20050487 Ver 2_Other Agency Comments_20150728

FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
July 17, 2015
Tyler Crunibley, Project Manager
Wilmington District, U.S. Army Corps of'Engineers
69 Darlington Avenue
Wilmington, NC 28403
Subject: Towns of Emerald Isle, Topsail Beach, Holden Beach, Ocean Isle Beach, and New
Hanover County; SDI-5 Maintenance Dredging Project
Action 11) Numbers SAW-2014-02004,,,,SAW-2014-02005, SAW-2014-02006, SAW-
2014-02007. and SAW-2014-02009 - -
Dear Mr. Crurribley:
This letter is in response to your June 24, 2015 electronic public notice (e-PN), requesting
comments on the proposed SDI-5 Maintenance Dredging Pro'
Dredging Project, proposed by the Town of
Emerald Isle, Town of Topsail Beach, Town of I lolden Beach, Town of Ocean Isle Beach, and
New Hanover County. These local stakeholders for five inlets on the southeast North Carolina
coast are requesting CAMA Major Permits to conduct maintenance dredging for navigation with
associated beneficial placement of dredged material. The inlets include:
Bogue Inlet -------------------- Town of Emerald Isle
New Topsail Inlet ------------- Town of "Topsail Beach
Carolina Beach Inlet ---------- New Hanover County
Lockwoods Folly Inlet - - - - -- -]'own of Holden Beach
Shallotte River Inlet --------- Town of Ocean Isle Beach
The Wilmington District Corps of Engineers (Corps) is processing these permit applications
separately.
In the e-PN, the Corps indicates that the applicants have proposed to 111111lic the depths and
dimensions of the federally-authorized navigation projects, with the exception of'Shallotte Inlet
(because Shallotte Inlet is a Coastal Storm Damage Reduction project rather than a navigation
project). The applicants have proposed to utilize existin., nental Studies and assessments
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from previous Corps projects and from authorized private or local government projects. The
Table on page 23 of the permit application indicates that the authorized final project depth for
each inlet will be used, including a -4-2 foot allowable over-depth. The Service understands that
at least one ofthe four navigation projects, Lockwoods Folly, has not been dredged to the
authorized final project depth, but has instead been maintained to a maximum depth of-8 feet at
MLW (4-2 11. over-depth). Any discrepancies between authorized final project depth and actual
depths ofprevious dredging efforts should be clarified. In addition, it is unclear whether all of
the inlets have been subjected to stringent sedirrient analysis at the authorized final project depth.
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In several ofthe inlets and particularly in and near the AIWW crossings, pockets of incompatible
material have been identified. The permit application lacks detail concerning how compatibility
of material will be determined and ensured prior to placement on the beach, or how incompatible
material will be identified and handled after dredging has begun on a project.
Federally Protected Species
The Service has reviewed a\ allable information on federally - threatened or endangered species
knoxvii to Occur in the respective counties of each proposed project (Carteret, Onslow, Fender,
New I lanover, and Brunswick counties). Several species may occur in the project area,
including the West Indian manatee (Trichechus manams), piping plover (Charmlrimy melodus
nielodus), red knot ((,'ttfidris camaus rqfii), seabeach amaranth (AmaranthusImmilus), and the
Kemp"s ridley (LepOochelys kemj)i), hawksbill (Erelmochelys imbricalct), leatlici•back
(Dcrmochelys corhlcm), loggerhead (C(irella caretia), and green (Chelonia rnyd(is) sea turtles.
Of the five sea turtle species, the loggerhead, green, leatherback, and Kerrip's ridley sea turtle
may nest in the project areas.
In addition, designated critical habitat for loggerhead sea turtles and piping plover are found
within or adjacent to every proposed no project area. Nesting C� critical habitat for the Northern
Recover Unit (NRU) of the Northwest Atlantic Distinct Population Segment (DIIS) of the
loggerhead sea turtle is found adjacent to Rogue Inlet (LOGG-T-NC-01 and -02), New Topsail
Inlet (LOGE-T-NC-03 ) and -04), Carolina Beach Inlet (I-OGG-T -NC-05), Lockwoods Folly Inlet
(1,0G,G-T-NC-07 and -08). and Shallotte Inlet (LOGG-T-NC-08). Critical habitat for
overwinterino piping plovers is found adjacent to Rogue Inlet (Unit NC-I 0), New Topsail Inlet
(Unit NC -11), Carolina Beach Inlet (Unit NC-14), Lockwoods Folly Inlet (Unit NC -I6), and
Shaltotte Inlet (Unit NC' - 17).
Whales, sliortnose sturgeon (Acij)enscr brevisrostrum), Atlantic Sturgeon (.,Icipenser
oxy1rinchus), and sea turtles in the water are under the jurisdiction ofNOAA Fisheries' Protected
Species Division.

The Corps has niade a determination of May Affect, l-ikely to Adversely Affect for scabeach
amaranth, red knot, piping plover., and piping plover critical habitat. The Corps has made a
determination of'May Affect, Not Likely to Adversely Affect for all species of nesting sea turtles
and the West Indian manatee.
Service Concerns and Recommendations
Any discrepancies between authorized final project depth and actual depths of previous
dredging efforts Should be clarified. In addition, it is unclear whether all of the inlets
have been subjected to stringent sediment analysis at the authorized final project depth,
If the applicants propose to dredge deeper than previous Navigation Program or other
dred-ino , efforts, sediment analyses should be conducted to ensure that the material above
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and at the proposed depth is compatible with the proposed disposal area(s).
The applicants should clarify the methods for ensuring that only compatible material is
placed on the beach and in nearshore disposal areas.
Because sand placement activities, even those conducted during the winter, may
adversely affect sea turtles, the Service cannot concur with the Corps' determination of
May Affect, Not Likely to Adversely Affect for the Kenap's Ridley, loggerhead,
leatherback, and green sea turtle. In addition, it is Unclear to the Service whether work
may be conducted during the sea turtle nesting season. The Service concurs with the
(..'orps* determination of Not Likely to Adversely Affect the West Indian manatee. We
understand that the Corps intends to initiate formal consultation pursuant to ESA Section
7(a)(2), and we recommend that the consultation include all. of the species listed above,
with the exception of the West Indian manatee.
The Service appreciates the opportunity to Comment on this project, We look forward to
working with the Corps during formal Consultation. If You have questions regarding these
I -- "n lese
comments, please contact Kathy Matthews at 919-856-4520, ext. 27 or by e -mail at
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