20061275 Ver 1_Public Notice Response_20061006

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C O A S T A L SCIENCE ~ E N G I N E E R I N G
PO (30X 8056 COLUM6IA SC 29202 • TEL [phone] • FAX [phone] EMAIL cseCcaastalscience.com
October 2, 2006
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Mr. Raleigh Bland D l.5 ~ ~!_~-, n
US Army Engineer District f i~~!
Washington Regulatory Field Office 0CT i5 ,.".tl lib
PO BOX 1000
Washington NC 22889 TEL: [phone] oENR-WAi_, ,_;, ,~;;~
WETI-AN0.s AND STO~~,tyVATER BRANCH
RE: Town of Nags Head Beach (Dare County) -Action ID No. SAW 2006-40282-128
Responses To Comments from State Resource Agencies [CSE 2203]
Dear Mr. Bland:
This letter is submitted in response to comments from various state agencies regarding application
by the Town of Nags Head for a permit to place sand along the oceanfront (ID No. SAW 2006
40282 128). Copies of comments were received by Coastal Science & Engineering on 13
September 2006.
1) NC Division of Water Quality (letter from Cyndi Karoly, Supervisor dated 23 August 2006)
The comment letter acknowledges receipt of the permit application and indicates that NCDWQ
cannot issue a 401 Certification until the project has received a FONSI. The application is
currently under review by the State Clearinghouse.
Response: No response required.
2) NC Department of Cultural Resources (letter from Peter Sandbeck dated 31 August 2006)
The comment letter requests the precise location of the offshore borrow area and a
determination of whether that area has been surveyed for submerged cultural resources.
NCDCR also indicates there may be remains of shipwrecked vessels washed up and buried
along the Nags Head beach and that such remains should be protected during construction
activities.
Response: The applicant is in the process of finalizing the offshore borrow area
from among three subareas (1, 2, and 3) within offshore area "S1" (designation by the US Army
Corps of Engineers for the federal Dare County beach nourishment project). The applicant
obtained additional borings in subareas 1, 2, and 3 in August 2006 for purposes of confirming
sediment quality and compatibility with native beach sands along Nags Head. In response to the
comment, the applicant through CSE (agent) will engage the services of an experienced
archeologist to conduct a comprehensive survey of the selected subareas) of S 1, provided that

Mr. Raleigh Bland, USACE October 2, 2006
RE: Response to Comments (Action ID No. SAW 2006-20282-128) [2203] Page 2
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all or part of the area has not been previously surveyed for cultural resources. Presently, only
about 25 percent of subareas 1, 2 and 3 is required to accomplish the project. The applicant is
researching previous cultural resource data for S 1 and, if necessary, will supplement such data
with new surveys in fa112006. Results will be submitted to your agency and made a part of the
EIS for the project.
A 1999 study by Mid-Atlantic Technology and Environmental Research Inc (MATER) detected
no magnetic anomalies within the portions of offshore area S 1 that they surveyed. According to
MATER, ... "single isolated objects of modern or historic origin seldom have the potential to
meet the criteria for nomination to the National Register of Historic Places." Accordingly, .. .
"no additional cultural resource investigations or restrictive actions are recommended."
(MATER, 1999, pg 15 - as reprinted in Appendix B of the draft EIS for the present project)
Because it appears that there maybe some gaps in the survey area covered with respect to
offshore area S1 (subareas 1, 2, and 3), the applicant anticipates conducting additional cultural
resource surveys to fill the gap(s). Three isolated magnetic anomalies were detected off Kitty
Hawk (federal offshore area N1).
The applicant is aware of certain submerged shipwrecks close to shore documented in previous
studies. These are referenced in the draft EIS for the present project (cf, Section 4.7 and
Appendix B-1999 Cultural Resources Study by MATER).
In anticipation of potential uncovering of shipwreck objects along the beach around the time of
construction, project plans and specifications will require the contractor(s) to report, vacate,
and protect such areas as they are detected. Further, the plans will show locations of
previously reported nearshore wrecks and establish a suitable buffer area (ie, approximately
X500 feet) where placement of submerged pipeline is prohibited. In general, nearly all heavy
equipment operations will be conducted on the nourished beach above the high watermark.
Sand filling operations tend to reduce the chance exposure of shipwreck artifacts and protect
such objects by burial under additional sands.
3) NC Wildlife Resources Commission (letter from Maria Tripp dated 7 September 2006)
The comment letter expresses concern regarding project impacts to sea turtles and certain
shorebirds, specifically the schedule for construction, physical changes to the beach, and
sediment quality issues. Concern was also expressed regarding the schedule for renourishment
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in subsequent years.

Mr. Raleigh Bland, USACE October 2, 2006
RE: Response to Comments (Action ID No. SAW 2006-20282-128) [2203] Page 3
CSE
RE: Construction Schedule
Response:
The applicant recognizes the importance of the Sea Turtle Moratorium (May 1 to November 15)
and Beach Nesting Waterbird Moratorium (April 1 to August 31) and plans to implement
several mitigative measures to protect endangered and threatened species during construction.
First, the primary reasons for the applicant's request for summer construction are safety and
construction duration. Nags Head is affected by some of the highest waves along the US East
Coast. Thirty years of wave measurements at the USACE Field Research Facility at Duck (~20
miles north of the project area) show significant waves exceeding 6 feet occurring frequently in
cold-weather months. Associated with low-pressure disturbances, wave conditions which
preclude offshore dredging operations are likely to occur 3 or 4 days out of every 10 days
during winter months but only 1 or 2 days out of every 10 days during summer months in the
Nags Head area. During severe weather conditions offshore, significant waves commonly
exceed 8 ft with seas producing hazardous conditions. Combined with cold temperatures in
winter, such conditions are much more hazardous for contractors and pose a direct danger to
personnel working offshore. Nags Head is not situated close to a safe harbor so when storms
threaten, the dredge has to motor to Norfolk (about 65 miles way) at considerable cost in lost
time and production. The net result is construction activities will last longer if they are
restricted to winter months. Further, the likelihood of serious injury to workers will be much
greater than normal for this type of project.
There is ample precedent for beach nourishment during turtle nesting season. A recent federal
nourishment project at Folly Beach (SC) was accomplished between April and November 2005.
Such projects are generally implemented with strict turtle-monitoring protocols. The proposed
project will improve the habitat that is presently inadequate to support certain threatened
species. A wider beach after construction will provide better protection for turtle nests and
increase the chances of success. According to NEST (Network for Endangered Sea Turtles),
there were only two successful loggerhead nests in 2003 within their 58-mile coastal monitoring
area (Virginia border south to Oregon Inlet). Several nests were lost to erosion during late
summer and early fall storms. Out of five nests in 2004, only about 50 percent of the hatchlings
survived. Deaths of many eggs were attributed to storm inundation. Similarly, out of six nests
in 2005, two were washed out by Hurricane Ophelia in mid September.
The Nags Head project area is near the northern limit for sea turtle nesting activities. Low
numbers of nests are also due to the severely degraded condition of the beach and the high
frequency of storm waves. Between 20 August and 13 September 2006, several tropical storms
passing well offshore generated sufficient wave energy to cut back the dry beach by as much as
50 ft. A buried seawall at the Comfort Inn near Whalebone Junction was exposed, allowing

Mr. Raleigh Bland, USACE October 2, 2006
RE: Response to Comments (Action ID No. SAW 2006-20282-128) [2203] Page 4
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normal high tides to reach the base of the building. In many areas, 5-ft (or higher) vertical dune
escarpments were left exposed along the back of the beach. Such conditions are common along
Nags Head and recur frequently even without direct impact of storms. These are the types of
conditions that will be mitigated by nourishment, thereby improving the chance for successful
turtle nests.
For the same reasons that Nags Head provides marginal habitat for sea turtles, its beach is too
narrow to support nesting shorebirds. The principal federal species of concern, piping plover, is
not known to nest in the area but it may forage in the area. The draft EIS for the project
(Section 5.15.2.1) states that "Temporary disruption of the piping plover foraging habitat is
expected as a result of sand placement. The USFWS (1996) has designated a critical habitat for
the piping plover that extends from the southern portion of Bodie Island to the northern portion
of Pea Island ..." This habitat is two miles or more from the project area. While construction
activities may disrupt foraging by plovers, the slurry accompanying sand discharge releases
nutrients and food sources (eg, polychaete worms) on which foraging birds feed. The net
impact is therefore uncertain with benefits accompanying disruption. Further, the postproject
beach condition will produce more foraging area compared with existing conditions.
As a means of mitigating impacts during summer months, the applicant will implement the
following monitoring (subject to concurrence with state and federal regulatory agencies).
• Trawling for turtles ahead of the hopper dredge(s) and relocation of any caught turtles
(when sea temperatures exceed 57°F).
• Daily beach patrols for turtle nesting activities and relocation or condoning off of nests.
• Establish a communications chain to alert interested personnel (eg, federal, state, and
NGOs) immediately of any turtle incidents.
• Have in-place established protocols (as recommended by NMFS and USFWS) for dealing
with turtle takes, nests, or other related activities.
• The project will be subject to NMFS protocols for endangered species monitoring and
protection.

Mr. Raleigh Bland, USACE October 2, 2006
RE: Response to Comments (Action ID No. SAW 2006-20282-128) [2203] Page 5
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RE: Potential Physical Impacts of Changed Habitat on Sea Turtles
Response:
The proposed project will add beach-quality sand, similar to the native sand along Nags Head.
It will produce an average ~75-ft wider dry beach and leave gentle slopes in the intertidal zone.
Much of the nourishment volume will be placed in the surf zone to produce a gentle slope so as
to minimize formation of escarpments. The additional dry beach width will reduce exposure of
the foredune to damaging waves and, therefore, reduce the frequency and scale of escarpments.
Nevertheless, along high energy beaches such as Nags Head, temporary escarpments will
continue to form in connection with the normal beach cycle of onshore-offshore sediment
transport.
The sediment color and texture of the borrow material closely match the native beach and,
therefore, are not expected to alter compaction, temperature, or other physical characteristics.
Nesting success is likely to increase after the project by virtue of a wider dry beach.
RE: Construction During Migration by Beach-Nesting Water Birds
Response:
Beach construction activities are generally limited to 1,000 linear feet of shoreline on any
given day. As nourishment sections are completed but prior to removal of the pipeline, there is
little construction activity to disrupt foraging of the nourished beach by shorebirds. In fact,
recently deposited nourishment sediments often attract shorebirds because of the introduction of
invertebrate remains (worms, etc) dredged from offshore. The slurry runoff is often observed to
be attractive to certain shorebirds. Foraging shorebirds are likely to avoid heavy equipment and
construction personnel working at the site.
RE: Concerns Re ag rding Repeat Nourishment Projects
Response:
The applicant is proposing aone-time nourishment project sponsored entirely with local funds
in expectation of it lasting until the federal project can be implemented. The scale and
longevity of the project is uncertain but is expected to be as much as ten years based on historic
erosion rates. There is uncertainty in this estimate because Nags Head has never before been
nourished. Periodic monitoring will be performed to determine the longevity of the fill.
Renourishment is anticipated under two scenarios at an indeterminate schedule:
a) Implementation of the federal Dare County project which is presented in detail in USACE's
(2000) final feasibility report and environmental impact stations or hurricane protection and
beach erosion control: Dare County beaches (Bodie Island portion), Dare County, North

Mr. Raleigh Bland, USAGE October 2, 2006
RE: Response to Comments (Action ID No. SAW 2006-20282-128) [2203] Page 6
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Carolina (Vol I and Vol II, US Army Corps of Engineers, Wilmington District, South
Atlantic Division).
b) Emergency renourishment under sponsorship by FEMA after a catastrophic storm so as to
replace documented sand losses (under FEMA's "Improved Projects" poststorm damage
reduction program).
The applicant desires to construct the proposed project and not have to perform renourishment
or beach-scraping activities for up to a decade. If the project is not completed, the applicant
and certain individual property owners will likely have to perform beach/dune scraping every
year to protect community infrastructure and existing property.
RE: Ouality Control of Borrow Area Sediment
Response:
The applicant is investing considerable sums on additional geotechnical surveys in the offshore
borrow area. Presently, the density of borings available to delineate the final borrow area is ~1
per 10 acres. In general, the available borings show only trace amounts of mud and no
consolidated material or rock fragments. The project plans and specifications as well as daily
construction observations will include protocols for daily sampling and monitoring of sediment
quality. Should poor-quality material not meeting the NC Coastal Resources Commission
sediment criteria for nourishment be encountered, the contractor will be immediately directed to
abandon that section of the borrow area, temporarily stop pumping, and move the dredge to
another section of the borrow area. Daily observers will be present to monitor the discharge on
the beach. Further controls include continuous monitoring of gauges and the hoppers onboard
the dredge which provide a measure of the slurry density and visual evidence when excessive
mud or rock are encountered.
RE: Protection of Storm-water Outfalls on the Beach
Response:
The Town of Nags Head maintains at least six storm-water outfalls on the beach. These outfalls
terminate at the beach face below the dry sand level. The applicant will extend the outfalls as
necessary so as to maintain comparable discharge across the beach face. The specific lengths to
be added will depend on the final nourishment budget, bid prices for sand, and beach-fill
density at a particular section of the beach. The. applicant intends to maintain storm-water
discharge capacity without modification in the number or location of discharge points.

Mr. Raleigh Bland, USACE
~~ Response to Comments (Action ID No. SAW 2006-20282.128)
October 2, 2006
[2203] Page 7
This completes the applicant's response to three comment letters rece'
resource agencies. Please contact me or Bill Forman (252.222.0976) ife ouo date for the state
questions or require more information regarding these responses.
Y have additional
On behalf of the Town of Nags Head, thank you for your attention.
Yours truly,
Coastal Science & Engineering (CSE)
Timothy W K1 ana PhD
Project Director
cc: Mr Charles Cameron, Interim Town Manager
References
MATER. 1999. A Phase 1 upland and underwater archaeological survey of the Dare Count beach
borrow areas, North Carolina. Attachment B, 24 pp, in USACE (2000).
Y es and
USACE. 2000 (Sep). Fina] feasibility report and environmental impact statement on hurricane protection
beach erosion control: Dare County beaches (Bodie Island portion), Dare Coun
ty, North Carolina. Vol I
and Vol II, US Army Corps of Engineers, Wilmington District, South Atlantic Division. and
USFWS. 1996. Piping plover (Charadrius melodus), Atlantic coast population, revised recovery plan. Hadle
MA, 258 pp.
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