20040561 Ver 4_DCM add info letter- Major Mod request_20200626

Strickland, Bev
From: Coats, Heather
Sent: Friday, June 26, 2020 9:27 AM
To: Greg Finch; 'Jeff Griffin'
Cc: Mairs, Robb L; Snider, Holley; Smith, Ronnie D CIV USARMY CESAW (USA); Pietila,
Tanya K; Cannon, Amanda J; Howell, Jonathan; Deaton, Anne
Subject: Bald Head Island/Frying Pan Shoals add info letter- Major Mod request for Permit #
91-14
Attachments: BHI FPS DMF add info2.pdf, VBHI Nourish w FryingPanShoals DMFcomments.pdf;
VBHI FPS for nourishment_Director cover letter.pdf, CMDF_VBHI #91-14
mod_NCWRC^.pdf, ER_20-1126.pdf
Hi Greg,
Please see the attached add info letter in response to the comments we received from NCDMF. I'm also attaching
NCWRC's comments we received that support DMF concerns and includes some recommended conditions, should those
fisheries concerns be resolved, as well as comments/recommendations from DNCR.
Please let me know if you have any questions.
Best regards,
Heather
Heather Coats
Beach & Inlet Management Project Coordinator
Division of Coastal Management
North Carolina Department of Environmental Quality
910 796 7302 office
heather. coats(a)ncdenr.aov
127 Cardinal Drive Extension
Wilmington, NC 28405
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

ROY COOPER NORT" CAROUNA
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MICHAEL . RE AN
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BRAXTON C. DAV15
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June 26, 2020
Land Management
c/o Mr. Greg Finch
3805 Wrightsville Ave., Suite 15
Wilmington, NC 28403
Email: fg inch(,lmgropp.net
SUBJECT: Application for a Major Modification Permit to State Permit No. 91-14, for
the Village of Bald Head Island, Brunswick County
Dear Mr. Finch:
This letter is in response to the above referenced CAMA/Dredge & Fill permit application,
which was accepted as complete by the Division's Wilmington office on March 5, 2020. The NC
Division of Marine Fisheries (DMF) has notified us by way of the attached letter that they have
objections to the project as proposed and will require additional information to withdraw these
objections.
Therefore, it is necessary that processing of your permit application be placed in abeyance in
accordance with 15A NCAC 07J.0204(d) until DMF withdraws their objections, or until you
notify us that you do not intend to provide additional information, upon which time we will
resume processing. Please note, continued objection by a review agency may lead to denial of
your application. Also, please be aware that we have not received comments from all review
agencies at this time, and further information may be required as a result of additional agency
comment.
FM
NonhCanAlmDeparYmentafEnvlronmemlQuaRry I Division ofCoastal Mmagernen#
W ffognan bfflet I IV Cardinal DrILAevoen-len I MrMhQW. North C"ha 28405
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If you have any questions concerning these matters, please feel free to contact me by telephone
at [phone], or by email me at [e-mail].
Sincerely,
�tl� no�
Heather Coats
Beach & Inlet Management Project Coordinator
Cc: MHC Files/WiRO Files
Ronnie Smith, USACE (via email)
Robb Mairs/Holley Snider, DWR (via email)
NonhCarnllmDepartmentafEnvlronmemlQualLry I Division ofCoastal Mmagernen#
Mwngnan bfflee I ICJ Cardinal DrlueEx1enS-1erL I Mr hQW. North Cerollna 28405
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ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
STEPHEN W. MURPHEY
Director
MEMORANDUM:
TO: Heather Coats, DCM Beach and Inlet Management Project Coordinator
FROM: Anne Deaton, DMF Habitat Program Manager 4 a
SUBJECT: Village of Bald Head Island, South Beach Nourishment from Frying Pan Shoals
DATE: June 2, 2020
North Carolina Division of Marine Fisheries (NCDMF) has reviewed the CAMA major modification
application to nourish approximately 17,200 linear feet of beachfront along South Beach, Village of
Bald Head Island (VBHI). Approximately 98 acres would be placed below the mean high water line.
As a sand source, the applicant proposes to establish a 188.7 acre borrow area on the west side of
Frying Pan Shoals, approximately one mile seaward of the southeast shoreline of Bald Head Island.
South Beach is adjacent to the Atlantic Ocean and the Cape Fear River. The applicant has identified
an area of approximately 460 acres for potential sand extraction, stating the selected borrow area
for Phase I would be limited to 188.7 acres. They propose dredging a maximum of 2.5 million cubic
yards (mcy) in Phase I to a depth of approximately -20 ft., although more sand is available. Sand will
be excavated by cutter suction dredge and pumped to the South Beach shoreline. They estimate
needing to borrow sand every 9-10 years.
The applicant states that the project is needed due to concerns that sand from the previously
approved Jay Bird Shoals will be insufficient. Other alternative borrow sites were considered but
rejected by the applicant due to potentially incompatible sediment (upper Cape Fear River, former
federal channel in ocean, and ODMDS), insufficient sand or already used for renourishment
elsewhere (Bald Head Creek Shoal) or not wanting to remove nearshore shoals that provide erosion
control protection or may be desired for beach nourishment purposes by Brunswick beaches
(Middle Ground, Bald Head Shoal). The applicant states that Jay Bird Shoals, although having
sufficient sand for beach nourishment events to date, cannot support expansion of the borrow area
limits in the future.
Bald Head Island receives sand from the Wilmington Harbor dredging in Years 2 and 4 of a 6-year
cycle, and last received sand from this source in 2014/15. Additionally, the VBHI received a permit
to construct a Terminal Groin at the western end of South Beach, which was constructed in 2015,
with Jay Bird Shoals determined to be the preferred borrow area for groin fillet maintenance. In
2017, the town sought a major modification to the permit to utilize Frying Pan Shoals as a borrow
area in addition to Jay Bird Shoals. After resource concerns were raised by the reviewing agencies
regarding use of Frying Pan Shoals, the applicant went back to use of Jay Bird Shoals, and the beach
nourishment with that source occurred in 2019.
This current major modification application is almost identical to the 2017 request to utilize the
same area of Frying Pan Shoals. Resource concerns described in NCDMF's July 6, 2017 comment
letter remain the same and are summarized below.
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021

North Carolina's cape -associated shoals represent a significant and unique habitat. Diamond,
Lookout, and Frying Pan Shoals separate the three ocean bays in North Carolina - Raleigh, Onslow,
and Long bays, and have a major influence on circulation. Water depth ranges from 2-18 ft on the
shoals, dropping to 20-40 ft on the seafloor adjacent to them. Longshore currents interact with the
cape shoals, creating upwellings of nutrient -rich bottom water. The high productivity from
upwelling and benthic algae attract large schools of foraging planktivores which in turn attracts
larger predators, such as mackerel, cobia, and sharks. These species are targeted by fishermen on
and near Frying Pan Shoals. Some species, such as shrimp concentrate along the shoals prior to
migration in or out of the estuary. The area on and adjacent to Frying Pan Shoals within three
miles is an important commercial shrimping ground. Other recreational fisheries at this location
include tarpon, red drum, bluefish, and kingfish. Along the Cape Fear River, blue crab (juvenile and
adult) are common in the inlet system. In 2020, approved management actions included in the
Blue Crab FMP Amendment 3 established additional Crab Spawning Sanctuaries south of Pamlico
Sound, including Cape Fear River Inlet. Crab pots, trawls, crab and oyster dredges are prohibited
from March 1 through October 31 to protect female blue crabs that congregate in the inlet systems
to spawn during that time. Removal of sand from Frying Pan Shoals could fragment the habitat and
negatively affect these fish populations. Additionally, dredging sand from Frying Pan Shoals will
result in the physical removal of benthic invertebrate communities. These epifauna and infauna
species provide a food source for benthic and pelagic fish and invertebrates. By removing this
foraging habitat, benthic -pelagic coupling may be interrupted until recruitment and
recolonization occurs.
The cape -associated shoal complex is designated as Essential Fish Habitat (EFH) by the National
Marine Fisheries Service (NMFS) for several different fish species such as tuna, swordfish, billfish,
coastal and pelagic sharks, cobia, mackerel species and penaeid shrimp. A subset of Essential Fish
Habitat is designated by NMFS as Habitat Areas of Particular Concern (EFH-HAPC). These areas
are documented to be of particular importance to fishery species, and take into account ecological
function, rarity, and sensitivity to anthropogenic activities. The cape shoals are designated as EFH-
HAPC for penaeid shrimp and coastal migratory pelagic species (king and Spanish mackerel and
cobia).
In 2017, NCDMF recommended denial of the permit application as proposed due to significant
adverse impacts to a critically important habitat area, fishery species, and fishing activity. The
division stated at that time that they would reconsider if the following information was provided:
1. An Environmental Impact Statement(EIS) through the USACE
2. Assess impacts to larval transport - Dredging in Frying Pan Shoals can potentially interfere with
the passage of larvae and early juveniles from offshore spawning grounds into estuarine nursery
areas. A detailed scientific field investigation, analysis, and modelling of larval transport
dynamics that exist around Frying Pan Shoals currently and how that will change based on the
proposed dredging activity. This information should be used to model estimated impacts of the
dredging to larval ingress and egress through the inlet.
3. Assess sediment transport and refilling of borrow area - The proposal to dredge a hole, nearly
20 feet deep in some locations, in the shoal could negatively and potentially permanently alter
the habitat on the shoal. Frying Pan Shoal is classified as a relict shoal receiving much of its
sand deposits from the Holocene and Pleistocene periods (Normandeau Associates, Inc. 2014).
These shoals formed over a long period of time and may not recover at rates necessary to
sustain recurring borrow activities. It is unknown how currents, wind, and storm events will
respond spatially and temporally to removal of sand from the shoal. In addition, no studies
have been performed to investigate the type of material that is expected to be deposited within
the footprint of the excavated area. If incompatible materials fill the dredged footprint, new
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021
2

borrow sources will be sited on the shoal resulting in cumulative impacts to the habitat. A
sediment transport model should be used to investigate the previously mentioned concerns.
4. DMF would also like to seethe applicant explore alternative sand sources that may have less
significant impacts to critical fisheries habitats; this would include previously permitted
alternative borrow sources.
All of the additional information requested in 2017 has not been provided as far as the division is
aware. In the current application, the applicant did provide information on why the other
alternative locations were not viable (#4). However, Jay Bird Shoals has been able to provide
adequate sand at this point, and appears to remain a viable option. Use of some of the smaller
shoals close to shore are not necessarily unviable, the applicant just indicates they would prefer
not to dredge those to maintain wave break protection for their island.
Regarding sediment transport modelling to determine borrow area infilling and character, the
VBHI application stated that the area met the criteria of being dynamic in a highly depositional
area and was sited to minimize biological impacts to resident and transient species and their
habitats. The data and studies concluding that the area will refill, the rate of refilling, and the
type of sediment that will fill into the borrow hole were not provided. This is critical to
understanding the extent of habitat impacts, corresponding fishery impacts, and cumulative
impacts on the integrity of Frying Pan Shoals. Similarly, no data was provided to support that the
project would not cause significant impacts to fishery species. We recognize that the applicant
has provided geotechnical information on the sediment characteristics of the shoal, and has
stated that they will monitor the borrow site to determine deposition rates immediately after
construction, annually for three years, and biennially after that. While this information is critical
for assessing long-term impacts of the projects, studies prior to the excavation are needed to
avoid and minimize impacts.
The ecological effect of degrading the integrity of Frying Pan Shoals is largely unknown. McNinch
and Wells (1999) noted that the cape shoals limit sediment exchange between adjacent
embayments and that much of the sand on the shoal is from longshore transport, generally north
to south. At Cape Lookout, McNinch and Luettich (2000) also found that a seaward directed tidal
flow leads to net sediment transport from the shoal to offshore. They conclude that the seaward
flow may also serve as a primary mechanism for exporting nearshore and estuarine waters
offshore. Both studies raise questions on how and at what rate the borrow area on the west
inshore side of the shoal would refill and what effect that would have on marine organisms. The
Bureau of Ocean Energy Management (BOEM) (Normandeau Associates Inc. 2014) provided a
literature synthesis on the habitat value and function of shoal complexes to fish and fisheries
that supports the high value of shoals to a diversity of species. However specific studies were
lacking for the cape shoals in North Carolina compared to other regions. The report summarizes
information and data gaps that remain to better understand the processes of the shoals and their
ecological function for fish and invertebrates, to aid in determining what extent sand could be
removed that will not disrupt physical or ecological processes.
The proposed application requests to remove a large amount of sand (188 acres, 2.5 mcy, 20 ft
deep) as Phase 1, with intentions to repeat dredging from the borrow area indefinitely on 9-10
year cycles. As proposed, this project would have significant adverse impacts to a unique habitat
that is critical for multiple commercial and recreational fisheries. There are numerous questions
remaining that need to be addressed before this project should go forward. Staff from BOEM are
currently planning to hold a workshop this fall to discuss the state of the science of Frying Pan
Shoals and how to move forward in addressing data gaps. Until then, the applicant has a viable
alternative, use of Jay Bird Shoals. The NCDMF therefore objects to this permit modification
request. Should the project be permitted, the NCDMF requests that the applicant be required to
monitor sediment deposition rates and composition, as well as monitor benthic invertebrate
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021
3

composition and change to productivity. The project should be considered a one-time event
until all necessary research recommended by NCDMF and the 2020 BOEM workshop is
completed and reviewed.
Thank you for the opportunity to comment.
For any questions, contact Anne Deaton at [phone] or [e-mail]
Literature Cited
McNinch, J.E. and R. Luettich Jr. 2000. Physical processes around a cuspate foreland: implications to
the evolution and long-term maintenance of a cape -associated shoal. Continental Shelf
Research. 20(17), 2367-2389.
McNinch, J.E. and J.T. Wells. 1999. Sedimentary processes and depositional history of cape -
associated shoal, Cape Lookout, North Carolina. Marine Geology. 158: 233-252.
Normandeau Associates, Inc. 2014. Understanding the Habitat Value and Function of
Shoal/Ridge/Trough Complexes to Fish and Fisheries on the Atlantic and Gulf of Mexico
Outer Continental Shelf. Draft Literature Synthesis for the U.S. Dept. of the Interior, Bureau of
Ocean Energy Management. Contract # M12PS00031. 116 pp.
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 1 Morehead City, North Carolina 28557
252-726-7021
4

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
STEPHEN W. MURPHEY
June 5, 2020 Director
Heather Coats, DCM Beach and Inlet Management Project Coordinator
NC DEQ Division of Coastal Management
127 Cardinal Dr. Ext.
Wilmington, NC 28405
Re: Village of Bald Head Island; major modification to dredge Frying Pan Shoals for beach
nourishment
Dear Ms. Coats:
After discussions with staff, I concur with their recommendation to deny this major modification
request to dredge 2.5 million cubic yards within a 188.7 acre borrow area to a depth of
approximately -20 feet from the west side of Frying Pan Shoals within state waters. The material
would be piped to nourish 17,200 linear feet of beachfront along South Beach. Approximately 98
acres of the material would be placed below the mean high water line. Frying Pan Shoals is a
critical habitat resource for multiple fishery species, particularly Penaeid shrimp, blue crab, and
coastal migratory species. Additional information on geological and oceanographic characteristics
of the shoal, how these traits enhance fish use near Frying Pan Shoals, how the excavation would
affect the ecosystem services provided by the shoals, and the rate and character of redeposition at
the borrow area is needed to fully understand the extent of impact excavation would have on fish
habitat and associated fisheries. Due to the magnitude of the project, the importance of fisheries
associated with the cape structure, and the many remaining data gaps, the division objects to
excavation of Frying Pan Shoals for beach nourishment at Bald Head Island.
Please keep Anne Deaton informed on the final status of the proposed project. Thank you for the
opportunity to comment on this application.
Sincerely,
Stephen W. Murphey, Director
NC Division of Marine Fisheries
Cc: Braxton Davis, DCM Director
Dee Lupton, DMF Deputy Director
Anne Deaton, DMF Habitat Protection Manager
%'Nothing Compares_".,
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 1 Morehead City, North Carolina 28557
252-726-7021

ROY COOPER
MICHAEL S. REGAN
BRAXTON DAVIS
C_W-05.ocr.&f
May 5, 2020
MEMORANDUM.
FROM: Heather Coats, Beach & Inlet Management Project Coordinator ;4567 8
NCDEQ - Division of Coastal Management
``2, 19
127 Cardinal Drive Ext., Wilmington, NC 28405
Fax: [phone] (Courier 04-75-33)
MAY202o
heather.coatsO-ncdenr,gov
SUBJECT: CAMA /Dredge & Fill Application Review
t z
r
l
Applicant: Village of Bald Head Island
Project Location: Beachfront area along South Beach, adjacent to the Atlantic Ocean ape Fear River,
Bald Head Island, Brunswick County
Proposed Project: Beach nourishment project
Please indicate below your agency's position or viewpoint on the proposed project and
return this form to Heather Coats at the address above by May 29, 2020. If you have any questions
regarding the proposed project, contact Heather Coats at [phone] when appropriate, in-depth
comments with supporting data is requested.
REPLY: This agency has no objection to the project as proposed,
**Additional comments may be attached**
This agency has no comment on the proposed project.
This agency approves of the project only if the recommended changes
are incorporated. See attached.
This agency objects to the project for reasons described in the attached comments.
PRINT NAME
AGENCY (it-12
SIGNATURE
GATE
State of North Carolina J Envnonmental Quality I Coastal Management
127 Cardinal Drive Fact, Wilmington, NC 2W5 919 796 7215

9 North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO: Heather Coats
Division of Coastal Management
North Carolina Department of Environmental Quality
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: June 19, 2020
SUBJECT: CAMA Dredge/Fill Permit Modification for Village of Bald Head Island, 491-14,
Brunswick 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 sites are located in an
approximately 189.7-acre borrow area on the western side of Frying Pan Shoals and 17,200' of
beachfront along South Beach adjacent the Atlantic Ocean and Cape Fear River on Bald Head Island, NC_
Our comments are provided in accordance with provisions of the Coastal Area Management Act (G.S.
113A-100 through 113A-128), as amended, Sections 401 and 404 of the Clean Water Act, as amended,
and the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.).
The applicant proposes a Major Modification of Permit 4 91-14 for the use of Frying Pan Shoals as a one-
time borrow site for the nourishment of 17,200' of beachfront on Bald Head Island. The 188.7-acre
proposed borrow source is within a 460-acre site previously proposed in 2017 as a multiuse borrow
source for the same nourishment activity. The NCWRC reviewed and commented on the proposal (Dunn
9 March 2017) providing guidelines for nourishment activities and stating concern regarding impacts to
and support for state and federal marine resource agencies' recommendations for avoidance and
minimization of impacts to the important habitat areas associated with Frying Pan Shoals. After review of
agency comments, the applicant removed from consideration the use of Frying Pan Shoals and only
utilized Jay Bird Shoals for the 2019 nourishment event. The current proposal states Jay Bird Shoals no
longer contains adequate amounts of material for nourishment and that other sources that contribute to the
sediment management of Bald Head Island's shore, such as the USACE Wilmington Harbor, the VBHI
marina channel, the Bald Head Creek channel, the terminal groin and groin field, are insufficient in
providing material and reducing beachfront erosion to satisfy the island. The beach fill template extends
from Station 48+00 to Station 218+00 with a potential taper to Station 220+00. The beach construction
berm would conform to previously permitted dimensions, with a maximum berm elevation of +8.5'
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fag: [phone]

NGVD29. The beach profile would have an average width of 350' over the length of the entire 17,200'
beachfront and would include a 20:1 slope. An estimated 98 acres of fill would be placed below MHW.
The applicant states 2.5 million cubic yards of material would be used for the nourishment event and 8.5
million cubic yards of material would be available at Frying Pan Shoals for future use. The application
states the VBHI would be responsible for any dune revegetation or stabilization deemed necessary by
agencies in a separate contract and visual surveys of escarpments and remediation would be conducted
prior to turtle nesting season.
The NCWRC has reviewed the permit application and has concern regarding the proposed borrow area
and associated impacts removal of material may have on important marine resources, invertebrate
recruitment, and sediment transport. Frying Pan Shoals provides important marine fishery habitat.
Removal of material from this area may alter these habitat areas significantly. Although the NCWRC
generally voices concern with impacts to more anadromous, estuarine, and inland fish species, we
strongly encourage the applicant and permitting agencies to coordinate with and incorporate concerns and
management practices recommended by state and federal marine resource agencies. Concerns voiced
during the 2017 permit application review process and recommendations regarding modeling and data
acquisition 1 reporting should be completed prior to consideration of permit issuance. If these concerns are
not determined to be adequately addressed by state and federal marine resource agencies, the applicant
should consider nourishment template redesign to minimize project scope or alternate borrow source
areas. While the current application states this request is a one-time use, the narrative does reference the
total amount of material within Frying Pan Shoals that could be available for nourishment. This indicates
not a one-time removal of material, but subsequent removals and associated cumulative impacts.
Independent of source material location and sediment compatibility, projects that affect oceanfront
beaches and natural inlet processes such as beach nourishment, inlet dredging, inlet relocation and the
construction of hardened structures on or along beaches may adversely affect nesting sea turtles and
shorebird foraging and nesting areas. Due to the scope of this project and the documented use of the
beaches by sea turtles and shorebirds, the NCWRC has the following comments and recommendations:
— The NCWRC has an established sea turtle nesting moratorium that reduces the potential
for unintended impacts to nesting sea turtle species that frequent the coast of North
Carolina. To avoid impacts to these species, all work on the oceanfront shoreline,
including mobilization and demobilization for all beach nourishment events should be
conducted outside of the sea turtle nesting season which runs from May 1 until November
15, or until the last known sea turtle nest has hatched.
— Oceanfront beaches on Bald Head Island provide suitable nesting, foraging and roosting
areas for multiple shorebird species. Nesting birds are sensitive to increased human
activity and other disturbances around their nesting areas. To limit unintended impacts to
nesting bird species in and near the project area, all work should adhere to the shorebird
nesting period from April 1 until August 31_
--- To protect both nesting shorebirds and sea turtles Iles on Bald Head Island, a combined April 1
— November 15 moratorium should be included as a permit condition.
— Survey and monitoring reports should be provided to the appropriate parties in a timely
manner and consultation should be done with regulatory and resources agencies prior to
ceasing or changing any survey or monitoring activity. The NCWRC requests copies of
these reports associated with the permitted activity_

— As stated in our comments provided during the review of the terminal groin application,
regular nourishment events could potentially impact benthic invertebrate populations
Benthic invertebrates are an important food source for foraging birds, both resident and
migratory, during both the breeding and nonbreeding seasons. Regular beach nourishment
events, such as every five years, can reduce benthic populations when populations are not
given appropriate time for recovery. This project in addition to other dredging and
nourishment projects in the area impose frequent disturbance.
The application states the design template for material placement will be as previously
permitted and conducted. Any area where the newly nourished beach ties into the existing
profile should not have a backslope or trough upon completion that could trap or misonent
nesting female sea turtles or hatchings.
— The application states the applicant will be responsible for any dune revegetation or
stabilization as deemed necessary. To minimize impacts to nesting sea turtles and their
habitats, guidelines have been established for dune planting and sand fence installation.
We request the applicant consult resource agencies prior to finalizing design or contracts
so measures can be implemented to minimize impacts to wildlife and public trust
resources. These measures may include planting or fence positioning, methodology, and
scheduling_ Ideally all activities should adhere to the aforementioned moratorium.
— To aid in the understanding of sediment management activities on Bald Head Island, their
success, scheduling, and associated impacts, we recommend an overview of all projects
on Bald Head Island he conducted and a single comprehensive management plan
developed.
The NCWRC appreciates the opportunity to review and comment on this permit modification. If you need
further assistance or additional information, please contact me at [phone] or
maria.dunn(u;,ncwildlife.or(,

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Roy Cooper
Secretary Susi H. Hamilton
June 16, 2020
MEMORANDUM
TO: Heather Coats
Beach & Inlet Management Project Coordinator
NCDEQ - Division of Coastal Management
FROM: Ramona M. Bartos, Deputy
State Historic Preservation Officer
Office of Archives and History
Deputy Secretary Kevin Cherry
heather. coats&ncdenr.gov
SUBJECT: Beach nourishment, along South Beach, Bald Head Island, Brunswick County, ER 20-1126
Thank you for your May 5, 2020, submission concerning the above -referenced project. We appreciate you
submitting the additional survey report and will keep it on file as a courtesy copy at the Office of State
Archaeology.
A review of our files indicates nine known archaeological sites are located along the Cape Fear Inlet opening
adjacent to the South Beach of Bald Head Island, including Jaybird Shoals. The six wrecks closest to the project
are the CFI004 Sandpiper Wreck, CFI001 Ella, CFI003 Bald Head Rudder Wreck, CFI0002 Baldhead Ballast
Wreck, CFI0006 Jay Bird Shoals Site, and CFI0007 Wes Hall Site-R1-14.
The Bald Head Island south beach renourishment project has the potential to affect these culturally significant
shipwrecks, if avoidance protocols are not enacted. Avoidance is essential given the potential of irreparable
damage to cultural resources, as well as to the dredging equipment, as site CFI001 - the Ella is a substantial
steel structure.
All contractors and heavy equipment operators in the renourishment area should be aware of the presence of
these wrecks, as well as possible beach materials, and should be prepared to stop work if such objects are
discovered. While the only sites noted on the beach have been disarticulated wreck fragments, this was an area
of high maritime activity for the last 450 years, and it is entirely possible that the aforementioned sites may
occasionally deposit more fragments on the beach.
We are aware however that work has been carried out in the area in the past, with the dredging of the channel
and the installation of stone jetties. We, therefore, concur with the recommendation outlined in the submitted
report from 2016, which states "In the event that the buffered anomalies can be avoided, no additional
investigation is recommended in conjunction with the proposed project." To that effect, we offer this
"unanticipated discoveries" condition:
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

If additional cultural resource(s) are identified during monitoring and/or construction, all work will be
halted within the limits of the resource(s) and the Office of State Archaeology (OSA) will be contacted.
Work should move to another area and the Underwater Archaeology Branch should be contacted
immediately (910-250-7320). A staff member will be sent to assess the wreckage and determine the
proper course of action.
The OSA will initiate the coordination required for a determination of eligibility or recovery effort. If
after consultation between the County and OSA, additional mitigation is determined necessary, the
County, in consultation with OSA, will develop and implement appropriate protection/mitigation
measures for the resource(s). Inadvertent or accidental discovery of human remains will be handled in
accordance with North Carolina General Statutes 65 and 70.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36 CFR
Part 800.
Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-814-6579 or
[e-mail]. In all future communication concerning this project, please cite the above -
referenced tracking number.