20040561 Ver 4_NMFS email response VBHI biological monitoring plan 2022_20220406

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Fritz Rohde - NOAA Federal
Ronald Smith
Pace.Wilber; Twyla Cheatwood - NOAA Federal; Deaton, Anne; Howell, Jonathan
[External] VBHI biological monitoring plan
Tuesday, April 5, 2022 5:28:49 PM
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Hi Ronnie:
Thank you for sending us the Village of Bald Head Island Frying Pan Shoals Beach Nourishment
Project Biological Monitoring Plan (January 2022). The position of the National Marine Fisheries
Service regarding the dredging of Frying Pan Shoals is unchanged since our comment letter of
March 30, 2017 (attached), which included four conservation recommendations. Frying Pan Shoals
is a dynamic environment and we have concerns about physical impacts to the shoals, such as but
not limited to altered wave climate, turbidity, infilling rates, and grain size distribution filling the
excavation site. Fisheries concerns include spatial and temporal impacts to the fish and invertebrate
communities over the short and long term, the biological components of the ecosystem and impacts
to all life stages, and micro -habitat use.
Comments on the proposed plan follow:
The updated biological monitoring plan involves a fisheries component to help address concerns by
the resource agencies regarding the lack of fisheries data for Frying Pan Shoals. The applicant is
proposing to use a 12-ft otter trawl along six transects with 1-minute tows inside the proposed
borrow area (total of 15 tows) and 12 tows outside the borrow area (reference or control). While a
small trawl such as proposed would be adequate to document juvenile, demersal fish populations in
narrow estuarine creeks, it is woefully inadequate in the Atlantic Ocean. The SEAMAP Shallow
Water Trawl Survey already has standardized methodology (net size and tow times), which could be
employed in this study to provide meaningful results. The applicant references the fish studies at
Canaveral Shoals, which reported that there was no evidence to indicate that fish use of the dredge
site (which had experienced multiple dredge operations since 2000) differed from the nearby control
site. This is the proverbial apple to oranges comparison since the Canaveral studies used long lines
to capture large, more mobile fishes and the acoustic telemetry study did the same; they did not use a
small trawl.
The following is taken from a Scope of Work from ERDC for an assessment of the benthic
community at an offshore borrow area off Topsail Beach, NC and NMFS recommends the same
approach for this study:
"Benthic samples will be collected using a Young Grab Sampler, which is a modified version of the
Van Veen Sampler. The Young grab sampler is a stainless steel clamshell-type grab sampler similar

to a Ponar dredge. Sample size is 0.04 m2 and is typically used for marine benthic macroinvertebrate
sampling and has become the standard grab sampler used by NOAA, USGS and USEPA."
With regards to Number 2 in our letter (alternative sites), has the applicant ever investigated the use
of material in the ODMDS?
Thank you for considering these comments.
Best regards
Fritz