20052016 Ver 1_No Written Concurrence_20191016

Strickland, Bev
From: Mairs, Robb L
Sent: Wednesday, October 16, 2019 8:51 AM
To: Coats, Heather; Dunn, Maria T.; [e-mail]; Hair, Sarah E CIV CESAW
CESAD (US)
Subject: RE: FW: FW: [EXTERNAL] Surf City dune restoration project- Minor Modification
request to Permit #190-05
Hey Heather,
Thanks for the updated narrative, and I believe we discussed this at the office as well. Based on the work being
proposed above the MHW boundary, this project would not require written approval from the DWR (DWR#2005-2016).
Thanks again,
Robb Mairs
Environmental Specialist II
Division of Water Resources
North Carolina Department of Environmental Quality
910 796.7303 office
robb.mairsa-ncdenr.gov
https://deg.nc.gov/about/divisions/water-resources/water-resources-permits/wastewater-branch/401-wetlands-buffer-
ep rmits
127 Cardinal Drive Extension
Wilmington, NC 28405
T
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Coats, Heather
Sent: Tuesday, October 8, 2019 11:20 AM
To: Dunn, Maria T. <[e-mail]>; [e-mail]; Hair, Sarah E CIV CESAW CESAD (US)
<Sarah.E.Hai [e-mail]>
Cc: Mairs, Robb L <[e-mail]>
Subject: FW: FW: FW: [EXTERNAL] Surf City dune restoration project- Minor Modification request to Permit #190-05
Hi ladies & Robb,
Please see the updated narrative for the Surf City dune restoration project (minor modification of CAMA permit 190-05)
acknowledging that no dune planting will occur after April 30 and let me know if you have any questions or comments.
Thanks!

Heather
Heather Coats
Beach & Inlet Management Project Coordinator
Division of Coastal Management
North Carolina Department of Environmental Quality
910 796 7302 office
heather. coats(cDncdenr.gov
127 Cardinal Drive Extension
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Matthews, Kathryn [mailto:kathryn [e-mail]]
Sent: Tuesday, September 10, 2019 2:21 PM
To: Coats, Heather <[e-mail]>
Cc: Hair, Sarah E CIV CESAW CESAD (US) <[e-mail]>; Dunn, Maria T. <[e-mail]>;
0ohn [e-mail]; [e-mail]
Subject: Re: FW: FW: [EXTERNAL] Surf City dune restoration project- Minor Modification request to Permit #190-05
• External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
amCcDnc.gov
Thanks, I would like the narrative corrected, so that there is no confusion next spring. Also, if you would
incorporate into the permit the five conditions I listed at the bottom of my email, that would be great.
Thanks,
Kathy
On Tue, Sep 10, 2019 at 1:21 PM Coats, Heather <heather. coats kncdenr. gov> wrote:
Hi everyone,
Please see Jamie's response below regarding clarification of the proposed dune planting dates for the Surf City dune
reconstruction project permit modification request and let me know if his email is sufficient for the record or whether
you'd like the narrative corrected. We can also condition any authorization issued accordingly.
Please let me know if you have any further questions or comments or if I can help with anything else.
Heather

Heather Coats
Beach & Inlet Management Project Coordinator
Division of Coastal Management
North Carolina Department of Environmental Quality
910 796 7302 office
heather. coats(cancdenr.gov
127 Cardinal Drive Extension
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Jamie Pratt [mailto:[e-mail]]
Sent: Wednesday, September 4, 2019 12:04 PM
To: Coats, Heather <[e-mail]>
Cc: Ashley Loftis <[e-mail]>
Subject: Re: FW: [EXTERNAL] Surf City dune restoration project- Minor Modification request to Permit #190-05
• xternal email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
am nc. ov
Hi Heather-

Yes, that was an oversight on my part. Sorry about that. All planting will be completed by April 30, as
indicated by the italicization text. I forgot to pull the other statement out of the narrative. Thank you for
catching that.
Jamie
On Wed, Sep 4, 2019 at 11:49 AM Coats, Heather <heather. coats kncdenr. gov> wrote:
Hi Jamie & Ashley,
Kathy called my attention to the language in the dune planting section still referencing planting in May/June.
Can you please confirm that it was an oversight and the intent is now to complete all work by April 30?
Please review her comments let me know if you have any questions about her comments below? I am still
waiting to hear back from the USACE, NCWRC & DWR, so please be aware that there may be some
additional comments/conditions.
Dune Planting
Following the completion of the project, a contractor will be hired to plant vegetation in the dunes in
order to provide stabilization and encourage further dune growth. All dune planting associated with this
permit application will be completed by the normal April 30 environmental moratorium. A small tractor
will be used to bore holes and place the plants, and a water truck will be used to water the planted
dunes. Dune plantings will occur along the entire 32,500 linear feet of oceanfront dune system of Surf
City within the spatial parameters of this proposed dune template. The total potential square footage of
plantings is approximately 2,181,946 square feet or 50 acres. Dune plantings following beach and dune
construction will most likely consist of Sea Oats (Uniola paniculata), transplanted from a greenhouse,
and planted as sprigs in late spring/early summer just before they come out of dormancy. The timing of
the initial planting is critical to ensure the Sea Oats have a chance to survive and thrive. Final planting
times and duration depend upon the completion of the dune construction and contractor availability,
but a work time from of 4-6 weeks in April to June can be used for planning purposes. Sea Oats will be

planted from elevation 8.0' NAVD to the landward extent of the dune crest on 2 foot centers. Adjacent
planting rows will be staggered to form an offset planting pattern along the entire stretch of constructed
dunes.
Thanks!
Heather Coats
Beach & Inlet Management Project Coordinator
Division of Coastal Management
North Carolina Department of Environmental Quality
910 796 7302 office
heather. coats(cancdenr.gov
127 Cardinal Drive Extension
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Matthews, Kathryn [mailto:kathryn [e-mail]]
Sent: Wednesday, September 4, 2019 11:08 AM
To: Coats, Heather <[e-mail]>
Cc: Hair, Sarah E CIV CESAW CESAD (US) <[e-mail]>; Mairs, Robb L <[e-mail]>;
Dunn, Maria T. <[e-mail]>; Dail, Jason <[e-mail]>; Wilson, Debra
<[e-mail]>; John Ellis <john [e-mail]>; Stojsavljevic, Katie<[e-mail]>
Subject: Re: [EXTERNAL] Surf City dune restoration project- Minor Modification request to Permit #190-05

External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
[e-mail]
Hi Heather,
I do not object to the work proposed, and I am pleased to see that all of the work is proposed to be
conducted during the winter work window, including the dune planting. However, there is additional
language in the project description that indicates that dune planting may extend beyond April 30
and into June. I am concerned that this may happen if they are unable to start the project quickly
this fall, because 32,500 If is quite a long distance to cover, even with a tractor and water wagon. I
recommend that dune planting begin as quickly as possible on the portions of beach that were
completed in the spring of 2019, in order to finish dune planting prior to the beginning of sea turtle
nesting season.
American beachgrass (Ammophila breviligulata) is a dune species that may be successfully planted
in fall, winter, and spring, and bitter (seaside) panicum (Panicum amarum) also does well when
planted in late winter, spring, or fall (Hosier 2018; Shadow 2007; Lamphere 2006). The applicant
may wish to consider using these species that can be planted during larger portions of the winter
work window, which will allow dune planting to begin as early as November 16.
It is the Corps' decision whether or not they have jurisdiction for these activities, but as we've
discussed this summer, if there is no federal nexus, then it becomes very difficult to authorize take
of listed species. Because the likelihood of take of listed species increases substantially after April
30, we recommend that the project activities not extend past that date (including dune planting).
Alternatively, if FEMA is involved up -front, they may wish to consult with us on the portions that they
are funding (if any), and then we would have a federal nexus to draft and issue a BO for the
proposed activities, if needed. It is the decision of the federal permitting or funding agency whether
or not to request initiation of consultation.
As we have discussed, the Service and NCWRC are coordinating the development of a set of
guidelines for dune planting during the sea turtle nesting season. However, these guidelines are
intended for much smaller projects that can be conducted using ATVs and similar equipment, not
for projects that involve miles of shoreline. However, there is the possibility that, if a significant
amount of dune planting is completed prior to April 30, the remainder could be done after that date if
the guidelines are applicable and can be followed. At this time, we have not finalized the applicable

length of dune planting that will be covered by the guidelines, but we hope to have final guidelines
in the next few weeks.
Additionally, on April 4, 2019, NCDCM, NCWRC, USFWS and TI Coastal Services agreed that
instead of removing and screening material that had been placed before screening began, that the
area would be revisited in the fall to determine if rock removal actions are needed. This is an
important component of this project in whole and FEMA is aware of this agreement as they had a
representative present during the site visit and discussion. What is the status of this
determination? Has anyone from NCDCM been out there to see how the material looks now?
Below are my preliminary recommended conditions for the construction. After discussion with the
agencies, I may have other conditions to recommend.
1. Work shall only be conducted during the winter work window (November 16 to April 30).
2. Prior to sand placement, all derelict material, large amounts of rock, or other debris must be
removed from the beach to the maximum extent possible.
3. During construction, trash and food items shall be disposed of properly either in predator -proof
receptacles, or in receptacles that are emptied each night to minimize the potential for attracting
predators of piping plovers and red knots.
4. Only beach compatible fill shall be placed on the beach or in any associated dune
system. Beach compatible fill must be sand that is similar to a native beach in the vicinity of the site
that has not been affected by prior sand placement activity. Beach compatible fill must be sand
comprised solely of natural sediment and shell material, containing no construction debris, toxic
material, large amounts of rock, or other foreign matter. The beach compatible fill must be similar in
both color and grain size distribution (sand grain frequency, mean and median grain size and
sorting coefficient) to the native material in the Action Area. Beach compatible fill is material that
maintains the general character and functionality of the material occurring on the beach and in the
adjacent dune and coastal system. In general, fill material that meets the requirements of the most
recent version of the North Carolina Technical Standards for Beach Fill (15A NCAC 07H .0312) is
considered compatible.
5. The proposed sand screening process to remove gravel should be conducted for the entirety of
the project. Material placed on the beach shall be qualitatively inspected daily to ensure
compatibility. If the inspection process finds that a significant amount of non -beach compatible

material is on or has been placed on the beach, all work shall stop immediately, and the NCDCM
and/or Corps will be notified by the permittee and/or its contractors to determine the appropriate
plan of action. Required actions may include immediate removal of material and/or long-term
remediation activities.
Literature cited
Hosier, P.E. 2018. Seacoast Plants of the Carolinas: A New Guide for Plant Identification and Use in the
Coastal Landscape. Sea Grant Publication UNC-SG-18-01. University of North Carolina Press. 492 pp.
Lamphere, J. 2006. Plant Guide for bitter panicum (Panicum amarum). USDA Natural Resources
Conservation Service (NRCS) Golden Meadow Plant Materials Center, Galliano, LA 70874.
Shadow, R. A. 2007. Plant fact sheet for Sea oats (Uniola paniculata L.). USDA NRCS, East Texas Plant
Material Center, Nacogdoches, TX 75964.
I hope all of you are safe this week. Please let me know if you have questions or concerns.
Kathy
On Tue, Sep 3, 2019 at 5:12 PM Coats, Heather <heather. coats kncdenr. gov> wrote:
Hello everyone,
TI Coastal Services, Inc., on behalf of The Town of Surf City, has submitted a minor modification request to
CAMA/Dredge & Fill Permit No. 190-05 (DWR No. 052016 & COE Action ID No. 2006-00158).
CAMA/D&F Permit No. 190-05 was issued to the Town of Surf City on 12/5/05 for a one-time dune
restoration project via beach bulldozing with the option to also truck in sand to rebuilt dunes where needed.
The permit has remained active since that time, with minor modifications issued for additional beach
bulldozing activities on 4/12/07, 3/10/08, 11/26/08 and 4/16/10. The permit was also renewed on 3/18/09,
1/9/13, 12/12/14, 11/7/16 and most recently on 1/29/19. The current expiration date for the permit is
12/31/20.
An emergency general permit was issued to the Town on 9/28/18 to allow the reconstruction of the dune via
truck haul. Through coordination with NCWRC and USFWS, work was allowed prior to the November 15

window, but was conditioned that work be completed prior to May 1 (later amended to April 1) without
further agency coordination and approval. The Town started work in March 2019. The allowance of work
was coordinated through April 30, 2019 and the project was halted on that date. According to the applicant,
approximately
85,000 cubic yards of material was placed on the beach to reconstruct the dune during that time. A concern
with sand compatibility of the trucked in material was also discussed during the project.
The Town is proposing to continue restoration of the frontal dune that eroded during Hurricane Florence.
They are proposing to truck in approximately 200,000 cubic yards of sand from the ST Wooten site and have
stated that the material would be screened using a 3/4" MEC basket. Geotechnical data for the ST Wooten
site have also been included in the attached application. While the application states up to 32,200 linear feet
of beach would be filled under the request, work was conducted under the general permit from
approximately Station 241+00 to the north end of the project (Station 319+00). The applicant states that the
only work to be performed in this northern area is minor dressing/scarp repair, as needed.
Sand would be brought to site and stockpiled at 3 construction accesses located at Kinston Avenue,
Wilmington Avenue, and Broadway Street. The sand would then be transferred to off -road trucks and
transported to the active dune construction area and placed within location. The dune was designed at an
elevation of +14' NAVD88, with a 25' wide crest tying into grade where possible, and with a 3:1 waterward
slope down to an elevation of +6' NAVD88.
The applicant is also proposing dune plantings, mostly likely consisting of Sea Oats.
Please review the attached application and let me know if you have any questions, concerns or conditions
by September 20, if possible.
Heather Coats
Beach & Inlet Management Project Coordinator
Division of Coastal Management
North Carolina Department of Environmental Quality
910 796 7302 office

heather. coats a-ncdenr.gov
127 Cardinal Drive Extension
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
Kathy Matthews
Fish and Wildlife Biologist
Raleigh Ecological Services
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, NC 27636-3726
Phone [phone] x27
Email [e-mail]
10

Kathy Matthews
Fish and Wildlife Biologist
Raleigh Ecological Services
U.S. Fish and Wildlife Service
P.O. Box 33726
Raleigh, NC 27636-3726
Phone [phone] x27
Email [e-mail]
11