20071670 Ver 3_WRC Comments_20231026

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
MEMORANDUM
TO: Emily Hughes
Wilmington District
US Army Corps of Engineers
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FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: October 26, 2023
SUBJECT: SAW-2007-03344 Modification Request, Maintenance Dredging US Coast Guard Station
Emerald Isle, Carteret County, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the modification
request with regard to impacts on fish and wildlife resources. 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, the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531 et seq.), the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661 et seq.), the Magnuson -Stevens Fishery Conservation and Management Act (FCMA), as
amended (16 U.S.C. 1801 et seq.), and the Migratory Bird Treaty Act (16 U.S.C. 703-712 et seq.).
The US Coast Guard station Emerald Isle (USCG EI) is requesting a modification to their US Army
Corps of Engineers (USAGE) permit to maintain navigation from USCG EI to the federally maintained
navigation channel within Bogue Inlet. The modification includes expansion of the project area to allow
dredging to occur as needed within an approximately 650-acre area and to extend the authorization until
2033. All other aspects of the existing allowance are proposed to remain the same.
The NCWRC has reviewed the modification request. We have been involved with and have commented
numerous times throughout the past two decades on this project as well as other projects in the area. The
most recent comments (Dunn 12 September 2022) were submitted during the Draft Environmental
Assessment review that included the new 300' "shortcut" route. Our continued interest and involvement
are due to the important wildlife resources in the vicinity. Bogue Sound and the Bogue Inlet complex
provide important habitat opportunities for numerous federally and state listed species, including piping
plover (Charadrius melodus melodus), red knot (Calidris canutus rufa), roseate tern (Sterna dougallii
dougallii), gull -billed tern (Sterna nilotica), common tern (Sterna hirundo), least tern (Sterna antillarum),
black skimmer (Rynchops niger), snowy egret (Egretta thula), tricolored heron (Egretta tricolor), little
blue heron (Egretta caerulea), glossy ibis (Plegadis falcinellus), Wilson's plover (Charadrius wilsonia),
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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American oystercatcher (Haematopus palliatus), and Kemp's Ridley (Lepidochelys kempi), hawksbill
(Eretmochelys imbricata), leatherback (Dermochelys coriacea), loggerhead (Caretta caretta), and green
(Chelonia mydas) sea turtles. Therefore, all development and maintenance activities should take into
account the presence of these species and their habitats.
The NCWRC does not object to the expanded project area as presented in the September 26, 2023
correspondence. Measures to minimize impacts to resources include inclusion of the April 1 — November
15 moratorium and a buffer around submerged aquatic vegetation (SAV) during dredge events. The
avoidance of staging, dredging and placement of material during these months avoids peak biological
periods of activity and can greatly reduce the project's direct impact on species.
The NCWRC has consistently requested the USACE consider beneficial placement of material in areas
other than the Emerald Isle beach placement area. Our agency notes the USACE responded that they
removed Bogue Island Shoal as a placement option as it was not their intention to use the site. The
NCWRC requests the USACE reconsider adding Bogue Island Shoal and other areas as placement
options during this 10-year permit renewal process, even if detailed plans cannot be provided at this time.
Important coastal habitats, such as shoals, bare sand islands, vegetated islands, and coastal wetlands are
being negatively impacted by erosional activities such as sea level rise. Managing our coastal resources to
provide resiliency may be an important endeavor during the next 10 years. Therefore, we request SAW-
007-03344 include other placement areas as options for material placement. A reference of these areas
within the permit would allow them to be considered whereas if they are not included, they would not be
options until after 2033. The details regarding methodology, volumes, and management could be
evaluated and presented within the 10-year period as opportunity for placement arises. If a specific list of
areas cannot be presented at this time, we request a statement be added that would allow the option to
modify the permit within the 10-year period to increase beneficial placement opportunities. To benefit
habitats in the area, we encourage the USACE to coordinate with the North Carolina Division of Parks
and Recreation, Hammocks Beach State Park to learn of available placement areas and habitat
management needs. Use of these areas would provide additional placement options for USACE, help
meet the USACE beneficial use goal, aid in the management of coastal resources, and offset negative
impacts of beach disposal. Representatives from North Carolina State Parks will be copied on this
correspondence.
While we understand the Town of Emerald Isle and the Carteret County Shore Protection Office will be
in consultation with the USACE for material placed within the designated beach and nearshore deposition
areas and that any manipulation outside the designated areas would require additional authorizations, we
would like to once again reference the Bogue Inlet Waterbird Management Plan (2004) prepared by the
NCWRC and the US Fish and Wildlife Service (USFWS). This document was established to help address
and mitigate impacts the realignment of Bogue Inlet had on avian resources on the western end of Bogue
Banks within the Town of Emerald Isle. While the USACE may not be directly involved in some of the
management strategies of this document, we request they encourage the Town and County to consult with
resource agencies and abide by the existing plan during material placement events.
Thank you for the opportunity to review this modification and renewal request. If there are any
comments, questions, or concerns please do not hesitate to contact me at maria.dunn(kncwildlife.org or
252-495-5554.