Corps Comment Letter for SAW 2010-00175_Response Letter

4700 Falls of Neuse Road, Suite 300 ,,,'
Raleigh, North Carolina 27609
moffafi & niahol [phone]
www.moffattnichol.com
May 30, 2023
US Army Corps of Engineers
Wilmington District
69 Darlington Avenue
Wilmington, NC 28403
Attn: Greg Currey / Regulatory Project Manager
Subject: Response to Comments for USS Battleship North Carolina - Living with Water
Improvements, State ID#: 20-21601-02A/SAW 2010-00175
Dear Mr. Currey,
Thank you for your time and effort in reviewing our permit application for the USS Battleship North Carolina
Living with Water Improvements Project. Below are the responses to your comments:
1) Please provide an "Alternatives Analysis" for this project or a description of the alternatives
considered. This should include at a minimum the "No Build" alternative and others
(examples increased culvert sizes, floodwall, etc.) Included in this discussion, should be the
living shoreline proposal. Please demonstrate a need for the living shoreline.
RESPONSE:
The Battleship is under threat from storm surge, sea level rise, sunny day tidal flooding and stormwater run-
off. Notwithstanding hurricanes, the Battleship has seen more flood stage events in the past decade than in
the previous 60 years. The trend in flooding events (measured at greater than 5.5' as recorded by the National
Weather Service tidal gauge (WLON7) located at the foot of the Cape Fear Memorial Bridge) illustrates the
alarming increase in flood events observed on
the property. According to the National
Weather Service, Wilmington's rainfall in
2019 is the lowest ever recorded. As of
August 7th, the area was nearly 15.5" below
normal rainfall. Yet the Battleship
experiences alarmingly common sunny day
flooding, caused by high tides on the Cape
Fear River, likely associated with rising sea -
levels. High tidal waters breach the Cape Fear
River banks and/or enter the Battleship's
upstream marshes, flow southerly across the
marsh off her bow to the paved road where
flood waters turn eastward in the grass swale, enter the parking lot and flood the property from the road toward
the Battleship (the point of view in above photo). The National Weather Service evaluated existing flood
conditions in 2014 to compare observed vs predicted tidal conditions, as measured at the NOAA tide gauge
(Attachment A). This information has been integrated into the Coastal Resources Commission Science Panel's
Sea Level Rise Report, pending completion.
Page 1

With a 60-year coastal riverine history, the Battleship is a sentinel site for climate change. Resting 28 miles
upstream of the Atlantic Ocean, the Battleship property is hydrologically contiguous to more than 2000 acres
of tidal wetlands and intertidal shoreline on Eagles Island. Like many coastal sites, an increasing trend in tidal
flooding causes problems. Tidal erosion and flooding inundation damages habitats, creates sink holes, reduces
accessibility to the Memorial, and degrades water quality with vehicular pollutants, soil, and silt. The Battleship
is committed to an on -the -ground green infrastructure solution to improve accessibility, prepare for, and adapt
to climate change, and improve degraded fish and wildlife wetland habitats and water quality.
The Battleship has been evaluating alternatives to mitigating flooding since 2015 with the initiation of a US
Army Corps of Engineers (USACE) Special Investigations study to analyse hydrology and hydraulics on the
Battleship site (Attachment B). Based on the USACE's analysis and findings, three alternatives were identified
and included storm drainage improvements, increase land elevation, and a levee or flood wall system.
The Battleship Commission has unanimously embraced becoming a more resilient operation to ensure the
Battleship is sustained for future generations. With over $4 million in awarded grants, the Battleship has
developed a nature -based infrastructure approach given the critical estuarine ecosystem the project site is
located and to make the site more sustainable against coastal flooding. The "Living with Water" plan was
modelled after the Dutch approach of integrated water management and flood infrastructure planning with
multi -benefit investments. The "Living with Water" approach begins the process of shifting water from threat
to asset by improving visitor access, enhancing wetland habitat, and creating STEM educational opportunities
for students. Therefore, the structural alternatives recommended by the USACE in their 2017 Special
Investigations Study were not determined to be feasible or aligned with the environmental conditions. An
additional analysis was conducted by the NC Department of Transportation in 2021 to verify drainage features
as well as make recommendations for flood mitigation, including resurfacing or improvements (i.e., raising the
road grades) to USS North Carolina Road (Attachment C). This alternative is not in the control of the Battleship
and would not be considered a feasible alternative.
The design team identified project elements that were necessary to reduce the Battleship's risk from nuisance
flooding and coastal inundation, as proven by recent data to be increasing. The "Living with Water" project
incorporates three major strategies for developing a long-term resiliency plan: coastal defense; "Living with
Water"; and connectivity to historical, cultural, and environmental amenities. Finding or creating space for
water to provide opportunities for increased water storage, habitat regeneration, and recreation were the guiding
principle used throughout project planning and design. The original "Living with Water Master Plan", as shown
below, identified vulnerable areas of the site and proposed an ecosystem -based approach to increase resiliency
to Battleship facilities, infrastructure, and increase resilience for adjacent habitats.
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Original Living with Water Plan and proposed pr ject elements. This plan has been adapted to include the preferred stormwater
wetland, necessary parking capacity, and tidal creek configuration based on modelling.
The proposed "Living with Water" project provides a sustainable design to address water quality impairments
in the lower coastal Cape Fear River watershed. Our team's approach aims to mimic the natural, pre -
development hydrology of Eagles Island by reducing runoff and nuisance flooding and help to restore water
quality requirements of the receiving surface water. By excavating existing parking lot, non -point source
discharges will be reduced from vehicles, buses, and operation/maintenance equipment. In addition to creating
Primary Nursery Area habitat for forage fish and shrimp, the approximately 800 linear feet of restored living
shoreline will provide an effective and sustainable method to managing the shoreline within the Battleship's
berth.
The southern shoreline of the
Battleship's berth has been heavily
modified over the years and is currently
covered in loose rubble and concrete
roadway slabs and/or barriers to
protect against erosion. Design
alternatives included a rock sill that
would serve as the foundation to
regrade the shoreline to create the
intertidal regime that will sustain plants
and marsh grasses in this environment.
The team revisited the use of rock sill,
evaluating its performance to maintain
the desired shoreline slope and
intertidal regime, and ability to
minimize wave action and siltation
rates that could affect the long-term sustainability of the intertidal habitats.
regrading of the bank only to create a perched system.
The preferred option included
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The water level collected by NOAA was instrumental in this evaluation along with completing an updated
opinion of probable construction costs to identify the living shoreline system that achieves the overall
objectives. The water level and salinity data collected by NOAA along with soil sampling, was used to identify
intertidal habitat elevations/topology, specie types including upland bank species (spartina, elderberry) and,
tidal wetlands (spartina alterniflora, black needle rush. The living shoreline is longer -term, provides a less -
expensive technique that reduces erosion while at the same time restores the shoreline's natural integrity and
function. Extensive rip rap, built over time, will be removed from the existing shoreline, and planted with native
marsh vegetation found within Eagles Island.
2) What type of wetland plants will be planted at the created tidal creek wetlands (plugs,
seedlings, etc.?)? Will there also be shrub and tree planting? Please provide a wetland
planting plan and schematic.
RESPONSE:
The Battleship, in coordination with NOAA, conducted a wetland vegetation survey to classify the existing
plant community and establish a range of elevations over which each identified species was distributed. Results
of this survey was provided in the permit application as Appendix J. As described by NOAA, the current
shoreline of the Battleship berth is characterized by a wide variety of wetland plants ranging from the invasive
Phragmites australis on the western and northern shoreline, to a mix of species characteristic of freshwater to
brackish wetlands along the southern shoreline. While species distribution does not appear to be dominantly
controlled by elevation, there is a strong spatial gradient in their presence with salt -tolerant species like Spartina
and Distichlis more abundant near the river and less salt -tolerant species like Typha and Eliocharis occurring only
in the southeast corner of the battleship basin.
The occurrence of freshwater wetland plants near the southeast corner of the basin is likely indicative of the
flow of fresh water through large Phragmites-dominated marsh to the west of Battleship Park. Site managers
have noted that water from this parcel tends to flow southward along the treeline at the western extent of this
parcel until it is diverted back toward the battleship basin by Battleship Road. We speculate that this freshwater
drainage leads to low salinity porewater conditions that are conducive to the growth of the less salt tolerant
species documented here.
Table 1. Species identified during shoreline survey and the elevations at which they occurred.
Species
Number of observations
Elevation range of occurrence
Spartina alterniflora
11
-0.28 — 0.33
Phragmites australis
8
-0.24 — 0.86
Spartina cynosuroides
4
-0.21— 0.71
Sagittaria lancifolia
2
0.1-0.4
Distichlis spicata
10
0.14 — 0.71
Eliocharis sp.
1
0.23
Scirpus sp
2
0.35-0.66
Borrichia frutescens
1
OAS
Triadica sp.
1
0.49
Juncus effuses
1
0.63
Typha latifolia
1
0.64
Iva frutescens
2
0.65 - 0.91
1/1, Page 4

Species
Number of observations
Elevation range of occurrence
Upland lawn grasses
4
0.7 - 1.44
Hydrocotyle sp.
1
1.1
In part, the goal of determining the growth elevations of each species was to facilitate a living shoreline and
tidal wetland design that would be more conducive to the establishment of native species than to Phragmites.
While we accept the likelihood that Phragmites will eventually take over this shoreline, our intention is to
promote the quick establishment of a dense community of native vegetation which we believe will be the
best defense against Pbragmites colonization.
Based on this survey as well as recommendations from the NC Cooperative Extension, the Battleship has
selected a suite of native wetland plants for each planting zone consisting of low marsh, high marsh, and
upland transition. The proposed species to be planted, size and spacing can be found below, as well as on
LP601 of the Battleship Living with Water Construction Document Drawings (Attachment D).
TIDAL WETLAND PLANT SPECIES
PLANTING ZONE
SCIENTIFIC NAME
COMMON NAME
TYPE
STEM COUNT
A. LOW MARSH
SPARTINA ALTERNIFLORA
SMOOTH CORDGRASS
6.7-CI PLUG
21,035
B. HIGH MARSH
CLADIUM JAMAICENSE
SAWGRASS
6.7-CI PLUG
2,600
DISTICHLIS SPICATA
SALTGRASS
6.7-CI PLUG
4,800
JUNCOS ROEMERIANUS
BLACK NEEDLERUSH
6.7-CI PLUG
5,680
LIMONIUM CAROLINIANUM
SEA LAVENDER
6.7-CI PLUG
500
SAGITTARIA LANCIFOLIA
BULLTONGUE
6.7-CI PLUG
2,500
SALICORNIA VIRGINICA
GLASSWORT
6.7-CI PLUG
1,000
C. UPLAND TRANSITION
BORRICHIA FRUTESCENS
SEA OX-EYE DAISY
6.7-CI PLUG
500
SPARTINA PATENS
SALTMEADOW CORDGRASS
6.7-CI PLUG
11,740
STORMWATER WETLAND PLANT SPECIES
PLANTING ZONE
SCIENTIFIC NAME
COMMON NAME
TYPE
STEM COUNT
A. SHALLOW WATER
CLADIUM JAMAICENSE
SAWGRASS
6.7-CI PLUG
855
PONTEDERIA CORDATA
PICKERELWEED
6.7-CI PLUG
200
SAGITTARIA LANCIFOLIA
BULLTONGUE
6.7-CI PLUG
1,715
SCHOENOPLECTUS
AMERI CANUS
THREE -SQUARE BULRUSH
6.7-CI PLUG
860
B. SHALLOW LAND
HIBISCUS MOSCHEUTOS
SWAMP ROSEMALLOW
6.7-CI PLUG
200
SOLIDAGO SEMPERVIRENS
SEASIDE GOLDENROD
6.7-CI PLUG
200
SPARTINA PATENS
SALTMEADOW CORDGRASS
I 6.7-CI PLUG
3,390
1/hI1 Page 5

3) Can the boardwalk across the created tidal creek and wetlands be elevated higher or can the
width be narrowed, please justify? If not, the current wetland area shaded by this boardwalk
will be considered an impact and must be removed from the wetland creation total.
RESPONSE:
The boardwalk across the created tidal creek and wetlands can not be adjusted due to ADA compliance and
will be required for full access to the overflow parking lot. The elevation of the boardwalk was designed to
tie-in to sidewalk and cannot be adjusted. The tidal creek and associated wetland habitat shaded by the
boardwalk is 0.08 acres and can be removed from the wetland creation total (1.33 acres). The corrected total
of wetlands created will be 1.25 acres.
4) Why are the wetland impacts (0.43 ac.) associated with the vehicular entrances considered to
be temporary impacts? If the wetland impacts are re -considered to permanent, please update
the permanent impacts in Table 2.1 in the narrative.
RESPONSE:
The temporary wetland impacts (0.43 acres) are associated with potential heavy equipment access to build the
proposed berm and driveway into the overflow parking lot on the west side of the project site. The contractor
will be responsible for returning the area back to its original condition. The contractor can elect to access these
areas from the north to minimize impacts to existing Phragmites and Typha wetlands. The vehicular entrances
are considered permanent wetland fill and is included in the 0.26-acre total in Table 2.1.
As a note, the NC Department of Transportation manages the vegetation within the right of way drainage ditch
through mowing and chemical spraying (as shown in below photograph taken on May 24, 2023).
NCDOT actively manages vegetation within the drainage ditch and right of zvay through mowing and chemical
.praying.
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5) For the wetland enhancement described for the tidal creek wetlands, can you elaborate on
why you believe this work qualifies as "wetland enhancement"? Please provide a discussion
(including a functional assessment i.e., NCWAM) on the current wetland area and how the
proposal will enhance/improve upon those functions.
RESPONSE:
The wetland enhancement areas are classified as jurisdictional wetlands and have hydrophytic vegetation,
wetland hydrology, and hydric soil conditions. Nevertheless, the area delineated as wetland enhancement area
within the proposed project is not functioning at the fullest capacity. The area on the western part of the project
site has been utilized as a construction staging area by NCDOT in the past and as such has received fill and
impacts from heavy equipment. Over time increasing tidal flooding events has introduced flood waters and
allowed for opportunistic wetland species (i.e., Typha) to take hold. Based on the surrounding landscape, existing
natural wetlands include brackish marsh and/or estuarine shrub scrub.
In order to determine and document the functional uplift from the creation of two acres of salt/brackish marsh
at the Battleship NC site, an evaluation was made in 2019, early in the planning phase, of the proposed wetland
creation site using the NC Wetland Assessment Method (NC WAM) (see Attachment E). NC WAM is the
officially accepted method for wetland evaluation based on a Public Notice from the US Army Corps of
Engineers (Wilmington District) on April 21, 2015. This evaluation was conducted by John Dorney, previously
of Moffatt & Nichol (M&N), who helped develop the method, has been an instructor for the method since its
inception, and has published several articles about the method over the past several years. This evaluation was
done based on his knowledge of similar salt/brackish marshes on small tidal streams of similar size in the
Wilmington area in consultation with Adam Efird of M&N staff who has successfully completed the class. The
evaluation assumes that Phragmites can be kept out of the wetland although it is present in significant amounts
in wetlands nearby.
This evaluation concludes that the created marsh will provide a significant functional uplift from its existing
condition of the parking lot. The NC WAM evaluation shows that all three main functions of the wetland
(hydrology, water quality, and habitat) are likely to be rated High as well as the Overall function of the wetland
which would be rated High. It is important to note that if Phragmites is allowed to become dominant over the
created wetland, then NC WAM predicts that the Habitat value of the wetland would be Low while the Overall
value of the wetland would still be High. This finding reinforces the need to institute regular measures to control
Phragmites as is planned for this project and described further below.
6) You state in the application narrative "The wetland and tidal creek will capture, hold,
infiltrate, and direct tidal floodwaters to the Cape Fear River." Can you expand on this,
describing the flooding reduction mechanisms or processes? Also expand here describing
what conditions of the current site facilitate or cause flooding.
RESPONSE:
The major flooding events at the Battleship Memorial are caused by high water on the Cape Fear River.
According to the USACE Special Investigation Study (Attachment A and B), when the Cape Fear River reaches
elevation 2.70 ft NAVD88, water begins to overtop its banks and flow into the vehicle parking areas and grassed
park areas at the Memorial. At elevation 3.30 ft NAVD88, river water begins to overtop NCDOT roadways
USS North Carolina Road and Battleship Road NE. River water can also enter the Memorial area from the
low -land marsh areas west of the Battleship. Stormwater runoff can worsen flood conditions but is secondary
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to high river water levels. Stormwater drainage is hindered by the undersized and damaged pipe network, as
confirmed by NCDOT's investigation (Attachment C).
7) You state in the narrative "The estuarine wetland, tidal creek, and living shoreline will create
ecologically significant coastal habitat. They enhance shelter for juvenile fish species such as
striped bass, alewife, and blueback herring; provide developing areas for juvenile finfish
species, including flounder, red drum, Atlantic croaker, and American shad; and support the
recovery of fish species of concern such as the shortnose and Atlantic sturgeon." Can you
expand upon the habitat and environment created that will enhance these fish species? Also,
describe how this work will provide other ecological lift, such as for non -fish species or other
wetland function uplift.
RESPONSE:
The Battleship NORTH CAROLINA property, and Living with Water project site, is geophysically and
hydrologically linked to Eagles Island. Bounded by an extensive riverine network (the Brunswick River to the
west and the Cape Fear River to the north, east and south), Eagles Island is identified as ecologically significant
in local, state, and national research and management plans. Likewise, the Living with Water habitat restoration
approaches are identified as priority activities for improving ecological structure and function in the lower Cape
Fear River.
Locally, the Eagles Island Coalition has preserved over 1,000 acres and identified additional conservation
priority habitats including the Battleship site (Eagles Island Conservation Management Plan, 2015 — 2025). As
well, the Cape Fear River Partnership promotes the restoration and establishment of estuarine shoreline and
tidal wetlands to provide long-term, habitat -based solutions for the most pressing challenges facing migratory
fish (Cape Fear River Action Plan for Migratory Fish, 2013; https://capefearriverpartnership.com/). The
Action Plan for Migratory Fish is organized around three goals to meet the Cape Fear River Partnership's
mission to restore and demonstrate the value of robust, productive, and self-sustaining stocks of migratory fish
in the Cape Fear River. One of the main goals is to improve habitat for anadromous fish, under which the
Living with Water proposal would support by restoring important estuarine shoreline and creating wetland
habitat.
The Living with Water project area represents a major navigational landmark for anadromous fish. Shoreline -
oriented fish such as striped bass, alewife and blueback herring follow the Cape Fear River to its upstream
confluence with the Brunswick River while migrating to historic spawning grounds. The project's nature -based
infrastructure will provide critical ecosystem functions and services such as refuge habitat. Creation of new
benthic foraging habitat will increase the Primary Nursery Area for recreationally important prey species such
as blue crabs and penaeid shrimp and helps support development areas for more than 40 known juvenile finfish
species in the lower Cape Fear River, including flounder, red drum, striped bass, American shad and American
eel.
On a State level, the North Carolina Division of Coastal Management and North Carolina Division of Marine
Fisheries promote expanding the use of nature -based infrastructure in their Living Shoreline Strategy (2016),
while other State studies and resource management plans call for the restoration and protection of tidal wetland
habitat on Eagles Island including:
• North Carolina Department of Environmental Quality — Cape Fear River Basin Plan (2005);
• North Carolina Department of Environmental Quality — Coastal Habitat Protection Plan (2016);
• North Carolina Division of Water Resources —Unique Wetland Designation (2010);
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• North Carolina Division of Marine Fisheries — Primary Nursery Area Designation (2011); and
• Audubon North Carolina — Important Bird Area Designation (2009).
Federal research has also identified Eagle's Island as a priority habitat. The National Fish and Wildlife
Foundation's Coastal Resilience Assessment of the Cape Fear Watershed ranked the area surrounding the
Battleship as one of the highest scoring Resilience Hubs in the watershed for fish and wildlife assets
(www.NFWF.org/coastalresilience). The National Marine Fisheries Service and the National Oceanic and
Atmospheric Administration (NOAA) designated Eagles Island's tidal wetlands and adjacent riverine systems
as a priority area in the Recovery Plan for the Shortnose Sturgeon (1998). NOAA further identified the Cape
Fear River and Battleship area as Critical Habitat Designation for the Atlantic sturgeon (2016). Both
designations are pursuant to the Endangered Species Act of 1973.
A variety of national research -based publications support living shorelines and tidal wetlands as priority
activities for achieving habitat and water quality benefits. According to NOAA's National Ocean Service, living
shoreline benefits include nutrient pollution remediation, essential fish habitat structure and buffering of
shorelines from waves and storms, while wetlands trap sediments, sequester carbon, provide fish nursery
habitat, and increase biodiversity (httl2s://oceanservice.noaa.gov/facts/living-shorehne.html). NOAA's Office
for Coastal Management recognizes water and stormwater management, climate mitigation and conservation
and shoreline process benefits of salt marsh and tidal wetlands
(httl2s://coast.noaa.gov/data/digitalcoast/pdf/gi-practices-and-benefits.pdfl, while the National Audubon
Society recommends natural infrastructure, such as tidal wetlands and living shorelines, to protect birds and
communities from storm events and rising tides
(httl2s://www.audubon.org/sites/default/files/hurricane florence report audubon.p .
8) Provide a Monitoring and Maintenance Plan. This monitoring plan should include
monitoring of hydrology, wetland plant success or changes in fauna diversity and how this is
related to ecological uplift predictions. Describe maintenance requirements to ensure the
continued viability of the resource once initial construction is completed. This should
include some sort of phragmites maintenance and control plan.
RESPONSE:
Post -project monitoring will be used to determine the success of the project's goals — restoration of an
intertidal estuarine shoreline and creation of subtidal and intertidal wetland habitat. The below table shows
post -project monitoring procedures, metrics that will be collected and the frequency of data collection. The
spatial extent of post -project monitoring is the activity footprint of the restored living shoreline and
established tidal wetland.
Post Pr ject Monitoring for Living Shoreline and Wetland Creation and Enhancement
Metric & Methods & Protocols Frequency & Data Limitations &
Units Timing Considerations
Percent Cover Percent cover of biomass by 1 /year for 3 years Natural approaches to Phragmites
species and cover type management are limited, especially in
of Biomass including invasive Phragmites post -construction aquatic environments
(0-100 %)
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Metric & Methods & Protocols Frequency & Data Limitations &
Units Timing Considerations
Various elevation 1 /year for 3 years Natural approaches to Phragmites
measurements throughout post -construction management are limited, especially in
Elevation (cm) project footprint aquatic environments
Permits may direct additional
1 /year for 3 years
NA
Shoreline
regulatory requirements
post -construction
Position
(NAVD83)
Permits may direct additional
1/year for 3 years
Hydrology flows through project
Water level
regulatory requirements
post -construction
footprint will be analyzed over a
(cm/ft)
variety of tidal events
In addition to the post -project monitoring procedures in the above table, implementation monitoring will
evaluate the extent to which the final mature site mirrors the planned design and includes the following
protocols.
• Preparation of an as -built elevation survey of the entire project area after construction to provide a
baseline against which to measure future changes.
• Tracking vegetative planting success using the transect/quadrat approach as described in National
Fish and Wildlife Service marsh/living shoreline monitoring guidelines such as:
o Multiple transects across the project site will establish the full range of vegetative
communities present;
o A stratified random design will be used to determine the placement of individual sampling
plots along each transect; and
o Plots will be visited and evaluated annually during the period of peak biomass (late July to
early August) for species composition and percent cover.
• A class B elevation benchmark will be installed at the site and its orthometric elevation will be
determined via two (2) 4-hour-long static GPS data collections. The elevation of vegetation
monitoring plots will be determined annually during elevation monitoring by leveling (digital or
optical) from this benchmark.
Effectiveness monitoring will gather the additional data necessary to evaluate post -project success. It will
target parameters that can be used to evaluate whether the site is performing its intended functions and
includes the following protocols:
• Habitat provision will be assessed by visual observation/documentation of faunal use of the site
during the annual vegetation monitoring efforts. UNCW will evaluate benthic and fisheries
composition throughout the project period using standard methodologies.
• Analysis of changes in shoreline position and topography over time will be performed through a
combination of elevation monitoring (by leveling to the onsite benchmark and/or RTK-GPS
surveys) and shoreline mapping (determining shoreline position relative to a fixed point on land
and/or RTK-GPS surveys of current shoreline position).
• Patterns of site inundation will be calculated using data from the elevation monitoring efforts in
combination with water level records from nearby NWLON station (8658120).
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Furthermore, relevant monitoring data will be used to design a long-term monitoring plan to evaluate changes
over time and to support future adaptation measures, including space for native vegetation to migrate and
ongoing improvements to tidal flows and water quality. For further details on the monitoring plan, see
Attachment F.
9) How will ecological uplift from this project be measured (i.e., measurement of tidal events
via piezometers, areal vegetative coverage, control of invasives-phragmites)? Provide a plan
on how this will be measured in the monitoring plan.
RESPONSE:
Please see Attachment F for further details on the monitoring plan developed by the University of NC at
Wilmington (UNCW).
10) Provide Success Criteria for the project. This should include criteria for adequate hydrology
for the created wetlands and tidal creek and diversity and cover requirements for wetland
plantings. Also include criteria for the "stormwater" wetland area and the "living shoreline"
portions of the project.
RESPONSE:
Hydrology and hydraulics modelling did include the tidal creek and wetland, but no analysis was done related
to meeting wetland hydrologic criteria. As far as determining meeting hydrologic criteria for the tidal
wetland/shoreline/creek, the portions of wetland, living shoreline and creek proposed for creation will be
flooded daily during the tidal cycle. Higher elevation areas that may also actually be wetland in the future were
not assumed to be wetland in the future in the application (portion of upland transition zones). Surface water
levels were monitored on the site by NOAA and compared to a nearby NOAA monitoring station and found
that the water elevations were virtually the same. The NOAA monitoring station can be used to verify flood
levels/frequency at the project site after construction to confirm that tidal hydraulics are occurring.
The stormwater wetland is intended for treatment of runoff and not to be under USACE jurisdiction. Water
levels will be controlled by an outlet control structure and tidal inflow will be blocked by a flap gate.
The hydrology target will be that hydrology will be restored to within 10% of the hydrology of the reference
site, as determined ahead of construction. The vegetation target is that no more than incidental presence of
invasive species (primarily Phragmites sp.). The fauna target is that the species noted in the nearby reference site
are also found in the wetland creation site within one year of wetland creation and shoreline restoration.
University of North Carolina at Wilmington will provide the staff and resources to document benthos/nekton.
The reference for these targets will primarily be from a nearby reference site within the Battleship NC
berth/basin.
11) Provide an Adaptive Management Plan". This should describe a management strategy to
address unforeseen changes in site conditions or other components of the project.
RESPONSE:
An Operation and Maintenance Plan was developed per a grant contract agreement with the NC Land and
Water Fund (see Attachment G). This plan provides management strategies to address potential maintenance
,d,q Page 11

needs for all components of the project. This plan may be adapted by the Battleship during, and post -
construction as additional items arise. This plan will be considered a living document and will be managed
and implemented by the Battleship.
12) Will any "off -site" fill be used in the construction of the Living Shoreline and tidal creek and
adjacent wetlands construction portions of the project?
RESPONSE:
No "off -site" fill material will be used in the construction of the living shoreline, tidal creek, and wetlands.
Any material to be brought into the site will be used for the elevation of the parking lot.
13) Will any "on -site" fill be pushed waterward into the battleship basin in the construction of
the Living Shoreline and tidal creek and adjacent wetlands construction portions of the
project?
RESPONSE:
No "on -site" fill material will be pushed waterward into the battleship basin in the construction of any part of
the proposed project.
If you have any questions or concerns, please feel free to contact me anytime at [e-mail].
Sincerely,
Dawn York
Senior Coastal Planner
238 Princess St. Wilmington, NC 28401
P 910.218.7087 M 910.612.1152
moffatt & nichol