NCDOT 106-12 B-2500 Phase I SAV Mitigation

Brittingham, Cathy
From: Brittingham, Cathy
Sent: Friday, May 12, 2023 2:28 PM
To: Lancaster, Jamie J
Cc: Williams, Paul C; Stanton, Tyler P; Daisey, Greg; Kathy Herring; Ward, Garcy; Harrison,
James A;Wilson, Travis W.; [e-mail]; Bodnar, Gregg
Subject: RE: [External] Bonner SAV Mitigation Closeout
Attachments: B-2500 Phase I SAV Mitigation Site 106-12 close out letter May 12 2023.pdf
Hello,
Please see attached DCM response.
Sincerely,
Cathy Brittingham
Cathy Brittingham,Transportation Project Coordinator
N.C. Division of Coastal Management
[phone] phone
[e-mail]
Please visit www.nccoastalmanaqement.net to subscribe to Coastal Management's quarterly newsletter,the CAMAgram.
Mailing Address: Physical Address:
1617 Mail Service Center 512 North Salisbury Street
Raleigh,NC 27699-1617 Archdale Building
12th Floor, Room 1204G
Raleigh,NC 27604
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?
From: Kathy Herring<[e-mail]>
Sent:Thursday, February 2, 2023 2:17 PM
To: Brittingham, Cathy<[e-mail]>; Howell,Jonathan<[e-mail]>; Daisey,
Greg<[e-mail]>; Paugh, Leilani Y<[e-mail]>;[e-mail];
[e-mail]; Wilson,Travis W.<[e-mail]>; Matthews, Monte K CIV USARMY
CESAW (US<[e-mail]>; Harrison,James A<[e-mail]>; Ward, Garcy
<[e-mail]>; Kathy Herring<[e-mail]>
Cc:Williams, Paul C<[e-mail]>; Stanton,Tyler P<[e-mail]>; Cox, Marissa R
<[e-mail]>; Lancaster,Jamie J <[e-mail]>; Conforti,John G <[e-mail]>; Pete
Stafford <[e-mail]>
Subject: [External] Bonner SAV Mitigation Closeout
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All,
i

Attached is the NCDOT's request letter to close out the Bonner Bridge Replacement Project,Submerged Aquatic
Vegetation (SAV) Mitigation, Dare County,TIP No. B-2500 Phase I: DWR Project No. 20151222; DCM Major Modification
to Permit# 106-12.
If comments warrant,we can schedule a meeting to discuss. Please send comments by Friday, February 17, 2023.
Thank you,
Kathy
I have also attached the SAV Mitigation plan.
KATHY HERRING
Senior Project Scientist
8601 Six Forks Road
Forum 1, Suite 700
Raleigh, NC 27615
919.971.4367 C
[e-mail]
www.rkk.com
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ROY COOPER = c
Governor / 11
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ELIZABETH S.BISER ,,,,,,.„,. 4
Secretary `wnrn *"..=
BRAXTON DAVIS NORTH
Director Environmental Quality
May 12,2023
Jamie Lancaster,P.E.,Unit Head
Environmental Analysis Unit
N.C. Department of Transporta'.i in
1598 Mail Service Center
Raleigh,NC 27699-1598
RE: Bonner Bridge Replacement Project,TIP No.B-2500 Phase I, Submerged Aquatic Vegetation(SAV)
Mitigation and Monitoring,New CAMA Major Permit 106-12 issued on September 19,2012 and Major
Modification issued on December 15,2015.
Dear Mr.Lancaster:
The N.C.Division of Coastal Management(DCM)has reviewed the N.C. Department of Transportation
(NCDOT)letter dated 2/2/23 regarding mitigation and monitoring of impacts to submerged aquatic vegetation
(SAV)associated with TIP B-2500 Phase I. DCM has also reviewed the annual monitoring reports,participated
in multiple interagency discussions, and assessed site conditions.
Compensatory mitigation for permanent impacts to SAV
CAMA Major Permit No. 106-12,which was issued by DCM on September 19,2012 for the Bonner
Bridge Replacement Project,authorized 2.66 acres of permanent impacts to SAVs due to their location
within the alignment of the new Marc Basnight Bridge. Mitigation measures included the following: (1)
Removal of the existing Herbert C.Bonner Bridge,thus un-shading 1.38 acres of suitable SAV habitat;
and(2)Construction of a 500-foot long wavebreak structure within Pamlico Sound as an experimental
approach to attenuate wave energy in patchy SAV habitat and provide a suitable wave climate to promote
an increase of SAV coverage as mitigation for the remaining 1.28 acres of SAV impacts.Monitoring of
the unshaded area was not required by the CAMA permit.
Biannual and annual monitoring of the wavebreak structure and adjacent area included seagrass cover,
wave energy monitoring, sediment elevation surveys, success of relocated SAV,and wavebreak epibiota
assessments. Extensive analysis of the wavebreak structure was performed by NCDOT and the private
consulting firms CSA Ocean Sciences,Inc. and RK&K Engineering.
DCM agrees, in consultation with the N.C.Division of Marine Fisheries(DMF),that the wavebreak
structure provides adequate compensatory mitigation for 1.28 acres of permanent SAV impacts that were
incurred by the Bonner Bridge Replacement, TIP No.B-2500 Phase I. DCM agrees that no further
monitoring of the mitigation site is required,and that the mitigation requirements have been satisfied.
Future Mitigation
In the 2/2/23 letter,NCDOT requested to"maintain the ability to propose adding to or manipulating the
current wavebreak structure to continue to create a suitable colonization environment for seagrass to be
used for any SAV mitigation that may be required in future projects along NC Highway 12." DCM
would like to clarify that this mitigation action should not be used for future mitigation opportunities.
Q Carolina Departme Environmental Quality Coastal Management
NORTH GROLI D_E
J�/}1 DWRNorth Wetlands Unit 512 nt Northof Salisbury Street 1617 MailDivision Serviceof Center Raleigh.North Carolina 27699-1617
warm.'of Environmental Q.aliN /.' 919.707.9149

.'., , ,'
Page 2 of 3
May 12, 2023 letter
This is in accordance with Condition No.2 of the Major Modification of CAMA Permit 106-12 that was
issued on December 15,2015 which states:
2)The approved SAV mitigation plan shall not generate any excess mitigation credits.
DCM notes that there were multiple challenges during the implementation of the wavebreak structure.
These included,but are not limited to,the formation of a persistent,dynamic sand shoal to the south of
and immediately adjacent to the wavebreak structure, scour pits that developed underneath the structure,
subsidence of some wave attenuator units,and relocated seagrass from the wavebreak footprint that did
not survive. It is strongly recommended that NCDOT conduct additional interagency coordination to
develop strategies that will avoid similar challenges when SAV mitigation is required for future NCDOT
projects. Further use of this type of mitigation may have concerns based on location,durability,and
stability, and scope and scale of the future mitigation.
Ongoing Maintenance
Failing to maintain the structure and signage could result in negative impacts to the mitigation site and
boater safety. This could include the generation of marine debris if the structure deteriorates,a return to
pre-project conditions which would negate the mitigation,and potential vessel impacts if signage isn't
maintained. Although no further monitoring of SAV is required,operational conditions within the permit
require ongoing maintenance of the wavebreak structure. These include Condition Nos.25 and 26 of the
Major Modification of CAMA Permit 106-12 issued on December 15,2015:
25)The permittee shall maintain the authorized work in good condition and in conformance with
the terms and conditions of this permit for the life of the permitted wavebreak structure. The
permittee is not relieved of this requirement if he abandons the project without having the permit
transferred to a third party.
26)Unless otherwise approved by DCM, in consultation with USACE and DWR,the approved
SAV wavebreak structure,required signage and markings shall be inspected annually and shall be
maintained in perpetuity and owned by the permittee or its approved designee.
Monitoring Temporary Impacts to SAV
Condition No.32 of CAMA Permit 106-12 states:
(32) Due to the possibility that compaction from jetting containment structures, shading under
the work trestle,trenching of electric lines,mechanized clearing,and/or other site alterations
might prevent the temporary Coastal Wetland and SAV impact areas from re-attaining pre-project
functions,the permittee shall provide an annual update on the Coastal Wetland and SAV areas
temporarily impacted by this project. This annual update shall consist of photographs and a brief
written report on the progress of these temporarily impacted areas in re-attaining their pre-project
functions. Within three years after project completion,the permittee shall hold an agency field
meeting with DCM to determine if the Coastal Wetland and SAV areas temporarily impacted by
this project have re-attained pre-project functions. If at the end of three years DCM determines
that the Coastal Wetland and SAV areas temporarily impacted by the project have not re-attained
pre-project functions,DCM will determine whether compensatory mitigation shall be required.
During construction and demolition,numerous project modifications were authorized which may have
changed the final amount of temporary impacts to SAVs. DCM agrees with the NCDOT commitment
D.,,,----- Q NorthDWRWetlands Unit 512 Carolina Department of
North EnvironmentalSalisburyStreet Quality1617 Mail DivisionService of CoastalCenter Management
North Carolina 27699-1617
NORTH GARC. ""`"
°'a"'° 'au.,,,,
"\ �� 919.707.9149

Page 3 of 3
May 12, 2023 letter
contained within the 2/3/23 letter for an agency field meeting in the Summers of 2023 or 2024. DCM
strongly prefers that the meeting be conducted in Summer 2023. During the site visit it will be important
to review the temporary impact areas to determine if the SAV areas temporarily impacted by this project
have re-attained pre-project functions.
DCM would like more information,including results of the agency field meeting,about the SAV
temporary impact areas before we agree that no further monitoring is required for SAV temporary
impacts.
DCM appreciates the efforts of NCDOT and its consultants during implementation of this innovative
compensatory mitigation plan. A vast amount of data was collected that will undoubtedly be extremely valuable
for future discussions about SAV mitigation strategies in North Carolina and beyond.
Please contact Greg Daisey at [e-mail] or me at [e-mail] if you have any
questions or concerns.
Sincerely,
I
Cell
Cathy Britti am
Transportation Project Coordinator
CC: Kyle Barnes,USACE
Garcy Ward,DWR
Paul Williams,NCDOT
Tyler Stanton,NCDOT
Jimmy Harrison,DMF
Travis Wilson,WRC
Gregg Bodnar, DCM
Kathy Herring, RK&K
D E Q'_ NorthDWRWetlands Unit 512 Carolina Department ofNorth EnvironmentalSalisburyStreet Quality11617 Mail I Division ofService CoastalCenter MI anaRaleighgement
/� ,North Carolina 27699-1617
°ua;\,..." 919.707.9149

Brittingham, Cathy
From: Harrison, James A
Sent: Tuesday, February 21, 2023 4:40 PM
To: Brittingham, Cathy; Deaton, Anne
Cc: Daisey, Greg
Subject: Re: [External] Bonner SAV Mitigation Closeout
Good afternoon Cathy,
Thank you again for providing that information during our call. As mentioned during the call, it appears that the
mitigation requirement for the permanent impacts associated with Phase I of the Bonner Bridge Replacement
project has been satisfied and can be closed out. As you noted on the call,there is still some
uncertainty/questions regarding the temporary impacts associated with the bridge-DMF supports DCM's
request to adhere to the permit condition requiring the applicant to meet and coordinate with agency staff to
ensure this mitigation requirement has been successfully addressed. DMF also supports the requirements
included in the issued permit regarding the maintenance and upkeep of the structure and signage. Failing to
maintain the structure and signage could result in negative impacts to the mitigation site through marine debris
(if the structure breaks), return to pre-project conditions (negating the mitigation), and increased vessel impacts
(if signage isn't maintained). This is particularly true if it is the intention to continue to use this site as somewhat
of a mitigation bank. Finally,the closeout letter indicates the potential "adding to or manipulating of' the
wavebreak structure. DMF would recommend that the resource agencies be given the opportunity to review and
comment on any plans that may alter/adjust the structure prior to these events occurring.
If there is anything else that I can do to help out with this process,please let me know and I'll take care of it
asap. Thanks Cathy, and thank you again for your continued coordination and patience!
Jimmy
Jimmy Harrison
Habitat and Enhancement `section
NC Division of Marine risheries
[e-mail]
252-9+8-3835 (Office)
757-272-3230(Mobile)
tNk,,
.„.o"'\-1..,„
3 :' )I'
"tvery pizza can 6e a personal pizza if you try hard enough and believe in yourself"
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Brittingham, Cathy<[e-mail]>
Sent: Friday, February 17, 2023 15:01
To: Deaton, Anne <[e-mail]>; Harrison,James A<[e-mail]>
1

Cc: Daisey, Greg<[e-mail]>
Subject: FW: [External] Bonner SAV Mitigation Closeout
Hi Anne and Jimmy,
Here is the response I received from Mark Fonseca, and my response to him and Kathy.
Sincerely,
Cathy
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
1). E Q
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Brittingham, Cathy
Sent: Friday, February 17, 2023 11:48 AM
To: Fonseca, Mark<[e-mail]>; Kathy Herring<[e-mail]>
Cc: Pete Stafford <[e-mail]>; Stanton,Tyler P<[e-mail]>; Daisey, Greg
<G reg.Da i sey @ ncde n r.gov>
Subject: RE: [External] Bonner SAV Mitigation Closeout
Hi Mark and Kathy,
Thank you both for helping me "wrap my head" around the results by even further synthesizing the vast amount
of information that was gathered during the project.
I agree that there was a target of 1.28 acres of new seagrass, but there was not a permit-required target acreage.
2

Hopefully I won't have any more questions as I finish up the DCM response to the 2/2/23 NCDOT letter
requesting agency documentation that no further work is required and that the site is closed.
Sincerely,
Cathy
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
NORTH CAROLiNA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Fonseca, Mark<[e-mail]>
Sent: Friday, February 17, 2023 9:18 AM
To: Brittingham, Cathy<[e-mail]>
Cc: Pete Stafford <[e-mail]>; Kathy Herring<[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
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Hi Cathy,
I spoke with Kathy last night and I now understand your confusion.
You were correctly utilizing the Reference areas as they were originally designed, as being a baseline against which
changes in the wave forecast areas would be compared.
As we pointed out in the final project report, it is our opinion that much of the reference areas footprint were
compromised by being in what appears to be the zone of influence of the wavebreak.
3

We had reference areas increase in cover dramatically and became almost completely covered. As we observe the
larger pattern, it appeared—although with a single site like this it is not a bulletproof conclusion—that there was a much
larger effect and that as the seagrass expanded it may well have contributed to wave attenuation in a self-perpetuating
fashion. We think that there was a cascade of seagrass increase down the shoal precipitated by the wavebreak which
enveloped a good deal of the reference areas which were placed immediately adjacent to the model forecast wave
reduction zones.
We can find no indication of these areas having this degree of seagrass cover from freely available imagery going back
many years. Also, other areas on the shoal did not experience this degree of seagrass patch coalescence.
All that said,this cannot be proven unequivocally not without a statistically valid landscape scale study of regional
seagrass patch dynamics during the time period surrounding the wavebreak creation to verify that this was isolated to
the wavebreak vicinity. However,we have been qualitatively observing seagrass cover over time in the region and have
not observed any similar radical expansion of seagrass cover.
Importantly it is my understanding that while we had a target of 1.28 acres of new seagrass, there was not a permit-
required target acreage—Kathy, correct me if I am wrong.
Sorry for the long email—we can discuss by phone or Teams, etc. if you would like.
Boarding plane—best regards
Mark
Mark S. Fonseca, Ph.D.
CSA Ocean Sciences Inc.
Chief Sciences Officer
8502 SW Kansas Avenue I Stuart, Florida 34997
[e-mail]
Primary/Cell: [phone]
CSA Main:[phone]
e'llikil‘
CSA
www.csaocean.com
From: Brittingham, Cathy<[e-mail]>
Sent:Thursday, February 16, 2023 3:02 PM
To: Fonseca, Mark<[e-mail]>
Cc: Pete Stafford <[e-mail]>; Kathy Herring<[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
CAUTION:This email originated from outside of the Conshelf.com organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
That works for me, or next week. Thank you!
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
4

Office: [phone]
[e-mail]
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
11-1-1)::=EQ /0)
NO-2TH CAROLiNA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From: Fonseca, Mark<[e-mail]>
Sent:Thursday, February 16, 2023 3:01 PM
To: Kathy Herring<[e-mail]>
Cc: Brittingham, Cathy<[e-mail]>; Pete Stafford <[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
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Will do—in our Rhode Island office overseeing candidate interviews. May not get to dive into this until later tomorrow if
that is acceptable?
Mark S. Fonseca, Ph.D.
CSA Ocean Sciences Inc.
Chief Sciences Officer
8502 SW Kansas Avenue Stuart, Florida 34997
[e-mail]
Primary/Cell: [phone]
CSA Main: [phone]
r ^ '
CSA
www.csaocean.com
From: Kathy Herring<[e-mail]>
Sent:Thursday, February 16, 2023 1:53 PM
To: Fonseca, Mark<[e-mail]>
5

Cc: Brittingham, Cathy<[e-mail]>; Pete Stafford <[e-mail]>
Subject: Fwd: [External] Bonner SAV Mitigation Closeout
CAUTION:This email originated from outside of the Conshelf.com organization. Do not click links or open attachments
unless you recognize the sender and know the content is safe.
Hi Mark,would you please respond to this latest email from Cathy?
Thanks!
Kathy
Sent from my Verizon, Samsung Galaxy smartphone
Get Outlook for Android
From: Brittingham, Cathy<[e-mail]>
Sent:Thursday, February 16, 2023, 1:48 PM
To: Kathy Herring<[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
EXTERNAL EMAIL: Do not click links or open attachments unless you trust the 'Sender' and know the content is
safe.
So using August as an example, the reference went from 1.89 acres to 4.43 acres, which is an increase of 2.3x,
and the total all zones went from 17.68 to 30.23, which is an increase of 1.7x. So does that mean that the total
all zones increased at a slower rate when compared with the reference? I'm sitting at my desk if it is easier to
talk versus email.
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
6

NORTH CAROLINA
Department of Environmental Quality
Email rr r�ca es an ence a a
Carolina Public RecordsLati
From: Kathy Herring<[e-mail]>
Sent:Thursday, February 16, 2023 12:48 PM
To: Brittingham, Cathy<[e-mail]>
Cc: Daisey, Greg<[e-mail]>; Stanton,Tyler P<[e-mail]>; Pete Stafford
<[e-mail]>
Subject: Re: [External] Bonner SAV Mitigation Closeout
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Of course!
The heading"total all zones" in the closeout letter is referring to the three wave energy reduction zones of the
wavebreak,the red zone,orange zone and green zone. The %of each zone is the projected. amount of wave energy
reduced.
Please let me know if you have any other questions.
Kathy

Sent from my Verizon, Samsung Galaxy smartphone
Get Outlook for Android
From: Brittingham, Cathy<[e-mail]>
Sent:Thursday, February 16, 2023, 11:57 AM
To: Kathy Herring<[e-mail]>
Cc: Daisey, Greg<[e-mail]>; Stanton,Tyler P<[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
EXTERNAL EMAIL: Do not click links or open attachments unless you trust the 'Sender' and know the content is
safe.
Thanks, Kathy! That's great.
I want to make sure this is documented accurately in the project file, so I'm sorry I am asking some pretty basic
questions. Here is another question:
I was reading the March 2022 final report, and I see these terms in Figure 10: reference zone, red zone (>66%),
orange zone (33-66%), and green zone (5-33%). In addition, in the narrative of the March 2022 final report I
also see a relocation zone, a sand apron zone and a planted area zone. So.... Can you define specifically what is
included in the column "Total All Zones" within the closeout letter?
Thanks for your patience with me!
Sincerely,
Cathy
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
8

NORTH CAROLINA
Department of Environmental Quality
Emailcorrespondence
CarolinaPublic Lay
From: Kathy Herring<[e-mail]>
Sent:Thursday, February 16, 2023 6:05 AM
To: Brittingham, Cathy<[e-mail]>;Stanton,Tyler P<[e-mail]>
Cc: Daisey, Greg<[e-mail]>; Pete Stafford <[e-mail]>; Fonseca, Mark
<[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
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Good morning all,
Yes, it did. Table 1 in the close out letter indicates an increase of 6.65ac in August of 2021 compared to August of 2018
(considered baseline) and an increase of 12.55ac in August of 2022 compared to the August 2018 baseline data.
Due to the difficulty in interpreting the aerial imagery provided by NCDOT photogrammetry in 2017, the NCDOT BAU
tasked RK&K to begin collecting UAV imagery in 2018. The NCDOT decided to use the UAV imagery collected in the first
growing season after construction (August 2018) as baseline data for comparison purposes.
Kathy
9

Table 1. Total submerged aquatic vegetation by survey month and summed for all wave energy reduction zones,
respectively. All values are in acres.
2018 2019 2020 2021 2022
Reference Total Reference Total Reference Total Reference Total Reference Total
All All All All All
Zones Zones Zones Zones Zones
March 0.97 13.37
April 0.31 10.82 1.33 12.11 0.81 13.99
May 1.21 13.93 1.36 15.63 1.50 16.95 2.68 23.03
June 1.63 16.18 1.32 15.27 1.87 17.51 _
July 1.63 17.01 1.96 17.49 2.55 22.21
August 1.89 17.68 2.00 , 18.06 1.74 17.36 2.99 24.23 4.43 30.23
September 1.97 17.97 1.73 17.14 2.07 16.77 3.23 24.51
October 1.88 17.08 1.55 , 16.36 1.99 17.39 , 3.09 24.49 4.89 33.09
November 1.67 17.18 1.94 17.59 3.04 24.93
December 1.54 14.51
From: Brittingham, Cathy<[e-mail]>
Sent: Wednesday, February 15, 2023 3:42 PM
To: Kathy Herring<[e-mail]>; Stanton,Tyler P<[e-mail]>
Cc: Daisey, Greg<[e-mail]>
Subject: RE: [External] Bonner SAV Mitigation Closeout
EXTERNAL EMAIL: Do not click links or open attachments unless you trust the 'Sender' and know the content is
safe.
Hi Kathy and Tyler,
I am reviewing the closeout letter, and I have a question for clarification.
Did the SAV wavebreak result in an overall increase in seagrass coverage of at least 1.28 acres compared to the
baseline?
Sincerely,
Cathy
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
Office: [phone]
[e-mail]
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
10

NORTH CAROLINA J�
Department of Environmental Quality
Email rr n co e s o a ee o a
Carolina
Lat'
From: Kathy Herring<[e-mail]>
Sent:Thursday, February 2, 2023 2:17 PM
To: Brittingham, Cathy<[e-mail]>; Howell,Jonathan<[e-mail]>; Daisey,
Greg<[e-mail]>; Paugh, Leilani Y<[e-mail]>;[e-mail];
[e-mail]; Wilson,Travis W. <[e-mail]>; Matthews, Monte K CIV USARMY
CESAW (US<[e-mail]>; Harrison,James A<[e-mail]>; Ward, Garcy
<[e-mail]>; Kathy Herring<[e-mail]>
Cc:Williams, Paul C<[e-mail]>; Stanton,Tyler P<tstantonc ncdot.gov>; Cox, Marissa R
<[e-mail]>; Lancaster,Jamie J <iilancaster(a)ncdot.gov>; Conforti,John G <[e-mail]>; Pete
Stafford <[e-mail]>
Subject: [External] Bonner SAV Mitigation Closeout
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All,
Attached is the NCDOT's request letter to close out the Bonner Bridge Replacement Project,Submerged Aquatic
Vegetation (SAV) Mitigation, Dare County,TIP No. B-2500 Phase I: DWR Project No. 20151222; DCM Major Modification
to Permit# 106-12.
11

If comments warrant,we can schedule a meeting to discuss. Please send comments by Friday, February 17, 2023.
Thank you,
Kathy
I have also attached the SAV Mitigation plan.
KATHY HERRING
Senior Project Scientist
12

-fi, t_7411
STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION
ROY COOPER J. ERIC BOYETTE
GOVERNOR SECRETARY
February 2, 2023
Ms. Cathy Brittingham
Transportation Projects Coordinator
NC Division of Coastal Management
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh,NC 27699-1617
Re: Bonner Bridge Replacement Project, Submerged Aquatic Vegetation(SAV)Mitigation,
Dare County, TIP No. B-2500 Phase I: DWR Project No. 20151222; DCM Major
Modification to Permit# 106-12
Ms. Brittingham:
Construction of the Marc Basnight Bridge to replace the aging Herbert C. Bonner Bridge over
Oregon Inlet in Dare County, NC began in March 2016 and opened to traffic in February 2019.
The construction of the new bridge permanently impacted approximately 2.66 acres of Submerged
Aquatic Vegetation(SAV)for which mitigation was required from the North Carolina Department
of Transportation (NCDOT). Mitigation measures included removal of the old bridge, thus un-
shading 1.38 acres of suitable SAV habitat. The remaining 1.28 acres of impacted SAV habitat
was mitigated near the project area by installing an engineered structure to attenuate wave energy
and provide a suitable wave climate to promote SAV coverage. The wavebreak is a permanent
`living' structure providing 0.3 acres of hard surface currently colonized by algae, oysters and
other sessile communities as well as utilized by fish and birds.
As outlined in the B-2500 Bonner Bridge Phase I SAV Mitigation Plan, dated September 2015,
the Department has monitored the Bonner Bridge SAV mitigation site since construction of the
wavebreak was completed in January 2017.The final monitoring event was conducted in July 2021
and a final report with a summary of findings was submitted to the resource agencies on 9/29/2022.
Additional data was collected in 2022 and is provided within this request letter.
Mailing Address: Telephone:[phone] Location:
NC DEPARTMENT OF TRANSPORTATION Fax:[phone] CENTURY CENTER BUILDING A
ENVIRONMENTAL ANALYSIS UNIT Customer Service:1-877-368-4968 1020 BIRCH RIDGE DRIVE
1598 MAIL SERVICE CENTER RALEIGH,NC 27610
RALEIGH,NC 27699-1598 Website:www.ncdot.gov

The Bonner Bridge mitigation site is located in Pamlico Sound approximately 3 miles southwest of
Oregon Inlet and consists of a concrete wavebreak structure that is approximately 500 feet long x 5
feet wide x 4 feet tall. According to permit conditions,NCDOT was required to monitor the Bonner
Bridge mitigation site for five years post construction of the wavebreak.
During the project monitoring period, 2017 -2021 annual monitoring reports were submitted to the
appropriate regulatory agencies via email and Connect NCDOT:
https://connect.ncdot.gov/site/Preconstruction/division/div01 B-2500/Natural%20Environment/Forms/Allltems.aspx
These reports included updates of the following parameters cited in NCDOT's permit application:
wave energy (wave characteristics, water level, tide documentation, wave energy distribution),
seagrass (gap closure, change in seagrass cover, biological disturbance), structural/hard surface
(epibiota coverage), and sediment elevation (digital elevation models). These reports also
included, as per permit requirements,photographs and a written report, including a description of
the monitoring methodology, an analysis of the baseline vegetation and seagrass coverage
persistence.
After five years of monitoring, including data from 2022 (year 6), there has been an increase in
overall seagrass coverage of the area compared to the baseline data collected prior to the wavebreak
construction(Table 1). This additional data shows, that the area adjacent to the south side of the
structure is now supporting SAV, and is stabilizing.
May 2022
A VS
August 2022
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October 2022
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Table 1. Total submerged aquatic vegetation by survey month and summed for all wave energy reduction zones,
respectively. All values are in acres.
2018 2019 2020 2021 2022
Reference Total Reference Total Reference Total Reference Total Reference Total
All All All All All
Zones Zones Zones Zones Zones
March 0.97 13.37
April 0.31 10.82 1.33 12.11 0.81 13.99
May 1.21 13.93 1.36 15.63 1.50 16.95 2.68 23.03
June 1.63 16.18 1.32 15.27 1.87 17.51
July 1.63 17.01 1.96 17.49 2.55 22.21
August 1.89 17.68 2.00 18.06 1.74 17.36 2.99 24.23 4.43 30.23
September 1.97 17.97 1.73 17.14 2.07 16.77 3.23 24.51
October 1.88 17.08 1.55 16.36 1.99 17.39 3.09 24.49 4.89 33.09
November 1.67 17.18 1.94 17.59 3.04 24.93
December 1.54 14.51
As the final report shows, the structure also provides biological habitat for various biofauna such
as: fish, shellfish,algae, barnacles, oysters and birds.
Temporary Impact Areas Under and Adjacent to the Bonner Bridge Alignment
The mitigation plan also included monitoring of the temporary impacts due to construction of the
new bridge to determine if the SAV and marsh areas re-attained their pre-project coverage. Project
commitments also dictated that the NCDOT hold an agency field meeting within three years after
project completion. A meeting will be scheduled in the Summer of 2023 or 2024.
We were unable to delineate any recent before construction SAV areas due to cloud cover in the
aerial photography provided by the NCDOT Photogrammetry flights and RK&K was not
contracted to perform the aerial drone surveys until 2019.
The areas of monitoring the temporary impacts were divided between two different engineering
firms. Temporary impact data collected by Axiom Environmental, Inc. includes the area between
the Bonner and Basnight bridges and the area within 25ft of the Sound side (west) of the new
bridge. Their survey area is approximately 6.5 acres (Table 2).
Temporary impact data collected by RK&K (SAV and marsh habitat) utilizing UAS and GIS
delineations began in 2019 and includes 116.2 acres located at the northern end of the Bonner
Bridge where water depths were shallow enough to facilitate vegetative growth. Specifically, the

SAV and marsh delineation area comprised a 600-ft wide corridor from the centerline of the former
Bonner Bridge. The SAV delineation acreage from this area is presented in Tables 3 and 4.
The following tables and figures indicating which area was surveyed all indicate that the seagrass
and marsh areas have increased since construction was completed, and the bridge removed.
Table 2. Summary of Delineation of SAV in Temporary Impact Area 2017-2021 from Axiom
Delineations
Date Temporary Impact Area SAV
Cover
September 2017 1.19 ac
June 2018 0.68ac
June 2019 0.53ac
October 2019 0.37ac
July 2020 0.87ac
October 2020 0.48ac
July 2021 1.99ac
October 2021 1.08ac
Table 3. SAV in Temporary Impact Area by Year Based on RK&K UAS Delineations
Year May SAV Coverage(acres) September SAV Coverage(acres)
2019 5.29* 4.52
2020 7.05 6.90
2021 9.70 10.77
*SAY in bridge shadow was not assessed via aerial imagery
Tables 4 and 5. Seasonal and Annual SAV Acreage from RK&K UAS Delineation of Area under
Temporary Construction Bridge Footprint.
Table 4.
Seasonal SAV Growth Within Temporary Bridge
Footprint
0.600 0.497
< 0.400 0.254
UJ 0.200 0.045 0.040 0.066 0.099 .
0.000
May September May September May September
2019 2019 2020 2020 2021 2021
MONTH/YEAR

Table 5.
Yearly SAV Growth Within Temporary Bridge
Footprint
0.750
0.800
Q 0.600
Q 0.400
cc 0.200 0.085 0.165
0.000
2019 2020 2021
YEAR
Area"unshaded" by Removal of the Bonner Bridge
Removal of the Bonner Bridge occurred in late 2019 and early 2020 and was followed by a drop
in late summer project corridor SAV coverage followed by a significant springtime increase the
next growing season, as indicated in Axiom's final report. Approximately 0.002 acre of SAV was
identified in the southern portion of the Bonner Bridge alignment for the first time in October
2020. A total of 0.40 acre of SAV was identified in the Bonner Bridge alignment in July 2021 and
0.18 acre of SAV was identified in the Bonner Bridge alignment in October 2021. It is anticipated
that the establishment of SAV in the Bonner Bridge alignment is likely to continue.
The following figures from Axiom and RK&K final reports illustrate the aquatic area in the vicinity
of the old Bonner Bridge to show that the seagrass is moving into this `unshaded' area.

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`T1 Arca of Interest Are
2019 2020 Marsh Area Combined;32 19 Ar.) .{ ii °
2019-2020 SAV Area Combned(10.43 Ac,)
May 021ill:' ie
:M Marsh(32 27 x) .• e.
Submerged aquatic wgetahon(SAY)(9 70 ac t.) a ),
September 2021 r ''Jdk
Ire
Marsh(32.SO ac.y ‘, -
St ...-
Stbnerped aquatic v®patauon(SAV)(10.77 sc.) •
RICC N
0 ]00 �00 B0 US Few
1 1 r 1
r+....r rwwr ow •x ...........� 0 100 200 403 Utters
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Figure 4, Comparison of GIS-based SAV and marsh aerial imagery interpretations for the Bonner
Bridge study area in May and September 2021 vs.the combined 2019-2020 SAV and
Marsh interpretations. Note: Current bridge in imagery is the Basnight Bridge.

•
As the construction and monitoring of the wavebreak structure constitutes the SAV mitigation for
the Bonner Bridge Replacement Project(B-2500 Phase I),and the above tables and figures indicate
that the temporary impact areas are on a growth trajectory to attaining their pre-project conditions,
the NCDOT considers the Bonner Bridge SAV Mitigation complete and satisfies NCDOT's
commitments as per conditions of Permit # 106-12, and no further work would be required.
Therefore, the Bonner Bridge, B-2500 Phase I, SAV Mitigation project is proposed for closeout.
NCDOT requests that the appropriate resource agencies provide documentation stating that no
further work is required and that the site is closed. However, the NCDOT would like to maintain
the ability to propose adding to or manipulating the current wavebreak structure to continue to
create a suitable colonization environment for seagrass to be used for any SAV mitigation that may
be required in future projects along NC Highway 12. If you have any questions about this project,
please contact Mr. Tyler Stanton at(919) 707-6156.
Sincerely,
For Jamie Lancaster, P.E., Unit Head
Environmental Analysis Unit
cc: Mr. Kyle Barnes, USACOE
Mr. Monte Matthews, USACOE
Mr. Jonathan Howell,NCDCM
Mr. Garcy Ward,NCDWR
Mr. Travis Wilson,NCWRC
Mr. Paul Williams,NCDOT Division 1
Mr. Tyler Stanton,NCDOT EAU
Mr. John Conforti,NCDOT PMU
Ms. Kathy Herring, RK&K

Brittingham, Cathy
From: Kathy Herring <[e-mail]>
Sent: Friday,January 27, 2023 4:46 PM
To: Brittingham, Cathy; Stanton, Tyler P;Williams, Paul C
Cc: Daisey, Greg
Subject: [External] Re: B-2500 Phase I monitoring and mitigation of permanent and temporary
impacts to SAVs and Coastal Wetlands
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Cathy,
Yes, we are currently doing in-house reviews of the Wetland and SAV documents. It has taken longer than expected to
analyze the 2022 SAV data.
I plan to send out a revised project closeout letter to the agencies and then have a meeting, if discussion of the letter is
warranted.
Paul will be sending the Coastal Wetland temp impact report separately.
Sorry for the delay„
Kathy
Sent from my Verizon, Samsung Galaxy smartphone
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From: Brittingham, Cathy<[e-mail]>
Sent: Friday,January 27, 2023 4:38:13 PM
To: Kathy Herring<[e-mail]>; Stanton,Tyler P<[e-mail]>; Williams, Paul C
<[e-mail]>
Cc: Daisey, Greg<[e-mail]>
Subject: B-2500 Phase I monitoring and mitigation of permanent and temporary impacts to SAVs and Coastal Wetlands
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Hello,
At the 12/6/22 meeting with NCDOT, RK&K and DCM regarding the B-2500 Phase I monitoring and
mitigation of permanent and temporary impacts to SAVs and Coastal Wetlands, my recollection is that there
was additional information that was going to be provided by NCDOT/RK&K. I was wondering if
NCDOT/RK&K would provide an update on the preparation of additional documentation?
The additional documentation included the 2022 SAV data for the wavebreak structure to get more up-to-date
calculations to assist in the agency review and decisions regarding closeout; more specific information about the
status of temporary impacts to SAVs from Phase I, including what was the final amount of SAV temporary
impacts and have all of the areas re-attained pre-project functions; and a temporary impact monitoring report for
Coastal Wetlands similar to the ones that are provided at the annual mitigation monitoring report meetings
conducted by the EAU Monitoring and Stewardship Group.
Please let me know if you have any questions or concerns.
i

Sincerely,
Cathy
Cathy Brittingham
Transportation Project Coordinator, Division of Coastal Management
North Carolina Department of Environmental Quality
Office: [phone]
Cathv.brittinghampncdenr.gov
Mailing Address:
c/o DWR Transportation Permitting Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
Physical Address:
512 North Salisbury Street
Archdale Building, 12th Floor, Room 1204C
Raleigh, NC 27604
11111011,E Q
NORTH CAROLINA
Department of Environmental Quality
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2

Brittingham, Cathy
From: Brittingham, Cathy
Sent: Tuesday, December 6, 2022 1:02 PM
To: Deaton, Anne; Harrison, James A
Cc: Daisey, Greg
Subject: FW: 10/28/22 NCDOT meeting, SAV mitigation and monitoring, B-2500
Attachments: Meeting _Minutes_10_28_22_FinalDraft.docx; B-2500 Bonner Bridge CAMA permit
signed.pcf; B-2500 Major Modification issued, SAV mitigation plan, December 15,
2015.pdf; 8-2500 Phase I SAV and Marsh Survey, February 4, 2022 survey, RK&K.pdf;
B2500_S^''_Year5_AnnualReport_FIN_22March2022 (002).pdf; B-2500 Bonner Bridge
CAMA pe:mit s;gned.pdf
Hi Anne and Jimmy,
I have some updated information to share. This morning, Greg Daisey and I had a Teams meeting with
NCDOT and RK&K to follow-up on the 10/28/22 interagency meeting for B-2500 Phase I SAV mitigation and
monitoring. Here is a brief overview of what was discussed.
• I mentioned during the meeting that comments from DMF are very important to the DCM review. I told
DOT/RK&K that I had sent DMF an email seeking input on this topic, and they asked that I provide
them with your response when it is received.
• Regarding the CAMA permit expectation that the wavebreak structure would provide compensatory
mitigation for me balance of 1.28 acres of permanent SAV impacts, NCDOT/RK&K said that the final
CSA Report dated March 2022 is based on 2021 data. They acknowledged that the March 2022 report
states that"with the initial post-construction decline in acreage, there has been a 1.15-acre net addition
of SAV overall." They said that the 2022 data shows a greater net addition of SAVs. They are going to
compile the 2022 data for agency review, and hopefully that will show that the SAVs have increased by
at least a net amount of 1.28 acres.
• Regarding monitoring of temporary impacts to SAVs, we discussed the Axiom Environmental report
dated August 12, 2022. I noted that the report states that "surveys have found a general rise in coverage
since the end of construction ana removal activities." It was discussed that demolition in the water was
completed in early 2022. DOT/RK&K will review the Axiom Environmental data and provide more
specific information about the status of temporary impacts to SAVs from Phase I, including what was
the final amount of SAV temporary impacts and have all of the areas re-attained pre-project
functions. It was discussed that an interagency field visit during the growing season might be
beneficial.
• After the outstanding issues are resolved, NCDOT intends to distribute a close-out letter requesting that
the agencies agree to close out monitoring for the wavebreak structure.
Please feel free to contact me or Greg Daisey if you would like to talk about any of these issues.
Sincerely,
Cathy
i