-year mortality may be as high as 63% (Saunders et al. 2014; Saunders
pers.comm. 2016).

Survival rates in general for Great Lakes piping plovers have declined over 20 percentage points since
1994 (Table 1) (Saunders pers. comm. 2016). The estimated annual survival rates in 1994 for males in
the Great Lakes breeding population was 0.878 (or almost 88%), while the survival rate for females was
a bit lower at 0.87. The survival rates have fallen steadily since then, and by 2012, the survival rate was
0.667 for males and 0.650 for females (Saunders pers. comm. 2016). During this time, adult predation
by merlins (Falco columbarius) increased as a result of a general increase in merlin population numbers
and a range expansion that began in the 1980s (Haas 2011; Cava et al. 2014). Management of merlin
predation on the breeding grounds appears to have allowed the survival rate to stabilize (Roche et al.
2010a; Saunders pers. comm. 2016).

0
10
20
30
40
50
60
70
80
2002 2004 2006 2008 2010 2012 2014 2016 2018
No
.

o
f

P
a
i
r
s

Year
20
Table 1. Survival rates of adult male and female Great Lakes piping plovers, 1994 to 2012. Data from
Saunders pers. comm. 2016.

Year Male
Survival
Rate
Female
Survival
Rate
1994 0.878 0.870
1995 0.878 0.870
1996 0.811 0.799
1997 0.807 0.795
1998 0.827 0.816
1999 0.792 0.778
2000 0.737 0.721
2001 0.778 0.765
2002 0.761 0.746
2003 0.747 0.732
2004 0.790 0.776
2005 0.694 0.677
2006 0.639 0.621
2007 0.666 0.648
2008 0.677 0.660
2009 0.698 0.682
2010 0.713 0.697
2011 0.664 0.646
2012 0.667 0.650

2.1.3.3. Atlantic Coast Population

The Atlantic Coast piping plover breeds on coastal beaches from Newfoundland and southeastern
Quebec to North Carolina. Historical population trends for the Atlantic Coast piping plover have been
reconstructed from scattered, largely qualitative records. Nineteenth-century naturalists, such as
Audubon and Wilson, described the piping plover as a common summer resident on Atlantic Coast
beaches (Haig and Oring 1987). However, by the beginning of the 20th Century, egg collecting and
uncontrolled hunting, primarily for the millinery trade, had greatly reduced the population, and in some
areas along the Atlantic Coast, the piping plover was close to extirpation. Following passage of the
Migratory Bird Treaty Act (MBTA) (40 Stat. 775; 16 U.S.C. 703-712) in 1918, and changes in the
fashion industry that no longer exploited wild birds for feathers, piping plover numbers recovered to
some extent (Haig and Oring 1985).
21
Available data suggest that the most recent population decline began in the late 1940s or early 1950s
(Haig and Oring 1985). Reports of local or statewide declines between 1950 and 1985 are numerous,
and many are summarized by Cairns and McLaren (1980) and Haig and Oring (1985). While Wilcox
(1939) estimated more than 500 pairs of piping plovers on Long Island, New York, the 1989 population
estimate was 191 pairs (see Table 4, USFWS 1996a). There was little focus on gathering quantitative
data on piping plovers in Massachusetts through the late 1960s because the species was commonly
observed and presumed to be secure. However, numbers of piping plover breeding pairs declined 50 to
100 percent at seven Massachusetts sites between the early 1970s and 1984 (Griffin and Melvin 1984).
Piping plover surveys in the early years of the recovery effort found that counts of these cryptically-
colored birds sometimes went up with increased census effort, suggesting that some historic counts of
piping plovers by one or a few observers may have underestimated the piping plover population. Thus,
the magnitude of the species decline may have been more severe than available numbers imply.

Annual estimates of breeding pairs of Atlantic Coast piping plovers are based on multiple surveys at
most occupied sites. Sites that cannot be monitored repeatedly in May and June (primarily sites with
few pairs or inconsistent occupancy) are surveyed at least once during a standard nine-day count period
(Hecht and Melvin 2009). See Tables 2 and 3 for unpublished data from the Service.

22
Table 2. Estimated abundance of Atlantic Coast piping plovers, 1986 to 2000. Unpublished data from the Service (2016).

State or
Recovery Unit Number of pairs /year
1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000
Maine 15 12 20 16 17 18 24 32 35 40 60 47 60 56 50
New Hampshire 5 5 6 6
Massachusetts 139 126 134 137 140 160 213 289 352 441 454 483 495 501 496
Rhode Island 10 17 19 19 28 26 20 31 32 40 50 51 46 39 49
Connecticut 20 24 27 34 43 36 40 24 30 31 26 26 21 22 22

New York 106 135 172 191 197 191 187 193 209 249 256 256 245 243 289
New Jersey 102 93 105 128 126 126 134 127 124 132 127 115 93 107 112

Delaware 8 7 3 3 6 5 2 2 4 5 6 4 6 4 3
Maryland 17 23 25 20 14 17 24 19 32 44 61 60 56 58 60
Virginia 100 100 103 121 125 131 97 106 96 118 87 88 95 89 96
North Carolina 30 30 40 55 55 40 49 53 54 50 35 52 46 31 24
South Carolina 3 0 1 1 1 0

U.S. Total 550 567 648 724 752 751 790 877 968 1150 1162 1187 1168 1156 1207

Eastern Canada 240 223 238 233 230 252 223 223 194 200 202 199 211 236 230

Atlantic Coast
Total
790 790 886 957 982 1003 1013 1100 1162 1350 1364 1386 1379 1392 1437

23
Table 3. Estimated abundance of Atlantic Coast piping plovers, 2001 to 2014, with Preliminary data from 2015. Unpublished data
from the Service (2016). *Numbers in parentheses are preliminary estimates, subject to revision.

State or
Recovery Unit Number of pairs /year
2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015*
Maine 55 66 61 55 49 40 35 24 27 30 33 42 44 50 62
New Hampshire 7 7 7 4 3 3 3 3 5 4 4 6 7 6 8
Massachusetts 495 538 511 488 467 482 558 566 593 591 656 676 666 663 687
Rhode Island 52 58 71 70 69 72 73 77 84 85 86 90 92 91 99
Connecticut 32 31 37 40 34 37 36 41 44 43 52 51 45 51 62

New York 309 369 386 384 374 422 457 443 437 390 318 342 289 268 (303)
New Jersey 122 138 144 135 111 116 129 111 105 108 111 121 108 92 108

Delaware 6 6 6 7 8 9 9 10 10 9 8 7 6 6 6
Maryland 60 60 59 66 63 64 64 49 45 44 36 41 45 38 36
Virginia 119 120 114 152 192 202 199 208 193 192 188 259 251 245 256
North Carolina 23 23 24 20 37 46 61 64 54 61 62 70 56 65 64
South Carolina 0 0

U.S. Total 1280 1416 1420 1421 1407 1493 1624 1596 1597 1557 1554 1705 1609 1593 (1691)

Eastern Canada 250 274 256 237 217 256 266 253 252 225 209 179 184 186 179

Atlantic Coast
Total
1530 1690 1676 1658 1624 1749 1890 1849 1849 1782 1763 1884 1793 1779 (1870)
Since its 1986 listing under the ESA, the Atlantic Coast population estimate increased from
approximately 790 pairs to an estimated 1,870 pairs in 2015, and the U.S. portion of the
population more than tripled, from approximately 550 pairs to an estimated 1,691 pairs (Hecht
and Melvin 2009; Elliott-Smith et al. 2015; USFWS 2015). Even discounting apparent increases
in New York, New Jersey, and North Carolina between 1986 and 1989, which likely were due in
part to increased census effort (USFWS 1996a), the population nearly doubled between 1989 and
2008. The overall population growth pattern was tempered by periodic rapid declines in the
Southern and Eastern Canada Recovery Units. The eastern Canada population decreased 21% in
just three years (2002-2005), and the population in the southern half of the Southern Recovery
Unit declined 68% in seven years (1995-2001). The 64% decline in the Maine population, from
66 pairs in 2002 to 24 pairs in 2008, following only a few years of decreased productivity,
provides another example of the continuing risk of rapid and precipitous reversals in population
growth (Hecht and Melvin 2009).

2.1.4. Status and distribution

Reason for Listing: Hunting during the 19th and early 20th centuries likely led to initial declines
in the species; however, shooting piping plovers has been prohibited since 1918 pursuant to the
provisions of the MBTA. Other human activities, such as habitat loss and degradation,
disturbance from recreational pressure, contaminants, and predation are likely responsible for
continued declines. These factors include development and shoreline stabilization. The 1985
final rule stated the number of piping plovers on the Gulf of Mexico coastal wintering grounds
might be declining as indicated by preliminary analysis of the Christmas Bird Count data.
Independent counts of piping plovers on the Alabama coast indicated a decline in numbers
between the 1950s and early 1980s. At the time of listing, the Texas Parks and Wildlife
Department stated 30 percent of wintering habitat in Texas had been lost over the previous 20
years. The final rule also stated, in addition to extensive breeding area problems, the loss and
modification of wintering habitat was a significant threat to the piping plover.

Range-wide Trend: Five range-wide population surveys have been conducted for the piping
plover; the 1991 (Haig and Plissner 1992), 1996 (Plissner and Haig 1997), 2001, 2006 (Elliott-
Smith et al. 2009), and 2011 IPPCs. These surveys were completed to help determine the
species distribution and to monitor progress toward recovery. Data from these surveys were
provided in the previous pages.

Recovery Criteria

Delisting of the three piping plover populations may be considered when the following criteria
are met:

Northern Great Plains Breeding Population (USFWS 1988, 1994)

1. Increase the number of birds in the U.S. Northern Great Plains states to 2,300
pairs (Service 1994).
2. Increase the number of birds in the prairie region of Canada to 2,500 adult piping
plovers (Service 1988).
3. Secure long term protection of essential breeding and wintering habitat (Service
1994).

25
In 2016, the Service drafted new recovery criteria for the Northern Great Plains breeding
population. The new criteria are expected to be finalized in the near future.

Great Lakes Breeding Population (USFWS 2003a)

1. At least 150 pairs (300 individuals), for at least 5 consecutive years, with at least
100 breeding pairs (200 individuals) in Michigan and 50 breeding pairs (100
individuals) distributed among sites in other Great Lakes states.
2. Five-year average fecundity within the range of 1.5-2.0 fledglings per pair, per
year, across the breeding distribution, and ten-year population projections indicate
the population is stable or continuing to grow above the recovery goal.
3. Protection and long-term maintenance of essential breeding and wintering habitat
is ensured, sufficient in quantity, quality, and distribution to support the recovery
goal of 150 pairs (300 individuals).
4. Genetic diversity within the population is deemed adequate for population
persistence and can be maintained over the long-term.
5. Agreements and funding mechanisms are in place for long-term protection and
management activities in essential breeding and wintering habitat.

Atlantic Coast Breeding Population (USFWS 1996a)

1. Increase and maintain for 5 years a total of 2,000 breeding pairs, distributed among 4
recovery units.

Recovery Unit Minimum Subpopulation
Atlantic (eastern) Canada 400 pairs
New England 625 pairs
New York-New Jersey 575 pairs
Southern (DE-MD-VA-NC) 400 pairs

2. Verify the adequacy of a 2,000 pair population of piping plovers to maintain
heterozygosity and allelic diversity over the long term.
3. Achieve a 5-year average productivity of 1.5 fledged chicks per pair in each of the 4
recovery units described in criterion 1, based on data from sites that collectively
support at least 90% of the recovery unit’s population.
4. Institute long-term agreements to assure protection and management sufficient to
maintain the population targets and average productivity in each recovery unit.
5. Ensure long-term maintenance of wintering habitat, sufficient in quantity, quality, and
distribution to maintain survival rates for a 2,000-pair population.

26
Conservation Recommendations

Nonbreeding Plovers from All Three Breeding Populations (USFWS 2012)

1. Maintain natural coastal processes that perpetuate wintering and coastal migration
habitat.
2. Protect wintering and migrating piping plovers and their habitat from human
disturbance.
3. Monitor nonbreeding plovers and their habitat.
4. Protect nonbreeding plovers and their habitats from contamination and
degradation from oil or other chemical contaminants.
5. Assess predation as a potential limiting factor for piping plovers on wintering and
migration sites.
6. Improve application or regulatory tools.
7. Develop mechanisms to provide long-term protection of nonbreeding plovers and
their habitat.
8. Conduct scientific investigations to refine knowledge and inform conservation of
migrating and wintering piping plovers.

Breeding Range

Northern Great Plains Breeding Population

The IPPC numbers indicate that the Northern Great Plains breeding population (including
Canada) declined from 1991 through 2001, and then increased dramatically in 2006. This
increase corresponded with a multi-year drought in the Missouri River basin that exposed a great
deal of nesting habitat, suggesting that the population can respond fairly rapidly to changes in
habitat quantity and quality. Despite this improvement, we do not consider the numeric,
distributional, or temporal elements of the population recovery criteria achieved.

As the Missouri River basin emerged from drought and breeding habitat was inundated in
subsequent years after 2006, the population declined (See Figure 2). The management activities
carried out in many areas during drought conditions undoubtedly helped to maintain and increase
the piping plover population, especially to mitigate for otherwise poor reproductive success
during wet years when habitat is limited.

While the population increase seen between 2001 and 2006 demonstrates the possibility that the
population can rebound from low population numbers, ongoing efforts are needed to maintain
and increase the population. In the U.S., piping plover crews attempt to locate most piping
plover nests and take steps to improve their success. This work has suffered from insufficient
and unstable funding in most areas.

27
Emerging threats, such as energy development (particularly wind, oil and gas and associated
infrastructure) and climate change are likely to impact piping plovers both on the breeding and
wintering grounds. The potential impact of both of these threats is not well understood, and
measures to mitigate for them are also uncertain at this time.

In the 2009 status review, the Service concluded that the Northern Great Plains breeding
population remains vulnerable, especially due to management of river systems throughout the
breeding range (USFWS 2009a). Many of the threats identified in the 1988 recovery plan,
including those affecting Northern Great Plains breeding population during the two-thirds of its
annual cycle spent in the wintering range, remain today or have intensified.

Great Lakes Breeding Population

Despite a declining annual survival rate, the population has shown significant growth, from
approximately 17 pairs at the time of listing in 1986, to 75 pairs in 2015 and 2016. The total of
75 breeding pairs represents 50% of the current recovery goal of 150 breeding pairs for the Great
Lakes breeding population. Productivity goals, as specified in the 2003 recovery plan, have been
met over the past 5 years. During this time period the average annual fledging rate has varied,
but averages about 1.7, well above the 1.5 fledglings per breeding pair recovery goal (Cavalieri
pers. comm. 2016d). The total estimated population in 2016, including breeding pairs, non-
breeding adults, and 2016 chicks, is approximately 330 individuals. Approximately 130 of those
are 2016 chicks. However, that number may decline quickly over the next several months with
the expected mortality of some hatch-year adults (Cavalieri pers. comm. 2016b). Survival of
fledged hatch-year individuals has been estimated at approximately 37% (Roche et al. 2008;
Saunders et al. 2014), so approximately 48 chicks of the 130 chicks are expected to survive until
the 2017 breeding season. Analyses of banded piping plovers in the Great Lakes suggests that
after-hatch year (adult) survival rates are declining, although management of merlin predation on
the breeding grounds appears to have allowed the survival rate to stabilize (Roche et al. 2010;
Saunders pers. comm. 2016). It is the productivity rate, or recruitment rate, that has continued
to increase the overall population, despite considerable decreases in adult survival rates.
Continued population growth will require the long-term maintenance of productivity goals
concurrent with measures to sustain or improve important vital rates. Older birds are typically
more successful breeders (Cavalieri pers.comm. 2016b), so after-hatch year survival rates may
have a great effect on the overall population growth.

An additional factor in the number of breeding pairs is a sex ratio that is skewed towards males.
Many of the non-breeding adults are males. There may be as many as 40 more males in the
population each year than females, and males make up the majority of the non-breeding
population. Females are more valuable individuals in part because of their reduced number
compared to males (Cavalieri pers. comm. 2016b).

28
Several years of population growth is evidence of the effectiveness of the ongoing Great Lakes
piping plover recovery program. However, the average annual growth of just less than 2.3% in
this small population typically results in only 3 or 4 additional surviving individuals each year
(Catlin pers. comm. 2016a). Most major threats, including habitat degradation, predation, and
human disturbance remain persistent and pervasive. Severe threats from human disturbance and
predation remain ubiquitous within the Great Lakes. Expensive labor-intensive management to
minimize the effects of these continuing threats, as specified in recovery plan tasks, are
implemented every year by a network of dedicated governmental and private partners. Because
threats to Great Lakes piping plovers persist and annual gains are rather small, reversal of gains
in abundance and productivity are expected to quickly follow if current protection efforts are
reduced.

Habitat destruction and development have greatly reduced the amount of nesting habitat in all
states in the Great Lakes region from which piping plovers are extirpated. Human disturbance
and high predator densities compromise the quality of habitat that otherwise currently possesses
physical characteristics suitable for piping plover foraging and breeding. Many physically
suitable sites that are no longer occupied are distant from the current breeding area, potentially
limiting opportunities for recolonization. Additionally, lake level fluctuations and winter storms
periodically alter the quantity and quality of habitat at individual sites throughout the region
(USFWS 2003a). Emerging potential threats to piping plovers in the Great Lakes basin include
disease, increased predation by merlins on adults and chicks, wind turbine generators and,
potentially, climate change. Type-E botulism in the Northern Lake Michigan basin has resulted
in 15 to 20 piping plover mortalities since 2000 (USFWS 2013c), including at least 4 in 2016.
Future outbreaks in areas that support a concentration of breeding piping plovers could impact
survival rates and population abundance. Wind turbine projects, many of which are currently in
the planning stages, need further study to determine potential risks to piping plovers and/or their
habitat, as well as the need for specific protections to prevent or mitigate impacts. Climate
change projections for the Great Lakes include the potential for significant water-level decreases.
The degree to which this factor will impact piping plover habitat is unknown, but prolonged
water-level decreases are likely to alter habitat condition and distribution.

In the 2009 status review, the Service concluded that the Great Lakes breeding population
remains at considerable risk of extinction due to its small size, limited distribution and
vulnerability to stochastic events, such as disease outbreak (USFWS 2009a). In addition, the
factors that led to the piping plover’s 1986 listing remain present.

Atlantic Coast Breeding Population

Substantial population growth, from approximately 790 pairs in 1986 to an estimated 1,870 pairs
in 2015, has decreased the Atlantic Coast piping plover’s vulnerability to extinction since ESA
listing (Tables 2 and 3). Thus, considerable progress has been made towards the overall goal of
2,000 breeding pairs articulated in recovery criterion 1. As discussed in the 1996 revised

29
recovery plan, however, the overall security of the Atlantic Coast piping plover is fundamentally
dependent on even distribution of population growth, as specified in subpopulation targets, to
protect a sparsely-distributed species with strict biological requirements from environmental
variation (including catastrophes) and increase the likelihood of interchange among
subpopulations. Population growth has been tempered by geographic and temporal variability.
By far, the largest net population increase between 1989 and 2015 occurred in New England
(445 percent). Net growth in the Southern Recovery Unit population was over 182 percent
between 1989 and 2015, but the subpopulation target has not yet been attained. Preliminary
estimates indicate abundance in the New York-New Jersey recovery unit experienced a net
increase of 129 percent between 1989 and 2015. However, the population declined sharply from
a peak of 586 pairs in 2007 and has still not recovered, with only 411 pairs in 2015. In Eastern
Canada, where increases have often been quickly eroded in subsequent years, the population
posted a 25-percent decline between 1989 and 2015.

Productivity goals (criterion 3) specified in the 1996 recovery plan must be revised to
accommodate new information about latitudinal variation in productivity needed to maintain a
stationary population. Population growth, particularly in the three U.S. recovery units, provides
indirect evidence that adequate productivity has occurred in at least some years. However,
overall security of a 2,000 pair population will require long-term maintenance of these revised
recovery-unit-specific productivity goals concurrent with population numbers at or above
abundance goals.

Twenty years of relatively steady population growth, driven by productivity gains, also
evidences the efficacy of the ongoing Atlantic Coast piping plover recovery program. However,
all of the major threats (habitat loss and degradation, predation, human disturbance, and
inadequacy of other (non-ESA) regulatory mechanisms) identified in the 1986 ESA listing and
1996 revised recovery plan remain persistent and pervasive. Severe threats from human
disturbance and predation remain ubiquitous along the Atlantic Coast. Expensive labor-intensive
management to minimize the effects of these continuing threats, as specified in recovery plan
tasks, are implemented every year by a network of dedicated governmental and private
cooperators. Because threats to Atlantic Coast piping plovers persist (and in many cases have
increased since listing), reversal of gains in abundance and productivity would quickly follow
diminishment of current protection efforts.

Finally, two emerging potential threats, wind turbine generators and climate change (especially
sea-level rise) are likely to affect Atlantic Coast piping plovers throughout their life cycle. These
two threats must be evaluated to ascertain their effects on piping plovers and/or their habitat, as
well as the need for specific protections to prevent or mitigate impacts that could otherwise
increase overall risks to the species.

In the 2009 status review, the Service concluded that the Atlantic Coast piping plover remains
vulnerable to low numbers in the Southern and Eastern Canada (and, to a lesser extent, the New

30
York-New Jersey) Recovery Units (USFWS 2009a). Furthermore, the factors that led to the
piping plover’s 1986 listing remain operative rangewide (including in New England), and many
of these threats have increased. Interruption of costly, labor-intensive efforts to manage these
threats would quickly lead to steep population declines.

Nonbreeding Range

Piping plovers spend up to 10 months of their life cycle on their migration and winter grounds,
generally July 15 through as late as May 15. Piping plover migration routes and habitats overlap
breeding and wintering habitats, and, unless banded, migrants passing through a site usually are
indistinguishable from breeding or wintering piping plovers. Coastal migration stopovers by
banded piping plovers from the Great Lakes region have been documented in New Jersey,
Maryland, Virginia, North Carolina, South Carolina, and Georgia (Stucker et al. 2010).
Migrating birds from eastern Canada have been observed in Massachusetts, New Jersey, New
York, and North Carolina (Amirault et al. 2005). Piping plovers banded in the Bahamas have
been sighted during migration in nine Atlantic Coast states and provinces between Florida and
Nova Scotia (Gratto-Trevor pers. comm. 2012a). In general, the distance between stopover
locations and the duration of stopovers throughout the coastal migration range remain poorly
understood (USFWS, 2015).

Review of published records of piping plover sightings throughout North America by Pompei
and Cuthbert (2004) found more than 3,400 fall and spring stopover records at 1,196 sites.
Published reports indicated that piping plovers do not concentrate in large numbers at inland sites
and that they seem to stop opportunistically. In most cases, reports of birds at inland sites were
single individuals.

Piping plovers migrate through and winter in coastal areas of the U.S. from North Carolina to
Texas and in portions of Mexico and the Caribbean. Gratto-Trevor et al. (2009) reported that six
of 259 banded piping plovers observed more than once per winter moved across boundaries of
the seven U.S. regions. This species exhibits a high degree of intra- and inter-annual wintering
site fidelity (Noel and Chandler 2016; Cohen and Gratto-Trevor 2011; Gratto-Trevor et al. 2016;
Drake et al. 2001; Noel et al. 2005; Stucker and Cuthbert 2006). Of 216 birds observed in
different years, only eight changed regions between years, and several of these shifts were
associated with late summer or early spring migration periods (Gratto-Trevor et al. 2009). Local
movements are more common. In South Carolina, Maddock et al. (2009) documented many
cross-inlet movements by wintering banded piping plovers as well as occasional movements of
up to 18 km by approximately 10% of the banded population; larger movements within South
Carolina were seen during fall and spring migration. Similarly, eight banded piping plovers that
were observed in two locations during 2006-2007 surveys in Louisiana and Texas were all in
close proximity to their original location, such as on the bay and ocean side of the same island or
on adjoining islands (Maddock 2008). In Cape Lookout NS, wintering banded birds were
surveyed along Shackleford Banks. Individual birds were always observed in the same general

31
area over multiple seasons, indicating that the wintering birds are very site-specific and return to
the same area in consecutive years (NPS 2003)

Gratto-Trevor et al. (2012) found strong patterns (but no exclusive partitioning) in winter
distribution of uniquely banded piping plovers from four breeding populations (Figure 4).
Resightings of more than 700 uniquely marked birds from 2001 to 2008 were used to analyze
winter distributions along the Atlantic and Gulf Coasts. Plovers from eastern Canada and most
Great Lakes birds wintered from North Carolina to Southwest Florida. However, eastern Canada
birds were more heavily concentrated in North Carolina, while a larger proportion of Great
Lakes piping plovers were found in South Carolina, Georgia, and Florida. This pattern is
consistent with analysis of band sightings of Great Lakes plovers from 1995-2005 by Stucker et
al. (2010). Gratto-Trevor et al. (2012) also found that Northern Great Plains breeding population
were primarily seen farther west and south, especially on the Texas Gulf Coast.

The majority of birds from the Canadian Prairie were observed in Texas (particularly southern
Texas), while individuals from the U.S. Great Plains were more widely distributed on the Gulf
Coast from Texas to Florida. Seventy-nine percent of 57 piping plovers banded in the Bahamas
in 2010 have been reported breeding on the Atlantic Coast; one has been resighted in the
Northern Great Plains (Catlin pers. comm. 2013). Furthermore, consistent with patterns observed
in other parts of the wintering range, a few individuals banded in the Great Lakes and Northern
Great Plains breeding populations have been observed in the Bahamas (Gratto-Trevor pers.
comm. 2012; Catlin pers. comm. 2012a). Collectively, these studies demonstrate an intermediate
level of connectivity between breeding and wintering areas. Specific breeding populations will
be disproportionately affected by habitat and threats occurring where they are most concentrated
in the winter (USFWS 2015).

The findings of Gratto-Trevor et al. (2009; 2012) provide evidence of differences in the
wintering distribution of piping plovers from these four breeding areas. However, the
distribution of birds by breeding origin during migration remains largely unknown. Until
recently, the wintering locations of the U.S. Atlantic Coast breeding population was relatively
unknown, as was the breeding origin of piping plovers wintering on Caribbean islands. A 2010
banding effort in the Bahamas, led by Dr. Cheri Trevor-Gratto, indicated that the majority of
piping plovers wintering in the Bahamas are from the Atlantic breeding population (Gratto-
Trevor et al. 2016; AFWA 2015). A 2014/2015 winter census effort on five Bahamian islands
located 657 piping plovers, 31 of which had bands identifying them as members of the U.S. or
Canadian breeding population. Research efforts indicate that around half of the Atlantic
population of piping plovers winter across the Bahamas for up to ten months each year. The
majority (25%) of the plovers are in just three locations – Andros Island, Joulter Cays and the
Berry Islands (AFWA 2015). In September 2015, the Bahamian government established the
113,920-acre Joulter Cays National Park. This large group of uninhabited islands and intertidal
sand flats will continue to provide important wintering habitat for piping plovers, red knots, and
other shorebirds (Audubon 2015; BNT 2015).

32

Figure 4. (From Gratto-Trevor et al. 2012, reproduced by permission). Four breeding locations
(inset) included in Gratto-Trevor et al.’s (2012) study of wintering piping plovers in North
America, 1998–2008, including eastern Canada (white circle with a large black spot in the
center), Great Lakes (gray circle), Great Plains (white circle), and Prairie Canada (black circle).
The North American wintering area is expanded to the right, divided into different wintering
regions. The size of the adjacent circles relative to others represents the percentage of individual
piping plovers from a specific breeding area reported in each wintering region up to December
2008.

Five rangewide mid-winter (late January to early February) IPPCs, conducted at five-year
intervals starting in 1991, are summarized in Table 4. Total numbers have fluctuated over time,
with some areas experiencing increases and others decreases. Regional and local fluctuations
may reflect the quantity and quality of suitable foraging and roosting habitat, which vary over
time in response to natural coastal formation processes as well as anthropogenic habitat changes

33
(e.g., inlet relocation, dredging of shoals and spits). Fluctuations may also represent localized
weather conditions (especially wind) during surveys, or unequal survey coverage. Changes in
wintering numbers may also be influenced by growth or decline in the particular breeding
populations that concentrate their wintering distribution in a given area.

Mid-winter surveys may substantially underestimate the abundance of nonbreeding piping
plovers using a site or region during other months. In late September 2007, 104 piping plovers
were counted at the south end of Ocracoke Island, North Carolina (NPS 2007), where none were
seen during the 2006 International Piping Plover January Winter Census (Elliott-Smith et al.
2009). Noel et al. (2007) observed up to 100 piping plovers during peak migration at Little St.
Simons Island, Georgia, where approximately 40 piping plovers wintered in 2003–2005.
Differences among fall, winter, and spring counts in South Carolina were less pronounced, but
inter-year fluctuations (e.g., 108 piping plovers in spring 2007 versus 174 piping plovers in
spring 2008) at 28 sites were striking (Maddock et al. 2009). Even as far south as the Florida
Panhandle, monthly counts at Phipps Preserve in Franklin County ranged from a mid-winter low
of four piping plovers in December 2006 to peak counts of 47 in October 2006 and March 2007
(Smith 2007).

Local movements of nonbreeding piping plovers may also affect abundance estimates. At
Deveaux Bank, one of South Carolina’s most important piping plover sites, five counts at
approximately 10-day intervals between August 27 and October 7, 2006, oscillated from 28 to 14
to 29 to 18 to 26 (Maddock et al. 2009). Noel and Chandler (2008) detected banded Great Lakes
piping plovers known to be wintering on their Georgia study site in 73.8 + 8.1 % of surveys over
three years.

Abundance estimates for nonbreeding piping plovers may also be affected by the number of
surveyor visits to the site. Preliminary analysis of detection rates by Maddock et al. (2009)
found 87% detection during the mid-winter period on core sites surveyed three times a month
during fall and spring and one time per month during winter, compared with 42% detection on
sites surveyed three times per year (Cohen 2009 pers. communication).

34
Table 4. Results of the 1991, 1996, 2001, 2006, and 2011 International Piping Plover Winter
Censuses (Haig and Plissner 1993; Plissner and Haig 2000; Ferland and Haig 2002; Haig et al.
2005; Elliott-Smith et al. 2009; Elliott-Smith et al. 2015).

Location 1991 1996 2001 2006 2011
Virginia not surveyed
(ns) ns ns 1 1
North Carolina 20 50 87 84 43
South Carolina 51 78 78 100 86
Georgia 37 124 111 212 63
Florida 551 375 416 454 306
-Atlantic 70 31 111 133 83
-Gulf 481 344 305 321 223
Alabama 12 31 30 29 38
Mississippi 59 27 18 78 88
Louisiana 750 398 511 226 86
Texas 1,904 1,333 1,042 2,090 2,145
Puerto Rico 0 0 6 2 2
U.S. Total 3,384 2,416 2,299 3,357 2,858
Mexico 27 16 ns 76 30
Bahamas 29 17 35 417 1,066
Cuba 11 66 55 89 19
Other Caribbean
Islands 0 0 0 28 ns
GRAND
TOTAL 3,451 2,515 2,389 3,884 3,973
Percent of Total
International
Piping Plover
Breeding
Census
62.9% 42.4% 40.2% 48.2% 69.4%

35
The 2004 and 2005 hurricane seasons affected a substantial amount of habitat along the Gulf
Coast. Habitats such as those along Gulf Islands NS have benefited from increased washover
events, which created optimal habitat conditions for piping plovers. Conversely, hard shoreline
structures put into place following storms throughout the species range to prevent such shoreline
migration prevent habitat creation (see Factors Affecting Species Environment within the Action
Area).

2.1.5. Analysis of the Species Likely to be Affected

The three recovery plans stated that shoreline development throughout the wintering range poses
a threat to all populations of piping plovers. The plans further stated that beach maintenance and
nourishment, inlet dredging, and artificial structures, such as jetties, groins, and revetments,
could eliminate wintering areas and alter sedimentation patterns leading to the loss of nearby
habitat. Unregulated motorized and pedestrian recreational use, inlet and shoreline stabilization
projects, beach maintenance and nourishment, and pollution affect most winter and migration
areas. Data from studies at Hilton Head, Kiawah Island, and other locations in South Carolina
and Georgia demonstrate that impacts from poor winter habitat conditions can be seen the
following year on the breeding grounds (Saunders et al. 2014; Gibson et al. 2016). Piping
plovers wintering at areas with fewer anthropogenic disturbances had higher survival,
recruitment, and population growth rates than areas with greater disturbance.

Important components of ecologically sound barrier beach management include perpetuation of
natural dynamic coastal formation processes. Structural development along the shoreline or
manipulation of natural inlets upsets the dynamic processes and results in habitat loss or
degradation (Melvin et al. 1991). Throughout the range of migrating and wintering piping
plovers, inlet and shoreline stabilization, inlet dredging, beach maintenance and nourishment
activities, and seawall installations continue to constrain natural coastal processes. Dredging of
inlets can affect spit formation adjacent to inlets and directly remove or affect ebb and flood tidal
shoal formation. Jetties, which stabilize an island, cause island widening and subsequent growth
of vegetation on inlet shores. Seawalls restrict natural island movement and exacerbate erosion.
As discussed in more detail below, all these efforts result in loss of piping plover habitat.
Construction of these projects during months when piping plovers are present also causes
disturbance that disrupts the birds’ foraging efficiency and hinders their ability to build fat
reserves over the winter and in preparation for migration, as well as their recuperation from
migratory flights. In addition, up to 24 shorebird species migrate or winter along the Atlantic
Coast and almost 40 species of shorebirds are present during migration and wintering periods in
the Gulf of Mexico region (Helmers 1992). Continual degradation and loss of habitats used by
wintering and migrating shorebirds may cause an increase in intra-specific and inter-specific
competition for remaining food supplies and roosting habitats. The shrinking extent of shoreline
that supports natural coastal formation processes concentrates foraging and roosting
opportunities for all shorebird species, and forces some individuals into suboptimal habitats.

36
Thus, intra- and inter-specific competition most likely exacerbates threats from habitat loss and
degradation.

Loss, modification, and degradation of habitat

The wide, flat, sparsely vegetated barrier beaches, spits, sandbars, and bayside flats preferred by
piping plovers in the U.S. are formed and maintained by natural forces and are thus susceptible
to degradation caused by development and shoreline stabilization efforts. As described below,
barrier island and beachfront development, inlet and shoreline stabilization, inlet dredging, beach
maintenance and nourishment activities, seawall installations, and mechanical beach grooming
continue to alter natural coastal processes throughout the range of migrating and wintering
piping plovers. Jetties stabilize inlets and cause island widening and subsequent vegetation
growth on the updrift inlet shores; they also cause island narrowing and/or erosion on the
downdrift inlet shores. Seawalls and revetments restrict natural island movement and exacerbate
erosion. Although dredge and fill projects that place sand on beaches and dunes may restore lost
or degraded habitat in some areas, in other areas these projects may degrade habitat quality by
altering the natural sediment composition, depressing the invertebrate prey base, hindering
habitat migration with sea level rise, and replacing the natural habitats of the dune-beach-
nearshore system with artificial geomorphology. Construction of any of these projects during
months when piping plovers are present also causes disturbance that disrupts the birds’ foraging
and roosting behaviors. These threats are exacerbated by accelerating sea level rise, which
increases erosion and habitat loss where existing development and hardened stabilization
structures prevent the natural migration of the beach and/or barrier island.

Development and Construction

Development and associated construction threaten the piping plover in its migration and
wintering range by degrading, fragmenting, and eliminating habitat. Constructing buildings and
infrastructure adjacent to the beach can eliminate roosting and loafing habitat within the
development’s footprint and degrade adjacent habitat by replacing sparsely vegetated dunes or
back-barrier beach areas with landscaping, pools, fences, etc. In addition, bayside development
can replace foraging habitat with finger canals, bulkheads, docks and lawns. High-value plover
habitat becomes fragmented as lots are developed or coastal roads are built between oceanside
and bayside habitats. Development activities can include lowering or removing natural dunes to
improve views or grade building lots, planting vegetation to stabilize dunes, and erecting sand
fencing to establish or stabilize continuous dunes in developed areas; these activities can further
degrade, fragment, and eliminate sparsely vegetated and unvegetated habitats used by the piping
plover and other wildlife. Development and construction of other infrastructure in close
proximity to barrier beaches often creates economic and social incentives for subsequent
shoreline stabilization projects, such as shoreline hardening and beach nourishment.

37
At present, there are approximately 2,119 miles of sandy beaches within the U.S. continental
wintering range of the piping plover (Table 5). Approximately 40% (856 miles) of these sandy
beaches are developed, with mainland Mississippi (80%), Florida (57%), Alabama (55%), South
Carolina (51%), and North Carolina (49%) comprising the most developed coasts, and
Mississippi barrier islands (0%), Louisiana (6%), Texas (14%) and Georgia (17%) the least
developed (Rice 2012b). As discussed further below, developed beaches are highly vulnerable
to further habitat loss because they cannot migrate in response to sea level rise.

Several studies highlight concerns about adverse effects of development and coastline
stabilization on the quantity and quality of habitat for migrating and wintering piping plovers and
other shorebirds. For example, Zdravkovic and Durkin (2011) observed fewer plovers on the
developed portions of the Laguna and Gulf beach sides of South Padre Island than on
undeveloped portions during both migratory and wintering surveys. Drake et al. (2001) observed
that radio-tagged piping plovers overwintering along the southern Laguna Madre of Texas
seldom used tidal flats adjacent to developed areas (five of 1,371 relocations of radio-marked
individuals), suggesting that development and associated anthropogenic disturbances influence
piping plover habitat use. Detections of piping plovers during repeated surveys of the upper
Texas coast in 2008 were low in areas with significant beach development (Arvin 2009).

The development of bayside or estuarine shorelines with finger canals and their associated
bulkheads, docks, buildings, and landscaping leads to direct loss and degradation of plover
habitat. Finger canals are channels cut into a barrier island or peninsula from the soundside to
increase the number of waterfront residential lots. Finger canals can lead to water pollution, fish
kills, loss of aquatic nurseries, saltwater intrusion of groundwater, disruption of surface flows,
island breaching due to the funneling of storm surge, and a perpetual need for dredging and
disposal of dredged material in order to keep the canals navigable for property owners (Morris et
al. 1978; Bush et al. 1996).

Rice (2012b) has identified over 900 miles (43%) of sandy beaches in the wintering range that
are currently “preserved” through public ownership, ownership by non-governmental
conservation organizations, or conservation easements (Table 5). These beaches may be subject
to some erosion as they migrate in response to sea level rise or if sediment is removed from the
coastal system, and they are vulnerable to recreational disturbance. However, they are the areas
most likely to maintain the geomorphic characteristics of suitable piping plover habitat.

38
Table 5. The lengths and percentages of sandy oceanfront beach in each state that are
developed, undeveloped, and preserved as of December 2011 (Rice 2012b).
State
Approximate
Shoreline
Beach Length
(miles)
Approximate
Miles of Beach
Developed
(percent of total
shoreline length)
Approximate
Miles of Beach
Undeveloped
(percent of total
shoreline length)a
Approximate
Miles of Beach
Preserved
(percent of total
shoreline length)b
North Carolina 326 159
(49%)
167
(51%)
178.7
(55%)
South Carolina 182 93
(51%)
89
(49%)
84
(46%)
Georgia 90 15
(17%)
75
(83%)
68.6
(76%)
Florida 809 459
(57%)
351
(43%)
297.5
(37%)
-Atlantic 372 236
(63%)
136
(37%)
132.4
(36%)
-Gulf 437 223
(51%)
215
(49%)
168.0.
(38%)
Alabama 46 25
(55%)
21
(45%)
11.2
(24%)
Mississippi barrier
island coast 27 0
(0%)
27
(100%)
27
(100%)
Mississippi mainland
coast 51c 41
(80%)
10
(20%)
12.6
(25%)
Louisiana 218 13
(6%)
205
(94%)
66.3
(30%)
Texas 370 51
(14%)
319
(86%)
152.7
(41%)
TOTAL 2,119 856
(40%)
1,264
(60%)
901.5
(43%)
a Beaches classified as “undeveloped” occasionally include a few scattered structures.
b Preserved beaches include public ownership, ownership by non-governmental conservation
organizations, and conservation easements. The miles of shoreline that have been preserved generally
overlap with the miles of undeveloped beach but may also include some areas (e.g., in North Carolina)
that have been developed with recreational facilities or by private inholdings.
c The mainland Mississippi coast along Mississippi Sound includes 51.3 miles of sandy beach as of 2010-
2011, out of approximately 80.7 total shoreline miles (the remaining portion is non-sandy, either marsh
or armored coastline with no sand). See Rice 2012b for details.

39
In summary, approximately 40% of the sandy beach shoreline in the migration and wintering
range is already developed, while 43% are largely preserved. This means, however, that the
remaining 17% of shoreline habitat (that which is currently undeveloped but not preserved) is
susceptible to future loss to development and the attendant threats from shoreline stabilization
activities and sea level rise.

Dredging and Sand Mining

The dredging and mining of sediment from inlet complexes threatens the piping plover on its
wintering grounds through habitat loss and degradation. The maintenance of navigation
channels by dredging, especially deep shipping channels such as those in Alabama and
Mississippi can significantly alter the natural coastal processes on inlet shorelines of nearby
barrier islands, as described by Otvos (2006), Morton (2008), Otvos and Carter (2008), and
Stockdon et al. (2010). Cialone and Stauble (1998) describe the impacts of mining ebb shoals
within inlets as a source of beach fill material at eight locations and provide a recommended
monitoring protocol for future mining events.

Forty-four percent of the tidal inlets within the U.S. wintering range of the piping plover have
been or continue to be dredged, primarily for navigational purposes (Table 6). States where
more than two-thirds of inlets have been dredged include Alabama (three of four), Mississippi
(four of six), North Carolina (16 of 20), and Texas (13 of 18), and 16 of 21 along the Florida
Atlantic coast. The dredging of navigation channels or relocation of inlet channels for erosion-
control purposes contributes to the cumulative effects of inlet habitat modification by removing
or redistributing the local and regional sediment supply; the maintenance dredging of deep
shipping channels can convert a natural inlet that normally bypasses sediment from one shoreline
to the other into a sediment sink, where sediment no longer bypasses the inlet.

40
Table 6. The number of open tidal inlets, inlet modifications, and artificially closed inlets
in each state as of December 2011. Numbers for North Carolina are as of September 2016
(USFWS 2012; Rice 2012a; 2016).

State
Existing Inlets
Artificially
closed Number
of Inlets
Total
Number of
Modified
Inlets
Habitat Modification Type
structuresa dredged relocated mined artificially
opened
North
Carolina 20 17 (85%) 7 16 5 10 4 13
South
Carolina 47 21 (45%) 17 11 2 3 0 1
Georgia 23 6 (26%) 5 3 0 1 0 0
Florida
-Atlantic 21 19 (90%) 19 16 0 3 10 0
Florida
-Gulf 48 24 (50%) 20 22 0 6 7 1
Alabama 4 4 (100%) 4 3 0 0 0 2
Mississippi 6 4 (67%) 0 4 0 0 0 0
Louisiana 34 10 (29%) 7 9 1 2 0 46
Texas 18 14 (78%) 10 13 2 1 11 3
TOTAL 221 119
(54%)
89
(40%)
97
(44%)
8
(4%)
20
(9%)
30
(14%)
64
(N/A)
a Structures include jetties, terminal groins, groin fields, rock or sandbag revetments, seawalls,
and offshore breakwaters.
Among the dredged inlets identified in Rice (2012a), dredging efforts began as early as the 1800s
and continue to the present, generating long-term and even permanent effects on inlet habitat; at
least 11 inlets were first dredged in the 19th century, with the Cape Fear River (North Carolina)
being dredged as early as 1826 and Mobile Pass (Alabama) in 1857. Dredging can occur on an
annual basis or every two to three years, resulting in continual perturbations and modifications to
inlet and adjacent shoreline habitat. The volumes of sediment removed can be major, with 2.2
million cubic yards (mcy) of sediment removed on average every 1.9 years from the Galveston
Bay Entrance (Texas) and 3.6 mcy of sediment removed from Sabine Pass (Texas) on average
every 1.4 years (USACE 1992).

41
As sand sources for beach nourishment projects have become more limited, the mining of ebb
tidal shoals for sediment has increased (Cialone and Stauble 1998). This is a problem because
exposed ebb and flood tidal shoals and sandbars are prime roosting and foraging habitats for
piping plovers. In general, such areas are only accessible by boat; and as a result, they tend to
receive less human recreational use than nearby mainland beaches. Rice (2012a) found that the
ebb shoal complexes of at least 20 inlets within the wintering range of the piping plover have
been mined for beach fill. Ebb shoals are especially important because they act as “sand
bridges” that connect beaches and islands by transporting sediment via longshore transport from
one side (updrift) to the other (downdrift) side of an inlet. The mining of sediment from these
shoals upsets the inlet system equilibrium and can lead to increased erosion of the adjacent inlet
shorelines (Cialone and Stauble 1998). Rice (2012a) noted that this mining of material from
inlet shoals for use as beach fill is not equivalent to the natural sediment bypassing that occurs at
unmodified inlets for several reasons, most notably for the massive volumes involved that are
“transported” virtually instantaneously instead of gradually and continuously and for the
placement of the material outside of the immediate inlet vicinity, where it would naturally
bypass. The mining of inlet shoals can remove massive amounts of sediment, with 1.98 mcy
mined for beach fill from Longboat Pass (Florida) in 1998, 1.7 mcy from Shallotte Inlet (North
Carolina) in 2001 and 1.6 mcy from Redfish Pass (Florida) in 1988 (Cialone and Stauble 1998;
USACE 2004). Cialone and Stauble (1998) found that monitoring of the impacts of ebb shoal
mining has been insufficient, and in one case the mining pit was only 66% recovered after five
years; they conclude that the larger the volume of sediment mined from the shoals, the larger the
perturbation to the system and the longer the recovery period.

Information is limited on the effects to piping plover habitat of the deposition of dredged
material, and the available information is inconsistent. Drake et al. (2001) concluded that the
conversion of bayshore tidal flats of southern Texas mainland to dredged material impoundments
results in a net loss of habitat for wintering piping plovers because such impoundments
eventually convert to upland habitat. Although Zdravkovic and Durkin (2011) found 200 piping
plovers on the Mansfield Channel dredge material islands during a survey in late 2009, none
were counted there in early 2011. By contrast, most of the sound islands where Cohen et al.
(2008) found foraging piping plovers at Oregon Inlet, North Carolina were created by the U.S.
Army Corps of Engineers from dredged material. Another example is Pelican Island, in Corpus
Christi Bay, Texas, where dredged material is consistently used by piping plovers (Cobb pers.
comm. 2012a). Research is needed to understand why piping plovers use some dredge material
islands, but are not regularly found using many others.

In summary, the removal of sediment from inlet complexes via dredging and sand mining for
beach fill has modified nearly half of the tidal inlets within the continental wintering range of the
piping plover, leading to habitat loss and degradation. Many of these inlet habitat modifications
have become permanent, existing for over 100 years. The expansion of several harbors and ports
to accommodate deeper draft ships poses an increasing threat as more sediment is removed from
the inlet system, causing larger perturbations and longer recovery times; maintenance dredging

42
conducted annually or every few years may prevent full recovery of the inlet system. Sand
removal or sediment starvation of shoals, sandbars and adjacent shoreline habitat has resulted in
habitat loss and degradation, which may reduce the system’s ability to maintain a full suite of
inlet habitats as sea level continues to rise at an accelerating rate. Rice (2012a) noted that the
adverse impacts of this threat to piping plovers may be mitigated, however, by eliminating
dredging and mining activities in inlet complexes with high habitat value, extending the interval
between dredging cycles, discharging dredged material in nearshore downdrift waters so that it
can accrete more naturally than when placed on the subaerial beach, and designing dredged
material islands to mimic natural shoals and flats.

Inlet Stabilization and Relocation

Many navigable tidal inlets along the Atlantic and Gulf coasts are stabilized with hard structures.
A description of the different types of stabilization structures typically constructed at or adjacent
to inlets – jetties, terminal groins, groins, seawalls, breakwaters and revetments – can be found in
the Manual for Coastal Hazard Mitigation (Herrington 2003) and in Living by the Rules of the
Sea (Bush et al. 1996).

The adverse direct and indirect impacts of hard stabilization structures at inlets and inlet
relocations can be significant. The impacts of jetties on inlet and adjacent shoreline habitat have
been described by Cleary and Marden (1999), Bush et al. (1996), Wamsley and Kraus (2005),
USFWS (2009a), Thomas et al. (2011), and many others. The relocation of inlets or the creation
of new inlets often leads to immediate widening of the new inlet and loss of adjacent habitat,
among other impacts, as described by Mason and Sorenson (1971), Masterson et al. (1973),
USACE (1992), Cleary and Marden (1999), Cleary and Fitzgerald (2003), Wamsley and Kraus
(2005), and Kraus (2007).

Rice (2012a) found that, as of 2011, an estimated 54% of 221 mainland or barrier island tidal
inlets in the U.S continental wintering range of the piping plover had been modified by some
form of hardened structure, dredging, relocation, mining, or artificial opening or closure (Table
6). On the Atlantic Coast, 43% of the inlets have been stabilized with hard structures, whereas
37% were stabilized on the Gulf Coast. The Atlantic coast of Florida has 17 stabilized inlets
adjacent to each other, extending between the St. John’s River in Duval County and Norris Cut
in Miami-Dade County, a distance of 341 miles. A shorebird would have to fly nearly 344 miles
between unstabilized inlets along this stretch of coast.

The state with the highest proportion of natural, unmodified inlets is Georgia (74%). The highest
number of adjacent unmodified, natural inlets is the 15 inlets found in Georgia between Little
Tybee Slough at Little Tybee Island Nature Preserve and the entrance to Altamaha Sound at the
south end of Wolf Island National Wildlife Refuge, a distance of approximately 54 miles.
Another relatively long stretch of adjacent unstabilized inlets is in Louisiana, where 17 inlets
between a complex of breaches on the West Belle Pass barrier headland (in Lafourche Parish)

43
and Beach Prong (near the western boundary of the state Rockefeller Wildlife Refuge) have no
stabilization structures; one of these inlets (the Freshwater Bayou Canal), however, is dredged
(Rice 2012a).

Unstabilized inlets naturally migrate, reforming important habitat components over time,
particularly during a period of rising sea level. Inlet stabilization with rock jetties and
revetments alters the dynamics of longshore sediment transport and the natural movement and
formation of inlet habitats such as shoals, unvegetated spits and flats. Once a barrier island
becomes “stabilized” with hard structures at inlets, natural overwash and beach dynamics are
restricted, allowing encroachment of new vegetation on the bayside that replaces the unvegetated
(open) foraging and roosting habitats that plovers prefer. Rice (2012a) found that 40% (89 out of
221) of the inlets open in 2011 have been stabilized in some way, contributing to habitat loss and
degradation throughout the wintering range. Accelerated erosion may compound future habitat
loss, depending on the degree of sea level rise (Titus et al. 2009). Due to the complexity of
impacts associated with projects such as jetties and groins, Harrington (2008) noted the need for
a better understanding of potential effects of inlet-related projects, such as jetties, on bird
habitats.

Relocation of tidal inlets also can cause loss and/or degradation of piping plover habitat.
Although less permanent than construction of hard structures, the effects of inlet relocation can
persist for years. For example, December-January surveys documented a continuing decline in
wintering plover numbers from 20 birds pre-project (2005-2006) to three birds during the 2009 -
2011 seasons (SCDNR 2011). The subsequent decline in the wintering population on Kiawah is
strongly correlated with the decline in polychaete worm densities, suggesting that plovers may
have emigrated to other sites as foraging opportunities in these habitats became less profitable
(SCDNR 2011). At least eight inlets in the migration and wintering range have been relocated; a
new inlet was cut and the old inlet was closed with fill. In other cases, inlets have been relocated
without the old channels being artificially filled (Table 6).

The artificial opening and closing of inlets typically creates very different habitats from those
found at inlets that open or close naturally (Rice 2012a). Rice (2012a) found that 30 inlets have
been artificially created within the migration and wintering range of the piping plover, including
10 of the 21 inlets along the eastern Florida coast (Table 6). These artificially created inlets tend
to need hard structures to remain open or stable, with 20 of the 30 (67%) of them having hard
structures at present. An even higher number of inlets (64) have been artificially closed, the
majority in Louisiana (Table 6). One inlet in Texas was closed as part of the Ixtoc oil spill
response efforts in 1979 and 32 were closed as part of Deepwater Horizon oil spill response
efforts in 2010-2011. Of the latter, 29 were in Louisiana, two in Alabama and one in Florida.
To date only one of these inlets, West (Little Lagoon) Pass in Gulf Shores, Alabama, has been
reopened, and the rest remain closed with no plans to reopen any of those identified by Rice
(2012a). Most other artificial inlet closures in Louisiana are part of barrier island restoration
projects, because much of that state’s barrier islands are disintegrating (Otvos 2006; Morton

44
2008; Otvos and Carter 2008). Inlets closed during coastal restoration projects in Louisiana are
purposefully designed to approximate low, wide naturally closed inlets and to allow overwash in
the future. By contrast, most artificially closed inlets have higher elevations and tend to have a
constructed berm and dune system. Overwash may occur periodically at a naturally closed inlet
but is prevented at an artificially closed inlet by the constructed dune ridge, hard structures, or
sandbags (Rice 2012a).

The construction of jetties, groins, seawalls and revetments at inlets leads to habitat loss and both
direct and indirect impacts to adjacent shorelines. Rice (2012a) found that these structures result
in long-term effects, with at least 13 inlets across six of the eight states having hard structures
initially constructed in the 19th century. The cumulative effects are ongoing and increasing in
intensity, with hard structures built as recently as 2011 and others proposed for 2012. With sea
level rising and global climate change altering storm dynamics, pressure to modify the remaining
half of sandy tidal inlets in the range is likely to increase, notwithstanding that this would be
counterproductive to the climate change adaptation strategies recommended by the USFWS
(2010d), CCSP (2009), Williams (2013), Pilkey and Young (2009), and many others.

Groins

Groins pose an ongoing threat to piping plover beach habitat within the continental wintering
range. Groins are hard structures built perpendicular to the shoreline (sometimes in a T-shape),
designed to trap sediment traveling in the littoral drift and to slow erosion on a particular stretch
of beach or near an inlet. “Leaky” groins, also known as permeable or porous groins, are low-
crested structures built like typical groins but which allow some fraction of the littoral drift or
longshore sediment transport to pass through the groin. They have been used as terminal groins
near inlets or to hold beach fill in place for longer durations. Although groins can be individual
structures, they are often clustered along the shoreline in “groin fields.” Because they
intentionally act as barriers to longshore sand transport, groins cause downdrift erosion, which
degrades and fragments sandy beach habitat for the piping plover and other wildlife. The
resulting beach typically becomes scalloped in shape, thereby fragmenting plover habitat over
time.

Groins and groin fields are found throughout the southeastern Atlantic and Gulf Coasts and are
present at 28 of 221 sandy tidal inlets (Rice 2012a). Leaky terminal groins have been installed at
the south end of Amelia Island, Florida, the west end of Tybee Island, Georgia, and the north end
of Hilton Head Island, South Carolina. Permeable or leaky groins have also been constructed on
the beaches of Longboat Key and Naples, Florida, and terminal groins were approved in 2011 for
use in up to four inlet locations in North Carolina (reversing a nearly 30-year prohibition on hard
stabilization structures in that state).

Although most groins were in place before the piping plover’s 1986 ESA listing, new groins
continue to be installed, perpetuating the threat to migrating and wintering piping plovers. Two

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groins were built in South Carolina between 2006 and 2010, bringing the statewide total to 165
oceanfront groins (SC DHEC 2010). Eleven new groins were built in Florida between 2000 and
2009. The East Pass Navigation Project in Okaloosa County, Florida (USFWS 2009c) illustrates
the negative impacts to plover habitat that can be associated with groins, which are often built as
one component of a much larger shoreline or inlet stabilization project. The East Pass
Navigation Project includes two converging jetties, one with a groin at the end, with dredged
material placed on either side to stabilize the jetties; minimal piping plover foraging habitat
remains due to changed inlet morphology. As sea level rises at an accelerating rate, the threat of
habitat loss, fragmentation and degradation from groins and groin fields may increase as
communities and beachfront property owners seek additional ways to protect infrastructure and
property.

Seawalls and Revetments

Seawalls and revetments are hard vertical structures built parallel to the beach in front of
buildings, roads, and other facilities. Although they are intended to protect human infrastructure
from erosion, these armoring structures often accelerate erosion by causing scouring both in front
of and downdrift from the structure, which can eliminate intertidal plover foraging and adjacent
roosting habitat. Physical characteristics that determine microhabitats and biological
communities can be altered after installation of a seawall or revetment, thereby depleting or
changing composition of benthic communities that serve as the prey base for piping plovers.
Dugan and Hubbard (2006) found in a California study that intertidal zones were narrower and
fewer in the presence of armoring, armored beaches had significantly less macrophyte wrack,
and shorebirds responded with significantly lower abundance (more than three times lower) and
species richness (2.3 times lower) than on adjacent unarmored beaches. As sea level rises,
seawalls will prevent the coastline from moving inland, causing loss of intertidal foraging habitat
(Galbraith et al. 2002; Defeo et al. 2009). Geotubes (long cylindrical bags made of high-strength
permeable fabric and filled with sand) are less permanent alternatives, but they prevent overwash
and thus the natural production of sparsely vegetated habitat.

Rice (2012b) found that at least 230 miles of beach habitat has been armored with hard erosion-
control structures. Data were not available for all areas, so this number is a minimum estimate of
the length of habitat that has been directly modified by armoring. Out of 221 inlets surveyed, 89
were stabilized with some form of hard structure, of which 24 had revetments or seawalls along
their shorelines. The Texas coast is armored with nearly 37 miles of seawalls, bulkheads and
revetments, the mainland Mississippi coast has over 45 miles of armoring, the Florida Atlantic
coast has at least 58 miles, and the Florida Gulf coast over 59 miles (Rice 2012b). Shoreline
armoring has modified plover beachfront habitat in all states, but Alabama (4.7 miles), Georgia
(10.5 miles) and Louisiana (15.9 miles) have the fewest miles of armored beaches.

Although North Carolina has prohibited the use of hard erosion-control structures or armoring
since 1985 the “temporary” installation of sandbag revetments is allowed. As a result the precise

46
length of armored sandy beaches in North Carolina is unknown, but at least 350 sandbag
revetments have been constructed (Rice 2012b). South Carolina also limits the installation of
some types of new armoring but already has 24 miles (27% of the developed shoreline or 13% of
the entire shoreline) armored with some form of shore-parallel erosion-control structure (SC
DHEC 2010).

The repair of existing armoring structures and installation of new structures continues to degrade,
destroy, and fragment beachfront plover habitat throughout its continental wintering range. As
sea level rises at an accelerating rate, the threat of habitat loss, fragmentation and degradation
from hard erosion-control structures is likely to increase as communities and property owners
seek to protect their beachfront development. As coastal roads become threatened by rising sea
level and increasing storm damage, additional lengths of beachfront habitat may be modified by
riprap, revetments, and seawalls.

Sand Placement Projects

Sand placement projects threaten the piping plover and its habitat by altering the natural,
dynamic coastal processes that create and maintain beach strand and bayside habitats, including
the habitat components that piping plovers rely upon. Although specific impacts vary depending
on a range of factors, so-called “soft stabilization” projects may directly degrade or destroy
roosting and foraging habitat in several ways. Beach habitat may be converted to an artificial
berm that is densely planted in grass, which can in turn reduce the availability of roosting habitat.
Over time, if the beach narrows due to erosion, additional roosting habitat between the berm and
the water can be lost. Berms can also prevent or reduce the natural overwash that creates and
maintains sparsely vegetated roosting habitats. The growth of vegetation resulting from
impeding the natural overwash can also reduce the availability of bayside intertidal feeding
habitats.

Overwash is an essential process, necessary to maintain the integrity of many barrier islands and
to create new habitat (Donnelly et al. 2006). In a study on the Outer Banks of North Carolina,
Smith et al. (2008) found that human “modifications to the barrier island, such as construction of
barrier dune ridges, planting of stabilizing vegetation, and urban development, can curtail or
even eliminate the natural, self-sustaining processes of overwash and inlet dynamics.” They also
found that such modifications led to island narrowing from both oceanside and bayside erosion.
Lott et al. (2009b) found a strong negative correlation between ocean shoreline sand placement
projects and the presence of piping and snowy plovers in the Panhandle and southwest Gulf
Coast regions of Florida.

Sand placement projects threaten migration and wintering habitat of the piping plover in every
state throughout the range (Rice 2012b, Table 7). At least 684.8 miles (32%) of sandy beach
habitat in the continental wintering range of the piping plover have received artificial sand
placement via dredge disposal activities, beach nourishment or restoration, dune restoration,

47
emergency berms, inlet bypassing, inlet closure and relocation, and road reconstruction projects.
In most areas, sand placement projects are in developed areas or adjacent to shoreline or inlet
hard stabilization structures in order to address erosion, reduce storm damages, or ameliorate
sediment deficits caused by inlet dredging and stabilization activities.

The beaches along the mainland coast of Mississippi are the most modified by sand placement
activities with at least 85% affected (Table 7). Of the oceanfront beaches, the Atlantic coast of
Florida has had the highest proportion (at least 51%) of beaches modified by sand placement
activities. Approximately 47% of Florida’s sandy beach coastline has received sand placement
of some type, with many areas receiving fill multiple times from dredge disposal, emergency
berms, beach nourishment, dune restoration and other modifications (Rice 2012b).

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Table 7. Approximate shoreline miles of sandy beach that have been modified by sand
placement activities for each state in the U.S. continental wintering range of the piping
plover as of December 2011. These totals are minimum numbers, given missing data for
some areas (Rice 2012b; USFWS 2012).

State Known Approximate Miles of
Beach Receiving Sand
Proportion of Modified
Sandy Beach Shoreline
North Carolina 91.3 28%
South Carolina 67.6 37%
Georgia 5.5 6%
Florida Atlantic coast 189.7 51%
Florida Gulf coast 189.9 43%
Alabama 7.5 16%
Mississippi barrier island
coast 1.1 4%
Mississippi mainland coast 43.5 85%
Louisiana 60.4 28%
Texas 28.3 8%
TOTAL 684.8+ 32%

In Louisiana, the sustainability of the coastal ecosystem is threatened by the inability of the
barrier islands to maintain geomorphologic functionality. The state’s coastal systems are starved
for sediment sources (USACE 2010). Consequently, most of the planned sediment placement
projects in Louisiana are conducted as environmental restoration projects by various federal and
state agencies because without the sediment many areas would erode below sea level. Several
Louisiana Coastal Wetland Planning, Protection, and Restoration Act projects have been
constructed on portions of undeveloped islands within the Terrebonne Basin to restore and
maintain the diverse functions of those barrier island habitats (USFWS 2010b). Altogether over
60 miles of sandy beaches have been modified with sand placement projects in Louisiana, both
through restoration projects and in response to the Deepwater Horizon oil spill (Rice 2012b).

Both the number and the size of sand projects along the Atlantic and Gulf coasts are increasing
(Trembanis et al. 1999), and these projects are increasingly being chosen as a means to combat
sea level rise and related beach erosion problems (Klein et al. 2001). Lott et al. (2009a)
documented an increasing trend in sand placement events in Florida (Figure 5). In northwest
Florida, the USFWS consulted on first-time sand placement projects along 46 miles of shoreline
in 2007-2008. Much of this work was authorized on public lands (Gulf Islands National
Seashore, portions of St. Joseph State Park, and at Eglin Air Force Base). Throughout the plover

49
migration and wintering range, the number of sand placement events has increased every decade
for which records are available, with at least 710 occurring between 1939 and 2007, and more
than 75% occurring since 1980 (Trembanis et al. 1999). The cumulative volume of sand placed
on East Coast beaches has risen exponentially since the 1920s (Trembanis et al. 1999). As a
result, sand placement projects increasingly pose threats to plover habitat. As of 2011, at least
32% (~ 685 miles) of the sandy beaches in the continental wintering range have had one or more
sand placement projects.

Loss of Macroinvertebrate Prey Base due to Shoreline Stabilization

Wintering and migrating piping plovers depend on the availability and abundance of
macroinvertebrates as an important food item. Studies of invertebrate communities have found
that communities are richer (greater total abundance and biomass) on protected (bay or lagoon)
intertidal shorelines than on exposed ocean beach shorelines (Cohen et al. 2006; Defeo and
McLachlan 2011). Polychaete worms comprise the majority of the shorebird diet (Tsipoura and
Burger 1999; Verkuil et al. 2006); and of the piping plover diet in particular (Hoopes 1993;
Nicholls 1989; Zonick and Ryan 1996).

Figure 5. Number of sand placement events per decade in Florida between 1959-1999, and
2000-2006 (from Lott et al. 2009b).

The quality and quantity of the macroinvertebrate prey base is threatened by shoreline
stabilization activities, including the approximately 685 miles of beaches that have received sand
placement of various types. The addition of dredged sediment can temporarily affect the benthic
fauna of intertidal systems. Invertebrates may be crushed or buried during project construction.

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Although some benthic species can burrow through a thin layer of additional sediment (38-89 cm
for different species), thicker layers (i.e., >1 meter) are likely to smother these sensitive benthic
organisms (Greene 2002). Numerous studies of such effects indicate that the recovery of benthic
fauna after beach nourishment or sediment placement projects can take anywhere from six
months to two years, and possibly longer in extreme cases (Thrush et al. 1996; Bishop et al.
2006; Peterson et al. 2006).

Invertebrate communities may also be affected by changes in the physical environment resulting
from shoreline stabilization activities that alter the sediment composition or degree of exposure.
For example, SCDNR (2011) found the decline in piping plovers to be strongly correlated with a
decline in polychaete densities on the east end of Kiawah Island, South Carolina, following an
inlet relocation project in 2006. Similar results were documented on Bird Key, South Carolina,
in 2006 when rapid habitat changes occurred within the sheltered lagoon habitat following
dredge disposal activities, and piping plovers shifted to more exposed areas. Their diet also
appeared to have shifted to haustoriid amphipods, based on analysis of fecal samples containing
pieces of Neohaustorius schmitzi, Lepidactylus dytiscus, and Acanthohaustorius sp., which were
also found during the invertebrate sampling in both locations (SCDNR 2011).

Shoreline armoring with hard stabilization structures such as seawalls and revetments can also
alter the degree of exposure of the macroinvertebrate prey base by modifying the beach and
intertidal geomorphology, or topography. Seawalls typically result in the narrowing and
steepening of the beach and intertidal slope in front of the structure, eventually leading to
complete loss of the dry and intertidal beach as sea level continues to rise (Pilkey and Wright
1988; Hall and Pilkey 1991; Dugan and Hubbard 2006; Defeo et al. 2009; Kim et al. 2011).

Sand placement projects bury the natural beach with up to millions of cubic yards of new
sediment, and grade the new beach and intertidal zone with heavy equipment to conform to a
predetermined topographic profile. This can lead to compaction of the sediment (Nelson et al.
1987; USACE 2008; Defeo et al. 2009). If the material used in a sand placement project does
not closely match the native material on the beach, the sediment incompatibility may result in
modifications to the macroinvertebrate community structure, because several species are
sensitive to grain size and composition (Rakocinski et al. 1996; Peterson et al.2006; Peterson and
Bishop 2005; Colosio et al. 2007; Defeo et al. 2009).

Delayed recovery of the benthic prey base or changes in their communities due to physical
habitat changes may affect the quality of piping plover foraging habitat. The duration of the
impact can adversely affect piping plovers because of their high site fidelity. Although recovery
of invertebrate communities has been documented in many studies, sampling designs have
typically been inadequate and have only been able to detect large-magnitude changes (Schoeman
et al. 2000; Peterson and Bishop 2005). Therefore, uncertainty persists about the impacts of
various projects to invertebrate communities and how these impacts affect shorebirds,

51
particularly the piping plover. Rice (2009) has identified several conservation measures that can
avoid and minimize some of the known impacts.

Invasive Vegetation

The spread of invasive plants into suitable wintering piping plover habitat is a relatively recently
identified threat (USFWS 2009a). Such plants tend to reproduce and spread quickly and to
exhibit dense growth habits, often outcompeting native plants. Uncontrolled invasive plants can
shift habitat from open or sparsely vegetated sand to dense vegetation, resulting in the loss or
degradation of piping plover roosting habitat, which is especially important during high tides and
migration periods. The propensity of invasive species to spread, and their tenacity once
established, make them a persistent threat that is only partially countered by increasing
landowner awareness and willingness to undertake eradication activities.

Many invasive species are either currently affecting or have the potential to affect coastal
beaches and thus plover habitat. Beach vitex (Vitex rotundifolia) is a woody vine introduced into
the southeastern U.S. as a dune stabilization and ornamental plant which has spread to coastal
communities throughout the southeastern U.S. from Virginia to Florida, and west to Texas
(Westbrooks and Madsen 2006). Hundreds of beach vitex occurrences and targeted eradication
efforts in North and South Carolina and a small number of known locations in Georgia and
Florida are discussed in the 5-Year Review (USFWS 2009a). Crowfootgrass (Dactyloctenium
aegyptium), which grows invasively along portions of the Florida coastline, forms thick bunches
or mats that can change the vegetative structure of coastal plant communities and thus alter
shorebird habitat (USFWS 2009a; Florida Exotic Pest Plant Council 2009). Australian pine
(Casuarina equisetifolia) affects piping plovers and other shorebirds by encroaching on foraging
and roosting habitat (Stibolt 2011); it may also provide perches for avian predators. Japanese
sedge (Carex kobomugi), which aggressively encroaches into sand beach habitats (USDA plant
profile website), was documented in Currituck County, North Carolina, in the mid-1970s and as
recently as 2003 on Currituck National Wildlife Refuge (Gramling pers. comm. 2011), at two
sites where migrating piping plovers have also been documented.

Defeo et al. (2009) cite biological invasions of both plants and animals as global threats to sandy
beaches, with the potential to alter the food web, nutrient cycling and invertebrate assemblages.
Although the extent of the threat is uncertain, this may be due to poor survey coverage more than
an absence of invasions.

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Wrack Removal and Beach Cleaning

Wrack on beaches and baysides provides important foraging and roosting habitat for piping
plovers (Drake 1999a; Smith 2007; Maddock et al. 2009; Lott et al. 2009b) and for many other
shorebirds. Because shorebird numbers are positively correlated both with wrack cover and the
biomass of their invertebrate prey that feed on wrack (Tarr and Tarr 1987; Hubbard and Dugan
2003; Dugan et al. 2003), beach grooming has been shown to decrease bird numbers (Defeo et
al. 2009).

It is increasingly common for beach-front communities to carry out “beach cleaning” and “beach
raking” activities. Beach cleaning is conducted on private beaches, where piping plover use is
not well documented, and on some municipal or county beaches used by piping plovers. Most
wrack removal on state and federal lands is limited to post-storm cleanup and does not occur
regularly. Wrack removal and beach raking both occur on the Gulf beach side of the developed
portion of South Padre Island in the Lower Laguna Madre in Texas, where plovers have been
documented during both the migratory and wintering periods (Zdravkovic and Durkin 2011).
Wrack removal and other forms of beach cleaning have been the subject of formal consultations
between the U.S. Army Corps of Engineers, municipalities, and USFWS in Nueces County,
Texas (USFWS 2008c, 2009c).

Although beach cleaning and raking machines effectively remove human-made debris, these
efforts also remove accumulated wrack, topographic depressions, emergent foredunes and
hummocks, and sparse vegetation nodes used by roosting and foraging piping plovers
(Nordstrom 2000; Dugan and Hubbard 2010). Removal of wrack also reduces or eliminates
natural sand-trapping, further destabilizing the beach. Furthermore, the sand adhering to
seaweed and trapped in the cracks and crevices of wrack also is lost to the beach when the wrack
is removed. Although the amount of sand lost during a single sweeping activity may be small,
over a period of years this loss could be significant (Neal et al. 2007).

Tilling beaches to reduce soil compaction, which is sometimes required by the USFWS for sea
turtle protection after beach nourishment activities, has similar impacts to those described above.
In northwest Florida, tilling on public lands is currently conducted only if the land manager
determines that it is necessary. Where tilling is needed, adverse effects are reduced by Florida
USFWS sea turtle protection provisions that require tilling to be above the primary wrack line,
rather than within it.

As of 2009, the Florida Department of Environmental Protection’s Beaches and Coastal
Management Systems section had issued 117 permits allowing multiple entities to conduct beach
raking or cleaning operations. Beach cleaning along 45 miles of coastline in Nueces, Kleberg,
and Cameron Counties in Texas was addressed in five USFWS biological opinions completed
between 2008 and 2012 (Cobb pers. comm. 2012c).

53
Dugan and Hubbard (2010), studying beach grooming activities on the beaches and dunes of
southern California, concluded that “beach grooming has contributed to widespread conversion
of coastal strand ecosystems to unvegetated sand” by removing wrack cover, increasing the
transport of windblown sediment, lowering the seed bank and the survival and reproduction of
native plants, and decreasing native plant abundance and richness. They argue that conserving
beach ecosystems by reducing beach grooming and raking activities “could help retain sediment,
promote the formation of dunes, and maintain biodiversity, wildlife, and human use in the face of
rising sea level (Dugan and Hubbard 2010).”

Accelerating sea level rise and other climate change impacts

Accelerating sea level rise poses a threat to piping plovers during the migration and wintering
portions of their life cycle. As noted in the previous section, threats from sea level rise are
tightly intertwined with artificial coastal stabilization activities that modify and degrade habitat.
If climate change increases the frequency or magnitude of extreme temperatures, piping plover
survival rates may be affected. Other potential adverse and beneficial climate change-related
effects (e.g., changes in the composition or availability of prey, emergence of new diseases,
fewer periods of severe cold weather) are poorly understood, but cannot be discounted.

Numerous studies have documented accelerating rise in sea levels worldwide (Rahmstorf et al.
2007; CCSP 2009; Pilkey and Young 2009; Vermeer and Rahmstorf 2009). Predictions include
a sea level rise of between 50 and 200 cm above 1990 levels by the year 2100 (Rahmstorf 2007;
Pfeffer et al. 2008; Vermeer and Rahmstorf 2009; Grinsted et al. 2010) and potential conversion
of as much as 33% of the world’s coastal wetlands to open water by 2080 (IPCC 2007; CCSP
2008). Potential effects of sea level rise on piping plover roosting and foraging habitats may
vary regionally due to subsidence or uplift, the geological character of the coast and nearshore,
and the influence of management measures such as beach nourishment, jetties, groins, and
seawalls (CCSP 2009; Galbraith et al. 2002; Gutierrez et al. 2011). Sea level rise along the U.S.
Gulf Coast exceeded the global average by 13-15 cm because coastal lands there are subsiding
(EPA 2009). The rate of sea level rise in Louisiana is particularly high (Louisiana Coastal
Wetlands Conservation and Restoration Task Force and the Wetlands Conservation and
Restoration Authority 1998). Sediment compaction and oil and gas extraction compound
tectonic subsidence along the Gulf of Mexico coastline (Penland and Ramsey 1990; Morton et al.
2003; Hopkinson et al. 2008).

Low elevations and proximity to the coast make all nonbreeding piping plover foraging and
roosting habitats vulnerable to the effects of rising sea level. Areas with small tidal ranges are the
most vulnerable to loss of intertidal wetlands and flats (EPA 2009). Sea level rise was cited as a
contributing factor in the 68% decline in tidal flats and algal mats in the Corpus Christi, Texas
region (i.e., Lamar Peninsula to Encinal Peninsula) between the 1950s and 2004 (Tremblay et al.
2008). Mapping by Titus and Richman (2001) showed that more than 80% of the lowest land
along the Atlantic and Gulf coasts was in Louisiana, Florida, Texas, and North Carolina.

54
Gutierrez et al. (2011) found that along the Atlantic coast, the central and southern Florida coast
is the most likely Atlantic portion of the wintering and migration range to experience moderate
to severe erosion with sea level rise.

Inundation of piping plover habitat by rising seas could lead to permanent loss of habitat,
especially if those shorelines are armored with hardened structures (Dugan and Hubbard 2006;
Fish et al. 2008; Defeo et al. 2009). Overwash and sand migration are impeded on the developed
portions of sandy ocean beaches (Smith et al. 2008) that comprise 40% of the U.S. nonbreeding
range (Rice 2012b). As the sea level rises, the ocean-facing beaches erode and attempt to
migrate inland. Buildings and artificial sand dunes then prevent sand from washing back toward
the lagoons (i.e., bayside), and the lagoon side becomes increasingly submerged during extreme
high tides (Scavia et al. 2002). Barrier beach shorebird habitat and natural features that protect
mainland developments are both diminished as a result.

Modeling by Galbraith et al. (2002) for three sea level rise scenarios at five important U.S.
shorebird staging and wintering sites predicted aggregate loss of 20-70% of current intertidal
foraging habitat. The most severe losses were projected at sites where the coastline is unable to
move inland due to steep topography or seawalls. Of five study sites, the model predicted the
lowest loss of intertidal shorebird foraging habitat at Bolivar Flats, Texas (a designated piping
plover critical habitat unit) by 2050 because the habitat at that site will be able to migrate inland
in response to rising sea level. The potential for such barrier island migration with rising sea
level is most likely in the 42% of plover’s U.S. nonbreeding range that is currently preserved
from development (Rice 2012b). Although habitat losses in some areas are likely to be offset by
gains in other locations, Galbraith et al. (2002) noted that time lags between these losses and the
creation of replacement habitat elsewhere may have serious adverse effects on shorebird
populations. Furthermore, even if piping plovers are able to move their wintering locations in
response to accelerated habitat changes, there could be adverse effects on the birds’ survival
rates or subsequent productivity.

In summary, the magnitude of threats from sea level rise is closely linked to threats from
shoreline development and artificial stabilization. These threats will be perpetuated in places
where damaged structures are repaired or replaced, exacerbated where the height and strength of
structures are increased, and increased at locations where development and coastal stabilization
is expanded. Sites that are able to adapt to sea level rise are likely to become more important to
piping plovers as habitat at developed or stabilized sites degrades.

Weather events

Storm Events

Storms are an integral part of the natural processes that form coastal habitats used by migrating
and wintering piping plovers, and positive effects of storm-induced overwash and vegetation

55
removal have been noted in portions of the wintering range. For example, biologists reported
piping plover use of newly created habitats at Gulf Islands National Seashore in Florida within
six months of overwash events that occurred during the 2004 and 2005 hurricane seasons
(Nicholas pers. comm. 2005). Hurricane Katrina created a new inlet and improved habitat
conditions on some areas of Dauphin Island, Alabama, but subsequent localized storms
contributed to habitat loss there (LeBlanc pers. comm. 2009) and the inlet was subsequently
closed with a rock dike as part of Deepwater Horizon oil spill response efforts (Rice 2012a).
Following Hurricane Ike in 2008, Arvin (2009) reported decreased numbers of piping plovers at
some heavily eroded Texas beaches in the center of the storm impact area and increases in plover
numbers at sites about 100 miles to the southwest. Piping plovers were observed later in the
season using tidal lagoons and pools that Hurricane Ike created behind the eroded beaches (Arvin
2009).

Adverse effects attributed to storms alone are sometimes actually due to a combination of storms
and other environmental changes or human use patterns. For example, four hurricanes between
2002 and 2005 are often cited in reference to rapid erosion of the Chandeleur Islands, a chain of
low-lying islands in Louisiana where the 1991 International Piping Plover Winter Census (Haig
and Plissner 1992) tallied more than 350 birds. Comparison of imagery taken three years before
and again several days after Hurricane Katrina found that the Chandeleur Islands had lost 82% of
their combined surface area (Sallenger 2010). A review of aerial photographs taken before the
2006 Census suggested that little piping plover habitat remained (Elliott-Smith et al. 2009).
However, Sallenger et al. (2009) noted that habitat changes in the Chandeleur Islands stem not
only from the effects of these storms, but rather from the combined effects of the storms, and
more than a thousand years of diminishing sand supply and sea level rise. Although the
Chandeleur Islands marsh platform continued to erode for 22 months post-Katrina, some sand
was released from the marsh sediments which in turn created beaches, spits, and welded swash
bars that advanced the shoreline seaward. Despite the effects of intense erosion, the Chandeleur
Islands are still providing high quality shorebird habitat in the form of sand flats, spits, and
beaches used by substantial numbers of piping plovers (Catlin et al. 2011), a scenario that could
continue if restoration efforts are sustainable and successful from a shorebird perspective
(USACE 2010).

Storm-induced adverse effects include post-storm acceleration of human activities such as beach
nourishment, sand scraping, closure of new inlets, and berm and seawall construction. Such
stabilization activities can result in the loss and degradation of feeding and resting habitats. Land
managers sometimes face public pressure after big storm events to plant vegetation, install
sandfences, and bulldoze artificial “dunes.” For example, national wildlife refuge managers
sometimes receive pressure from local communities to “restore” the beach and dunes following
blow-outs from storm surges that create the overwash foraging habitat preferred by plovers
(Hunter pers. comm. 2011). At least 64 inlets have been artificially closed, the vast majority of
them shortly after opening in storm events (see Table 6, page 39). Storms also can cause
widespread deposition of debris along beaches. Subsequent removal of this debris often requires

56
large machinery that in turn can cause extensive disturbance and adversely affect habitat
elements such as wrack. Challenges associated with management of public use can grow when
storms increase access (Gibson et. al. 2009; LeBlanc pers. comm. 2009).

Some available information indicates that birds may be resilient, even during major storms, and
move to unaffected areas without harm. Other reports suggest that birds may perish in or
following storm events. Noel and Chandler (2005) suspected that changes in habitat caused by
multiple hurricanes along the Georgia coastline altered the spatial distribution of piping plovers
and may have contributed to the winter mortality of three individuals. Wilkinson and Spinks
(1994) suggested that low plover numbers in South Carolina in January 1990 could have been
partially influenced by effects on habitat from Hurricane Hugo the previous fall, while Johnson
and Baldassarre (1988) found a redistribution of piping plovers in Alabama following Hurricane
Elena in 1985.

Climate change studies indicate a trend toward increasing numbers and intensity of hurricane
events (Emanuel 2005; Webster et al. 2005). Combined with the predicted effects of sea level
rise, this trend indicates potential for increased cumulative impact of future storms on habitat.
Major storms can create or enhance piping plover habitat while causing localized losses
elsewhere in the wintering and migration range.
Severe Cold Weather

Several sources suggest the potential for adverse effects of severe winter cold on survival of
piping plovers. The Atlantic Coast piping plover recovery plan mentioned high mortality of
coastal birds and a drop from approximately 30-40 to 15 piping plovers following an intense
1989 snowstorm along the North Carolina coast (Fussell 1990). A preliminary analysis of
survival rates for Great Lakes piping plovers found that the highest variability in survival
occurred in spring and correlated positively with minimum daily temperature (weighted mean
based on proportion of the population wintering near five weather stations) during the preceding
winter (Roche pers. comm. 2010; 2012). Catlin (pers. comm. 2012b) reported that the average
mass of ten piping plovers captured in Georgia during unusually cold weather in December 2010
was 5.7 grams (g) less than the average for nine birds captured in October of the same year (46.6
g and 52.4 g, respectively; p = 0.003).

Disturbance from recreation activities

Increasing human disturbance is a major threat to piping plovers in their coastal migration and
wintering range (USFWS 2009a). Intense human disturbance in shorebird winter habitat can be
functionally equivalent to habitat loss if the disturbance prevents birds from using an area (Goss-
Custard et al. 1996). Nicholls and Baldassarre (1990a) found less people and off-road vehicles at
sites where nonbreeding piping plovers were present than at sites without piping plovers. Pfister
et al. (1992) implicate anthropogenic disturbance as a factor in the long-term decline of
migrating shorebirds at staging areas. Disturbance can cause shorebirds to spend less time

57
roosting or foraging and more time in alert postures or fleeing from the disturbances (Burger
1991; 1994; Elliott and Teas 1996; Lafferty 2001a, 2001b; Thomas et al. 2003). Shorebirds that
are repeatedly flushed in response to disturbance expend energy on costly short flights (Nudds
and Bryant 2000).

Shorebirds are more likely to flush from the presence of dogs than people, and breeding and
nonbreeding shorebirds react to dogs from farther distances than people (Lafferty 2001a, 2001b;
Lord et al. 2001; Thomas et al. 2003). Hoopes (1993) found that dogs flush breeding piping
plovers from further distances than people and that both the distance the plovers move and the
duration of their response is greater. Foraging shorebirds at a migratory stopover on Delaware
Bay, New Jersey responded most strongly to dogs compared with other disturbances; shorebirds
often failed to return within ten minutes after the dog left the beach (Burger et al. 2007). Dogs
off-leash were disproportionate sources of disturbance in several studies (Thomas et al. 2003;
Lafferty 2001b), but leashed dogs also disturbed shorebirds. Pedestrians walking with dogs
often go through flocks of foraging and roosting shorebirds; some even encourage their dogs to
chase birds.

Off-road vehicles can disrupt piping plover’s normal behavior patterns. The density of off-road
vehicles negatively correlated with abundance of piping plovers on the ocean beach in Texas
(Zonick 2000). Cohen et al. (2008) found that radio-tagged wintering piping plovers using ocean
beach habitat at Oregon Inlet in North Carolina were far less likely to use the north side of the
inlet where off-road vehicle use was allowed. Ninety-six percent of piping plover detections
occurred on the south side of the inlet even though it was more than four times farther away from
foraging sites, prompting a recommendation that controlled management experiments be
conducted to determine if recreational disturbance drives roost site selection (Cohen et al. 2008).
Zdravkovic and Durkin (2011) stated that Laguna Madre Gulf beaches are considered part of the
Texas state highway system and are severely impacted by unrestricted public recreational off-
road vehicle use.

In a study of migrating shorebirds in Maryland, Forgues (2010) found that shorebird abundance
declined with increased off-road vehicle frequency, as did the number and size of roosts.
Migrants spent less time foraging in the presence of vehicles. In a before-after control-impact
experiment, densities of three focal species were significantly reduced after a vehicle closure was
lifted, while densities outside the closure zone exhibited little change; densities of two other
species also decreased more in the area where the closure was removed, but the difference was
not significant (Forgues 2010). In North Carolina, a before-after control-impact experiment
using the undisturbed plots as the controls found that vehicle disturbance decreased abundance of
shorebirds and altered their habitat use during fall migration (Tarr 2008).

Recreational activities, especially off-road vehicles, may degrade piping plover habitat. Tires
that crush wrack into the sand render it unavailable as a roosting habitat or foraging substrate
(Goldin 1993; Hoopes 1993). At four study beaches in New York and Massachusetts, Kluft and

58
Ginsberg (2009) found that abundance of invertebrates in pitfall trap samples and abundance of
wrack was higher on vehicle-free beaches, although invertebrate abundance in wrack clumps and
cores taken below them did not show consistent differences between areas open and closed to
vehicles. Off-road vehicles significantly lessened densities of invertebrates on intertidal flats on
the Cape Cod National Seashore in Massachusetts (Wheeler 1979). In eastern Australia, off-road
vehicles use has been documented as a significant cause of invertebrate mortality on beaches
(Schlacher et al. 2008a; 2008b). Results of Schlacher and Thompson (2012) in eastern Australia
also suggest that channeling major pedestrian access points away from key shorebird habitat may
enhance protection of their prey base.

Various local and regional examples also illustrate threats from recreation. On a 12-kilometer
stretch of Mustang Island in Texas, Foster et al. (2009) observed a 25% decline in piping plover
abundance and a simultaneous five-fold increase in human use over a 29-year study period, 1979
– 2007. This trend was marginally significant, but declines in two other plover species were
significant; declining shorebird abundance was attributed to a combination of human disturbance
and overall declines in shorebird populations (Foster et al. 2009). In South Carolina, almost half
of sites with five or more piping plovers had ten or more people present during surveys
conducted in 2007-2008 and more than 60% allow dogs (Maddock and Bimbi unpubl. data).
Zdravkovic and Durkin (2011) noted disturbance to piping plovers in Texas from kite-boarding,
windsurfing, and horseback riding.

Oil spills and other contaminants

Piping plovers may accumulate contaminants from point and non-point sources at migratory and
wintering sites. Depending on the type and degree of contact, contaminants can have lethal and
sub-lethal effects on birds, including behavioral impairment, deformities, and impaired
reproduction (Rand and Petrocelli 1985). Notwithstanding documented cases of lightly oiled
piping plovers that have survived and successfully reproduced (Amirault-Langlais et al. 2007),
contaminants have both the potential to cause direct toxicity to individual birds and to negatively
impact their invertebrate prey base (Chapman 1984; Rattner and Ackerson 2008). Piping
plovers’ extensive use of the intertidal zone puts them in constant contact with coastal habitats
likely to be contaminated by water-borne spills. Negative impacts can also occur during
rehabilitation of oiled birds.

Oil Spills

Following the Ixtoc spill, which began on June 3, 1979 off the coast of Mexico, approximately
350 metric tons of oil accumulated on South Texas barrier beaches, resulting in a 79% decrease
in the total number of infaunal organisms on contaminated portions of the beach (Kindinger
1981; Tunnell et al. 1982). Chapman (1984) collected pre- and post-spill data on the abundance,
distribution, and habitat use of shorebirds on the beaches in the affected area and saw declines in
the numbers of birds as well as shifts in the habitats used. Shorebirds avoided the intertidal area

59
of the beach, occupying the backshore or moving to estuarine habitats when most of the beach
was coated. Chapman surmised that the decline in infauna probably contributed to the observed
shifts in habitats used. His observations indicated that all the shorebirds, including piping
plovers, avoided the contaminated sediments and concentrated in oil-free areas. Amos, however,
reported that piping plovers ranked second to sanderlings in the numbers of oiled birds he
observed on the beach, although there was no recorded mortality of plovers due to oil (Amos
pers. comm. 2009; 2012). Oiled birds were seen for a year or more following the initial spill,
likely due to continued washing in of sunken tar; but there were only occasional subsequent
observations of oiled or tarred plovers (Amos pers. comm. 2009).

According to government estimates, the 2010 Deepwater Horizon Mississippi Canyon Well #252
oil spill discharged more than 200 million gallons of oil into the Gulf of Mexico (U.S.
Government 2010). Containment activities, recovery of oil-water mix, and controlled burning
removed some oil, but additional impacts to natural resources may stem from the 1.84 million
gallons of dispersant that were applied to the spill (U.S. Government 2010). At the end of July
2010, approximately 625 miles of Gulf of Mexico shoreline was oiled. This included
approximately 360 miles in Louisiana, 105 miles in Mississippi, 66 miles in Alabama, and 94
miles in Florida (U.S. Government 2010). These numbers do not address cumulative impacts or
include shoreline that was cleaned earlier. The U.S. Coast Guard, the states, and responsible
parties that form the Unified Command (with advice from federal and state natural resource
agencies) initiated protective measures and clean-up efforts as provided in contingency plans for
each state’s coastline. The contingency plans identified sensitive habitats, including all ESA-
listed species’ habitats, which received a higher priority for response actions.

Efforts to prevent shoreline oiling and cleanup response activities can disturb piping plovers and
their habitat. Although most piping plovers were on their breeding grounds in May, June, and
early July when the Deepwater well was discharging oil, oil was still washing onto Gulf beaches
when the plovers began arriving back on the Gulf in mid-July. Ninety percent of piping plovers
detected during the prior four years of surveys in Louisiana were in the Deepwater Horizon oil
spill impact zone, and Louisiana’s Department of Wildlife and Fisheries reported significant
disturbance to birds and their habitat from response activities. Wrack lines were removed, and
sand washing equipment “cleansed” beaches (Seymour pers. comm. 2011). Potential long-term
adverse effects stem from the construction of sand berms and closing of at least 32 inlets (Rice
2012a). Implementation of prescribed best management practices reduced, but did not negate,
disturbance to plovers (and to other beach-dependent wildlife) from cleanup personnel, all-
terrain vehicles, helicopters, and other equipment. USFWS and state biologists present during
cleanup operations provided information about breeding, migrating, and wintering birds and their
habitat protection needs. However, high staff turnover during the extended spill response period
necessitated continuous education and training of clean up personnel (Bimbi pers. comm. 2011).
Limited clean-up operations were still on-going throughout the spill area in November 2012
(Herod pers. comm. 2012). Results of a natural resources damage assessment study to assess
injury to piping plovers (Fraser et al. 2010) are not yet available.

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More subtle but cumulatively damaging sources of oil and other contaminants are leaking vessels
located offshore or within the bays on the Atlantic and Gulf coasts, offshore oil rigs and undersea
pipelines in the Gulf of Mexico, pipelines buried under the bay bottoms, and onshore facilities
such as petroleum refineries and petrochemical plants. In Louisiana, about 2,500-3,000 oil spills
are reported in the Gulf region each year, ranging in size from very small to thousands of barrels
(Carver pers. comm. 2011). Chronic spills of oil from rigs and pipelines and natural seeps in the
Gulf of Mexico generally involve small quantities of oil. The oil from these smaller leaks and
seeps, if they occur far enough from land, will tend to wash ashore as tar balls. In cases such as
this, the impact is limited to discrete areas of the beach, whereas oil slicks from larger spills coat
longer stretches of the shoreline (Rice pers. comm. 2009). In late July and early August 2009,
for example, oil suspected to have originated from an offshore oil rig in Mexican waters was
observed on plumage or legs of 14 piping plovers in south Texas (Cobb pers. comm. 2012b).

Pesticides and Other Contaminants

A piping plover was found among dead shorebirds discovered on a sandbar near Marco Island,
Florida following the county’s aerial application of the organophosphate pesticide Fenthion for
mosquito control in 1997 (Pittman 2001; Williams 2001). Subsequent to further investigations
of bird mortalities associated with pesticide applications and to a lawsuit being filed against the
Environmental Protection Agency in 2002, the manufacturer withdrew Fenthion from the
market, and Environmental Protection Agency banned all use after November 30, 2004
(American Bird Conservancy 2007). Absent identification of contaminated substrates or
observation of direct mortality of shorebirds on a site used by migrating and wintering piping
plovers, detection of contaminants threats is most likely to occur through analysis of unhatched
eggs. Contaminants in eggs can originate from any point in the bird’s annual cycle, and
considerable effort may be required to ascertain where in the annual cycle exposure occurred.

There has been limited opportunistic testing of piping plover eggs. Polychlorinated biphenol
(PCB) concentrations in several composites of Great Lakes piping plover eggs tested in the
1990s had potential to cause reproductive harm. Analysis of prey available to piping plovers at
representative Michigan breeding sites indicated that breeding areas along the upper Great Lakes
region were not likely the major source of contaminants to this population (Best pers. comm.
1999 in USFWS 2003a). Relatively high levels of PCB, dichloro diphenyl dichloroethylene
(DDE), and polybrominated diphenyl ether (PBDE) were detected in one of two clutches of
Ontario piping plover eggs analyzed in 2009 (Cavalieri pers. comm. 2011). Results of
opportunistic egg analyses to date from Atlantic Coast piping plovers did not warrant follow-up
investigation (Mierzykowski 2009; 2010; 2012; Mierzykowski pers. comm. 2012). No recent
testing has been conducted for contaminants in the Northern Great Plains piping plover
population.

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Energy development

Land-based Oil and Gas Exploration and Development

Various oil and gas exploration and development activities occur along the Gulf Coast.
Examples of conservation measures prescribed to avoid adverse effects on piping plovers and
their habitats include conditions on driving on beaches and tidal flats, restrictions on discharging
fresh water across unvegetated tidal flats, timing exploration activities during times when the
plovers are not present, and use of directional drilling from adjacent upland areas (USFWS
2008d; Firmin pers. comm. 2012). With the implementation of appropriate conditions, threats to
nonbreeding piping plovers from land-based oil and gas extraction are currently very low.

Wind Turbines

Wind turbines are a potential future threat to piping plovers in their coastal migration and
wintering range. Relatively small single turbines have been constructed along the beachfront in
at least a few locations (Caldwell pers. comm. 2012). Current risk to piping plovers from several
wind farms located on the mainland north and west of several bays in southern Texas is deemed
low during months of winter residency because the birds are not believed to traverse these areas
in their daily movements (Newstead pers. comm. 2012a). To date, no piping plovers have been
reported from post-construction carcass detection surveys at these sites (Clements pers. comm.
2012). However, Newstead (pers. comm. 2012a) has raised questions about collision risk during
migration departure, as large numbers of piping plovers have been observed in areas of the
Laguna Madre east of the wind farms during the late winter. Furthermore, there is concern that,
as sea level rises, the intertidal zone (and potential piping plover activity) may move closer to
these sites. Several off-shore wind farm proposals in South Carolina are in various stages of
early scoping (Caldwell pers. comm. 2012).

In addition to uncertainty regarding the location and design (e.g., number and height of turbines)
of future wind turbines, the magnitude of potential threats is difficult to assess without better
information about piping plover movements and behaviors. For wind projects situated on barrier
beaches, bay shorelines, or within bays, relevant information includes the flight routes of piping
plovers moving among foraging and roosting sites, flight altitude, and avoidance rates under
varying weather and light conditions. For off-shore wind projects, piping plover migration
routes and altitude, as well as avoidance rates will be key determinants of threats.

Predation

The extent of predation on migrating or wintering piping plovers remains largely unknown and is
difficult to document. Avian and mammalian predators are common throughout the species’
wintering range. Human activities affect the types, numbers, and activity patterns of some
predators, thereby exacerbating natural predation on breeding piping plovers (USFWS 1996).

62
One incident involving a cat observed stalking piping plovers was reported in Texas (NY Times
2007). It has been estimated that free-roaming cats kill over one billion birds every year in the
U.S., representing one of the largest single sources of human-influenced mortality for small
native wildlife (Sax and Gaines 2008).

Predatory birds, including peregrine falcons, merlin, and harriers, are present in the nonbreeding
range. Newstead (pers. comm. 2012b) reported two cases of suspected avian depredation of
piping plovers in a Texas telemetry study, but he also noted that red tide may have compromised
the health of these plovers. It has been noted, however, that the behavioral response of
crouching when in the presence of avian predators may minimize avian predation on piping
plovers (Morrier and McNeil 1991; Drake 1999a; Drake et al. 2001). Drake (1999a) theorized
that this piping plover behavior enhances concealment associated with roosting in depressions
and debris in Texas.

Nonbreeding piping plovers may reap some collateral benefits from predator management
conducted for the primary benefit of other species. Florida Keys Refuges National Wildlife
Refuge (USFWS 2011a), for example, released a draft integrated predator management plan that
targets predators, including cats, for the benefit of native fauna and flora. Other predator control
programs are ongoing in North Carolina, South Carolina, Florida, and Texas beach ecosystems
(USFWS 2009a).Although the extent of predation to nonbreeding piping plovers is unknown, it
remains a potential threat.

Military operations

Five of the eleven coastal military bases located in the U.S. continental range of nonbreeding
piping plovers have consulted with the USFWS about potential effects of military activities on
plovers and their habitat (USFWS 2009a; USFWS 2010b). Formal consultation under section 7
of the ESA with Camp Lejeune, North Carolina in 2002 provided for year-round piping plover
surveys, but restrictions on activities on Onslow Beach only pertain to the plover breeding
season (Hammond, USFWS, pers. comm. 2012). Informal consultations with three Florida bases
(Naval Station Mayport, Eglin Air Force Base, Tyndall Air Force Base) addressed training
activities that included beach exercises and occasional use of motorized equipment on beaches
and bayside habitats. Eglin Air Force Base conducts twice-monthly surveys for piping plovers,
and habitats consistently used by piping plovers are posted with avoidance requirements to
minimize direct disturbance from troop activities. Operations at Tyndall Air Force Base and
Naval Station Mayport were determined to occur outside optimal piping plover habitats. A 2001
consultation with the Navy for one-time training operations on Peveto Beach in Louisiana
concluded informally (USFWS 2010b). Current threats to wintering and migrating piping
plovers posed by military activities appear minimal.

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Disease

No instances of disease have been documented in piping plovers outside the breeding range. In
the southeastern U.S., the cause of death of one piping plover received from Texas was
emaciation (Acker pers. comm. 2009). Newstead (pers. comm. 2012b) reported circumstantial
evidence that red tide weakened piping plovers in the vicinity of the Laguna Madre and Padre
Island, Texas during the fall of 2011. Samples collected in Florida from two live piping plovers
in 2006 both tested negative for avian influenza (Hines pers. comm. 2009). The 2009 5-Year
Review concluded that West Nile virus and avian influenza remain minor threats to piping
plovers on their wintering and migration grounds.

2.2. Environmental Baseline

North Carolina barrier beaches are part of a complex and dynamic coastal system that
continually respond to inlets, tides, waves, erosion and deposition, longshore sediment transport,
and depletion, fluctuations in sea level, and weather events. The location and shape of the
coastline perpetually adjusts to these physical forces. Winds move sediment across the dry
beach forming dunes and the island interior landscape. The natural communities contain plants
and animals that are subject to shoreline erosion and deposition, salt spray, wind, drought
conditions, and sandy soils. Vegetative communities include foredunes, primary and secondary
dunes, interdunal swales, sand pine scrub, and maritime forests.

During storm events, overwash across the barrier islands is common, depositing sediments on the
bayside, clearing vegetation and increasing the amount of open, sandflat habitat ideal for
shoreline dependent shorebirds. However, the protection or persistence of these important
natural land forms, processes, and wildlife resources is often in conflict with long-term beach
stabilization projects and their indirect effects, i.e., increases in residential development,
infrastructure, and public recreational uses, and preclusion of overwash which limits the creation
of open sand flats preferred by piping plovers.

2.2.1. Status of the species within the Action Area

In North Carolina, piping plovers may be observed during every month of the year.

Breeding piping plovers

Nesting pairs are most likely to be seen on Cape Hatteras and Cape Lookout National Seashores
(Seashores), where up to 97% of North Carolina’s breeding individuals and breeding pairs have
been recorded each year. One breeding pair nested at Rich Inlet on the north end of Figure Eight
Island in 2014, 2015, and 2016, and one chick fledged at Rich Inlet in the summer of 2016. A
nest with two eggs was documented on Topsail Beach in 2016, but no chicks fledged (Suiter
pers. comm. 2016). In 2016, only three chicks fledged on Cape Hatteras and five fledged at

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Cape Lookout National Seashores. South Carolina has historically been the most southern
Atlantic state where piping plover nesting occurs. Nesting habitat for piping plovers is being lost
incrementally in the Carolinas. In recent years, no piping plover nests have been observed in
South Carolina. The nests on Figure Eight Island are not only the southernmost piping plover
nests in recent years, but also the only North Carolina nests outside of the Seashores. Prior to
2010, breeding pairs and nests were also typically found on Lea-Hutaff Island, but chicks have
not successfully fledged from those sites since 2008 (Schweitzer pers. comm. 2017). See Table
8 for data on piping plover breeding pairs in North Carolina.

Between 2000 and 2016, successful nests (with fledged chicks) were recorded on Bodie Island,
on the spit just north of Hatteras Inlet, Cape Point (Hatteras Island), several locations on Cape
Lookout National Seashore (including Middle Core Banks, North Core Banks, Ophelia Island
and South Core Banks), Lea-Hutaff Island, and Figure Eight Island. Locations where breeding
pairs have been recorded, but no successful nests have been recorded, include Old Dump Island,
Ocracoke Island, Bear Island, Bogue Inlet (East), New Topsail Inlet, Onslow Beach, Fort Fisher,
Holden Beach, and Ocean Isle Beach (Schweitzer pers. comm. 2017).

The number of breeding pairs estimated from 2011 to 2016 in NC is only about 27% higher than
the number of annual breeding pairs in the 1990s. Overall, there has been growth in numbers of
breeding pairs in North Carolina, but the majority of growth for the Southern Recovery Unit has
occurred in Virginia (Tables 2 and 3). The subpopulation target of 400 pairs has not yet been
obtained, although numbers of breeding piping plovers in the Southern Recovery Unit have
generally been above 300 for the past ten years (with the exception of 2011). The overall
increase in the Southern Recovery Unit is due to population growth in Virginia, where recent
storms have created and maintained habitat. However, the increase in Virginia was partially
offset by the drop in productivity in North Carolina and a continuing decline in Maryland. Most
of the Southern unit had cold, wet, and windy spring weather, which delayed breeding and was a
major contributor to low productivity. Wind and flooding may also have contributed to the drop
in abundance of breeding pairs in North Carolina, as several of the major breeding areas were
completely flooded, and birds may have been unable to find territories (Hecht Pers. Comm.
2016). Annual productivity in North Carolina has varied wildly over the past 20 years, and does
not show any trends in growth or decline (Figure 6). Productivity has been as low as 0.07 in
1991, when only three chicks fledged from 40 statewide pairs, to 0.96 in 2013, when 56 breeding
pairs fledged 54 chicks.

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Table 8. Piping plover breeding pairs and breeding success, 1986 to 2016. Data from the PBA
and NCWRC (Schweitzer, pers. comm. 2017). NR = Not Reported

Year # Pairs Number of chicks
fledged
Productivity rate
1986 36 NR NR
1987 30 NR NR
1988 40 NR NR
1989 55 32 0.59
1990 55 24 0.43
1991 40 3 0.07
1992 49 21 0.42
1993 53 40 0.74
1994 54 20 0.36
1995 50 22 0.44
1996 35 30 0.86
1997 52 12 0.23
1998 46 28 0.61
1999 31 15 0.48
2000 24 13 0.54
2001 23 11 0.48
2002 23 3 0.17
2003 24 11 0.46
2004 20 13 0.65
2005 37 34 0.92
2006 46 40 0.87
2007 61 16 0.26
2008 64 19 0.3
2009 54 39 0.72
2010 61 47 0.77
2011 62 48 0.77
2012 70 41 0.59
2013 56 54 0.96
2014 65 14 0.22
2015 64 41 0.64
2016 53 9 0.17

66
Figure 6. Annual reproductive productivity of piping plovers in North Carolina. Data from
Schweitzer (Pers. comm. 2017).

Nonbreeding piping plovers

Surveys by multiple groups have documented many banded and unbanded piping plovers during
migration and winter in North Carolina. The migrant population is larger than the winter
population or nesting population. Piping plovers that winter at sites (meaning they spend the
majority of their nonbreeding season at one location) can arrive at their winter site as early as
August and depart as late as April (Maddock et al. 2009). However, the best winter population
estimate cannot be determined until December and/or January. Results of a band re-sighting
analysis for birds documented at sites in South Carolina showed zero immigration or emigration
during the months of December and January (Cohen, pers. comm. 2009). Therefore, the Service
determines the local winter population by using the single highest count of birds observed during
surveys conducted between December 1 and January 31. Bird counts in other months are
considered migrants or nesting individuals.

Piping plover observations during six rangewide mid-winter IPPCs, conducted at five-year
intervals starting in 1991, are summarized for North Carolina, in Table 9. According to
Schweitzer (pers. comm. 2017), 35 sites were surveyed in 2016, and a larger amount of habitat
was surveyed than in 2011. The count of 101 observations in 2016 is the highest since surveys
began. However, these mid-winter surveys appear to greatly underestimate the abundance of
nonbreeding piping plovers using a site or region during other months, as discussed below.

0.59
0.43
0.07
0.42
0.74
0.36
0.44
0.86
0.23
0.61
0.48 0.54 0.48
0.17
0.46
0.65
0.92 0.87
0.26 0.3
0.72
0.77 0.77
0.5857
0.96
0.22
0.64
0.17
0
0.2
0.4
0.6
0.8
1
1.2
19
8
9
19
9
0
19
9
1
19
9
2
19
9
3
19
9
4
19
9
5
19
9
6
19
9
7
19
9
8
19
9
9
20
0
0
20
0
1
20
0
2
20
0
3
20
0
4
20
0
5
20
0
6
20
0
7
20
0
8
20
0
9
20
1
0
20
1
1
20
1
2
20
1
3
20
1
4
20
1
5
20
1
6
Pr
o
d
u
c
t
i
v
i
t
y

e
s
t
i
m
a
t
e

67
Table 9. Results of the IPPC winter census in North Carolina. Data from Schweitzer (pers.
comm. 2017).

Year Number of
piping plovers
1991 21
1996 50
2001 87
2006 84
2011 43
2016 101

Researchers from Virginia Tech (Virginia Tech Shorebird Program 2016) and others counted as
many as 200 banded and unbanded piping plovers (on one date) on the south tip of Ocracoke
Island between July 3 and August 26, 2017. The vast majority of the unbanded birds are
expected to be from the Atlantic Coast population. Using models associated with Capture-Mark-
Resighting (CMR) methods, Virginia Tech estimates that a total of approximately 533 (estimated
range of 431—675) individual birds from the Atlantic Coast breeding population utilized the site
as a migration stopover during this period, for an average length of at least 28 days. This
represents approximately 20% of the entire Atlantic Breeding population of piping plover at this
one site (Virginia Tech Shorebird Program 2016). Previous daily counts at this site were as high
as 104 (NCWRC 2017).

Other North Carolina sites where greater than 10 piping plovers have been observed regularly
since 2006 include other portions of Cape Hatteras National Seashore (including Bodie Island,
Cape Point, Bird Shoal, Clam Shoal, and Hatteras Inlet), Cape Lookout National Seashore
(including Core Banks, New Drum Inlet, and Shackleford Banks), Hammocks Beach State Park
(on both Bogue Inlet and Bear Inlet), Onslow Beach, New River Inlet, New Topsail Inlet, Lea-
Hutaff Island, Rich Inlet, Mason Inlet, and Masonboro Inlet. Most of these sites are
undeveloped, or in the case of inlets, are undeveloped on at least one side. With the exception
of New River, Mason and Masonboro Inlets, the inlets are also largely unmodified. The
modified inlets and adjacent habitats support fewer piping plover in general, although on
occasion larger numbers will be present. For example, since 2006, 10 piping plovers have been
observed on two different dates on Onslow Beach, but during many surveys, fewer than one or
two are observed (NCWRC 2017). Both Masonboro and Mason Inlets are relocated and mined
regularly for sand, which is placed on the adjacent shoreline. Masonboro Inlet is also armored
with jetties on either side.

68
Nine piping plovers were observed on the east end of Ocean Isle on March 31, 2011. The east
end of Ocean Isle Beach on Lockwoods Folly Inlet supported four unbanded piping plovers
during the winters of 2006 through 2008, and a breeding pair in 2007. However, the breeding
habitat was not marked for protection until June that year, and the pair did not successfully nest
(NCWRC 2017). Surveyors noted that beach traffic and development were likely affecting the
individual birds. In 2017, the Town of Ocean Isle Beach received a Corps permit to construct a
terminal groin along the shoreline near Lockwoods Folly Inlet.

Developed beaches and inlets that are regularly modified or disturbed are utilized by
significantly fewer piping plovers. For example, Dare County north of Bodie Island, Emerald
Isle, Oak Island, Holden Beach, and Sunset Beach have occasional piping plover observations,
particularly during spring and fall migration. However, none of these areas have had more than
five observations on a given date. The vast majority of surveys record no piping plovers or one
individual.

Banded piping plovers in North Carolina

Unpublished data from NCWRC’s PAWS database (NCWRC 2017) provide banded piping
plover data for most coastal areas of North Carolina. The majority of banded piping plovers are
recorded on Cape Hatteras and Cape Lookout National Seashores, and the islands and inlet
complexes from Cape Lookout south to Masonboro Island. Only a few banded birds have been
recorded in North Carolina south of Carolina Beach Inlet, in part because there are fewer records
due to development of these areas, and also focus by the bird community on areas north. Banded
piping plovers from all three breeding populations have been recorded on the National Seashores
and south to Masonboro Inlet. This region of North Carolina, from Cape Lookout to Masonboro
Inlet, is extremely important to the survival and recovery of the piping plover, particularly the
Great Lakes piping plover (which is listed as endangered).

Since 2007, Audubon North Carolina has identified approximately 122 individually-banded
piping plovers along the North Carolina coast from Topsail Island south to Masonboro Island
(Addison Pers. Comm. 2016). This area encompasses four inlets and five islands: Topsail
Island, New Topsail Inlet, Lea-Hutaff Island, Rich Inlet, Figure Eight Island, Mason Inlet,
Wrightsville Beach, Masonboro Inlet, and Masonboro Island. 79 of these banded plovers are
from the Great Lakes breeding population, 28 from the Atlantic Coast breeding population, and
nine are from the Northern Great Plains population. Only 6 are from an unidentified population.
The number or percentage of banded birds in each of the three populations depends on active
banding projects. Virtually all of the Great Lakes individuals are banded, unlike individuals
from the Atlantic Coast or Northern Great Plains breeding populations; the larger Atlantic Coast
and Northern Great Plain populations only have banding projects at a few sites across their broad
breeding ranges (Gratto-Trevor et al. 2012).

69
At least 52 banded piping plovers have been documented on either side of Rich Inlet or on
Figure Eight Island since 2006, including at least 30 individuals from the endangered Great
Lakes breeding population. The area has been monitored or surveyed by several different
parties, and large numbers of banded and unbanded piping plovers have been observed
throughout the migration and wintering season. For example, 40 piping plovers were observed
on March 15, 2015 (including four banded birds), 31 were observed on August 1, 2015
(including seven banded birds), 11 were observed on October 6, 2013 (none with bands), and 10
were observed on December 28, 2013 (three with bands). The Great Lakes piping plovers
migrating through and wintering in the Topsail/Rich/Mason/Masonboro Inlet complex have
fledged 70 chicks since 2005, which is a significant contribution to the growth rate for this very
small population.

Using a Jolly-Seber population model (Kery and Schaub 2012; Lyons et al. 2015), Virginia Tech
estimated the total number of Great Lakes piping plovers that migrated through or overwintered
at Rich Inlet and also those that migrated through or overwintered at Topsail, Rich, Mason, and
Masonboro Inlets. Based on the number of banded individuals from the Great Lakes piping
plover population, an average of approximately nine Great Lakes individuals, and as many as 12
are estimated to utilize Rich Inlet on a yearly basis. Considering the Masonboro to Topsail Inlet
complex (including Masonboro Inlet, Mason Inlet, Rich Inlet and Topsail Inlet), an estimated 15
Great Lakes piping plovers utilize these inlets.

Because the vast majority of piping plovers from the Great Lakes breeding population are
identifiable by bands, because they have high site fidelity for both overwintering and breeding
sites, and because detection on the breeding grounds is near perfect, it is possible to estimate the
average apparent survival of the piping plovers observed at various wintering sites. Table 10
lists the average apparent survival of Great Lakes piping plovers between 2012 and 2016, at
several inlets on the southeast coast. The average apparent survival rate of Great Lakes plovers
at Rich Inlet was 0.822 for 2012-2016, one of the highest survival rates in the South Atlantic
non-breeding grounds. The average apparent survival rate of Great Lakes plovers at (New)
Topsail Inlet for the same time period is much lower (0.486), and is similar to more highly
modified inlets in South Carolina and Georgia.

70
Table 10. Average Apparent Survival rates of Great Lakes piping plovers between 2012 and
2016, at several inlets in North Carolina, South Carolina, and Georgia. These numbers were
derived from a model that constrained survival to be independent among sites, allowed for
individuals to move to a new site (if seen), but constrained survival to be constant among years
(Gibson pers. comm. 2016; 2017).

Site Relative
Disturbance
Average Apparent Survival
(2012-2016)
Hilton Head, SC High 0.534 (SE 0.078)
Kiawah/Seabrook Island, SC Moderate 0.48 (SE 0.088)
Harbor Island, SC
(2010-2015) Low 0.700 (SE 0.089)
Deveaux Banks, SC
(2010-2015) Low 0.578 (SE 0.084)
Cumberland Island, GA
(2010-2015) Low 0.536 (SE 0.067)
Little Saint Simons Island,
GA (2010-2015) Low 0.576 (SE 0.044)
Rich Inlet, NC Low 0.822 (SE 0.086)
Topsail Inlet, NC Moderate 0.486 (SE 0.096)

2.2.2. Factors affecting the species environment within the Action Area

In accordance with the Act, the Service completes consultations with all federal agencies for
actions that may adversely affect sea turtles. In North Carolina, consultations have included
military missions and operations, beach nourishment and other shoreline protection, and actions
related to protection of coastal development on sandy beaches of North Carolina’s coast. A wide
range of recent and on-going activities have altered the proposed Action Area and others are
proposed along the coastline for the near future. Rice (2017) estimates that approximately 41%
of North Carolina’s sandy shoreline is developed. Activities are conducted along these
shorelines to protect infrastructure and buildings from coastal erosion. Many miles of
undeveloped sandy shorelines are also sporadically nourished, although it is not common for
other types of shoreline protection actions to be conducted in undeveloped areas.

71
Beach Nourishment/ Sand Placement:

Appendix A (from the PBA) lists historical beach sand placement projects for the state of North
Carolina. The beaches of North Carolina are regularly nourished with sand from the Corps and
from locally-sponsored or private projects. Sand placement activities widen beaches, change
their sedimentology and stratigraphy, alter coastal processes, and often plug dune gaps and
remove overwash areas. The addition of dredged sediment can temporarily affect the benthic
fauna of intertidal systems. Invertebrates may be crushed or buried during project construction.
Although some benthic species can burrow through a thin layer of additional sediment (38-89 cm
for different species), thicker layers (i.e., >1 meter) are likely to smother these sensitive benthic
organisms (Greene 2002). Numerous studies of such effects indicate that the recovery of benthic
fauna after beach nourishment or sediment placement projects can take anywhere from six
months to two years, and possibly longer in extreme cases (Thrush et al. 1996; Bishop et al.
2006; Peterson et al. 2006). In North Carolina, the majority of sand placement projects are
conducted during the migration and overwintering season for piping plovers, in an effort to avoid
adverse effects to nesting sea turtles. Depending on the timing of the project, burial of prey
items can have a significant adverse effect on migrating and overwintering birds.

Invertebrate communities may also be affected by changes in the physical environment resulting
from shoreline stabilization activities that alter the sediment composition or degree of exposure.
For example, SCDNR (2011) found the decline in piping plovers to be strongly correlated with a
decline in polychaete densities on the east end of Kiawah Island, South Carolina, following an
inlet relocation project in 2006. Similar results were documented on Bird Key, South Carolina,
in 2006 when rapid habitat changes occurred within the sheltered lagoon habitat following
dredge disposal activities, and piping plovers shifted to more exposed areas. Their diet also
appeared to have shifted to haustoriid amphipods, based on analysis of fecal (SCDNR 2011). If
the material used in a sand placement project does not closely match the native material on the
beach, the sediment incompatibility may result in modifications to the macroinvertebrate
community structure, because several species are sensitive to grain size and composition
(Rakocinski et al. 1996; Peterson et al. 2006; Peterson and Bishop 2005; Colosio et al. 2007;
Defeo et al. 2009).

Delayed recovery of the benthic prey base or changes in their communities due to physical
habitat changes may affect the quality of piping plover foraging habitat. The duration of the
impact can adversely affect piping plovers because of their high site fidelity. Although recovery
of invertebrate communities has been documented in many studies, sampling designs have
typically been inadequate and have only been able to detect large-magnitude changes (Schoeman
et al. 2000; Peterson and Bishop 2005). Therefore, uncertainty persists about the impacts of
various projects to invertebrate communities and how these impacts affect shorebirds,
particularly the piping plover.

72
The PBA estimates that approximately 112 miles of Atlantic shoreline has been nourished in
North Carolina. Rice (2017) estimates the length of nourished shoreline to be approximately 101
miles, with another 43 miles proposed. Within the states in the Atlantic Coast piping plover
breeding range (Maine to North Carolina), this represents the largest length of modified
shoreline. New Jersey is second with 78.43 miles of shoreline (Rice 2017). The first recorded
sand placement project in North Carolina was on Wrightsville Beach in 1939, when sand was
placed on 2.6 miles of shoreline. Sand placement did not occur again until the mid to late-
1950’s. Sand placement was generally intermittent and small in scope (less than 6 miles per
year) until the late 1980’s to 1990’s, when the frequency of sand placement and miles of
shoreline per year began to dramatically increase. Many of the beachfront communities have
received sand on more than 10 occasions. Carolina Beach is listed in the PBA as having had 40
and placement events, while Wrightsville Beach has had 26, and Holden Beach 45. For most of
these events, the sand source is navigation projects. Other sand sources include sediment mined
from inlets, offshore borrow areas, and previously dredged material from upland disposal areas
or existing material from an upland borrow area. Between 31% (Rice 2017) and 35% (PBA) of
the North Carolina Shoreline has been modified by sediment placement as of 2015.

The Service is aware of many other activities conducted on the beaches during the past 10-20
years or more, such as terminal groins, jetties, beach scraping, sandbagging, beach cleaning, and
beach driving. The Service consulted upon and concurred with many of these activities through
informal and formal consultation. Table 11 lists activities other than sand placement for which
the Service has consulted between 2006 and 2017. This table is not inclusive of all informal
consultations during that time period.

Table 11. Service consultations on North Carolina oceanfront shoreline activities other than sand placement, from 2006 to 2017.

Year County Project Name Service Federal
Activity Code
Project
Location
Project Type Anticipated
Incidental Take
(linear feet) or
Affected Length
of Beach
2017 Carteret CLNS ORV
Management
Plan
04EN2000-2017-I-
0127
04EN2000-2014-F-
0255
Cape Lookout
National
Seashore
ORV use and access
management – Cape
Lookout National
Seashore
56 miles
2016 Brunswick Kay and David
Picha
04EN2000-2016-F-
0544
West end of
Ocean Isle
Beach
Extend existing
sandbag revetment
468 lf
2016 Brunswick Holden Beach
Terminal Groin
04EN2000-2016-F-
0283
East End of
Holden Beach
Construction of
terminal groin and
sand fillet
4,000 lf
2016 Dare NCDOT - Kitty
Hawk NC12
Dune Repair
04EN2000-2016-I-
0718
Kitty Hawk Restore dune and
extend sandbags along
NC12
2,680 lf total,
including sandbag
revetments
installed in 2003-
2004 (Rice 2017)
2016 Dare CHNS Frisco
Pier Demolition
04EN2000-2016-I-
0511
Frisco, NC Demolish old pier Less than 100 lf
2015 Brunswick Ocean Isle
Terminal Groin
04EN2000-2015-F-
0201
East End of
Ocean Isle
Beach
Construction of
terminal groin and
sand fillet
24,500 lf
2015 Onslow Camp Lejeune
2015-2020
INRMP
04EN2000-2015-F-
0251
Camp Lejeune Integrated Natural
Resource Management
Plan
11 miles
2015 Onslow North Topsail
Sandbag
04EN2000-2014-F-
0495
North end of
North Topsail
Construction of
sandbag revetment
2,300 lf

74
Revetment Beach
2014 New
Hanover
Village of Bald
Head Island
Terminal Groin
04EN2000-2014-F-
0204
West end of
Bald Head
Island
Construction of
terminal groin and
sand fillet
12,600 lf
2014 Dare NCDOT Ocean
Outfall #3
04EN2000-2014-I-
0118-R001
04EN2000-2014-I-
0118-R002
Nags Head
Beach
Replacement of ocean
outfall #3 pipe
Less than 100 lf
2012 Dare NCDOT – NC
12 Repair
42420-2011-I-0334 Rodanthe and
Pea Island
NWR
Post-storm repair of
NC-12 breaches
2,110 lf (Rice
2017)
2010 Dare, Hyde CHNS Off-Road
Vehicle
Management
Plan
04EN2000-2015-I-
0362
42420-2010-F-0157
Cape Hatteras
National
Seashore –
excluding Pea
Island NWR
ORV use and access
management – Cape
Hatteras National
Seashore
67 miles
2008 Brunswick NCDOT East
Second Street
42420-2008-TA-0118 E. Second St.,
Ocean Isle
Beach
Replace sandbags 400 lf (1,885 lf
total, including
connecting Town
and private
landowner
revetments) (Rice
2017)
2008 Dare NCDOT -
Herbert C.
Bonner Bridge
42420-2006-F-0356-
R001, R002, R003;
04EN2000-2013-F-
0247-R001, R002;
04EN2000-2012-I-
Oregon Inlet,
Bodie Island,
Hatteras Island
Bridge replacement,
road and new bridge
construction
16.1 miles

75
0153;
04EN2000-2013-F-
0275
2006 Dare, Hyde CHNS Interim
Protected
Species
Management
Strategy
42420-2006-F-007 Cape Hatteras
National
Seashore
Management practices
for
recreational use and
protection of species
at CHNS until the
ORV
Management Plan was
completed
56 miles
2006 Carteret CLNS Interim
Protected
Species
Management
Strategy
Cape Lookout
National
Seashore
Management practices
for
recreational use and
protection of species
at CHNS until the
Final Management
Plan was completed
56 miles
2006 Onslow Cape Lejeune
2007-2011
INRMP
42420-2006-I-0182
42420-2006-I-0009
04EN2000-2012-I-
0154
Camp Lejeune 2006-2011 Integrated
Natural Resource
Management Plan
11 miles

Table 12 lists biological opinions since 2014 within the Raleigh Field Office geographic area
that have been issued for adverse impacts to piping plovers. The BOs include those for beach
renourishment, sandbag revetments, and terminal groin construction, all of which are included in
the Environmental Baseline for this BO.

Table 12. BOs issued since 2014 within the Raleigh Field Office geographic area, for adverse
impacts to piping plovers

OPINIONS
PIPING PLOVER HABITAT
Critical Habitat Habitat
Fiscal Year 2014: 1 BO n/a 12,600 lf
(2.4 mi)
Fiscal Year 2015: 5 BOs Approx. 33.49 acres,
2,200 lf
70,268 lf
(13.3 mi)
Fiscal Year 2016: 8 BOs 9,696 lf
(1.83 mi)
229,937 lf
(43.54 mi)
Fiscal Year 2017 (to date): 1 BO n/a 27,650 lf (5.24
mi)
Total: 15 BOs 11,896 lf (2.25 mi)
approx. 33.49 acres
340,455 lf
(64.48 mi)

Since the 1980s, development of the North Carolina coast has accelerated. Of the 20 currently
open inlets, 16 are modified by man in some manner (Rice 2016). All 16 are dredged, and 7
have hardened structures (Table 13). Brown’s Inlet, Bear Inlet, New Old Drum Inlet, and
Ophelia Inlet are the only four that have not had some type of habitat modification, although the
Corps dredges the AIWW crossing at Brown’s Inlet, and other channels associated with Bear
Inlet are dredged intermittently (e.g. Cow Channel).

Inlet dredging activities alter the sediment dynamics on adjacent shorelines and stabilize these
dynamic environments; beach disposal of dredge material further alters the natural habitat
adjacent to inlets. Estuarine dredging of navigational channels can alter water circulation
patterns and sediment transport pathways, as well as increase the frequency and magnitude of
boat wakes; sound-side sand or mud flats may be impacted by increased erosion rates as a result.
Historically, there have been Federal navigation projects in the AIWW and in inlets along the
North Carolina coast for decades. During hundreds of dredging events, the sediment has been
placed on the adjacent beach using pipelines.

77
Table 13. Open tidal inlets from north to south along the North Carolina coast in 2015 with
actual (X) and proposed (P) habitat modification(s) at each. Note that an X in the Jetties column
indicates one jetty is present and a D indicates two (dual) jetties. Table from Rice (2016).

Order

Inlet
Type of Habitat Modification

Artifi
ciall
y
cr
eat
e
d

Je
tties
Ter
min
a
l
gr
oin
s

/
g
r
o
in field
Se
a
walls

/

re
v
etmen
t
Bre
a
k
wat
ers

Dre
d
g
i
n
g

Reloc
ati
o
n
of

ch
a
n
nel
or

il
t
Min
ed fo
r be
ach

fi
l
l

1 Oregon Inlet1 X X X
2 Hatteras Inlet X
3 Ocracoke Inlet X
4 New Old Drum Inlet
5 Ophelia Inlet
6 Barden Inlet X X X
7 Beaufort Inlet X X X
8 Bogue Inlet X X X X
9 Bear Inlet
10 Brown’s Inlet
11 New River Inlet X X X X
12 New Topsail Inlet X X
13 Rich Inlet P X P X
14 Mason Inlet X X X X
15 Masonboro Inlet X D X X X
16 Carolina Beach Inlet X X X
17 Cape Fear River X X
18 Lockwoods Folly Inlet P X 19 Shallotte Inlet P X X
20 Tubbs Inlet X X X X 1 – The NCDOT mined ~33,000 cy of sediment from within Oregon Inlet to fill a scour hole adjacent to the Herbert C. Bonner Bridge across the inlet in December 2013, which had destabilized the bridge and led to its emergency closure.

Inlets associated with ports and other high-traffic areas typically have maintenance dredging
conducted annually, if not more often. At four shallow-draft inlets (Bogue, Topsail, Carolina
Beach, and Lockwoods Folly) the Corps has typically dredged the inlet on a quarterly basis, and
maintained inlet crossings and connecting channels every one to two years (NCDENR, 2015).

78
Local governments have received authorization to also conduct maintenance dredging of these
inlets on the same general schedule, with beach disposal during the winter work window. Inlets
that are mined for Coastal Storm Damage Reduction (CSDR) projects (conducted by the Corps
or local governments) are typically dredged on three-year intervals, with placement of the sand
on the adjacent shoreline. Dredging may remove intertidal shoals and unvegetated sandy habitat
on inlet shoulders. The average apparent survival rate of Great Lakes plovers at Topsail Inlet
(Table 10, page 70) is similar to other inlets in the Southeast Atlantic where inlet dredging
projects or other inlet modification projects are conducted. It is currently unclear how much of a
role recreational use plays in the survival rate at these inlets.

Since 2012, several North Carolina tidal inlets have been dredged regularly for navigation
purposes. Oregon Inlet continues to be dredged frequently for navigation and other purposes. In
late 2015 the NC Department of Transportation (NCDOT) dredged a channel on the west side of
Hatteras Inlet to maintain navigational access in and around Hatteras Inlet. The material was
sidecast next to the dredged channel (USACE 2015a; Kozak 2016). Ocracoke Inlet was dredged
by the Corps with a sidecast dredge in 2013 (Hinnant 2013). Portions of Beaufort Inlet are
dredged yearly or more often than yearly, in order to maintain navigation access to the Morehead
City State Port Terminal. Sediment disposal may be to Bogue Banks, to an upland disposal site,
or to the Offshore Dredged Material Disposal Site (ODMDS). Beaufort Inlet was dredged in
2013, 2014, and 2017, with dredged sediment placed on Bogue Banks to the west in 2014 (Hibbs
2013, 2014). Similarly, portions of the Lower Cape Fear River are dredged each year to
maintain navigation to Wilmington Harbor, with dredged material placed on adjacent beaches
(Bald Head Island or Caswell and Oak Island Beaches) or the ODMDS. The Wilmington Harbor
Inner Ocean Bar was dredged in 2017 with placement of sand on Caswell and Oak Island
Beaches. Carolina Beach Inlet was dredged with a USACE sidecast dredge in 2013. In 2015
Carolina Beach Inlet was dredged by the Corps, state and New Hanover County, with the
material placed in a nearshore disposal site off Carolina Beach (Hinnant 2013, Lane 2015).
Lockwoods Folly Inlet was dredged by the Corps in 2013 (Hinnant 2013). The Town of Oak
Island dredged Eastern Channel, part of the Lockwoods Folly Inlet complex, in 2015 and
removed over 3 acres of emergent shoal habitat; the beach-compatible portion of the dredged
material was placed on the beach of west Oak Island. The Corps dredged the AIWW and
portions of Lockwoods Folly Inlet in 2016-2017 and placed the sand on Holden Beach (Hughes
Pers. Comm. 2017). Cow Channel was dredged in early 2017 and the material placed on Bear
Island within Hammocks Beach State Park (Corey Pers. Comm. 2017).

According to Rice (2016), at least 10 inlets have been mined for sediment for beach nourishment
projects in North Carolina. Shallotte Inlet was mined in 2001 and 2014, Bogue Inlet in 2005,
Barden Inlet in 2006, and Rich Inlet (or Nixon Channel) seven times between 1983 and 2011.
More recently, Mason Inlet was mined in 2005, 2009, 2011, 2012-2013 and early 2016. Oregon
Inlet was mined in 2013. New River Inlet was mined in 2012-13 as part of an inlet channel
relocation project. New Topsail Inlet was mined in 2012 and 2015. The most recent project plans
for the federal and local Carolina and Kure Beach CSDR Projects identify Carolina Beach Inlet

79
as a primary sediment source; sediment dredged from the inlet has been placed periodically on
Carolina Beach for storm damage reduction since the 1960s. Similarly, sediment removed from
the inlet has been used as beach fill on Wrightsville Beach for storm damage reduction since the
early 1960’s.

Seven North Carolina inlets have been mined for beach sand in the past 5 years. Four of these
are sites that have been mined previously, while three have not. The NCDOT mined
approximately 33,000 cy of sediment from within Oregon Inlet in 2013 to provide sand to fill for
a scour hole adjacent to the Herbert C. Bonner Bridge in another location of the inlet (USACE
2013). New Topsail Inlet was mined in 2012 and 2015 by the Town of Topsail Beach to provide
sand for beach nourishment. In 2013, the inlet channel of New River Inlet was relocated, and
the dredged material used to fill the beach on North Topsail Beach (USACE 2015b). In
February 2017, the Town of North Topsail Beach received a modified permit to modify the ebb
tide channel position within New River Inlet.

The four inlets that have been mined previously include Mason Inlet, Shallotte Inlet, Carolina
Beach Inlet, and Masonboro Inlet. In many cases, these inlets are both managed for navigation
and alternatively mined for sand for beach nourishment. Mason Inlet was mined in 2011, 2013,
and 2016 to provide beach fill for Figure Eight Island and to maintain Mason Inlet within a
specific inlet corridor. In 2014 and 2017, the Corps mined Shallotte Inlet to nourish adjacent
Ocean Isle Beach, pursuant to the Corps’ CSDR project (Ocean Isle Beach 2015; Hughes Pers.
Comm. 2017). Carolina Beach Inlet was mined in 2013 and 2017 for beach fill on Carolina
Beach. Masonboro Inlet was mined in 2014 for beach fill on Wrightsville Beach (USFWS
2016a; 2016b).

In some cases, sand has been dredged from the AIWW or inlets and placed within the sounds to
improve habitat for migrating and nesting shorebirds. There are several “bird islands” along the
sound shorelines which intermittently receive sand from navigation projects. In 2017, the Corps
dredged Old House Channel to Oregon inlet and placed the sand on bird islands near Manteo
(Hughes Pers. comm. 2017). Also in 2017, Carteret County dredged Wainwright Slough and
placed the sand on the adjacent Wainwright Island. More such projects are planned in the near
future, such as proposed placement of material dredged from the lower Cape Fear River on South
Pelican and Ferry Slip Islands to restore these small islands for waterbird habitat.

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Shoreline Stabilization and Armoring:

In 2017, there are 4 jetties and 34 groins along the North Carolina coast, and sandbags, sandbag
revetments, groins, and jetties have been placed along at least 9.05 miles of North Carolina
shoreline (Rice 2017). See Table 14 for data from Rice (2017).

Sandbags on private properties provide stabilization to a significant portion of the North Carolina
shoreline. Rice (2017) estimated 152 separate sandbag structures along the North Carolina beach
shoreline. If multiple properties each had an individual seawall protecting their property and the
seawalls were attached to each other with no gaps, then Rice (2017) counted the armoring as one
structure (per Dallas et al. 2013) and measured the overall length.

Rice (2017) estimated that 24 of 37 North Carolina coastal communities have been modified by
armor. In these communities, the proportion of armored sandy beach habitat was as high as
18%. Four communities exceed 10% of the shoreline armored: Kitty Hawk (18%), Bald Head
Island (13%), Kure Beach (11%), and Ocean Isle Beach (10%).

In North Carolina, there are three currently existing terminal groins: along Oregon Inlet, at Fort
Macon along Beaufort Inlet in Carteret County, and on Bald Head Island in New Hanover
County. The terminal groin on Bald Head Island was installed in 2015, but the other two
(Oregon Inlet and Fort Macon) were installed decades ago, and downdrift erosion has been
severe at both, requiring frequent nourishment (Pietrafesa 2012; Riggs et al 2009). The Fort
Macon groin is fronted by a larger structure that Rice (2016) refers to as jetty.

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Table 14. Approximate number of each type of armoring visible on the oceanfront beach
in each community in North Carolina visible on Google Earth imagery between 1993 and
late 2015 / early 2016. Multiple seawalls, bulkheads or revetments are counted as one
structure if they are continuous with no separations.

Community Number of
Groins
Number of
Jetties
Number of
Seawalls,
Bulkheads
and/or
Revetments
Number of
Breakwaters
Corolla 0 0 2 0
Duck 0 0 0 0
Southern Shores 0 0 0 0
Kitty Hawk 0 0 12 0
Kill Devil Hills 7 0 11 0
Nags Head 0 0 29 0
Rodanthe 1 0 4 0
Salvo 0 0 0 0
Avon 0 0 0 0
Buxton 3 0 1 0
Frisco 0 0 0 0
Hatteras 0 0 0 0
Ocracoke 0 0 0 0
Cape Lookout NS
(Portsmouth Island to
Shackleford Banks)1
0 1 0 1
Atlantic Beach2 0 1 10 0
Pine Knoll Shores 0 0 6 0
Indian Beach 0 0 0 0
Salter Path 0 0 0 0
Emerald Isle 0 0 4 0
Swansboro Township
(Hammocks Beach SP) 0 0 0 0
Camp Lejeune 0 0 0 0
North Topsail Beach3 0 0 9 0
Surf City 0 0 10 0
Topsail Beach 0 0 14 0
Topsail Township (Lea-
Hutaff Island) 0 0 0 0
Figure 8 Island3 0 0 3 0

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Community Number of
Groins
Number of
Jetties
Number of
Seawalls,
Bulkheads
and/or
Revetments
Number of
Breakwaters
Wrightsville Beach 0 1 0 0
Masonboro Island 0 1 0 0
Carolina Beach 0 0 1 0
Kure Beach 0 0 2 0
Federal Point Township 0 0 0 0
Bald Head Island 23 0 1 0
Caswell Beach 0 0 1 0
Oak Island 0 0 17 0
Holden Beach3 0 0 5 0
Ocean Isle Beach3 0 0 10 0
Sunset Beach4 0 0 0 0
TOTAL 34 4 152 1
1 – A breakwater / jetty structure constructed in 1914-17 is present near Barden Inlet at Cape Lookout. A
landlocked jetty / breakwater structure was constructed on the Beaufort Inlet shoreline of Shackleford Banks in
1882 but is currently landlocked (Coburn et al. 2010).
2 – The jetty at Fort Macon SP in Atlantic Beach is referred to as a terminal groin by some sources. One additional
groin is located on the inlet shoreline of Fort Macon SP but was buried in 2015 and is not included here due to
its location on the inlet shoreline, rather than the oceanfront shoreline.
3 – Terminal groins have been proposed or are under development for the inlet shorelines of North Topsail Beach,
Figure 8 Island, Holden Beach and Ocean Isle Beach.
4 – One jetty at Little River Inlet is located on the southern tip of Bird Island / Sunset Beach, but is located within
the state of South Carolina.

The Oregon Inlet and Fort Macon Groins are located on the updrift side of the island, but
accretion in these areas is not significant due to scour. At Oregon Inlet, there is no sandy habitat
on the inlet shoulder updrift of the groin and revetment, and there has not been for decades.
There are two degraded groin/jetty structures in Dare County, adjacent to the old location of the
Cape Hatteras lighthouse. The Service has issued BOs for the authorization of two other
terminal groins (Towns of Ocean Isle Beach and Holden Beach), and the Figure “Eight”
Homeowners Association is currently (2017) seeking authorization to construct a terminal groin
on the north end of Figure Eight Island (south side of Rich Inlet). Also, in 2015, the North
Carolina legislature revised state regulations to allow additional terminal groins to be constructed
at New River Inlet and Bogue Inlet. However, it is unclear whether the local governments in the
vicinity of these two inlets will propose the construction of a terminal groin. The south jetty
along Masonboro Inlet was repaired by the Corps in 2013 and 2014 (USACE 2015c).

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There are two existing rock revetments along the coast of North Carolina: one at Fort Fisher
(approximately 3,040 lf), and another along Carolina Beach (approximately 2,050 lf). Sandbags
and sandbag revetments have been placed along at least 1,800 lf of the eastern shoreline on
Ocean Isle Beach, and the Tubbs Inlet shoreline on Ocean Isle Beach is completely lined with a
sandbag revetment. A sandbag revetment at least 1,800 lf long (with a geotube in front of a
portion) was constructed in 2015 at the north end of North Topsail Beach, and more sandbags
were added in 2016 to protect a parking lot north of the revetment. In 2000 and 2001, sandbag
revetments were installed on the north end of Figure Eight Island along Surf Court, Inlet Hook
Road, and Comber Road.

Beach scraping can artificially steepen beaches, stabilize dune scarps, plug dune gaps, and
redistribute sediment distribution patterns. Artificial dune building, often a product of beach
scraping, removes low-lying overwash areas and dune gaps. As chronic erosion catches up to
structures throughout the Action Area, artificial dune systems are constructed and maintained to
protect beachfront structures either by sand fencing or fill placement. Beach scraping or
bulldozing has become more frequent on North Carolina beaches in the past 20 years, in
response to storms and the continuing retreat of the shoreline with rising sea level. From 2012 to
2015, Rice (2017) estimated that at least 4.84 miles of the North Carolina shoreline was
impacted by beach scraping. These activities primarily occur during the winter months, when
migrating and overwintering plovers may be present. Artificial dune or berm systems have been
constructed and maintained in several areas. These dunes make the artificial dune ridge function
like a seawall that blocks natural beach retreat, evolution, and overwash.

Beach raking and rock-picking: Man-made beach cleaning and raking machines effectively
remove seaweed, fish, glass, syringes, plastic, cans, cigarettes, shells, stone, wood, and virtually
any unwanted debris (Barber Beach Cleaning Equipment 2009). These efforts may remove
accumulated wrack, topographic depressions, and sparse vegetation nodes used by roosting and
foraging piping plovers. Removal of wrack also eliminates a beach’s natural sand-trapping
abilities, further destabilizing the beach. In addition, sand adhering to seaweed and trapped in
the cracks and crevices of wrack is removed from the beach. Although the amount of sand lost
due to single sweeping actions may be small, it adds up considerably over a period of years
(Nordstrom et al. 2006; Neal et al. 2007). Beach cleaning or grooming can result in abnormally
broad unvegetated zones that are inhospitable to dune formation or plant colonization, thereby
enhancing the likelihood of erosion (Defreo et al. 2009). The Town of Carolina Beach rakes the
beach front in Freeman Park at least twice per year, including areas in piping plover critical
habitat unit NC-14. The Town of North Topsail Beach utilizes a rock-picker as needed, typically
annually, to remove rocky material from the beach berm along portions of its shoreline.

Sand Fencing: Rice (2017) estimates that 62.69 miles (19%) of North Carolina’s shoreline was
modified with sand fencing between 2012 and 2015. This length represents approximately 25%
of all of the sand fencing within the breeding range of the Atlantic Coast piping plover. Sand
fencing modified more than 50% of the sandy beach habitat in 6 communities: Pine Knoll

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Shores (97%), Kill Devil Hills (67%), Atlantic Beach (64%), Southern Shores (63%), Corolla
(53%) and Nags Head (53%). In 14 other coastal communities, between 20 and 50% of the
sandy beach habitat was modified by sand fencing between 2012 and early 2016. A total of
1,199 contiguous sections of sand fencing were identified on North Carolina’s oceanfront
beaches in the three years after Hurricane Sandy; only New Jersey had more contiguous sections
of sand fencing (1,305), but had a slightly lower total length of sandy beach modified by fencing
(60.26 miles, or 96.98 km) (Rice 2017). Sand fencing traps sand (typically lighter fine-grained
sand) and may stabilize continuous dunes in developed areas, thereby also degrading,
fragmenting, or eliminating sparsely vegetated and unvegetated habitats used by the piping
plover and other wildlife. Sand fencing may create steeper slopes, and alter the surrounding area
in a way that impedes shorebird nesting. For nesting, shorebirds typically prefer relatively flat
dune areas with coarser sand. The fencing also is a physical barrier that can block unfledged
chicks from getting from their nests to their food source, and the posts or stakes can serve as
perches for hawks and other predators that feed on the chicks (USFWS 2015, Massachusetts
Office of Coastal Management 2013).

Pedestrian Use of the Beach: There are a number of potential sources of pedestrians and pets on
North Carolina beaches, including those individuals originating from beachfront or boat access
points, public access points, and hotels, resorts, and residences. Elliott and Teas (1996) found a
significant difference in actions between piping plovers encountering pedestrians and those not
encountering pedestrians. Piping plovers encountering pedestrians spend proportionately more
time in non-foraging behavior. This study suggests that interactions with pedestrians on beaches
cause birds to shift their activities from calorie acquisition to calorie expenditure. In winter and
migration sites, human disturbance continues to decrease the amount of undisturbed habitat and
appears to limit local piping plover abundance (Zonick and Ryan 1996).

Disturbance also reduces the time migrating shorebirds spend foraging (Burger 1991). Pfister et
al. (1992) implicate disturbance as a factor in the long-term decline of migrating shorebirds at
staging areas. While piping plover migration patterns and needs remain poorly understood and
occupancy of a particular habitat may involve shorter periods relative to wintering, information
about the energetics of avian migration indicates that this might be a particularly critical time in
the species’ life cycle.

In many cases, dogs accompany pedestrians to the beach. Shorebirds are more likely to flush
from the presence of dogs than people, and breeding and nonbreeding shorebirds react to dogs
from farther distances than people (Lafferty 2001a, 2001b; Lord et al. 2001; Thomas et al. 2003).
Hoopes (1993) found that dogs flush breeding piping plovers from further distances than people
and that both the distance the plovers move and the duration of their response is greater.
Foraging shorebirds at a migratory stopover on Delaware Bay, New Jersey responded most
strongly to dogs compared with other disturbances; shorebirds often failed to return within ten
minutes after the dog left the beach (Burger et al. 2007). Dogs off-leash were disproportionate
sources of disturbance in several studies (Thomas et al. 2003; Lafferty 2001b), but leashed dogs

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also disturbed shorebirds. Pedestrians walking with dogs often go through flocks of foraging and
roosting shorebirds; some even encourage their dogs to chase birds.

Horseback riding is allowed on North Carolina beaches including Emerald Isle, Hatteras Island,
and Carolina Beach (Freeman Park). Horseback riding may cause adverse impacts to piping
plover habitat, by causing compaction or erosion, trampling of wrack and vegetation, and
flushing of birds. In general, a horse and rider may cause greater individual static ground
pressure than cars, because of the small ground area over which the weight is spread (UK CEED
2000).

Off-Road Vehicles: Off-road vehicles can disrupt piping plover’s normal behavior patterns. The
density of off-road vehicles negatively correlated with abundance of piping plovers on the ocean
beach in Texas (Zonick 2000). Cohen et al. (2008) found that radio-tagged wintering piping
plovers using ocean beach habitat at Oregon Inlet in North Carolina were far less likely to use
the north side of the inlet where off-road vehicle use was allowed. Ninety-six percent of piping
plover detections occurred on the south side of the inlet even though it was more than four times
farther away from foraging sites (Cohen et al. 2008). In a study of migrating shorebirds in
Maryland, Forgues (2010) found that shorebird abundance declined with increased off-road
vehicle frequency, as did the number and size of roosts. Migrants spent less time foraging in the
presence of vehicles. In North Carolina, a before-after control-impact experiment using the
undisturbed plots as the controls found that vehicle disturbance decreased abundance of
shorebirds and altered their habitat use during fall migration (Tarr 2008). Recreational activities,
especially off-road vehicles, may degrade piping plover habitat. Tires that crush wrack into the
sand render it unavailable as a roosting habitat or foraging substrate (Goldin 1993; Hoopes
1993). Off-road vehicles are allowed on portions Cape Hatteras National Seashore (including
Ocracoke Island) and Cape Lookout National Seashore for most if not all of the year. Driving is
also allowed at Fort Fisher. Other communities which allow beach driving for at least portions
of the year include Corolla, Duck, Nags Head, Kill Devil Hills, Atlantic Beach, Emerald Isle,
Indian Beach, Salter Path, North Topsail Beach, Surf City, Topsail Beach, and Carolina Beach
(Pippin 2013). Most of them only allow driving outside of the sea turtle nesting season
(November to April).

Summary and synthesis of threats

A review of threats to piping plovers and their habitat in their migration and wintering range
shows a continuing loss and degradation of habitat due to sand placement projects, inlet
stabilization, sand mining, groins, seawalls and revetments, dredging of canal subdivisions,
invasive vegetation, wrack removal, and recreational use. This cumulative habitat loss is, by
itself, of major threat to piping plovers, as well as the many other shorebird species competing
with them for foraging resources and roosting habitats in their nonbreeding range. However,
artificial shoreline stabilization also impedes the processes by which coastal habitats adapt to
storms and accelerating sea level rise, thus setting the stage for compounding future losses.

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Furthermore, inadequate management of increasing numbers of beach recreationists reduces the
functional suitability of coastal migration and wintering habitat and increases pressure on piping
plovers and other shorebirds depending upon a shrinking habitat base. Experience during the
Deepwater Horizon oil spill illustrates how, in addition to the direct threat of contamination, spill
response activities can result in short- and long-term effects on habitat and disturb piping plovers
and other shorebirds. If climate change increases the frequency and magnitude of severe weather
events, this may pose an additional threat. The best available information indicates that other
threats are currently low, but vigilance is warranted, especially in light of the potential to
exacerbate or compound effects of very significant threats from habitat loss and degradation and
from increasing human disturbance.

2.3. Effects of the Action

This section is an analysis of the beneficial, direct and indirect effects of the proposed action on
migrating and wintering piping plovers within the Action Area. The analysis includes effects
interrelated with and interdependent of the project activities. An interrelated activity is an
activity that is part of a proposed action and depends on the proposed activity. An
interdependent activity is an activity that has no independent utility apart from the action.

2.3.1. Factors to be considered

The proposed project will occur within habitat for migrating, wintering, and breeding piping
plovers and construction will occur during a portion of the migration, winter, and breeding
seasons. Long-term and permanent impacts could preclude the creation of new habitat and
increase recreational disturbance. Short-term and temporary impacts to piping plovers could
result from project work disturbing roosting plovers and degrading currently occupied adjacent
foraging areas.

Proximity of the action: Sand placement would occur within and adjacent to foraging, roosting,
and breeding habitats for migrating, wintering, or breeding piping plovers.

Distribution: Project construction activities that may impact migrating, wintering, or breeding
piping plovers would occur along the North Carolina shoreline.

Timing: The timing of project construction could directly and indirectly impact migrating,
wintering, and/or breeding piping plovers. Piping plovers may be present year-round in the
Action Area.

Nature of the effect: The effects of the project construction include a long-term reduction in
foraging, roosting, and nesting habitat, a long-term decreased rate of change that may preclude
habitat creation. A decrease in the survival of piping plovers on the migration and winter
grounds due to the lack of optimal habitat may contribute to decreased survival rates, decreased

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productivity on the breeding grounds, and increased vulnerability to the three populations.
The Service expects the action will result in direct and indirect, long-term effects to piping
plovers. The Service expects there may be morphological changes to adjacent piping plover
habitat, including roosting, foraging, and nesting habitat. Activities that affect or alter the use of
optimal habitat or increase disturbance to the species may decrease the survival and recovery
potential of the piping plover.

Duration: These may be recurring activities, expected to last as long as five and a half months
each time. Thus, the direct effects would be expected to be short-term in duration. Indirect
effects from the activity may continue to impact migrating, wintering, and breeding piping
plovers in subsequent seasons after sand placement.

Disturbance frequency: Disturbance from each event will be short term, lasting up to two years.
However, sand placement activities may take place several times over the life of each project. In
addition, several sand placement projects may be conducted in concurrent or consecutive years,
including in adjacent foraging, roosting, and nesting habitats. Recreational disturbance may
increase after project completion and have long-term impacts.

Disturbance intensity and severity: Project construction is anticipated to be conducted during
portions of the piping plover migration, winter, and breeding seasons. Conservation measures
have been incorporated into the project to minimize impacts. The Action Area encompasses an
area in the nesting, migration, and wintering range of the piping plover. Plovers located within
the Action Area are expected to move outside of the construction zone due to disturbance;
therefore, no plovers are expected to be directly taken as a result of this action.

2.3.2. Analyses for effects of the action

Beneficial effects: For some highly eroded beaches, sand placement will have a beneficial effect
on the habitat’s ability to support wintering and nesting piping plovers. Narrow beaches that do
not support a productive wrack line may see an improvement in foraging habitat available to
piping plovers following sand placement. The addition of sand to the sediment budget may also
increase a sand-starved beach’s likelihood of developing habitat features valued by piping
plovers, including washover fans and emergent nearshore sand bars. It is unclear whether this
programmatic opinion will be utilized mostly on highly eroded beaches.

Direct effects: Direct effects are those direct or immediate effects of a project on the species or
its habitat. The construction window will extend through the piping plover migration and winter
season and into the beginning of the breeding season. Since piping plovers can be present on
these beaches year-round, construction is likely to occur while this species is utilizing these
beaches and associated habitats. Heavy machinery and equipment (e.g., trucks and bulldozers
operating in Action Area) may adversely affect piping plovers in the Action Area by disturbance
and disruption of normal activities such as roosting and foraging, and possibly forcing birds to

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expend valuable energy reserves to seek available habitat elsewhere. Burial and suffocation of
invertebrate species will occur during the sand placement, and will affect up to 25 miles of
shoreline annually in North Carolina. In years following major storm events, the PBA states that
a 250% increase in average annual nourishment can reasonably be expected. Therefore, in post-
storm years, a maximum length of nourishment may be 62.5 miles (25 miles plus the additional
27.5 miles).

Indirect effects: The proposed project includes placement of sand as a protective element against
shoreline erosion to protect man-made infrastructure. Indirect effects include reducing the
potential for the formation of optimal habitats. The proposed project may limit the creation of
optimal foraging and roosting habitat, and may increase the attractiveness of these beaches for
recreation, increasing recreational pressures within the Action Area. Recreational activities that
potentially adversely affect plovers include disturbance by unleashed pets and increased
pedestrian use.

2.3.3. Species’ response to the proposed action

The Service anticipates potential adverse effects throughout the Action Area by limiting
proximity to roosting, foraging, and nesting habitat and degrading occupied foraging, roosting
and nesting habitat, and increasing disturbance from increased recreational use. Piping plovers
have been documented foraging and roosting within the project area.

2.4. Cumulative Effects

This project may occur on federal or non-federal lands. Cumulative effects include the effects of
future State, tribal, local, or private actions that are reasonably certain to occur in the Action
Area considered in this biological opinion. Future Federal actions that are unrelated to the
proposed action are not considered in this section, because they require separate consultation
pursuant to section 7 of the Act. It is reasonable to expect continued shoreline stabilization, inlet
dredging, sand placement projects, sand fencing, and beach scraping along the North Carolina
shoreline in the future since erosion and sea-level rise increases would impact the existing
beachfront development. However, with the exception of some of the above-listed project types,
most of the future actions that are reasonable certain to occur will require a Clean Water Act
(CWA) Section 404 permit, and thus will require separate consultation.

2.5 Conclusion

After reviewing the current status of the wintering piping plover populations from all three
breeding populations, the environmental baseline for the Action Area, the effects of the proposed
activities, the proposed Conservation Measures, and the cumulative effects, it is the Service’s
biological opinion that implementation of these actions, as proposed, is not likely to jeopardize
the continued existence of the three breeding populations of piping plover.

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• Construction will occur and/or will likely have an effect on up to 25 miles of shoreline
annually during nonemergency years, and up to 62.5 miles of shoreline annually during
emergency years.
• Piping plovers have been documented in the Action Area.
• Short-term and temporary impacts to piping plover activities could result from project
work occurring on the beach that flushes birds from roosting, foraging, or nesting habitat.
• Long-term impacts could include a hindrance in the ability of migrating or wintering
piping plovers to recuperate from their migratory flight from their breeding grounds,
survive on their wintering areas, or to build fat reserves in preparation for migration.
• The survival and recovery of all breeding populations of piping plovers are
fundamentally dependent on the continued availability of sufficient habitat in their
coastal migration and wintering range.
• All piping plover populations are inherently vulnerable to even small declines in their
most sensitive vital rates, i.e., survival of adults and fledged juveniles.

3. PIPING PLOVER WINTERING CRITICAL HABITAT

3.1. Status of the Critical Habitat

The Act defines critical habitat as the specific areas within the geographical area occupied by the
species, at the time it is listed in accordance with the provisions of section 4 of the Act, on which
are found those physical or biological features (1) essential to the conservation of the species and
(2) which may require special management considerations or protection, as well as specific areas
outside the geographical area occupied by the species at the time it is listed in accordance with
the provisions of section 4 of the Act, upon a determination by the Secretary that such areas are
essential for the conservation of the species (16 U.S.C. 1532(5)(A)).

This section summarizes the effects of all past human and natural activities or events that have
led to the current status of designated critical habitat for the piping plover and are relevant to
formulating the biological opinion about the proposed action.

3.1.1. Critical Habitat Description and Status

In 2001, critical habitat was designated for the breeding population in the Great Lakes region
(USFWS 2001a), while a separate rule determined critical habitat for the U.S. portion of the
Northern Great Plains breeding population in 2002 (USFWS 2002). No critical habitat has been
proposed or designated for the Atlantic Coast breeding population, but the needs of all three
breeding populations were considered in the 2001 critical habitat designation for wintering
piping plovers (USFWS 2001b) and in subsequent re-designations (USFWS 2008b; 2009c).
Critical habitat for wintering piping plovers currently comprises 141 units totaling 256,513 acres
along the coasts of North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi,
Louisiana, and Texas. The original designation included 142 areas (the rule erroneously states

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137 units) encompassing approximately 1,798 miles of mapped shoreline and 165,211 acres of
mapped areas (USFWS 2001b). A revised designation for four North Carolina units was
published in 2008 (USFWS 2008b). Eighteen revised Texas critical habitat units were
designated in 2009, replacing 19 units that were vacated and remanded by a 2006 court order
(USFWS 2009b). Designated areas include habitats that support roosting, foraging, and
sheltering activities of piping plovers.

In North Carolina, there are 18 designated critical habitat units for wintering piping plover, from
Oregon Inlet to Mad Inlet (Figures 7-8). See Appendix B for a figure and description of each
critical habitat unit.

Critical Habitat Physical and Biological Features (PBFs)

In accordance with section 3(5)(A)(i) and 4(b)(1)(A) of the ESA and regulations at 50 CFR
424.12, in determining which areas within the geographical area occupied by the species at the
time of listing to designate as critical habitat, the Service considers the physical or biological
features (PBFs) that are essential to the conservation of the species and which may require
special management considerations or protection.
These include, but are not limited to:

(1) Space for individual and population growth and for normal behavior;
(2) Food, water, air, light, minerals, or other nutritional or physiological requirements;
(3) Cover or shelter;
(4) Sites for breeding, reproduction, or rearing (or development) of offspring; and
(5) Habitats that are protected from disturbance or are representative of the historical,
geographic, and ecological distributions of a species.

The term ‘‘primary constituent elements’’ was introduced in the critical habitat designation
regulations (50 CFR 424.12) to describe aspects of the PBFs, which are referenced in the
statutory definition of critical habitat; the Services have proposed to remove the term ‘‘primary
constituent elements’’ and return to the statutory term ‘‘physical or biological features’’ for
future listings of critical habitat. See 79 FR 27066, May 12, 2014 and 81 FR 7214.

Critical Habitat Primary Constituent Elements

The PCEs essential for the conservation of wintering piping plovers are those habitat
components that support foraging, roosting, and sheltering and the physical features necessary
for maintaining the natural processes that support these habitat components. The PCEs include
intertidal beaches and flats (between annual low tide and annual high tide) and associated dune
systems and flats above annual high tide. Important components of intertidal flats include sand
and/or mud flats with no or very sparse emergent vegetation. In some cases, these flats may be
covered or partially covered by a mat of blue-green algae. Adjacent non-or sparsely-vegetated

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sand, mud, or algal flats above high tide are also important, especially for roosting piping
plovers, and are PCEs of piping plover wintering habitat. Such sites may have debris, detritus
(decaying organic matter), or micro-topographic relief (less than 50 cm above substrate surface)
offering refuge from high winds and cold weather. Important components of the beach/dune
ecosystem include surf-cast algae, sparsely vegetated backbeach and salterns (beach area above
mean high tide seaward of the permanent dune line, or in cases where no dunes exist, seaward of
a delineating feature such as a vegetation line, structure, or road), spits, and washover areas.
Washover areas are broad, unvegetated zones, with little or no topographic relief, that are formed
and maintained by the action of hurricanes, storm surge, or other extreme wave action. The units
designated as critical habitat are those areas that have consistent use by piping plovers and that
best meet the biological needs of the species. The amount of wintering habitat included in the
designation appears sufficient to support future recovered populations, and the existence of this
habitat is essential to the conservation of the species. Additional information on each specific
unit included in the designation can be found at 66 FR 36038 (USFWS 2001a).

Critical habitat does not include existing developed sites consisting of buildings, marinas, paved
areas, boat ramps, exposed oil and gas pipelines and similar structures. Only those areas
containing these PCEs within the designated boundaries are considered critical habitat.
Although 141 units totaling 256,513 acres along the coasts of North Carolina, South Carolina,
Georgia, Florida, Alabama, Mississippi, Louisiana, and Texas have been designated, not all units
are equally important depending on the presence, juxtaposition, and acreage of the PCEs and not
all units are equally important to the three breeding populations. Piping plovers from the three
breeding populations are not evenly distributed throughout their nonbreeding range (Gratto-
Trevor et al. 2012).

Distribution of Breeding Populations within Designated Critical Habitat in the Non-
breeding Range

Gratto-Trevor et al. (2012) emphasizes the significance of geographic differences between
wintering locations for the three piping plover populations. Plovers from eastern Canada and
most Great Lakes individuals wintered from North Carolina to Southwest Florida. However,
eastern Canada birds were more heavily concentrated in North Carolina, while a larger
proportion of Great Lakes piping plovers were found in South Carolina, Georgia, and Florida.
Very few individuals from the Great Lakes breeding population were observed in winter on the
Gulf Coast, west of Florida. Using information provided on inlets in Rice (2012a), the Service
determined that there are 151 inlets in the non-breeding range of the Great Lakes piping plover
population (including inlets from North Carolina to the Florida Gulf of Mexico shoreline).
Based on Rice (2012a), 19% of the inlets in piping plover critical habitat in this region have been
modified by dredging/mining, shoreline hardening, or relocation. Of these modified inlets,
approximately 34% are within piping plover critical habitat. In North Carolina, 16 of the 20
(75%) existing inlets are modified in some manner, most often by dredging (Table 13, page 77)

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(Rice 2016). This is higher than any other state in the non-breeding range of the Great Lakes
piping plover population (Rice 2012a).

3.1.2. Analysis of the Critical Habitat Likely to be Affected

There are many man-made activities that degrade or remove PCEs of piping plover wintering
critical habitat. Please see Appendix A (copied from the PBA) and Table 11 (Page 73) for a list
of activities conducted along the Atlantic Ocean shoreline in North Carolina.

Beach nourishment

At least 684 of 2,340 coastal shoreline mi (32% of beaches throughout the piping plover winter
and migration range in the U.S.) are bermed, nourished, or renourished, generally for recreational
purposes and to protect commercial and private infrastructure. The quantity and quality of
piping plover prey may also be affected by the placement of sediment for beach nourishment or
disposal of dredged material. Invertebrates may be crushed or buried during project construction.
Although some benthic species can burrow through a thin layer of additional sediment, thicker
layers (over 35 in (90 cm)) smother the benthic fauna (Greene 2002). By means of this vertical
burrowing, recolonization from adjacent areas, or both, the benthic faunal communities typically
recover. Recovery can take as little as 2 weeks or as long as 2 years, but usually averages 2 to 7
months (Greene 2002; Peterson and Manning 2001). Only a few percent of these impacts have
occurred within critical habitat mainly because nourishment is most often conducted adjacent to
infrastructure along the beachfront, rather than on the ends of islands near inlets.

Sand mining/dredging

Sand mining, the practice of extracting (dredging) sand from sand bars, shoals, and inlets in the
nearshore zone, is a less expensive source of sand than obtaining sand from offshore shoals for
beach nourishment. Sand bars and shoals are sand sources that move onshore over time and act
as natural breakwaters. Inlet dredging reduces the formation of exposed ebb and flood tidal
shoals considered to be primary or optimal piping plover roosting and foraging habitat.
Removing these sand sources can alter depth contours and change wave refraction as well as
cause localized erosion (Hayes and Michel 2008). Exposed shoals and sandbars are also
valuable to piping plovers, as they tend to receive less human recreational use (because they are
only accessible by boat) and therefore provide relatively less disturbed habitats for birds. Most
jettied inlets need maintenance dredging, but non-hardened inlets are often dredged as well.
According to Rice (2012; 2016), approximately 44% of the inlets in the non-breeding range have
been dredged or mined.

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Shoreline Stabilization

Many navigable mainland or barrier island tidal inlets along the Atlantic and Gulf of Mexico
coasts are stabilized with jetties, groins, or by seawalls and/or adjacent industrial or residential
development. This includes seawalls or adjacent development, which lock the inlets in place.
Rice (2012a) created database of the inlets within the migration and wintering range of the
piping plover, including identification of existing hard structures or other habitat modifications.
Several studies highlight concerns about adverse effects of development and coastline
stabilization on the quantity and quality of habitat for migrating and wintering piping plovers and
other shorebirds. For example, Zdravkovic and Durkin (2011) observed fewer plovers on the
developed portions of the Laguna and Gulf beach sides of South Padre Island than on
undeveloped portions during both migratory and wintering surveys. Drake et al. (2001) observed
that radio-tagged piping plovers overwintering along the southern Laguna Madre of Texas
seldom used tidal flats adjacent to developed areas (five of 1,371 relocations of radio-marked
individuals), suggesting that development and associated anthropogenic disturbances influence
piping plover habitat use.

Groins (structures made of concrete, rip rap, wood, or metal built perpendicular to the beach in
order to trap sand) are typically found on developed beaches with severe erosion. Although
groins can be individual structures, they are often clustered along the shoreline. Groins can act
as barriers to longshore sand transport and cause downdrift erosion (Hayes and Michel 2008),
resulting in the loss of habitat and preventing future piping plover habitat creation by limiting
sediment deposition and accretion. As sand fills the area updrift from the groin or jetty, some
littoral drift and sand deposition on adjacent downdrift beaches may occur due to spillover.
However, these groins and jetties often force the stream of sand into deeper offshore water where
it is lost from the system (Kaufman and Pilkey 1979). The loss of sand from the inlet system can
be exacerbated by inlet dredging and disposal outside of the inlet. Groins deflect longshore
currents offshore. This aggravates downdrift erosion and erosion escarpments are common on
the downdrift side of groins (Humiston and Moore 2001). Rice (2016) found that several inlets
along the Atlantic Coast have hard stabilization structures such as jetties or groins along the
entire inlet shoreline that have eliminated all sandy beach habitat from the inlet shoulders.
Terminal groins along adjacent developed areas can alter erosion and accretion patterns and
diminish the magnitude of the inlet cycle. As an example, the stabilization and dredging of
Shinnecock Inlet on Long Island’s South Shore in New York has directly negatively affected the
inlet’s ebb shoal equilibrium since construction in 1940. Buonaiuto et al. (2008) found that these
impacts will persist for nearly 150 years and possibly longer. As of 2008, the ebb shoal had only
reached approximately 60% of its estimated equilibrium volume and it is expected to take
another 75 years to reach full equilibrium. If the ebb shoal is mined or dredged, the time for
recovery will increase.

Seawalls and revetments are vertical hard structures built parallel to the beach in front of
buildings, roads, and other facilities to protect them from erosion. However, these structures

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often accelerate erosion by causing scouring in front of and downdrift from the structure (Hayes
and Michel 2008), which can eliminate intertidal foraging habitat and adjacent roosting habitat.
Seawalls confine the wave energy and intensify the erosion by concentrating the sediment
transport processes in an increasingly narrow zone. Eventually, the beach disappears, leaving the
seawall directly exposed to the full force of the waves (Williams et al 1995). Physical
characteristics that determine microhabitats and biological communities can be altered after
installation of a seawall or revetment, thereby depleting or changing composition of benthic
communities that serve as the prey base for piping plovers. Geotubes (long cylindrical bags
made of high-strength permeable fabric and filled with sand) and sandbag revetments are softer
alternatives, but act as barriers by preventing overwash. We did not find any sources that
summarize the linear extent of seawall, revetment, and geotube installation projects that have
occurred across the piping plover’s wintering and migration habitat.

Inlet Relocation

Tidal inlet relocation can cause loss and/or degradation of piping plover habitat; although less
permanent than construction of hard structures, effects can persist for years. Service biologists
are aware of at least seven inlet relocation projects (two in North Carolina, three in South
Carolina, two in Florida), but this number likely under-represents the extent of this activity.

The Mason Inlet Preservation Group (MIPG) has Corps authorization to conduct the Mason Inlet
Relocation Project (MIRP) at the south end of Figure Eight Island. The inlet relocation project is
conducted every 2-3 years, and may temporarily impact piping plover habitat, causing birds to
select other sites (USFWS 2006a). Ongoing stabilization and growth of vegetation the north end
of Wrightsville Beach due to the MIRP has led to a decline in the amount of suitable unvegetated
intertidal habitat available in the Mason Inlet area. The acreage of unvegetated intertidal flats
has significantly decreased, in part due to the lack of vegetation management in the Waterbird
Management Area on North Wrightsville Beach. Approximately 50-60 acres of unvegetated
intertidal flats was available within critical habitat unit NC-12 in 1998, prior to the project’s
initial construction (GoogleEarth©, accessed January 29, 2015). At that time, almost all
available habitat was on the south end of Figure Eight Island. In October 2014, the approximate
acreage of unvegetated intertidal flats in the same area was 22 to 28 acres (estimated from
Google Earth, accessed on January 29, 2015). This represents a degradation of about half of the
previously available intertidal flat habitat within piping plover critical habitat unit NC-12.

Exotic/invasive vegetation

The spread of coastal invasive plants is a threat to suitable piping plover habitat. Like most
invasive species, coastal exotic plants reproduce and spread quickly and exhibit dense growth
habits, often outcompeting native plant species. If left uncontrolled, invasive plants cause a
habitat shift from open or sparsely vegetated sand to dense vegetation, resulting in the loss or

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degradation of piping plover roosting habitat, which is especially important during high tides and
migration periods.

Beach vitex (Vitex rotundifolia) is a woody vine introduced into the southeastern U.S. as a dune
stabilization and ornamental plant (Westbrooks and Madsen 2006). It currently occupies a very
small percentage of its potential range in the U.S. The species has been found on beaches in all
eight coastal counties in North Carolina and three counties in South Carolina. Small populations
have been found in Maryland, Virginia, Georgia, Florida and Alabama. Task forces formed in
North and South Carolina in 2004-2005 have made great strides to remove this plant from their
coasts. To date, over 800 sites in North Carolina have been treated, with an additional 100 sites
in need of treatment. Similar efforts are underway in South Carolina and several hundred sites
have been treated there (Suiter pers. comm. 2015).

Unquantified amounts of crowfootgrass (Dactyloctenium aegyptium) grow invasively along
portions of the Florida coastline. It forms thick bunches or mats that may change the vegetative
structure of coastal plant communities and alter shorebird habitat. The Australian pine
(Casuarina equisetifolia) changes the vegetative structure of the coastal community in south
Florida and islands within the Bahamas. Shorebirds prefer foraging in open areas where they are
able to see potential predators, and tall trees provide good perches for avian predators.
Australian pines potentially impact shorebirds, including the piping plover, by reducing
attractiveness of foraging habitat and/or increasing avian predation. The propensity of these
exotic species to spread, and their tenacity once established, make them a persistent threat,
partially countered by increasing landowner awareness and willingness to undertake eradication
activities.

The Australian pine (Casuarina equisetifolia) changes the vegetative structure of the coastal
community in south Florida and islands within the Bahamas. Shorebirds prefer foraging in open
areas where they are able to see potential predators, and tall trees provide good perches for avian
predators. Australian pines potentially impact shorebirds, including the piping plover, by
reducing attractiveness of foraging habitat and/or increasing avian predation. The propensity of
these exotic species to spread, and their tenacity once established, make them a persistent threat,
partially countered by increasing landowner awareness and willingness to undertake eradication
activities.

Wrack removal and beach cleaning or rock-picking

Wrack on beaches and baysides provides important foraging and roosting habitat for piping
plovers (Drake 1999a; Smith 2007; Maddock et al. 2009; Lott et al. 2009b) and many other
shorebirds on their winter, breeding, and migration grounds. Because shorebird numbers are
positively correlated with wrack cover and biomass of their invertebrate prey that feed on wrack
(Tarr and Tarr 1987; Hubbard and Dugan 2003; Dugan et al. 2003), grooming will lower bird
numbers (Defreo et al. 2009). There is increasing popularity in the Southeast, especially in

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Florida, for beach communities to carry out “beach cleaning” and “beach raking” actions. Beach
cleaning occurs on private beaches, where piping plover use is not well documented, and on
some municipal or county beaches that are used by piping plovers. Most wrack removal on state
and federal lands is limited to post-storm cleanup and does not occur regularly.

Man-made beach cleaning and raking machines effectively remove seaweed, fish, glass,
syringes, plastic, cans, cigarettes, shells, stone, wood, and virtually any unwanted debris (Barber
and Sons 2012). However, these efforts also remove accumulated wrack, topographic
depressions, and sparse vegetation nodes used by roosting and foraging piping plovers. Removal
of wrack also eliminates a beach’s natural sand-trapping abilities, further destabilizing the beach.
In addition, sand adhering to seaweed and trapped in the cracks and crevices of wrack is
removed from the beach. Although the amount of sand lost due to single sweeping actions may
be small, it adds up considerably over a period of years (Nordstrom et al. 2006; Neal et al. 2007).
Beach cleaning or grooming can result in abnormally broad unvegetated zones that are
inhospitable to dune formation or plant colonization, thereby enhancing the likelihood of erosion
(Defreo et al. 2009). The Town of Carolina Beach rakes the beach front in Freeman Park at
least twice per year, including areas in piping plover critical habitat unit NC-14. The Town of
North Topsail Beach utilizes a rock-picker as needed, typically annually, to remove rocky
material from the beach berm along portions of its shoreline.

3.2. Environmental Baseline

3.2.1. Status of Critical Habitat within the Action Area

The PCEs for piping plover critical habitat include intertidal beaches and flats, particularly those
with no or very sparse emergent vegetation. Adjacent non-or sparsely-vegetated sand, mud, or
algal flats above high tide are also important, especially for roosting. Important components of
the beach/dune ecosystem include surf-cast algae, sparsely vegetated backbeach and salterns
(beach area above mean high tide seaward of the permanent dune line, or in cases where no
dunes exist, seaward of a delineating feature such as a vegetation line, structure, or road), spits,
and washover areas.

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Figures 7-8. Nonbreeding piping plover designated critical habitat units NC-1 through SC-2.

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3.2.2. Factors Affecting Critical Habitat within the Action Area

Beach nourishment: North Carolina sandy beaches are regularly nourished with sand from the
Corps, other federally-funded projects, and private activities. Nourishment activities widen
beaches, change their sedimentology and stratigraphy, alter coastal processes and often plug
dune gaps and remove overwash areas. Beach nourishment or disposal of dredged material
typically crushes or buries invertebrate prey during project construction, suppressing prey
populations for months. Although some benthic species can burrow through a thin layer of
additional sediment, thicker layers (over 35 in (90 cm)) smother the benthic fauna (Greene
2002). Recovery can take as long as 2 years, but usually averages 2 to 7 months (Greene 2002;
Peterson and Manning 2001).

Inlet dredging activities alter the sediment dynamics on adjacent shorelines and stabilize these
dynamic environments; beach disposal of dredge material further alters the natural habitat
adjacent to inlets. Estuarine dredging of navigational channels can alter water circulation
patterns and sediment transport pathways, as well as increase the frequency and magnitude of
boat wakes; sound-side sand or mud flats may be impacted by increased erosion rates as a result.
Historically, there have been Federal navigation projects in the AIWW and in inlets along the
North Carolina coast for decades. During hundreds of dredging events, the sediment has been
placed on the adjacent beach using pipelines. Inlets associated with ports and other high-traffic
areas typically have maintenance dredging conducted annually, if not more often. At four
shallow-draft inlets within piping plover designated critical habitat (Bogue, Topsail, Carolina
Beach, and Lockwoods Folly), the Corps has typically dredged the inlet on a quarterly basis, and
maintained inlet crossings and connecting channels every one to two years (NCDENR, 2015).
Local governments have received authorization to also conduct maintenance dredging of these
inlets on the same general schedule, with beach disposal during the winter work window. Inlets
that are mined for Coastal Storm Damage Reduction (CSDR) projects (conducted by the Corps
or local governments) are typically dredged on three-year intervals, with placement of the sand
on the adjacent shoreline. Dredging may remove intertidal shoals and unvegetated sandy habitat
from critical habitat units.

Since 2012, several North Carolina tidal inlets within designated piping plover critical habitat
have been dredged regularly for navigation purposes. Oregon Inlet continues to be dredged
frequently for navigation and other purposes. In late 2015 the NC Department of Transportation
(NCDOT) dredged a channel on the west side of Hatteras Inlet to maintain navigational access in
and around Hatteras Inlet. The material was sidecast next to the dredged channel (USACE
2015a, Kozak 2016). Ocracoke Inlet was dredged by the Corps with a sidecast dredge in 2013
(Hinnant 2013). Carolina Beach Inlet was dredged with a USACE sidecast dredge in 2013. In
2015 Carolina Beach Inlet was dredged by the Corps, state and New Hanover County, with the
material placed in a nearshore disposal site off Carolina Beach (Hinnant 2013, Lane 2015).
Lockwoods Folly Inlet was dredged by the Corps in 2013 (Hinnant 2013). The Town of Oak
Island dredged Eastern Channel, part of the Lockwoods Folly Inlet complex, in 2015 and

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removed over 3 acres of emergent shoal habitat within the critical habitat unit; the beach-
compatible portion of the dredged material was placed on the beach of west Oak Island. The
Corps dredged the AIWW and portions of Lockwoods Folly Inlet in 2016-2017 and placed the
sand on Holden Beach (Hughes Pers. Comm. 2017).

According to Rice (2016), at least 10 inlets within designated critical habitat have been mined for
sediment for beach nourishment projects in North Carolina. Shallotte Inlet was mined in 2001
and 2014, Bogue Inlet in 2005, Barden Inlet in 2006, and Rich Inlet (or Nixon Channel) seven
times between 1983 and 2011. More recently, Mason Inlet was mined in 2005, 2009, 2011,
2012-2013 and early 2016. Oregon Inlet was mined in 2013. New River Inlet was mined in
2012-2013 as part of an inlet channel relocation project. New Topsail Inlet was mined in 2012
and 2015. The most recent project plans for the federal and local Carolina and Kure Beach
CSDR Projects identify Carolina Beach Inlet as a primary sediment source; sediment dredged
from the inlet has been placed periodically on Carolina Beach for storm damage reduction since
the 1960s. Similarly, sediment removed from the inlet has been used as beach fill on
Wrightsville Beach for storm damage reduction since the early 1960’s.

Seven North Carolina inlets have been mined for beach sand in the past 5 years. Four of these
are sites that have been mined previously, while three have not. The NCDOT mined
approximately 33,000 cy of sediment from within Oregon Inlet in 2013 to provide sand to fill for
a scour hole adjacent to the Herbert C. Bonner Bridge in another location of the inlet (USACE
2013). New Topsail Inlet was mined in 2012 and 2015 by the Town of Topsail Beach to provide
sand for beach nourishment (Town of North Topsail Beach 2015).

The four inlets that have been mined previously include Mason Inlet, Shallotte Inlet, Carolina
Beach Inlet, and Masonboro Inlet. In many cases, these inlets are both managed for navigation
and alternatively mined for sand for beach nourishment. Mason Inlet was mined in 2011, 2013,
and 2016 to provide beach fill for Figure Eight Island and to maintain Mason Inlet within a
specific inlet corridor. In 2014 and 2017, the Corps mined Shallotte Inlet to nourish adjacent
Ocean Isle Beach, pursuant to the Corps’ CSDR project (Ocean Isle Beach 2015, Hughes Pers.
Comm. 2017). Carolina Beach Inlet was mined in 2013 and 2017 for beach fill on Carolina
Beach. Masonboro Inlet was mined in 2014 for beach fill on Wrightsville Beach (USFWS
2016b and 2016c).

Groins: In North Carolina, there are three currently existing terminal groins, along Oregon Inlet,
at Fort Macon along Beaufort Inlet in Carteret County, and on Bald Head Island in New Hanover
County. The terminal groin on Bald Head Island was installed only two years ago, but the other
two (Oregon Inlet and Fort Macon) were installed decades ago, and downdrift erosion has been
severe at both, requiring frequent nourishment (Pietrafesa 2012; Riggs et al 2009). The Oregon
Inlet and Fort Macon Groins are located on the updrift side of the island, but accretion in these
areas is not significant due to scour. At Oregon Inlet, there is no sandy habitat on the inlet
shoulder updrift of the groin and revetment, and there has not been for decades. There are two

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degraded groin/jetty structures in Dare County, adjacent to the old location of the Cape Hatteras
lighthouse. The Service has issued BOs for the authorization of two other terminal groins
(Towns of Ocean Isle Beach and Holden Beach). Also, in 2015, the North Carolina legislature
revised state regulations to allow additional terminal groins to be constructed at New River Inlet
and Bogue Inlet. However, it is unclear whether the local governments in the vicinity of these
two inlets will propose the construction of a terminal groin.

Recreational Use: There are a number of potential sources of pedestrians, pets, horses, and
vehicles on North Carolina beaches. Pedestrians may originate from beachfront or boat access
points, public access points, and hotels, resorts, and residences. Many of North Carolina inlets,
particularly those near more populated areas, are regular gathering spots for boaters. It is
common for boaters to park on the inlet shoulders or inlet shoals. In winter and migration sites,
human disturbance continues to decrease the amount of undisturbed habitat and appears to limit
local piping plover abundance (Zonick and Ryan 1996).

Horseback riding is allowed on North Carolina beaches including Emerald Isle, Hatteras Island,
and Carolina Beach (Freeman Park). Horseback riding may cause adverse impacts to piping
plover habitat, by causing compaction or erosion, and trampling of wrack and vegetation. In
general, a horse and rider may cause greater individual static ground pressure than cars, because
of the small ground area over which the weight is spread (UK CEED 2000).

Off-road vehicles can disrupt piping plover’s normal behavior patterns. The density of off-road
vehicles negatively correlated with abundance of piping plovers on the ocean beach in Texas
(Zonick 2000). In addition, recreational activities, especially off-road vehicles, may degrade
piping plover habitat. Tires that crush wrack into the sand render it unavailable as a roosting
habitat or foraging substrate (Goldin 1993; Hoopes 1993). Off-road vehicles are allowed on
portions Cape Hatteras National Seashore (including Ocracoke Island) and Cape Lookout
National Seashore for most if not all of the year. Driving is also allowed at Fort Fisher. Other
communities which allow beach driving for at least portions of the year include Corolla, Duck,
Nags Head, Kill Devil Hills, Atlantic Beach, Emerald Isle, Indian Beach, Salter Path, North
Topsail Beach, Surf City, Topsail Beach, and Carolina Beach (Pippin 2013).

3.3. Effects of the Action

This section is an analysis of the beneficial, direct and indirect effects of the proposed action on
piping plover wintering critical habitat within the Action Area. Direct effects are caused by the
Action and occur at the same time and place. Indirect effects are caused by the Action, but are
later in time and reasonably certain to occur. The analysis includes effects interrelated and
interdependent of the project activities.

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3.3.1. Factors to be considered

The proposed projects may occur adjacent to or within piping plover critical habitat units, during
a portion of the migration and winter seasons. Short-term and temporary impacts could result
from project work degrading currently occupied foraging areas in the critical habitat unit. The
direct effects from sand placement would be expected to be short-term in duration, until the
benthic community reestablishes within the new beach profile.

3.3.2. Analyses for effects of the action

Beneficial effects: For some highly eroded beaches, sand placement will have a beneficial effect
on the habitat’s ability to support wintering and nesting piping plovers. Narrow beaches that do
not support a productive wrack line may see an improvement in foraging habitat available to
piping plovers following sand placement. The addition of sand to the sediment budget may also
increase a sand-starved beach’s likelihood of developing habitat features valued by piping
plovers, including washover fans and emergent nearshore sand bars. It is unclear whether this
programmatic opinion will be utilized mostly on highly eroded beaches.

Direct effects: Direct effects are those direct or immediate effects of a project on the species or
its habitat. The construction window will extend through one or more piping plover migration
and winter seasons. Since piping plovers can be present on these beaches year-round,
construction is likely to occur while this species is utilizing these beaches and associated
habitats. Direct effects include burial of invertebrate prey items and suppression of prey
populations, resulting in degradation of foraging habitat.

Indirect effects: Indirect effects include reducing the potential for the formation of PCEs and
foraging and roosting habitat, and increasing the attractiveness of these beaches for recreation,
thereby increasing recreational pressures within the Action Area.

Interrelated and Interdependent Actions: An interrelated activity is an activity that is part of the
proposed action and depends on the proposed action for its justification. An interdependent
activity is an activity that has no independent utility apart from the action under consultation.
The Service has addressed all interrelated and interdependent actions in the analysis of effects
above. Therefore, there are no interdependent or interrelated actions associated with the proposed
action that have not already been analyzed under the effects of the action, that are expected to
affect wintering piping plover critical habitat.

3.4. Cumulative Effects

This project may occur on federal or non-federal lands. Cumulative effects include the effects of
future State, tribal, local, or private actions that are reasonably certain to occur in the Action
Area considered in this biological opinion. Future Federal actions that are unrelated to the

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proposed action are not considered in this section, because they require separate consultation
pursuant to section 7 of the Act. It is reasonable to expect continued shoreline stabilization, inlet
dredging, sand placement projects, sand fencing, and beach scraping along the North Carolina
shoreline in the future since erosion and sea-level rise increases would impact the existing
beachfront development. However, with the exception of some of the above-listed project types,
most of the future actions that are reasonable certain to occur will require a Clean Water Act
(CWA) Section 404 permit, and thus will require separate consultation.

3.5. Conclusion

After reviewing the current status of piping plover wintering critical habitat, the environmental
baseline for the Action Area, the effects of the proposed activities, the proposed Conservation
Measures, and the cumulative effects, it is the Service’s biological opinion that the project is not
likely to destroy or adversely modify designated critical habitat for wintering piping plovers.

• An unknown acreage of critical habitat included in the PCEs may be degraded due to
burial of prey items.
• Approximately 19% of the inlets within critical habitat in the piping plover non-breeding
range have been modified (Rice 2012a).
• Of all inlets modified in the piping plover non-breeding range, 34% is within a critical
habitat unit (Rice 2012a).
• 40% of North Carolina’s 20 inlets are currently modified with hard shoreline stabilization
structures (groins, jetties, or revetments) (Rice 2016), and if the two proposed groins at
Lockwoods Folly Inlet and Shallotte Inlet are built, the percentage will increase to 50%,
resulting in fewer and fewer optimal habitats for migrating and wintering piping plovers.
• The modification of PCEs/PBFs in the action area will not cause an appreciable reduction
in the conservation value provided by all designated CH for the species.

4. RED KNOT

4.1. Status of the Species/Critical Habitat

4.1.1. Species/critical habitat description

On December 11, 2014, the Service listed the rufa red knot (Calidris canutus rufa) (or red knot)
as threatened throughout its range (79 FR 73706). The red knot is a medium-sized shorebird
about 9 to 11 inches (in) (23 to 28 centimeters (cm)) in length. The red knot migrates annually
between its breeding grounds in the Canadian Arctic and several wintering regions, including the
Southeast U.S. (Southeast), the Northeast Gulf of Mexico, northern Brazil, and Tierra del Fuego
at the southern tip of South America. During both the northbound (spring) and southbound (fall)
migrations, red knots use key staging and stopover areas to rest and feed. Red knots migrate

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through and overwinter in North Carolina. The term “winter” is used to refer to the nonbreeding
period of the red knot life cycle when the birds are not undertaking migratory movements. Red
knots are most common in North Carolina during the migration season (mid-April through May
and July to Mid-October), and may be present in the state throughout the year (Fussell 1994;
Potter et al. 1980). Wintering areas for the red knot include the Atlantic coasts of Argentina and
Chile, the north coast of Brazil, the Northwest Gulf of Mexico from the Mexican State of
Tamaulipas through Texas to Louisiana, and the Southeast U.S. from Florida to North Carolina
(Newstead et al. 2013; Niles et al. 2008). Smaller numbers of knots winter in the Caribbean, and
along the central Gulf coast, the mid-Atlantic, and the Northeast U.S. Little information exists
on where juvenile red knots spend the winter months (USFWS and Conserve Wildlife
Foundation 2012), and there may be at least partial segregation of juvenile and adult red knots on
the wintering grounds. There is currently no designation of critical habitat for red knot.

4.1.2. Life history

Each year red knots make one of the longest distance migrations known in the animal kingdom,
traveling up to 19,000 miles (mi) (30,000 kilometers (km) annually between breeding grounds in
the Arctic Circle and wintering grounds. Red knots undertake long flights that may span
thousands of miles without stopping. As they prepare to depart on long migratory flights, they
undergo several physiological changes. Before takeoff, the birds accumulate and store large
amounts of fat to fuel migration and undergo substantial changes in metabolic rates. In addition,
leg muscles, gizzard (a muscular organ used for grinding food), stomach, intestines, and liver all
decrease in size, while pectoral (chest) muscles and heart increase in size. Due to these
physiological changes, red knots arriving from lengthy migrations are not able to feed maximally
until their digestive systems regenerate, a process that may take several days. Because stopovers
are time-constrained, red knots require stopovers rich in easily-digested food to achieve adequate
weight gain (Niles et al. 2008; van Gils et al. 2005a; van Gils et al. 2005b; Piersma et al. 1999)
that fuels the next migratory flight and, upon arrival in the Arctic, fuels a body transformation to
breeding condition (Morrison 2006). Red knots from different wintering areas appear to employ
different migration strategies, including differences in timing, routes, and stopover areas.
However, full segregation of migration strategies, routes, or stopover areas does not occur among
red knots from different wintering areas (USFWS 2013a; USFWS 2013b).

Major spring stopover areas along the Mid- and South Atlantic coast include Río Gallegos,
Península Valdés, and San Antonio Oeste (Patagonia, Argentina); Lagoa do Peixe (eastern
Brazil, State of Rio Grande do Sul); Maranhão (northern Brazil); the Virginia barrier islands
(U.S.); and Delaware Bay (Delaware and New Jersey, U.S.) (Cohen et al. 2009; Niles et al. 2008;
González 2005). Important fall stopover sites include southwest Hudson Bay (including the
Nelson River delta), James Bay, the north shore of the St. Lawrence River, the Mingan
Archipelago, and the Bay of Fundy in Canada; the coasts of Massachusetts and New Jersey and
the mouth of the Altamaha River in Georgia, U.S.; the Caribbean (especially Puerto Rico and the
Lesser Antilles); and the northern coast of South America from Brazil to Guyana (Newstead et

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al. 2013; Niles 2012; Niles et al. 2010; Schneider and Winn 2010; Niles et al. 2008; Antas and
Nascimento 1996; Morrison and Harrington 1992; Spaans 1978). However, large and small
groups of red knots, sometimes numbering in the thousands, may occur in suitable habitats all
along the Atlantic and Gulf coasts from Argentina to Canada during migration (Niles et al. 2008;
USFWS 2013a; USFWS 2013b).

Some red knots wintering in the Southeastern U.S. and the Caribbean migrate north along the
U.S. Atlantic coast before flying overland to central Canada from the mid-Atlantic, while others
migrate overland directly to the Arctic from the Southeastern U.S. coast (Niles et al. 2012).
These eastern red knots typically make a short stop at James Bay in Canada, but may also stop
briefly along the Great Lakes, perhaps in response to weather conditions (Niles et al. 2008;
Morrison and Harrington 1992). Red knots are restricted to the ocean coasts during winter, and
occur primarily along the coasts during migration. However, small numbers of rufa red knots are
reported annually across the interior U.S. (i.e., greater than 25 miles from the Gulf or Atlantic
Coasts) during spring and fall migration—these reported sightings are concentrated along the
Great Lakes, but multiple reports have been made from nearly every interior State (eBird.org
2012; USFWS 2013a).

Long-distance migrant shorebirds are highly dependent on the continued existence of quality
habitat at a few key staging areas. These areas serve as stepping stones between wintering and
breeding areas. Conditions or factors influencing shorebird populations on staging areas control
much of the remainder of the annual cycle and survival of the birds (Skagen 2006; International
Wader Study Group 2003). At some stages of migration, very high proportions of entire
populations may use a single migration staging site to prepare for long flights. Red knots show
some fidelity to particular migration staging areas between years (Duerr et al. 2011; Harrington
2001).

Habitats used by red knots in migration and wintering areas are similar in character, generally
coastal marine and estuarine (partially enclosed tidal area where fresh and salt water mixes)
habitats with large areas of exposed intertidal sediments. In North America, red knots are
commonly found along sandy, gravel, or cobble beaches, tidal mudflats, salt marshes, shallow
coastal impoundments and lagoons, and peat banks (Cohen et al. 2010; Cohen et al. 2009; Niles
et al. 2008; Harrington 2001; Truitt et al. 2001). The supra-tidal (above the high tide) sandy
habitats of inlets provide important areas for roosting, especially at higher tides when intertidal
habitats are inundated (Harrington 2008; USFWS 2013a).

The red knot is a specialized molluscivore, eating hard-shelled mollusks, sometimes
supplemented with easily accessed softer invertebrate prey, such as shrimp- and crab-like
organisms, marine worms, and horseshoe crab (Limulus polyphemus) eggs (Piersma and van Gils
2011; Harrington 2001). Mollusk prey are swallowed whole and crushed in the gizzard (Piersma
and van Gils 2011). Foraging activity is largely dictated by tidal conditions, as red knots rarely
wade in water more than 0.8 to 1.2 in (2 to 3 cm) deep (Harrington 2001). Due to bill

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morphology, the red knot is limited to foraging on only shallow-buried prey, within the top 0.8 to
1.2 in (2 to 3 cm) of sediment (Gerasimov 2009; Zwarts and Blomert 1992).

The primary prey of the rufa red knot in non-breeding habitats include blue mussel (Mytilus
edulis) spat (juveniles); Donax and Darina clams; snails (Littorina spp.), and other mollusks,
with polychaete worms, insect larvae, and crustaceans also eaten in some locations. A prominent
departure from typical prey items occurs each spring when red knots feed on the eggs of
horseshoe crabs, particularly during the key migration stopover within the Delaware Bay of New
Jersey and Delaware. Delaware Bay serves as the principal spring migration staging area for the
red knot because of the availability of horseshoe crab eggs (Clark et al. 2009; Harrington 2001;
Harrington 1996; Morrison and Harrington 1992), which provide a superabundant source of
easily digestible food. In South Carolina, red knots appear to concentrate on Donax spp. as prey
items, until horseshoe crab eggs become available, and then the horseshoe crab eggs become the
main prey item (Melissa Bimbi pers. comm. 2015).

Red knots and other shorebirds that are long-distance migrants must take advantage of seasonally
abundant food resources at intermediate stopovers to build up fat reserves for the next non-stop,
long-distance flight (Clark et al. 1993). Although foraging red knots can be found widely
distributed in small numbers within suitable habitats during the migration period, birds tend to
concentrate in those areas where abundant food resources are consistently available from year to
year (USFWS 2013a).

4.1.3. Population dynamics

In the U.S., red knot populations declined sharply in the late 1800s and early 1900s due to
excessive sport and market hunting, followed by hunting restrictions and signs of population
recovery by the mid-1900s (Urner and Storer 1949; Stone 1937; Bent 1927). However, it is
unclear whether the red knot population fully recovered its historical numbers (Harrington 2001)
following the period of unregulated hunting. More recently, long-term survey data from two key
areas (Tierra del Fuego wintering area and Delaware Bay spring stopover site) both show a
roughly 75 percent decline in red knot numbers since the 1980s (Dey et al. 2011; Clark et al.
2009; Morrison et al. 2004; Morrison and Ross 1989; Kochenberger 1983; Dunne et al. 1982;
Wander and Dunne, 1982; USFWS 2013a).

For many portions of the knot’s range, available survey data are patchy. Prior to the 1980s,
numerous natural history accounts are available, but provide mainly qualitative or localized
population estimates. No population information exists for the breeding range because, in
breeding habitats, red knots are thinly distributed across a huge and remote area of the Arctic.
Despite some localized survey efforts, (e.g., Niles et al. 2008), there are no regional or
comprehensive estimates of breeding abundance, density, or productivity (Niles et al. 2008).

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Counts in wintering areas are useful in estimating red knot populations and trends because the
birds generally remain within a given wintering area for a longer period of time compared to the
areas used during migration. This eliminates errors associated with turnover or double-counting
that can occur during migration counts. Harrington et al. (1988) reported that the mean count of
birds wintering in Florida was 6,300 birds (± 3,400, one standard deviation) based on 4 aerial
surveys conducted from October to January in 1980 to 1982. Based on these surveys and other
work, the Southeast wintering group was estimated at roughly 10,000 birds in the 1970s and
1980s (Harrington 2005a; USFWS 2013b).

Based on resightings of birds banded in South Carolina and Georgia from 1999 to 2002, the
Southeast wintering population was estimated at 11,700 ± 1,000 (standard error) red knots.
Although there appears to have been a gradual shift by some of the southeastern knots from the
Florida Gulf coast to the Atlantic coasts of Georgia and South Carolina, population estimates for
the Southeast region in the 2000s were at about the same level as during the 1980s (Harrington
2005a). Based on recent modeling using resightings of marked birds staging in Georgia in fall,
as well as other evidence, the Southeast wintering group may number as high as 20,000
(Harrington pers. comm. 2012), but field survey data are not available to corroborate this
estimate (USFWS 2013b).

Beginning in 2006, coordinated red knot surveys have been conducted from Florida to Delaware
Bay during 2 consecutive days from May 20 to 24 (Table 15). This period is thought to
represent the peak of the red knot migration. There has been variability in methods, observers,
and areas covered. From 2006 to 2010, there was no change in counts that could not be
attributed to varying geographic survey coverage (Dey et al. 2011); thus, we do not consider any
apparent trends in these data before 2010.

Because red knot numbers peak earlier in the Southeast than in the mid-Atlantic (Bimbi pers.
comm. 2013), the late-May coast-wide survey data likely reflect the movement of some birds
north along the coast, and may miss other birds that depart for Canada from the Southeast along
an interior (overland) route prior to the survey window. Thus, greater numbers of red knots may
utilize Southeastern stopovers than suggested by the data in Table 15. For example, a peak
count of over 8,000 red knots was documented in South Carolina during spring 2012 (South
Carolina Department of Natural Resources 2012). Dinsmore et al. (1998) found a mean of 1,363
(±725) red knots in North Carolina during spring 1992 and 1993, with a peak count of 2,764
birds (USFWS 2013b).

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Table 15. Red knot counts along the Atlantic coast of the U.S., May 20 to 24, 2006 to
2012 (Dey pers. comm. 2012; Dey et al. 2011).

State 2006 2007 2008 2009 2010 2011 2012
New Jersey 7,860 4,445 10,045 16,229 8,945 7,737 23,525
Delaware 820 2,950 5,350 5,530 5,067 3,433
Maryland nr nr 663 78 5 83 139
Virginia 5,783 5,939 7,802 3,261 8,214 6,236 8,482
North
Carolina
235 304 1,137 1,466 1,113 1,868 2,832
South
Carolina
nr 125 180 10 1,220 315 542
Georgia 796 2,155 1,487 nr 260 3,071 1,466
Florida nr nr 868 800 41 10
Total 15,494 15,918 27,532 21,844 25,328 24,377 40,429
nr = not reported

4.1.4. Status and Distribution

Reason for listing: The Service has determined that the rufa red knot is threatened due to loss of
both breeding and nonbreeding habitat; potential for disruption of natural predator cycles on the
breeding grounds; reduced prey availability throughout the nonbreeding range; and increasing
frequency and severity of asynchronies (“mismatches”) in the timing of the birds’ annual
migratory cycle relative to favorable food and weather conditions.

Range-Wide Trends:

Wintering areas for the red knot include the Southeast U.S. from Florida to North Carolina, the
Atlantic coasts of Argentina and Chile, the north coast of Brazil, and the Northwest Gulf of
Mexico from the Mexican State of Tamaulipas to Louisiana (Newstead et al. 2013; Patrick pers.
comm. 2012; Niles et al. 2008). Smaller numbers of knots winter in the Caribbean, and along
the central Gulf coast (Alabama, Mississippi), the mid-Atlantic, and the Northeast U.S. Calidris
canutus is also known to winter in Central America and northwest South America, but it is not
yet clear if all these birds are the rufa subspecies.

In some years, more red knots have been counted during a coordinated spring migration survey
than can be accounted for at known wintering sites, suggesting there are unknown wintering
areas. Indeed, geolocators have started revealing previously little-known wintering areas,
particularly in the Caribbean (Niles et al. 2012; Niles pers. comm. 2013).

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The core of the Southeast wintering area (i.e., that portion of this large region supporting the
majority of birds) is thought to shift from year to year among Florida, Georgia, and South
Carolina (Niles et al. 2008). However, the geographic limits of this wintering region are poorly
defined. Although only small numbers are known, wintering knots extend along the Atlantic
coast as far north as Virginia (Patrick pers. comm. 2012; Niles et al. 2006), Maryland (Burger et
al. 2012), and New Jersey (BandedBirds.org 2012; Hanlon pers. comm. 2012; Dey pers. comm.
2012). Still smaller numbers of red knots have been reported between December and February
from Long Island, New York, through Massachusetts and as far north as Nova Scotia, Canada
(eBird.org 2012).

Recovery Criteria

A Recovery Plan for the red knot has not yet been completed. It will be developed, pursuant to
Subsection 4(f) of the ESA, in the near future.

4.1.5. Analysis of the Species Likely to be Affected

Within the nonbreeding portion of the range, red knot habitat is primarily threatened by the
highly interrelated effects of sea level rise, shoreline stabilization, and coastal development.
Lesser threats to nonbreeding habitat include agriculture and aquaculture, invasive vegetation,
and beach maintenance activities. Within the breeding portion of the range, the primary threat to
red knot habitat is from climate change. With arctic warming, vegetation conditions in the
breeding grounds are expected to change, causing the zone of nesting habitat to shift and perhaps
contract. Arctic freshwater systems—foraging areas for red knots during the nesting season—
are particularly sensitive to climate change.

Climate Change & Sea Level Rise

The natural history of Arctic-breeding shorebirds makes this group of species particularly
vulnerable to global climate change (Meltofte et al. 2007; Piersma and Lindström 2004; Rehfisch
and Crick 2003; Piersma and Baker 2000; Zöckler and Lysenko 2000; Lindström and Agrell
1999). Relatively low genetic diversity, which is thought to be a consequence of survival
through past climate-driven population bottlenecks, may put shorebirds at more risk from
human-induced climate variation than other avian taxa (Meltofte et al. 2007); low genetic
diversity may result in reduced adaptive capacity as well as increased risks when population
sizes drop to low levels.

In the short term, red knots may benefit if warmer temperatures result in fewer years of delayed
horseshoe crab spawning in Delaware Bay (Smith and Michaels 2006) or fewer occurrences of
late snow melt in the breeding grounds (Meltofte et al. 2007). However, there are indications
that changes in the abundance and quality of red knot prey are already underway (Escudero et al.
2012; Jones et al. 2010), and prey species face ongoing climate-related threats from warmer

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temperatures (Jones et al. 2010; Philippart et al. 2003; Rehfisch and Crick 2003), ocean
acidification (NRC 2010; Fabry et al. 2008), and possibly increased prevalence of disease and
parasites (Ward and Lafferty 2004). In addition, red knots face imminent threats from loss of
habitat caused by sea level rise (NRC 2010; Galbraith et al. 2002; Titus 1990), and increasing
asynchronies (“mismatches”) between the timing of their annual breeding, migration, and
wintering cycles and the windows of peak food availability on which the birds depend (Smith et
al. 2011; McGowan et al. 2011; Meltofte et al. 2007; van Gils et al. 2005a; Baker et al. 2004).

With arctic warming, vegetation conditions in the red knot’s breeding grounds are expected to
change, causing the zone of nesting habitat to shift and perhaps contract, but this process may
take decades to unfold (Feng et al. 2012; Meltofte et al. 2007; Kaplan et al. 2003). Ecological
shifts in the Arctic may appear sooner. High uncertainty exists about when and how changing
interactions among vegetation, predators, competitors, prey, parasites, and pathogens may affect
the red knot, but the impacts are potentially profound (Fraser et al. 2013; Schmidt et al. 2012;
Meltofte et al. 2007; Ims and Fuglei 2005).

For most of the year, red knots live in or immediately adjacent to intertidal areas. These habitats
are naturally dynamic, as shorelines are continually reshaped by tides, currents, wind, and
storms. Coastal habitats are susceptible to both abrupt (storm-related) and long-term (sea level
rise) changes. Outside of the breeding grounds, red knots rely entirely on these coastal areas to
fulfill their roosting and foraging needs, making the birds vulnerable to the effects of habitat loss
from rising sea levels. Because conditions in coastal habitats are also critical for building up
nutrient and energy stores for the long migration to the breeding grounds, sea level rise affecting
conditions on staging areas also has the potential to impact the red knot’s ability to breed
successfully in the Arctic (Meltofte et al. 2007).

According to the NRC (2010), the rate of global sea level rise has increased from about 0.02 in
(0.6 mm) per year in the late 19th century to approximately 0.07 in (1.8 mm) per year in the last
half of the 20th century. The rate of increase has accelerated, and over the past 15 years has been
in excess of 0.12 in (3 mm) per year. In 2007, the IPCC estimated that sea level would “likely”
rise by an additional 0.6 to 1.9 feet (ft) (0.18 to 0.59 meters (m)) by 2100 (NRC 2010). This
projection was based largely on the observed rates of change in ice sheets and projected future
thermal expansion of the oceans but did not include the possibility of changes in ice sheet
dynamics (e.g., rates and patterns of ice sheet growth versus loss). Scientists are working to
improve how ice dynamics can be resolved in climate models. Recent research suggests that sea
levels could potentially rise another 2.5 to 6.5 ft (0.8 to 2 m) by 2100, which is several times
larger than the 2007 IPCC estimates (NRC 2010; Pfeffer et al. 2008). However, projected rates
of sea level rise estimates remain rather uncertain, due mainly to limits in scientific
understanding of glacier and ice sheet dynamics (NRC 2010; Pfeffer et al. 2008). The amount of
sea level change varies regionally because of different rates of settling (subsidence) or uplift of
the land, and because of differences in ocean circulation (NRC 2010). In the last century, for
example, sea level rise along the U.S. mid- Atlantic and Gulf coasts exceeded the global average

110
by 5 to 6 in (13 to 15 cm) because coastal lands in these areas are subsiding (USEPA 2013).
Land subsidence also occurs in some areas of the Northeast, at current rates of 0.02 to 0.04 in
(0.5 to 1 mm) per year across this region (Ashton et al. 2007); primarily the result of slow,
natural geologic processes (NOAA 2013). Due to regional differences, a 2-ft (0.6-m) rise in
global sea level by the end of this century would result in a relative sea level rise of 2.3 ft (0.7 m)
at New York City, 2.9 ft (0.9 m) at Hampton Roads, Virginia, and 3.5 ft (1.1 m) at Galveston,
Texas (U.S. Global Change Research Program (USGCRP) 2009). Table 16 shows that local
rates of sea level rise in the range of the red knot over the second half of the 20th century were
generally higher than the global rate of 0.07 in (1.8 mm) per year.

Table 16. Local sea level trends from within the range of the red knot (NOAA 2012)

Station Mean Local Sea Level Trend
(mm per year) Data Period
Pointe-Au-Père, Canada -0.36 ± 0.40 1900–1983
Woods Hole, Massachusetts 2.61 ± 0.20 1932–2006
Cape May, New Jersey 4.06 ± 0.74 1965–2006
Lewes, Delaware 3.20 ± 0.28 1919–2006
Chesapeake Bay Bridge Tunnel, Virginia 6.05 ± 1.14 1975–2006
Beaufort, North Carolina 2.57 ± 0.44 1953–2006
Clearwater Beach, Florida 2.43 ± 0.80 1973–2006
Padre Island, Texas 3.48 ± 0.75 1958–2006
Punto Deseado, Argentina -0.06 ± 1.93 1970–2002

Data from along the U.S. Atlantic coast suggest a relationship between rates of sea level rise and
long-term erosion rates; thus, long-term coastal erosion rates may increase as sea level rises
(Florida Oceans and Coastal Council 2010). However, even if such a correlation is borne out,
predicting the effect of sea level rise on beaches is more complex. Even if wetland or upland
coastal lands are lost, sandy or muddy intertidal habitats can often migrate or reform. However,
forecasting how such changes may unfold is complex and uncertain. Potential effects of sea level
rise on beaches vary regionally due to subsidence or uplift of the land, as well as the geological
character of the coast and nearshore (U.S. Climate Change Science Program (CCSP) 2009b;
Galbraith et al. 2002). Precisely forecasting the effects of sea level rise on particular coastal
habitats will require integration of diverse information on local rates of sea level rise, tidal
ranges, subsurface and coastal topography, sediment accretion rates, coastal processes, and other
factors that is beyond the capability of current models (CCSP 2009b; Frumhoff et al. 2007;
Thieler and Hammar-Klose 2000; Thieler and Hammar-Klose 1999).

Because the majority of the Atlantic and Gulf coasts consist of sandy shores, inundation alone is
unlikely to reflect the potential consequences of sea level rise. Instead, long-term shoreline
changes will involve contributions from inundation and erosion, as well as changes to other

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coastal environments such as wetland losses. Most portions of the open coast of the U.S. will be
subject to significant physical changes and erosion over the next century because the majority of
coastlines consist of sandy beaches, which are highly mobile and in a state of continual change
(CCSP 2009b).

By altering coastal geomorphology, sea level rise will cause significant and often dramatic
changes to coastal landforms including barrier islands, beaches, and intertidal flats (CCSP
2009b; Rehfisch and Crick 2003), primary red knot habitats. Due to increasing sea levels, storm-
surge-driven floods now qualifying as 100-year events are projected to occur as often as every 10
to 20 years along most of the U.S. Atlantic coast by 2050, with even higher frequencies of such
large floods in certain localized areas (Tebaldi et al. 2012). Rising sea level not only increases
the likelihood of coastal flooding, but also changes the template for waves and tides to sculpt the
coast, which can lead to loss of land orders of magnitude greater than that from direct inundation
alone (Ashton et al. 2007).

Red knot migration and wintering habitats in the U.S. generally consist of sandy beaches that are
dynamic and subject to seasonal erosion and accretion. Sea level rise and shoreline erosion have
reduced availability of intertidal habitat used for red knot foraging, and in some areas, roosting
sites have also been affected (Niles et al. 2008). With moderately rising sea levels, red knot
habitats in many portions of the U.S. would be expected to migrate or reform rather than be lost,
except where they are constrained by coastal development or shoreline stabilization (Titus et al.
2009). However, if the sea rises more rapidly than the rate with which a particular coastal system
can keep pace, it could fundamentally change the state of the coast (CCSP 2009b).

Climate change is also resulting in asynchronies during the annual cycle of the red knot. The
successful annual migration and breeding of red knots is highly dependent on the timing of
departures and arrivals to coincide with favorable food and weather conditions. The frequency
and severity of asynchronies is likely to increase with climate change. In addition, stochastic
encounters with unfavorable conditions are more likely to result in population-level effects for
red knots now than when population sizes were larger, as reduced numbers may have reduced the
resiliency of this subspecies to rebound from impacts.
For unknown reasons, more red knots arrived late in Delaware Bay in the early 2000s, which is
generally accepted as a key causative factor (along with reduced supplies of horseshoe crab eggs)
behind red knot population declines that were observed over this same timeframe. Thus, the red
knot’s sensitivity to timing asynchronies has been demonstrated through a population-level
response. Both adequate supplies of horseshoe crab eggs and high-quality foraging habitat in
Delaware Bay can serve to partially mitigate minor asynchronies at this key stopover site.
However, the factors that caused delays in the spring migrations of red knots from Argentina and
Chile are still unknown, and we have no information to indicate if this delay will reverse, persist,
or intensify. Superimposed on this existing threat of late arrivals in Delaware Bay are new
threats of asynchronies emerging due to climate change. Climate change is likely to affect the
reproductive timing of horseshoe crabs in Delaware Bay, mollusk prey species at other stopover

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sites, or both, possibly pushing the peak seasonal availability of food outside of the windows
when red knots rely on them. In addition, both field studies and modeling have shown strong
links between the red knot’s reproductive output and conditions in the Arctic including insect
abundance and snow cover. Climate change may also cause shifts in the period of optimal arctic
conditions relative to the time period when red knots currently breed.

Shoreline stabilization

Structural development along the shoreline and manipulation of natural inlets upset the naturally
dynamic coastal processes and result in loss or degradation of beach habitat (Melvin et al. 1991).
As beaches narrow, the reduced habitat can directly lower the diversity and abundance of biota
(life forms), especially in the upper intertidal zone. Shorebirds may be impacted both by reduced
habitat area for roosting and foraging, and by declining intertidal prey resources, as has been
documented in California (Defeo et al. 2009; Dugan and Hubbard 2006). In Delaware Bay, hard
structures also cause or accelerate loss of horseshoe crab spawning habitat (CCSP 2009b; Botton
et al. in Shuster et al. 2003; Botton et al. 1988), and shorebird habitat has been, and may continue
to be, lost where bulkheads have been built (Clark in Farrell and Martin 1997). In addition to
directly eliminating red knot habitat, hard structures interfere with the creation of new shorebird
habitats by interrupting the natural processes of overwash and inlet formation. Where hard
stabilization is installed, the eventual loss of the beach and its associated habitats is virtually
assured (Rice 2009), absent beach nourishment, which may also impact red knots. Where they
are maintained, hard structures are likely to significantly increase the amount of red knot habitat
lost as sea levels continue to rise.

In a few isolated locations, however, hard structures may enhance red knot habitat, or may
provide artificial habitat. In Delaware Bay, for example, Botton et al. (1994) found that, in the
same manner as natural shoreline discontinuities like creek mouths, jetties and other artificial
obstructions can act to concentrate drifting horseshoe crab eggs and thereby attract shorebirds.
Another example comes from the Delaware side of the bay, where a seawall and jetty at
Mispillion Harbor protect the confluence of the Mispillion River and Cedar Creek. These
structures create a low energy environment in the harbor, which seems to provide highly suitable
conditions for horseshoe crab spawning over a wider variation of weather and sea conditions
than anywhere else in the bay (Breese pers. comm. 2013). Horseshoe crab egg densities at
Mispillion Harbor are consistently an order of magnitude higher than at other bay beaches (Dey
et al. 2011), and this site consistently supports upwards of 15 to 20 percent of all the knots
recorded in Delaware Bay (Lathrop 2005). Notwithstanding localized red knot use of artificial
structures, and the isolated case of hard structures improving foraging habitat at Mispillion
Harbor, the nearly universal effect of such structures is the degradation or loss of red knot
habitat.

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Sand Placement

Where shorebird habitat has been severely reduced or eliminated by hard stabilization structures,
beach nourishment may be the only means available to replace any habitat for as long as the hard
structures are maintained (Nordstrom and Mauriello 2001), although such habitat will persist
only with regular nourishment episodes. In Delaware Bay, beach nourishment has been
recommended to prevent loss of spawning habitat for horseshoe crabs (Kalasz 2008; Carter et al.
in Guilfoyle et al. 2007; Atlantic States Marine Fisheries Commission (ASMFC) 1998), and is
being pursued as a means of restoring shorebird habitat in Delaware Bay following Hurricane
Sandy (Niles et al. 2013; USACE 2012). Beach nourishment was part of a 2009 project to
maintain important shorebird foraging habitat at Mispillion Harbor, Delaware (Kalasz pers.
comm. 2013; Siok and Wilson 2011). However, red knots may be directly disturbed if beach
nourishment takes place while the birds are present. On New Jersey’s Atlantic coast, beach
nourishment has typically been scheduled for the fall, when red knots are present, because of
various constraints at other times of year. In addition to causing disturbance during construction,
beach nourishment often increases recreational use of the widened beaches that, without careful
management, can increase disturbance of red knots. Beach nourishment can also temporarily
depress, and sometimes permanently alter, the invertebrate prey base on which shorebirds
depend. In addition to disturbing the birds and impacting the prey base, beach nourishment can
affect the quality and quantity of red knot habitat (Bimbi pers. comm. 2012; Greene 2002). The
artificial beach created by nourishment may provide only suboptimal habitat for red knots, as a
steeper beach profile is created when sand is stacked on the beach during the nourishment
process. In some cases, nourishment is accompanied by the planting of dense beach grasses,
which can directly degrade habitat, as red knots require sparse vegetation to avoid predation. By
precluding overwash and Aeolian transport, especially where large artificial dunes are
constructed, beach nourishment can also lead to further erosion on the bayside and promote
bayside vegetation growth, both of which can degrade the red knot’s preferred foraging and
roosting habitats (sparsely vegetated flats in or adjacent to intertidal areas). Preclusion of
overwash also impedes the formation of new red knot habitats. Beach nourishment can also
encourage further development, bringing further habitat impacts, reducing future alternative
management options such as a retreat from the coast, and perpetuating the developed and
stabilized conditions that may ultimately lead to inundation where beaches are prevented from
migrating (Bimbi pers. comm. 2012; Greene 2002).

The quantity and quality of red knot prey may also be affected by the placement of sediment for
beach nourishment or disposal of sand. Invertebrates may be crushed or buried during project
construction. Although some benthic species can burrow through a thin layer of additional
sediment, thicker layers (over 35 in (90 cm)) smother the benthic fauna (Greene 2002). By
means of this vertical burrowing, recolonization from adjacent areas, or both, the benthic faunal
communities typically recover. Recovery can take as little as 2 weeks or as long as 2 years, but
usually averages 2 to 7 months (Greene 2002; Peterson and Manning 2001). Although many
studies have concluded that invertebrate communities recovered following sand placement, study

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methods have often been insufficient to detect even large changes in abundance or species
composition due to high natural variability and small sample sizes (Peterson and Bishop 2005).
Peterson et al (2006) found that although Emerita talpoida abundance recovered relatively
rapidly after beach nourishment on Bogue Banks, recovery of Donax spp. and amphipods was
much longer. This is thought to be because Emerita is known to prefer relatively coarse
sediments (Bowman and Dolan 1985). Donax is one of the preferred prey items of red knot.
Uncertainty remains about the effects of sand placement on invertebrate communities and how
these impacts may affect red knots.

Dredging/sand mining

Many inlets in the U.S. range of the red knot are routinely dredged and sometimes relocated. In
addition, nearshore areas are routinely dredged (“mined”) to obtain sand for beach nourishment.
Regardless of the purpose, inlet and nearshore dredging can affect red knot habitats. Dredging
often involves removal of sediment from sand bars, shoals, and inlets in the nearshore zone,
directly impacting optimal red knot roosting and foraging habitats (Harrington in Guilfoyle et al.
2007; Winn and Harrington in Guilfoyle et al. 2006). These ephemeral habitats are even more
valuable to red knots because they tend to receive less recreational use than the main beach
strand. In addition to causing this direct habitat loss, the dredging of sand bars and shoals can
preclude the creation and maintenance of red knot habitats by removing sand sources that would
otherwise act as natural breakwaters and weld onto the shore over time (Hayes and Michel 2008;
Morton 2003). Further, removing these sand features can cause or worsen localized erosion by
altering depth contours and changing wave refraction (Hayes and Michel 2008), potentially
degrading other nearby red knot habitats indirectly because inlet dynamics exert a strong
influence on the adjacent shorelines. Studying barrier islands in Virginia and North Carolina,
Fenster and Dolan (1996) found that inlet influences extend 3.4 to 8.1 mi (5.4 to 13.0 km), and
that inlets dominate shoreline changes for up to 2.7 mi (4.3 km). Changing the location of
dominant channels at inlets can create profound alterations to the adjacent shoreline (Nordstrom
2000).

Reduced food availability

Commercial harvest of horseshoe crabs has been implicated as a causal factor in the decline of
the rufa red knot, by decreasing the availability of horseshoe crab eggs in the Delaware Bay
stopover (Niles et al. 2008). Notwithstanding the importance of the horseshoe crab and Delaware
Bay, other lines of evidence suggest that the rufa red knot also faces threats to its food resources
throughout its range.

During most of the year, bivalves and other mollusks are the primary prey for the red knot.
Mollusks in general are at risk from climate change-induced ocean acidification (Fabry et al.
2008). Oceans become more acidic as carbon dioxide emitted into the atmosphere dissolves in
the ocean. The pH (percent hydrogen, a measure of acidity or alkalinity) level of the oceans has

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decreased by approximately 0.1 pH units since preindustrial times, which is equivalent to a 25
percent increase in acidity. By 2100, the pH level of the oceans is projected to decrease by an
additional 0.3 to 0.4 units under the highest emissions scenarios (NRC 2010). As ocean
acidification increases, the availability of calcium carbonate declines. Calcium carbonate is a key
building block for the shells of many marine organisms, including bivalves and other mollusks
(USEPA 2012; NRC 2010). Vulnerability to ocean acidification has been shown in bivalve
species similar to those favored by red knots, including mussels (Gaylord et al. 2011; Bibby et al.
2008) and clams (Green et al. 2009). Reduced calcification rates and calcium metabolism are
also expected to affect several mollusks and crustaceans that inhabit sandy beaches (Defeo et al.
2009), the primary nonbreeding habitat for red knots. Relevant to Tierra del Fuego-wintering
knots, bivalves have also shown vulnerability to ocean acidification in Antarctic waters, which
are predicted to be affected due to naturally low carbonate saturation levels in cold waters
(Cummings et al. 2011).

Blue mussel spat is an important prey item for red knots in Virginia (Karpanty et al. 2012). The
southern limit of adult blue mussels has contracted from North Carolina to Delaware since 1960
due to increasing air and water temperatures (Jones et al. 2010). Larvae have continued to recruit
to southern locales (including Virginia) via currents, but those recruits die early in the summer
due to water and air temperatures in excess of lethal physiological limits. Failure to recolonize
southern regions will occur when reproducing populations at higher latitudes are beyond
dispersal distance (Jones et al. 2010). Thus, this key prey resource may soon disappear from the
red knot’s Virginia spring stopover habitats (Karpanty et al. 2012).

Reduced food availability at the Delaware Bay stopover site due to commercial harvest and
subsequent population decline of the horseshoe crab is considered a primary causal factor in the
decline of the rufa subspecies in the 2000s (Escudero et al. 2012; McGowan et al. 2011; CAFF
2010; Niles et al. 2008; COSEWIC 2007; González et al. 2006; Baker et al. 2004; Morrison
et al. 2004), although other possible causes or contributing factors have been postulated (Fraser
et al. 2013; Schwarzer et al. 2012; Escudero et al. 2012; Espoz et al. 2008; Niles et al. 2008).
Due to harvest restrictions and other conservation actions, horseshoe crab populations showed
some signs of recovery in the early 2000s, with apparent signs of red knot stabilization (survey
counts, rates of weight gain) occurring a few years later. Since about 2005, however, horseshoe
crab population growth has stagnated for unknown reasons. Under the current management
framework (known as Adaptive Resource Management, or ARM), the present horseshoe crab
harvest is not considered a threat to the red knot because harvest levels are tied to red knot
populations via scientific modeling. Most data suggest that the volume of horseshoe crab eggs is
currently sufficient to support the Delaware Bay’s stopover population of red knots at its present
size. However, because of the uncertain trajectory of horseshoe crab population growth, it is not
yet known if the egg resource will continue to adequately support red knot populations over the
next 5 to 10 years. In addition, implementation of the ARM could be impeded by insufficient
funding for the shorebird and horseshoe crab monitoring programs that are necessary for the
functioning of the ARM models. Many studies have established that red knots stopping over in

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Delaware Bay during spring migration achieve remarkable and important weight gains to
complete their migrations to the breeding grounds by feeding almost exclusively on a
superabundance of horseshoe crab eggs. A temporal correlation occurred between increased
horseshoe crab harvests in the 1990s and declining red knot counts in both Delaware Bay and
Tierra del Fuego by the 2000s. Other shorebird species that rely on Delaware Bay also declined
over this period (Mizrahi and Peters in Tanacredi et al. 2009), although some shorebird declines
began before the peak expansion of the horseshoe crab fishery (Botton et al. in Shuster et al.
2003).

Hunting

Legal and illegal sport and market hunting in the mid-Atlantic and Northeast U.S. substantially
reduced red knot populations in the 1800s, and we do not know if the subspecies ever fully
recovered to its former abundance or distribution. Neither legal nor illegal hunting are currently a
threat to red knots in the U.S., but both occur in the Caribbean and parts of South America.
Hunting pressure on red knots and other shorebirds in the northern Caribbean and on Trinidad is
unknown. Hunting pressure on shorebirds in the Lesser Antilles (e.g., Barbados, Guadeloupe) is
very high, but only small numbers of red knots have been documented on these islands, so past
mortality may not have exceeded tens of birds per year. Red knots are no longer being targeted in
Barbados or Guadeloupe, and other measures to regulate shorebird hunting on these islands are
being negotiated. Much larger numbers (thousands) of red knots occur in the Guianas, where
legal and illegal subsistence shorebird hunting is common. About 20 red knot mortalities have
been documented in the Guianas, but total red knot hunting mortality in this region cannot be
surmised. Subsistence shorebird hunting was also common in northern Brazil, but has decreased
in recent decades. We have no evidence that hunting was a driving factor in red knot population
declines in the 2000s, or that hunting pressure is increasing. In addition, catch limits, handling
protocols, and studies on the effects of research activities on survival all indicate that
overutilization for scientific purposes is not a threat to the red knot.

Threats to the red knot from overutilization for commercial, recreational, scientific, or
educational purposes exist in parts of the Caribbean and South America. Specifically, legal and
illegal hunting does occur. We expect mortality of individual knots from hunting to continue into
the future, but at stable or decreasing levels due to the recent international attention to shorebird
hunting.

Predation

In wintering and migration areas, the most common predators of red knots are peregrine falcons
(Falco peregrinus), harriers (Circus spp.), accipiters (Family Accipitridae), merlins (F.
columbarius), shorteared owls (Asio flammeus), and greater black-backed gulls (Larus marinus)
(Niles et al. 2008). Other large are anecdotally known to prey on shorebirds (Breese 2010). In
migration areas like Delaware Bay, terrestrial predators such as red foxes (Vulpes vulpes) and

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feral cats (Felis catus) may be a threat to red knots by causing disturbance, but direct mortality
from these predators may be low (Niles et al. 2008).

Although little information is available from the breeding grounds, the long-tailed jaeger
(Stercorarius longicaudus) is prominently mentioned as a predator of red knot chicks in most
accounts. Other avian predators include parasitic jaeger (S. parasiticus), pomarine jaeger (S.
pomarinus), herring gull and glaucous gulls, gyrfalcon (Falcon rusticolus), peregrine falcon, and
snowy owl (Bubo scandiacus). Mammalian predators include arctic fox (Alopex lagopus) and
sometimes arctic wolves (Canis lupus arctos) (Niles et al. 2008; COSEWIC 2007). Predation
pressure on Arctic-nesting shorebird clutches varies widely regionally, interannually, and even
within each nesting season, with nest losses to predators ranging from close to 0 percent to near
100 percent (Meltofte et al. 2007), depending on ecological factors. Abundance of arctic
rodents, such as lemmings, is often cyclical, although less so in North America than in Eurasia.
In the Arctic, 3- to 4-year lemming cycles give rise to similar cycles in the predation of shorebird
nests. When lemmings are abundant, predators concentrate on the lemmings, and shorebirds
breed successfully. When lemmings are in short supply, predators switch to shorebird eggs and
chicks (Niles et al. 2008; COSEWIC 2007; Meltofte et al. 2007; USFWS 2003b; Blomqvist et al.
2002; Summers and Underhill 1987).

Recreational disturbance

In some wintering and stopover areas, red knots and recreational users (e.g., pedestrians, ORVs,
dog walkers, boaters) are concentrated on the same beaches (Niles et al. 2008; Tarr 2008).
Recreational activities affect red knots both directly and indirectly. These activities can cause
habitat damage (Schlacher and Thompson 2008c; Anders and Leatherman 1987), cause
shorebirds to abandon otherwise preferred habitats, and negatively affect the birds’ energy
balances. Effects to red knots from vehicle and pedestrian disturbance can also occur during
construction of shoreline stabilization projects including beach nourishment. Red knots can also
be disturbed by motorized and nonmotorized boats, fishing, kite surfing, aircraft, and research
activities (Niles et al. 2008; Peters and Otis 2007; Harrington 2005b; Meyer et al. 1999; Burger
1986) and by beach raking or cleaning.

Table 17 lists biological opinions that have been issued for adverse impacts to red knots since
2014, within the Raleigh Field Office geographic area. Activities addressed by the BOs include
inlet dredging, sand placement, construction of sandbag revetments, and terminal groin
construction.

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Table 17. BOs issued since 2014 within the Raleigh Field Office geographic area.

OPINIONS RED KNOT HABITAT
Fiscal Year 2014: 1 BO 12,600 lf
(2.4 mi)
Fiscal Year 2015: 5 BOs 70,268 lf
(13.3 mi)
Fiscal Year 2016: 8 BOs 229,937 lf
(43.54 mi)
Fiscal Year 2017: 1 BO (to date) 27,650 lf (5.24 mi)
Total: 15 BOs 340,455 lf (64.48 mi)

The proposed action has the potential to adversely affect wintering and migrating red knots and
their habitat. Potential effects to red knots include disturbance during construction, degradation
of foraging habitat and destruction of the prey base from sand placement, attraction of predators
due to food waste from the construction crew, and disturbance due to increased recreational use.
Like the piping plover, red knots face predation by avian and mammalian predators that are
present year-round on the migration and wintering grounds.

4.2. Environmental Baseline

4.2.1. Status of the species within the Action Area

Aerial surveys for rufa red knots have been performed throughout the state and data from these
surveys are maintained by NCWRC. Data is only currently available from 2006 to 2012. Data
from the PBA and NCWRC (www.paws.org) are provided in Table 18.

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Table 18. Number of red knots observed during aerial surveys from Bogue Banks to Sunset
Beach, 2006-2012. Table (3.11) from the PBA, data from the PAWS database (NCWRC 2015).

2006 2007 2008 2009 2010 2011 2012
Bogue Banks 24 345 0 37 33
Bear Island 0 34 0 25
Onslow Beach 336
North Topsail Overwash 42 8 16
New Topsail Inlet 0 0 0
Lea-Hutaff Island 38 0 34 68 26 7 34
Rich Inlet 40 0
Figure 8 Island 2 85 64 9 0 54
Mason Inlet 57 0
Wrightsville Beach 6 0 1 72 5 0 0
Masonboro Island 111 30 1 27 15 22 58
Carolina Beach Inlet 36 11
Carolina Beach 0 14 0
Fort Fisher 81 4 20 8
Bald Head Island 78 67 21 5 26 40
Battery Island South 0 0
Oak Island 0 0 22 0
Lockwood Folly Inlet 0 25 18
Holden Beach 0 15 56
Ocean Isle Beach 0 23 112
Tubbs Inlet 0 11
Sunset Beach 0 0 35 75
Bird Shoal (Rachael
Carson) 40 0
Total 235 222 192 1128 106 215 511

The National Park Service has surveyed red knots along North Core Banks (NCB) and South
Core Banks (SCB) in Cape Lookout National Seashore (CALO) since 2006, conducting regular
counts from March through October each year. NCB has much higher counts of red knots than
SCB. The mean count along NCB for 2016 was 330 birds per count, while the mean along the
SCB shoreline was 34 birds per count. Data from these counts clearly indicate a peak in red knot
numbers during May for both NCB and SCB (NPS 2016) (Table 19).

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Table 19. Red Knot Peak Counts and Relative Abundance (number of birds per kilometer of
shoreline) on North Core Banks, 2006 – 2016. Data from NPS 2016.

Year Peak Count Date of Peak
Count
Relative
Abundance
(# birds per km)
2006 618 May 5 20
2007 718 May 15 23
2008 1,287 April 15 42
2009 525 May 25 14
2010 927 May 15 26
2011 648 May 15 18
2012 1,370 April 25 46
2013 854 May 25 29
2014 2,666 May 15 89
2015 2,201 May 15 74
2016 2,124 May 15 71

The Service has conducted red knot monitoring along the shoreline of Pea Island National
Wildlife Refuge (PINWR) since 1996. Numbers of red knots along PINWR are much lower than
those at CALO, with peak numbers ranging from two on June 13, 1996 to 190 on June 6, 2006
(Table 20) (Harrison pers. comm. 2017). Red knots are present during every season of the year
on PINWR.

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Table 20. Peak numbers of red knots along PINWR (Harrison pers. comm. 2017).

Year Peak
Count
Date of
Peak Count
1996 2 June 13
1997 5 September 23
1998 107 August 13
1999 44 August 2
2000 56 September 14
2001 74 October 5
2002 137 May 15
2003 34 May 28
2004 101 October 11
2005 36 June14
2006 190 June 6
2007 141 May 29
2008 42 December 3
2009 84 January 15
2010 18 November 17
2011 166 June 3
2012 31 June 5
2013 70 May 15
2014 18 May 28
2015 11 November 13
2016 13 May 26

4.2.2. Factors affecting the species environment within the Action Area

A wide range of recent and on-going beach disturbance activities have altered the North Carolina
coastline, and many more are proposed along the coastline for the near future. Appendix A
(copied from the PBA) and Table 11 (page 73) list many of these activities.

Beach nourishment: Appendix A (from the PBA) lists historical beach sand placement projects
for the state of North Carolina. The beaches of North Carolina are regularly nourished with sand
from the Corps and from locally-sponsored or private projects. Sand placement activities widen
beaches, change their sedimentology and stratigraphy, alter coastal processes, and often plug
dune gaps and remove overwash areas. The addition of dredged sediment can temporarily affect
the benthic fauna of intertidal systems. Invertebrates may be crushed or buried during project

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construction. In North Carolina, the majority of sand placement projects are conducted during
the migrating or overwintering season for red knots, in an effort to avoid adverse effects to
nesting sea turtles. Depending on the timing of the project, burial of prey items can have a
significant adverse effect on migrating and overwintering birds.

Invertebrate communities may also be affected by changes in the physical environment resulting
from shoreline stabilization activities that alter the sediment composition or degree of exposure.
If the material used in a sand placement project does not closely match the native material on the
beach, the sediment incompatibility may result in modifications to the macroinvertebrate
community structure, because several species are sensitive to grain size and composition
(Rakocinski et al. 1996; Peterson et al. 2006; Peterson and Bishop 2005; Colosio et al. 2007;
Defeo et al. 2009).

Delayed recovery of the benthic prey base or changes in their communities due to physical
habitat changes may affect the quality of red knot foraging habitat. Although recovery of
invertebrate communities has been documented in many studies, sampling designs have typically
been inadequate and have only been able to detect large-magnitude changes (Schoeman et al.
2000; Peterson and Bishop 2005). Therefore, uncertainty persists about the impacts of various
projects to invertebrate communities and how these impacts red knots.

The PBA estimates that approximately 112 miles of Atlantic shoreline has been nourished in
North Carolina. Rice (2017) estimates the length of nourished shoreline to be approximately 101
miles, with another 43 miles proposed. The first recorded sand placement project in North
Carolina was on Wrightsville Beach in 1939, when sand was placed on 2.6 miles of shoreline.
Sand placement did not occur again until the mid to late-1950’s. Sand placement was generally
intermittent and small in scope (less than 6 miles per year) until the late 1980’s to 1990’s, when
the frequency of sand placement and miles of shoreline per year began to dramatically increase.
Many of the beachfront communities have received sand on more than 10 occasions. Carolina
Beach is listed in the PBA as having had 40 and placement events, while Wrightsville Beach has
had 26, and Holden Beach 45. For most of these events, the sand source is navigation projects.
Other sand sources include sediment mined from inlets, offshore borrow areas, and previously
dredged material from upland disposal areas or existing material from an upland borrow area.
Between 31% (Rice 2017) and 35% (PBA) of the North Carolina Shoreline has been modified by
sediment placement as of 2015.

Inlet dredging activities alter the sediment dynamics on adjacent shorelines and stabilize these
dynamic environments; beach disposal of dredge material further alters the natural habitat
adjacent to inlets. Estuarine dredging of navigational channels can alter water circulation
patterns and sediment transport pathways, as well as increase the frequency and magnitude of
boat wakes; sound-side sand or mud flats may be impacted by increased erosion rates as a result.
Historically, there have been Federal navigation projects in the AIWW and in inlets along the
North Carolina coast for decades. During hundreds of dredging events, the sediment has been

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placed on the adjacent beach using pipelines. Inlets associated with ports and other high-traffic
areas typically have maintenance dredging conducted annually, if not more often. At four
shallow-draft inlets (Bogue, Topsail, Carolina Beach, and Lockwoods Folly) the Corps has
typically dredged the inlet on a quarterly basis, and maintained inlet crossings and connecting
channels every one to two years (NCDENR, 2015). Local governments have received
authorization to also conduct maintenance dredging of these inlets on the same general schedule,
with beach disposal during the winter work window. Inlets that are mined for Coastal Storm
Damage Reduction (CSDR) projects (conducted by the Corps or local governments) are typically
dredged on three-year intervals, with placement of the sand on the adjacent shoreline. Dredging
may remove intertidal shoals and unvegetated sandy habitat on inlet shoulders.

Since 2012, several North Carolina tidal inlets have been dredged regularly for navigation
purposes. Oregon Inlet continues to be dredged frequently for navigation and other purposes. In
late 2015 the NC Department of Transportation (NCDOT) dredged a channel on the west side of
Hatteras Inlet to maintain navigational access in and around Hatteras Inlet. The material was
sidecast next to the dredged channel (USACE 2015a, Kozak 2016). Ocracoke Inlet was dredged
by the Corps with a sidecast dredge in 2013 (Hinnant 2013). Portions of Beaufort Inlet are
dredged yearly or more often than yearly, in order to maintain navigation access to the Morehead
City State Port Terminal. Sediment disposal may be to Bogue Banks, to an upland disposal site,
or to the Offshore Dredged Material Disposal Site (ODMDS). Beaufort Inlet was dredged in
2013, 2014, and 2017, with dredged sediment placed on Bogue Banks to the west in 2014 (Hibbs
2013, 2014). Similarly, portions of the Lower Cape Fear River are dredged each year to
maintain navigation to Wilmington Harbor, with dredged material placed on adjacent beaches
(Bald Head Island or Caswell and Oak Island Beaches) or the ODMDS. The Wilmington Harbor
Inner Ocean Bar was dredged in 2017 with placement of sand on Caswell and Oak Island
Beaches. Carolina Beach Inlet was dredged with a USACE sidecast dredge in 2013. In 2015
Carolina Beach Inlet was dredged by the Corps, state and New Hanover County, with the
material placed in a nearshore disposal site off Carolina Beach (Hinnant 2013, Lane 2015).
Lockwoods Folly Inlet was dredged by the Corps in 2013 (Hinnant 2013). The Town of Oak
Island dredged Eastern Channel, part of the Lockwoods Folly Inlet complex, in 2015 and
removed over 3 acres of emergent shoal habitat; the beach-compatible portion of the dredged
material was placed on the beach of west Oak Island. The Corps dredged the AIWW and
portions of Lockwoods Folly Inlet in 2016-2017 and placed the sand on Holden Beach (Hughes
Pers. Comm. 2017). Cow Channel was dredged in early 2017 and the material placed on Bear
Island within Hammocks Beach State Park (Corey Pers. Comm. 2017).

According to Rice (2016), at least 10 inlets have been mined for sediment for beach nourishment
projects in North Carolina. Shallotte Inlet was mined in 2001 and 2014, Bogue Inlet in 2005,
Barden Inlet in 2006, and Rich Inlet (or Nixon Channel) seven times between 1983 and 2011.
More recently, Mason Inlet was mined in 2005, 2009, 2011, 2012-2013 and early 2016. Oregon
Inlet was mined in 2013. New River Inlet was mined in 2012-2013 as part of an inlet channel
relocation project. New Topsail Inlet was mined in 2012 and 2015. The most recent project plans

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for the federal and local Carolina and Kure Beach CSDR Projects identify Carolina Beach Inlet
as a primary sediment source; sediment dredged from the inlet has been placed periodically on
Carolina Beach for storm damage reduction since the 1960s. Similarly, sediment removed from
the inlet has been used as beach fill on Wrightsville Beach for storm damage reduction since the
early 1960’s.

Seven North Carolina inlets have been mined for beach sand in the past 5 years. Four of these
are sites that have been mined previously, while three have not. The NCDOT mined
approximately 33,000 cy of sediment from within Oregon Inlet in 2013 to provide sand to fill for
a scour hole adjacent to the Herbert C. Bonner Bridge in another location of the inlet (USACE
2013). New Topsail Inlet was mined in 2012 and 2015 by the Town of Topsail Beach to provide
sand for beach nourishment (Town of North Topsail Beach 2015). In 2013, the inlet channel of
New River Inlet was relocated, and the dredged material used to fill the beach on North Topsail
Beach (Town of North Topsail Beach 2015, USACE 2015b). In February 2017, the Town of
North Topsail Beach received a modified permit to modify the ebb tide channel position within
New River Inlet.

The four inlets that have been mined previously include Mason Inlet, Shallotte Inlet, Carolina
Beach Inlet, and Masonboro Inlet. In many cases, these inlets are both managed for navigation
and alternatively mined for sand for beach nourishment. Mason Inlet was mined in 2011, 2013,
and 2016 to provide beach fill for Figure Eight Island and to maintain Mason Inlet within a
specific inlet corridor. In 2014 and 2017, the Corps mined Shallotte Inlet to nourish adjacent
Ocean Isle Beach, pursuant to the Corps’ CSDR project (Ocean Isle Beach 2015, Hughes Pers.
Comm. 2017). Carolina Beach Inlet was mined in 2013 and 2017 for beach fill on Carolina
Beach. Masonboro Inlet was mined in 2014 for beach fill on Wrightsville Beach (USFWS
2016b and 2016c).

In some cases, sand has been dredged from the AIWW or inlets and placed within the sounds to
improve habitat for migrating and nesting shorebirds. There are several “bird islands” along the
sound shorelines which intermittently receive sand from navigation projects. In 2017, the Corps
dredged Old House Channel to Oregon inlet and placed the sand on bird islands near Manteo
(Hughes Pers. comm. 2017). Also in 2017, Carteret County dredged Wainwright Slough and
placed the sand on the adjacent Wainwright Island. More such projects are planned in the near
future, such as proposed placement of material dredged from the lower Cape Fear River on South
Pelican and Ferry Slip Islands to restore these small islands for waterbird habitat.

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Shoreline Stabilization and Armoring:

In 2017, there are 4 jetties and 34 groins along the North Carolina coast, and sandbags, sandbag
revetments, groins, and jetties have been placed along at least 9.05 miles of North Carolina
shoreline (Rice 2017). See Table 14 (page 81) for data from Rice (2017).

Sandbags on private properties provide stabilization to a significant portion of the North Carolina
shoreline. Rice (2017) estimated 152 separate sandbag structures along the North Carolina beach
shoreline. If multiple properties each had an individual seawall protecting their property and the
seawalls were attached to each other with no gaps, then Rice (2017) counted the armoring as one
structure (per Dallas et al. 2013) and measured the overall length.

Rice (2017) estimated that 24 of 37 North Carolina coastal communities have been modified by
armor. In these communities, the proportion of armored sandy beach habitat was as high as
18%. Four communities exceed 10% of the shoreline armored: Kitty Hawk (18%), Bald Head
Island (13%), Kure Beach (11%), and Ocean Isle Beach (10%).

In North Carolina, there are three currently existing terminal groins: along Oregon Inlet, at Fort
Macon along Beaufort Inlet in Carteret County, and on Bald Head Island in New Hanover
County. The terminal groin on Bald Head Island was installed in 2015, but the other two
(Oregon Inlet and Fort Macon) were installed decades ago, and downdrift erosion has been
severe at both, requiring frequent nourishment (Pietrafesa 2012; Riggs et al 2009). The Fort
Macon groin is fronted by a larger structure that Rice (2016) refers to as jetty.

The Oregon Inlet and Fort Macon Groins are located on the updrift side of the island, but
accretion in these areas is not significant due to scour. At Oregon Inlet, there is no sandy habitat
on the inlet shoulder updrift of the groin and revetment, and there has not been for decades.
There are two degraded groin/jetty structures in Dare County, adjacent to the old location of the
Cape Hatteras lighthouse. The Service has issued BOs for the authorization of two other
terminal groins (Towns of Ocean Isle Beach and Holden Beach), and the Figure “Eight”
Homeowners Association is currently (2017) seeking authorization to construct a terminal groin
on the north end of Figure Eight Island (south side of Rich Inlet). Also, in 2015, the North
Carolina legislature revised state regulations to allow additional terminal groins to be constructed
at New River Inlet and Bogue Inlet. However, it is unclear whether the local governments in the
vicinity of these two inlets will propose the construction of a terminal groin. The south jetty
along Masonboro Inlet was repaired by the Corps in 2013 and 2014 (USACE 2015c).

There are two existing rock revetments along the coast of North Carolina: one at Fort Fisher
(approximately 3,040 lf), and another along Carolina Beach (approximately 2,050 lf). Sandbags
and sandbag revetments have been placed along at least 1,800 lf of the eastern shoreline on
Ocean Isle Beach, and the Tubbs Inlet shoreline on Ocean Isle Beach is completely lined with a
sandbag revetment. A sandbag revetment at least 1,800 lf long (with a geotube in front of a

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portion) was constructed in 2015 at the north end of North Topsail Beach, and more sandbags
were added in 2016 to protect a parking lot north of the revetment. In 2000 and 2001, sandbag
revetments were installed on the north end of Figure Eight Island along Surf Court, Inlet Hook
Road, and Comber Road.

Beach scraping can artificially steepen beaches, stabilize dune scarps, plug dune gaps, and
redistribute sediment distribution patterns. Artificial dune building, often a product of beach
scraping, removes low-lying overwash areas and dune gaps. As chronic erosion catches up to
structures throughout the Action Area, artificial dune systems are constructed and maintained to
protect beachfront structures either by sand fencing or fill placement. Beach scraping or
bulldozing has become more frequent on North Carolina beaches in the past 20 years, in
response to storms and the continuing retreat of the shoreline with rising sea level. From 2012 to
2015, Rice (2017) estimated that at least 4.84 miles of the North Carolina shoreline was
impacted by beach scraping. These activities primarily occur during the winter months, when
red knots may be present. Artificial dune or berm systems have been constructed and maintained
in several areas. These dunes make the artificial dune ridge function like a seawall that blocks
natural beach retreat, evolution, and overwash.

Beach raking and rock-picking: Man-made beach cleaning and raking machines effectively
remove seaweed, fish, glass, syringes, plastic, cans, cigarettes, shells, stone, wood, and virtually
any unwanted debris (Barber Beach Cleaning Equipment 2009). Removal of wrack also
eliminates a beach’s natural sand-trapping abilities, further destabilizing the beach. In addition,
sand adhering to seaweed and trapped in the cracks and crevices of wrack is removed from the
beach. Although the amount of sand lost due to single sweeping actions may be small, it adds up
considerably over a period of years (Nordstrom et al. 2006; Neal et al. 2007). Beach cleaning or
grooming can result in abnormally broad unvegetated zones that are inhospitable to dune
formation or plant colonization, thereby enhancing the likelihood of erosion (Defreo et al.
2009). The Town of Carolina Beach rakes the beach front in Freeman Park at least twice per
year. The Town of North Topsail Beach utilizes a rock-picker as needed, typically annually, to
remove rocky material from the beach berm along portions of its shoreline.

Sand Fencing: Rice (2017) estimates that 62.69 miles (19%) of North Carolina’s shoreline was
modified with sand fencing between 2012 and 2015. Sand fencing modified more than 50% of
the sandy beach habitat in 6 communities: Pine Knoll Shores (97%), Kill Devil Hills (67%),
Atlantic Beach (64%), Southern Shores (63%), Corolla (53%) and Nags Head (53%). In 14
other coastal communities, between 20 and 50% of the sandy beach habitat was modified by
sand fencing between 2012 and early 2016. A total of 1,199 contiguous sections of sand fencing
were identified on North Carolina’s oceanfront beaches in the three years after Hurricane Sandy;
only New Jersey had more contiguous sections of sand fencing (1,305), but had a slightly lower
total length of sandy beach modified by fencing (60.26 miles, or 96.98 km) (Rice 2017). Sand
fencing traps sand (typically lighter fine-grained sand) and may stabilize continuous dunes in

127
developed areas, thereby also degrading, fragmenting, or eliminating sparsely vegetated and
unvegetated habitats used by the red knot.

Pedestrian Use of the Beach: There are a number of potential sources of pedestrians and pets on
North Carolina beaches, including those individuals originating from beachfront or boat access
points, public access points, and hotels, resorts, and residences.

Disturbance from recreational use reduces the time migrating shorebirds spend foraging (Burger
1991). Pfister et al. (1992) implicate disturbance as a factor in the long-term decline of
migrating shorebirds at staging areas. In many cases, dogs accompany pedestrians to the beach.
Shorebirds are more likely to flush from the presence of dogs than people, and breeding and
nonbreeding shorebirds react to dogs from farther distances than people (Lafferty 2001a, 2001b;
Lord et al. 2001; Thomas et al. 2003). Foraging shorebirds at a migratory stopover on Delaware
Bay, New Jersey responded most strongly to dogs compared with other disturbances; shorebirds
often failed to return within ten minutes after the dog left the beach (Burger et al. 2007). Dogs
off-leash were disproportionate sources of disturbance in several studies (Thomas et al. 2003;
Lafferty 2001b), but leashed dogs also disturbed shorebirds. Pedestrians walking with dogs
often go through flocks of foraging and roosting shorebirds; some even encourage their dogs to
chase birds.

Horseback riding is allowed on North Carolina beaches including Emerald Isle, Hatteras Island,
and Carolina Beach (Freeman Park). Horseback riding may cause adverse impacts to red knot
habitat, by causing compaction or erosion, trampling of wrack and vegetation, and flushing of
birds. In general, a horse and rider may cause greater individual static ground pressure than cars,
because of the small ground area over which the weight is spread (UK CEED 2000).

Off-Road Vehicles: Off-road vehicles can disrupt red knots’ normal behavior patterns. In a
study of migrating shorebirds in Maryland, Forgues (2010) found that shorebird abundance
declined with increased off-road vehicle frequency, as did the number and size of roosts.
Migrants spent less time foraging in the presence of vehicles. In North Carolina, a before-after
control-impact experiment using the undisturbed plots as the controls found that vehicle
disturbance decreased abundance of shorebirds and altered their habitat use during fall migration
(Tarr 2008). Recreational activities, especially off-road vehicles, may degrade red knot habitat.
Tires that crush wrack into the sand render it unavailable as a roosting habitat or foraging
substrate (Goldin 1993; Hoopes 1993). Off-road vehicles are allowed on portions Cape Hatteras
National Seashore (including Ocracoke Island) and Cape Lookout National Seashore for most if
not all of the year. Driving is also allowed at Fort Fisher. Other communities which allow beach
driving for at least portions of the year include Corolla, Duck, Nags Head, Kill Devil Hills,
Atlantic Beach, Emerald Isle, Indian Beach, Salter Path, North Topsail Beach, Surf City, Topsail
Beach, and Carolina Beach (Pippin 2013).

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4.3. Effects of the Action

This section is an analysis of the beneficial, direct and indirect effects of the proposed action on
migrating and wintering red knots within the Action Area. The analysis includes effects
interrelated and interdependent of the project activities. An interrelated activity is an activity
that is part of a proposed action and depends on the proposed activity. An interdependent
activity is an activity that has no independent utility apart from the action.

4.3.1. Factors to be considered

The proposed project will occur within habitat used by red knots and construction will occur
during a portion of the migration and winter seasons. Project impacts could include burial of
prey items, degradation of foraging and roosting habitat, precluding the creation of new habitat,
and increasing recreational disturbance. Short-term and temporary impacts to red knots could
result from project work disturbing roosting red knots and degrading currently occupied foraging
areas.

Proximity of action: Sand placement will occur within and adjacent to red knot roosting and
foraging habitat.

Distribution: Project construction activities that may impact migrating and wintering red knots
along the coastline of North Carolina would occur on the inlet shoulder and beach front.

Timing: The timing of project construction could directly and indirectly impact migrating and
wintering red knots.

Nature of the effect: The effects of the project construction include a temporary reduction in
foraging habitat, a long term decreased rate of change that may preclude habitat creation, and
increased recreational disturbance. A decrease in the survival of red knots on the migration and
winter grounds due to the lack of optimal habitat may contribute to decreased survival rates,
decreased productivity on the breeding grounds, and increased vulnerability to the population.

Duration: These may be recurring activities, expected to last up to five and a half months each
time. Thus, the direct effects would be expected to be short-term in duration. Indirect effects
from the activity may continue to impact migrating and wintering red knots in subsequent
seasons after sand placement.

Disturbance frequency: Disturbance from each event will be short term, lasting up to two years.
However, sand placement activities may take place several times over the life of each project, or
concurrently or consecutively on adjacent beaches. Recreational disturbance may increase after
project completion and have long-term impacts.

129
Disturbance intensity and severity: Project construction is anticipated to be conducted during
portions of the red knot migration and winter seasons. The Action Area encompasses an area in
the migrating and wintering range of the red knot. Conservation measures have been
incorporated into the project to minimize impacts. The severity is likely to be slight, as red knots
located within the Action Area are expected to move outside of the construction zone due to
disturbance; therefore, no red knots are expected to be directly taken as a result of this action.

4.3.2. Analyses for effects of the action

Beneficial effects: For some highly eroded beaches, sand placement with compatible sand may
have a beneficial effect on the habitat’s ability to support wintering or migrating red knots. The
addition of compatible sand to the sediment budget may increase a sand-starved beach’s
likelihood of developing habitat features valued by red knots.

Direct effects: Direct effects are those direct or immediate effects of a project on the species or
its habitat. The construction window will extend into one or more red knot migration and winter
seasons. Heavy machinery and equipment (e.g., trucks and bulldozers operating on Action Area
beaches, the placement of the dredge pipeline along the beach, and sand disposal) may adversely
affect migrating and wintering red knots in the Action Area by disturbance and disruption of
normal activities such as roosting and foraging, and possibly forcing birds to expend valuable
energy reserves to seek available habitat elsewhere.

Burial and suffocation of invertebrate species will occur during the sand placement, and will
affect up to 25 miles of shoreline annually in North Carolina. In years following major storm
events, a maximum length of nourishment may be 62.5 miles (25 miles plus the additional 27.5
miles). Timeframes projected for benthic recruitment and re-establishment following beach
nourishment are between 6 months to 2 years.

Indirect effects: The proposed project includes beach renourishment along up to 25 miles of
shoreline annually in normal years, and up to 62.5 miles of shoreline in years following a major
storm. Indirect effects include reducing the potential for the formation of optimal habitats
(coastal marine and estuarine habitats with large areas of exposed intertidal sediments). The
proposed project may limit the creation of optimal foraging and roosting habitat, and may
increase the attractiveness of these beaches for recreation increasing recreational pressures
within the Action Area. Recreational activities that potentially adversely affect red knots include
disturbance by unleashed pets and increased pedestrian use.

4.3.3. Species’ response to the proposed action

The proposed project will occur within habitat that is used by migrating and wintering red knots.
Since red knots can be present on these beaches almost year-round, construction is likely to

130
occur while this species is utilizing these beaches and associated habitats. Short-term and
temporary impacts to red knot activities could result from project work occurring on the beach
that flushes birds from roosting or foraging habitat. Long-term impacts could include a
hindrance in the ability of migrating or wintering red knots to recuperate from their migratory
flight from their breeding grounds, survive on their wintering areas, or to build fat reserves in
preparation for migration. Long-term impacts may also result from changes in the physical
characteristics of the beach from the placement of the sand material.

4.4. Cumulative Effects

This project may occur on federal or non-federal lands. Cumulative effects include the effects of
future State, tribal, local, or private actions that are reasonably certain to occur in the Action
Area considered in this biological opinion. Future Federal actions that are unrelated to the
proposed action are not considered in this section, because they require separate consultation
pursuant to section 7 of the Act. It is reasonable to expect continued shoreline stabilization, inlet
dredging, sand placement projects, sand fencing, and beach scraping along the North Carolina
shoreline in the future since erosion and sea-level rise increases would impact the existing
beachfront development. However, with the exception of some of the above-listed project types,
most of the future actions that are reasonable certain to occur will require a Clean Water Act
(CWA) Section 404 permit, and thus will require separate consultation.

4.5 Conclusion

After reviewing the current status of the migrating and wintering red knot populations, the
environmental baseline for the Action Area, the effects of the proposed activities, the proposed
Conservation Measures, and the cumulative effects, it is the Service’s biological opinion that
implementation of these actions, as proposed, is not likely to jeopardize the continued existence
of the red knot.

• Construction will occur and/or will likely have an effect on up to 25 miles of North
Carolina shoreline annually in normal years, and up to 62.5 miles of shoreline in years
following a major storm.
• Red knots have been documented in the Action Area.
• Short-term and temporary impacts to red knot activities could result from project work
occurring on the beach that flushes birds from roosting or foraging habitat.
• Long-term impacts could include a hindrance in the ability of migrating or wintering red
knots to recuperate from their migratory flight from their breeding grounds, survive on
their wintering areas, or to build fat reserves in preparation for migration.
• The survival and recovery of red knots is fundamentally dependent on the continued
availability of sufficient habitat in their migration and wintering range.

131
5. SEABEACH AMARANTH

5.1. Status of the Species/Critical Habitat

5.1.1. Species/critical habitat description

Seabeach amaranth (Amaranthus pumilus) is an annual plant that grows on Atlantic barrier
islands and ocean beaches currently ranging from South Carolina to New York. It was listed as
threatened under the ESA on April 7, 1993 (58 FR 18035) because of its vulnerability to human
and natural impacts and the fact that it had been eliminated from two-thirds of its historic range
(USFWS 1996b). Seabeach amaranth stems are fleshy and pink-red or reddish, with small
rounded leaves that are 0.5 to 1.0 inches in diameter. The green leaves, with indented veins, are
clustered toward the tip of the stems, and have a small notch at the rounded tip. Flowers and
fruits are relatively inconspicuous, borne in clusters along the stems. There is no designation of
critical habitat for seabeach amaranth.

5.1.2. Life history

Seabeach amaranth is an annual plant. Germination of seabeach amaranth seeds occurs over a
relatively long period, generally from April to July. Upon germinating, this plant initially forms a
small unbranched sprig, but soon begins to branch profusely into a clump. This clump often
reaches one foot in diameter and consists of five to 20 branches. Occasionally, a clump may get
as large as three feet or more across, with 100 or more branches. Flowering begins as soon as
plants have reached sufficient size, sometimes as early as June, but more typically commencing
in July and continuing until the death of the plant in late fall. Seed production begins in July or
August and peaks in September during most years, but continues until the death of the plant.
Weather events, including rainfall, hurricanes, and temperature extremes, and predation by
webworms have strong effects on the length of the reproductive season of seabeach amaranth.
Because of one or more of these influences, the flowering and fruiting period can be terminated
as early as June or July. Under favorable circumstances, however, the reproductive season may
extend until January or sometimes later (Radford et al. 1968; Bucher and Weakley 1990;
Weakley and Bucher1992).

5.1.3. Population dynamics

Within North Carolina and across its range, seabeach amaranth numbers vary from year to year.
Data in North Carolina is available from 1987 to 2013. Recently, the number of plants across the
entire state dwindled from a high of 19,978 in 2005 to 165 in 2013. This trend of decreasing
numbers is seen throughout its range. 249,261 plants were found throughout the species’ range
in 2000. By 2013, those numbers had dwindled to 1,320 plants. In 2014, there was a slight
increase in the number of plants to 2,829 (USFWS, unpublished data).

132
Seabeach amaranth is dependent on natural coastal processes to create and maintain habitat.
However, high tides and storm surges from tropical systems can overwash, bury, or inundate
seabeach amaranth plants or seeds, and seed dispersal may be affected by strong storm events.
In September of 1989, Hurricane Hugo struck the Atlantic Coast near Charleston, South
Carolina, causing extensive flooding and erosion north to the Cape Fear region of North
Carolina, with less severe effects extending northward throughout the range of seabeach
amaranth. This was followed by several severe storms that, while not as significant as Hurricane
Hugo, caused substantial erosion of many barrier islands in the seabeach amaranth's range.
Surveys for seabeach amaranth revealed that the effects of these climatic events were substantial
(Weakley and Bucher 1992). In the Carolinas, populations of amaranth were severely reduced.
In South Carolina, where the effects of Hurricane Hugo and subsequent dune reconstruction were
extensive, amaranth numbers declined from 1,800 in 1988 to 188 in 1990, a reduction of 90
percent. A 74 percent reduction in amaranth numbers occurred in North Carolina, from 41,851
plants in 1988 to 10,898 in 1990. Although population numbers in New York increased in 1990,
range-wide totals of seabeach amaranth were reduced 76 percent from 1988 (Weakley and
Bucher 1992). The influence stochastic events have on long-term population trends of seabeach
amaranth has not been assessed.

5.1.4. Status and distribution

The species historically occurred in nine states from Rhode Island to South Carolina (USFWS
2003c). By the late 1980s, habitat loss and other factors had reduced the range of this species to
North and South Carolina. Since 1990, seabeach amaranth has reappeared in several states that
had lost their populations in earlier decades. However, threats like habitat loss have not
diminished, and populations are declining overall. It is currently found in New York, New
Jersey, Delaware, Maryland, Virginia, North Carolina, and South Carolina. The typical habitat
where this species is found includes the lower foredunes and upper beach strands on the ocean
side of the primary sand dunes and overwash flats at accreting spits or ends of barrier islands.
Seabeach amaranth has been and continues to be threatened by destruction or adverse alteration
of its habitat. As a fugitive species dependent on a dynamic landscape and large-scale
geophysical processes, it is extremely vulnerable to habitat fragmentation and isolation of small
populations. Further, because this species is easily recognizable and accessible, it is vulnerable to
taking, vandalism, and the incidental trampling by curiosity seekers. Seabeach amaranth is
afforded legal protection in North Carolina by the General Statutes of North Carolina, Sections
106-202.15, 106- 202.19 (N.C. Gen. Stat. section 106 (Supp. 1991)), which provide for
protection from intrastate trade (without a permit).

The most serious threats to the continued existence of seabeach amaranth are construction of
beach stabilization structures, natural and man-induced beach erosion and tidal inundation, fungi
(i.e., white wilt), beach grooming, herbivory by insects and mammals, and off-road vehicles.
Herbivory by webworms, deer, feral horses, and rabbits is a major source of mortality and

133
lowered fecundity for seabeach amaranth. However, the extent to which herbivory affects the
species as a whole is unknown.

Potential effects to seabeach amaranth from vehicle use on the beaches include vehicles running
over, crushing, burying, or breaking plants, burying seeds, degrading habitat through compaction
of sand and the formation of seed sinks caused by tire ruts. Seed sinks occur when blowing seeds
fall into tire ruts, then a vehicle comes along and buries them further into the sand preventing
germination. If seeds are capable of germinating in the tire ruts, the plants are usually destroyed
before they can reproduce by other vehicles following the tire ruts. Those seeds and their
reproductive potential become lost from the population.

Pedestrians also can negatively affect seabeach amaranth plants. Seabeach amaranth occurs on
the upper portion of the beach which is often traversed by pedestrians walking from parking lots,
hotels, or vacation property to the ocean. This is also the area where beach chairs and umbrellas
are often set up and/or stored. In addition, resorts, hotels, or other vacation rental establishments
may set up volleyball courts or other sporting activity areas on the upper beach at the edge of the
dunes. All of these activities can result in the trampling and destruction of plants. Pedestrians
walking their dogs on the upper part of the beach, or dogs running freely on the upper part of the
beach, may result in the trampling and destruction of seabeach amaranth plants.
The extent of the effects that dogs have on seabeach amaranth is not known.

Recovery Criteria

Seabeach amaranth will be considered for delisting when the species exists in at least six states
within its historic range and when a minimum of 75 percent of the sites with suitable habitat
within each state are occupied by populations for l0 consecutive years (USFWS 1996b). The
recovery plan states that mechanisms must be in place to protect the plants from destructive
habitat alterations, destruction or decimation by off-road vehicles or other beach uses, and
protection of populations from debilitating webworm predation.

5.1.5. Analysis of the species likely to be affected

The predominant threat to seabeach amaranth is the destruction or alteration of suitable habitat,
primarily because of beach stabilization efforts and storm-related erosion (USFWS 1993). Other
important threats to the plant include beach grooming and vehicular traffic, which can easily
break or crush the fleshy plant and bury seeds below depths from which they can germinate; and
predation by webworms (caterpillars of small moths) (USFWS 1993). Webworms feed on the
leaves of the plant and can defoliate the plants to the point of either killing them or at least
reducing their seed production. Beach vitex (Vitex rotundifulia) is another threat to seabeach
amaranth, as it is an aggressive, invasive, woody plant that can occupy habitat similar to
seabeach amaranth and outcompete it (Invasive Species Specialist Group (ISSG) 2010).

134
The proposed action has the potential to adversely affect seabeach amaranth. Potential effects
include burying, trampling, or injuring plants as a result of construction operations and/or
sediment disposal activities; burying seeds to a depth that would prevent future germination as a
result of construction operations and/or sediment disposal activities; and, destruction of plants by
trampling or breaking as a result of increased recreational activities. Sand may be placed
between November 16 and April 30, which includes portions of the growing season of seabeach
amaranth. Therefore, there is also the potential for sand placement to adversely impact plants in
the Action Area.

Table 21 lists biological opinions that have been issued for adverse impacts to seabeach
amaranth since 2014, within the Raleigh Field Office geographic area. Activities addressed by
the BOs include inlet dredging, sand placement, construction of sandbag revetments, and
terminal groin construction.

135
Table 21. BOs issued since 2014 within the Raleigh Field Office geographic area.

OPINIONS SEABEACH AMARANTH
HABITAT
Fiscal Year 2014: 1 BO 12,600 lf
(2.4 mi)
Fiscal Year 2015: 4 BOs 67,968 lf
(12.9 mi)
Fiscal Year 2016: 5 BOs 169,250 lf
(32.05 mi)
Fiscal Year 2017 (to date): 1 BO 27,650 lf (5.24 mi)
Total: 11 BOs 277,468 lf
(52.55 mi)

5.2. Environmental Baseline

5.2.1. Status of the species within the Action Area

Since 1992, seabeach amaranth surveys have been conducted along much of the North Carolina
shoreline. The numbers of seabeach amaranth vary widely from year to year. See Table 22 for
data from the Corps and the Service (unpublished). Seabeach amaranth has not typically been
observed in Dare County, but there are records for all other beaches in the state. Since 1992, the
statewide total number of seabeach amaranth records has varied from as few as 105 plants in the
year 2000 to 33,514 plants in 1995. Over the past 12 years, the numbers of seabeach amaranth
have declined dramatically across the state. It is unclear what is causing the decline in numbers
of plants.
Table 22. Annual seabeach amaranth records in North Carolina, from 1987 to 2014. Data from various sources, collated by the Service.

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1987 5474 1409 58 0 0 0 0 3337 10278
1988 2518 13310 900 2 0 0 0 3531 20261
1989 0 0 0 0 0 0 0
1990 3082 250 339 175 0 0 0 613 4459
1991 0 0 467 703 0 0 0 0 0 1170
1992 0 10 2556 407 0 22410 416 0 2 9 1 3148 21 5 3175 32160
1993 1290 975 3762 73 0 2089 1344 157 0 7 35 26 6103 52 15 6286 22214
1994 0 0 704 948 1181 3 0 135 1309 38 0 19 103 2 4409 239 112 4762 13964
1995 0 1 75 1155 14776 0 1925 3965 1323 0 295 579 1 4628 59 22 4710 33514
1996 88 10 1 3 0 0 1000 995 289 0 93 37 1983 99 819 3038 8455
1997 65 6 2 51 81 0 3 22 0 1 0 599 1 7 607 1445
1998 265 0 125 369 3946 1000 0 110 191 0 231 1 107 5367 32 11 0 11755
1999 8 0 2 9 218 1 0 39 1 0 6 0 24 15 268 5 0 596
2000 2 0 4 13 40 0 12 5 0 3 3 9 10 4 105
2001 43 8 51 126 451 0 4041 64 0 9 1 66 223 5 5088
2002 86 7 71 261 1983 50 0 413 104 72 51 0 542 702 45 4387
2003 19 11 206 1354 5270 66 0 1043 735 3 207 0 1267 843 206 11230
2004 1 0 79 58 5292 22 1797 1722 782 656 664 2 0 11 79 49 11214
2005 1 1 284 671 10711 1302 3416 1011 244 772 0 1 45 174 800 545 19978
2006 0 0 33 30 251 2 16 39 4 1 4 462 1954 337 118 3251
2007 0 0 2 125 130 6 5 160 21 0 9 0 0 0 116 281 20 875
2008 0 0 0 0 76 313 17 432 14 0 3 0 0 2 65 574 110 1606
2009 0 0 0 1 100 281 71 15 80 6 0 0 0 0 8 64 123 36 785
2010 0 0 0 6 28 70 187 32 215 18 4 0 0 0 0 1576 434 4 2574
2011 0 0 0 1 18 56 0 6 136 0 17 2 0 0 0 16 116 5 373
2012 0 0 0 0 7 5 1 4 83 2 0 0 NS 0 NS 5 46 1 154
2013 0 0 0 0 0 1 0 1 10 1 31 0 0 0 NS 1 108 1 12 166
2014 0 0 52 0 27 38 3 0 0 0 0 1 349 20 36 526
Site Totals 0 0 11652 15013 4234 6564 51893 2592 3206 39528 1115 7665 4385 1507 1494 825 261 30627 7413 2384 166 30059 222583
222583
5.2.2. Factors affecting the species environment within the Action Area

A wide range of recent and on-going beach disturbance activities have altered the North Carolina
coastline, and many more are proposed along the coastline for the near future. Appendix A
(copied from the PBA) and Table 11 (page 73) list many of these activities.

Beach nourishment: The beaches of North Carolina are regularly nourished with sand from the
Corps and locally-managed activities. Nourishment activities widen beaches, change their
sedimentology and stratigraphy, alter coastal processes and often plug dune gaps and remove
overwash areas.

Beach scraping can artificially steepen beaches, stabilize dune scarps, plug dune gaps, and
redistribute sediment distribution patterns. Artificial dune building, often a product of beach
scraping, removes low-lying overwash areas and dune gaps. As chronic erosion catches up to
structures throughout the Action Area, artificial dune systems are constructed and maintained to
protect beachfront structures either by sand fencing or fill placement. Beach scraping or
bulldozing has become more frequent on North Carolina beaches in the past 20 years, in
response to storms and the continuing retreat of the shoreline with rising sea level. These
activities primarily occur during the winter months. Artificial dune or berm systems have been
constructed and maintained in several areas. These dunes make the artificial dune ridge function
like a seawall that blocks natural beach retreat, evolution, and overwash.

Beach raking and rock-picking: Man-made beach cleaning and raking machines effectively
remove seaweed, plants, fish, glass, syringes, plastic, cans, cigarettes, shells, stone, wood, and
virtually any unwanted debris (Barber Beach Cleaning Equipment 2009). These efforts may
remove seabeach amaranth. Although the amount of sand lost due to single sweeping actions
may be small, it adds up considerably over a period of years (Nordstrom et al. 2006; Neal et al.
2007). Beach cleaning or grooming can result in abnormally broad unvegetated zones that are
inhospitable to dune formation or plant colonization, thereby enhancing the likelihood of erosion
(Defreo et al. 2009).

Pedestrian Use of the Beach: There are a number of potential sources of pedestrians and pets on
North Carolina beaches, including those individuals originating from beachfront, public access
points, and nearby hotels, resorts, and residences.

Shoreline stabilization: Sandbags on private properties provide stabilization to the shoreline of
North Carolina Beaches. Sandbags and sandbag revetments have been placed along at least
1,800 lf of the eastern shoreline on Ocean Isle Beach, and the Tubbs Inlet shoreline on Ocean
Isle Beach is completely lined with a sandbag revetment. In 2014/2015, a sandbag revetment
was constructed on over 1,800 lf of shoreline at the north end of Topsail Island. The intertidal
areas and sand flats along the inlet were used as a sand source. The inlet shoreline downdrift of
the sandbag revetment has eroded significantly since installation. A rock revetment was
constructed several years ago in Carolina Beach (approximately 2,050 lf). In addition, the Town
of Ocean Isle Beach has requested authorization for construction of a single, 1,050 lf terminal
groin (300 lf landward, and 750 lf waterward of mean high water or MHW) on the east end of
the island, placement of a concurrent 3,214 lf sand fillet, and the periodic placement of sand in
the fillet from either scheduled federal disposal events and/or from locally-sponsored beach
nourishment and disposal projects. The project is not yet constructed.

138
5.3. Effects of the Action

5.3.1. Factors to be considered

Proximity of action: Beach renourishment will occur within and adjacent to seabeach amaranth
habitat.

Distribution: Project construction activities that may affect seabeach amaranth plants would
occur along the North Carolina shoreline.

Timing: The timing of project construction could directly and indirectly impact seabeach
amaranth. In warm years, seabeach amaranth plants may be present until January.

Nature of the effect: The effects of the project construction include burying, trampling, or
injuring plants as a result of construction operations and/or sediment disposal activities; burying
seeds to a depth that would prevent future germination as a result of construction operations
and/or sediment disposal activities; and destruction of plants by trampling or breaking as a result
of increased recreational activities.

Duration: These may be recurring activities, expected to last up to five and a half months each
time. Thus, the direct effects would be expected to be short-term in duration. Indirect effects
from the activity may continue to impact seabeach amaranth in subsequent seasons after sand
placement.

Disturbance frequency: Disturbance from each event will be short term, lasting up to two years.
However, sand placement activities may take place several times over the life of the project.
Recreational disturbance may increase after project completion and have long-term impacts.

Disturbance intensity and severity: Project construction is anticipated to be conducted during
portions of the seabeach amaranth growing and flowering season. Conservation measures have
been incorporated into the project to minimize impacts.

5.3.2. Analyses for effects of the action

Beneficial Effects: The placement of beach-compatible sand may benefit this species by
providing additional suitable habitat or by redistributing seed sources buried during past storm
events, beach disposal activities, or natural barrier island migration. Disposal of sand may be
compatible with seabeach amaranth provided the timing of beach disposal is appropriate and the
material placed on the beach is compatible with the natural sand. Further studies are needed to
determine the best methods of beach disposal in seabeach amaranth habitat (Weakley and Bucher
1992).

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Direct Effects: Sand placement activities may bury or destroy existing plants, resulting in
mortality, or bury seeds to a depth that would prevent future germination, resulting in reduced
plant populations. Increased traffic from recreationists and their pets can also destroy existing
plants by trampling or breaking the plants.

Indirect Effects: Future tilling on the beach may be necessary if beach compaction hinders sea
turtle nesting activities. The placement of heavy machinery or associated tilling equipment on
the beach may destroy or bury existing plants.

5.3.3. Species’ response to the proposed action

The placement of sand in the Action Area could bury existing plants if work is conducted during
the growing season. Sand placement at any time of year could also bury seeds to a depth that
would prevent germination.

Sand placement on beaches could also have positive impacts on seabeach amaranth by creating
additional habitat for the species, if the material is compatible. Although more study is needed
before the long-term impacts can be accurately assessed, several populations are shown to have
established themselves on beaches receiving dredged sediments, and have thrived through
subsequent applications of dredged material (Weakley and Bucher 1992).

5.4. Cumulative Effects

This project may occur on federal or non-federal lands. Cumulative effects include the effects of
future State, tribal, local, or private actions that are reasonably certain to occur in the Action
Area considered in this biological opinion. Future Federal actions that are unrelated to the
proposed action are not considered in this section, because they require separate consultation
pursuant to section 7 of the Act. It is reasonable to expect continued shoreline stabilization, sand
placement projects, sand fencing, and beach scraping along the North Carolina shoreline in the
future since erosion and sea-level rise increases would impact the existing beachfront
development. However, with the exception of some of the above-listed project types, most of the
future actions that are reasonable certain to occur will require a Clean Water Act (CWA) Section
404 permit, and thus will require separate consultation.

5.5. Conclusion

After reviewing the current status of the seabeach amaranth population, the environmental
baseline for the Action Area, the effects of the proposed activities, the proposed Conservation
Measures, and the cumulative effects, it is the Service’s biological opinion that implementation
of these actions, as proposed, is not likely to jeopardize the continued existence of the seabeach
amaranth.

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• Construction will occur and/or will likely have an effect on up to 25 miles of North
Carolina shoreline annually in normal years, and up to 62.5 miles of shoreline in years
following a major storm.
• Seabeach amaranth has been documented in the Action Area.
• The placement of sand in the Action Area could bury existing plants and also bury seeds
to a depth that would prevent germination.
• Increased traffic from recreationists and their pets can also destroy existing plants by
trampling or breaking the plants.
• It is unclear whether the placement of sand would have positive impacts on seabeach
amaranth by creating additional habitat for the species, or by exposing seeds that had
previously buried.

6. LOGGERHEAD, GREEN, LEATHERBACK, HAWKSBILL, AND KEMP’S
RIDLEY SEA TURTLES

6.1. Status of the Species/Critical Habitat

6.1.1. Species/critical habitat description

6.1.1.1. Species description – Loggerhead Sea Turtle

The loggerhead sea turtle, which occurs throughout the temperate and tropical regions of the
Atlantic, Pacific, and Indian Oceans, was federally listed worldwide as a threatened species on
July 28, 1978 (43 Federal Register (FR) 32800). On September 22, 2011, the loggerhead sea
turtle’s listing under the ESA was revised from a single threatened species to nine distinct
population segments (DPS) listed as either threatened or endangered (79 FR 39755). The nine
DPSs and their statuses are:

Northwest Atlantic Ocean DPS – threatened
Northeast Atlantic Ocean DPS – endangered
Mediterranean Sea DPS – endangered
South Atlantic Ocean DPS – threatened
North Pacific Ocean DPS – endangered
South Pacific Ocean DPS – endangered
North Indian Ocean DPS – endangered
Southwest Indian Ocean DPS – threatened
Southeast Indo-Pacific Ocean DPS – threatened

The loggerhead sea turtle grows to an average weight of about 200 pounds and is characterized
by a large head with blunt jaws. Adults and subadults have a reddish-brown carapace. Scales on
the top of the head and top of the flippers are also reddish-brown with yellow on the borders.

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Hatchlings are a dull brown color (National Marine Fisheries Service (NMFS) 2009a). The
loggerhead feeds on mollusks, crustaceans, fish, and other marine animals.

The loggerhead may be found hundreds of miles out to sea, as well as in inshore areas such as
bays, lagoons, salt marshes, creeks, ship channels, and the mouths of large rivers. Coral reefs,
rocky places, and ship wrecks are often used as feeding areas. Within the Northwest Atlantic,
the majority of nesting activity occurs from April through September, with a peak in June and
July (Williams-Walls et al. 1983; Dodd 1988; Weishampel et al. 2006). Nesting occurs within
the Northwest Atlantic along the coasts of North America, Central America, northern South
America, the Antilles, Bahamas, and Bermuda, but is concentrated in the southeastern U.S. and
on the Yucatán Peninsula in Mexico on open beaches or along narrow bays having suitable sand
(Sternberg 1981; Ehrhart 1989; Ehrhart et al. 2003; NMFS and USFWS 2008).

6.1.1.1.1. Critical Habitat Description - Designated critical habitat for the Northwest
Atlantic (NWA) population of loggerhead sea turtles

The Act defines critical habitat as the specific areas within the geographical area occupied by the
species, at the time it is listed in accordance with the provisions of section 4 of the Act, on which
are found those physical or biological features (1) essential to the conservation of the species and
(2) which may require special management considerations or protection, as well as specific areas
outside the geographical area occupied by the species at the time it is listed in accordance with
the provisions of section 4 of the Act, upon a determination by the Secretary that such areas are
essential for the conservation of the species (16 U.S.C. 1532(5)(A)).

This section summarizes the effects of all past human and natural activities or events that have
led to the current status of designated critical habitat for the piping plover and are relevant to
formulating the biological opinion about the proposed action.

On July 10, 2014, the Service designated portions North Carolina beaches as critical habitat for
the Northwest Atlantic (NWA) population of loggerhead sea turtles (79 FR 39756). See
Appendix C for a description of the designated critical habitat units in North Carolina. North
Carolina counties which include critical habitat for nesting loggerhead sea turtles include
Carteret, Onslow, Pender, New Hanover, and Brunswick.
In total, 1,189.9 kilometers (km) (739.3 miles) of loggerhead sea turtle nesting beaches are
designated critical habitat in the States of North Carolina, South Carolina, Georgia, Florida,
Alabama, and Mississippi. These beaches account for 48 percent of an estimated 2,464 km
(1,531 miles) of coastal beach shoreline, and account for approximately 84 percent of the
documented nesting (numbers of nests) within these six States. The designated critical habitat
has been identified by the recovery unit in which they are located. Recovery units are
management subunits of a listed entity that are geographically or otherwise identifiable and
essential to the recovery of the listed entity. Within the United States, four terrestrial recovery
units have been designated for the Northwest Atlantic population of the loggerhead sea turtle: the

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Northern Recovery Unit (NRU), Peninsular Florida Recovery Unit (PFRU), Dry Tortugas
Recovery Unit (DTRU), and Northern Gulf of Mexico Recovery Unit (NGMRU). For the NRU,
the Service has designated 393.7 km (244.7 miles) of Atlantic Ocean shoreline in North
Carolina, South Carolina, and Georgia, encompassing approximately 86 percent of the
documented nesting (numbers of nests) within the recovery unit. The eight critical habitat units
in North Carolina total 96.1 miles (154.6 km) of beach. 15.1 miles (24.3 km) are located within
state-owned lands, while 81 miles (130.3 km) are on land owned by private parties or others,
such as counties and municipalities.

Under the Act and its implementing regulations, the Service is required to identify the physical
or biological features (PBFs) essential to the conservation of the loggerhead sea turtle in areas
occupied at the time of listing, focusing on the features’ primary constituent elements (PCEs).
The Service determined that the following PBFs are essential for the loggerhead sea turtle:

(1) PBF 1—Sites For Breeding, Reproduction, or Rearing (or Development) of Offspring.
To be successful, reproduction must occur when environmental conditions support adult activity
(e.g., sufficient quality and quantity of food in the foraging area, suitable beach structure for
digging, nearby inter-nesting habitat) (Georges et al. 1993). The environmental conditions of the
nesting beach must favor embryonic development and survival (i.e., modest temperature
fluctuation, low salinity, high humidity, well drained, well aerated) (Mortimer 1982; Mortimer
1990). Additionally, the hatchlings must emerge to onshore and offshore conditions that enhance
their chances of survival (e.g., less than 100 percent depredation, appropriate offshore currents
for dispersal) (Georges et al. 1993).

(2) PBF 2 - Natural Coastal Processes or Activities That Mimic These Natural Processes.
It is important that loggerhead nesting beaches are allowed to respond naturally to coastal
dynamic processes of erosion and accretion or mimic these processes.

The Service considers PCEs to be those specific elements of the PBFs that provide for a species’
life-history processes and are essential to the conservation of the species. Based on our current
knowledge of the PBFs and habitat characteristics required to sustain the species’ life-history
processes, the terrestrial primary constituent elements specific to the Northwest Atlantic Ocean
DPS of the loggerhead sea turtle are the extra-tidal or dry sandy beaches from the mean high-
water line to the toe of the secondary dune, which are capable of supporting a high density of
nests or serving as an expansion area for beaches with a high density of nests and that are well
distributed within each State, or region within a State, and representative of total nesting,
consisting of four components:

(1) PCE 1—Suitable nesting beach habitat that has (a) relatively unimpeded nearshore access
from the ocean to the beach for nesting females and from the beach to the ocean for both post-
nesting females and hatchlings and (b) is located above mean high water to avoid being
inundated frequently by high tides.

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(2) PCE 2—Sand that (a) allows for suitable nest construction, (b) is suitable for facilitating gas
diffusion conducive to embryo development, and (c) is able to develop and maintain
temperatures and moisture content conducive to embryo development.

(3) PCE 3—Suitable nesting beach habitat with sufficient darkness to ensure nesting turtles are
not deterred from emerging onto the beach and hatchlings and post-nesting females orient to the
sea.

(4) PCE 4—Natural coastal processes or artificially created or maintained habitat mimicking
natural conditions. This includes artificial habitat types that mimic the natural conditions
described in PCEs 1 to 3 above for beach access, nest site selection, nest construction, egg
deposition and incubation, and hatchling emergence and movement to the sea.

The units in North Carolina contain all of the PBFs and PCEs. The PBFs in this unit may require
special management considerations or protections to ameliorate the threats of recreational use,
predation, beach sand placement activities, in-water and shoreline alterations, climate change,
beach erosion, artificial lighting, human-caused disasters, and response to disasters.

6.1.1.2. Species/critical habitat description - Green Sea Turtle

The green sea turtle was federally listed on July 28, 1978 (43 FR 32800). On April 6, 2016, the
NMFS and Service issued a final rule to list 11 DPSs of the green sea turtle. Three of the DPSs
are endangered species (Central South Pacific, Central West Pacific, and Mediterranean Sea),
and eight are threatened species (81 FR 20058). In North Carolina, the green sea turtle is part of
the North Atlantic Ocean DPS, and is listed as threatened. The green sea turtle has a worldwide
distribution in tropical and subtropical waters.

The green sea turtle grows to a maximum size of about 4 feet and a weight of 440 pounds. It has
a heart-shaped shell, small head, and single-clawed flippers. The carapace is smooth and colored
gray, green, brown, and black. Hatchlings are black on top and white on the bottom (NMFS
2009b). Hatchling green turtles eat a variety of plants and animals, but adults feed almost
exclusively on seagrasses and marine algae.

Major green turtle nesting colonies in the Atlantic occur on Ascension Island, Aves Island, Costa
Rica, and Surinam. Within the U.S., green turtles nest in small numbers in the U.S. Virgin
Islands and Puerto Rico, and in larger numbers along the east coast of Florida, particularly in
Brevard, Indian River, St. Lucie, Martin, Palm Beach, and Broward Counties (NMFS and
USFWS 1991). Nests have been documented, in smaller numbers, north of these Counties, from
Volusia through Nassau Counties in Florida, as well as in Georgia, South Carolina, North
Carolina, and as far north as Delaware in 2011. In 2015, 41 green sea turtle nests were
documented in North Carolina. Nests have been documented in smaller numbers south of

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Broward County in Miami-Dade. Nesting also has been documented along the Gulf coast of
Florida from Escambia County through Franklin County in northwest Florida and from Pinellas
County through Monroe County in southwest Florida (FWC/FWRI 2010b).

Green sea turtles are generally found in fairly shallow waters (except when migrating) inside
reefs, bays, and inlets. The green turtle is attracted to lagoons and shoals with an abundance of
marine grass and algae. Open beaches with a sloping platform and minimal disturbance are
required for nesting.

Critical habitat for the green sea turtle has been designated for the waters surrounding Culebra
Island, Puerto Rico, and its outlying keys (63 FR 46693). No designated critical habitat is
present in the Action Area.

6.1.1.3. Species/critical habitat description - Leatherback Sea Turtle

The leatherback sea turtle was federally listed as an endangered species on June 2, 1970 (35 FR
8491). Leatherbacks have the widest distribution of the sea turtles with nonbreeding animals
recorded as far north as the British Isles and the Maritime Provinces of Canada and as far south
as Argentina and the Cape of Good Hope (Pritchard 1992). Foraging leatherback excursions
have been documented into higher-latitude subpolar waters. They have evolved physiological
and anatomical adaptations (Frair et al. 1972; Greer et al. 1973) that allow them to exploit waters
far colder than any other sea turtle species would be capable of surviving.

The adult leatherback can reach 4 to 8 feet in length and weigh 500 to 2,000 pounds. The
carapace is distinguished by a rubber-like texture, about 1.6 inches thick, made primarily of
tough, oil-saturated connective tissue. Hatchlings are dorsally mostly black and are covered with
tiny scales; the flippers are edged in white, and rows of white scales appear as stripes along the
length of the back (NMFS 2009c). Jellyfish are the main staple of its diet, but it is also known to
feed on sea urchins, squid, crustaceans, tunicates, fish, blue-green algae, and floating seaweed.
This is the largest, deepest diving of all sea turtle species.

Leatherback turtle nesting grounds are distributed worldwide in the Atlantic, Pacific, and Indian
Oceans on beaches in the tropics and subtropics. The Pacific Coast of Mexico historically
supported the world’s largest known concentration of nesting leatherbacks. The leatherback
turtle regularly nests in the U.S. Caribbean in Puerto Rico and the U.S. Virgin Islands. Along the
U.S. Atlantic coast, most nesting occurs in Florida (NMFS and USFWS 1992). Nesting has also
been reported in Georgia, South Carolina, and North Carolina (Rabon et al. 2003) and in Texas
(Shaver 2008). Adult females require sandy nesting beaches backed with vegetation and sloped
sufficiently so the distance to dry sand is limited. Their preferred beaches have proximity to
deep water and generally rough seas.

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Marine and terrestrial critical habitat for the leatherback sea turtle has been designated at Sandy
Point on the western end of the island of St. Croix, U.S. Virgin Islands (44 FR 17710). There is
no designated critical habitat in North Carolina.

6.1.1.4. Species/critical habitat description – Kemp’s Ridley Sea Turtle

The Kemp’s ridley sea turtle was federally listed as endangered on December 2, 1970 (35 FR
18320). The Kemp's ridley, along with the flatback sea turtle (Natator depressus), has the most
geographically restricted distribution of any sea turtle species. The range of the Kemp’s ridley
includes the Gulf coasts of Mexico and the U.S., and the Atlantic coast of North America as far
north as Nova Scotia and Newfoundland.

Adult Kemp's ridleys and olive ridleys are the smallest sea turtles in the world. The weight of an
adult Kemp’s ridley is generally between 70 to 108 pounds with a carapace measuring
approximately 24 to 26 inches in length (Heppell et al. 2005). The carapace is almost as wide as
it is long. The species’ coloration changes significantly during development from the grey-black
dorsum and plastron of hatchlings, a grey-black dorsum with a yellowish-white plastron as post-
pelagic juveniles and then to the lighter grey-olive carapace and cream-white or yellowish
plastron of adults. Their diet consists mainly of swimming crabs, but may also include fish,
jellyfish, and an array of mollusks.

The Kemp’s ridley has a restricted distribution. Nesting is essentially limited to the beaches of
the western Gulf of Mexico, primarily in Tamaulipas, Mexico (NMFS et al. 2011). Nesting also
occurs in Veracruz and a few historical records exist for Campeche, Mexico (Marquez-Millan
1994). Nesting also occurs regularly in Texas and infrequently in a few other U.S. states.
However, historic nesting records in the U.S. are limited to south Texas (Werler 1951, Carr
1961, Hildebrand 1963).

Most Kemp’s ridley nests located in the U.S. have been found in south Texas, especially Padre
Island (Shaver and Caillouet 1998; Shaver 2002, 2005). Nests have been recorded elsewhere in
Texas (Shaver 2005, 2006a, 2006b, 2007, 2008), and in Florida (Johnson et al. 1999, Foote and
Mueller 2002, Hegna et al. 2006, FWC/FWRI 2010b), Alabama (J. Phillips, Service, personal
communication, 2007 cited in NMFS et al. 2011; J. Isaacs, Service, personal communication,
2008 cited in NMFS et al. 2011), Georgia (Williams et al. 2006), South Carolina (Anonymous
1992), and North Carolina (Marquez et al. 1996), but these events are less frequent. Kemp’s
ridleys inhabit the Gulf of Mexico and the Northwest Atlantic Ocean, as far north as the Grand
Banks (Watson et al. 2004) and Nova Scotia (Bleakney 1955). They occur near the Azores and
eastern north Atlantic (Deraniyagala 1938, Brongersma 1972, Fontaine et al. 1989, Bolten and
Martins 1990) and Mediterranean (Pritchard and Marquez 1973, Brongersma and Carr 1983,
Tomas and Raga 2007, Insacco and Spadola 2010).

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Juvenile Kemp’s ridleys spend on average 2 years in the oceanic zone (NMFS SEFSC
unpublished preliminary analysis, July 2004, as cited in NMFS et al. 2011) where they likely live
and feed among floating algal communities. They remain here until they reach about 7.9 inches
in length (approximately 2 years of age), at which size they enter coastal shallow water habitats
(Ogren 1989); however, the time spent in the oceanic zone may vary from 1 to 4 years or perhaps
more (Turtle Expert Working Group (TEWG) 2000, Baker and Higgins 2003, Dodge et al.
2003).

No critical habitat has been designated for the Kemp’s ridley sea turtle.

6.1.1.5. Species/critical habitat description – Hawksbill Sea Turtle

The hawksbill sea turtle was Federally listed as endangered on June 2, 1970 (35 FR 8491). The
hawksbill is found in tropical and subtropical seas of the Atlantic, Pacific, and Indian Oceans.
The species is widely distributed in the Caribbean Sea and western Atlantic Ocean. Data
collected in the Wider Caribbean reported that hawksbills typically weigh around 176 pounds or
less; hatchlings average about 1.6 inches straight length and range in weight from 0.5 to 0.7
ounces. The carapace is heart shaped in young turtles, and becomes more elongated or egg-
shaped with maturity. The top scutes are often richly patterned with irregularly radiating streaks
of brown or black on an amber background. The head is elongated and tapers sharply to a point.
The lower jaw is V-shaped (NMFS 2009d).

Within the continental U.S., hawksbill sea turtle nesting is rare, and nests are only known from
Florida and North Carolina. Nesting in Florida is restricted to the southeastern coast of Florida
(Volusia through Miami-Dade Counties) and the Florida Keys (Monroe County) (Meylan 1992;
Meylan et al. 1995). Two nests have been recorded in North Carolina, both in 2015. Both nests,
located on the Seashore, were originally thought to be loggerhead nests, but discovered to be
hawksbill nests after DNA testing of eggshells. Hawksbill tracks are difficult to differentiate
from those of loggerheads and may not be recognized by surveyors. Therefore, surveys in
Florida and elsewhere in the southeastern U.S. likely underestimate actual hawksbill nesting
numbers (Meylan et al. 1995). In the U.S. Caribbean, hawksbill nesting occurs on beaches
throughout Puerto Rico and the U.S. Virgin Islands (NMFS and USFWS 1993).

Critical Habitat for the hawksbill sea turtle was designated on June 24, 1982 (47 FR 27295) and
September 2, 1998 (63 FR 46693). Critical habitat for the hawksbill sea turtle has been
designated for selected beaches and/or waters of Mona, Monito, Culebrita, and Culebra Islands,
Puerto Rico. There is no designated critical habitat in North Carolina.

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6.1.2. Life history

6.1.2.1. Life history – Loggerhead Sea Turtle

Loggerheads are long-lived, slow-growing animals that use multiple habitats across entire ocean
basins throughout their life history. This complex life history encompasses terrestrial, nearshore,
and open ocean habitats. The three basic ecosystems in which loggerheads live are the:

1. Terrestrial zone (supralittoral) - the nesting beach where both oviposition (egg laying)
and embryonic development and hatching occur.

2. Neritic zone - the inshore marine environment (from the surface to the sea floor) where
water depths do not exceed 656 feet. The neritic zone generally includes the continental
shelf, but in areas where the continental shelf is very narrow or nonexistent, the neritic
zone conventionally extends to areas where water depths are less than 656 feet.

3. Oceanic zone - the vast open ocean environment (from the surface to the sea floor) where
water depths are greater than 656 feet.

Maximum intrinsic growth rates of sea turtles are limited by the extremely long duration of the
juvenile stage and fecundity. Loggerheads require high survival rates in the juvenile and adult
stages, common constraints critical to maintaining long-lived, slow-growing species, to achieve
positive or stable long-term population growth (Congdon et al. 1993; Heppell 1998; Crouse
1999; Heppell et al. 1999; 2003; Musick 1999).

Numbers of nests and nesting females are often highly variable from year to year due to a
number of factors including environmental stochasticity, periodicity in ocean conditions,
anthropogenic effects, and density-dependent and density-independent factors affecting survival,
somatic growth, and reproduction (Meylan 1982; Hays 2000; Chaloupka 2001; Solow et al.
2002). Despite these sources of variation, and because female turtles exhibit strong nest site
fidelity, a nesting beach survey can provide a valuable assessment of changes in the adult female
population, provided that the study is sufficiently long and effort and methods are standardized
(Meylan 1982; Gerrodette and Brandon 2000; Reina et al. 2002). Table 23 summarizes key life
history characteristics for loggerheads nesting in the U.S.

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Table 23. Typical values of life history parameters for loggerheads nesting in the U.S. (NMFS
and USFWS 2008).
Life History Trait Data
Clutch size (mean) 100-126 eggs1
Incubation duration (varies depending on time of year and
latitude) Range = 42-75 days2,3
Pivotal temperature (incubation temperature that produces an
equal number of males and females) 84˚F5
Nest productivity (emerged hatchlings/total eggs) x 100
(varies depending on site specific factors) 45-70 percent2,6
Clutch frequency (number of nests/female/season) 3-4 nests7
Internesting interval (number of days between successive
nests within a season) 12-15 days8
Juvenile (<34 inches Curved Carapace Length) sex ratio 65-70 percent female4
Remigration interval (number of years between successive
nesting migrations) 2.5-3.7 years9
Nesting season late April-early September
Hatching season late June-early November
Age at sexual maturity 32-35 years10
Life span >57 years11
1 Dodd (1988).
2 Dodd and Mackinnon (1999, 2000, 2001, 2002, 2003, 2004).
3 Witherington (2006) (information based on nests monitored throughout Florida beaches in 2005, n =
865).
4 NMFS (2001); Foley (2005).
5 Mrosovsky (1988).
6 Witherington (2006) (information based on nests monitored throughout Florida beaches in 2005, n =
1,680).
7 Murphy and Hopkins (1984); Frazer and Richardson (1985); Hawkes et al. 2005; Scott 2006.
8 Caldwell (1962), Dodd (1988).
9 Richardson et al. (1978); Bjorndal et al. (1983).
10 Snover (2005).
11 Dahlen et al. (2000).

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Loggerheads nest on ocean beaches and occasionally on estuarine shorelines with suitable sand.
Nests are typically laid between the high tide line and the dune front (Routa 1968; Witherington
1986; Hailman and Elowson 1992). Wood and Bjorndal (2000) evaluated four environmental
factors (slope, temperature, moisture, and salinity) and found that slope had the greatest
influence on loggerhead nest-site selection on a beach in Florida. Loggerheads appear to prefer
relatively narrow, steeply sloped, coarse-grained beaches, although nearshore contours may also
play a role in nesting beach site selection (Provancha and Ehrhart 1987).

The warmer the sand surrounding the egg chamber, the faster the embryos develop (Mrosovsky
and Yntema 1980). Sand temperatures prevailing during the middle third of the incubation
period also determine the sex of hatchling sea turtles (Mrosovsky and Yntema 1980). Incubation
temperatures near the upper end of the tolerable range produce only female hatchlings while
incubation temperatures near the lower end of the tolerable range produce only male hatchlings.

Loggerhead hatchlings pip and escape from their eggs over a 1- to 3-day interval and move
upward and out of the nest over a 2- to 4-day interval (Christens 1990). The time from pipping
to emergence ranges from 4 to 7 days with an average of 4.1 days (Godfrey and Mrosovsky
1997). Hatchlings emerge from their nests en masse almost exclusively at night, and presumably
using decreasing sand temperature as a cue (Hendrickson 1958; Mrosovsky 1968; Witherington
et al. 1990). Moran et al. (1999) concluded that a lowering of sand temperatures below a critical
threshold, which most typically occurs after nightfall, is the most probable trigger for hatchling
emergence from a nest. After an initial emergence, there may be secondary emergences on
subsequent nights (Carr and Ogren 1960; Witherington 1986; Ernest and Martin 1993; Houghton
and Hays 2001).

Hatchlings use a progression of orientation cues to guide their movement from the nest to the
marine environments where they spend their early years (Lohmann and Lohmann 2003).
Hatchlings first use light cues to find the ocean. On naturally lighted beaches without artificial
lighting, ambient light from the open sky creates a relatively bright horizon compared to the dark
silhouette of the dune and vegetation landward of the nest. This contrast guides the hatchlings to
the ocean (Daniel and Smith 1947; Limpus 1971; Salmon et al. 1992; Witherington and Martin
1996; Witherington 1997; Stewart and Wyneken 2004).

6.1.2.2. Life history - Green Sea Turtle

Green sea turtles deposit from one to nine clutches within a nesting season, but the overall
average is about 3.3 nests. The interval between nesting events within a season varies around a
mean of about 13 days (Hirth 1997). Mean clutch size varies widely among populations. Clutch
size varies from 75 to 200 eggs with incubation requiring 48 to 70 days, depending on incubation
temperatures. Only occasionally do females produce clutches in successive years. Usually two
or more years intervene between breeding seasons (NMFS and USFWS 1991). Age at sexual
maturity is believed to be 20 to 50 years (Hirth 1997).

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6.1.2.3. Life history – Leatherback Sea Turtle

Leatherbacks nest an average of five to seven times within a nesting season, with an observed
maximum of 11 nests (NMFS and USFWS 1992). The interval between nesting events within a
season is about 9 to 10 days. Clutch size averages 80 to 85 yolked eggs, with the addition of
usually a few dozen smaller, yolkless eggs, mostly laid toward the end of the clutch (Pritchard
1992). Nesting migration intervals of 2 to 3 years were observed in leatherbacks nesting on the
Sandy Point National Wildlife Refuge, St. Croix, U.S. Virgin Islands (McDonald and Dutton
1996). Leatherbacks are believed to reach sexual maturity in 13 to 16 years (Dutton et al. 2005;
Jones et al. 2011).

6.1.2.4. Life history – Kemp’s Ridley Sea Turtle

Nesting occurs primarily from April into July. Nesting often occurs in synchronized
emergences, known as “arribadas” or “arribazones,” which may be triggered by high wind
speeds, especially north winds, and changes in barometric pressure (Jimenez et al. 2005).
Nesting occurs primarily during daylight hours. Clutch size averages 100 eggs and eggs
typically take 45 to 58 days to hatch depending on incubation conditions, especially temperatures
(Marquez-Millan 1994, Rostal 2007).

Females lay an average of 2.5 clutches within a season (TEWG 1998) and inter-nesting interval
generally ranges from 14 to 28 days (Miller 1997; Donna Shaver, Padre Island National
Seashore, personal communication, 2007 as cited in NMFS et al. 2011). The mean remigration
interval for adult females is 2 years, although intervals of 1 and 3 years are not uncommon
(Marquez et al. 1982; TEWG 1998, 2000). Males may not be reproductively active on an annual
basis (Wibbels et al. 1991). Age at sexual maturity is believed to be between 10 to 17 years
(Snover et al. 2007).

6.1.2.5. Life history – Hawksbill Sea Turtle

Hawksbills nest on average about 4.5 times per season at intervals of approximately 14 days
(Corliss et al. 1989). In Florida and the U.S. Caribbean, clutch size is approximately 140 eggs,
although several records exist of over 200 eggs per nest (NMFS and USFWS 1993). On the basis
of limited information, nesting migration intervals of two to three years appear to predominate.

Hawksbills are recruited into the reef environment at about 14 inches in length and are believed
to begin breeding about 30 years later. However, the time required to reach 14 inches in length is
unknown and growth rates vary geographically. As a result, actual age at sexual maturity is
unknown.

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6.1.3. Population dynamics

6.1.3.1. Population dynamics – Loggerhead Sea Turtle

The loggerhead occurs throughout the temperate and tropical regions of the Atlantic, Pacific, and
Indian Oceans (Dodd 1988). However, the majority of loggerhead nesting is at the western rims
of the Atlantic and Indian Oceans. The most recent reviews show that only two loggerhead
nesting beaches have greater than 10,000 females nesting per year (Baldwin et al. 2003; Ehrhart
et al. 2003; Kamezaki et al. 2003; Limpus and Limpus 2003; Margaritoulis et al. 2003):
Peninsular Florida (U.S.) and Masirah (Oman). Those beaches with 1,000 to 9,999 females
nesting each year are Georgia through North Carolina (U.S.), Quintana Roo and Yucatán
(Mexico), Cape Verde Islands (Cape Verde, eastern Atlantic off Africa), and Western Australia
(Australia).

The major nesting concentrations in the U.S. are found in South Florida. However, loggerheads
nest from Texas to Virginia. Since 2000, the annual number of loggerhead nests in NC has
fluctuated between 333 in 2004 to 1,260 in 2013 (Godfrey, unpublished data). Total estimated
nesting in the U.S. has fluctuated between 49,000 and 90,000 nests per year from 1999-2010
(NMFS and USFWS 2008; FWC/FWRI 2010a). Adult loggerheads are known to make
considerable migrations between foraging areas and nesting beaches (Schroeder et al. 2003;
Foley et al. 2008). During non-nesting years, adult females from U.S. beaches are distributed in
waters off the eastern U.S. and throughout the Gulf of Mexico, Bahamas, Greater Antilles, and
Yucatán.

From a global perspective, the U.S. nesting aggregation is of paramount importance to the
survival of the species, as is the population that nests on islands in the Arabian Sea off Oman
(Ross 1982; Ehrhart 1989; Baldwin et al. 2003).

6.1.3.2. Population dynamics - Green Sea Turtle

There are an estimated 150,000 females that nest each year in 46 sites throughout the world
(NMFS and Service 2007a). In the U.S. Atlantic, the majority of nesting occurs along the coast
of eastern central Florida, with an average of 10,377 each year from 2008 to 2012 (Witherington
pers. comm. 2013). Years of coordinated conservation efforts, including protection of nesting
beaches, reduction of bycatch in fisheries, and prohibitions on the direct harvest of sea turtles,
have led to increasing numbers of turtles nesting in Florida and along the Pacific coast of
Mexico. On April 6, 2016, NMFS and the Service reclassified the status of the two segments
that include those breeding populations (North Atlantic Ocean DPS and East Pacific Ocean DPS)
from endangered to threatened (81 FR 20058). In North Carolina, between 4 and 44 green sea
turtle nests are laid annually (Godfrey, unpublished data). In the U.S. Pacific, over 90 percent of
nesting throughout the Hawaiian archipelago occurs at the French Frigate Shoals, where about
200 to 700 females nest each year (NMFS and Service 1998a). Elsewhere in the U.S. Pacific,

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nesting takes place at scattered locations in the Commonwealth of the Northern Marianas, Guam,
and American Samoa. In the western Pacific, the largest green turtle nesting aggregation in the
world occurs on Raine Island, Australia, where thousands of females nest nightly in an average
nesting season (Limpus et al. 1993). In the Indian Ocean, major nesting beaches occur in Oman
where 30,000 females are reported to nest annually (Ross and Barwani 1995).

6.1.3.3. Population dynamics – Leatherback Sea Turtle

A dramatic drop in nesting numbers has been recorded on major nesting beaches in the Pacific.
Spotila et al. (2000) have highlighted the dramatic decline and possible future extirpation of
leatherbacks in the Pacific.

The East Pacific and Malaysia leatherback populations have collapsed. Spotila et al. (1996)
estimated that only 34,500 females nested annually worldwide in 1995, which is a dramatic
decline from the 115,000 estimated in 1980 (Pritchard 1982). In the eastern Pacific, the major
nesting beaches occur in Costa Rica and Mexico. At Playa Grande, Costa Rica, considered the
most important nesting beach in the eastern Pacific, numbers have dropped from 1,367
leatherbacks in 1988-1989 to an average of 188 females nesting between 2000-2001 and 2003-
2004. In Pacific Mexico, 1982 aerial surveys of adult female leatherbacks indicated this area had
become the most important leatherback nesting beach in the world. Tens of thousands of nests
were laid on the beaches in 1980s, but during the 2003-2004 seasons a total of 120 nests were
recorded. In the western Pacific, the major nesting beaches lie in Papua New Guinea, Papua,
Indonesia, and the Solomon Islands. These are some of the last remaining significant nesting
assemblages in the Pacific. Compiled nesting data estimated approximately 5,000 to 9,200 nests
annually with 75 percent of the nests being laid in Papua, Indonesia.

However, the most recent population size estimate for the North Atlantic alone is a range of
34,000 to 94,000 adult leatherbacks (TEWG 2007). During recent years in Florida, the total
number of leatherback nests counted as part of the SNBS program ranged from 540 to 1,797
from 2006-2010 (FWC/FWRI 2010a). Assuming a clutch frequency (number of
nests/female/season) of 4.2 in Florida (Stewart 2007), these nests were produced by a range of
128 to 428 females in a given year. Nesting in North Carolina is sporadic. In 2010, two nests
were reported in North Carolina, five were reported in 2012, and none were reported in 2013-
2015.

Nesting in the Southern Caribbean occurs in the Guianas (Guyana, Suriname, and French
Guiana), Trinidad, Dominica, and Venezuela. The largest nesting populations at present occur in
the western Atlantic in French Guiana with nesting varying between a low of 5,029 nests in 1967
to a high of 63,294 nests in 2005, which represents a 92 percent increase since 1967 (TEWG
2007). Trinidad supports an estimated 6,000 leatherbacks nesting annually, which represents
more than 80 percent of the nesting in the insular Caribbean Sea. Leatherback nesting along the
Caribbean Central American coast takes place between Honduras and Colombia. In Atlantic

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Costa Rica, at Tortuguero, the number of nests laid annually between 1995 and 2006 was
estimated to range from 199 to 1,623. Modeling of the Atlantic Costa Rica data indicated that
the nesting population has decreased by 67.8 percent over this time period.

In Puerto Rico, the main nesting areas are at Fajardo (Northeast Ecological Corridor) and
Maunabo on the main island of Puerto Rico and on the islands of Culebra and Vieques. Between
1993 and 2010, the number of nests in the Fajardo area ranged from 51 to 456. In the Maunabo
area, the number of nests recorded between 2001 and 2010 ranged from a low of 53 in 2002 to a
high of 260 in 2009 (Diez 2011). On the island of Culebra, the number of nests ranged from a
low 41 in 1996 to a high of 395 in 1997 (Diez 2011). On beaches managed by the
Commonwealth of Puerto Rico on the island of Vieques, the Puerto Rico Department of Natural
and Environmental Resources recorded annually 14-61 leatherback nests between 1991 and
2000; 145 nests in 2002; 24 in 2003; and 37 in 2005 (Diez 2011). The number of leatherback sea
turtle nests recorded on Vieques Island beaches managed by the Service ranged between 13 and
163 during 2001-2010. Using the numbers of nests recorded in Puerto Rico between 1984 and
2005, the Turtle Expert Working Group (2007) estimated a population growth of approximately
10 percent per year. Recorded leatherback nesting on the Sandy Point National Wildlife Refuge
on the island of St. Croix, U.S. Virgin Islands, between 1982 and 2010, ranged from a low of 82
in 1986 to a high of 1,008 in 2001 (Garner and Garner 2010). Using the number of observed
females at Sandy Point from 1986 to 2004, the Turtle Expert Working Group (2007) estimated a
population growth of approximately 10 percent per year. In the British Virgin Islands, annual
nest numbers have increased in Tortola from zero to six nests per year in the late 1980s to 35 to
65 nests per year in the 2000s (TEWG 2007).

The most important nesting beach for leatherbacks in the eastern Atlantic lies in Gabon, Africa.
It was estimated there were 30,000 nests along 60 miles of Mayumba Beach in southern Gabon
during the 1999-2000 nesting season (Billes et al. 2000). Some nesting has been reported in
Mauritania, Senegal, the Bijagos Archipelago of Guinea-Bissau, Turtle Islands and Sherbro
Island of Sierra Leone, Liberia, Togo, Benin, Nigeria, Cameroon, Sao Tome and Principe,
continental Equatorial Guinea, Islands of Corisco in the Gulf of Guinea and the Democratic
Republic of the Congo, and Angola. In addition, a large nesting population is found on the
island of Bioko (Equatorial Guinea) (Fretey et al. 2007). In North Carolina between the year
2000 and 2013, as many as 9 nests were laid per year (Godfrey, unpublished data).

6.1.3.4. Population dynamics – Kemp’s Ridley Sea Turtle

Most Kemp’s ridleys nest on the beaches of the western Gulf of Mexico, primarily in
Tamaulipas, Mexico. Nesting also occurs in Veracruz and Campeche, Mexico, although a small
number of Kemp’s ridleys nest consistently along the Texas coast (NMFS et al. 2011). In
addition, rare nesting events have been reported in Alabama, Florida, Georgia, South Carolina,
and North Carolina. Historical information indicates that tens of thousands of ridleys nested near
Rancho Nuevo, Mexico, during the late 1940s (Hildebrand 1963). The Kemp's ridley population

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experienced a devastating decline between the late 1940s and the mid-1980s. The total number
of nests per nesting season at Rancho Nuevo remained below 1,000 throughout the 1980s, but
gradually began to increase in the 1990s. In 2009, 16,273 nests were documented along the 18.6
miles of coastline patrolled at Rancho Nuevo, and the total number of nests documented for all
the monitored beaches in Mexico was 21,144 (USFWS 2010). In 2011, a total of 20,570 nests
were documented in Mexico, 81 percent of these nests were documented in the Rancho Nuevo
beach (Burchfield and Peña 2011). In addition, 153 and 199 nests were recorded during 2010
and 2011, respectively, in the U.S., primarily in Texas.

6.1.3.5. Population dynamics - Hawksbill Sea Turtle

About 15,000 females are estimated to nest each year throughout the world with the Caribbean
accounting for 20 to 30 percent of the world’s hawksbill population. Only five regional
populations remain with more than 1,000 females nesting annually (Seychelles, Mexico,
Indonesia, and two in Australia) (Meylan and Donnelly 1999). Mexico is now the most important
region for hawksbills in the Caribbean with about 3,000 nests per year (Meylan 1999). In the
U.S. Pacific, hawksbills nest only on main island beaches in Hawaii, primarily along the east
coast of the island of Hawaii. Hawksbill nesting has also been documented in American Samoa
and Guam (NMFS and USFWS 1998b).

6.1.4. Status and distribution

Reason for Listing: There are many threats to sea turtles, including nest destruction from natural
events, such as tidal surges and hurricanes, or eggs lost to predation by raccoons, foxes, ghost-
crabs, and other animals. However, human activity has significantly contributed to the decline of
sea turtle populations along the Atlantic Coast and in the Gulf of Mexico (NRC 1990). These
factors include the modification, degradation, or loss of nesting habitat by coastal development,
artificial lighting, beach driving, and marine pollution and debris. Furthermore, the overharvest
of eggs for food, intentional killing of adults and immature turtles for their shells and skin, and
accidental drowning in commercial fishing gear are primarily responsible for the worldwide
decline in sea turtle populations.

6.1.4.1. Status and distribution – Loggerhead Sea Turtle

Range-wide Trend: Five recovery units have been identified in the Northwest Atlantic based on
genetic differences and a combination of geographic distribution of nesting densities, geographic
separation, and geopolitical boundaries (NMFS and USFWS 2008). Recovery units are subunits
of a listed species that are geographically or otherwise identifiable and essential to the recovery
of the species. Recovery units are individually necessary to conserve genetic robustness,
demographic robustness, important life history stages, or some other feature necessary for long-
term sustainability of the species. The five recovery units identified in the Northwest Atlantic
are:

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1. Northern Recovery Unit (NRU) - defined as loggerheads originating from nesting
beaches from the Florida-Georgia border through southern Virginia (the northern extent
of the nesting range);

2. Peninsula Florida Recovery Unit (PFRU) - defined as loggerheads originating from
nesting beaches from the Florida-Georgia border through Pinellas County on the west
coast of Florida, excluding the islands west of Key West, Florida;

3. Dry Tortugas Recovery Unit (DTRU) - defined as loggerheads originating from nesting
beaches throughout the islands located west of Key West, Florida;

4. Northern Gulf of Mexico Recovery Unit (NGMRU) - defined as loggerheads originating
from nesting beaches from Franklin County on the northwest Gulf coast of Florida
through Texas; and

5. Greater Caribbean Recovery Unit (GCRU) - composed of loggerheads originating from
all other nesting assemblages within the Greater Caribbean (Mexico through French
Guiana, The Bahamas, Lesser Antilles, and Greater Antilles).

The mtDNA analyses show that there is limited exchange of females among these recovery units
(Ehrhart 1989; Foote et al. 2000; NMFS 2001; Hawkes et al. 2005). Male-mediated gene flow
appears to be keeping the subpopulations genetically similar on a nuclear DNA level (Francisco-
Pearce 2001).

Historically, the literature has suggested that the northern U.S. nesting beaches (NRU and
NGMRU) produce a relatively high percentage of males and the more southern nesting beaches
(PFRU, DTRU, and GCRU) a relatively high percentage of females (e.g., Hanson et al. 1998;
NMFS 2001; Mrosovsky and Provancha 1989). The NRU and NGMRU were believed to play
an important role in providing males to mate with females from the more female-dominated
subpopulations to the south. However, in 2002 and 2003, researchers studied loggerhead sex
ratios for two of the U.S. nesting subpopulations, the northern and southern subpopulations
(NGU and PFRU, respectively) (Blair 2005; Wyneken et al. 2005). The study produced
interesting results. In 2002, the northern beaches produced more females and the southern
beaches produced more males than previously believed. However, the opposite was true in 2003
with the northern beaches producing more males and the southern beaches producing more
females in keeping with prior literature. Wyneken et al. (2005) speculated that the 2002 result
may have been anomalous; however, the study did point out the potential for males to be
produced on the southern beaches. Although this study revealed that more males may be
produced on Southern Recovery Unit beaches than previously believed, the Service maintains
that the NRU and NGMRU play an important role in the production of males to mate with
females from the more Southern Recovery Units.

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The NRU is the second largest loggerhead recovery unit within the Northwest Atlantic Ocean
DPS. Annual nest totals from northern beaches averaged 5,446 nests from 2006 to 2011, a
period of near-complete surveys of NRU nesting beaches, representing approximately 1,328
nesting females per year (4.1 nests per female, Murphy and Hopkins 1984) (NMFS and USFWS
2008). In 2008, nesting in Georgia reached what was a new record at that time (1,646 nests),
with a downturn in 2009, followed by yet another record in 2011 (1,987 nests). South Carolina
had the two highest years of nesting in the 2000s in 2009 (2,183 nests) and 2010 (3,141 nests).
The previous high for that 11-year span was 1,433 nests in 2003. North Carolina had 1,252 nests
in 2015. The Georgia, South Carolina, and North Carolina nesting data come from the
seaturtle.org Sea Turtle Nest Monitoring System, which is populated with data input by the State
agencies. The loggerhead nesting trend from daily beach surveys was declining significantly at
1.3 percent annually from 1983 to 2007 (NMFS and USFWS, 2008). Overall, there is strong
statistical data to suggest the NRU has experienced a long-term decline (NMFS and USFWS
2008). Currently, however, nesting for the NRU is showing possible signs of stabilizing (76 FR
58868, September 22, 2011).

Recovery Criteria (only the Demographic Recovery Criteria are presented below; for the Listing
Factor Recovery Criteria, see NMFS and USFWS 2008)

1. Number of Nests and Number of Nesting Females
a. Northern Recovery Unit
i. There is statistical confidence (95 percent) that the annual rate of increase
over a generation time of 50 years is 2 percent or greater resulting in a total
annual number of nests of 14,000 or greater for this recovery unit
(approximate distribution of nests is North Carolina =14 percent [2,000 nests],
South Carolina =66 percent [9,200 nests], and Georgia =20 percent [2,800
nests]); and
ii. This increase in number of nests must be a result of corresponding increases
in number of nesting females (estimated from nests, clutch frequency, and
remigration interval).

b. Peninsular Florida Recovery Unit
i. There is statistical confidence (95 percent) that the annual rate of increase
over a generation time of 50 years is statistically detectable (one percent)
resulting in a total annual number of nests of 106,100 or greater for this
recovery unit; and
ii. This increase in number of nests must be a result of corresponding increases
in number of nesting females (estimated from nests, clutch frequency, and
remigration interval).

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c. Dry Tortugas Recovery Unit
i. There is statistical confidence (95 percent) that the annual rate of increase
over a generation time of 50 years is three percent or greater resulting in a
total annual number of nests of 1,100 or greater for this recovery unit; and
ii. This increase in number of nests must be a result of corresponding increases
in number of nesting females (estimated from nests, clutch frequency, and
remigration interval).

d. Northern Gulf of Mexico Recovery Unit
i. There is statistical confidence (95 percent) that the annual rate of increase
over a generation time of 50 years is three percent or greater resulting in a
total annual number of nests of 4,000 or greater for this recovery unit
(approximate distribution of nests (2002-2007) is Florida= 92 percent [3,700
nests] and Alabama =8 percent [300 nests]); and
ii. This increase in number of nests must be a result of corresponding increases
in number of nesting females (estimated from nests, clutch frequency, and
remigration interval).

e. Greater Caribbean Recovery Unit
i. The total annual number of nests at a minimum of three nesting assemblages,
averaging greater than 100 nests annually (e.g., Yucatán, Mexico; Cay Sal
Bank, Bahamas) has increased over a generation time of 50 years; and
ii. This increase in number of nests must be a result of corresponding increases
in number of nesting females (estimated from nests, clutch frequency, and
remigration interval).

2. Trends in Abundance on Foraging Grounds
A network of in-water sites, both oceanic and neritic across the foraging range is
established and monitoring is implemented to measure abundance. There is statistical
confidence (95 percent) that a composite estimate of relative abundance from these
sites is increasing for at least one generation.

3. Trends in Neritic Strandings Relative to In-water Abundance
Stranding trends are not increasing at a rate greater than the trends in in-water relative
abundance for similar age classes for at least one generation.

6.1.4.2. Status and distribution - Green Sea Turtle

Range-wide Trend: The North Atlantic Ocean DPS currently exhibits high nesting abundance,
with an estimated total nester abundance of 167,424 females at 73 nesting sites. More than
100,000 females nest at Tortuguero, Costa Rica, and more than 10,000 females nest at Quintana
Roo, Mexico. Nesting data indicate long-term increases at all major nesting sites. There is little

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genetic substructure within the DPS, and turtles from multiple nesting beaches share common
foraging areas. Nesting is geographically widespread and occurs at a diversity of mainland and
insular sites (81 FR 20058). Annual nest totals documented as part of the Florida SNBS program
from 1989-2010 have ranged from 435 nests laid in 1993 to 13,225 in 2010. Nesting occurs in
26 counties with a peak along the east coast, from Volusia through Broward Counties. Although
the SNBS program provides information on distribution and total abundance statewide, it cannot
be used to assess trends because of variable survey effort. Therefore, green turtle nesting trends
are best assessed using standardized nest counts made at INBS sites surveyed with constant
effort over time (1989-2010). Green sea turtle nesting in Florida is increasing based on 22 years
(1989-2010) of INBS data from throughout the state ((FWC/FWRI 2010b). The increase in
nesting in Florida is likely a result of several factors, including: (1) a Florida statute enacted in
the early 1970s that prohibited the killing of green turtles in Florida; (2) the species listing under
the ESA afforded complete protection to eggs, juveniles, and adults in all U.S. waters; (3) the
passage of Florida's constitutional net ban amendment in 1994 and its subsequent enactment,
making it illegal to use any gillnets or other entangling nets in State waters; (4) the likelihood
that the majority of Florida green turtles reside within Florida waters where they are fully
protected; (5) the protections afforded Florida green turtles while they inhabit the waters of other
nations that have enacted strong sea turtle conservation measures (e.g., Bermuda); and (6) the
listing of the species on Appendix I of Convention on International Trade in Endangered Species
of Wild Fauna and Flora (CITES), which stopped international trade and reduced incentives for
illegal trade from the U.S (NMFS and Service 2007a).

Recovery Criteria

The U.S. Atlantic population of green sea turtles can be considered for delisting if, over a period
of 25 years, the following conditions are met:

1. The level of nesting in Florida has increased to an average of 5,000 nests per year for at
least six years. Nesting data must be based on standardized surveys;

2. At least 25 percent (65 miles) of all available nesting beaches (260 miles) is in public
ownership and encompasses at least 50 percent of the nesting activity;

3. A reduction in stage class mortality is reflected in higher counts of individuals on
foraging grounds; and

4. All priority one tasks identified in the recovery plan have been successfully implemented.

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6.1.4.3. Status and distribution - Leatherback Sea Turtle

Range-wide Trend: Pritchard (1982) estimated 115,000 nesting females worldwide, of which 60
percent nested along the Pacific coast of Mexico. Declines in leatherback nesting have occurred
over the last two decades along the Pacific coasts of Mexico and Costa Rica. The Mexican
leatherback nesting population, once considered to be the world’s largest leatherback nesting
population (historically estimated to be 65 percent of the worldwide population), is now less than
1 percent of its estimated size in 1980. Spotila et al. (1996) estimated the number of leatherback
sea turtles nesting on 28 beaches throughout the world from the literature and from
communications with investigators studying those beaches. The estimated worldwide population
of leatherbacks in 1995 was about 34,500 females on these beaches with a lower limit of about
26,200, and an upper limit of about 42,900. This is less than one-third the 1980 estimate of
115,000. Leatherbacks are rare in the Indian Ocean and in very low numbers in the western
Pacific Ocean. The most recent population size estimate for the North Atlantic is a range of
34,000 to 94,000 adult leatherbacks (TEWG 2007). The largest population is in the western
Atlantic. Using an age-based demographic model, Spotila et al. (1996) determined that
leatherback populations in the Indian Ocean and western Pacific Ocean cannot withstand even
moderate levels of adult mortality and that the Atlantic populations are being exploited at a rate
that cannot be sustained. They concluded that leatherbacks are on the road to extinction and
further population declines can be expected unless action is taken to reduce adult mortality and
increase survival of eggs and hatchlings.

In the western Atlantic, the U.S., nesting populations occur in Florida, Puerto Rico, and the U.S.
Virgin Islands. In Florida, the SNBS program documented an increase in leatherback nesting
numbers from 98 nests in 1989 to between 453 and 1,747 nests per season in the early 2000s
(FWC 2009a; Stewart and Johnson 2006). Although the SNBS program provides information on
distribution and total abundance statewide, it cannot be used to assess trends because of variable
survey effort. Therefore, leatherback nesting trends are best assessed using standardized nest
counts made at INBS sites surveyed with constant effort over time (1989-2010). Under the
INBS program, approximately 30 percent of Florida's SNBS beach length is surveyed. The
INBS nest counts represent approximately 34 percent of known leatherback nesting in Florida.
An analysis of the INBS data has shown an exponential increase in leatherback sea turtle nesting
in Florida since 1989. From 1989 through 2010, the annual number of leatherback sea turtle
nests at the core set of index beaches ranged from 27 to 615 (FWC 2010b). Using the numbers
of nests recorded from 1979 through 2009, Stewart et al. (2011) estimated a population growth
of approximately 10.2 percent per year. In Puerto Rico, the main nesting areas are at Fajardo
(Northeast Ecological Corridor) and Maunabo on the main island and on the islands of Culebra
and Vieques. Nesting ranged from 51 to 456 nests between 2001 and 2010 (Diez 2011). In the
U.S. Virgin Islands, leatherback nesting on Sandy Point National Wildlife Refuge on the island
of St. Croix ranged from 143 to 1,008 nests between 1990 and 2005 (TEWG 2007; NMFS and
USFWS 2007b).

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Recovery Criteria

The U.S. Atlantic population of leatherbacks can be considered for delisting if the following
conditions are met:

1. The adult female population increases over the next 25 years, as evidenced by a
statistically significant trend in the number of nests at Culebra, Puerto Rico, St.
Croix, U.S. Virgin Islands, and along the east coast of Florida;
2. Nesting habitat encompassing at least 75 percent of nesting activity in U.S. Virgin
Islands, Puerto Rico, and Florida is in public ownership; and
3. All priority one tasks identified in the recovery plan have been successfully
implemented.

6.1.4.4. Status and distribution – Kemp’s Ridley Sea Turtle

Nesting aggregations of Kemp’s ridleys at Rancho Nuevo were discovered in 1947, and the adult
female population was estimated to be 40,000 or more individuals based on a film by Andres
Herrera (Hildebrand 1963, Carr 1963). Within approximately 3 decades, the population had
declined to 924 nests and reached the lowest recorded nest count of 702 nests in 1985. Since the
mid-1980s, the number of nests observed at Rancho Nuevo and nearby beaches has increased 15
percent per year (Heppell et al. 2005), allowing cautious optimism that the population is on its
way to recovery. This increase in nesting can be attributed to full protection of nesting females
and their nests in Mexico resulting from a bi-national effort between Mexico and the U.S. to
prevent the extinction of the Kemp’s ridley, the requirement to use Turtle Excluder Devices
(TEDs) in shrimp trawls both in the U.S. and Mexico, and decreased shrimping effort (NMFS et
al. 2011, Heppell et al. 2005).

Recovery Criteria (only the Demographic Recovery Criteria are presented below; for the Listing
Factor Recovery Criteria, see NMFS et al. 2011)

The recovery goal is to conserve and protect the Kemp’s ridley sea turtle so that protections
under the ESA are no longer necessary and the species can be removed from the List of
Endangered and Threatened Wildlife. Biological recovery criteria form the basis from which to
gauge whether the species should be reclassified to threatened (i.e., downlisted) or delisted,
whereas the listing factor criteria ensure that the threats affecting the species are controlled or
eliminated.

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Downlisting Criteria

1. A population of at least 10,000 nesting females in a season (as estimated by clutch
frequency per female per season) distributed at the primary nesting beaches (Rancho
Nuevo, Tepehuajes, and Playa Dos) in Mexico is attained. Methodology and capacity
to implement and ensure accurate nesting female counts have been developed.

2. Recruitment of at least 300,000 hatchlings to the marine environment per season at
the three primary nesting beaches (Rancho Nuevo, Tepehuajes, and Playa Dos) in
Mexico is attained to ensure a minimum level of known production through in situ
incubation, incubation in corrals, or a combination of both.

Delisting Criteria

1. An average population of at least 40,000 nesting females per season (as measured by
clutch frequency per female per season and annual nest counts) over a 6-year period
distributed among nesting beaches in Mexico and the U.S. is attained. Methodology
and capacity to ensure accurate nesting female counts have been developed and
implemented.

2. Ensure average annual recruitment of hatchlings over a 6-year period from in situ
nests and beach corrals is sufficient to maintain a population of at least 40,000 nesting
females per nesting season distributed among nesting beaches in Mexico and the U.S
into the future. This criterion may rely on massive synchronous nesting events (i.e.,
arribadas) that will swamp predators as well as rely on supplemental protection in
corrals and facilities.

6.1.4.5. Status and distribution – Hawksbill Sea Turtle

The hawksbill sea turtle has experienced global population declines of 80 percent or more during
the past century and continued declines are projected (Meylan and Donnelly 1999). Most
populations are declining, depleted, or remnants of larger aggregations. Hawksbills were
previously abundant, as evidenced by high-density nesting at a few remaining sites and by trade
statistics.

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Recovery Criteria

The U.S. Atlantic population of hawksbills can be considered for delisting if, over a period of 25
years, the following conditions are met:

1. The adult female population is increasing, as evidenced by a statistically significant
trend in the annual number of nests on at least five index beaches, including Mona
Island and Buck Island Reef National Monument;

2. Habitat for at least 50 percent of the nesting activity that occurs in the U.S. Virgin
Islands and Puerto Rico is protected in perpetuity;

3. Numbers of adults, subadults, and juveniles are increasing, as evidenced by a
statistically significant trend on at least five key foraging areas within Puerto Rico,
U.S. Virgin Islands, and Florida; and

4. All priority one tasks identified in the recovery plan have been successfully
implemented.

The Recovery Plan for the Hawksbill Turtle in the U.S. Caribbean, Atlantic, and Gulf of Mexico
was signed in 1993 (NMFS and USFWS 1993), and the Recovery Plan for U.S. Pacific
Populations of the Hawksbill Turtle was signed in 1998 (NMFS and USFWS 1998b).

6.1.5. Analysis of the species/critical habitat likely to be affected

Barrier islands and inlets are complex and dynamic coastal systems that are continually
responding to sediment supply, waves, and fluctuations in sea level. The location and shape of
the beaches of barrier islands perpetually adjusts to these physical forces. Waves that strike a
barrier island at an angle, for instance, generate a longshore current that carries sediment along
the shoreline. Cross-shore currents carry sediment perpendicular to the shoreline. Wind moves
sediment across the dry beach, dunes and island interior. During storm events, overwash may
breach the island at dune gaps or other weak spots, depositing sediments on the interior and back
sides of islands, increasing island elevation and accreting the soundside shoreline.

Tidal inlets play a vital role in the dynamics and processes of barrier islands. Sediment is
transferred across inlets from island to island via the tidal shoals or deltas. The longshore
sediment transport often causes barrier spits to accrete, shifting inlets towards the neighboring
island. Flood tidal shoals that are left behind by the migrating inlet are typically incorporated
into the soundside shoreline and marshes of the island, widening it considerably. Many inlets
have a cycle of inlet migration, breaching of the barrier spit during a storm, and closure of the
old inlet with the new breach becoming the new inlet. Barrier spits tend to be low in elevation,
sparse in vegetation, and repeatedly submerged by high and storm tides.

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The proposed action has the potential to adversely affect nesting females, nests, and hatchlings
on the beach within the proposed Action Area. Potential effects include destruction of nests
deposited within the boundaries of the proposed project, harassment in the form of disturbing or
interfering with female turtles attempting to nest within the construction area or on adjacent
beaches as a result of construction activities, disorientation of hatchling turtles on beaches
adjacent to the construction area as they emerge from the nest and crawl to the water as a result
of project lighting or equipment on the beach, and behavior modification of nesting females
during the nesting season resulting in false crawls or situations where they choose marginal or
unsuitable nesting areas to deposit eggs within the Action Area, due to compaction or
escarpments. The quality of the placed sand could affect the ability of female turtles to nest, the
suitability of the nest incubation environment, and the ability of hatchlings to emerge from the
nest.

Threats to Sea Turtle Species

Coastal Development

Loss of sea turtle nesting habitat related to coastal development has had the greatest impact on
nesting sea turtles. Beachfront development not only causes the loss of suitable nesting habitat,
but can result in the disruption of powerful coastal processes accelerating erosion and
interrupting the natural shoreline migration (National Research Council 1990b). This may in
turn cause the need to protect upland structures and infrastructure by armoring, groin placement,
beach emergency berm construction and repair, and beach nourishment, all of which cause
changes in, additional loss of, or impact to the remaining sea turtle habitat.

Hurricanes and Storms

Hurricanes and other large storms were probably responsible for maintaining coastal beach
habitat upon which sea turtles depend through repeated cycles of destruction, alteration, and
recovery of beach and dune habitat. Hurricanes and large storms generally produce damaging
winds, storm tides and surges, and rain, which can result in severe erosion of the beach and dune
systems. Overwash and blowouts are common on barrier islands.

Hurricanes and other storms can result in the direct loss of sea turtle nests, either by erosion or
washing away of the nests by wave action and inundation or “drowning” of the eggs or pre-
emergent hatchlings within the nest, or indirectly by causing the loss of nesting habitat.
Depending on their frequency, storms can affect sea turtles on either a short-term basis (nests lost
for one season and/or temporary loss of nesting habitat) or long term, if frequent (habitat unable
to recover). The manner in which hurricanes affect sea turtle nesting also depends on their
characteristics (winds, storm surge, rainfall), the time of year (within or outside of the nesting
season), and where the northeast edge of the hurricane crosses land.

164
Because of the limited remaining nesting habitat in a natural state with no immediate
development landward of the sandy beach, frequent or successive severe weather events could
threaten the ability of certain sea turtle populations to survive and recover. Sea turtles evolved
under natural coastal environmental events such as hurricanes. The extensive amount of
predevelopment coastal beach and dune habitat allowed sea turtles to survive even the most
severe hurricane events. It is only within the last 20 to 30 years that the combination of habitat
loss to beachfront development and destruction of remaining habitat by hurricanes has increased
the threat to sea turtle survival and recovery. On developed beaches, typically little space
remains for sandy beaches to become reestablished after periodic storms. While the beach itself
moves landward during such storms, reconstruction or persistence of structures at their pre-storm
locations can result in a loss of nesting habitat.

Erosion

A critically eroded area is a segment of shoreline where natural processes or human activity have
caused or contributed to erosion and recession of the beach or dune system to such a degree that
upland development, recreational interests, wildlife habitat, or important cultural resources are
threatened or lost. It is important to note that for erosion to be considered critical there must be
an existing threat to or loss of one of those four specific interests listed.

Beachfront Lighting

Artificial lights along a beach can deter females from coming ashore to nest or misdirect females
trying to return to the surf after a nesting event. A significant reduction in sea turtle nesting
activity has been documented on beaches illuminated with artificial lights (Witherington 1992).
Artificial beachfront lighting may also cause disorientation (loss of bearings) and misorientation
(incorrect orientation) of sea turtle hatchlings. Visual signs are the primary sea-finding
mechanism for hatchlings (Mrosovsky and Carr 1967; Mrosovsky and Shettleworth 1968;
Dickerson and Nelson 1989; Witherington and Bjorndal 1991). Artificial beachfront lighting is a
documented cause of hatchling disorientation and misorientation on nesting beaches (Philibosian
1976; Mann 1977; Witherington and Martin 1996). The emergence from the nest and crawl to
the sea is one of the most critical periods of a sea turtle’s life. Hatchlings that do not make it to
the sea quickly become food for ghost crabs, birds, and other predators, or become dehydrated
and may never reach the sea. In addition, research has documented significant reduction in sea
turtle nesting activity on beaches illuminated with artificial lights (Witherington 1992). During
the 2010 sea turtle nesting season in Florida, over 47,000 turtle hatchlings were documented as
being disoriented (FWC/FWRI 2011).

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Predation

Predation of sea turtle eggs and hatchlings by native and introduced species occurs on almost all
nesting beaches. Predation by a variety of predators can considerably decrease sea turtle nest
hatching success. The most common predators in the southeastern U.S. are ghost crabs
(Ocypode quadrata), raccoons (Procyon lotor), feral hogs (Sus scrofa), foxes (Urocyon
cinereoargenteus and Vulpes vulpes), coyotes (Canis latrans), armadillos (Dasypus
novemcinctus), and fire ants (Solenopsis invicta) (Dodd 1988; Stancyk 1995). In the absence of
nest protection programs in a number of locations throughout the southeast U.S., raccoons may
depredate up to 96 percent of all nests deposited on a beach (Davis and Whiting 1977; Hopkins
and Murphy 1980; Stancyk et al. 1980; Talbert et al. 1980; Schroeder 1981; Labisky et al. 1986).

Beach Driving

The operation of motor vehicles on the beach affects sea turtle nesting by interrupting or striking
a female turtle on the beach, headlights disorienting or misorienting emergent hatchlings,
vehicles running over hatchlings attempting to reach the ocean, and vehicle tracks traversing the
beach that interfere with hatchlings crawling to the ocean. Hatchlings appear to become diverted
not because they cannot physically climb out of the rut (Hughes and Caine 1994), but because
the sides of the track cast a shadow and the hatchlings lose their line of sight to the ocean horizon
(Mann 1977). The extended period of travel required to negotiate tire tracks and ruts may
increase the susceptibility of hatchlings to dehydration and depredation during migration to the
ocean (Hosier et al. 1981). Driving on the beach can cause sand compaction which may result in
adverse impacts on nest site selection, digging behavior, clutch viability, and emergence by
hatchlings, decreasing nest success and directly killing pre-emergent hatchlings (Mann 1977;
Nelson and Dickerson 1987; Nelson 1988).

The physical changes and loss of plant cover caused by vehicles on dunes can lead to various
degrees of instability, and therefore encourage dune migration. As vehicles move either up or
down a slope, sand is displaced downward, lowering the trail. Since the vehicles also inhibit
plant growth, and open the area to wind erosion, dunes may become unstable, and begin to
migrate. Unvegetated sand dunes may continue to migrate across stable areas as long as vehicle
traffic continues. Vehicular traffic through dune breaches or low dunes on an eroding beach may
cause an accelerated rate of overwash and beach erosion (Godfrey et al. 1978). If driving is
required, the area where the least amount of impact occurs is the beach between the low and high
tide water lines. Vegetation on the dunes can quickly reestablish provided the mechanical
impact is removed.

Climate Change

The varying and dynamic elements of climate science are inherently long term, complex, and
interrelated. Regardless of the underlying causes of climate change, glacial melting and

166
expansion of warming oceans are causing sea level rise, although its extent or rate cannot as yet
be predicted with certainty. At present, the science is not exact enough to precisely predict when
and where climate impacts will occur. Although we may know the direction of change, it may
not be possible to predict its precise timing or magnitude. These impacts may take place
gradually or episodically in major leaps.

Climate change is evident from observations of increases in average global air and ocean
temperatures, widespread melting of snow and ice, and rising sea level, according to the
Intergovernmental Panel on Climate Change Report (IPCC 2007a). The IPCC Report (2007a)
describes changes in natural ecosystems with potential widespread effects on many organisms,
including marine mammals and migratory birds. The potential for rapid climate change poses a
significant challenge for fish and wildlife conservation. Species’ abundance and distribution are
dynamic, relative to a variety of factors, including climate. As climate changes, the abundance
and distribution of fish and wildlife will also change. Highly specialized or endemic species are
likely to be most susceptible to the stresses of changing climate. Based on these findings and
other similar studies, the U.S. Department of the Interior (DOI) requires agencies under its
direction to consider potential climate change effects as part of their long-range planning
activities (Service 2007).

In the southeastern U.S., climatic change could amplify current land management challenges
involving habitat fragmentation, urbanization, invasive species, disease, parasites, and water
management. Global warming will be a particular challenge for endangered, threatened, and
other “at risk” species. It is difficult to estimate, with any degree of precision, which species will
be affected by climate change or exactly how they will be affected. The Service will use
Strategic Habitat Conservation planning, an adaptive science-driven process that begins with
explicit trust resource population objectives, as the framework for adjusting our management
strategies in response to climate change (USFWS 2006). As the level of information increases
relative to the effects of global climate change on sea turtles and its designated critical habitat,
the Service will have a better basis to address the nature and magnitude of this potential threat
and will more effectively evaluate these effects to the range-wide status of sea turtles.
Temperatures are predicted to rise from 1.6°F to 9°F for North America by the end of this
century (IPCC 2007a, b). Alterations of thermal sand characteristics could result in highly
female-biased sex ratios because sea turtles exhibit temperature dependent sex determination
(e.g., Glen and Mrosovsky 2004; Hawkes et al. 2008).

Along developed coastlines, and especially in areas where shoreline protection structures have
been constructed to limit shoreline movement, rising sea levels will cause severe effects on
nesting females and their eggs. Erosion control structures can result in the permanent loss of dry
nesting beach or deter nesting females from reaching suitable nesting sites (National Research
Council 1990a). Nesting females may deposit eggs seaward of the erosion control structures
potentially subjecting them to repeated tidal inundation or washout by waves and tidal action.

167
Based on the present level of available information concerning the effects of global climate
change on the status of sea turtles and their designated critical habitat, the Service acknowledges
the potential for changes to occur in the Action Area, but presently has no basis to evaluate if or
how these changes are affecting sea turtles. Nor does our present knowledge allow the Service
to project what the future effects from global climate change may be or the magnitude of these
potential effects.

Recreational Beach Use

Human presence on or adjacent to the beach at night during the nesting season, particularly
recreational activities, can reduce the quality of nesting habitat by deterring or disturbing and
causing nesting turtles to avoid otherwise suitable habitat. In addition, human foot traffic can
make a beach less suitable for nesting and hatchling emergence by increasing sand compaction
and creating obstacles to hatchlings attempting to reach the ocean (Hosier et al. 1981).

The use and storage of lounge chairs, cabanas, umbrellas, catamarans, and other types of
recreational equipment on the beach at night can also make otherwise suitable nesting habitat
unsuitable by hampering or deterring nesting by adult females and trapping or impeding
hatchlings during their nest to sea migration. The documentation of non-nesting emergences
(also referred to as false crawls) at these obstacles is becoming increasingly common as more
recreational beach equipment is left on the beach at night. Sobel (2002) describes nesting turtles
being deterred by wooden lounge chairs that prevented access to the upper beach.

Sand Placement

Sand placement projects may result in changes in sand density (compaction), beach shear
resistance (hardness), beach moisture content, beach slope, sand color, sand grain size, sand
grain shape, and sand grain mineral content if the placed sand is dissimilar from the original
beach sand (Nelson and Dickerson 1988a). These changes could result in adverse impacts on sea
turtle nest site selection, digging behavior, clutch viability, and hatchling emergence (Nelson and
Dickerson 1987; Nelson 1988).

Beach nourishment projects create an elevated, wider, and unnatural flat slope berm. Sea turtles
nest closer to the water the first few years after nourishment because of the altered profile (and
perhaps unnatural sediment grain size distribution) (Ernest and Martin 1999; Trindell 2005)

Beach compaction and unnatural beach profiles resulting from beach nourishment activities
could negatively impact sea turtles regardless of the timing of projects. Sand compaction may
increase the length of time required for female sea turtles to excavate nests and cause increased
physiological stress to the animals (Nelson and Dickerson 1988b). The placement of rocky
material may have similar effects. These impacts can be minimized by using suitable sand.

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A change in sediment color on a beach could change the natural incubation temperatures of sea
turtle nests in an area, which, in turn, could alter natural sex ratios. To provide the most suitable
sediment for nesting sea turtles, the color of the nourished sediments should resemble the natural
beach sand in the area. Natural reworking of sediments and bleaching from exposure to the sun
would help to lighten dark nourishment sediments; however, the timeframe for sediment mixing
and bleaching to occur could be critical to a successful sea turtle nesting season.

In-water and Shoreline Alterations

Many navigable mainland or barrier island tidal inlets along the Atlantic and Gulf of Mexico
coasts are stabilized with jetties or groins. Jetties are built perpendicular to the shoreline and
extend through the entire nearshore zone and past the breaker zone to prevent or decrease sand
deposition in the channel (Kaufman and Pilkey 1979). Groins are also shore-perpendicular
structures that are designed to trap sand that would otherwise be transported by longshore
currents and can cause downdrift erosion (Kaufman and Pilkey 1979).

These in-water structures have profound effects on adjacent beaches (Kaufman and Pilkey 1979).
Jetties and groins placed to stabilize a beach or inlet prevent normal sand transport, resulting in
accretion of sand on updrift beaches and acceleration of beach erosion downdrift of the structures
(Komar 1983; Pilkey et al. 1984). Witherington et al. (2005) found a significant negative
relationship between loggerhead nesting density and distance from the nearest of 17 ocean inlets
on the Atlantic coast of Florida. The effect of inlets in lowering nesting density was observed
both updrift and downdrift of the inlets, leading researchers to propose that beach instability
from both erosion and accretion may discourage sea turtle nesting.

Following construction, the presence of groins and jetties may interfere with nesting turtle access
to the beach, result in a change in beach profile and width (downdrift erosion, loss of sandy
berms, and escarpment formation), trap hatchlings, and concentrate predatory fishes, resulting in
higher probabilities of hatchling predation. In addition to decreasing nesting habitat suitability,
construction or repair of groins and jetties during the nesting season may result in the destruction
of nests, disturbance of females attempting to nest, and disorientation of emerging hatchlings
from project lighting.

Threats to loggerhead sea turtle terrestrial habitat

Recreational beach use: beach cleaning, human presence (e.g., dog beach, special events, piers,
and recreational beach equipment);

Beach driving: essential and nonessential off-road vehicles, all-terrain vehicles, and recreational
access and use;

Predation: depredation of eggs and hatchlings by native and nonnative predators;

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Beach sand placement activities: beach nourishment, beach restoration, inlet sand bypassing,
dredge material disposal, dune construction, emergency sand placement after natural disaster,
berm construction, and dune and berm planting;

In-water and shoreline alterations: artificial in-water and shoreline stabilization measures (e.g.,
in-water erosion control structures, such as groins, breakwaters, jetties), inlet relocation, inlet
dredging, nearshore dredging, and dredging and deepening channels;

Coastal development: residential and commercial development and associated activities
including beach armoring (e.g., sea walls, geotextile tubes, rock revetments, sandbags,
emergency temporary armoring); and activities associated with construction, repair, and
maintenance of upland structures, stormwater outfalls, and piers;

Artificial lighting: direct and indirect lighting, skyglow, and bonfires;

Beach erosion: erosion due to aperiodic, short-term weather-related erosion events, such as
atmospheric fronts, northeasters, tropical storms, and hurricanes;

Climate change: includes sea level rise;

Habitat obstructions: tree stumps, fallen trees, and other debris on the beach; nearshore sand
bars; and ponding along beachfront seaward of dry beach;

Human-caused disasters and response to natural and human-caused disasters: oil spills, oil spill
response including beach cleaning and berm construction, and debris cleanup after natural
disasters;

Military testing and training activities: troop presence, pyrotechnics and nighttime lighting,
vehicles and amphibious watercraft usage on the beach, helicopter drops and extractions, live fire
exercises, and placement and removal of objects on the beach.

Some individuals in a population are more “valuable” than others in terms of the number of
offspring they are expected to produce. An individual’s potential for contributing offspring to
future generations is its reproductive value. Because of delayed sexual maturity, reproductive
longevity, and low survivorship in early life stages, nesting females are of high value to a
population. The loss of a nesting female in a small recovery unit would represent a significant
loss to the recovery unit. The reproductive value for a nesting female has been estimated to be
approximately 253 times greater than an egg or a hatchling (NMFS and USFWS 2008).
With regard to indirect loss of eggs and hatchlings, on most beaches, nesting success typically
declines for the first year or two following sand placement, even though more nesting habitat is
available for turtles (Trindell et al. 1998; Ernest and Martin 1999; Herren 1999). Reduced
nesting success on constructed beaches has been attributed to increased sand compaction,

170
escarpment formation, and changes in beach profile (Nelson et al. 1987; Crain et al. 1995;
Lutcavage et al. 1997; Steinitz et al. 1998; Ernest and Martin 1999; Rumbold et al. 2001). In
addition, even though constructed beaches are wider, nests deposited there may experience
higher rates of wash out than those on relatively narrow, steeply sloped beaches (Ernest and
Martin 1999). This occurs because nests on constructed beaches are more broadly distributed
than those on natural beaches, where they tend to be clustered near the base of the dune. Nests
laid closest to the waterline on constructed beaches may be lost during the first year or two
following construction as the beach undergoes an equilibration process during which seaward
portions of the beach are lost to erosion. As a result, the project may be anticipated to result in
decreased nesting and loss of nests that are laid within the Action Area for two subsequent
nesting seasons following the completion of the proposed sand placement. However, it is
unknown whether nests that would have been laid in an Action Area during the two subsequent
nesting seasons had the project not occurred are actually lost from the population, or if nesting is
simply displaced to adjacent beaches. Regardless, eggs and hatchlings have a low reproductive
value; each egg or hatchling has been estimated to have only 0.004 percent of the value of a
nesting female (NMFS and USFWS 2008). Thus, even if the majority of the eggs and hatchlings
that would have been produced on the project beach are not realized for up to 2 years following
project completion, the Service would not expect this loss to have a significant effect on the
recovery and survival of the species, for the following reasons: 1) some nesting is likely just
displaced to adjacent non-project beaches, 2) not all eggs will produce hatchlings, and 3)
destruction and/or failure of nests will not always result from a sand placement project. A
variety of natural and unknown factors negatively affect incubating egg clutches, including tidal
inundation, storm events, and predation, accretion of sand, and erosional processes. The loss of
all life stages of sea turtles including eggs are considered “take” and minimization measures are
required to avoid and minimize all life stages. During project construction, predators of eggs and
nestlings may be attracted to the Action Area due to food waste from the construction crew.

In the U.S., consultations with the Service have included military missions and operations, beach
nourishment and other shoreline protection projects, and actions related to protection of coastal
development on sandy beaches along the coast. Much of the Service’s section 7 consultation
involves beach nourishment projects. A list of the Service’s consultations completed over the
last two years in North Carolina is included in Table 24. The Act does not require entities
conducting projects with no Federal nexus to apply for a section 10(a)(1)(B) permit. This is a
voluntary process and is applicant driven. Section 10(a)(1)(A) permits are scientific permits that
include activities that would enhance the survival and conservation of a listed species. Those
permits are not listed as they are expected to benefit the species and are not expected to
contribute to the cumulative take assessment.

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Table 24. Biological opinions within the Raleigh Field Office geographic area that have been
issued since 2014 for adverse impacts to sea turtle species. Activities addressed by the BOs
include inlet dredging, sand placement, construction of sandbag revetments, and terminal groin
construction.

OPINIONS SPECIES HABITAT
Critical Habitat
(loggerhead)
Habitat
Fiscal Year
2014: 1 BO
Loggerhead, leatherback, green, and
Kemp’s ridley sea turtles
12,600 lf
(2.4 mi)
12,600 lf
(2.4 mi)
Fiscal Year
2015: 5 BOs
Loggerhead, leatherback, green,
hawksbill, and Kemp’s ridley sea
turtles
50,268 lf
(9.5 mi)
70,268 lf
(13.3 mi)
Fiscal Year
2016: 7 BOs
Loggerhead, leatherback, green,
hawksbill, and Kemp’s ridley sea
turtles
133,150 lf
(25.22 mi)
229,469 lf
(45.25 mi)
Fiscal Year 2017
(to date): 1 BO
Loggerhead, leatherback, green,
hawksbill, and Kemp’s ridley sea
turtles
N/A 27,650 lf
(5.24 mi)
Total: 14 BOs 196,018 lf
(37.12 mi)
339,987 lf
(64.39 mi)

6.2. ENVIRONMENTAL BASELINE

6.2.1. Status of sea turtle species within the Action Area

In general, sea turtle nesting has increased significantly in North Carolina between 2000 to 2016,
although some years saw a substantial dip in the total number of nests. See Table 25 for data on
sea turtle nests in North Carolina from the year 2000 to 2016. Data from NCWRC (2014) and
www.seaturtle.org (Accessed April 20, 2017). With the exception of hawksbill sea turtle, which
has only been recorded (through DNA testing) nesting on Cape Hatteras, sea turtles species nest
along the entire length of the North Carolina shoreline.

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Table 25. Sea turtle nest totals for North Carolina, 2000 to 2016.

Ye
a
r

Lo
g
g
e
r
h
e
a
d

Gr
e
e
n

Le
a
t
h
e
r
b
a
c
k

Ke
m
p
'
s

r
i
d
l
e
y

Ha
w
k
s
b
i
l
l

Un
k
n
o
w
n

To
t
a
l

2000 754 22 4 0

0 780
2001 655 9 0 0

0 664
2002 693 15 1 1

0 710
2003 862 4 0 1

0 871
2004 333 6 4 0

0 343
2005 645 14 7 0

0 666
2006 763 10 0 0

0 773
2007 534 21 9 0

1 565
2008 889 22 0 0

0 911
2009 614 4 3 0

1 622
2010 856 18 2 2

3 881
2011 950 16 0 1

0 967
2012 1074 24 5 2

0 1105
2013 1260 44 0 1

0 1305
2014 546 16 0 2

0 564
2015 1254 39 0 1 2 0 1296
2016 1622 24 0 4 0 0 1650

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The loggerhead sea turtle nesting and hatching season for North Carolina beaches extends from
May 1 through November 15. Incubation ranges from about 45 to 95 days. Loggerhead nesting
has increased significantly since 2000. As few as 333 nests were recorded in 2004, but in 2016,
1,622 loggerhead nests were recorded across the state. Loggerhead nests have been recorded in
every beach community in North Carolina.

The green sea turtle nesting and hatching season on North Carolina beaches extends from May
15 through November 15. Incubation ranges from about 45 to 75 days. Green sea turtles have
nested in North Carolina every year since at least 2000, and nest numbers have increased over
that time with some instances of significant dips in the annual number. Only four nests were
recorded in 2003 and 2009, while as many as 29 were recorded in 2015 and 44 in 2013. Nests
have been recorded from the northern outer banks to Brunswick County.

The Kemp’s ridley sea turtle nesting and hatchling season on North Carolina beaches appears to
be similar to other species. Incubation ranges from 45 to 58 days. Fifteen (15) Kemp’s ridley
sea turtle nests have been recorded along the North Carolina shoreline since 2000. Though
typically only one or two nests may be laid each year (four were laid in 2016), the nests have
been laid from the northern outer banks to New Hanover County.

The leatherback sea turtle nesting and hatching season on North Carolina beaches extends from
April 15 through November 15. Incubation ranges from about 55 to 75 days. There have been
35 known leatherback nests laid on North Carolina Beaches since 2000. The nests have been
laid in every area of the state, from the northern outer banks to Brunswick County.

The hawksbill sea turtle nesting and hatching season has not been determined on North Carolina
beaches, but is assumed to be similar to other species. Two hawksbill nests were reported in
2015 at Cape Hatteras National Seashore south of Hatteras; the first records of hawksbill sea
turtle nests in the state of North Carolina, and also the first outside the state of Florida. Both
nests were north of the Action Area. One nest successfully hatched (hatching success of 64.5%);
the other was destroyed by high surf from storms. The nest that successfully hatched had an
incubation period of 59 days. It is currently unclear whether or not the hawksbill sea turtle may
nest again in the Action Area. However, suitable nesting habitat is present throughout the Action
Area.

6.2.2. Factors affecting the species environment within the Action Area

The Service and NMFS share Federal jurisdiction for sea turtles under the ESA. The Service has
responsibility for sea turtles on the nesting beach. NMFS has jurisdiction for sea turtles in the
marine environment. Activities proposed in this formal consultation would involve only impacts
to sea turtles in the terrestrial environment, which includes the following life stages: nesting sea
turtles, nests and eggs, and hatchlings as they emerge from the nest and crawl to the sea.

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A wide range of recent and on-going beach disturbance activities have altered the proposed
Action Area and, to a greater extent, the North Carolina coastline, and many more are proposed
along the coastline for the near future. Appendix A (copied from the PBA) and Table 11 (page
73) list many of these activities.

Beach nourishment: Appendix A (from the PBA) lists historical beach sand placement projects
for the state of North Carolina. The beaches of North Carolina are regularly nourished with
sand from the Corps and locally-managed activities. Nourishment activities widen beaches,
change their sedimentology and stratigraphy, alter coastal processes and often plug dune gaps
and remove overwash areas. The PBA estimates that approximately 112 miles of Atlantic
shoreline has been nourished in North Carolina. Rice (2017) estimates the length of nourished
shoreline to be approximately 101 miles, with another 43 miles proposed. The first recorded
sand placement project in North Carolina was on Wrightsville Beach in 1939, when sand was
placed on 2.6 miles of shoreline. Sand placement did not occur again until the mid to late-
1950’s. Sand placement was generally intermittent and small in scope (less than 6 miles per
year) until the late 1980’s to 1990’s, when the frequency of sand placement and miles of
shoreline per year began to dramatically increase. Many of the beachfront communities have
received sand on more than 10 occasions. Carolina Beach is listed in the PBA as having had 40
and placement events, while Wrightsville Beach has had 26, and Holden Beach 45. For most of
these events, the sand source is navigation projects. Other sand sources include sediment mined
from inlets, offshore borrow areas, and previously dredged material from upland disposal areas
or existing material from an upland borrow area. Between 31% (Rice 2017) and 35% (PBA) of
the North Carolina Shoreline has been modified by sediment placement as of 2015.

Beach scraping can artificially steepen beaches, stabilize dune scarps, plug dune gaps, and
redistribute sediment distribution patterns. Artificial dune building, often a product of beach
scraping, removes low-lying overwash areas and dune gaps. As chronic erosion catches up to
structures throughout the Action Area, artificial dune systems are constructed and maintained to
protect beachfront structures either by sand fencing or fill placement. Beach scraping or
bulldozing has become more frequent on North Carolina beaches in the past 20 years, in
response to storms and the continuing retreat of the shoreline with rising sea level. These
activities primarily occur during the winter months. Artificial dune or berm systems have been
constructed and maintained in several areas. These dunes make the artificial dune ridge function
like a seawall that blocks natural beach retreat, evolution, and overwash. From 2012 to 2015,
Rice (2017) estimated that at least 4.84 miles of the North Carolina shoreline was impacted by
beach scraping.

Beach raking and rock-picking: Man-made beach cleaning and raking machines effectively
remove seaweed, plants, fish, glass, syringes, plastic, cans, cigarettes, shells, stone, wood, and
virtually any unwanted debris (Barber Beach Cleaning Equipment 2009). Beach cleaning or
grooming can result in abnormally broad unvegetated zones that are inhospitable to dune
formation or plant colonization, thereby enhancing the likelihood of erosion (Defreo et al.

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2009). Removal of wrack also eliminates a beach’s natural sand-trapping abilities, further
destabilizing the beach. Sand adhering to seaweed and trapped in the cracks and crevices of
wrack is removed from the beach. Although the amount of sand lost due to single sweeping
actions may be small, it adds up considerably over a period of years (Nordstrom et al. 2006; Neal
et al. 2007). The Town of Carolina Beach rakes the beach front in Freeman Park at least twice
per year, including areas in piping plover critical habitat unit NC-14. The Town of North
Topsail Beach utilizes a rock-picker as needed, typically annually, to remove rocky material
from the beach berm along portions of its shoreline.

Pedestrian Use of the Beach: There are a number of potential sources of pedestrians and pets on
North Carolina beaches, including those individuals originating from beachfront, public access
points, and nearby hotels, resorts, and residences.

Shoreline stabilization: In 2017, there are 4 jetties and 34 groins along the North Carolina coast,
and sandbags, sandbag revetments, groins, and jetties have been placed along at least 9.05 miles
of North Carolina shoreline (Rice 2017). See Table 14 (page 81) for data from Rice (2017).

Sandbags on private properties provide stabilization to a significant portion of the North Carolina
shoreline. Rice (2017) estimated 152 separate sandbag structures along the North Carolina beach
shoreline. If multiple properties each had an individual seawall protecting their property and the
seawalls were attached to each other with no gaps, then Rice (2017) counted the armoring as one
structure (per Dallas et al. 2013) and measured the overall length.

Rice (2017) estimated that 24 of 37 North Carolina coastal communities have been modified by
armor. In these communities, the proportion of armored sandy beach habitat was as high as
18%. Four communities exceed 10% of the shoreline armored: Kitty Hawk (18%), Bald Head
Island (13%)1, Kure Beach (11%), and Ocean Isle Beach (10%).

Groins often result in accelerated beach erosion downdrift of the structures (Komar 1983;
National Research Council 1987) and corresponding degradation of suitable sea turtle nesting
habitat (NMFS and Service 1991; 1992). Initially, the greatest changes are observed close to the
structures, but effects may eventually extend significant distances along the coast (Komar 1983).
Groins operate by blocking the natural longshore transport of littoral drift (Kaufman and Pilkey
1979; Komar 1983). Conventional rubble mound groins control erosion by trapping sand and
dissipating some wave energy. In general, except for terminal groins at the downdrift limit of a
littoral cell, groins are not considered favorable erosion control alternatives because they usually
impart stability to the updrift beach and transfer erosion to the downdrift side of the structure. In
addition, groins deflect longshore currents offshore, and excess sand builds up on the updrift side

1 The proportion of Bald Head Island’s sandy beach habitat that has been modified by armor is 13% when the
Smithville Twp. portions of Zeke’s Island Reserve and Bald Head Island State Natural Area are included. When
only the Village of Bald Head Island is included, the proportion of sandy beach habitat modified by armor increases
to 23% (Rice 2017).

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of the structure which may be carried offshore by those currents. This aggravates downdrift
erosion and erosion escarpments are common on the downdrift side of groins (Humiston and
Moore 2001).

6.3. EFFECTS OF THE ACTION

6.3.1. Factors to be considered

Proximity of action: Sand placement activities would occur within and adjacent to nesting
habitat for sea turtles and dune habitats that ensure the stability and integrity of the nesting
beach. Specifically, the project would potentially impact loggerhead, green, leatherback,
hawksbill, and Kemp’s ridley nesting females, their nests, and hatchling sea turtles.

Distribution: Sand placement activities may impact nesting and hatchling sea turtles and sea
turtle nests. The Service expects the proposed construction activities could directly and
indirectly affect the availability and suitability of habitat for nesting and hatchling sea turtles.

Timing: The timing of the sand placement activities (between November 16 and April 30) could
indirectly impact nesting females, their nests, and hatchling sea turtles.

Nature of the effect: The effects of sand placement activities may change the nesting behavior of
adult female sea turtles, diminish nesting success, and cause reduced hatching and emerging
success. Sand placement can also change the incubation conditions within the nest. Any
decrease in productivity and/or survival rates would contribute to the vulnerability of the sea
turtles nesting in the southeastern U.S. However, if portions of the area to be nourished are
severely eroded, placement of sand may provide nesting habitat where it doesn’t currently exist.

Duration: These may be recurring activities, lasting up to five and a half months each time.
Thus, the direct effects would be expected to be short-term in duration. Indirect effects from the
activity may continue to impact nesting and hatchling sea turtles and sea turtle nests in
subsequent nesting seasons.

Disturbance frequency: Disturbance to the sediment from each event will be short term, lasting
up to two years. However, sand placement activities may take place several times over the life
of the project. Recreational disturbance may increase after project completion and have long-
term impacts.

Disturbance intensity and severity: Project construction is anticipated to be conducted outside of
the sea turtle nesting season. Conservation measures have been incorporated into the project to
minimize impacts.

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6.3.2. Analyses for effects of the action

The Action Area encompasses the entire shoreline on the Atlantic coast of North Carolina.

Beneficial Effects: The placement of sand on a beach with reduced dry foredune habitat may
increase sea turtle nesting habitat if the placed sand is highly compatible (i.e., grain size, shape,
color, etc.) with naturally occurring beach sediments in the area, and compaction and escarpment
remediation measures are incorporated into the project. In addition, a nourished beach that is
designed and constructed to mimic a natural beach system may benefit sea turtles more than an
eroding beach it replaces.

Direct Effects: Although sand placement activities may increase the potential nesting area,
significant negative impacts to sea turtles may result if protective measures are not incorporated
during project construction.

a. Equipment during construction

The use of heavy machinery on beaches during a construction project may also have
adverse effects on sea turtles. The physical changes and loss of plant cover caused by
vehicles on vegetated areas or dunes can lead to various degrees of instability and cause
dune migration. As vehicles move over the sand, sand is displaced downward, lowering
the substrate. Since the vehicles also inhibit plant growth, and open the area to wind
erosion, the beach and dunes may become unstable. Vehicular traffic on the beach or
through dune breaches or low dunes may cause acceleration of overwash and erosion
(Godfrey et al. 1978). Driving along the beachfront should be between the low and high
tide water lines. To minimize the impacts to the beach, dunes, and dune vegetation,
transport and access to the construction sites should be from the road to the maximum
extent possible. However, if vehicular access to the beach is necessary, the areas for
vehicle and equipment usage should be designated and marked.

b. Artificial lighting as a result of an unnatural beach slope on the adjacent beach

Visual cues are the primary sea-finding mechanism for hatchling sea turtles (Mrosovsky
and Carr 1967; Mrosovsky and Shettleworth 1968; Dickerson and Nelson 1989;
Witherington and Bjorndal 1991). When artificial lighting is present on or near the
beach, it can misdirect hatchlings once they emerge from their nests and prevent them
from reaching the ocean (Philibosian 1976; Mann 1977; FWC 2007). In addition, a
significant reduction in sea turtle nesting activity has been documented on beaches
illuminated with artificial lights (Witherington 1992). The unnatural sloped beach
adjacent to the structure exposes sea turtles and their nests to lights that were less visible,
or not visible, from nesting areas before the sand placement activity, leading to a higher
mortality of hatchlings. Review of over 10 years of empirical information from beach

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nourishment projects indicates that the number of sea turtles impacted by lights increases
on the post-construction berm. A review of selected nourished beaches in Florida (South
Brevard, North Brevard, Captiva Island, Ocean Ridge, Boca Raton, Town of Palm Beach,
Longboat Key, and Bonita Beach) indicated disorientation reporting increased by
approximately 300 percent the first nesting season after project construction and up to
542 percent the second year compared to pre-nourishment reports (Trindell et al. 2005).

Specific examples of increased lighting disorientations after a sand placement project
include Brevard and Palm Beach Counties, Florida. A sand placement project in Brevard
County, completed in 2002, showed an increase of 130 percent in disorientations in the
nourished area. Disorientations on beaches in the County that were not nourished
remained constant (Trindell 2007). This same result was also documented in 2003 when
another beach in Brevard County was nourished and the disorientations increased by 480
percent (Trindell 2007). Installing appropriate beachfront lighting is the most effective
method to decrease the number of disorientations on any developed beach including
nourished beaches. A shoreline protection project was constructed at Ocean Ridge in
Palm Beach County, Florida, between August 1997 and April 1998. Lighting
disorientation events increased after nourishment. In spite of continued aggressive efforts
to identify and correct lighting violations in 1998 and 1999, 86 percent of the
disorientation reports were in the nourished area in 1998 and 66 percent of the reports
were in the nourished area in 1999 (Howard and Davis 1999).

Indirect Effects: Many of the direct effects of beach nourishment may persist over time and
become indirect impacts. These indirect effects include increased susceptibility of relocated
nests to catastrophic events, the consequences of potential increased beachfront development,
changes in the physical characteristics of the beach, the formation of escarpments, and future
sand migration.

a. Changes in the physical environment

Beach nourishment projects create an elevated, wider, and unnatural flat slope berm. Sea
turtles nest closer to the water the first few years after nourishment because of the altered
profile (and perhaps unnatural sediment grain size distribution) (Ernest and Martin 1999;
Trindell 2005).

Beach compaction and unnatural beach profiles resulting from beach nourishment
activities could negatively impact sea turtles regardless of the timing of projects. Very
fine sand or the use of heavy machinery can cause sand compaction on nourished beaches
(Nelson et al. 1987; Nelson and Dickerson 1988a). Significant reductions in nesting
success (i.e., false crawls occurred more frequently) have been documented on severely
compacted nourished beaches (Fletemeyer 1980; Raymond 1984; Nelson and Dickerson
1987; Nelson et al. 1987), and increased false crawls may result in increased

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physiological stress to nesting females. Sand compaction may increase the length of time
required for female sea turtles to excavate nests and cause increased physiological stress
to the animals (Nelson and Dickerson 1988b). Nelson and Dickerson (1988c) concluded
that, in general, beaches nourished from offshore borrow sites are harder than natural
beaches, and while some may soften over time through erosion and accretion of sand,
others may remain hard for 10 years or more. The placement of rocky material on the
beach may cause significant reductions in nesting success (i.e., increased frequency of
false crawls), and may make it difficult for hatchlings to emerge from the nest.

These impacts can be minimized by using suitable sand and by tilling compacted sand
and/or removing rock (minimum depth of 36 inches) after project completion. As the
material is reworked by natural forces, the percentage of rock and gravel may increase.

A change in sediment color on a beach could change the natural incubation temperatures
of nests in an area, which, in turn, could alter natural sex ratios. To provide the most
suitable sediment for nesting sea turtles, the color of the nourished sediments should
resemble the natural beach sand in the area. Natural reworking of sediments and
bleaching from exposure to the sun would help to lighten dark nourishment sediments;
however, the timeframe for sediment mixing and bleaching to occur could be critical to a
successful sea turtle nesting season.

b. Escarpment formation

On nourished beaches, steep escarpments may develop along their water line interface as
they adjust from an unnatural construction profile to a more natural beach profile
(Coastal Engineering Research Center 1984; Nelson et al. 1987). Escarpments can
hamper or prevent access to nesting sites (Nelson and Blihovde 1998). Researchers have
shown that female sea turtles coming ashore to nest can be discouraged by the formation
of an escarpment, leading to situations where they choose marginal or unsuitable nesting
areas to deposit eggs (e.g., in front of the escarpments, which often results in failure of
nests due to prolonged tidal inundation). This impact can be minimized by leveling any
escarpments prior to the nesting season.

c. Increased susceptibility to catastrophic events

Nest relocation within a nesting season may concentrate eggs in an area making them
more susceptible to catastrophic events. Hatchlings released from concentrated areas also
may be subject to greater predation rates from both land and marine predators, because
the predators learn where to concentrate their efforts (Glenn 1998; Wyneken et al. 1998).

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d. Increased beachfront development

Pilkey and Dixon (1996) stated that beach replenishment frequently leads to more
development in greater density within shorefront communities that are then left with a
future of further replenishment or more drastic stabilization measures. Dean (1999) also
noted that the very existence of a beach nourishment project can encourage more
development in coastal areas. Following completion of a beach nourishment project in
Miami during 1982, investment in new and updated facilities substantially increased
tourism there (National Research Council 1995). Increased building density immediately
adjacent to the beach often resulted as much larger buildings that accommodated more
beach users replaced older buildings. Overall, shoreline management creates an upward
spiral of initial protective measures resulting in more expensive development that leads to
the need for more and larger protective measures. Increased shoreline development may
adversely affect sea turtle nesting success. Greater development may support larger
populations of mammalian predators, such as foxes and raccoons, than undeveloped areas
(National Research Council 1990a), and can also result in greater adverse effects due to
artificial lighting, as discussed above.

6.3.3 Species’ response to the proposed action

The Service determined there is a potential for long-term adverse effects on sea turtles as a result
of sand placement. An increase in sandy beach may not necessarily equate to an increase in
suitable sea turtle nesting habitat.

The following summary illustrates sea turtle responses to and recovery from a nourishment
project comprehensively studied by Ernest and Martin (1999). A significantly larger proportion
of turtles emerging on nourished beaches abandoned their nesting attempts than turtles emerging
on natural or pre-nourished beaches. This reduction in nesting success is most pronounced
during the first year following project construction and is most likely the result of changes in
physical beach characteristics associated with the nourishment project (e.g., beach profile,
sediment grain size, beach compaction, frequency and extent of escarpments). During the first
post-construction year, the time required for turtles to excavate an egg chamber on untilled, hard-
packed sands increases significantly relative to natural conditions. However, tilling (minimum
depth of 36 inches) is effective in reducing sediment compaction to levels that did not
significantly prolong digging times. As natural processes reduced compaction levels on
nourished beaches during the second post-construction year, digging times returned to natural
levels (Ernest and Martin 1999).

During the first post-construction year, nests on nourished beaches are deposited significantly
seaward of the toe of the dune and significantly landward of the tide line than nests on natural
beaches. More nests are washed out on the wide, flat beaches of the nourished treatments than
on the narrower steeply sloped natural beaches. This phenomenon may persist through the

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second post-construction year monitoring and result from the placement of nests near the
seaward edge of the beach berm where dramatic profile changes, caused by erosion and scarping,
occur as the beach equilibrates to a more natural contour.

The principal effect of beach nourishment on sea turtle reproduction is a reduction in nesting
success during the first year following project construction. Although most studies have
attributed this phenomenon to an increase in beach compaction and escarpment formation, Ernest
and Martin (1999) indicated that changes in beach profile may be more important. Regardless,
as a nourished beach is reworked by natural processes in subsequent years and adjusts from an
unnatural construction profile to a natural beach profile, beach compaction and the frequency of
escarpment formation decline, and nesting and nesting success return to levels found on natural
beaches.

6.4. CUMULATIVE EFFECTS

This project may occur on federal or non-federal lands. Cumulative effects include the effects of
future State, tribal, local, or private actions that are reasonably certain to occur in the Action
Area considered in this biological opinion. Future Federal actions that are unrelated to the
proposed action are not considered in this section, because they require separate consultation
pursuant to section 7 of the Act. It is reasonable to expect continued shoreline stabilization, inlet
dredging, sand placement projects, sand fencing, and beach scraping along the North Carolina
shoreline in the future since erosion and sea-level rise increases would impact the existing
beachfront development. However, with the exception of some of the above-listed project types,
most of the future actions that are reasonable certain to occur will require a Clean Water Act
(CWA) Section 404 permit, and thus will require separate consultation.

6.5. CONCLUSION

After reviewing the current status of the nesting loggerhead sea turtle, green sea turtle,
leatherback sea turtle, hawksbill sea turtle, and Kemp’s ridley sea turtle, the environmental
baseline for the Action Area, the effects of the proposed sand placement, the proposed
Conservation Measures, and the cumulative effects, it is the Service's biological opinion that the
placement of sand is not likely to jeopardize the continued existence of the loggerhead sea turtle,
green sea turtle, leatherback sea turtle, hawksbill sea turtle, and Kemp’s ridley sea turtle. It is the
Service’s biological opinion that the placement of sand is not likely to adversely modify
terrestrial loggerhead critical habitat.

• The conservation of the five loggerhead recovery units in the Northwest Atlantic is
essential to the recovery of the loggerhead sea turtle. Each individual recovery unit is
necessary to conserve genetic and demographic robustness, or other features necessary
for long-term sustainability of the entire population. Thus, maintenance of viable nesting
in each recovery unit contributes to the overall population. The NRU, one of the five

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loggerhead recovery units in the Northwest Atlantic occurs within the Action Area. The
NRU averages 5,215 nests per year (based on 1989-2008 nesting data). Of the available
nesting habitat within the NRU, construction will occur and/or will likely have an effect
on up to 25 miles of North Carolina shoreline annually in normal years, and up to 62.5
miles of shoreline in years following a major storm.
• Because of the programmatic nature of this BO, construction may occur and/or have an
effect on up to 25 miles of loggerhead terrestrial critical habitat annually in normal years,
and up to 62.5 miles of loggerhead terrestrial critical habitat in years following a major
storm (although we acknowledge it is unlikely that all of the work would be conducted
within critical habitat units), out of a total of 96.1 miles.
• Generally, green, leatherback, hawksbill, and Kemp’s ridley sea turtle nesting overlaps
with or occurs within the beaches where loggerhead sea turtles nest on both the Atlantic
and Gulf of Mexico beaches. Thus, for green, leatherback, hawksbill, and Kemp’s ridley
sea turtles, sand placement activities will occur and/or will likely have an effect on up to
25 miles of North Carolina shoreline annually in normal years, and up to 62.5 miles of
shoreline in years following a major storm.
• Research has shown that the principal effect of sand placement on sea turtle reproduction
is a reduction in nesting success, and this reduction is most often limited to the first year
or two following project construction. Research has also shown that the impacts of a
typical sand nourishment project on sea turtle nesting habitat are short-term because a
nourished beach will be reworked by natural processes in subsequent years, and beach
compaction and the frequency of escarpment formation will decline.

7. INCIDENTAL TAKE STATEMENT

Section 9 of the ESA and Federal regulations pursuant to section 4(d) of the ESA prohibit the
take of endangered or threatened species, respectively, without special exemption. Take is
defined as to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture or collect, or to attempt
to engage in any such conduct. Harm is further defined by the Service to include significant
habitat modification or degradation that results in death or injury to listed species by significantly
impairing essential behavioral patterns, including breeding, feeding, or sheltering. Harass is
defined by the Service as intentional or negligent actions that create the likelihood of injury to
listed species to such an extent as to significantly disrupt normal behavior patterns which
include, but are not limited to, breeding, feeding, or sheltering. Incidental take is defined as take
that is incidental to, and not the purpose of, carrying out an otherwise lawful activity. Under the
terms of section 7(b)(4) and section 7(o)(2), taking that is incidental to and not intended as part
of the agency action is not considered to be prohibited under the ESA, provided that such taking
is in compliance with the terms and conditions of this incidental take statement.

The measures described below in Section 7.3 are non-discretionary, and must be implemented by
the Corps so that they become binding conditions of any funding action or any grant or permit
issued to the Applicant, as appropriate, for the exemption in section 7(o)(2) to apply. The Corps

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has a continuing duty to regulate the activity covered by this incidental take statement. If the
Corps (1) fails to assume and implement the terms and conditions or (2) fails to require the
Applicant to adhere to the terms and conditions of the incidental take statement through
enforceable terms that are added to the permit or grant document, the protective coverage of
section 7(o)(2) may lapse. In order to monitor the impact of incidental take, the Corps must
report the progress of the action and its impacts on the species to the Service as specified in the
incidental take statement [50 CFR §402.14(i)(3)].

Sections 7(b)(4) and 7(o)(2) of the ESA generally do not apply to listed plant species. However,
limited protection of listed plants from take is provided to the extent that the ESA prohibits the
removal and reduction to possession of Federally listed endangered plants or the malicious
damage of such plants on areas under Federal jurisdiction, or the destruction of endangered
plants on non-Federal areas in violation of state law or regulation, or in the course of any
violation of a State criminal trespass law.

7.1. AMOUNT OR EXTENT OF TAKE

7.1.1. Amount or Extent of Take – Piping Plover

It is difficult for the Service to estimate the exact number of piping plovers that could be
migrating through or wintering within the Action Area at any point in time and place during and
after maintenance events. Disturbance to suitable habitat resulting from placement of sand would
affect the ability of an undetermined number of piping plovers to find suitable foraging and
roosting habitat for an unknown length of time after construction.

The Service anticipates that no more than 25 miles of highly eroded shoreline along the North
Carolina coastline would receive sand placement per year during nonemergency years, with a
maximum of 62.5 miles of shoreline receiving sand during or following an emergency event
(declared disaster or Congressional Order) as a result of the Statewide Programmatic action.
This represents 8% of the entire North Carolina shoreline per year during a nonemergency year,
and 19% of the shoreline during an emergency year.

Therefore, directly and indirectly an unspecified amount of piping plovers along this length of
shoreline, all at some point, potentially usable by piping plovers, could be taken in the form of
harm, harassment, and/or habitat loss as a result of this proposed action; however, incidental take
of piping plovers will be difficult to detect for the following reasons:

(1) harassment to the level of harm may only be apparent on the breeding grounds the
following year; and
(2) dead plovers may be carried away by waves or predators.

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The level of take of this species can be anticipated by the proposed activities because:

(1) piping plovers nest, migrate through and winter in the Action Area;
(2) the placement of the constructed beach is expected to affect the coastal morphology
and prevent early successional stages, thereby precluding the maintenance and
creation of additional recovery habitat;
(3) increased levels of pedestrian disturbance may be expected; and
(4) a temporary reduction of food base will occur.

The Service has reviewed the biological information and other information relevant to this
action. The take is expected in the form of harm and harassment because of: (1) decreased
fitness and survivorship of plovers due to loss and degradation of foraging and roosting habitat;
and (2) decreased fitness and survivorship of plovers nesting or attempting to migrate to breeding
grounds due to loss and degradation of nesting, foraging, and roosting habitat.

7.1.2. Amount or Extent of Take – Red Knot

It is difficult for the Service to estimate the exact number of red knots that could be migrating
through or wintering within the Action Area at any one point in time and place during
maintenance events. Disturbance to suitable habitat resulting from sand placement activities
within the Action Area would affect the ability of an undetermined number of red knots to find
suitable foraging and roosting habitat during any given year.

The Service anticipates that no more than 25 miles of highly eroded shoreline along the North
Carolina coastline would receive sand placement per year during nonemergency years, with a
maximum of 62.5 miles of shoreline receiving sand during or following an emergency event
(declared disaster or Congressional Order) as a result of the Statewide Programmatic action.
This represents 8% of the entire North Carolina shoreline per year during a nonemergency year,
and 19% of the shoreline during an emergency year.

Therefore, directly and indirectly, an unspecified amount of red knots along this length of
shoreline, all at some point, potentially usable by red knots, could be taken in the form of harm,
harassment, and/or habitat loss as a result of this proposed action; however, incidental take of red
knots will be difficult to detect for the following reasons:

(1) harassment to the level of harm may only be apparent on the breeding grounds the
following year; and
(2) dead red knots may be carried away by waves or predators.

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The level of take of this species can be anticipated by the proposed activities because:

(1) red knots migrate through and winter in the Action Area;
(2) the placement of the constructed beach is expected to affect the coastal morphology
and prevent early successional stages, thereby precluding the maintenance and
creation of additional recovery habitat;
(3) increased levels of pedestrian disturbance may be expected; and
(4) a temporary reduction of food base will occur.

The Service has reviewed the biological information and other information relevant to this
action. The take is expected in the form of harm and harassment because of: (1) decreased
fitness and survivorship of red knots due to loss and degradation of foraging and roosting habitat;
and (2) decreased fitness and survivorship of red knots attempting to migrate to breeding grounds
due to loss and degradation of foraging and roosting habitat.

7.1.3. Amount or Extent of Take – Loggerhead, Green, Leatherback, Hawksbill, and
Kemp’s Ridley Sea Turtles

The Service anticipates that no more than 25 miles of highly eroded shoreline along the North
Carolina coastline would receive sand placement per year during nonemergency years, with a
maximum of 62.5 miles of shoreline receiving sand during or following an emergency event
(declared disaster or Congressional Order) as a result of the Statewide Programmatic action.
This represents 8% of the entire North Carolina shoreline per year during a nonemergency year,
and 19% of the shoreline during an emergency year.

Along this length of shoreline, take is expected to be in the form of: (1) destruction of all nests
that may be constructed and eggs that may be deposited and missed by a nest survey, nest mark
and avoidance program, or egg relocation program within the boundaries of the proposed project;
(2) destruction of all nests deposited during the period when a nest survey, nest mark and
avoidance, or egg relocation program is not required to be in place within the boundaries of the
proposed project; (3) reduced hatching success due to egg mortality during relocation and
adverse conditions at the relocation site; (4) harassment in the form of disturbing or interfering
with female turtles attempting to nest within the construction area or on adjacent beaches as a
result of construction activities; (5) misdirection of nesting and hatchling turtles on beaches
adjacent to the sand placement or construction area as a result of project lighting; (6) behavior
modification of nesting females due to escarpment formation within the Action Area during the
nesting season, resulting in false crawls or situations where they choose marginal or unsuitable
nesting areas to deposit eggs; (7) behavior modification of nesting females due to unsuitable
material within the Action Area during the nesting season, resulting in false crawls or situations
where they choose marginal or unsuitable nesting areas to deposit eggs; (8) reduced hatching or
emergence success due to unsuitable nesting habitat, resulting in egg mortality or inability of

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hatchlings to emerge from the egg cavity; and (9) destruction of nests from escarpment leveling
within a nesting season when such leveling has been approved by the Service.

Incidental take is anticipated for the 25 miles (nonemergency years) and 62.5 miles (emergency
years) of beach that has been identified. The Service anticipates incidental take of sea turtles
will be difficult to detect for the following reasons: (1) the turtles nest primarily at night and all
nests are not found because [a] natural factors, such as rainfall, wind, and tides may obscure
crawls and [b] human-caused factors, such as pedestrian and vehicular traffic, may obscure
crawls, and result in nests being destroyed because they were missed during a nesting survey,
nest mark and avoidance, or egg relocation program (2) the total number of hatchlings per
undiscovered nest is unknown; (3) the reduction in percent hatching and emerging success per
relocated nest over the natural nest site is unknown; (4) an unknown number of females may
avoid the project beach and be forced to nest in a less than optimal area; (5) lights may misdirect
an unknown number of hatchlings and cause death; and (6) escarpments may form and prevent
an unknown number of females from accessing a suitable nesting site.

The incidental take of these species can be anticipated by the sand placement activities on
suitable turtle nesting beach habitat because: (1) turtles nest within the Action Area; (2) the
renourishment project will modify the incubation substrate, beach slope, and sand compaction;
and (3) artificial lighting will deter and/or misdirect nesting hatchling turtles.

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7.2. EFFECT OF THE TAKE

Piping Plovers

In the accompanying SPBO, the Service determined that this level of anticipated take is not
likely to result in jeopardy to the Northern Great Plains, Great Lakes, or Atlantic Coast breeding
populations of the piping plover. The Service determined that the proposed activities are not
likely to result in adverse modification of wintering critical habitat for the piping plover.

Red Knot

In the accompanying biological opinion, the Service determined that this level of anticipated take
is not likely to result in jeopardy to the red knot species.

Seabeach Amaranth

In the accompanying biological opinion, the Service determined that the potential of the project
to damage or destroy seabeach amaranth is not likely to result in jeopardy to the seabeach
amaranth species.

Loggerhead, Green, Leatherback, Hawksbill, and Kemp’s Ridley Sea Turtles

In the accompanying biological opinion, the Service determined that this level of anticipated take
is not likely to result in jeopardy to the loggerhead sea turtle, green sea turtle, leatherback sea
turtle, hawksbill sea turtle, and Kemp’s ridley sea turtle species. The Service determined that
the proposed activities are not likely to result in adverse modification of loggerhead terrestrial
critical habitat.

7.3. REASONABLE AND PRUDENT MEASURES AND TERMS AND CONDITIONS

The Service believes the following reasonable and prudent measures (RPMs) are necessary and
appropriate to minimize take of piping plovers, red knots, seabeach amaranth, and sea turtles in
the Action Area for the following sand placement activities:

A. Sand placement from beach nourishment activities; and
B. Sand placement from navigation channel maintenance.

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If unable to comply with the RPMs and Terms and Conditions, the Corps, as the regulatory
authority or construction agent may:

1. Inform the Service why the RPM or Term and Condition is not reasonable and prudent
for the specific project or activity and request exception under the SPBO; or
2. Initiate consultation with the Service for the specific project or activity.
The Service may respond by either of the following:

1. Allowing an exception to the Terms and Conditions under the SPBO; or
2. Recommending or accepting initiation of consultation (if initiated by the Corps) for the
specific project or activity.

REASONABLE AND PRUDENT MEASURES for:

A. Projects that include sand placement from beach nourishment activities, primarily for
shore protection (these projects are usually larger scaled) shall include the following
measures:

Post-construction requirements are listed in Reasonable and Prudent Measures A.13, A.16, A.17,
A.18, A.19, and A.21. These post-construction requirements may be subject to congressional
authorization and the allocation of funds. If the Corps or Permittee cannot fulfill these
Reasonable and Prudent Measures, the Corps must reinitiate consultation.

RPMs – All Species

A.1. Conservation Measures included in the Corps’ Programmatic Biological Assessment
(PBA) that address protection of nesting sea turtles, piping plovers, red knots, and
seabeach amaranth shall be implemented in the Corps federally authorized project or
regulated activity. If a RPM and Term and Condition address the same requirement, the
requirements of the RPM and Term and Condition take precedence over the
Conservation Measure.

A.2. The Corps will notify the Service of the commencement of projects that utilize this
SPBO for the purposes of tracking incidental take of all species.

A.3. For the life of the project, all sand placement activities above MHW must be conducted
within the winter work window (November 16 to April 30).

A.4. Prior to sand placement, all derelict material, large amounts of rock, or other debris must
be removed from the beach to the maximum extent possible.

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A.5. During construction, trash and food items shall be disposed of properly either in
predator-proof receptacles, or in receptacles that are emptied each night to minimize the
potential for attracting predators of piping plovers, red knots, and sea turtles.

A.6. Pipeline placement must be coordinated with NCDCM, the Corps, the Service, and the
NCWRC. Pipeline placement coordination may be accomplished through the permit
application or Corps’ contract processes utilizing appropriate GIS tools.

A.7. Access points for construction vehicles should be as close to the project site as possible.
Construction vehicle travel down the beach should be limited to the maximum extent
possible.

A.8. A meeting between representatives of the Permittee or Corps, the Service, NCWRC, and
NCDCM, must be held prior to the commencement of work on each project.

A.9. The Corps shall facilitate an annual meeting with the Service to assess the effectiveness
of the protection and minimization measures outlined in this SPBO.

RPMs - Piping Plovers and Red Knots

A.10. All personnel involved in the construction or sand placement process along the beach
shall be aware of the potential presence of piping plovers and red knots. Before start of
work each morning, a visual survey must be conducted in the area of work for that day,
to determine if piping plovers and red knots are present.

A.11. If project-related activities will potentially adversely affect nesting shorebirds or active
nesting habitat, the Corps or Permittee must coordinate with the Service and NCWRC
prior to proceeding. If the project is ongoing and shorebirds begin territorial or other
nesting behaviors within the project area, then the Corps or Permittee must contact the
Service and NCWRC as soon as possible.

A.12. If project activities will be conducted in Optimal Piping Plover Areas (defined in Terms
and Conditions A.13 and A.14), the Corps or the Permittee shall clearly delineate work
areas within the Optimal Piping Plover Area such as pipeline corridors, travel corridors,
and access points. Disturbance outside those delineated work areas must be limited to
the maximum extent possible, thereby minimizing effects to sandy unvegetated habitat
within the project footprint.

A.13. If project activities will be conducted in Optimal Piping Plover Areas (defined in Term
and ConditionsA.13 and A.14), the Corps, the Permittee, or the local sponsor shall
provide the mechanisms necessary to monitor impacts to the piping plovers from the
project for two years post-construction.

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RPMs – Loggerhead, Green, Leatherback, Hawksbill, and Kemp’s Ridley Sea Turtles

A.14. Only beach quality sand suitable for sea turtle nesting, successful incubation, and
hatchling emergence (defined in Term and Condition A.18) shall be used for sand
placement.

A.15. During dredging operations, material placed on the beach shall be qualitatively inspected
daily to ensure compatibility. If the inspection process finds that a significant amount of
non-beach compatible material is on or has been placed on the beach, all work shall stop
immediately and the NCDCM and the Corps will be notified by the Permittee or Corps
to determine the appropriate plan of action.

A.16. Sea turtle nesting surveys must be conducted within the project area between May 1 and
November 15 of each year, for at least two consecutive nesting seasons after completion,
if the sand remains on the beach. Acquisition of readily available sea turtle nesting data
from qualified sources (volunteer organizations, other agencies, etc.) is acceptable.

A.17. Visual surveys for escarpments along the Action Area must be made immediately after
completion of sand placement, and within 30 days prior to May 1, for two subsequent
years after any construction or sand placement event.

A.18. Sand compaction must be qualitatively evaluated at least twice after each sand
placement event. Sand compaction must be inspected in the project area immediately
after completion of any sand placement event and one time after project completion
between October 1 and May 1.

A.19. A report describing the fate of observed sea turtle nests and hatchlings and any actions
taken, must be submitted to the Service following completion of work for each year
when a sand placement activity has occurred.

A.20. If a dune system is part of the project design, the placement and design of the dune must
be coordinated with the Service.

RPMs – Seabeach Amaranth

A.21. The Corps Civil Works Program shall continue its annual seabeach amaranth monitoring
program.

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TERMS AND CONDITIONS FOR:

A. Sand placement from beach nourishment activities

All conservation measures described in the Corps’ Programmatic Biological Assessment are
hereby incorporated by reference as Terms and Conditions within this document pursuant to 50
CFR §402.14(I) with the addition of the following Terms and Conditions. In order to be exempt
from the prohibitions of section 9 of the Act, the Corps shall comply with the following Terms
and Conditions, which implement the Reasonable and Prudent Measures, described above and
outline reporting/monitoring requirements. These terms and conditions are non-discretionary.

Post-construction requirements are listed in Terms and Conditions A.13, A.14, A.17, A.18, A.19,
A.20, A.22, A.23, A.24, A.25, and A.26. These post-construction requirements may be subject
to congressional authorization and the allocation of funds. If the Corps or Permittee cannot
fulfill these Terms and Conditions, the Corps must reinitiate consultation.

Terms and Conditions – All Species

A.1. Conservation Measures included in the Corps’ PBA that address protection of nesting sea
turtles, piping plover, red knot, and seabeach amaranth listed on pages 10-11 of the
SPBO shall be implemented in the Corps federally authorized project or regulated
activity.

A.2. The Corps or the Permittee must provide the following information to the Service at least
10 business days prior to the commencement of work:
a) Project location (include latitude and longitude coordinates, as well as mile
markers, cross streets, or street addresses if available);
b) Project description (including linear feet of beach, actual fill template, access
points, and borrow areas); and
c) Anticipated date of commencement and anticipated duration of construction.

A.3. For the life of the permit/project, all sand placement activities above MHW must be
conducted within the winter work window (November 16 to April 30), unless a variance
is approved after additional consultation with the Service.

A.4. Prior to sand placement, all derelict material, large amounts of rock, or other debris must
be removed from the beach to the maximum extent possible. If debris removal activities
take place during shorebird breeding season (April 1– August 31), the work shall be
conducted during daylight hours only.

192
A.5. During construction, trash and food items shall be disposed of properly either in predator-
proof receptacles, or in receptacles that are emptied each night to minimize the potential
for attracting predators of piping plovers, red knots, and sea turtles.

A.6. Pipeline placement must be coordinated with NCDCM, the Corps, the Service, and the
NCWRC. This may be accomplished through the permit application or Corps’ contract
processes utilizing appropriate GIS tools.

A.7. Access points for construction vehicles should be as close to the project site as possible.
Construction vehicle travel down the beach should be limited to the maximum extent
possible.

A.8. A meeting between representatives of the contractor(s), the Corps, the Service, the
NCWRC, and NCDCM, must be held prior to the commencement of work. Advance
notice (of at least 5 business days) must be provided prior to conducting this meeting.
The meeting will provide an opportunity for explanation and/or clarification of the
Conservation Measures and Terms and Conditions, and will include the following:
a) Staging locations, and storing of equipment, including fuel stations;
b) Coordination with the surveyors on required species surveys;
c) Pipeline placement;
d) Minimization of driving within and around the Action Area;
e) Follow up coordination during construction and post construction;
f) Direction of the work including progression of sand placement along the beach;
g) Plans for compaction monitoring;
h) Plans for escarpment surveys and
i) Names and qualifications of personnel involved in any required species surveys.

A.9. Following the preconstruction meeting, the Corps shall provide the Service with specific
anticipated shoreline lengths and anticipated duration of the project, using the form on the
following web link:
<https://www.fws.gov/northflorida/SeaTurtles/Docs/Corp%20of%20Engineers%20Sea%
20Turtle%20Permit%20Information.pdf >. Only the following information should be
filled out: Corps permit number, FWS Log Number, Project Location, Construction
Activity, Duration of Project, and Actual Take (linear feet of beach). This form shall be
emailed to the Service at <[e-mail]>. The form should be filled out using
information from the permit application or authorization. This form is in addition to the
annual report, listed below.

A.10. The Corps shall meet with the Service, NCDCM, and NCWRC (and cooperating agencies
such as BOEM, as appropriate) annually to discuss the effectiveness of the avoidance
measures and additional measures to include for future projects. The agencies will also
review the projects utilizing this SPBO the previous year to ensure that the reporting

193
requirements for calculating the extent of take are adequate. This meeting will also
explore:
a) The possibility of using dredged materials to enhance potential or existing piping
plover habitat within and adjacent to the project area;
b) Methods for funding beneficial use opportunities for dredged materials that are
not least-cost disposal to benefit piping plovers and their habitat;
c) The development of shore protection design guidelines that can be utilized during
future project planning to protect and/or enhance piping plover habitat; and
d) Incorporating artificial lagoons or ephemeral pools into project designs adjacent
to inlets where sand placement is proposed.

Terms and Conditions – Piping Plovers and Red Knots

A.11. All personnel involved in the construction or sand placement process along the beach
shall be aware of the potential presence of piping plovers and red knots. Before start of
work each morning, a visual survey must be conducted in the area of work for that day, to
determine if piping plovers and red knots are present. If shorebirds are present in the
work area, careful movement of equipment in the early morning hours should allow those
individuals to move out of the area. Construction operations shall be carried out at all
times in a manner as to avoid negatively impacting shorebirds and allowing them to exit
the area.

A.12. If project-related activities will potentially adversely affect nesting shorebirds or active
nesting habitat, the Corps or Permittee must coordinate with the Service and NCWRC
prior to proceeding. If the project is ongoing and shorebirds begin territorial or other
nesting behaviors within the project area, then the Corps or Permittee must contact the
Service and NCWRC as soon as possible.

A.13. If project activities will be conducted in Optimal Piping Plover Areas, piping plover
habitat (sandy unvegetated habitat) within the Optimal Piping Plover Area shall be
avoided to the maximum extent practicable when staging equipment, establishing travel
corridors, and aligning pipeline. The Corps or the Permittee, to the maximum extent
practicable, shall clearly delineate work areas within the Optimal Piping Plover Area
such as pipeline corridors, travel corridors, and access points. Disturbance outside those
delineated work areas must be limited, thereby minimizing effects to sandy unvegetated
habitat. Driving on the beach for construction shall be limited to the minimum necessary
within the designated travel corridor. The delineation of work corridors and work areas
in authorized project plans will be sufficient to meet this term and condition.
Optimal Piping Plover Areas are defined as having documented use by piping plovers,
and they include coastal habitat features that function mostly unimpeded. Optimal Piping
Plover Areas include:

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a) Designated piping plover Critical Habitat Units (see Appendix C);
b) All Federal, State, and County publicly owned land where coastal processes are
allowed to function, mostly unimpeded*, that have any of the following
features in the Action Area:
i. Located within 1 mile of an inlet;
ii. Emergent nearshore sand bars;
iii. Washover fans;
iv. Emergent soundside and Ocean shoals and sand bars;
v. Soundside mudflats, sand flats, and algal flats; or
vi. Soundside shorelines.

[*Publicly owned land where coastal processes are allowed to function, mostly unimpeded,
generally does not include public lands that are solely state-owned water bottoms, street
ends, parking lots, piers, beach accesses, heavily-developed or highly-manipulated parks,
or shoreline developed for commercial or residential purposes. It generally does include
public lands consisting of undeveloped parks, preserves, and other natural undeveloped
shoreline and dunes.]

A.14. If project related activities will be conducted in Optimal Piping Plover Areas, then the
piping plover and red knot survey protocol in Appendix D must be followed. Two full
years of post-construction monitoring is required. Optimal Piping Plover Areas include:

a) Designated piping plover Critical Habitat Units (see Appendix C);
b) All Federal, State, and County publicly owned land where coastal processes are
allowed to function, mostly unimpeded*, that have any of the following
features in the Action Area:
i. Located within 1 mile of an inlet;
ii. Emergent nearshore sand bars;
iii. Washover fans;
iv. Emergent soundside and Ocean shoals and sand bars;
v. Soundside mudflats, sand flats, and algal flats; or
vi. Soundside shorelines.

[*Publicly owned land where coastal processes are allowed to function, mostly unimpeded,
generally does not include public lands that are solely state-owned water bottoms, street
ends, parking lots, piers, beach accesses, heavily-developed or highly-manipulated parks,
or shoreline developed for commercial or residential purposes. It generally does include
public lands consisting of undeveloped parks, preserves, and other natural undeveloped
shoreline and dunes.]

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Terms and Conditions – Sea Turtles

A.15. Only beach compatible fill shall be placed on the beach or in any associated dune system.
Beach compatible fill must be sand that is similar to a native beach in the vicinity of the
site that has not been affected by prior sand placement activity. Beach compatible fill
must be sand comprised solely of natural sediment and shell material, containing no
construction debris, toxic material, large amounts of rock, or other foreign matter. The
beach compatible fill must be similar in both color and grain size distribution (sand grain
frequency, mean and median grain size and sorting coefficient) to the native material in
the Action Area. Beach compatible fill is material that maintains the general character
and functionality of the material occurring on the beach and in the adjacent dune and
coastal system. In general, fill material that meets the requirements of the most recent
version of the North Carolina Technical Standards for Beach Fill (15A NCAC 07H
.0312) is considered compatible.

A.16. During dredging operations, material placed on the beach shall be qualitatively inspected
daily to ensure compatibility. If the inspection process finds that a significant amount of
non-beach compatible material is on or has been placed on the beach, all work shall stop
immediately, and the NCDCM, Corps, and BOEM (as appropriate) will be notified by the
permittee and/or its contractors to determine the appropriate plan of action. Required
actions may include immediate removal of material and/or long-term remediation
activities.

A.17. Daily sea turtle nesting surveys must be conducted within the project area between May 1
and November 15 of each year, for at least two consecutive nesting seasons after
completion of sand placement (2 years post-construction monitoring). Acquisition of
readily available sea turtle nesting data from qualified sources (volunteer organizations,
other agencies, etc.) is acceptable. However, in the event that data from other sources
cannot be acquired, the Corps or permittee will be responsible to collect the data. Data
collected for each nest should include, at a minimum, the information in the table, below.
This information will be provided to the Service in the annual report, and will be used to
periodically assess the cumulative effects of these projects on sea turtle nesting and
hatchling production and monitor suitability of post construction beaches for nesting.
Please see REPORTING REQUIREMENTS, below.

196

A.18. Visual surveys for escarpments along the Action Area must be made immediately after
completion of sand placement, and within 30 days prior to May 1, for two subsequent
years after any construction or sand placement event. Escarpments that interfere with sea
turtle nesting or that exceed 18 inches in height for a distance of 100 feet must be leveled
and the beach profile must be reconfigured to minimize scarp formation by the dates
listed above. Any escarpment removal must be reported by location. The Service must
be contacted immediately if subsequent reformation of escarpments that interfere with
sea turtle nesting or that exceed 18 inches in height for a distance of 100 feet occurs
during the nesting and hatching season to determine the appropriate action to be taken. If
it is determined that escarpment leveling is required during the nesting or hatching
season, the Service or NCWRC will provide a brief written authorization within 30 days
that describes methods to be used to reduce the likelihood of impacting existing nests.
An annual summary of escarpment surveys and actions taken must be submitted to the
Service.

Parameter Measurement Variable
Number of
False
Crawls
Visual
Assessment of
all false crawls
Number/location of false crawls in nourished areas; any
interaction of turtles with obstructions, such as sand bags or
scarps, should be noted.
False
Crawl Type
Categorization
of the stage at
which nesting
was abandoned

Number in each of the following categories:
a) Emergence - no digging;
b) Preliminary body pit;
c) Abandoned egg chamber.
Nests Number The number of sea turtle nests in nourished areas should be
noted. If possible, the location of all sea turtle nests should
be marked on a project map, and approximate distance to
scarps or sandbags measured in meters. Any abnormal
cavity morphologies should be reported as well as whether
turtle touched sandbags or scarps during nest excavation.
Nests Lost Nests The number of nests lost to inundation or erosion or the
number with lost markers.
Nests Relocated nests The number of nests relocated and a map of the relocation
area(s). The number of successfully hatched eggs per
relocated nest.
Lighting
Impacts
Disoriented sea
turtles
The number of disoriented hatchlings and adults.

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A.19. Sand compaction must be qualitatively evaluated at least twice after each sand placement
event, once in the project area immediately after completion of any sand placement event
and once after project completion between October 1 and May 1. Compaction
monitoring and remediation are not required if the placed material no longer remains on
the beach. Within 14 days of completion of sand placement and prior to any tilling (if
needed), a field meeting shall be held with the Service, NCWRC, and the Corps to
inspect the project area for compaction and determine whether tilling is needed.
a) If tilling is needed for sand suitability, the area must be tilled to a depth of 36
inches. All tilling activities shall be completed prior to May 1 of any year.
b) Tilling must occur landward of the wrack line and avoid all vegetated areas that
are 3 square feet or greater, with a 3-foot buffer around all vegetation.
c) If tilling occurs during the shorebird nesting season or seabeach amaranth
growing season (after April 1), shorebird surveys and/or seabeach amaranth
surveys are required prior to tilling.
d) A summary of the compaction assessments and the actions taken shall be included
in the annual report to NCDCM, the Corps, and the Service.
e) These conditions will be evaluated and may be modified if necessary to address
and identify sand compaction problems.

A.20. A report describing the fate of observed sea turtle nests and hatchlings and any actions
taken, must be submitted to the Service following completion of the proposed work for
each year when a sand placement activity has occurred. Please see REPORTING
REQUIREMENTS, below.

A.21. If a dune system is part of the project design, the placement and design of the dune must
be coordinated with the Service.

Terms and Conditions – Seabeach Amaranth

A.22. The Corps Civil Works Program shall continue its annual seabeach amaranth monitoring
program in accordance with April 19, 1993 Biological Opinion for various U.S. Army
Corps of Engineers’ projects and Terms and Conditions A.23 to A.26, below..

A.23. The Corps should survey beach sand placement areas for at least five years following
each placement event, to determine the status of the seabeach amaranth populations in the
project areas and the effects that beach disposal has on this species. Surveys should be
conducted in August or September so that the number of plants reaching reproductive age
can be determined.

A.24. Suitable habitat along shoreline reaches that have received sand within the previous five
years should be surveyed for the occurrence of seabeach amaranth. Documentation for
each seabeach amaranth plant should include location (using a handheld GPS unit),

198
unique features, abnormalities, or other relevant information. If multiple plants are
observed in an area, a single representative GPS point may be logged with accompanying
notes describing total plants associated with that point.

A.25. A Corps report describing the seabeach amaranth survey and results should be submitted
to Service, the North Carolina Natural Heritage Program, and the North Carolina Plant
Conservation Program, by December 31 of each year. The report should include a map
showing locations of seabeach amaranth populations and the numbers of plants, with
separate figures for those in flower or fruit, found in the sand placement areas.

A.26. If tilling of the beach is required due to high compaction levels resulting from beach
disposal, surveys should be conducted in advance of the tilling for seabeach amaranth
(see sea turtle section - Reasonable and Prudent Measures). No tilling should be
conducted in the immediate areas where seabeach amaranth plants are growing.

REASONABLE AND PRUDENT MEASURES for:

B. Projects that are navigation maintenance dredging with beach placement shall include
the following measures:

Historically, sand placement events associated with navigation maintenance dredging projects
have no local sponsor, are smaller-scaled, conducted at closer time intervals, and the sand often
does not remain on the beach for an extended period of time.

Post-construction requirements are listed in Reasonable and Prudent Measures B.11, B.12, B.13,
B.15, and B.16. These post-construction requirements may be subject to congressional
authorization and the allocation of funds. If the Corps or Permittee cannot fulfill these Terms
and Conditions, the Corps must reinitiate consultation.

B.1. Conservation Measures included in the Corps’ PBA that address protection of piping
plovers, red knots, nesting sea turtles, and seabeach amaranth shall be implemented in the
Corps’ federally authorized project or regulated activity.

B.2. The Corps will notify the Service of the commencement of projects that utilize this SPBO
for the purposes of tracking incidental take of all species.

B.3. For the life of the project, all sand placement activities above MHW must be conducted
within the winter work window (November 16 to April 30).

B.4. Prior to sand placement, all derelict material, large amounts of rock, or other debris must
be removed from the beach to the maximum extent possible.

199
B.5. During construction, trash and food items shall be disposed of properly either in predator-
proof receptacles, or in receptacles that are emptied each night to minimize the potential
for attracting predators of piping plovers, red knots, and sea turtles.

B.6. Pipeline placement must be coordinated with NCDCM, the Corps, the Service, and the
NCWRC.

B.7. Access points for construction vehicles should be as close to the project site as possible.
Construction vehicle travel down the beach should be limited to the maximum extent
possible.

B.8. Beach quality sand suitable for sea turtle nesting, successful incubation, and hatchling
emergence shall be used for sand placement.

B.9. A meeting between representatives of the Corps, Service, NCWRC, and NCDCM shall
be held prior to the commencement of work on this project.

B.10. During dredging operations, material placed on the beach shall be inspected daily to
ensure compatibility. If the inspection process finds that non-beach compatible material,
including large amounts of shell or rock, is or has been placed on the beach, all work
shall stop immediately and the NCDCM and the Corps will be notified by the permittee
and/or its contractors to determine the appropriate plan of action.

B.11. For navigation projects with placement of at least 200,000 cubic yards of sand on the
beach, sea turtle nesting surveys must be conducted within the project area between May
1 and November 15 of each year, for at least two consecutive nesting seasons after
completion, if the sand remains on the beach. Acquisition of readily available sea turtle
nesting data from qualified sources (volunteer organization, other agencies, etc.) is
acceptable.

B.12. Sand compaction shall be monitored and tilling shall be conducted if needed to reduce the
likelihood of impacting sea turtle nesting and hatching activities.

B.13. Escarpment formation shall be monitored and leveling shall be conducted if needed to
reduce the likelihood of impacting nesting and hatchling sea turtles.

B.14. Construction equipment and materials shall be stored in a manner that will minimize
impacts to piping plovers, red knots, and nesting shorebirds.

B.15. A report describing the actions taken shall be submitted to the Service work for each year
when the activity has occurred.

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B.16. The Corps Civil Works Program shall continue its annual seabeach amaranth monitoring
program.

TERMS AND CONDITIONS for:

B. Projects that are navigation maintenance dredging with beach placement, or Corps civil
works project shall include the following measures:

Historically, sand placement events associated with navigation maintenance dredging projects
have no local sponsor, are smaller-scaled, conducted at closer time intervals, and the sand often
does not remain on the beach for an extended period of time.

All conservation measures described in the Corps’ Programmatic Biological Assessment are
hereby incorporated by reference as Terms and Conditions within this document pursuant to 50
CFR §402.14(I) with the addition of the following Terms and Conditions. In order to be exempt
from the prohibitions of section 9 of the Act, the Corps shall comply with the following Terms
and Conditions, which implement the Reasonable and Prudent Measures, described above and
outline reporting/monitoring requirements. These terms and conditions are non-discretionary.

Post-construction requirements are listed in Terms and Conditions B.11, B.12, B.13, B.15, B.16,
B.17, B.18, and B.19. These post-construction requirements may be subject to congressional
authorization and the allocation of funds. If the Corps or Permittee cannot fulfill these Terms
and Conditions, the Corps must reinitiate consultation.

B.1. Conservation Measures included in the Corps’ PBA that address protection of nesting sea
turtles, piping plover, red knot, and seabeach amaranth listed on pages 10-11 of the
SPBO shall be implemented in the Corps federally authorized project or regulated
activity.

B.2. The Corps or the Permittee must provide the following information to the Service at least
10 business days prior to the commencement of work:

a) Project location (include latitude and longitude coordinates, as well as mile markers,
cross streets, or street addresses if available);
b) Project description (including linear feet of beach, actual fill template, access points,
and borrow areas);
c) Anticipated date of commencement and anticipated duration of construction

B.3. For the life of the permit/project, all sand placement activities above MHW must be
conducted within the winter work window (November 16 to April 30), unless allowed
after additional consultation with the Service.

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B.4. Prior to sand placement, all derelict material, large amounts of rock, or other debris must
be removed from the beach to the maximum extent possible. If debris removal activities
take place during shorebird breeding season (April 1– August 31), the work shall be
conducted during daylight hours only.

B.5. During construction, trash and food items shall be disposed of properly either in predator-
proof receptacles, or in receptacles that are emptied each night to minimize the potential
for attracting predators of piping plovers, red knots, and sea turtles.

B.6. Pipeline placement must be coordinated with NCDCM, the Corps, the Service, and the
NCWRC.

B.7. Access points for construction vehicles should be as close to the project site as possible.
Construction vehicle travel down the beach should be limited to the maximum extent
possible.

B.8. Only beach compatible fill shall be placed on the beach or in any associated dune system.
Beach compatible fill must be sand that is similar to a native beach in the vicinity of the
site that has not been affected by prior sand placement activity. Beach compatible fill
must be sand comprised solely of natural sediment and shell material, containing no
construction debris, toxic material, large amounts of rock, or other foreign matter. The
beach compatible fill must be similar in both color and grain size distribution (sand grain
frequency, mean and median grain size and sorting coefficient) to the native material in
the Action Area. Beach compatible fill is material that maintains the general character
and functionality of the material occurring on the beach and in the adjacent dune and
coastal system. In general, fill material that meets the requirements of the most recent
version of the North Carolina Technical Standards for Beach Fill (15A NCAC 07H
.0312) is considered compatible.

B.9. The Service must be invited to any pre-construction meetings held prior to the
commencement of work. Advance notice (of at least 5 business days) must be provided
prior to conducting this meeting. The meeting will provide an opportunity for
explanation and/or clarification of the Conservation Measures and Terms and Conditions,
and will include the following:
a) Staging locations, storing equipment including fuel stations;
b) Coordination with the surveyors on required species surveys;
c) Pipeline placement (between 5 to 10 feet from dune);
d) Minimizing driving;
e) Follow up coordination during construction and post construction;
f) Direction of the project including progression of sand placement along the beach;
g) Plans for compaction monitoring;

202
h) Plans for escarpment surveys; and
i) Names and qualifications of personnel involved in any required surveys.

B.10. During dredging operations, material placed on the beach shall be inspected daily to
ensure compatibility. If the inspection process finds that non-beach compatible material,
including large amounts of shell or rock exceeding the state sediment criteria (15A
NCAC 07H .0312), is or has been placed on the beach, all work shall stop immediately,
and the NCDCM and the Corps will be notified by the permittee and/or its contractors to
determine the appropriate plan of action.

B.11. For navigation projects with placement of at least 200,000 cubic yards of sand on the
beach, sea turtle nesting surveys must be conducted within the project area between May
1 and November 15 of each year, for at least two consecutive nesting seasons after
completion of sand placement (2 years post-construction monitoring). Acquisition of
readily available sea turtle nesting data from qualified sources (volunteer organizations,
other agencies, etc.) is acceptable. Data collected for each nest should include, at a
minimum, the information in the table, below. This information will be provided to the
Raleigh Field Office in the annual report, and will be used to periodically assess the
cumulative effects of these projects on sea turtle nesting and hatchling production and
monitor suitability of post construction beaches for nesting. Please see REPORTING
REQUIREMENTS, below.

Parameter Measurement Variable
Number of
False
Crawls
Visual
Assessment of
all false crawls
Number/location of false crawls in nourished areas; any
interaction of turtles with obstructions, such as sand bags or
scarps, should be noted.
False
Crawl Type
Categorization
of the stage at
which nesting
was abandoned

Number in each of the following categories:
a) Emergence - no digging;
b) Preliminary body pit;
c) Abandoned egg chamber.
Nests Number The number of sea turtle nests in nourished areas should be
noted. If possible, the location of all sea turtle nests should
be marked on a project map, and approximate distance to
scarps or sandbags measured in meters. Any abnormal
cavity morphologies should be reported as well as whether
turtle touched sandbags or scarps during nest excavation.
Nests Lost Nests The number of nests lost to inundation or erosion or the
number with lost markers.

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B.12. Sand compaction must be qualitatively evaluated at least twice after each sand placement
event, once in the project area immediately after completion of any sand placement event
and once after project completion between October 1 and May 1. Compaction
monitoring and remediation are not required if the placed material no longer remains on
the beach. Within 14 days of completion of sand placement and prior to any tilling (if
needed), a field meeting shall be held with the Service, NCWRC, and the Corps to
inspect the project area for compaction and determine whether tilling is needed.

a) If tilling is needed for sand suitability, the area must be tilled to a depth of 36
inches. All tilling activities shall be completed prior to May 1 of any year.
b) Tilling must occur landward of the wrack line and avoid all vegetated areas that
are 3 square feet or greater, with a 3-foot buffer around all vegetation.
c) If tilling occurs during the shorebird nesting season or seabeach amaranth
growing season (after April 1), shorebird surveys and/or seabeach amaranth
surveys are required prior to tilling.
d) A summary of the compaction assessments and the actions taken shall be included
in the annual report to NCDCM, the Corps, and the Service.
e) These conditions will be evaluated and may be modified if necessary to address
and identify sand compaction problems.

B.13. Visual surveys for escarpments along the Action Area must be made immediately after
completion of sand placement, and within 30 days prior to May 1, for two subsequent
years after any construction or sand placement event. Escarpments that interfere with sea
turtle nesting or that exceed 18 inches in height for a distance of 100 feet must be leveled
and the beach profile must be reconfigured to minimize scarp formation by the dates
listed above. Any escarpment removal must be reported by location. The Service must
be contacted immediately if subsequent reformation of escarpments that interfere with
sea turtle nesting or that exceed 18 inches in height for a distance of 100 feet occurs
during the nesting and hatching season to determine the appropriate action to be taken. If
it is determined that escarpment leveling is required during the nesting or hatching
season, the Service or NCWRC will provide a brief written authorization within 30 days
that describes methods to be used to reduce the likelihood of impacting existing nests.
An annual summary of escarpment surveys and actions taken must be submitted to the
Service.

Nests Relocated nests The number of nests relocated and a map of the relocation
area(s). The number of successfully hatched eggs per
relocated nest.
Lighting
Impacts
Disoriented sea
turtles
The number of disoriented hatchlings and adults.

204
B.14. Piping plover habitat (sandy unvegetated habitat along inlet shoulders) shall be avoided
to the maximum extent practicable when staging equipment, establishing travel corridors,
and aligning pipeline.

B.15. A report describing the fate of observed sea turtle nests and hatchlings and any actions
taken, must be submitted to the Service following completion of the proposed work for
each year when a sand placement activity has occurred. Please see REPORTING
REQUIREMENTS, below.

B.16. The Corps’ annual seabeach amaranth monitoring program shall continue in accordance
with April 19, 1993 Biological Opinion for various U.S. Army Corps of Engineers’
projects.

B.17. The Corps should survey beach sand placement areas for at least five years following
each placement event, to determine the status of the seabeach amaranth populations in the
project areas and the effects that beach disposal has on this species. Surveys should be
conducted in August or September so that the number of plants reaching reproductive age
can be determined.

B.18. Suitable habitat along shoreline reaches that have received sand within the previous five
years should be surveyed for the occurrence of seabeach amaranth. Documentation for
each seabeach amaranth plant should include location (using a handheld GPS unit),
unique features, abnormalities, or other relevant information. If multiple plants are
observed in an area, a single representative GPS point may be logged with accompanying
notes describing total plants associated with that point.

B.19. A Corps report describing the seabeach amaranth survey and results should be submitted
to Service, the North Carolina Natural Heritage Program, and the North Carolina Plant
Conservation Program, by December 31 of each year. The report should include a map
showing locations of seabeach amaranth populations and the numbers of plants, with
separate figures for those in flower or fruit, found in the sand placement areas.

205
7.4 REPORTING REQUIREMENTS

An annual report detailing the monitoring and survey data collected during the preceding year
(required in the above Terms and Conditions) and summarizing all piping plover, red knot,
shorebird, and sea turtle data must be provided to the Service’s Raleigh Field Office by January
31 of each year for review and comment. In addition, any information or data related to a
conservation measure or recommendation that is implemented should be included in the annual
report. As in the past, the Corps should submit a separate annual monitoring report detailing
seabeach amaranth monitoring and survey data for the preceding year. The contact for these
reporting requirements is:

Pete Benjamin, Supervisor
Raleigh Field Office
U.S. Fish and Wildlife Service
Post Office Box 33726
Raleigh, North Carolina 27636-3726
[phone]

Upon locating a dead, injured, or sick individual of an endangered or threatened species, initial
notification must be made to the Service’s Law Enforcement Office below. Additional
notification must be made to the Raleigh Ecological Services Field Office identified above and to
the NCWRC at [phone]. Care should be taken in handling sick or injured individuals and
in the preservation of specimens in the best possible state for later analysis of cause of death or
injury.

Jason Keith
U.S. Fish and Wildlife Service
551-F Pylon Drive
Raleigh, NC 27606
[phone], extension 34

7.5. COORDINATION OF INCIDENTAL TAKE STATEMENT WITH OTHER
LAWS, REGULATIONS, AND POLICIES

The Service will not refer the incidental take of any migratory bird for prosecution under the
Migratory Bird Treaty Act of 1918, as amended (16 USC S 703-712), if such take is in
compliance with the terms and conditions specified herein. Take resulting from activities that
are not in conformance with the Corps permit or this biological opinion (e.g. deliberate
harassment of wildlife, etc.) are not considered part of the proposed action and are not covered
by this incidental take statement and may be subject to enforcement action against the individual
responsible for the act.

206
8. CONSERVATION RECOMMENDATIONS

Section 7(a)(1) of the ESA directs Federal agencies to utilize their authorities to further the
purposes of the ESA by carrying out conservation programs for the benefit of endangered and
threatened species. Conservation recommendations are discretionary agency activities to
minimize or avoid adverse effects of a proposed action on listed species or critical habitat, to
help implement recovery plans, or to develop information.

The Service recommends the following Conservation Actions:

1. Construction activities for these projects and similar future projects should be planned to
take place outside the shorebird nesting season (Prior to March 30).

2. The Permittee or the Corps should maintain suitable piping plover migrating and
wintering habitat. Natural accretion at inlets should be allowed to remain. Accreting
sand spits on barrier islands provide excellent foraging habitat for migrating and
wintering plovers.

3. The Service encourages the Corps to work with local sponsors and/or applicants and
permittees to develop local beach management plans that include protections for sea
turtles, seabeach amaranth, piping plovers, red knots, and other shorebirds.

4. A conservation/education display sign at beach access points would be helpful in
educating local beach users about the coastal beach ecosystem and associated rare
species, including sea turtles, seabeach amaranth, piping plover, and red knot. The sign
could highlight each species life history and basic biology and ways recreationists can
assist in species protection efforts (e.g., keeping pets on a leash, removing trash to sealed
refuse containers, etc.). The Service would be willing to assist the Corps or the Permittee
in the development of such a sign, in cooperation with NCWRC.

5. The Service encourages continued investigation into opportunities for increasing
monitoring for Civil Works operations and maintenance projects, including the potential
development of a piping plover and red knot survey fund to assist in the management and
monitoring of shorebirds in Optimal Piping Plover Areas.

6. If public driving is allowed on the project beach, and if the Corps has the authority, we
recommend it exercise its discretionary authority to require the local sponsor or Permittee
to have authorization from the Service for incidental take of piping plover, red knot, sea
turtles, including nests and hatchlings (as appropriate), due to such driving or provide
written documentation from the Service that no incidental take authorization is required.
If required, the incidental take authorization for driving on the beach should be obtained
prior to any subsequent sand placement events.

207

7. If the project area is within a local municipality that has not adopted a lighting ordinance,
and lighting is shown to be an issue on a nourished beach, and if the Corps has the
authority, we recommend it exercise its discretionary authority to require an ordinance be
adopted prior to any subsequent sand placement event.

8. If the Corps has the authority, we recommend it exercise its discretionary authority to
require that leash-laws and predator control programs (including education of pet owners
and cat colony supporters) be implemented.

9. The Corps should work with local municipalities to identify and eradicate beach vitex, an
invasive species. Beach vitex populations have been known to impact nesting sea turtles
and shorebirds.
In order for the Service to be kept informed of actions minimizing or avoiding adverse effects or
benefitting listed species or their habitats, the Service requests notification of the implementation
of any conservation recommendations.

9. REINITIATION NOTICE – CLOSING STATEMENT

This concludes formal consultation on the action outlined in the request. As provided in 50 CFR
§402.16, reinitiation of formal consultation is required where discretionary Federal agency
involvement or control over the action has been retained (or is authorized by law) and if: (1) the
amount or extent of incidental take is exceeded; (2) new information reveals effects of the Corps’
action that may affect listed species or critical habitat in a manner or to an extent not considered
in this opinion or the project has not been completed within five years of the issuance of this
biological opinion; (3) the Corps’ action is subsequently modified in a manner that causes an
effect to the listed species or critical habitat not considered in this opinion; or (4) a new species is
listed or critical habitat designated that may be affected by the action. In instances where the
amount or extent of incidental take is exceeded, any operations causing such take must cease
pending reinitiation.

208
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Appendix A

North Carolina
Historical Sand Placement Projects
(from the PBA)

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280

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APPENDIX B
North Carolina Critical Habitat Units
Piping Plover Wintering Critical Habitat

Critical habitat may be viewed at the following web site. An online map is available for
viewing, as well as dowloadable GIS shapefiles and metadata:
https://ecos.fws.gov/ecp/report/table/critical-habitat.html

Unit NC-1 (Oregon Inlet): This unit extends from the southern portion of Bodie Island
through Oregon Inlet to the northern portion of Pea Island. It begins at Ramp 4 near the
Oregon Inlet Fishing Center on Bodie Island and extends approximately 4.7 mi (7.6 km)
south to the intersection of NC Highway 12 and Salt Flats Wildlife Trail (near Mile Marker
30, NC Highway 12), approximately 2.9 mi (4.8 km) from the groin, on Pea Island. The unit
is bounded by the Atlantic Ocean on the east and Pamlico Sound on the west and includes
lands from the MLLW (mean lower low water) on the Atlantic Ocean shoreline to the line of
stable, densely vegetated dune habitat (which is not used by piping plovers and where PCEs
do not occur) and from the MLLW on the Pamlico Sound side to the line of stable, densely
vegetated habitat, or (where a line of stable, densely vegetated dune habitat does not exist)
lands from MLLW on the Atlantic Ocean shoreline to the MLLW on the Pamlico Sound side.
Any emergent sandbars south and west of Oregon Inlet, including Green Island and lands
owned by the State of North Carolina, such as island DR–005–05 and DR–005– 06, are
included (not shown on map). This unit does not include the Oregon Inlet Fishing Center,

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NC Highway 12 and the Bonner Bridge or its associated structures, the terminal groin, or the
historic Pea Island Life-Saving Station, or any of their ancillary facilities (e.g., parking lots,
out buildings).

Unit NC-2 (Cape Hatteras Point): This unit is entirely within Cape Hatteras National
Seashore and encompasses the point of Cape Hatteras (Cape Point). The unit extends south
approximately 4.5 km (2.8 miles) from the ocean groin near the old location of the Cape
Hatteras Lighthouse to the point of Cape Hatteras, and then extends west 7.6 km (4.7 miles)
(straight-line distances) along Hatteras Cove shoreline(South Beach) to the edge of Ramp 49
near the Frisco Campground. The unit includes lands from the MLLW on the Atlantic Ocean
to the line of stable, densely vegetated dune habitat (which is not used by the piping plover

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and where PCEs do not occur). This unit does not include the ocean groin.
Unit NC-3 (Clam Shoals): The entire unit is owned by the State. This unit includes several
island s in Pamlico Sounds known as Bird Islands. This unit includes lands on all islands to
the MLLW.
Unit NC-4 (Hatteras Inlet): This unit extends from the western end of Hatteras Island to the
eastern end of Ocracoke Island. The unit extends approximately 7.6 km (4.7 mi) southwest
from the first beach access point at the edge of Ramp 55 at the end of NC Highway 12 near
the Graveyard of the Atlantic Museum on the western end of Hatteras Island to the edge of
the beach access at the ocean-side parking lot (approximately 0.1 mi south of Ramp 59) on
NC Highway 12, approximately 1.25 km (0.78 mi) southwest (straightline distance) of the
ferry terminal on the northeastern end of Ocracoke Island. The unit includes lands from the
MLLW on the Atlantic Ocean shoreline to the line of stable, densely vegetated dune habitat
(which is not used by the piping plover and where PCEs do not occur) and from the MLLW
on the Pamlico Sound side to the line of stable, densely vegetated habitat, or (where a line of
stable, densely vegetated dune habitat does not exist) lands from MLLW on the Atlantic
Ocean shoreline to the MLLW on the Pamlico Sound side. All emergent sandbars within
Hatteras Inlet between Hatteras Island and Ocracoke Island, including lands owned by the
State of North Carolina such as Island DR–009– 03/04 (not shown on map), are included.
The unit is adjacent to but does not include the Graveyard of the Atlantic Museum, the ferry
terminal, the groin on Ocracoke Island, NC Highway 12, or their ancillary facilities (e.g.,
parking lots, out buildings).
Unit NC-5 (Ocracoke Island): This unit is entirely within Cape Hatteras National Seashore
and includes the western portion of Ocracoke Island beginning at the beach access point at
the edge of Ramp 72 (South Point Road), extending west approximately 3.4 km (2.1 mi) to
Ocracoke Inlet, and then back east on the Pamlico Sound side to a point where stable,
densely-vegetated dune habitat meets the water. This unit includes lands from the MLLW on
the Atlantic Ocean shoreline to the line of stable, densely-vegetated dune habitat (which is
not used by the piping plover and where PCEs do not occur) and from the MLLW on the
Pamlico Sound side to the line of stable, densely vegetated habitat, or (where a line of stable,
densely vegetated dune habitat does not exist) lands from MLLW on the Atlantic Ocean
shoreline to the MLLW on the Pamlico Sound side. All emergent sandbars within Ocracoke
Inlet are also included. This unit does not include any portion of the maintained South Point
Road, NC Highway 12, or any of their ancillary facilities.
Unit NC-6 (Portsmouth Island – Cape Lookout): The entire unit is within Cape Lookout
National Seashore. This unit includes all land to MLLW on Atlantic Ocean to MLLW on
Pamlico Sound, from Ocracoke Inlet extending west to the western end of the Pilontary
Islands. This unit includes the islands of Casey, Sheep, Evergreen, Portsmouth, Whalebone,
Kathryne Jane, and Merkle Hammock. This unit also extends west from the eastern side of
Old Drum Inlet to 1.6 km (1.0 mi) west of the New Drum Inlet and includes all lands from
MLLW on Atlantic Ocean to MLLW on Core Sound.

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Unit NC-7 (South Core Banks): The entire unit is within Cape Lookout National Seashore.
This unit extends south from Cape Lookout Lighthouse, along Cape Lookout, to Cape Point
and northwest to the northwestern peninsula. All lands from MLLW on the Atlantic Ocean,
Onslow Bay, and Lookout Bight up to where densely vegetated habitat, not used by the
piping plover, begins and the constituent elements no longer occur are included.
Unit NC-8 (Shackleford Banks): The entire unit is within Cape Lookout National
Seashore. This unit is in two parts: (1) The eastern end of Shackleford Banks from MLLW of

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Barden Inlet extending west 2.4 km (1.5 mi), including Diamond City Hills, Great Marsh
Island, and Blinds Hammock; and, (2) The western end of Shackleford Banks from MLLW
extending east 3.2 km (2.0 mi) from Beaufort Inlet. The unit includes all land from MLLW to
where densely vegetated habitat, not used by the piping plover, begins and where the
constituent elements no longer occur and any emergent sandbars within Beaufort Inlet. This
unit is bordered by Onslow Bay, Shackleford Slue, and Back Sound.
Unit NC–9 (Rachel Carson): The entire unit is within the Rachel Carson National Estuarine
Research Reserve. This unit includes islands south of Beaufort including Horse Island, Carrot
Island, and Lennox Point. This unit includes entire islands to MLLW.
Unit NC–10 (Bogue Inlet): The majority of the unit is privately owned, with the remainder
falling within Hammocks Beach State Park. This unit includes contiguous land south, west,
and north of Bogue Court to MLLW line of Bogue Inlet on the western end of Bogue Banks.
It includes the sandy shoals north and adjacent to Bogue Banks and the land on Atlantic
Ocean side to MLLW. This unit also extends 1.3 km (0.8 mi) west from MLLW of Bogue
Inlet on the eastern portion of Bear Island.

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Unit NC–11 (Topsail): The entire area is privately owned. This unit extends southwest from
1.0 km (0.65 mi) northeast of MLLW of New Topsail Inlet on Topsail Island to 0.53 km
(0.33 mi) southwest of MLLW of Rich Inlet on Figure Eight Island. It includes both Rich
Inlet and New Topsail Inlet and the former Old Topsail Inlet. All land, including emergent
sandbars, from MLLW on Atlantic Ocean and sound side to where densely vegetated habitat,

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not used by the piping plover, begins and where the constituent elements no longer occur. In
Topsail Sound, the unit stops as the entrance to tidal creeks become narrow and channelized.
Unit NC–12 (Figure Eight Island): The majority of the unit is privately owned. This unit
extends south from the western end of Beach Road on Figure Eight Island to the northern end
of Highway 74 on Wrightsville Beach. The unit includes Mason Inlet and the sand and
mudflats northwest of the inlet from MLLW on Atlantic Ocean to where densely vegetated
habitat, not used by the piping plover, begins and where the constituent elements no longer
occur.
Unit NC–13 (Masonboro): The entire unit is within the North Carolina National Estuarine
Research Reserve. This unit extends 1.1 km (0.70 mi) south from the MLLW of Masonboro
Inlet on Masonboro Island. This unit includes all lands along the Atlantic Ocean, Masonboro
Inlet, and Masonboro Sound from MLLW to where densely vegetated habitat, not used by
the piping plover, begins and where the constituent elements no longer occur.
Unit NC–14 (Carolina Beach Inlet): The majority of the unit is within Myrtle Grove Sound
on Masonboro Island and is owned by the North Carolina National Estuarine Research
Reserve. It extends 1.80 km (1.12 mi) west along the south shoreline of Wolf Island from the
mouth of the Altamaja sound. This unit extends south from 3.2 km (2.0 mi) north of MLLW
at Carolina Beach Inlet on Masonboro Island to 1.1 km (0.70 mi) south of MLLW at Carolina
Beach Inlet on Carolina Beach. It includes land from MLLW on Atlantic Ocean across and
including lands to MLLW on the western side of Masonboro Island, excluding existing
dredge spoil piles. Emergent sand bars within Carolina Beach Inlet are also included.
Unit NC–15 (Ft. Fisher): This unit is within Ft. Fisher State Recreation Area and Zeke’s
Island Estuarine Reserve. This unit extends south from Ft. Fisher Islands (from the rocks),
south of the ferry terminal, to approximately 0.8 km (0.5 mi) south of MLLW at Corn Cake
Inlet on Smith Island. It includes all land (including Zeke’s Island) from MLLW on Atlantic
Ocean across to MLLW on the eastern side of the Cape Fear River.

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Unit NC–16 (Lockwood Folly Inlet): The entire unit is on Oak Island (formerly known as
the Town of Long Beach) and is privately owned. This unit extends from the end of West
Beach Drive, west to MLLW at Lockwood Folly Inlet, including emergent sandbars south
and adjacent to the island. This unit includes land from MLLW on Atlantic Ocean across to

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MLLW adjacent to the Eastern Channel and the Intracoastal Waterway.
Unit NC–17 (Shallotte Inlet): The entire unit is privately owned. This unit begins just west
of Skimmer Court on the western end of Holden Beach. It includes land south of SR 1116, to
where densely vegetated habitat, not used by the piping plover, begins and where the
constituent elements no longer occur to the MLLW along the Atlantic Ocean. It includes the
contiguous shoreline from MLLW to where densely vegetated habitat, not used by the piping
plover, begins and where the constituent elements no longer occur along the Atlantic Ocean,
Shallotte Inlet, and Intracoastal Waterway stopping north of Skimmer Court Road. The
unnamed island and emergent sandbars to MLLW within Shallotte Inlet are also included.
Unit NC–18 (Mad Inlet): The entire unit is privately owned. This unit extends west 1.2 km
(0.75 mi) from the end of Main Street (SR 1177) on western Sunset Beach to the eastern
portion of Bird Island and includes the marsh areas north of western Sunset Beach shoreline.
The shoreline area begins at MLLW on the Atlantic Ocean and continues landward to where
densely vegetated habitat, not used by the piping plover, begins and where the constituent
elements no longer occur.

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APPENDIX C
North Carolina Critical Habitat Units
NWA DPS of the Loggerhead Sea Turtle

Critical habitat may be viewed at the following web site. An online map is available for
viewing, as well as dowloadable GIS shapefiles and metadata:
https://ecos.fws.gov/ecp/report/table/critical-habitat.html

293

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Unit LOGG-T-NC-01 (Bogue Banks): This unit consists of 38.9 km (24.2 mi) of island
shoreline along the Atlantic Ocean. The island is separated from the mainland by the Atlantic
Intracoastal Waterway and Bogue Sound. The unit extends from Beaufort Inlet to Bogue
Inlet. The unit includes lands from the MHW line landward to the toe of the secondary dune
or developed structures. Land in this unit is in State and private ownership. The State portion
is Fort Macon State Park, which is managed by the North Carolina Division of Parks and
Recreation. This unit supports expansion of nesting from an adjacent unit (LOGG–T–NC–
02) that has high-density nesting by loggerhead sea turtles in North Carolina.
Unit LOGG-T-NC-02 (Bear Island): This unit consists of 6.6 km (4.1 mi) of island
shoreline along the Atlantic Ocean. The island is separated from the mainland by the Atlantic
Intracoastal Waterway and salt marsh. The unit extends from Bogue Inlet to Bear Inlet. The
unit includes lands from the MHW line landward to the toe of the secondary dune or
developed structures. Land in this unit is in State ownership. The island is managed by the
North Carolina Division of Parks and Recreation as Hammocks Beach State Park. This unit
has high-density nesting by loggerhead sea turtles in North Carolina.
Unit LOGG-T-NC-03 (Topsail Island): This unit consists of 35.0 km (21.8 mi) of island
shoreline along the Atlantic Ocean. The island is separated from the mainland by the Atlantic
Intracoastal Waterway, Chadwick Bay, Alligator Bay, Goose Bay, Rogers Bay, Everett Bay,
Spicer Bay, Waters Bay, Stump Sound, Banks Channel, and salt marsh. The unit extends
from New River Inlet to New Topsail Inlet. The unit includes lands from the MHW line to
the toe of the secondary dune or developed structures. Land in this unit is in private and
other ownership. The local municipality portion is the North Topsail Beach Park, which is
managed by t he Town of North Topsail Beach. This unit has high-density nesting by
loggerhead sea turtles in North Carolina.
Unit LOGG-T-NC-04 (Lea-Hutaff Island): This unit consists of 6.1 km (3.8 mi) of island
shoreline along the Atlantic Ocean. Following the closure of Old Topsail Inlet in 1998, two
islands, Lea Island and Hutaff Island, joined to form what is now a single island referred to
as Lea-Hutaff Island. The island is separated from the mainland by the Atlantic Intracoastal
Waterway, Topsail Sound, Eddy Sound, Long Point Channel, Green Channel, and salt marsh.
The unit extends from New Topsail Inlet to Rich Inlet. The unit includes lands from the
MHW line to the toe of the secondary dune or developed structures. Land in this unit is in
State and private ownership. The State portion is part of the Lea Island State Natural Area,
which includes most of the original Lea Island, and is owned by the North Carolina Division
of Parks and Recreation and managed by Audubon North Carolina. The remainder of the
original Lea Island is privately owned. The original Hutaff Island is entirely privately owned.
This unit supports expansion of nesting from an adjacent unit (LOGG–T–NC–03) that has
high-density nesting by loggerhead sea turtles in North Carolina.
Unit LOGG-T-NC-05: (Pleasure Island): This unit consists of 18.6 km (11.5 mi) of island
shoreline along the Atlantic Ocean. The island is separated from the mainland by the Atlantic
Intracoastal Waterway, Cape Fear River, Upper Midnight Channel Range, Lower Midnight
Channel Range, Reaves Point Channel Range, Horseshoe Shoal Channel Range, Snow Marsh
Channel Range, and The Basin (bay). The unit extends from Carolina Beach Inlet to

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33.91433 N, 77.94408 W (historic location of Corncake Inlet). The unit includes lands from
the MHW line to the toe of the secondary dune or developed structures. Land in this unit is in
State, private, and other ownership. The State portion is Fort Fisher State Recreation Area,
which is managed by the North Carolina Division of Parks and Recreation. The local
municipality portion includes half of Freeman Park Recreation Area, which is managed by
the Town of Carolina Beach. The County portion includes the other half of Freeman Park
Recreation Area, which is also managed by the Town of Carolina Beach under an interlocal
agreement with New Hanover County. This unit supports expansion of nesting from an
adjacent unit (LOGG–T–NC–06) that has high-density nesting by loggerhead sea turtles in
North Carolina.
Unit LOGG-T-NC-06 (Bald Head Island): This unit consists of 15.1 km (9.4 mi) of island
shoreline along the Atlantic Ocean. The island is part of the Smith Island Complex, which is
a barrier spit that includes Bald Head, Middle, and Bluff Islands. The island is separated
from the mainland by the Atlantic Intracoastal Waterway, Cape Fear River, Battery Island
Channel, Lower Swash Channel Range, Buzzard Bay, Smith Island Range, Southport
Channel, and salt marsh. The unit extends from 33.91433N, 77.94408W (historic location of
Corncake Inlet) to the mouth of the Cape Fear River. The unit includes lands from the MHW
line to the toe of the secondary dune or developed structures. Land in this unit is in State and
private and other ownership. The State portion is Bald Head State Natural Area. This unit has
high-density nesting by loggerhead sea turtles in North Carolina.
Unit LOGG-T-NC-07 (Oak Island): This unit consists of 20.9 km (13.0 mi) of island
shoreline along the Atlantic Ocean. The island is separated from the mainland by the Atlantic
Intracoastal Waterway, Cape Fear River, Eastern Channel, and salt marsh. The unit extends
from the mouth of the Cape Fear River to Lockwoods Folly Inlet. The unit includes lands
from the MHW line to the toe of the secondary dune or developed structures. Land in this
unit is in private and other ownership. This unit has high-density nesting by loggerhead sea
turtles in North Carolina..
Unit LOGG-T-NC-08 (Holden Beach): This unit consists of 13.4 km (8.3 mi) of island
shoreline along the Atlantic Ocean. The island is separated from the mainland by the Atlantic
Intracoastal Waterway, Elizabeth River, Montgomery Slough, Boone Channel, and salt
marsh. The unit extends from Lockwoods Folly Inlet to Shallotte Inlet. The unit includes
lands from the MHW line to the toe of the secondary dune or developed structures. Land in
this unit is in private and other ownership. This unit supports expansion of nesting from an
adjacent unit (LOGG–T–NC–07) that has high-density nesting by loggerhead sea turtles in
North Carolina.

APPENDIX D: USFWS Raleigh North Carolina Field Office Piping Plover
and Red Knot Survey Minimum Survey Requirements To Document Site
Abundance and Distribution

Required skills, training, and equipment for conducting surveys

1. Piping plover monitors must be capable of detecting and recording locations of
roosting and foraging plovers, accurately reading and recording bands, and
documenting observations in legible, complete field notes. Aptitude for monitoring
includes keen powers of observation, familiarity with avian biology and behavior,
experience observing birds or other wildlife for sustained periods, tolerance for
adverse weather, experience in data collection and management, and patience.
Monitors must also be able to captain a boat (if applicable) and walk long distances
carrying field gear.
2. Binoculars, a GPS unit (set to record in decimal degrees in the WGS datum), a 10-
60x spotting scope with a tripod, boat access (if applicable), and the RFO’s datasheet
must be used to conduct the surveys.

Piping plover survey methodology

3. Nonbreeding piping plover abundance and distribution must be determined through 6
surveys per season (2 during fall migration scheduled ≤3 days apart, 2 during winter
scheduled ≤3 days apart, and 2 during spring migration scheduled ≤3 days apart).
Suitable habitat must be surveyed by walking the survey area (weather and tide
permitting, no surveys should be conducted if sustained winds exceed 20 mph) during
the survey window (July 15 – May 15).

4. Surveys should be scheduled around the peak of migration (September in Fall and
March in Spring) based on input from the RFO. Winter surveys must be conducted
between December 1 and January 31. Surveys should be conducted around mid-tide
when birds will still be foraging, making legs easier to see for re-sighting bands, but
more concentrated.

5. All unbanded and banded piping plovers must be recorded on the RFO datasheet.
Weather data must be collected at the beginning of each survey. The
presence/absence of bands, GPS coordinate, plumage, behavior, and habitat type must
be recorded for each piping plover.

6. Band resightings must be read and documented during each survey.

7. GPS coordinates must be collected in decimal degrees during each survey for each
bird as close to the location of the bird as possible without causing a change in
behavior (if the bird is spending most of its time watching the monitor instead of
continuing the behavior it was exhibiting when it was first spotted).

8. Recreation and disturbance must be documented during the surveys. The number of
people, dogs (on and off leash), bicycles, vehicles, etc. must be recorded during the

297
surveys. Additionally, any activity causing a disturbance (change in behavior,
particularly if the disturbance flushes the birds) to roosting or foraging birds must be
noted on the datasheet.

9. Survey data must be recorded in the field on the RFO datasheet and transcribed into
the Microsoft Access database (provided by the RFO). Electronic hard copies of the
datasheets and the database must be provided annually by June 15 to the RFO.

Red Knot

10. Red knots must be recorded during the piping plover surveys when both species are
present. Additional surveys for red knots during their peak season must follow the
same protocol outlined above. Band combinations, flag color and alphanumeric
codes, and geolocators must be noted on the datasheet if applicable. All resightings
must be reported on www.bandedbirds.org.

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How To Resight and Report Banded Piping Plovers

Be careful not to disturb the bird. A slow, quiet approach avoids harassment and allows the
observer to carefully scan the band combination. Using a spotting scope facilitates accurate
observations from a distance.

Please record:
1. Location where the bird was seen (GPS coordinates are helpful).
2. Date when the bird was seen.
3. Any observations of the bird’s behavior (e.g., roosting, foraging).
4. Band combination:
a. Band combinations should be recorded in the following sequence: upper left (UL;
above the “knee”), lower left (LL; below the “knee”), upper right (UR), lower
right (LR). “Right” and “left” are from the bird’s perspective, not the observer’s
(just like a person’s right and left legs).
b. Band types include flags (band with tab sticking out), metal, and color bands.
c. Some bands may have alpha-numeric codes printed on the band or the flag (e.g.,
A1). The code, in addition to the color and location of the band or flag should be
documented. Both the color of the band and the code (e.g., white writing on a
green band) should be noted.
d. Some bands are split (a single band with two colors; e.g., orange/blue) or triple
split (a single band with three colors; e.g., blue/orange/blue).
e. Sometimes two bands of the same color are placed over each other, appearing like
one very tall band.
f. Some piping plovers are banded on the upper legs only, and bands can be stacked
(one above the other) on the upper leg.
g. Record leg positions where bands are absent.
h. Note if the color or type of any of the bands is uncertain or if some parts of a leg
were not seen clearly.
i. Recognize that band colors can fade over time.

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Left Figure: This band combination below would be recorded as: metal (UL), dark blue
(LL), black flag (UR), red over black (LR). The abbreviated band combination (refer to
http://www.fws.gov/charleston/pdf/PIPL/20141205_usfws_pipl_survey_datasheet.pdf)
would be recorded as: X,B:Lf,RL.
Middle Figure: Examples of alpha-numeric gray, black, and white flags.
Right Figure: Example in yellow circle shows use of an alpha-numeric code on a color
band.

For banded piping plovers seen in North Carolina, please send this information along with
the observer’s contact information to [e-mail]. For more information about
band resighting, please consult
http://www.fws.gov/charleston/pdf/PIPL_Band_Identification_Training.pdf

Datasheet Habitat Descriptor Definitions
Back beach – dry sand, beach landward of the mean high water (MHW) line and seaward of
the dune line.
Dune – A mound, hill, or ridge of wind-blown sand, either bare or covered with vegetation
located landward of the back beach.
Ephemeral pool – a temporary water feature located on the beach.
Mudflat – intertidal area typically located behind sand spits adjacent to inlets. They appear
darker in color than sand, and are soft and slick to walk on. The closest vegetation is
typically Spartina sp.
Intertidal beach – wet, smooth sand; beach seaward of the MHW line and landward of the
mean low water (MLW) line.
Sandflat – flat, rippled intertidal area along sound shorelines or around the mouth of an inlet.
They are firm to walk on.
Dense vegetation – vegetation located on the back beach or dunes that provides >75% cover.
Washover – beach sand that has been transported landward of the beach/dune system by
storm waves, areas where sand and shells become the top layer of once vegetated areas
following a storm event.
Wrack – organic plant material deposited between the MHW line and the spring high tide
line.

Photo: Kelsi Hunt
Photo: Kelsi Hun
UL UR

LL LR
Photo: Kelsi Hunt

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Nonbreeding PIPL/REKN Survey Data Sheet Page___of___

Date:________Location: __________________________________Observer(s): _______________________________________

Survey #:_____Survey Coverage: (circle one): ALL NE SW Survey Type: (circle one): Population Foraging Roosting S/R

Start Time:______ End Time:______ General weather (circle one): Sunny Partly cloudy Cloudy Rain Fog Other (describe)

Temp:____°F Wind Direction (circle one): N NE E SE S SW W NW Wind Speed (circle one): 0-5 6-10 11-15 16-20 >21 MPH

Tidal stage at start of survey (circle one): Low Mid High (Rising/Falling)

Disturbance (#): Pedestrian(s)______Boat(s)_____Bicycle(s)_____ATV(s)_____ORV(s)_____Dog(s) On______Dog(s) Off______

PI
P
L
/
R
E
K
N
#
UL
U

UL
L

LL
U

LL
L

UR
U

UR
L

LR
U

LR
L

Flag
or
band
Cod
e

Latitude

Longitude Pl
u
m
a
g
e

Be
h
a
v
i
o
r

Ha
b
i
t
a
t

Notes

Abbreviation Key
Band Color Plumage Behavior Habitat
A
B
b
f
G
g
L
N
O
P
R
U
W
X
Y
-
/
//

Gray
Dark blue
Light blue
Flag
Dark green
Light green
Black
No band seen (leg position not visible)
Orange
Pink
Red
Purple
White
Metal
Yellow
No band (no band on that leg position)
Split band (color/color on one band)
Triple split band (color/color/color on one band)

B
A
P
Basic (nonbreeding)
Alternate (breeding)
Partial (some breeding)
D
FR
R
L
T
O
Disturbed
Foraging
Roosting
Loafing
Territorial
Other
M
S
B
D
WR
IT
WA
VS
VT
EP
O
Mudflats
Sandflats
Beach
Dunes
Wrack
Ocean intertidal
Washover
Vegetation sparse (<75%)
Vegetation thick (>75%)
Ephemeral pool
Other