20221509 Ver 1_NCDMF Comments - Sugarloaf Island - Carteret_20221215

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
KATHY B. RAWLS
Director
TO:
Gregg Bodnar, NCDCM Assistant Major Permits Coordinator
FROM: James Harrison, NCDMF Fisheries Resource Specialist
SUBJECT: Sugarloaf Island, Carteret County
DATE: 15 December 2022
A North Carolina Division of Marine Fisheries (DMF) Fisheries Resource Specialist has
reviewed the N.C. Division of Coastal Management (DCM) Coastal Area Management Act
(CAMA) permit application for proposed actions that may impact fish and/or fish habitats. The
proposed work is located at Sugarloaf Island, which is south of Evans Street in Morehead City,
within Carteret County. The applicant, the Town of Morehead City, is proposing to excavate and
construct a habitat enhancement area protected by sills and wave attenuators within Bogue
Sound and Harbor Channel for public use. The waters within the project area are classified as
SA; HQW and are closed to shellfish harvesting. Submerged aquatic vegetation (SAV) was not
observed within the project area, but historical data suggests the presence of SAV habitat
adjacent to the northwest side of the island.
The applicant is proposing to construct two sill structures made from proprietary materials. The
first sill would be adjacent to the northwest end of the island. It would be 5' wide and 840' long
with openings 10' wide positioned at 250' intervals. It would be sited in water depths that are -2'
normal low water (NLW) and built to a height that would provide 6" exposure at low tide. The
second sill would be adjacent to the southern shoreline of the island. It would be 5' wide and
2,764' long with staggered 10' wide gaps at 230' intervals. It would be sited in -2' NLW waters
approximately 10' waterward of the shoreline with 6" of exposure at low tide.
The applicant is also proposing to install a concrete wave attenuation breakwater offshore of the
island. This structure would primarily be located adjacent to the south side of the island and
would wrap around the east and west ends, ranging from 40' to 400' offshore. The proposed
breakwater would be 18' wide and 3,474' long. Openings ranging from 27' to up to 200' wide
would be included at varying intervals. The proposed alignment is sited along the -4' NLW depth
contour and would give the structure 3.6' of exposure at low tide. The structure would have
pilings with reflectors and lighting to alert vessel operators of the structure's presence during
periods of low visibility. These marker pilings would be sited at the openings and at varying
intervals along the structure.
The proposed breakwater would tie into the shoreline on the eastern terminus of the island and
transition into a traditional riprap revetment. The revetment would be approximately 35' south of
the edge of the existing Federal Channel and within the Federal Channel setback of Harbor
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

Channel This revetment would be 18' wide and 206' long Immediately waterward of this
revetment, the applicant is proposing to excavate approximately 7,000 cubic yards of material.
This 20,000 square foot (SF) excavation would tie into the -12' NLW depth within the center of
the Federal Channel.
The excavated spoil would be temporarily contained within a 3,000 SF unvegetated area
immediately landward of the revetment. This spoil material would be utilized for habitat
restoration efforts in the nearshore areas of the island, landward of the proposed wave attenuator
system's alignment. The intent of this proposed fill would be to enhance SAV and coastal
wetland habitats with associated native coastal riparian plantings.
The year immediately following construction will involve an assessment of natural recruitment
of SAV within the expected SAV enhancement areas. After this assessment is completed,
plantings of Halodule wrightii and Zostera marina will be considered. Survival of plantings
would be determined one month after planting. Every four months thereafter, SAV shoot density
and cover will be monitored. If less than 75% survival has occurred before the end of the first
year of transplant monitoring, remedial planting will occur during the next available planting
period to bring the percentage survival rate to the minimum standard. After remedial planting,
the monitoring schedule will be reset to the baseline. A second remedial planting can be done, if
necessary, and will be determined by the chief field biologist.
The proposed riprap would impact 3,708 SF of Public Trust Area within the Federal Channel
setback of Harbor Channel. The proposal would excavate approximately 20,000 SF of shallow
bottom, as well as filling 80,552 SF of shallow bottom and 35,708 SF of high ground. The
proposed shoreline stabilization structures would usurp approximately 450,000 SF of Public
Trust Area and dramatically alter traditional marine vessel ingress/egress to Sugarloaf Island.
DMF has concerns with the proposed project, particularly the amount of Public Trust Area to be
usurped and facing proposed habitat conversion. DMF also has concerns with the proposed SAV
enhancement concept and monitoring plan. First, an in-depth monitoring plan should be
developed and provided to the resource agencies for review. This plan needs to provide details
regarding the specific goals (i.e., measurable goals) for each year of monitoring and what would
be considered a success. DMF understands and acknowledges that there is a degree of
uncertainty regarding the specific square footage of SAV transplanting that will be required as a
result of the proposal to allow natural colonization to occur. However, the plan could include
scenarios to address these uncertainties, such as assuming colonization to occur at rates of 0-90%
areal coverage and include what transplant success rate would be deemed suitable. The plan
should also provide a level of detail that would allow the monitoring approach to be replicated.
Additionally, the monitoring and/or management plan should also include details regarding the
maintenance and upkeep of the proposed structures. This should address items such as who will
be financially responsible for conducting necessary repairs for the expected life of the structure
and who will provide the staffing for necessary upkeep/maintenance, as well as any additional
pertinent information regarding the maintenance and upkeep of these structures. The
management/monitoring plan in its entirety should be submitted to and reviewed by resource
agency staff prior to commencement of construction activities.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

As noted above, DMF is concerned with the level of encroachment into Public Trust waters,
specifically without a course for remediation should the proposed habitat conversion and
enhancement be unsuccessful. The proposed attenuator alignment would result in a significant
amount of public trust shallow open water usurped and converted to a different habitat type. This
concern is further compounded by the uncertainty with the SAV enhancement areas, as there is
no guarantee that these areas will produce thriving SAV. Failure of the SAV to grow
successfully would result in a significant loss of and fill in open shallow water habitat with no
real habitat tradeoff. As such, the plan should include measures to be taken, as well as triggers
for those measures, should the SAV enhancement portion of the proposed project be deemed
unsuccessful. Providing a clearer description of the measures to be taken if the SAV
enhancement isn't successful may help to alleviate concerns with proposed alignment. Until an
agreeable monitoring/management plan is received and approved by the resource agencies, DMF
would recommend that the attenuator alignment be adjusted to an alignment closer to the
shoreline in order to minimize the amount of shallow water habitat loss.
The proposed project involves a significant amount of in -water work and placement of materials.
Considering the scope of the proposed project, DMF would recommend that the permit issued
include a 1 April through 30 September moratorium on all in -water work as a permit condition.
Inclusion of this permit requirement will require the in -water work to occur during the less
biologically productive winter (colder) months, thereby helping to minimize potential impacts to
fisheries resources present in and/or utilizing the project area.
Taking into consideration that SAV enhancement is a goal of the Coastal Habitat Protection
Plan, construction of a project such as this that aims to enhance SAV habitat would be aligned
with the goals of DMF. Therefore, DMF does not object to the overall project concept. However,
as noted above, DMF would recommend that a more in-depth monitoring and management plan
be submitted prior to the commencement of any project -related activities. This plan should be
provided to the resource agencies with sufficient time to review and provide any
comments/recommendations as needed. DMF's concerns should be alleviated by submission of
the requested plan and inclusion of the moratorium as a permit condition.
Thank you for consideration of our comments and concerns. Please contact Jimmy Harrison at
[phone] or at [e-mail] with any further questions or concerns.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021