Responses to DWR Comments Southern Dare.pdf

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Response to NC Division of Water Resources Comments Regarding the
Proposed "Southern Dare County Channel Maintenance and Dredge Material
Management Project"
Comment N.
The State and Federal Resource agencies have reviewed the proposed maintenance application for
the project above. The proposed project would alter the already approved maintenance permits that
have been issued for the continued maintenance of the channels and disposal corridors within the
Hatteras Inlet Complex.
Response:
Dare County s proposed actions do not fundamentally deviate from or alter the nature of the
previously approved permits and authorizations that have been granted to other entities, namely
the USACE and NC DOT. The County, however, has proposed to widen one location (the northern
portion of Sloop Channel) where historically, the channel was considerably wider. The proposed
channel width of 200 ft differs from the USACE's authorization and NC DOT's permits which
allow for the maintenance of Sloop Channel to 100 ft wide and 225 ft wide, respectively. It should
be noted that Dare County s existing permit to maintain the Hatteras Connector Channel, located
adjacent to Sloop Channel, also allows for a 200 ft wide channel due to high rates of shoaling.
The purpose of the proposed 200 foot width in Sloop Channel is to provide advanced maintenance
dredging to minimize how frequently dredging may need to occur in this area and to allow for
safer passage through this corridor. At times, ship traffic is limited through this narrow cut to one
way only. The channel that is currently included in the realigned federal Hatteras to Hatteras
Inlet channel (Horsshoe) is much different than the original straight shot across the inlet, where
natural flow would have provided adequate space for safe passage, similar to how the channel
through portions of Barney Slough and the Hatteras Connector Channel are naturally deeper.
The ability to maintain a wider channel in this area will provide a better opportunity to provide
dependable navigation through the area.
Comment #2.
The impacts may remove shallow water habitat areas, SAV habitat, marine resources and
management of bird islands.
Response:
By design, the impacts associated with the proposed dredging activity will remove shallow water
habitat areas. The habitat that will be removed will be limited to sandy bottom areas devoid of
other significant resources such as SAV or shellfish beds. While infunal benthic organisms which
reside within the dredged areas and dredged material placement areas will be directly impacted,
it is anticiated that these resources will recolonize the area within the order of months.
No SA or shellfish will be removed or impacted by the proposed dredging or disposal activites.
As stated in the Environmental Assessment (EA):

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"Biological monitoring efforts focused on SA and shellfish resources will be developed
in coordination with the NC DMF and implemented to ensure that dredging and placement
activity will not impact these resources. Given the depth of water in and around the open
water placement areas in Pamlico Sound, no SAV surveys will be conducted in those areas
as the buffer required for disposal operations is not expected to encroach into depths where
SA would be present. Shellfish surveys, however, will be performed prior to any initial
placement of material in and around both the open water disposal areas in Pamlico Sound
and the deep -water disposal area in proximity to the Hatteras Inlet Flood Channel
Placement Area. These surveys will be conducted prior to initial disposal activities. The
purpose of the shellfish surveys will be to identify the presence of shellfish resources such
that a no -disposal buffer may be imposed upon any of these resources that are located
within 100 feet of placement when dredging operations occur between the months of
October through March and with 300 ft of placement when dredging operations occur
between the months of April through September. "
While the bird islands have seen benefits from the navigation projects over the years through the
beneficial reuse of the dredged material via placement on the bird islands, the goal of this overall
management plan is to maintain navigation through the supplementation of routine maintenance
conducted by the USA CE. The placement of material on these islands is performed on a roughly
5-year cycle via a USA CE-contractedpipeline dredge. The need for channel maintence within the
project area, however, requires dredging to be performed on more frequent basis to accomplish
the goals of the projet (safe nabigabiltiy) and, in fact, some locations require near -constant
maintenance. Furthermore, there is a need for flexibility to be able to adapt and address
"hotspots " as conditions change. One of the catalysts for implementing this proposed project was
that USACE Civil Workss has indicated that Cora June Island has reached capacity and may not
be available for regular use in the future. Therefore, additional disposal options are needed. In
addition, Dare County has been informed by the USACE that the extended time in which it took
this site to be permitted has now rendered it cost prohibitive to use by the USACE due to the fact
that they assume they have to build up a berm around the now submerged island.
Comment #3.
The resource agencies have requested a comprehensive management plan of the Hatteras Inlet
Complex such that the USACE Civil Works and Dare County is in sync with the maintenance of
these channels and disposal areas. This office agrees with the resource agencies and requires a
comprehensive management plan for the continued maintenance of this complex. Unless modified,
the existing certifications shall stand unless modified when a special needs occurs.
Response:
As described in the USACE's November 2022 EAIFONSI entitled, "Hatteras to Hatteras Inlet
Channel Realignment, Rollinson Channel Navigation Project", the USACE committed to develop
a Hatteras Inlet Management Plan, or "HIMP" in response to comments received by NMFS
Habitat Conservation Division. Since that time, the USACE has worked independently to develop
the framework of the HIMP which will include the following elements:

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• Identification of all dredging and placement locations, including beneficial use sites;
• Identification of all dredge types used at the inlet;
• Best Management Practices (BMPs) identified by location and dredge type, if necessary,
to minimize impacts to SAV, spawning sanctuaries, and fishery species traversing the inlet;
• Commitments (by location and dredge type, if necessary) for when all efforts will be made
to limit the dredging to the period of I October to 31 March;
• Descriptions of the annual reporting and the select circumstances when dredging -event -
specific coordination is needed for emergency or urgent dredging; and
• SAV monitoring at the Inlet that dovetails with the monitoring done by the Albemarle -
Pamlico National Estuary Partnership
At Dare County's request, a meeting convened on September 7, 2023 with represetntaives from
various entities involved in managing the Hatteras Inlet Complex (namely the County, the USA CE,
and NC DOT) to discuss the proposed structure of the HIMP. During the meeting, it was
determined that the initial HIMP draft will include a spreadsheet and Word document designed to
capture all of the relevant information as identified in the bulleted list above. In addition, it was
proposed that some or all aspects of the final HIMP will be entered into a GIS platform for
visualization. The HIMP will be designed such that it is a "living document" and, accordingly,
will be updated as needed. Should any other entities put forth an interest to implement actions
that would effect the management of the Hatteras Inlet Complex, they will provide relevant
information to the HIMP products as well.