M-0540A Start of Study

L North Carolina Wildlife Resources Commission 9
Cameron Ingram, Executive Director
MEMORANDUM
TO: Colin Mellor, Eastern Regional Team Lead
Environmental Policy Unit, NCDOT
FROM: Travis Wilson, Highway Project Coordinator
Habitat Conservation Program
DATE: January 21, 2021
SUBJECT: Response to the start of study notification regarding fish and wildlife concerns for
the proposed Living Shorelines Project in Carteret and Onslow Counties North
Carolina., Project M-0504A
This memorandum responds to a request for our concerns regarding impacts on fish and wildlife
resources resulting from the subject project. Biologists on the staff of the N. C. Wildlife
Resources Commission (NCWRC) have reviewed the proposed improvements. Our comments
are provided in accordance with certain provisions of the National Environmental Policy Act (42
U.S.C. 4332(2)(c)) and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661-667d),In general, the NCWRC supports the use of living shorelines as opposed to
more a hardened structural approach to address shoreline erosion. However certain design
parameters are important for living shorelines to function as promoted to restore and enhance
habitat. Below is a list of general considerations for living shoreline projects:
• The sill should be designed to have 5' openings for every 100' of sill. Ideally sills are to
be designed with breaks to allow adequate water flushing and aquatic passage. This is an
especially important component for living shorelines. The design of the structure should
include the entirety of the water column. Sometimes proposals include material, cloth,
bedding stone, and granite stone that rises above substrate. While this is likely proposed
to minimize wash out areas, this design lends itself to filling in with sediment or even
oyster shells over time, eliminating connectivity with open water and the area landward
the sill. Consideration for a lower drop down or no drop down and having just the sills
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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with a natural opening is requested. Areas within the sill and behind can also be protected
with a small rock sill appropriately placed waterward or landward of the openings.
Overlaps can also be successful.
• Sill design height is preferred to be no greater than +1' NWL or NHW (whichever is
appropriate).
• Sill slope should not exceed 1.5':1'
• Sill placement from shore is preferred to be 30' or less from the NWL of the shore unless
the irregularity of the shore lends itself to have areas with greater distances.
• Sills should not tie into the shore in a manner that exacerbates erosion on an unprotected
shoreline.
• Sills should be marked at the ends and at 50' intervals with reflective material to
minimize navigation hazards. The posts with reflective material should be 3' above
NHW.
• The NCWRC prefers no fill be placed in the water landward the sill to facilitate the
planting of coastal wetlands. Coastal wetland species can be planted as appropriate for
their success in existing conditions. Often sediment accretion occurs in time. The planting
of coastal wetlands can occur once the structure and site has equilibrated without the
placement of fill in shallow water habitats. These shallow water areas provide important
habitat areas for numerous aquatic species and should not be filled.
• SAV or shellfish surveys may be necessary within the sill alignment or any fill area
depending on site conditions, sill location and size. SAV surveys should be conducted
during the growing season, April 1 — September 30.
• The use of oyster bags should only be considered where oyster recruitment is present and
within lower energy areas. Bags can easily roll during storm events and fill adjacent
coastal marsh. If the project is monitored, the applicant should patrol after large events
and remove from wetlands any dislodge oyster bags.
Specifically, in reference to the study area map provided in your January 51h, 2021 memorandum
as well as additional information provided during the meeting held on January 19, 2021 we have
the following comments:
• Site 2 is designed with the sills approximately 150' waterward of the shoreline with the
area behind the sill to be backfilled. This distance seems excessive. We request that
NCDOT examine the potential for the sills to be located closer to the existing shoreline.
Also, the use of backfill in an area this large could constitute more of an impact from
filling habitat, dredging habitat to obtain the fill, as well as temporary construction

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impacts for equipment access. The area for all these impacts should be calculated and
considered.
• Sites 3 A&B have portions located inside the marsh complex. Historic photos indicate
there may be the presence of SAV. Additional SAV surveys during the growing season
should be conducted.
Thank you for the opportunity to provide input in the early planning stages for this project. If we
can further assist your office, please contact me at [phone] or
[e-mail]