20230780 Ver 2_USACE & NPS DEA CALO Back Sound to Lookout Bight_NCWRC_20230706

� North Carolina Wildlife Resources Commission �
Cameron Ingram, Executive Director
MEMORANDUM
TO: John Policarpo
Wilmington District
US Army Corps of Engineers
FROM: Mania T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: May 19, 2023
SUBJECT: Public Notice for the Draft Environmental Assessment (Draft EA) Channel from
Back Sound to Lookout Bight Maintenance of the US Army Corps of Engineers and US
National Park Service, Carteret County, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the April 2023
public notice and Draft EA with regard to impacts on fish and wildlife resources. 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.) and the Migratory Bird Treaty Act.
The US Army Corps of Engineers (USACE) and US National Park Service (NPS) have submitted a Draft
EA to discuss maintenance dredge and spoil placement activities from Back Sound to Lookout Bight. The
proposed maintenance dredging is divided into two sections; the northern section that includes the fixed
USACE federal channel through Back Sound toward Barden Inlet and the southern section that includes a
corridor encompassing Barden Inlet and Lookout Bight, where the USACE and NPS channels follow
natural deep waters and include two NPS channels that provide access to two existing NPS boat docks.
The proposed dredging would use Government -owned shallow draft plant and contracted hydraulic
cutterhead pipeline dredges. Pipeline dredging would be used for initial dredging, then every 3 to 5 years,
depending on shoaling rates and available funding. Pipeline dredged material would be placed on
Sandbag Island bird island or on nearby NPS soundside or oceanside beaches. Between pipeline dredging
events, Government -owned shallow draft plant (i.e., special purpose hopper dredge or sidecast
dredge) would remove any shoals impeding navigation. Special purpose hopper dredged material would
be placed in naturally occurring scour holes within the Barden Inlet and Lookout Bight channel. Sidecast
dredging is also proposed to be used to maintain the USACE and NPS channels when other dredge plants
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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are not available and would sidecast material 80-feet from the vessel's starboard or port side. All
Government plant dredging would occur within the recommended October 1 through March 31
environmental window. Placement of dredged material on Sandbag Island would occur from September 1
through March 31, to protect nesting birds. Sandbag Island dredged material placement via control -of -
effluent would utilize methodologies to avoid impacts to submerged aquatic vegetation to the maximum
extent practicable. Placement of dredged material on NPS oceanside beach would occur from November
16 through April 30, to protect nesting sea turtles.
The NCWRC has reviewed the Draft EA and has the following comments:
• SAV surveys and ground truthing exercises should be done to determine avoidance,
minimization, and / or impacts to SAV resources.
The Draft EA details dredging and material management for maintenance, not just a one-time
event. While Morgan Island at this time does not need material placement for waterbird
management, future placement of material may benefit the island. Therefore, inclusion of Morgan
Island as a potential placement area is requested. Material placement would be done in a manner
to enhance habitat benefits and should be coordinated with the NPS and NCWRC to determine
need and placement of material. Disturbance to the island would be limited outside the marsh and
areas of the island with shrubs and trees that provide heron and egret nesting opportunities.
• The Draft EA is a management plan that presents several dredge and disposal needs and options.
One option is material placement on the oceanfront shoreline of South Core Banks. While this is
an option to be considered, the NCWRC prefers material be placed on Sandbag or Morgan
Islands for waterbird habitat management rather than ocean shoreline placement.
The NCWRC is concerned with the use of sandbags and geotubes on the islands. Sandbags from
previous placements are still evident as they are not covered with sand. It is unlikely from the
length of time between placement events that sand placed over the bags will remain. The Draft
EA also includes instruction that the casing for the geotubes may be cut to expose sand, but
removal of the casing would be difficult. Therefore, because of the long-term presence of sandbag
and geotube material, the hardening of the shore, and removal of habitat opportunities from
uncovered sandbags, the NCWRC prefers sandbags and geotubes not be used on islands managed
for waterbirds.
The Draft EA suggests coastal wetlands, specifically Spartina sp. sprigs, be planted along the
eastern perimeter of Sandbag Island. While this may be a good habitat enhancement option for
aquatic resources, the presence of marsh may remove nesting and forage habitat for some species
of waterbirds that use the island. Therefore, prior to any wetland designs or plantings, we request
consultation with our agency and the NPS to determine appropriate wetland grass species, design,
and density to not adversely impact waterbird use.
• Numerous species of migratory waterbirds present in the area were not listed within Appendix D.
• Several waterbird breeding season dates listed within the Draft EA may be slightly different than
actual within the Cape Lookout National Seashore.
0 The NCWRC is not aware of Atlantic Puffins breeding in North Carolina.

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• Roseate Terns have been reported in the area and should be included as a species that may be
found in the project area.
Overall, the NCWRC appreciates the information and detail presented in the Draft EA for Back Sound
and Lookout Bight. We strongly encourage continued communication with our agency and the NPS with
regard to material management activities that may affect and improve waterbird habitats. This may
include material composition, placement area, volumes, and seasonal activity restriction.
Thank you for the opportunity to review and provide comments. We look forward to any forthcoming
information and coordination as the Final EA is presented and the project is implemented. If there are any
comments, questions, or concerns please do not hesitate to contact me at man a.dunnkncwildlife.org or
252-495-5554.