20040561 Ver 4_WRC Comments_20200619

Staff Review
Does this application have all the attachments needed to accept it into the review process?*
r Yes r No
ID#* Version* 4
20040561
Is this project a public transportation project?* r Yes
r No
Reviewer List:* Robb Mairs:eads\rlmairs2
Select Reviewing Office:* Wilmington Regional Office - [phone]
Does this project require a request for payment to be sent?*
r
Yes
r
No

Project Submittal Form
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mandatory questions are answered.
Project Type:* r New Project r New Project Existing ID
r Pre -Application Submittal r More Information Response
r Other Agency Comments r Stream or Buffer Appeal
r For the Record Only (Courtesy
Copy)
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r DCM Comments
r DFM Comments
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r DCM Permit
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Project Contact Information
Name: Maria T Dunn
Who is submitting the inforrration?
Email Address: [e-mail]
Project Information
Existing ID #: Existing Version:
20040561 4
20170001(no dashes) 1
Project Name: Village Of Bald Head Island
Is this a public transportation project?
r Yes
r No
Is the project located within a INC DCM Area of Environmental Concern (AEC)?
r Yes r No r Unknown
County (ies)
Brunswick
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CMDF_VBHI #91-14 mod_NCWRC^.pdf 1.51 MB
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W By checking the box and signing box below, I certify that:
• I have given true, accurate, and complete information on this form;
• I agree that submission of this form is a "transaction" subject to Chapter 66, Article 40 of the NC General Statutes (the
"Uniform Electronic Transactions Act")
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(the "Uniform Electronic Transactions Act');
• I understand that an electronic signature has the same legal effect and can be enforced in the same way as a written
signature; AND
• I intend to electronically sign and submit the online form."
Signature:
Submittal Date: Is filled in autonatically.

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(,