20052016 Ver 3_CMDF_Surf City beach bulldozing renewal_190-05_NCWRC_20230915

� North Carolina Wildlife Resources Commission �
Cameron Ingram, Executive Director
MEMORANDUM
TO: Heather Coats
Division of Coastal Management
North Carolina Department of Environmental Quality
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: September 15, 2023
SUBJECT: CAMA Dredge/Fill Permit Renewal for Town of Surf City, 9190-05, Pender / Onslow
Counties, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the permit
renewal with regard to impacts on fish and wildlife resources. The project site is located along the
Atlantic Ocean shoreline within the limits of the Town of Surf City. Our comments are provided in
accordance with provisions of the Coastal Area Management Act (G.S. I I3A-100 through I I3A-128), as
amended, Sections 401 and 404 of the Clean Water Act, as amended, the Endangered Species Act of
1973, as amended (16 U.S.C. 1531 et seq.), the Fish and Wildlife Coordination Act (48 Stat. 401, as
amended; 16 U.S.C. 661 et seq.), the Magnuson -Stevens Fishery Conservation and Management Act
(FCMA), as amended (16 U.S.C. 1801 et seq.), and the Migratory Bird Treaty Act (16 U.S.C. 703-712 et
seq.).
Surf City is proposing to renew Permit 9190-05 that allows traditional beach bulldozing methods along its
managed ocean shoreline. Material would be pushed from the mean low low water line landward along
the beach profile at -1' below grade to even out escarpments and rebuild the existing dune system as
needed. During the initial and subsequent reviews of this proposal, this activity is proposed to occur only
on a small scale to provide immediate repair to badly damaged dune systems after coastal storms and
between large scale nourishment events. It is assumed this is the continued management practice.
The NCWRC participated in previous project reviews and understands the concern Surf City has
regarding beach erosion. We appreciate the proposed project standing as an island wide permit and
project area rather than left to individual property owners.
As mentioned previously, continued disturbance from beach bulldozing can have an adverse impact to the
benthic community and therefore the foraging habitat of shore and water birds. Population numbers of
worms, crabs, and other micro fauna are lowered after such events; therefore, beach bulldozing should
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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only occur on an as needed basis and not as a regular maintenance activity, perhaps being triggered by a
set slope or shore grade based on the model used in the island's coastal storm damage reduction plan.
The NCWRC does not object to permit renewal provided all conditions in Permit 9190-05, including the
April 1 — November 15 moratorium, remain. These dates encompass both the shorebird and sea turtle
nesting moratoria and would provide protection for federally and state protected species such as piping
plover (Charadruis melodus), rufa red knot (Calidris canutus rufa) and the Kemp's ridley (Lepidochelys
kempi), leatherback (Dermochelys coriacea), loggerhead (Caretta caretta), and green (Chelonia mydas)
sea turtles. In the event of emergencies during this time, consultation with the US Fish and Wildlife
Service and the NCWRC should be initiated to determine the best response to minimize impacts to these
resources.
We appreciate the opportunity to review and comment on this permit modification. If you need further
assistance or additional information, please contact me at maria.dunn&ncwildlife.org or [phone].