20221509 Ver 1_WRC Comments_20230606

� North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
MEMORANDUM
TO: Gregg Bodnar
Division of Coastal Management
North Carolina Department of Environmental
Quality
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: June 6, 2023
SUBJECT: CAMA Dredge/Fill Permit Application for Town of Morehead City, Sugarloaf
Island, Carteret County, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the permit
application with regard to impacts on fish and wildlife resources. The project site is located along the
shoreline of Sugarloaf Island south of Evans Street near Morehead City Harbor Channel within Bogue
Sound. 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.).
The applicant proposes to excavate and construct shoreline stabilization structures within Bogue Sound
adjacent to Sugarloaf Island in Morehead City. The purpose and need of the project as stated in several
meetings is to stabilize the eroding island and to provide protection for the Morehead City Harbor area.
An earlier permit application submittal was circulated in 2022 and received numerous comments from
state and federal agencies, altering the design of the initial proposal. The most recent iteration was
received on April 10, 2023. This version includes some reduction in the area usurped by the Wave
Attenuation Device (WAD), primarily along the southern shore. The current alignment still follows the
2011 MHW line, placing the sill well offshore the northwest end and the southern shoreline of the island.
The WAD are set concrete pyramidal units with holes and gaps, installed at this location to have a base
width of 18' and a height +1.5' above current MHHW. Gaps are proposed in the alignment of the WAD
along the shore to provide some vessel access. Landward the WAD some areas are proposed to have
additional structure installation. A 5' wide base of Oyster Catcher Tables and Marsh Mounds are
proposed to provide media for oyster recruitment. Coastal wetland plantings will occur on sand flats and
areas adjacent to coastal wetlands. Submerged aquatic vegetation (SAV) enhancement is anticipated as
areas behind the sill are calmed. To ensure SAV propagation success, a monitoring plan has been
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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submitted, allowing one-year of natural SAV recruitment and then survey and monitoring for three years.
Subsequent SAV planting may occur if needed. In addition to the shoreline stabilization, a portion of the
eastern end of the island near the USACE Federal Navigation Channel will be dredged. The shoaling in
this area narrows a section of the heavily used channel. Material mechanically removed will be placed on
the island, above the MHW line. A revetment is proposed near the Federal Channel to deter shoal
formation. Bogue Sound at this location is classified SA HQW and is closed to shellfish harvesting.
The NCWRC has reviewed the permit application and has participated in numerous discussions. We
appreciate the coordination from the applicant with state and federal agencies to reduce impacts to the
island and surrounding aquatic habitats. However, several aspects of this project do not follow the general
guidance provided by NCWRC for shoreline stabilization.
The NCWRC generally requests sills be installed no greater than 30' from the shore's normal water line.
This minimizes usurpation of public trust waters, aquatic habitat fill, and minimizes navigation hazards in
many situations. We also recognize that sills and living shorelines are meant to allow continuous
hydrologic connectivity and aquatic passage. Sills should be designed with 5' openings every 100' and
have a structure height approximately +1' above NWL. The intention of sills and living shorelines is not
to prevent water from reaching shore, but to reduce energy on the shore.
Although the project does not meet the general guidance our agency provides, we will not object to permit
issuance. Minimal realignment has occurred to align the sill closer to shore in the southern section. An
adjustment of the sill closer to shore on the northwest end of the island would have also been preferred.
However, due to the circumstances on this island (including no SAV or shellfish resources and proximity
of a harbor channel) and for this project proposal (including SAV and wetland restoration with survey and
monitoring) we will not request additional alignment minimization. However, our agency would like the
height of the WAD structures to be reduced to +1.5' above MHW, not +1.5' above MHHW.
The eastern portion of the island is proposed to be mechanically dredged with material placed on the
island landward the southern sill. While this may be a good option for material removal prior to planting
and island restoration, future material placement should this area be maintained outside USACE dredge
activities should not negatively impact the island. The NCWRC does not generally support the placement
of fill landward of sills. However, we will not object to this proposal due to the material, island
conditions, and scope of the initial project. Fill should not be placed in wetlands or atop SAV. Removal of
material from the channel should adhere to previously issued permit conditions or conditions requested by
the NC Division of Marine Fisheries (NCDMF) to minimize environmental impacts.
The intention of this project is to enhance and restore SAV and coastal wetlands, not to mitigate for
impacts to SAV, coastal wetlands, or aquatic habitats. Therefore, the project proposal and provided
monitoring plan is acceptable. The NCWRC requests monitoring data and project progress be provided to
our agency as well as other interested agencies.
Sugarloaf Island is heavily used by the public. If user conflicts or needs arise, we request the Town of
Morehead City consider access amendments. Due to the heavy use of the island by the public, there is
minimal waterbird use of Sugarloaf Island. The stabilization design provided for this project would not
likely be appropriate for islands with better waterbird habitat opportunities. It is likely that access to the
island by diamondback terrapins will be extremely limited.
The NCWRC appreciates the coordination exhibited throughout the review of this permit application. We
look forward to project reports, including construction, surveys, and monitoring. If you need further
assistance or additional information, please contact me at maria.dunn(cr�,ncwildlife.org or [phone].