20040561 Ver 4_DMF response to VBHI modified monitoring plan draft 04012022_final_20220406

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
KATHY B. RAWLS
Director
April 6, 2022
TO: Heather Coats, DCM Beach and Inlet Management Project Coordinator
FROM: Anne Deaton, DMF Habitat Program Manager
SUBJECT: Response to VBHI March 23, 2022 letter re: CAMA Permit # 91-14, VBHI South Beach
Nourishment with Frying Pan Shoals Borrow Source
The NC Division of Marine Fisheries (DMF) has reviewed the latest information provided by Davey
Resource Group on behalf of Village of Bald Head Island (VBHI), regarding the proposed modification to
nourish South Beach using sand from Frying Pan Shoals (FPS).
In response to DMF's comments provided in May and June 2022, the VBHI updated the project's
biological monitoring plan to include a fisheries monitoring component. While DMF appreciates the
applicant's willingness to obtain pre- and post -data on fish species and abundance in the vicinity of the
proposed dredging, DMF fishery scientists have reviewed the proposed sampling protocol and found it to
be inadequate for several reasons. The described trawling is inappropriate to successfully sample in the
ocean. To accurately characterize fish use of different trophic level species and life stages, different trawl
mesh sizes and a variety of gears are needed. Also, due to interannual variability of catch, more than one
year of pre -data is needed. Finally, the information required to accurately assess potential cumulative
impacts to the ecological productivity of FPS, requires that the data be obtained prior to permitting the
project. The National Marine Fisheries Service (NMFS) comments on the latest biological monitoring
plan are attached.
The applicant states in their letter that since the Canaveral Shoals research did not identify change in fish
use near the dredge site, dredging at FPS should have the same impact. The Canaveral Shoals complex is
located at the transition between the warm temperate and subtropical biogeographic zones and therefore
supports different fish species, benthic, and planktonic assemblages and is not comparable. Data are
needed specific to Frying Pan Shoals.
The applicant states they do not see the necessity of waiting for the BOEM study to be completed due to
the delay and that the study would occur in federal waters. However, funding was approved for the
project (FY 2022-2025) and an RFP for the project is expected to be posted soon with sampling likely
beginning in fall 2022. The draft protocol includes a comprehensive approach to monitoring the
ecosystem structure and dynamics at various locations on FPS. The study will be limited to federal
waters, beginning three miles offshore. Conducting a complimentary study within state waters during the
same time period as the federal study would be a timely and cost-effective approach. Comprehensive
studies on physical, benthic, planktonic, and fish characterization coupled with sand transport modelling
for potential impacts from dredging into the shoals are needed. The modeling should include assessing the
effect of one or more borrow areas of different configurations and locations to fully understand the limits
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

of sand mining before negative consequences occur. Confident estimates of sediment infilling rate and
sediment type at potential borrow areas must be included. Essentially, the latest proposed monitoring
provided by VBHI remains inadequate.
While we understand that this modification request is for a one-time dredging event, it will establish a
precedent for dredging NC's cape shoals, which support the framework of NC's barrier islands that are
well known for their ecological productivity and value, are critical to multiple fish species and fisheries in
NC, and are federally designated as Essential Fish Habitat -Habitat Area of Particular Concern (EFH-
HAPC) for species and fisheries important to North Carolina. Please refer to past comments on the
ecological value of FPS for fish populations. For this reason, comprehensive studies are needed to
evaluate potential impacts of the proposed project.
In summary, the additional monitoring offered by VBHI does not satisfy DMF's concerns with permitting
this modification and DMF continues to object to the proposed project due to significant adverse impacts
to marine and estuarine fishery resources, as described in previous memos. The DMF's opinion is
consistent with NOAA's assessment of the updated plan as being inadequate and its recommendation to
eliminate FPS as a sand source due to its importance as EFH-HAPC to Aquatic Resources of National
Importance.
We appreciate the opportunity to comment. If you have any questions, please contact Anne Deaton at
[e-mail]; 910-796-7311.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021