Bodie Island Lighthouse Pond Mitigation Site

•
CA A117- a3DC -Pe rk-r1 71
Ufa o. s 4J o l y s v ?/ Y/
Put in letter, not permit.
NOTE: Compensatory wetland mitigation for permanent impacts to Coastal Wetlands on
this project is not specifically required by DCM due to the relatively low amount
of permanent impacts to Coastal Wetlands. Therefore, the use of Phragmites
control as a compensatory wetland mitigation technique should not be interpreted
as an acceptable form of compensatory wetland mitigation when mitigation for
Coastal Wetland impacts is required by DCM in the future.
NOTE: DCM does not typically accept wetlands containing Phragmites as suitable
compensatory wetland mitigation for impacts to Coastal Wetlands.
NOTE: The mitigation plan includes restoration of approximately 50 acres of tidal marsh
habitat through exotic plant control measures for Phragmites. It also includes
restoration of approximately 1.28 acres of SAV areas and un-shading of 1.38
acres of SAV areas.
Gl //✓) ( /

2022 NCDOT MITIGATION MONITORING REPORT REVIEW MEETING
DIVISIONS 1-8
Meeting Minutes
February 22,2023
1:00pm -3pm
DOT CCA Technical Services Conf. Room Col. C11 (CAP 30)and Online (GoTo Meeting)
Opening Remarks
Dave Johnson -NCDOT
• Meeting being recorded for those not in attendance.
• 2022 Stewardship Reports posted online.
General Remarks
• Site visits will include invitations for permitting and commenting agencies regardless
of which agency requested visit. Like the meeting invite, DOT will also include
previous agency reps if there has been re-organization for a given area of
responsibility.
Monitoring Reports:
Division 1
B-2500 Bodie Island Lighthouse Pond (Dare) -Year 4
• Wes Cartner presented work completed at site for 2022.
• Phragmites spraying-58 acres sprayed.
• Hand spraying as well near boardwalk.
o 1.12 ac. Just Round-up sprayed this year due to timing of
application.
• Exploring mechanisms to implement controlled burn with assistance from
National Park Service.
• Continue spraying and monitoring in 2023.
B-2500 Basnight Bridge Temp. Impact Report (Dare)—Year 1 of 3
• Per Paul Williams-NCDOT monitoring area closely.
• Sites 4& 5 significant erosion on sound-side. May get worse over time.
• Site 6 is revegetating where the existing piles were cut at ground level.
• Continue monitoring.

ANNUAL REPORT FOR 2022
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Bodie Island Lighthouse Pond Mitigation Site
Dare County
COE Action ID: SAW-1993-03077
CAMA #: 106-12
401 Certification #: 20120629
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Prepared By:
Environmental Analysis Unit
North Carolina Department of Transportation
December 2022

TABLE OF CONTENTS
SUMMARY 1
1.0 Introduction 2
.1 Project Description 2
.2 Purpose 2
.3 Project History 2
.4 Debit Ledger 2
2.0 Vegetation: 3
.1 Success Criteria 3
.2 Vegetation Treatment 3
.3 Vegetation Modeling 3
.4 Vegetation Monitoring 4
.5 Conclusions. 4
3.0 Recommendations 5
FIGURES
Figure 1 — Vicinity Map 6
Figure 2 — Treatment Area Map 2022 7
Figure 3 — Change Detection Results: 2019 to 2022 8
APPENDICES
Appendix A— Site Photo Points 2022
Appendix B — Pesticide Record Forms 2022

SUMMARY
The Bodie Island Lighthouse Pond Mitigation Site (Site) is located in Dare County, North
Carolina. Wetland mitigation consists of rehabilitating former Spartina-dominated marsh
habitat through exotic plant control measures for Phragmites australis in accordance with the
approved Final Wetland Mitigation Plan NC 12 Replacement of Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet(dated January 30, 2013, hereafter referred to as Mitigation
Plan). Herbicide hand treatment began in May 2018 in areas adjacent to the Bodie Island
Lighthouse Boardwalk. Aerial herbicide applications (via Unmanned Aerial Systems (UAS))
began on October 2018 following final mitigation approval by the National Park Service
(NPS). Approximately 2.5 acres of wetland mitigation will be debited from the Site for
unavoidable wetland impacts associated with the Replacement of the NC 12 Herbert C.
Bonner Bridge (Bridge No. 11) over Oregon Inlet.
Based on 2011 aerial photography, the North Carolina Department of Transportation
(NCDOT) proposed wetland mitigation that encompassed approximately 50 acres of wetland
restoration through the rehabilitation of marsh habitat. Phragmites mapping and modeling
efforts conducted in May 2019 estimated approximately 53.4 acres of Phragmites-affected
marsh were located within the Site. Additional mapping and modeling was conducted in
August 2022. Results from the 2022 modeling efforts indicate that there are a total of 19.4
acres of live Phragmites present within the Site. Areas that appeared to contain Phragmites
were sprayed using the UAS between September 19 and 21 of 2022. This area totaled
approximately 58.94 acres. Treated acreage was larger than the modeled acreage of
Phragmites because the scattered nature of the distribution on-site made it difficult to isolate.
Hand spraying was also conducted in areas surrounding the boardwalk and lighthouse, and
along the wood line surrounding the marsh. In total, approximately 1.12 acres were treated
by hand spraying. Burning was not conducted in 2022.
Restoration success criteria include: 1) a decrease in total aerial coverage of dense
Phragmites stands from the current densities after first-year treatment; 2) a decreasing trend
in aerial coverage of mapped Phragmites each treatment year; and 3) total aerial coverage
of dense Phragmites stands of 10 acres or less with stems less than three feet tall at the end
of the final monitoring year. Hydrologic monitoring is not required for this project. Based on
the 2020 Monitoring Report, the total aerial coverage of dense Phragmites stands decreased
within treated areas after first-year treatment. In addition, aerial coverage of Phragmites
decreased by approximately 34 acres from 2019 to 2022, based on aerial mapping and
modeling. Modeling results also showed that the distribution is patchy, with Phragmites
occurring at low densities throughout the survey area. Eleven vegetation monitoring plots
were visually assessed to determine percent coverage of Phragmites. Results from
vegetation plot analysis confirmed model results, with an average percent cover of
Phragmites of approximately 35 percent.
NCDOT proposes to continue hand and aerial herbicide applications to Phragmites affected
marsh areas in 2023 and perform vegetation monitoring via aerial photography and
Phragmites modeling. NCDOT will also visually monitor the Site to ensure that new
Phragmites is not intruding into unmapped areas. NCDOT is coordinating with NPS to
schedule a prescribed burn in the coming years. Manual trimming of dead Phragmites stems
may be conducted along the woodline to facilitate hand spraying in 2023.
1

1.0 INTRODUCTION
1.1 Project Description
The Site is located adjacent to the Bodie Island Lighthouse six miles south of Nags Head, NC
and three miles north of Oregon Inlet (Figure 1). The Site consists of approximately 60 acres
of wetland restoration through the rehabilitation of marsh habitat. Proposed debits to the Site
include 2.5 acres of wetland mitigation for wetland impacts associated with construction of
the Replacement of the NC 12 Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet.
Wetland mitigation measures include reducing and controlling percent aerial coverage of the
exotic plant Phragmites australis using approved herbicides and prescribed burning, while
allowing natural reestablishment of native marsh plant species.
1.2 Purpose
In order for the Site to be considered successful it must meet success criteria established in
the Final Wetland Mitigation Plan, NC 12 Replacement of the NC 12 Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet dated January 30, 2013 (hereafter referred to as Mitigation
Plan). This report details mitigation activities at the Site in 2022, as recommended through
the adaptive management guidelines approved in the Mitigation Plan. Hydrologic monitoring
is not required for the Site.
1.3 Project History
May 2018 Begin Hand Herbicide Application in Selected Areas
October 2018 NPS Issues Special Use Permit for UAS Application
October 2018 Begin Herbicide Application Season 2018
November 2018 End Herbicide Application Season 2018
June 2019 Begin Herbicide Application Season 2019
November 2019 End Herbicide Application Season 2019
January 2020 USDOI Grounds all UAS Flights over all DOI Property
October 2020 Hand Herbicide Application in Selected Areas
Oct-Nov 2021 UAS Herbicide Application over 59.37 Acres
August 2022 DOT Collected Aerial Imagery for Modeling Purposes
September 2022 UAS Herbicide Application over 58.94 acres
September 2022 Hand Herbicide Application over 1.12 acres
1.4 Debit Ledger
A total of 2.5 wetland acres of the Site will be debited for unavoidable wetland impacts
associated with the NC 12 Replacement of the Herbert C. Bonner Bridge (Bridge No. 11)over
Oregon Inlet. Remaining site assets must have regulatory agency approval prior to use as
mitigation on other projects.
2

2.0 VEGETATION
2.1 Success Criteria
NCDOT shall monitor wetland mitigation by photographs and determinations of aerial percent
vegetation cover of Phragmites stands. Vegetation success criteria are:
• Total aerial coverage of dense Phragmites stand will decrease from mapped acreage
after the first-year treatment.
• The trend of decreased aerial coverage of mapped Phragmites will continue each
treatment year.
• Total aerial coverage of dense Phragmites stands will be 10 acres or less with stems
less than three feet tall at the end of the final monitoring year.
The Site will be monitored until success criteria are met with a brief annual progress report
being submitted to the United States Army Corps of Engineers (USACOE), North Carolina
Division of Water Resources (NCDWR), and North Carolina Division of Coastal Management
(NCDCM). Upon meeting success criteria, NCDOT will schedule an agency field meeting to
determine if the restored areas have achieved mitigation requirements.
2.2 Vegetation Treatment
Approved Phragmites control treatments for the Site include Glyphosate and Imazapyr
herbicide application, and prescribed burning. A total of 58.94 acres of the Project Area
(Figure 2) was treated with UAS aerial herbicide applications in September 2022. An
additional 1.12 acres were treated in September 2022 by hand spraying around the boardwalk
and wood line surrounding the marsh. Treatments included only Glyphosate (Roundup
Custom®) herbicide in 2022 to avoid exceeding the maximum allowable annual application
rate for Imazapyr. Aerial herbicide treatment consisted of Roundup Custom®/Methylated
Seed Oil (MSO) (64oz/1% per acre). Hand spraying treatment consisted of Roundup Custom®
(1.19 gal per acre) and a dye/foaming agent. The treatment area consisted of Phragmites
affected marsh surrounding the Bodie Island Lighthouse Pond as depicted in Figure 2.
Prescribed burning was not conducted in 2022; however, DOT is currently coordinating with
NPS to schedule a prescribed burn in the coming years. In addition, DOT may manually trim
dead Phragmites stems along the woodline to facilitate hand spraying in 2023.
2.3 Vegetation Modeling
Vegetation modeling was conducted by DOT in August and September 2022.Visual spectrum
imagery (RGB) was collected on August 8 with a Sony xr1 and multispectral imagery (MSI)
was collected on August 18 with a MicaSense RedEdge-MX, both onboard a WingtraOne
GEN II. All imagery was post-processed in Pix4Dmapper v4.7.5 by Geo Owl. Results indicate
that there are a total of approximately 19.4 acres of live Phragmites present at the Site,
representing a reduction of approximately 34 acres of Phragmites affected marsh between
2019 and 2022. Approximately 3.5 acres from the 2019 DOT delineation which were not
captured within the RGB survey and could not be included in the analysis, thus results may
over- or underestimate the presence of Phragmites or reduction due to herbicide application.
The current distribution of Phragmites is extremely patchy and occurs mostly at low densities
throughout the Site. However, the model also showed new Phragmites growth within the Site.
3

Some of the new growth (indicated by "Change to Phragmites" on Figure 3) could be due to
misclassification of pixels around the edges of shrubs; however, other areas warrant further
investigation to determine if new growth is actually occurring. Figure 3 depicts vegetation
changes within the Site from 2019 to 2022. Continued vegetation modeling of treated areas
are anticipated for the 2023 season.
2.4 Vegetation Monitoring Results
Eleven vegetation monitoring plots were collected via UAS in 2022 for purposes of quantifying
percent coverage of Phragmites across the Site. Figure 2 depicts the location of each
monitoring plot and photographs of each plot are presented in Appendix A. Vegetation
monitoring results for 2022 showed approximately 35 percent average aerial coverage of
Phragmites across the Site. Individual monitoring plot results are presented in Table 1.
Table 1. 2022 Visual Vegetation Monitoring Plots
Vegetation °"o
Plot ID Phragmites
Coverage
1 5
2 10
3 70
4 60
5 40
6 50
7 25
8 10
9 30
10 60
11 20
Average 35
2.5 Conclusions
Phragmites coverage at the Site decreased by approximately 34 acres between 2019 and
2022. Areas that appeared to contain Phragmities were sprayed using the UAS between
September 19 to 21 of 2022. This area totaled approximately 58.94 acres. The area sprayed
is larger than the area currently covered by Phragmites because the patchy, low-density
distribution made it difficult to isolate Phragmites affected marsh from native marsh
vegetation.
Hand spraying was conducted in areas surrounding the boardwalk and around the wood line
adjacent to the marsh. In total, approximately 1.12 acres were treated by hand spraying.
Burning was not conducted in 2022. The quantified results of 2019-2021 herbicide
applications were assessed in August and September 2022 via aerial imagery and
4

Phragmites modeling. Modeling results showed a total of approximately 19.4 acres of
Phragmites, occurring mostly at low densities, throughout the Site. Vegetation monitoring
plots showed approximately 35 percent average aerial coverage of Phragmites across the
Site. At this time, Phragmites regrowth will continue to be evaluated and any adjustments to
herbicide application rates will be made in accordance with the pesticide label.
As in previous years, continued successes at the Site will include: 1) Precise application of
herbicide to Phragmites dominated areas with no unintended adverse impacts to the park
vegetation or wildlife, and 2) Minimal disturbances to Bodie Island Lighthouse Park operations
and visitors. Evaluation of the approved herbicides and herbicide delivery methods used at
the Site have demonstrated that herbicide applications continue to remain viable and effective
methods for delivering pesticide application in environmentally sensitive areas.
3.0 RECOMMENDATIONS
In 2023, NCDOT anticipates continued herbicide applications to Phragmites affected marsh
areas located within the Site. Total acres to be treated in 2023 are contingent on NPS
approvals, site weather conditions, 2023 vegetation monitoring, and Phragmites modeling
results. In Spring 2023, NCDOT plans continued aerial mapping of the existing Phragmites
boundary to determine the extent of the 2023 spray area. NCDOT will also coordinate with
NPS in an effort to obtain a burn permit for the Site. If successful, burning would likely occur
during the winter following the 2023 spraying season. NCDOT plans to hand clear
approximately three acres of phragmites affected areas along the woodline in February of
2023 to eliminate dead standing stems of phragmites and enable hand spraying in June 2023.
5

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^f� Road Data;Natural Earth Data;U.S.Department of State Humanitarian'Information Unit;and NOAA National Centers for Environmental Information,U.S.Coastal
Relief Model.Data refreshed June,2022.
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does not meet NC 47-30 Requirements and therefore is not t
for design,construction,or recording or transfer of ittle.The GRAPHIC SCALE FIGURE 1 t
Exhibit was compiled from available information obtained �••�• Bodie Island Lighthouse Pond Mitigation Site
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from the sources listed below. Vicinity Map \'4 � �
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`Treated acreage excludes a 5-10 ft buffer that was applied
around perimeter of Treatment Area to avoid woody vegetation.
This Exhibit is for planning purposes only and shown herein �onnr
does not meet NC 47-30 Requirements and therefore is not GRAPHIC SCALE FIGURE 2 t
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Exhibit was compiled from available information obtained g Bodie Island Lighthouse Pond Mitigation Site
from the sources listed below. 21
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This Exhibit is for planning purposes only and shown herein aop*�
does not meet NC 47-30 Requirements and therefore is not
for design,construction,or recording or transfer of ittle.The a GRAPHIC SCALE FIGURE 3 a`� `,
Exhibit was compiled from available information obtained i Bodie Island Lighthouse Pond Mitigation Site •
from the sources listed below.
0 375 750 1,500 Change Detection Results: 2019 to 2022
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APPENDIX A
SITE PHOTO POINTS 2022

Bodie Island Lighthouse Pond Mitigation Site
September 2022
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Hand sprayed area adjacent to the lighthouse.

Aid,.(�-0Th.11i- - c1-)-1 / on t Coln Q-ey
2021 NCDOT MITIGATION MONITORING REPORT REVIEW MEETING MINUTES
DIVISIONS 1-8
Agenda
March 9, 2022
10:00 am- 12pm
DOT CCA Technical Services Conf. Room Col. C11 (CAP 30) and Online (Go To Meeting)
Opening Remarks
Dave Johnson - NCDOT
349 Stewardship sites on DOT site. Sites posted online, if any questions, contact DOT.
Monitoring Reports:
Division 1
B-2500 Bodie Island Lighthouse Pond (Dare) -Year 3
/ \ • Mitigation Modeling Group-update-Phragmites was treated in 2021.
Coverage remains similar to 2020. Approx. 60 ac treated in 2021,
phragmites regrowth will be reevaluated in spring 2022.
• Coordinating w USFWS, regarding possible controlled burn on the
Phragmites.
• ACOE-any idea if hand spraying working from original treatment? Hand
spraying boundary only in areas that drone could not get close to. Yes,
appears to be working according to DOT.
• DOT will continue spraying effort in 2022.
B-2500A-AB New Inlet Br. Temp Impact Report (Dare) - Year 2
• DCM asked include site 15 jetting site in report. Also include hand
clearing impacts. Report was revised by DOT and was posted to EAU
Website on 3/21/2022.
• Also add hand clearing areas next to temporary fill areas on project.
• Remaining sites to be graded and planted by May 2022.
• DOT Continue monitoring in 2022.
B-4916 Bridge 57 over Quicoccosin Swamp Temp. Impacts—Year 1 (Bertie)
• DOT Continue monitoring in 2022.

ANNUAL REPORT FOR 2021
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Bodie Island Lighthouse Pond Mitigation Site
Dare County
COE Action ID: SAW-1993-03077
CAMA #: 106-12
401 Certification #: 20120629
Prepared By:
Environmental Analysis Unit
North Carolina Department of Transportation
December 2021

TABLE OF CONTENTS
SUMMARY 1
1.0 Introduction 2
.1 Project Description 2
.2 Purpose 2
.3 Project History 2
.4 Debit Ledger 2
2.0 Vegetation: 3
.1 Success Criteria 3
.2 Vegetation Treatment 3
.3 Vegetation Modeling 3
.4 Vegetation Monitoring 3
.5 Conclusions. 4
3.0 Recommendations 4
FIGURES
Figure 1 —Vicinity Map 5
Figure 2 —Treatment Area Map 2021 6
APPENDICES
Appendix A— Site Photo Points 2021
Appendix B — Pesticide Record Form 2021

• 5 0 c•- j\ 3SZ
C0 �cs •
SUMMARY UJ- - •
The Bodie Island Lighthouse Pond Mitigation Site (Site) is located in Dare County, North
Carolina. Wetland mitigation consists of rehabilitating former Spartina-dominated marsh
habitat through exotic plant control measures for Phragmites australis in accordance with
the approved Final Wetland Mitigation Plan NC 12 Replacement of Herbert C. Bonner
Bridge (Bridge No. 11) over Oregon Inlet (dated January 30, 2013, hereafter referred to
as Mitigation Plan). Herbicide hand treatment began in May 2018 in areas adjacent to the
Bodie Island Lighthouse Boardwalk. Aerial herbicide applications (via Unmanned Aerial
Systems (UAS)) began on October 2018 following final mitigation approval by the
National Park Service (NPS). Approximately 2.5 acres of wetland mitigation will be
debited from the Site for unavoidable wetland impacts associated with the Replacement
of the NC 12 Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet.
Based on 2011 aerial photography, the North Carolina Department of Transportation
(NCDOT) proposed wetland mitigation that encompassed approximately 50 acres of
wetland restoration through the rehabilitation of marsh habitat. Aerial photos taken in
2016 indicated that Phragmites within the marsh had expanded beyond the 2011
footprint. Phragmites mapping and modeling efforts conducted in May 2019 estimated
approximately 55.7 acres of Phragmites-affected marsh located within the mitigation site.
dditional mapping and modeling has not been conducted since 2019 due to the
grounding of non-emergency UAS over Department of Interior (DOI) properties and
platform specific D I UAS restrictions Areas that appeared to contain Phragmites w re e
sprayed using the UAS between—gabber and November 15 of 2021. This area totaled
approximately 59.37 acres. Hand spraying was not conducted in areas surrounding the
boardwalk and lighthouse due to high winds during the window of opportunity (i.e.
between end of aerial applications and end of growing season). In addition, burning was
not conducted in 2021.
Restoration success criteria include: 1) a decrease in total aerial coverage of dense
Phragmites stands from the current densities after first-year treatment; 2) a decreasing
trend in aerial coverage of mapped Phragmites each treatment year; and 3) total aerial
coverage of dense Phragmites stands of 10 acres or less with stems less than three feet
tall at the end of the final monitoring year. Hydrologic monitoring is not required for this
project. Based on the 2020 Monitoring Report, the total aerial coverage of dense
Phragmites stands decreased within treated areas after first-year treatment. However,
2021 Phragmites coverage appears similar to 2020 because NCDOT was unable to
conduct aerial herbicide application in 2020.
NCDOT proposes to continue hand and aerial herbicide applications to Phragmites
affected marsh areas in 2022 and perform vegetation monitoring via aerial photography
and Phragmites modeling for 59.37 acres of marsh treated with herbicide in 2021.
NCDOT will also visually monitor the Site outside of the 59.37 acres of treated marsh to
en ragmites is not intruding into unmapped areas. CDOT is coordinating
wit PS to schedule a prescribed burn in the winter fo owi g e 2022 spray season.
1

1.0 INTRODUCTION
1.1 Project Description
The Site is located adjacent to the Bodie Island Lighthouse six miles south of Nags Head,
NC and three miles north of Oregon Inlet (Figure 1). In 2011, the Site consisted of
approximately 50 acres of wetland restoration through the rehabilitation of marsh habitat,
however 2019 aerial mapping and vegetation modeling indicated Phragmites dominated
areas expanded to 55.7 acres. Proposed debits to the Site include 2.5 acres o we arr.-id—
mitigation
for wetland impacts associated with construction of the Replacement of the NC
12 . Bonner Bridge (Bridge No. 11) over Oregon Inlet. Wetland mitigation
easures include reducing and controlling percent aerial coverage of the exotic plant
Phragmites australis using approved herbicides and prescribed burning, while allowing
-y natural reestablishment of native marsh plant species.
1.2 Purpose
In order for the Site to be considered successful it must meet success criteria established
in the Final Wetland Mitigation Plan, NC 12 Replacement of the NC 12 Herbert C. Bonner
Bridge (Bridge No. 11) over Oregon Inlet dated January 30, 2013 (hereafter referred to
as Mitigation Plan). This report details mitigation activities at the Site in 2021, as
recommended through the adaptive management guidelines approved in the Mitigation
Plan. Hydrologic monitoring is not required for the Site.
1.3 Project History
May 2018 Begin Hand Herbicide Application in Selected Areas
October 2018 NPS Issues Special Use Permit for UAS Application
October 2018 Begin Herbicide Application Season 2018
November 2018 End Herbicide Application Season 2018
June 2019 Begin Herbicide Application Season 2019
November 2019 End Herbicide Application Season 2019
January 2020 USDOI Grounds all UAS Flights over all DOI Property
October 2020 Hand Herbicide Application in Selected Areas
Oct-Nov 2021 UAS Herbicide Application over 59.37 Acres
1.4 Debit Ledger 0
A total of 2.5 wetland acres of the Site will be debited for unavoidable wetland impacts
associated with the NC 12 Replacement of the Herbert C. Bonner Bridge (Bridge No. 11)
over Oregon Inlet. Remaining site assets must have regulatory agency approval prior to
use as mitigation on other projects.
2

2.0 VEGETATION
2.1 Success Criteria
NCDOT shall monitor wetland mitigation by photographs and determinations of aerial
percent vegetation cover of Phragmites stands. Vegetation success criteria are:
• Total aerial coverage of dense Phragmites stand will decrease from mapped
acreage after the first-year treatment.
• The trend of decreased aerial coverage of mapped Phragmites will continue each
treatment year.
• Total aerial coverage of dense Phragmites stands will be 10 acres or less with
stems less than three feet tall at the end of the final monitoring year.
The Site will be monitored until success criteria are met with a brief annual progress report
being submitted to the United States Army Corps of Engineers (USACOE), North Carolina
Division of Water Resources (NCDWR), and North Carolina Division of Coastal
Management(NCDCM). Upon meeting success criteria, NCDOT will schedule an agency
field meeting to determine if the restored areas have achieved mitigation requirements.
2.2 Vegetation Treatment
Approved Phragmites control treatments for the Site include Glyphosate and Imazapyr
herbicide application, and prescribed burning. A total of 59.37 acres of the Project Area
(Figure 2) was treated with UAS aerial herbicide applications in October and November
2021. Treatments included a mixture of both Glyphosate (Roundup Custom®) and
Imazapyr (Habitat®) herbicides. Herbicide treatment consisted of Habitat®/Roundup
Custom®/Methylated Seed Oil (MSO) (64oz/64oz/1%) per acre. The treatment area
consisted of Phragmites affected marsh surrounding the Bodie Island Lighthouse Pond
as depicted in Figure 2. Prescribed burning and hand application of herbicide was not
conducted in 2021.
2.3 Vegetation Modeling
Vegetation modeling did not occur for the 2021 spraying season due to the US
Department of Interior (DOI) policy restricting certain UAS platforms from being used on
DOI property(i.e. NCDOT did not own a DOI approved UAS platform capable of collecting
aerial photos in 2021). Continued vegetation modeling of areas treated in 2019, 2020,
and 2021 are anticipated for the 2022 season pending DOI UAS use policy.
2.4 Vegetation Monitoring Results
Quantified vegetation monitoring results were not available for the 2019-2020 treatment
seasons due to the grounding of non-emergency UAS over DOI properties and platform
specific DOI UAS restrictions as described in Section 2.3. A visual inspection from the
marsh boundary appeared to indicate similar Phragmites coverage compared to 2020,
which is to be expected given that UAS operations were grounded at the mitigation site
3

in 2020. Grounding of UAS operations restricted areas that could be treated to hand
sprayed areas around the boardwalk and lighthouse in 2020. Quantitative monitoring for
Phragmites regrowth in herbicide treated areas will be performed in Spring 2022 per the
Mitigation Plan.
2.5 Conclusions
Phragmites coverage at the Site appeared similar to what was observed in 2020. Areas
that appeared to contain Phragmities were sprayed using the UAS between October and
November 15 of 2021. This area totaled approximately 59.37 acres.
Hand spraying was not conducted in areas surrounding the boardwalk due to high winds
during the window of opportunity (i.e. between end of aerial applications and end of
growing season). In addition, burning was not conducted in 2021. The quantified results
of 2019-2021 herbicide applications will be assessed in Spring 2022 via aerial imagery
and Phragmites modeling. At this time, Phragmites regrowth will continue to be evaluated
and any adjustments to herbicide application rates will be made in accordance with the
pesticide label.
As in previous years, continued successes at the mitigation site will include: 1) Precise
application of herbicide to Phragmites dominated areas with no unintended adverse
impacts to the park vegetation or wildlife, and 2) Minimal disturbances to Bodie Island
Lighthouse park operations and visitors. Evaluation of the approved herbicides and
herbicide delivery methods used at the mitigation site have demonstrated that herbicide
applications continue to remain viable and effective methods for delivering pesticide
application in environmentally sensitive areas.
3.0 RECOMMENDATIONS
In 2022, NCDOT anticipates continued herbicide applications to Phragmites affected
marsh areas located within the Site. The total acres to be treated in 2022 are contingent
on NPS approvals, site weather conditions, 2019-2021 vegetation monitoring, and
Phragmites modeling results. In Spring 2022, NCDOT plans continued aerial mapping of
the existing Phragmites boundary to determine the extent of the 2022 spray area. NCDOT
will also coordinate with NPS in an effort to obtain a burn permit for the Site. If successful,
burning would likely occur during the winterpfollowing the 2022 spraying season.
4

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This Exhibit is for planning purposes only and shown herein
does not meet NC 47-30 Requirements and therefore is not OF NORT Cq
for design, construction, or recording or transfer of ittle. The 9°�y
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from the sources listed below. 4 0
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This Exhibit is for planning purposes only and shown herein
does not meet NC 47-30 Requirements and therefore is not NOiH
for design, construction, or recording or transfer of ittle. The
Exhibit c�°�?o Exhibit was compiled from available information obtained
from the sources listed below. Site . .
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APPENDIX B
PESTICIDE RECORD FORM 2021

Bodie Island Lighthouse Pesticide Record Keeping Form 2021
Name and Certification Application Brand or Product EPA Registration Size of Area Rate Per Total Amount
Number Date* Name Number Treated Unit** Applied Location Crop
Wes Cartner
034-703 10/14/2021 Habitat 241-426-67690 10.82 64oz. 5.41 Bodie Island Lighthouse Phragmites australis
Wes Cartner 10/14/2021 Roundup Custom 524-343 10.82 64oz. 5.41 Bodie Island Lighthouse Phragmites australis
034-703
Wes Cartner 10/15/2021 Habitat 241-426-67690 4.66 64oz. 2.33 Bodie Island Lighthouse Phragmites australis
034-703
Wes Cartner
034-703 10/15/2021 Roundup Custom 524-343 4.66 64oz. 2.33 Bodie Island Lighthouse Phragmites australis
Wes Canner
034-703 11/1/2021 Habitat 241-426-67690 14.78 64oz. 7.39 Bodie Island Lighthouse Phragmites australis
Wes Cartner
034-703 11/1/2021 Roundup Custom 524-343 14.78 64oz. 7.39 Bodie Island Lighthouse Phragmites australis
Wes Cartner
034-703 11/2/2021 Habitat 241-426-67690 15.71 64oz. 7.855 Bodie Island Lighthouse Phragmites australis
Wes Cartner
034-703 11/2/2021 Roundup Custom 524-343 15.71 64oz. 7.855 Bodie Island Lighthouse Phragmites australis
Wes Cartner
034-703 11/10/2021 Habitat 241-426-67690 13.4 64oz. 6.7 Bodie Island Lighthouse Phragmites australis
Wes Cartner
034-703 11/10/2021 Roundup Custom 524-343 13.4 64oz. 6.7 Bodie Island Lighthouse Phragmites australis
Additional Notes:
*date should include month,day and year **rate per unit is not required by the Federal Pesticide Recordkeeping Regulations

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This Exhibit is for planning purposes only and shown herein
p10RTly
does not meet NC 47-30 Requirements and therefore is not0
GRAPHIC SCALE FIGURE 1 �oF c49
for design, construction, or recording or transfer of ittle. The �`
Exhibit was compiled from available information obtained aor ro =•E Bodie Island Lighthouse Pond Mitigation Site
from the sources listed below. °
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perimeter of Treatment Area to avoid woody vegetation.
This Exhibit is for planning purposes only and shown herein
does not meet NC 47-30 Requirements and therefore is not OF NORTHC
for design, construction, or recording or transfer of ittle. The - cam
Exhibit was compiled from available information obtained Site -
from from the sources listed below.
Sources: NCOneMap - 2020 Aerial Imagery oFI-Rp,10

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s around perimeter of Treatment Area to avoid woody vegetation.
i
This Exhibit is for planning purposes only and shown herein
does not meet NC 47-30 Requirements and therefore is not Hof NORTHcv,�,9
for design, construction, or recording or transfer of ittle. The (1) GRAPHIC SCALE FIGURE 2
Exhibit was compiled from available information obtained Bodie Island Lighthouse Pond Mitigation Site .
from the sources listed below. _
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Sources: NCOneMap - 2020 Aerial Imagery Feet OF110.0

2020 NCDOT MITIGATION MONITORING REPORT REVIEW MEETING
DIVISIONS 1-8
Meeting Minutes
March 10, 2021
10:00 am DOT CCA Structures Conf. Room Col. C4 (CAP 40) and Online
Site Visit Summary and Invitees/Attendance listed at end of this document.
Opening Remarks/General Comments
Dave Johnson opened the 2020 monitoring report meeting with some general comments.
Following the monitoring meeting, DOT will schedule field reviews as required. DOT will also
schedule site visits from the 2019 meeting since those were not completed due to budget
restraints and the pandemic. All the monitoring and stewardship reports are online at the
following web address .
https://connect.ncdot.gov/resources/Environmental/EAU/Monitoring-
Stewardship/PaQcs/default.aspx
Monitoring Reports Review:
Division 1
B-2500 Bodie Island Lighthouse Pond (Dare) - Year 2
Morgan Weatherford provided comments on the 2020 spraying at the Bodie Island site. USACE
inquired about the plan to include burning of phragmites in addition to the herbicide treatments.
DOT proposes to continue Phragmites herbicide treatments, work with USFWS to include burn
treatments, and vegetation monitoring in 2021.
B-2500A-AB New Inlet Br. Temp Impact Report(Dare) -Year 1
The temporary fill removal is scheduled at sites 1-6, 13 and 14 within the next month. REU is
planning to replant with the appropriate marsh grass species once removal is complete. Site 12 is
being treated for phragmites and will be graded & planted once that is complete. DCM
requested to ensure that all the temporary fill areas are removed per the permit. DOT proposes to
continue monitoring in 2021.
B-5507 Sand Run& Warwick Swamp Temp Imp Sites(Chowan/Gates) -Year 1
DOT proposes to continue monitoring in 2021. DWR inquired about Bridge#20. Paul Williams
stated that the site has been inundated and the plan is to add fill material and complete the
planting.
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Division 2
B-4598 Mason Creek Bridge Temporary Impact Site (Pamlico) - Year 2
DOT proposes to discontinue monitoring and will submit a closeout request letter. A site visit
was not required by the Resource Agencies.
B-5413 Smith Creek Temporary Impact Site(Beaufort) - Year 1
DOT proposes to continue monitoring in 2021.
Beaufort Br. 249 over Duck Creek Temporary Impact Site (Beaufort) -Year 1
DCM stated that elevation of the site is too low for CAMA species to survive. DOT will
schedule a site visit with the Resource Agencies to review elevations and develop a remediation
plan. DCM reminded that the permit area has an in-water work moratorium which will need to
be considered prior to implementing remediation.
R-3307 Turner Street Marsh (Carteret)-Year 3
DCM stated that although the area under the bridge is not meeting the success criteria, '/2 credit
may be given due to the functional benefit of removing the causeway. In the proposal, DOT
would not receive excess mitigation credit at the site, but DCM would consider that the site
provides adequate mitigation credit to meet the permit requirements for R-3307. DWR &
USACE agreed to the proposal. DOT will submit a closeout request letter.
R-3307 US 70 Temporary Impact Sites (Carteret) - Year 2
DOT proposes to discontinue monitoring and will submit a closeout request letter. A site visit
was not required by the Resource Agencies.
Division 3
B-4929 Surf City Bridge Temporary Impact Site(Fender) :Year 2
DOT plans to plant southside of Intracoastal waterway. DCM requested that DOT complete
additional marsh plantings in an area adjacent to Surf City park, where Geotech's boring
machine impacted existing marsh. DOT will locate these areas and complete planting in 2021.
DOT proposes to continue monitoring in 2021.
Onslow Br. 134 over Gibson Branch Temporary Impact Site (Onslow)- Year 1
USACE inquired about the tree species that were supplementally planted. DOT planted bald
cypress and water tupelo at the site in 2020. Larger plant material was suggested due to site
staying inundated. DOT proposes to continue monitoring in 2021.
R-2303B Stagecoach& Boren Brick Sites(Sampson) - Year 4
USACE requested that DOT add a debit ledger to the report and include what was originally
proposed versus the proposed updated credits at the site. DOT will also provide the agencies
with the original maps for the sites as well as the updated site maps. NCDOT is putting together
a spreadsheet listing initial proposed mitigation for each site, current as-built proposed mitigation
for each site, and debit ledger information as it relates to permit requirements. This draft
spreadsheet will be distributed to the regulatory agencies for review before being added to the R-
2303 monitoring report. DOT proposes to continue monitoring in 2021.

ANNUAL REPORT FOR 2020
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Bodie Island Lighthouse Pond Mitigation Site
Dare County
COE Action ID: SAW-1993-03077
CAMA #: 106-12
401 Certification #: 20120629
Prepared By:
Environmental Analysis Unit
North Carolina Department of Transportation
December 2020

TABLE OF CONTENTS
SUMMARY 1
1.0 Introduction 2
.1 Project Description 2
.2 Purpose 2
.3 Project History 2
.4 Debit Ledger 2
2.0 Vegetation: 3
.1 Success Criteria 3
.2 Vegetation Treatment 3
.3 Vegetation Modeling 3
.4 Vegetation Monitoring 3
.5 Conclusions. 4
3.0 Recommendations 4
FIGURES
Figure 1 — Site Map 2020 5
Figure 2 — Treatment Areas Map 2020 6
APPENDICES
Appendix A — Site Photo Points 2020
Appendix B — Post Spray Photos 2020
Appendix C — Pesticide Record Form 2020

SUMMARY
The Bodie Island Lighthouse Pond Mitigation Site is located in Dare County, North
Carolina. Wetland mitigation consists of rehabilitating former Spartina-dominated marsh
habitat through exotic plant control measures for Phragmites australis in accordance with
the approved Final Wetland Mitigation Plan NC 12 Replacement of Herbert C. Bonner
Bridge (Bridge No. 11) over Oregon Inlet (dated January 30, 2013). Herbicide hand
treatment began in May 2018 in areas adjacent to the Bodie Island Lighthouse Boardwalk.
Aerial herbicide applications (via Unmanned Aerial Systems (UAS)) began on October
2018 following final mitigation approval by the National Park Service (NPS).
Approximately 2.5 acres of wetland mitigation will be debited from the site for unavoidable
wetland impacts associated with the Replacement of the NC 12 Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet.
Based on 2011 aerial photography, the North Carolina Department of Transportation
(NCDOT) proposed wetland mitigation that encompassed approximately 50 acres of
wetland restoration through the rehabilitation of marsh habitat. Aerial photos taken in
2016 indicate that Phragmites within the marsh has expanded beyond the 2011 footprint.
Phragmites mapping and modeling efforts conducted in May 2019 estimates there are
now approximately 55.7 acres of Phragmites-affected marsh located within the mitigation
site.
Management of the Phragmites will be sought through an adaptive management plan
which ultimately will be turned over to the National Park Service to maintain. Monitoring
methods for wetland mitigation shall include photographs and determinations of percent
aerial cover of existing Phragmites stands. Restoration success criteria include: 1) a
decrease in total aerial coverage of dense Phragmites stands from the current densities
after the first-year treatment; 2) a decreasing trend in aerial coverage of mapped
Phragmites each treatment year; and 3) The total aerial coverage of dense Phragmites
stands of 10 acres or less with stems less than three feet tall at the end of the final
monitoring year. Hydrologic monitoring is not required for this project.
NCDOT proposes to continue hand and aerial herbicide applications to Phragmites
affected marsh areas in 2021 and perform vegetation monitoring via aerial photography
and Phragmites modeling for 73.1 acres of marsh treated with herbicide in 2019 and 0.33
acres of marsh treated with herbicide in 2020. NCDOT will also visually monitor the Bodie
Island Lighthouse Pond outside of the 73.1 acres of treated marsh to ensure new
Phragmites in not intruding into unmapped areas.
1

1.0 INTRODUCTION
1.1 Project Description
The Bodie Island Lighthouse Pond Mitigation Site is located adjacent to the Bodie Island
Lighthouse six miles south of Nags Head, NC and three miles north of the Oregon Inlet
(Figure 1 ). In 2011 , the mitigation site consisted of approximately 50 acres of wetland
restoration through the rehabilitation of marsh habitat, however 2019 aerial mapping and
vegetation modeling indicate Phragmites dominated areas have expanded to 55.7 acres.
Proposed debits to the mitigation site include 2.5 acres of wetland mitigation for wetland
impacts associated with the construction of the Replacement of the NC 12 Herbert C.
Bonner Bridge (Bridge No. 11) over Oregon Inlet. Wetland mitigation measures consists
of reducing and controlling the percent aerial coverage of the exotic plant Phragmites
australis using approved herbicides and prescribed burning, while allowing the natural
reestablishment of the native marsh plant species.
1.2 Purpose
In order for the mitigation site to be considered successful, the site must meet the success
criteria established in the Final Wetland Mitigation Plan, NC 12 Replacement of the NC
12 Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet dated January 30, 2013.
This report details site activities at the mitigation site in 2020. Hydrologic monitoring is not
required for the site.
1.3 Project History
May 2018 Begin Hand Herbicide Application in Selected Areas
October 2018 NPS Issues Special Use Permit for UAS Application
October 2018 Begin Herbicide Application Season 2018
November 2018 End Herbicide Application Season 2018
June 2019 Begin Herbicide Application Season 2019
November 2019 End Herbicide Application Season 2019
January 2020 USDOI Grounds all UAS Flights over all DOI Property
October 2020 Hand Herbicide Application in Selected Areas
1.4 Debit Ledger
A total of 2.5 wetland acres of the Bodie Island Lighthouse Pond Mitigation Site will be
debited for unavoidable wetland impacts associated with the NC 12 Replacement of the
Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet. Remaining site assets must
have regulatory agency approval prior to use as mitigation on other projects.

2.0 VEGETATION
2.1 Success Criteria
NCDOT shall monitor the wetland mitigation by photographs and determinations of aerial
percent vegetation cover of Phragmites stands. The vegetation success criteria are:
• The total aerial coverage of dense Phragmites stand will decrease from the
mapped acreage after the first-year treatment.
• The trend of decreased aerial coverage of mapped Phragmites will continue each
treatment year.
• The total aerial coverage of dense Phragmites stands will be 10 acres or less with
stems less than three feet tall at the end of the final monitoring year.
The mitigation site will be monitored until success criteria are met with a brief annual
progress report being submitted to the USACOE, NCDWR and NCDCM. Upon meeting
success criteria, NCDOT will schedule an agency field meeting to determine if the
restored areas have achieved mitigation requirements.
2.2 Vegetation Treatment
Approved Phragmites control treatments for the Bodie Island Lighthouse Pond Mitigation
Site include Glyphosate and Imazapyr herbicide application, and prescribed burning. A
total of 0.33 acres of the approximately 111-acre project area was hand treated with
herbicide applications on October 1, 2020 and included both Glyphosate and lmazapyr
herbicides (Figure 2). Herbicide treatment consisted of Habitat®/AquaPro®/Methylated
Seed Oil (MSO) (64oz/64oz/1%) per acre with chemical application rates dependent on
2019 herbicide applications. The treatment area consisted of Phragmites affected marsh
adjacent to the Bodie Island Lighthouse and Boardwalk. Prescribed burning was not
conducted in 2020.
2.3 Vegetation Modeling
Vegetation modeling did not occur for the 2020 spraying season due to the US
Department of Interior (DOI) grounding of all non-emergency UAS on DOI properties.
Continued vegetation modeling of areas treated in 2019 and 2020 are anticipated for the
2021 season pending DOI UAS use policy.
2.4 Vegetation Monitoring Results
Quantified vegetation monitoring results were not available for the 2019 treatment season
due to the grounding of non-emergency UAS over DOI properties. Subsequently, aerial
review of the vegetation monitoring plots was not performed for the 2020 season. A field
review from the marsh boundary and aerial observation from the Bodie Island Lighthouse
showed decreased Phragmites coverage in those areas sprayed in 2019 (Appendices B
and C). This observation meets two of the mitigation success criteria in which the total
aerial coverage of dense Phragmites stand will decrease from the mapped acreage after

the first-year treatment, and the trend of decreased aerial coverage of mapped
Phragmites will continue each treatment year. As observed in 2019, native marsh species
(e.g. ferns, sedges, climbing hempvine, bushy bluestem, groundsel tree, etc.) were
observed reestablishing in herbicide treated areas previously dominated by Phragmites.
Quantitative monitoring for Phragmites regrowth in the 2019 and 2020 herbicide treated
areas will be performed in Spring 2021 per the Final Wetland Mitigation Plan NC 12
Replacement of Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet. Field review
and photographic data revealed better Phragmites die back in areas sprayed with a
Habitat®/AquaPro®/Methylated Seed Oil (MSO) mixture rather than areas sprayed with
Habitat or AquaPro alone (Appendix B).
2.5 Conclusions
Full execution of the Bodie Island Lighthouse Pond mitigation plan was not implemented
for the 2020 spraying season. A total of 0.33 acres of the approximately 111-acre wetland
mitigation site was treated with herbicide for Phragmites coverage. Visual observation of
2019 herbicide application areas showed a decrease in the total coverage of Phragmites
at the Bodie Island Lighthouse Mitigation Site. The quantified results of 2019 and 2020
herbicide applications will be assessed in Spring 2021 via aerial imagery and Phragmites
modeling. At this time, Phragmites regrowth will continue to be evaluated and any
adjustments to herbicide application rates will be made in accordance with the pesticide
label. As in 2019, continued successes at the mitigation site included: 1) Precise
application of herbicide to Phragmites dominated areas with no unintended adverse
impacts to the park vegetation or wildlife, and 2) Minimal disturbances to Bodie Island
Lighthouse park operations and visitors (Boardwalk shut down for approximately 1 hour
in 2020). Evaluation of the approved herbicides and herbicide delivery methods used at
the mitigation site have demonstrated that herbicide applications continue to remain
viable and effective methods for delivering pesticide application in environmentally
sensitive areas.
3.0 RECOMMENDATIONS
In 2021, NCDOT anticipates continued herbicide applications to Phragmites affected
marsh areas located within the Bodie Island Lighthouse Pond Mitigation Site. The total
acres to be treated in 2021 are contingent on NPS approvals, site weather conditions,
and 2019 and 2020 vegetation monitoring and Phragmites modeling results. In Spring
2021, NCDOT plans continued aerial mapping of the existing Phragmites boundary to
determine the extent of the summer spray area.
4

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This Exhibit is for planning purposes only and shown herein does not meet NC 47-30 Requirements FIGURE 1
and therefore is not for design,construction,or recording or transfer of title.The Exhibit was compiled pf tTM Cq_
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from available information obtained from the sources listed below.
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Sources: GRAPHIC SCALE Bodie Island Lighthouse Pond Mitigation Site
NCialand 0 330 660 1,320 Site Map 2020 a .lI
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This Exhibit is for planning purposes only and shown herein does not meet NC 47-30 Requirements FIGURE 2
and therefore is not for design,construction,or recording or transfer of title.The Exhibit was compiled NORTH 4 from available information obtained from the sources listed below. �'
GRAPHIC SCALE Bodie Island Lighthouse Pond Mitigation Site
Sources:
NCOneMap 0 40 80 160 c
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APPENDIX B
POST SPRAY PHOTOS 2020

Bodie Island Lighthouse Pond Mitigation Site
June 2020
Photo 1: Post Spray 2019, SE of lighthouse. Photo 2: Post spray 2019, E of lighthouse.
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Photo 3: Post spray 2019, NE of lighthouse. Photo 4: Post spray 2019, N of lighthouse.
•
Photo 5: Post spray 2019, NW of lighthouse. Photo 6: Post spray 2019, W boundary.

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Photo 7. Post spray 2019, W boundary. Photo 8. Post spray 2019, W boundary.
Photo 9. Post spray 2019, NW boundary. Photo 10. Post spray 2019, N boundary.
Photo 11. Post spray 2019, N boundary. Photo 12. Post spray 2019, NE boundary.

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Photo 13. Post spray 2019, NE boundary. Photo 14. Post spray 2019, E boundary.
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Photo 15. Post spray 2019, E boundary. Photo 16. Post spray 2019, E boundary.
Photo 17. Post spray 2019, E boundary. Photo 18. Post spray 2019, SE boundary.

Photo 19. Post spray 2019, SE boundary. Photo 20. Post spray 2019, SE boundary.
Photo 21. Post spray 2019, SE boundary. Photo 22. Post spray, SE boundary.
„::.,
Photo 23. Post spray, S boundary. Photo 24. Post spray, S boundary.

Bodie Island Pesticide Recordkeeping Form 2020
Name and Application Brand or EPA Registration Size of Area Rate Total Amount
Certification Number Date* Product Name Number Treated Per Unit** Applied Location Crop
Timothy E.Black
026-36767 10/01/20 Habitat 241-426-67690 0.33 ac. 64 oz/acre 22 Oz Bodie Island Lighthouse Phragmitesaustralis
Timothy E.Black
026-36767 10/01/20 Aqua Pro 62719-324-67690 0.33 ac. 64 oz/acre 22 oz Bodie Island Lighthouse Phragmitesaustralis
Additional Notes:
Pesticide applied via backpack spray. Wind speed less than 10 mph. ', -74Z'c <
*date should include month,day and year **rate per unit is not required by the Federal Pesticide Recordkeeping Regulations Page: 1

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2019 NCDOT MITIGATION MONITORING REPORT REVIEW MEETING
DIVISIONS 1-8
Meeting Minutes
Wednesday March 11th 2020
2:00-4:00 Structure Design Conference Room
The following personnel were in attendance:
*Garcy Ward,NCDWR *Cathy Brittingham,NCDCM
*Brad Shaver, USACE *Kyle Barnes, USACE
*Eric Alsmeyer,USACE *Greg Daisy,NCDCM
*David Bailey, USACE Rob Ridings,NCDWR
*Stephen Lane,NCDCM *Tom Steffens, USACE
*Andy Williams, USACE *Amanetta Somerville, USEPA
*Travis Wilson,NCWRC April Norton,NCDWR
*Chad Coggin,NCDOT-DEO4 *Paul_Williams,NCDOT-DEO1
Randy Griffin,NCDOT-EAU *Anneliese Westphal,NCDOT- DEO 3
Byron Moore,NCDOT-EAU David Johnson,NCDOT-EAU
Jason Elliott,NCDOT-EAU Matt Green,NCDOT-REU L
Alex Geddie NCDOT-EAU Morgan Weatherford NCDOT-EAU
*Via webinar
Opening Remarks/General Comments:
Jason Elliott opened the 2019 monitoring report meeting with some general comments. Mr. Elliott
stated that DOT will schedule field reviews for potential closeout and any project issues that need
to be resolved once the report review,meetings have been completed. He also pointed out that all
of the monitoring_and stewardship reports were online at the following web address:
https://connect ncdot.gov/resources/Environmental/Pages/Pennits-and-Mitigation.aspi.
Monitoring Reports:
Division 1
4
-2500 Bodie Island Lighthouse Pond(Dare)-Year 1
DOT proposes to continue Phragmites herbicide treatments and vegetation
;I; monitoring in 2020.
RIVC Boardwalk Mitigation Site(Dare) - *Year 3*
9 Q DOT proposes to discontinue monitoring and will submit a closeout request letter.
411 ' U A site visit was not required by the Resource Agencies.

ANNUAL REPORT FOR 2019
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Bodie Island Lighthouse Pond Mitigation Site
Dare County
COE Action ID: SAW-1993-03077
CAMA #: 106-12
401 Certification #: 20120629
OF NORiH C
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T - O
S ti Of 10�SO
Prepared By:
Environmental Analysis Unit
North Carolina Department of Transportation
December 2019

Y
TABLE OF CONTENTS
SUMMARY 1
1.0 Introduction 2
.1 Project Description 2
.2 Purpose 2
.3 Project History 2
.4 Debit Ledger 2
2.0 Vegetation: 2
.1 Success Criteria 2
.2 Vegetation Treatment 3
.3 Vegetation Modeling 4
.4 Vegetation Monitoring 5
.5 Conclusions. 5
3.0 Recommendations 6
FIGURES
Figure 1 — Site Map 2019 7
Figure 2 —Treatment Areas Map 2019 8
Figure 3 — Herbicide Treatment Area 2018 9
TABLES
Table 1 — Bodie Island Mitigation Site herbicide applications, 2019 3
Table 2 — Ground Truth Classification from Validation ROls 4
APPENDICES
Appendix A— Imagery Processing Workflow
Appendix B — Site Photo Points 2019
Appendix C — Control and Vegetation Plots 2019
Appendix D — Post Spray Photos 2019
Appendix E — Pesticide Record Forms 2019

r
SUMMARY
The Bodie Island Lighthouse Pond Mitigation Site is located in Dare County, North
Carolina. Wetland mitigation consists of rehabilitating former Spartina-dominated marsh
habitat through exotic plant control measures for Phragmites australis in accordance with
the approved Final Wetland Mitigation Plan NC 12 Replacement of Herbert C. Bonner
Bridge (Bridge No. 11) over Oregon Inlet (dated January 30, 2013). Herbicide hand
treatment began in May 2018 in areas adjacent to the Bodie Island Lighthouse Boardwalk.
Aerial herbicide applications (via Unmanned Aerial Systems (UAS)) began on October
2018 following final mitigation approval by the National Park Service (NPS).
Approximately 2.5 acres of wetland mitigation will be debited from the site for unavoidable
wetland impacts associated with the Replacement of the NC 12 Herbert C. Bonner Bridge
(Bridge No. 11) over Oregon Inlet.
Based on 2011 aerial photography, the North Carolina Department of Transportation
(NCDOT) proposed wetland mitigation that encompassed approximately 50 acres of
wetland restoration through the rehabilitation of marsh habitat. Aerial photos taken in
2016 indicate that Phragmites within the marsh has expanded beyond the 2011 footprint.
Phragmites mapping and modeling efforts conducted in May 2019 estimates there are
now approximately 55.7 acres of Phragmites-affected marsh located within the mitigation
site.
Management of the Phragmites will be sought through an adaptive management plan
which ultimately will be turned over to the National Park Service to maintain. Monitoring
methods for wetland mitigation shall include photographs and determinations of percent
aerial cover of existing Phragmites stands. Restoration success criteria include: 1) a
decrease in total aerial coverage of dense Phragmites stands from the current densities
after the first-year treatment; 2) a decreasing trend in aerial coverage of mapped
Phragmites each treatment year; and 3) The total aerial coverage of dense Phragmites
stands of 10 acres or less with stems less than three feet tall at the end of the final
monitoring year. Hydrologic monitoring is not required for this project.
NCDOT proposes to continue hand and aerial herbicide applications to Phragmites
affected marsh areas in 2020 and perform vegetation monitoring via aerial photography
and Phragmites modeling for 73.1 acres of marsh treated with herbicide in 2019. NCDOT
will also visually monitor the Bodie Island Lighthouse Pond outside of the 73.1 acres of
treated marsh to ensure new Phragmites in not intruding into unmapped areas.
1

1.0 INTRODUCTION
1.1 Project Description
The Bodie Island Lighthouse Pond Mitigation Site is located adjacent to the Bodie Island
Lighthouse six miles south of Nags Head, NC and three miles north of the Oregon Inlet
(Figure 1). In 2011, the mitigation site consisted of approximately 50 acres of wetland
restoration through the rehabilitation of marsh habitat, however 2019 aerial mapping and
vegetation modeling indicate Phragmites dominated areas have expanded to 55.7 acres.
Proposed debits to the mitigation site include 2.5 acres of wetland mitigation for wetland
impacts associated with the construction of the Replacement of the NC 12 Herbert C.
Bonner Bridge (Bridge No. 11) over Oregon Inlet. Wetland mitigation measures consists
of reducing and controlling the percent aerial coverage of the exotic plant Phragmites
australis using approved herbicides and prescribed burning, while allowing the natural
reestablishment of the native marsh plant species.
1.2 Purpose
In order for the mitigation site to be considered successful, the site must meet the success
criteria established in the Final Wetland Mitigation Plan, NC 12 Replacement of the NC
12 Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet dated January 30, 2013.
This report details site activities at the mitigation site in 2019. Hydrologic monitoring is not
required for the site.
1.3 Project History
May 2018 Begin Hand Herbicide Application in Selected Areas
October 2018 NPS Issues Special Use Permit for UAS Application
October 2018 Begin Herbicide Application Season 2018
November 2018 End Herbicide Application Season 2018
June 2019 Begin Herbicide Application Season 2019
November 2019 End Herbicide Application Season 2019
1.4 Debit Ledger
A total of 2.5 wetland acres of the Bodie Island Lighthouse Pond Mitigation Site will be
debited for unavoidable wetland impacts associated with the NC 12 Replacement of the
Herbert C. Bonner Bridge (Bridge No. 11) over Oregon Inlet. Remaining site assets must
have regulatory agency approval prior to use as mitigation on other projects.
2.0 VEGETATION
2.1 Success Criteria
NCDOT shall monitor the wetland mitigation by photographs and determinations of aerial
percent vegetation cover of Phragmites stands. The vegetation success criteria are:
2

v
• The total aerial coverage of dense Phragmites stand will decrease from the
mapped acreage after the first-year treatment.
• The trend of decreased aerial coverage of mapped Phragmites will continue each
treatment year.
• The total aerial coverage of dense Phragmites stands will be 10 acres or less with
stems less than three feet tall at the end of the final monitoring year.
The mitigation site will be monitored until success criteria are met with a brief annual
progress report being submitted to the USACOE, NCDWR and NCDCM. Upon meeting
success criteria, NCDOT will schedule an agency field meeting to determine if the
restored areas have achieved mitigation requirements.
2.2 Vegetation Treatment
Approved Phragmites control treatments for the Bodie Island Lighthouse Pond Mitigation
Site include Glyphosate and Imazapyr herbicide application, and prescribed burning. A
total of 73.1 acres of the approximately 111-acre project area was treated with hand and
aerial herbicide applications in 2019 and included both Glyphosate and Imazapyr
herbicides (Figure 2). Herbicide treatments included Glyphosate (AquaPro®) only areas,
Imazapyr (Habitat®) only areas, and Habitat°/AquaPro°/Methylated Seed Oil (MSO)
areas. Chemical application rates were dependent on previous 2018 herbicide
applications. AquaPro® only areas consisted of hand treatment of 4.3 acres of marsh
adjacent to the Bodie Island Lighthouse Boardwalk and marsh/pine forest boundary at
40-200 oz per acre. Habitat°only areas consisted of UAS treatment of 6.0 acres of marsh
at 32 oz per acre. Habitat°/AquaPro°/MSO areas consisted of UAS treatment of 62.8
acres of Phragmites affected marsh at 64oz/64oz/1% per acre respectively. Prescribed
burning was not conducted in 2019.
Table 1. Bodie Island Mitigation Site Herbicide Applications, 2019
Treatment Area Herbicide Treatment (oz/acre) Date Acres
1 Habitat (32) 6/18/2019 3.8
2 Habitat (32) 7/1/2019 1.0
3 Habitat/AquaPro/MSO (64/64/1%) 7/2/2019 6.9
4 Habitat (32) 7/9/2019 1.2
5 Habitat/AquaPro/MSO (64/64/1%) 7/9/2019 8.3
6 Habitat/AquaPro/MSO (64/64/1%) 7/10/2019 8.4
7 Habitat/AquaPro/MSO (64/64/1%) 9/16/2019 0.1
8 Habitat/AquaPro/MSO (64/64/1%) 9/11/2019 0.9
9 Habitat/AquaPro/MSO (64/64/1%) 7/29/2019 2.7
10 Habitat/AquaPro/MSO (64/64/1%) 7/30/2019 13.5
11 Habitat/AquaPro/MSO (64/64/1%) 9/11/2019 8.6
12 Habitat/AquaPro/MSO (64/64/1%) 7/31/2019 and 13.4
8/20/2019**
13 AquaPro (40-200)* 7/2019 through 11/2019** 4.3
Total 73.1
*Hand Application
**Represents a continuation of herbicide treatment over multiple days.
3

2.3 Vegetation Modeling
An imagery processing workflow was used to establish a vegetation model to identify
areas of Phragmites affected marsh within the Bodie Island Lighthouse Pond Mitigation
Site with an accuracy of 99.1% (Appendix A). Data used to establish the model consisted
of aerial RGB (Red-Green-Blue) and Multispectral imagery captured of the Bodie Island
Lighthouse Pond Mitigation Site via UAS. RGB imagery was processed using Pix4D
Mapper to create an orthomosaic and digital surface model (DSM). Multispectral imagery
was processed using AgiSoft to generate the reflectance map and two spectral indices:
the normalized difference vegetation index (NDVI) and the soil-adjusted vegetation index
(SAVI). The NDVI is a common spectral index that is used to differentiate vegetative cover
and density from other land cover types. The SAVI is a spectral index that corrects for the
influence of spectral reflectance on substrates where vegetative cover is low.
ArcMap Pro was used to stack the five multispectral bands (blue, green, red, red edge,
near infrared), NDVI, SAVI, and DSM to create a composite file with data from all bands,
indices, and the DSM. The composite was clipped to remove portions of the imagery that
contained large areas of water, forest, or grass surfaces. This was done to reduce
processing time and eliminate possible classification errors where there is no Phragmites.
Calibration Regions of Interest (ROIs) of seven land cover classes used for the
classification were created by visual inspection of the UAS imagery and previous DOT
Phragmites delineations: Forest, Grass, Ground, Manmade, Native, Phrag, and Water.
The ArcGIS Pro Support Vector Machine (SVM) Classifier was used to classify the
composite image based on the ROIs. Following the initial classification, a majority filter
was applied four times. This is a common technique that resamples the cells in a raster
to generalize and reduce single pixel misclassifications.
SVM results show 32,230,061 pixels assigned to class Phrag and 66,480,451 pixels (a
resolution of 0.27441857 cm2) assigned to class Non-Phrag (this translates to 55.719
acres of Phrag and 114.93 acres of Non-Phrag, respectively). The overall accuracy
achieved by the SVM classifier was 99.1436% for the validation ROIs (Kappa Coefficient
= 0.9747). Table 2 describes the ground truth classification accuracies for both classes.
Within the validation ROls, Non-Phrag was correctly classified with 99.02% accuracy and
Phrag was correctly assigned 99.6% of the time (this also equates to Producer Accuracy,
or the probability that a pixel is classified correctly within a class). Commission errors
(false positive — predicted to be Class A but assigned to Class B) were 0.11 % for Non-
Phrag and 3.53 % for Phrag. Omission errors (false negative — predicted to be Class B
but assigned to Class A) were 0.98 % for Non-Phrag and 0.40 % for Phrag. User
accuracy, or the probability that a predicted pixel really belongs to that class, was 99.89
% for Non-Phrag and 96.47 % for Phrag.
Table 2. Ground Truth Classification from Validation ROIs.
Class Non-Phrag_ Phraq Total
Non-Phrag 13409527 (99.02%) 14557 (0.40%) 13424084 (78.11%)
Phrag 132613 (0.98%) 3628834 (99.6%) 3761447 (21.89%)
Total 13542140 (100%) 3643391 (100%) 17185531 (100%)
4

•
Table 2. Ground Truth Classification from Validation ROls continued.
Class Commission Omission Producer Accuracy User Accuracy
Non- 14557/13424084 132613/13542140 13409527/13542140 13409527/13424084
Phrag (0.11%) (0.98%) (99.02%) (99.89%)
Phrag 132613/3761447 14557/3643391 3628834/3643391 3628834/3761447
(3.53%) (0.40%) (99.6%) (96.47%)
2.4 Vegetation Monitoring Results
Vegetation monitoring results from the 2018 treatment season were positive. Aerial
imagery and Phragmites modeling data showed a decrease in Phragmites coverage for
areas treated with herbicide in 2018 (Figure 3, Appendices B and C). This result meets
one of the mitigation success criteria in which the total aerial coverage of dense
Phragmites stand will decrease from the mapped acreage after the first-year treatment.
Additionally, native marsh species (ferns) were observed reestablishing in herbicide
treated areas previously dominated by Phragmites (Appendix C, Photo 4). Development
of the Phragmites vegetation model in 2019 has provided a valuable tool to evaluate the
mitigation site's success criteria. The model showed high accuracy (99.1%) and will
provide the ability to quantify the aerial coverage of Phragmites. The Phragmites model
data for Spring 2019 represents the second attempt to quantify Phragmites coverage at
the Bodie Island Lighthouse Pond Mitigation Site and will serve as the primary baseline
for quantifiable comparison in subsequent treatment years. Monitoring for Phragmites
regrowth in the 2019 herbicide treated areas will be performed in Spring 2020 per the
Final Wetland Mitigation Plan NC 12 Replacement of Herbert C. Bonner Bridge (Bridge
No. 11) over Oregon Inlet.
2.5 Conclusions
Full execution of the Bodie Island Lighthouse Pond mitigation plan was implemented in
2019. Subsequently, a total of 73.1 acres of the approximately 111-acre wetland
mitigation site was treated with herbicide for Phragmites coverage. Herbicide applications
in 2018 resulted in a decrease in the total coverage of Phragmites at the Bodie Island
Lighthouse Mitigation Site. The effects of 2019 herbicide applications will be assessed in
Spring 2020 via aerial imagery and Phragmites modeling. At this time, Phragmites
regrowth will continue to be evaluated and any adjustments to herbicide application rates
will be made in accordance with the pesticide label. As in 2018, continued successes at
the mitigation site included: 1) Precise application of herbicide (Hand and Aerial) to
Phragmites dominated areas with no unintended adverse impacts to the park vegetation
or wildlife, 2) Successful flights of the UAS without incidence, and 3) Minimal disturbances
to Bodie Island Lighthouse park operations and visitors (Boardwalk shut down for
approximately 2-3 hours in 2019). Evaluation of the approved herbicides and herbicide
delivery methods used at the mitigation site have demonstrated that hand and UAS aerial
herbicide applications continue to remain viable and effective methods for delivering
pesticide application in environmentally sensitive areas. In field use, both methods
allowed for precise herbicide applications to the target species while minimizing
environmental risk associated with drift.
5

3.0 RECOMMENDATIONS
In 2020, NCDOT anticipates continued herbicide applications to Phragmites affected
marsh areas located within the Bodie Island Lighthouse Pond Mitigation Site. The total
acres to be treated in 2020 are contingent on NPS approvals, site weather conditions,
and 2019 vegetation monitoring and Phragmites modeling results. NCDOT will be
mapping the Phragmites again in the spring of 2020 to determine the extent that needs
to be sprayed in the summer.
6

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i
APPENDIX A
IMAGERY PROCESSING WORKFLOW

Digital
RGB Surface
Imagery Model
(DSM)
Blue
Normalize
d
Green Difference
Multispectral Vegetation
Imagery Index
Red
Soil
Adjusted
Red Edge Vegetation
Index
Near
Infrared
Ground
reference
data Support
Vector Stack layers 4
Visual 1mi+ Machine
analysisof (SVM)
imagery Classifier
Mer
ge
Regions of Initial classification
Interest classification (Phrag/Non-
(ROls) - Phrag)
Train
ROls - Accuracy Results: 55 acres
Validate �� Phrag; 99%
assessment
accuracy

APPENDIX B
SITE PHOTO POINTS 2019

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Summer 2019
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APPENDIX C
CONTROL AND VEGETATION PLOTS 2019

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APPENDIX D
POST SPRAY PHOTOS 2019

Bodie Island Lighthouse Pond Mitigation Site
Summer 2019
y i
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Photo 1: Spray Area 2018, prior to spray 2019. Photo 2: Post spray 2019, west boundary.
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Photo 3: Post spray 2019, west boundary. Photo 4: Post spray 2019, north boundary.
a *�
Photo 5: Post spray 2019 along NC 12. Photo 6: Post spray 2019 along NC 12.

APPENDIX E
PESTICIDE RECORD FORMS 2019

Christopher Dustin CLIENT: NC Department of Transportation
028-758
Bodie Island Lighthouse Pesticide Record Keeping Form 2019 _
Name and Application Brand or EPA Registration Size of Area Rate Total Amount
Certification Number Date* Product Name Number Treated Per Unit** Applied Location Crop
Christopher Dustin
028-758 06/18/19 Habitat 241-426-67690 3.8 ac 32oz. 0.95 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin
028-758 07/01/19 Habitat 241-426-67690 1 .0 ac. 32 oz. 0.25 gal. Bodie Island Lighthouse Phragmites australis
Christopher
028-758ustin 07/02/19 Habitat 241-426-67690
6.91 ac. 64oz. 3.46 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher 028-758ustin 07/02/19 AquaPro 62719-324-67690 6.91 ac. 64oz. 3.46 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin07/09/19 Habitat 241-426-67690Phragmiteac. saustralis
Christopher Dustin 62719-324-67690Phragmitesaustralisac.
Christopher Dustin
028-758 07/09/19 Habitat 241-426-67690 1 .18 ac. 32oz. 0.3 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin
028-758 07/10/19 Habitat 241-426-67690 8.35 ac. 64oz. 4.18 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin
07/10/19 A uapro 8.35 ac. 64oz. 4.18gal. Bodie Island Lighthouse Phragmitesaustralis
028-758 q 62719-324-67690g
Christopher Dustin
028-758 07/29/19 Habitat 241-426-67690 8.1 ac. 64oz. 4.05 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin
028-758 07/29/19 AquaPro 62719-324-67690 8.1 ac 64oz. 4.05 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustinustin 07/30/19 Habitat 241-426-67690
8.09 ac 64oz. 4.05 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher
028-758ustin 07/30/19 AquaPro 62719-324-67690 8.09 ac. 64oz. 4.05 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin
028-758 07/31/19 Habitat 241-426-67690 3.91 ac. 64oz. 1 .95 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin 028-758 07/31/19 AquaPro 62719-324-67690
3.91 ac. 64oz. 1 .95 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher 08/20/19 Habitat 241-426-67690 9.4 ac. 64oz. 4.7 gal. Bodie Island Lighthouse g Phragmites australis
Additional Notes:
*date should include month,day and year **rate per unit is not required by the Federal Pesticide Recordkeeping Regulations Page:

Christopher Dustin CLIENT: NC Department of Transportation
028-758
Bodie Island Lighthouse Pesticide Record Keeping Form 2019
Name and Application Brand or EPA Registration Size of Area Rate Total Amount
Certification Number Date* Product Name Number Treated Per Unit** Applied Location Crop
Christopher Dustin
028-758 08/20/19 AquaPro 62719-324-67690 9.4 ac 64oz. 4.7 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustinustin 09/11/19 Habitat 241-426-67690
9.54 ac. 64oz. 4.77 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher Dustin 028-758 09/11/19 AquaPro 62719-324-67690
9.54 ac. 64oz. 4.77 gal. Bodie Island Lighthouse Phragmitesaustralis
Christopher 09/16/19 Habitat 241-426-67690 Phragmitesaustralis
Christopher
Dustin 09/16/19
AquaPro 62719-324-67690 0.98 ac. 64oz. 0.49 gal. Bodie Island Lighthouse Phragmitesaustralis
Additional Notes:
*date should include month,day and year **rate per unit is not required by the Federal Pesticide Recordkeeping Regulations Page:

i
'Ground Application-Daily Pesticide Use Recordkeeping Form(Page 1)
NC Pesticide Herbicide Active Size of Area AquaPro"Applied Rate of AquaPro• Target
Applicator Application Date EPA Registration No. Method Location Notes
License Name Ingredient(%) Treated(ac) (gal) Applied
A (gal/ac) Species
July 29,2019 Foliar-1 psi 2.2 0.034 0.055 1.593 Double Treatment Area
July 29,2019 Follar-1 psi 2.2 0.018 0.029 1.546 Single Treatment Area
July 30,2019 Foliar-1 psi 2.2 0.183 0.083 0.452 Single Treatment Area
July 30,2019 Foliar-1 psi 2.2 0.115 0.104 0.901 Double Treatment Area
July 31,2019 Foliar-1 psi 2.2 0.141 0.207 1.466 Single Treatment Area
July 31,2019 Follar-1 psi 2.2 0.044 0.041 0.939 Double Treatment Area
Thomas 1,2019 Foliar-1 psi 2.2 0.043 0.016 0.375 Single Treatment Area
Bodle Island Phrogmites
Barrett 026-19493 August 1,2019 AquaPro• 62719-324-67690 Foliar-1 psi 2.2 0.399 0.150 0.375 Double Treatment Area
Lighthouse Marsh australis
October 22,2019 Foliar-2 psi 4.4 0.195 0.082 0.421 Single Treatment Area
October 22,2019 Foliar-2 psi 4.4 0.575 0.242 0.421 Double Treatment Area
October 23,2019 Foliar-15 psi 2.2 1.293 0.468 0.362 Single Treatment Area
October 23,2019 Foliar-15 psi 2.2 0.017 0.009 0.541 Double Treatment Area
October 24,2019 Foliar-15 psi 2.2 0.801 0.248 0.310 Single Treatment Area
November 11,2019 Foliar-15 psi 2.2 0.684 0.446 0.651 Single Treatment Area
November 12,2019 Foliar-15psi 2.2 0.310 0.124 0.400 Single Treatment Area
4.853 2.302 0.474
Total Area,
Average Rate of
Note:The values listed above and to the right show the areas sprayed to accountingfor anyspray overlap.See includes Total AquaPro° A uaPro°°Applied
Bprior P Y q q PP
page 2 for spray overlap totals. double Applied(gal) Over Entire Site
treatment (gal/ac)
areas(ac)
Additional Notes
AquaPro•refers to the original concentrate solution purchased from the supplier.
Dye/Foaming Agent-JARFACTANT 225 DK(Chemical Name:Alkyl Polyglycoside,CASK 68515-73-1)used for the July,August,&October applications at a rate of 1.6 oz per gallon of spray solution.
LazerTM Blue Spray Pattern Indicator was used for the November applications at a rate of 1.0 oz per gallon of spray solution.
r
I certify that the information shown above is true and correct to the best of my knowledge. 11/2 6/19

L
•
4.
Ground Application-Daily Pesticide Use Recordkeeping Form (Page 2)
NC Pesticide Herbicide Active Size of Area AquaPro"Applied Rate of AquaPro" Target
Applicator Application Date EPA Registration No. Method Location Notes
License Name Ingredient(%) Treated(ac) (gal) Applied(gal/ac) Species
July 29,2019 Foliar-1 psi 2.2 0.018 0.029 1.546 Single Treatment Area
July 30,2019 Foliar-1 psi 2.2 0.183 0.083 0.452 Single Treatment Area
July 31,2019 Follar-1 psi 2.2 0.141 0.207 1.466 Single Treatment Area
August 1,2019 Follar-1 psi 2.2 0.043 0.016 0.375 Single Treatment Area
Thomas July-October 2019 Foliar-1 psi 2.2-4.4 0.591 0.600 1.015 Bodie Island Phra mites Double Treatment Area
Barrett 026-19493 AquaPro• 62719-324-67690 9
October 22,2019 Foliar-2 psi 4.4 0.195 0.082 0.421 Lighthouse Marsh australis Single Treatment Area
October 23,2019 Foliar-15 psi 2.2 1.293 0.467 0.361 Single Treatment Area
October 24,2019 Foliar-15 psi 2.2 0.801 0.248 0.310 Single Treatment Area
November 11,2019 Foliar-15 psi 2.2 0.684 0.446 0.651 Single Treatment Area
November 12,2019 Foliar-15 psi 2.2 0.310 0.124 0.400 Single Treatment Area
4.261 2.302 0.540
Average Rate of
Note:Values listed above and to the right account for any spray overlap areas across the entire site.Approximately, Total Area Total AquaPro® AquaPro"Applied
0.60 acres of the entire site were sprayed twice during the 2019 season. Treated(an) Applied(gal) Over Entire Site
(gal/ac)
Additional Notes
AquaPro•refers to the original concentrate solution purchased from the supplier.
Dye/Foaming Agent-JARFACTANT 225 DK(Chemical Name:Alkyl Polyglycoside,CAM 68515-73.1)used for the July,August,&October applications at a rate of 1.6 oz per gallon of spray solution.
Lazer"Blue Spray Pattern Indicator was used for the November applications at a rate of 1.0 oz per gallon of spray solution.
I certify that the information shown above is true and correct to the best of my knowledge. 11/2 6/19

\\ Cot)yew°ky
„" -e c Ds o" o s e L 3l-,A1A_ouSsZ pot, ck
Brittingham, Cathy
From: Williams, Paul C b slab _ # /
Sent: Friday, October 25, 2013 4:24 PM �td�� w/ s(
To: Brittingham, Cathy
Subject: FW: Bodie Island Lighthouse Pond
Attachments: '1022131251a.jpg; 1022131249a.jpg; 1022131250a.jpg
� \ CAZ-ev2S ff
= #'Z jklV fia454-PS
Paul C. Williams, Jr. 'f'"_\ /f c,pO-r re I(yen ce\ ,8 _oz 5-00
DOT Project Field Representative
N.C. Dept. of Environment & Natural Resources Division of Coastal Management
1367 U.S. 17 South
Elizabeth City, NC 27909
Office: [phone]
Mobile: [phone]
Fax: [phone]
paul.williamsOncdenr.gov
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
Original Message
From: Williams, Paul C
Sent: Tuesday, October 22, 2013 4:31 PM
To: Huggett, Doug
Subject: Bodie Island Lighthouse Pond
This is the culvert and the other structure at the pond. The culvert is on the soundside,
and the other structure is on the pondside. The culvert is failing, but some water is still
getting through. The other structure is about 5-6' wide; not sure how deep. I would say the
connectivity is very poor.
Didn't make it around the entire pond, but walked a long ways and didn't see any other
structures. I'll check again when the weather is colder.
Thanks,
Paul C. Williams, Jr.
DOT Project Field Representative
N.C. Dept. of Environment & Natural Resources Division of Coastal Management
1367 U.S. 17 South
Elizabeth City, NC 27909
Office: [phone]
Mobile: [phone]
Fax: [phone]
paul.williamsPncdenr.gov

E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
2

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Final Wetland Mitigation Plan
NC 12 Replacement of Herbert C. Bonner
Bridge
(Bridge No. 11 ) over Oregon Inlet
Federal Aid No. BRS-2358(15)
NCDOT Project Definition: 32635
TIP Project No. B-2500
Dare County, North Carolina
Prepared by
United States National Park Service
North Carolina Department of Transportation
January 30, 2013
1

Brittingham, Cathy
From: Chris Militscher[[e-mail]]
Sent: Friday, May 25, 2012 2:43 PM
To: Paugh, Leilani Y
Cc: William Biddlecome ([e-mail]); Wainwright, David; Brittingham,
Cathy
Subject: Revised draft Wetland Mitigation Plan - B-2500
Leilani: EPA has reviewed the revised draft wetland mitigation plan dated 5/17/12 for B-2500. I appreciate
you including herbicide MSDs. EPA notes that NCDOT is seeking 5:1 mitigation credit ratios for the
proposed Phragmites treatment at Bodie Island Pond. EPA has not identified specific environmental
objections to the proposed mitigation plan. Thank you for the opportunity to comment.
Christopher A. Militscher, REM, CHMM
USEPA Region 4 NEPA Program Office
919-856-4206 (Raleigh)
404-562-9512 (Atlanta)
•

sir
t

Brittingham, Cathy
From: Paugh, Leilani Y
Sent: Thursday, May 17, 2012 5:38 PM
To: Biddlecome, William J SAW([e-mail]); McLendon, Scott C
SAW([e-mail]); Wrenn, Brian; Wainwright, David; Brittingham,
Cathy; Huggett, Doug; Wilson, Travis W.; [e-mail];
[e-mail]; [e-mail]; [e-mail];
[e-mail]; [e-mail]
Cc: [e-mail]; Weatherford, Morgan D; Hering, David T; Smyre, Elizabeth A;
Harris, David B
Subject: B-2500 PHase I mitigation plan at Bodie Island
Attachments: Bodie Lighthouse draft plan.docx
HI Bill
I have attached the revised draft mitigation plan for the Bodie Island _Lighthouse Pond for
the merger team's review and comment.
Thank you
LeiLani
Email correspondence to and from this sender is subject to the N.C. Public Records Law and
may be disclosed to third parties.
1

Brittingham, Cathy
From: [e-mail]
Sent: Wednesday, November 30, 2011 11:07 AM
To: Paugh, Leilani Y; Wrenn, Brian; Biddlecome, William J SAW; Smyre, Elizabeth A; Sechler,
Ron; Brittingham, Cathy; Wilson, Travis W.; [e-mail]; Wainwright, David
Subject: New NPDES permit requirement for aquatic herbicide applications
Merger Team members: For the scheduled Phase I Bonner Bridge meeting on 12/15, I will be
bringing new information (handout) concerning the
10/31/11 EPA issued final NPDES pesticide general permit requirements
(GP) for point source discharges from the application of pesticides to waters of the U.S.
This new requirement would potentially apply to any herbicide spraying associated with the
proposed mitigation plans. NCDENR is delegated the NPDES permit program under the CWA.
This new final rule was directed by past Court challenges and rulings and basically nullifies
the previous exemption from the NPDES permit program for discharges of pesticides/herbicides
under FIFRA labeling and use compliance in waters of the U.S.
This GP is required to address NMFS Listed Resources of Concern.
Thanks.
Christopher A. Militscher, REM, CHMM
USEPA Region 4 Raleigh Office
919-856-4206 or 404-562-9512
1

Brittingham, Cathy
From: [e-mail]
Sent: Tuesday, May 17, 2011 8:53 AM
To: Smyre, Elizabeth A
Cc: Benjamin, Pete; Biddlecome, Bill; Brittingham, Cathy; Broili, Thayer; Bryant, Mike;
[e-mail]; Cox, David R.; Gledhill-earley, Renee; Gregson, Jim; Huggett,
Doug; Jordan, Gary; Hart, Kevin; Lane, Stephen; Lucas, Ron; McLendon, Scott; Murray, Mike;
Sechler, Ron; Stewart, Dennis; Wainwright, David; Wilber, Pace; Wilson, Travis W.; Wrenn,
Brian; Paugh, Leilani Y; Weatherford, Morgan D
Subject: Re: Bodie Lighthouse draft plan.docx
Beth/Leilani: I agree with Gary Jordan's 5/16/11 comments on the mitigation plan. I believe this
mitigation to be primarily enhancement and temporal in nature. With hundreds of acres of exotic
Phragmites in other nearby areas of the Sound, it will only be a matter of time before the NPS Bodie
Island pond/wetland site returns to this invasive plant. -
I have previously visited the Mashoes Road NCDOT mitigation site several times back in the early and
mid-2000's where the mitigation included eradication of Phragmites as part of the 404 permit success
criteria. Despite years of conserted efforts and substantial cost by NCDOT, the Phragmites could not be
successfully eradicated within the standard monitoring period and the NCDOT requested the USACE to
amend the permit condition.
Professionally and personally, I am also not a proponent of aerial spraying of non-selective
herbicides (despite the general 'EPA acceptance for aquatic use' under FIFRA). Most all of the
manufacturer's testing under this Federal program is for the 'active ingredients', not the 'inert carrier
agents' which make up the greatest percentage of the herbicide. Some 'inert carrier agents' are
potentially very toxic and over-spraying or long-term applications can contaminate surface and ground
waters and can harm wildlife. Typically, I view substantial applications of herbicides as 'a measure of last
resort'. I would request that NCDOT perform a literature search and provide an example or two where
aerial spraying of herbicides for Phragmites has been successfully achieved in a coastal environment and
for what potential period of time.
I defer to other mitigation professionals and agency representatives on the specific mitigation ratios, but
2:1 for potentially temporary enhancement does not seem reasonable to me.
Thank you.
Christopher A. Militscher, REM, CHMM
USEPA Region 4 Raleigh Office
Merger Team Representative
919-856-4206
"Smyre, Elizabeth A" <[e-mail]> wrote:
To: "Benjamin, Pete" <pete [e-mail]>, "Biddlecome, Bill"
<[e-mail]>, "Brittingham, Cathy" <[e-mail]>,
"Broili, Thayer" <Thayer [e-mail]>, "Bryant, Mike" <mike [e-mail]>,
"[e-mail]" <Clarence.Coleman@dot.c ov>, "Cox, David R." <[e-mail]>,
"Gledhill-earley, Renee" <renee.gledhill-earley@ncdcrrgov>, "Gregson, Jim" <[e-mail]>,
"Huggett, Doug" <[e-mail]>, "Jordan, Gary" <gary [e-mail]>, "Hart, Kevin"
<[e-mail]>, "Lane, Stephen" <[e-mail]>, "Lucas, Ron"
<[e-mail]>, "McLendon, Scott" <[e-mail]>, Chris
Militscher/R4/USEPA/US@EPA, "Murray, Mike" <Mike [e-mail]>, "Sechler, Ron"
<[e-mail]>, "Stewart, Dennis" <dennis [e-mail]>, "Wainwright, David"
<[e-mail]>, "Wilber, Pace" <[e-mail]>, "Wilson, Travis W."
<[e-mail]>, "Wrenn, Brian" <[e-mail]>
From: "Smyre, Elizabeth A" <[e-mail]>
1

Brittingham, Cathy
From: [e-mail]
Sent: Monday, May 16, 2011 4:22 PM
To: [e-mail]
Cc: Wrenn, Brian; Smyre, Elizabeth A; Brittingham, Cathy; [e-mail]; Cox,
David R.; Wainwright, David; Huggett, Doug; Jordan, Gary; Gregson, Jim; Hart, Kevin; Paugh,
Leilani Y; Weatherford, Morgan D; Bryant, Mike; Murray, Mike; Militscher, Chris; Wilber, Pace;
Benjamin, Pete; Gledhill-earley, Renee; Lucas, Ron; Sechler, Ron; McLendon, Scott; Lane,
Stephen; Broili, Thayer; Wilson, Travis W.; Biddlecome, Bill
Subject: Re: Bodie Lighthouse draft plan.docx
Attachments: Bodie Lighthouse draft plan.docx
Gary,
I concur. Good job -short and to the point.
Dennis Stewart
Refuge Biologist
Alligator River National Wildlife Refuge
Pea Island National Wildlife Refuge
[phone] x231 [phone] (cell)
Gary Jordan/R4/FWS/DOI To [e-mail]
cc"Benjamin, Pete"<[e-mail]>,"Biddlecome,Bill"
05/16/2011 04:06 PM <[e-mail]>,"Brittingham,Cathy"
<[e-mail]>,"Broili,Thayer"<[e-mail]>,"Bryant,
Mike"<[e-mail]>,"[e-mail]"
<[e-mail]>,"Cox,David R."<[e-mail]>,"Gledhill-
earley, Renee"<[e-mail]>,"Gregson,Jim"
<[e-mail]>,"Huggett,Doug"<[e-mail]>,"Jordan,
Gary"<[e-mail]>,"Hart,Kevin"<[e-mail]>,"Lane,
Stephen"<[e-mail]>,"Lucas,Ron"<[e-mail]>,
"McLendon,Scott"<[e-mail]>,"Militscher,Chris"
<[e-mail]>,"Murray,Mike"<[e-mail]>,
"Sechler, Ron"<[e-mail]>,"Stewart,Dennis"
<[e-mail]>,'Wainwright,David"<[e-mail]>,
'Wilber,Pace"<[e-mail]>,'Wilson,Travis W."
<[e-mail]>,'Wrenn,Brian"<[e-mail]>,"Smyre,
Elizabeth A"<[e-mail]>,'Weatherford,Morgan D"
<mdweatherford @ncdot.gov>
Subject Re: Bodie Lighthouse draft plan.docxLink
Lei Lan i,
Here are my comments/questions regarding the draft Bonner Bridge wetland mitigation plan.
1) The USFWS is not opposed to the concept of using Phragmites treatment at the Bodie Island Lighthouse Pond as
mitigation for wetland impacts on National Park Service lands on Bodie Island.
2) How long is the treatment process to continue? The plan does not specify.
3) The USFWS believes that the proposed mitigation is enhancement and not restoration. The site is already a
functioning wetland, albeit the wildlife habitat is degraded due to the presence of Phragmites. The functional uplift may
only prove to be temporal, with diminishing benefits after treatment ends.
4) The proposed ratio of 2:1 seems too high. The impacts are permanent, while the functional uplift will likely be
1

Brittingham, Cathy
From: [e-mail]
Sent: Monday, May 16, 2011 4:06 PM
To: Paugh, Leilani Y
Cc: Benjamin, Pete; Biddlecome, Bill; Brittingham, Cathy; Broili, Thayer; Bryant, Mike;
[e-mail]; Cox, David R.; Gledhill-earley, Renee; Gregson, Jim; Huggett,
Doug; Jordan, Gary; Hart, Kevin; Lane, Stephen; Lucas, Ron; McLendon, Scott; Militscher,
Chris; Murray, Mike; Sechler, Ron; Stewart, Dennis; Wainwright, David; Wilber, Pace; Wilson,
Travis W.; Wrenn, Brian; Smyre, Elizabeth A; Weatherford, Morgan D
Subject: Re: Bodie Lighthouse draft plan.docx
Attachments: Bodie Lighthouse draft plan.docx
LeiLani,
Here are my comments/questions regarding the draft Bonner Bridge wetland mitigation plan.
1) The USFWS is not opposed to the concept of using Phragmites treatment at the Bodie Island Lighthouse Pond as
mitigation for wetland impacts on National Park Service lands on Bodie Island.
2) How long is the treatment process to continue? The plan does not specify.
3) The USFWS believes that the proposed mitigation is enhancement and not restoration. The site is already a
functioning wetland, albeit the wildlife habitat is degraded due to the presence of Phragmites. The functional uplift may
only prove to be temporal, with diminishing benefits after treatment ends.
4) The proposed ratio of 2:1 seems too high. The impacts are permanent, while the functional uplift will likely be
temporary. Within the range of functions of the existing wetland to be enhanced, the functional uplift is only partial.
5) Any excess credits left over at the Bodie Island Lighthouse Pond would not be acceptable for wetland impacts within
the Pea Island National Wildlife Refuge in future phases of the project.
6) Wetland mitigation (i.e. for Section 404 impacts) should not be confused with mitigation for use of Refuge lands.
Theoretically, a wetland mitigation site could possibly be used to satisfy requirements to mitigate for the use of Refuge
lands, but the legal requirements fall under two separate federal laws.
Gary Jordan
Fish and Wildlife Biologist
US Fish and Wildlife Service
PO Box 33726
Raleigh, NC 27636-3726
Phone [phone] ext. 32
Fax [phone]
gary jordanfws.qov
"Smyre,Elizabeth A"<bsmyre(aWncdot.gov> To"Benjamin,Pete"<pete benlamin(&fws.gov>,"Biddlecome,Bill"
<william.i.biddlecomeasaw02.usace.armv.mil>,"Brittingham,Cathy"
05/11/2011 05:27 PM <cathy.brittinghamancdenr.gov>,"Broili,Thayer"<Thayer BroiliAnps.gov>,"Bryant,
Mike"<mike brvant(c�fws.gov>,"Clarence.Coleman(dIclot.gov"
<Clarence.Coleman(a�dot.gov>,"Cox, David R."<david.cox(n�ncwildlife.orq>,"Gledhill-
earley,Renee"<renee.dledhill-earley a(�ncdcr.gov>,"Gregson,Jim"
<jim.gregson(C17.ncdenr.qov>,"Huggett,Doug"<douq.huggettc ncdenr.gov>,"Jordan,
Gary"<ciary iordan a(�.fws.gov>,"Hart,Kevin"<kevin.hart(a�ncdenr.gov>,"Lane,
Stephen"<stephen.lane(a,ncdenr.gov>,"Lucas,Ron"<ron.lucas(o�fhwa.dot.dov>,
"McLendon,Scott"<Scott.C.McLendon(a�saw02.usace.army.mil>,"Militscher,Chris"
<Militscher.Chris(a.epamail.epa.gov>,"Murray,Mike"<Mike Murravna nps.dov>,
"Sechler, Ron"<Ron.Sechlernoaa.qov>,"Stewart, Dennis"
<dennis stewartfws.qov>,'Wainwright,David"<david.wainwright(a�ncdenr.gov>,
'Wilber,Pace"<Pace.WilberAnoaa.gov>,'Wilson,Travis W."
<travis.wilson(a7ncwildlife.orq>,"Wrenn,Brian"<brian.wrenn( ncdenr.gov>
cc"Paugh,Leilani Y"<Ipaughna,ncdot.gov>,'Weatherford,Morgan D"
<mdweatherford(ril ncdot.qov>
Subject Bodie Lighthouse draft plan.docx
1

B-2500 Merger Team & Co. :
Attached is the latest draft of the wetland mitigation plan (the Bodie Island Lighthouse
pond mitigation) for the Bonner Bridge project. NCDOT is still working with the NPS on
many of the details, but we'd also like your feedback on the current draft.
Please review and send any comments to LeiLani Paugh at [e-mail] as soon as
possible.
Thanks,
Beth
***Please note my phone number has changed, effective March 30, 2011- see below. ***
Beth Smyre, P.E.
Project Planning Engineer
NC Department of Transportation
Project Development & Environmental Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
(919) 707-6043
•
Email correspondence to and from this sender is subject to the N.C. Public Records Law and
may be disclosed to third parties.
2

Brittingham, Cathy
From: Wilson, Travis W.
Sent: Wednesday, June 08, 2011 10:18 AM
To: Smyre, Elizabeth A; Benjamin, Pete; Biddlecome, Bill; Brittingham, Cathy; Broili, Thayer;
Bryant, Mike; [e-mail]; Cox, David R.; Gledhill-earley, Renee; Gregson,
Jim; Huggett, Doug; Jordan, Gary; Hart, Kevin; Lane, Stephen; Lucas, Ron; McLendon, Scott;
Militscher, Chris; Murray, Mike; Sechler, Ron; Stewart, Dennis; Wainwright, David; Wilber,
Pace; Wrenn, Brian
Cc: Paugh, Leilani Y; Weatherford, Morgan D
Subject: RE: Bodie Lighthouse draft plan.docx
I have reviewed the draft wetland mitigation plan for B-2500 and offer the following
comments.
WRC does not object to the removal of Phragmites and restoration of native vegetation in the
Bodie Island Lighthouse Pond to compensate for the loss of wetlands located on NPS property,
however wetland impacts in other phases of this project should be reviewed on a case by case
basis to determine if this site provides appropriate mitigation.
WRC agrees that Phragmites treatment "has proven to be a challenging and unpredictable
undertaking" . With that in mind it is important for all parties to come to a consensus on
the project expectations. The goal of the mitigation plan appears to be providing treatment
with no specific commitment of reducing Phragmites coverage, and although an adaptive
management plan is imperative to successful treatment the objectives of "treatment and
control" are not defined. Treatment is more of a strategy than an objective and control is
not defined. Does control mean no net gain in Phragmites coverage, reduced coverage, or
• restored native vegetation? •
This site currently provides exceptional functions, the proposed mitigation will result in no
net gain in area and will consist of improving a specific function, therefore the mitigation
type appears to best fit Enhancement, and a 2:1 ratio would be generous. It is not evident
that 35 acres of Phragmites treatment and control would offset the loss of 17.5 acres of
wetlands.
If DOT provides treatment and there is no reduction in Phragmites coverage and no net gain in
native veg then there is no net gain in resource function as required in defining either
restoration or enhancement mitigation options. NCDOT should be able to demonstrate
improvement at the end of implementation and monitoring. It may be more appropriate to
determine credit at the end of monitoring.
Travis W. Wilson
Eastern Region Highway Project Coordinator Habitat Conservation Program NC Wildlife Resources
Commission
1142 I-85 Service Rd.
Creedmoor, NC 27522
Phone: [phone] ext. 6
Fax: [phone]
Travis.WilsonRncwildlife.org
Original Message
From: Smyre, Elizabeth A
1

Brittingham, Cathy
From: Wainwright, David
Sent: Thursday, May 19, 2011 11:11 AM
To: Paugh, Leilani Y; Weatherford, Morgan D
Cc: Smyre, Elizabeth A; Benjamin, Pete; Biddlecome, Bill; Brittingham, Cathy; Broili, Thayer;
Bryant, Mike; [e-mail]; Cox, David R.; Gledhill-earley, Renee; Gregson,
Jim; Huggett, Doug; Jordan, Gary; Hart, Kevin; Lane, Stephen; Lucas, Ron; McLendon, Scott;
Militscher, Chris; Murray, Mike; Sechler, Ron; Stewart, Dennis; Wilber, Pace; Wilson, Travis
W.; Wrenn, Brian
Subject: RE: Bodie Lighthouse draft plan
Leilani,
The DWQ has reviewed the draft mitigation proposal for the Bonner Bridge. We have a few
comments/concerns; many of our concerns reflect what has already been stated by others. We
realize that the document is not complete, and discussions are ongoing with the NPS. Our
comments and concerns are stated below.
* The eradication of phragmites in an existing wetland is considered to be enhancement by the
DWQ, not restoration. Our rules clearly state what we consider restoration and what is
considered enhancement (15A NCAC 2H 0.056[4]).
*15A NCAC 2H 0506(7) states that "all mitigation proposals shall provide for the replacement
of wetland acres lost due to the proposed activity at a minimum of 1:1 through restoration or
creation prior to utilizing enhancement or preservation to satisfy the mitigation
requirements unless the Director determines that the public good would be better served by
other types of mitigation." Thus far, the DWQ has believed that this plan would better serve
the public good; however, there will still need to be•a request to the Director for an
exemption from this rule before we can fully accept this proposal. At this time, we support
the proposal and do not believe that an exemption will be an issue.
* It is unclear in the proposal how long it is anticipated satisfactory control of the
phragmites will take (the proposal just states "annually").
* What happens if success criteria are not met within the anticipated time (as yet to be
stated); how long will be allowed before it is decided that the eradication is not
successful?
* If the eradication is not deemed a success, what other mitigation options are available? A
"backup" plan should be suggested, but not necessarily in detail.
* It is assumed, although not expressly stated, that the goal is to eradicate all of the
phragmites. Success criteria should be discussed in more detail.
* How long will the NCDOT be responsible for the eradication of the phragmites? What happens
if, a few years after eradication, it begins to invade the treated area again - would the
NCDOT come back in and retreat? The DWQ generally accepts the plan, but is concerned about
the longer-term eradication of the phragmites. The DWQ does not want "temporary mitigation"
to be provided.
The DWQ appreciates the opportunity to review and comment on the draft proposal. Should you
have any questions, please feel free to contact either me or Brian.
David Wainwright
NCDENR, Division of Water Quality
Transportation Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
1

Brittingham, Cathy
From: Biddlecome, William J SAW[[e-mail]]
Sent: Wednesday, June 08, 2011 4:26 PM
To: Smyre, Elizabeth A; Benjamin, Pete; Brittingham, Cathy; Broili, Thayer; Bryant, Mike;
[e-mail]; Cox, David R.; Gledhill-earley, Renee; Gregson, Jim; Huggett,
Doug; Jordan, Gary; Hart, Kevin; Lane, Stephen; Lucas, Ron; McLendon, Scott C SAW;
Militscher, Chris; Murray, Mike; smtp-Sechler, Ron; Stewart, Dennis; Wainwright, David;
Wilber, Pace; Wilson, Travis W.; Wrenn, Brian
Cc: Paugh, Leilani Y; Weatherford, Morgan D; Matthews, Monte K SAW; McLendon, Scott C SAW
Subject: RE: Bodie Lighthouse draft plan.docx (UNCLASSIFIED)
Classification: UNCLASSIFIED
Caveats: NONE
All,
I offer the following comments about the plan:
1. Based on the new mitigation rule, restoration is divided into two categories,
reestablishment and rehabilitation. I clearly think this proposal could -fit into the
category of rehabilitation and therefore could qualify for wetland restoration credit. It is
easy to get confused between the term enhancement and rehabilitation because they are very
similar in nature. The difference I see is that enhancement results in the gain of selected
aquatic resource function(s) while rehabilitation returns natural/historic functions to a
degraded aquatic resource. In short I believe this proposal could compensate for wetland
impacts associated with Phase 1 of the Bonner Project. As far as ratios are concerned and
the issue of whether this is enhancement or rehabilitation, I think we need to sit down as a
group and come up with a conclusion of what is acceptable for phase 1 of this project. From
what I understand a majority of the wetland impacts for phase 1 are -for some lower quality
wetland systems and many are man dominated (mowed and maintained) . I believe the plan needs
to be more detailed than it is currently. The Significant Natural Heritage Areas (SNHA)
profile as the draft plan states needs to include specific management action recommendations
and should be part of and integrated into the mitigation plan. We have all heard the term
SMART. The plan needs to be specific, measurable, attainable, reasonable, track able. There
are goals in the plan which we all have our own interpretation of what makes those goals
successful, but the plan needs to be written where those goals are more specific so they can
be measured and tracked as to the success of the project where everyone knows what
constitutes success (i.e. is it a reduction in Phragmites coverage by 50% and an increase of
native species by 50% for a set amount of time: does Phragmites reduction with no native
regeneration count towards anything
etc. ?) .
2. I think the first paragraph of the plan needs to be changed to read "the proposed
mitigation will be used to offset impacts for phase 1 and possibly used for future phases as
determined appropriate at that time." Also remove "wetland impacts of future phases could be
as high as 50.8 acres." We don't know if or what the impacts may be for future phases. At
the time of these future phases, for which we don't know what amount of wetland impacts may
occur or if any wetland impacts will occur, we can decide if there is additional restoration
(rehabilitation) acreages available from this particular wetland rehabilitation site. I
don't think we are willing to commit to so called credits for future phases of this project
because of the uncertainties surrounding the future phases, the dynamic nature of the barrier
island systems, and the past failures and difficulty of Phragmites control/management. Is it
NCDOT's intention to make this site part of your UMBI?
1

Original Message
From: Smyre, Elizabeth A {mailto:[e-mail]]
Sent: Wednesday, May 11, 2011 5:28 PM
To: Benjamin, Pete; Biddlecome, William J SAW; Brittingham, Cathy; Broili, Thayer; Bryant,
Mike; Clarence.Coleman(dot.gov; Cox, David R.; Gledhill-earley, Renee; Gregson, Jim; Huggett,
Doug; Jordan, Gary; Hart, Kevin; Lane, Stephen; Lucas, Ron; McLendon, Scott C SAW;
Militscher, Chris; Murray, Mike; smtp-Sechler, Ron; Stewart, Dennis; Wainwright, David;
Wilber, Pace; Wilson, Travis W.; Wrenn, Brian
Cc: Paugh, Leilani Y; Weatherford, Morgan D
Subject: Bodie Lighthouse draft plan.docx
B-2500 Merger Team & Co. :
Attached is the latest draft of the wetland mitigation plan (the Bodie Island Lighthouse pond
mitigation) for the Bonner Bridge project. NCDOT is still working with the NPS on many of the
details, but we'd also like your feedback on the current draft.
Please review and send any comments to LeiLani Paugh at 1paughOncdot.gov as soon as possible.
Thanks,
Beth
***Please note my phone number has changed, effective March 30, 2011- see
below.***
Beth Smyre, P.E.
Project Planning Engineer
NC Department of Transportation
Project Development & Environmental Analysis Branch
1548 Mail Service Center
Raleigh, NC 27699-1548
(919) 707-6043
Email correspondence to and from this sender is subject to the N.C. Public Records Law and
may be disclosed to third parties.
Classification: UNCLASSIFIED
Caveats: NONE
2

NT OF
United States Department of the Interior NATIONAL 7
y
Lei _~P • PARK
Ph ^` � NATIONAL PARK SERVICE SERVICE;
OUTER BANKS GROUP
Fort Raleigh National Historic Site Wright Brothers National Memorial
Cape Hatteras National Seashore
L7621 (CAHA)
1401 National Park Drive
Manteo,North Carolina 27954
SEP 1 6 2009
Ms. Beth Smyre, P.E.
Project Planning Engineer
NC Department of Transportation •
Project Development & Environmental Analysis Branch
1548 Mail Service Center
Raleigh,NC 27699-1548
SUBJECT: Bonner Bridge Wetland Mitigation
Dear Ms. Smyre:
The National Park Service (NPS)requests that NC Department of Transportation
(NCDOT) consider wetland mitigation related to highway alignment changes north of the
current Bonner Bridge by enhancing wetlands of high conservation value within Cape
Hateras National Seashore. Specifically,wetland enhancement would include control of
exotic plants in wetlands on Bodie Island. Control of common reed (Phragmites
australis) has been identified by the NPS and the North Carolina Natural Heritage
Program (NC NHP) as a management need for the two sites listed on the state's Registry
of Natural Heritage Areas (NHAs): Bodie Island Roadside Ponds and Ditches (Site ID
#1090; 1045 acres) and Bodie Island Lighthouse Pond (Site ID#1134; 255 acres). NC
NHP maps of these two NHAs are enclosed, and additional detail can be requested from
the NC NHP.
Bodie Island Roadside Ponds and Ditches (Site ID#1090) is described as: "Brackish to
nearly fresh marshes provide important feeding area for several thousand wintering snow
geese. Gulls, terns,herons, egrets, shorebirds and waterfowl forage on ponds. Rails
(black and yellow)widespread in brackish marshes. Some of most heterogeneous
brackish marshes in NC."
Bodie Island Lighthouse Pond (Site ID#1134) is described as: "Pond is habitat for very
large numbers of waterbirds making it excellent bird watching site. Rare black-necked
stilt nests at edge of pond. Federally Endangered peregrine falcon forages around pond
in the fall. "Threatened" sal marsh spikerush present, as well as beaked spikerush and
Olney's threesquare. Black rail has been noted heard calling in the marsh near the
boardwalk. Watch List plans include Schoenoplectus americanus(formerly known as
Scirpus olneyi)."
TAKE PR 1 DE` ,
14AMERICA

The signed(in 1987) Letter of Intent and Agreement states that "the NPS agrees to
manage and maintain these Natural Heritage Areas for the perpetuation and protection of
their primary biological resources". In some cases, manipulation--by burning,mowing,
cutting, control of exotic species,managed water levels, or placement of dredged
materials -- may be appropriate to control natural vegetational succession and maintain
habitats for rare or special-interest species... A monitoring program will be maintained
for endangered and threatened species of animals and plants."
Planning for enhancement of these NHAs would require close coordination among NC
DOT,NPS, and NC NHP. A survey of infested acres would be needed to determine if
control of exotic plants within these NHAs would meet the minimum required mitigation
acreage. Our current understanding of the mitigation to be performed is that
approximately 14 acres of mitigation would be appropriate based on approximately 3.5
acres of disturbance and mitigation occurring at a 4 to 1 ratio. In the event that these two
NHAs yield insufficient acreage to fulfill the mitigation acreage requirements, then(a)
additional enhancements would be identified for the Natural Heritage Areas or(b)
additional acreage for exotic plant control would be identified on Bodie Island on NPS-
land within Cape Hatteras National Seashore. A Wetland Mitigation Plan would be
developed and agreed upon prior to implementation of mitigation.
We look forward to further discussion of this proposal with you and NC NHP. Ms.
Meghan Carfioli will be the primary point of contact on this issue for the NPS.
Sincerely,
'IAA 140 2
Michael B. Murray
Superintendent
Enclosures: Maps

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