20040561 Ver 4_DMF Comments_20210709

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
KATHY B. RAWLS
Director
July 9, 2021
Heather Coats, DCM Beach and Inlet Management Project Coordinator
NC DEQ Division of Coastal Management
127 Cardinal Dr. Ext.
Wilmington, NC 28405
Re: Clarification on DMF May 11, 2021 Comments re Major Modification to CAMA Permit # 91-14,
VBHI South Beach Nourishment with Frying Pan Shoals Borrow Source
Dear Ms. Coats:
After staff discussions, the division continues to object to this project as proposed due to significant
adverse impacts that could occur to multiple commercially and recreationally important fishery species.
Additional information provided by the applicant was insufficient to remove our concerns.
We appreciate the opportunity to comment. Please keep Anne Deaton informed on the final status of the
proposed project.
Sincerely,
tii/5
Kathy B. Rawls, Director
NC Division of Marine Fisheries
Cc: Braxton Davis, DCM Director
Dee Lupton, DMF Deputy Director
Anne Deaton, DMF Habitat Program Manager
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
KATHY B. RAWLS
Director
July 9, 2021
TO: Heather Coats, DCM Beach and Inlet Management Project Coordinator
FROM: Anne Deaton, DMF Habitat Program Manager 4 D
SUBJECT: Clarification on DMF May 11, 2021 Comments re Major Modification to CAMA Permit
# 91-14, VBHI South Beach Nourishment with Frying Pan Shoals Borrow Source
The Division of Marine Fisheries (DMF) reviewed and provided comments in May 2021 to additional
information provided by Land Management Group (LMG) on behalf of Village of Bald Head Island
(VBHI), regarding the proposed modification to nourish South Beach using sand from Frying Pan Shoals
(FPS). These additional comments are provided to clarify the May 2021 letter.
In 2017, DMF objected to a major modification to use Frying Pan Shoals as the sand source for beach
nourishment rather than the originally permitted Jay Bird Shoals. The reason for the objection was based
on significant adverse impacts to numerous fishery species and their habitat due to the repeated dredging
of Frying Pan Shoals. Additionally, DMF requested a more thorough review of project impacts be
provided in an Environmental Impact Statement, which would include additional information on impacts
to larval transport, expected sediment infilling, and further evaluation of alternative sources. In May 2020,
the VBHI submitted a revised application that was nearly identical to the 2017 application. Therefore, the
division responded in June 2020 that their concerns remained and reiterated the division's previous
request for additional information to evaluate the project. After receiving an Essential Fish Habitat (EFH)
Assessment and additional sediment modelling from the consultant, DMF responded in May 2021 that the
newly provided information had not sufficiently addressed their concerns. The applicant has not
addressed larval transport impacts, or how the changes to FPS will affect the forage and fishery species
that utilize the area. The benthic sampling offered by the applicant was not sufficiently robust to address
the ecosystem level impacts that could occur.
To clarify, the division continues to object to the proposed project due to significant adverse impacts to
marine and estuarine fishery resources. Frying Pan Shoals is known to support a high diversity of fish and
benthic invertebrate species and to support high overall productivity. Large schools of plankivores draw
in larger species that are commercially and recreationally important. Federal and state portions of Frying
Pan Shoals complex and the adjacent inlet are designated as Essential Fish Habitat (EFH) - Habitat Areas
of Particular Concern (HAPC) by the South Atlantic Fishery Management Council (SAFMC) and the
National Marine Fisheries Service (NMFS) for coastal migratory pelagics (mackerel, cobia), penaeid
shrimp, and snapper -grouper species. Dolphin, wahoo, tarpon, coastal sharks, and other highly migratory
species (tuna, billfish) occur on and around the shoals. Numerous state and interjurisdictional managed
species also utilize FPS, including spotted sea trout, red drum, Atlantic croaker, spot, Atlantic menhaden,
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

southern flounder, bluefish, and blue crab. The NC Marine Fisheries Commission identified FPS as a
Strategic Habitat Area in 2018 and designated the mouth of the Cape Fear River, including a portion of
the shoal, as a Crab Spawning Sanctuary in 2020. Additionally, the estuarine plume that extends
approximately six kilometers from the river mouth into the ocean supports a high number of larval fish
taxa, and is thought to greatly enhance fisheries productivity (Markovsky 2004).
While there is general knowledge of species presence at FPS, more precise spatial and temporal
characterization of species' use is not known. This information is critical to determining where and how a
borrow area could be sited in a manner that would avoid and minimize impacts to fish productivity of the
area. Greater understanding of the mechanisms that contribute to the high productivity of FPS is needed
to fully understand the biological implications of dredging in various locations of the shoal complex.
Furthermore, different locations on the shoal should be evaluated for borrow sites to determine the least
environmentally damaging practicable alternative sand source. For example, consider the shoal crest as
well as the base, east versus west flanks, closer to shore versus farther offshore.
In summary, because FPS is a unique and highly productive area, it is critical to fully evaluate potential
impacts to fishery resources that may occur from the establishment of sand borrow sites under various
scenarios. The information is needed to do the analysis and should be done prior to dredging.
Additionally, a full analysis of Jay Bird Shoals should be done to determine why that borrow site has not
successfully refilled, to inform future borrow site designs. To efficiently determine priority research
needs, particularly related to biological resources, DMF suggests that a scientific workgroup be formed,
comprised of researchers with various expertise to develop and prioritize research needs and coordinate
the effort with BOEM to initiate that research.
Feel free to contact me if you have any questions: 910-796-7311; [e-mail]
Literature Cited
Markovsky, W.C. 2004. The role of the Cape Fear River discharge plume in fisheries
production: aggregation and trophic enhancement. A Thesis submitted to the University
of North Carolina at Wilmington. Department of Biological Sciences. 86 pp.
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021