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Home My WebLink About20240027 Ver 1_More Info Received_20240308NN AT i E SHORELINES a DAFEY#— company 8 March 2024 Cameron Luck Assistant Major Permits Coordinator NC Division of Coastal Management NC Department of Environmental Quality 400 Commerce Avenue Morehead City, North Carolina 28557 via email Native Shorelines Davey Resource Group, Inc. 1101 Haynes Street, Suite 211 Raleigh, North Carolina 27604 RE: Major Permit Application for Proposed Living Shorelines at the Pine Knoll Shores Aquarium (PA-1139), Pine Knoll Shores, North Carolina Dear Mr. Luck: We have reviewed the comment letter sent to us by NCDWR directly as well as the letters from NCDMF and NCWRC that you provided earlier this week in reference to the above permit application. Please see our responses below acting as Authorized Agent for NC Parks, the permittee. The NCWRC letter of 19 February 2024 states that the project proposes 5' gaps between the sections of proposed living shoreline. As stated in Section 5.0 Proposed Living Shorelines on page 10 of the project narrative, all but one of the gaps are currently proposed as 10 to 25-foot gaps. There is one single 5-foot gap proposed in Section B to reduce SAV impacts at that location. Each of the workplan maps also shows that all but the aforementioned gap are 10 to 25 feet wide. As such, the NCWRC's request has already been met and no changes to the plans or narrative are required. Please review our narrative and maps for more information. 2. The NCWRC letter of 19 February 2024 requests that all materials be no higher than 1-foot above mean high water (MHW). Sill heights as proposed and drawn on the workplans will vary from 0.83-feet to 2.33-feet at their maximum heights and water depths at MHW across the alignment are generally 1.5 to 3.0 feet. As such, all structures are already currently proposed to have a maximum height of no more than 1-foot above MHW. As such, the NCWRC's request has already been met and no changes to the plans or narrative are required. www.nativeshorelines.com Comment Response Letter 8 March 2024 Major Permit Application for Proposed Living Shorelines at the Pine Knoll Shores Aquarium (PA- 1139), Pine Knoll Shores, North Carolina 3. The NCDWR letter of 23 February 2024 requested an updated monitoring plan and the NCDMF letter of 4 March 2024 laid out several requests NCDMF has for monitoring at the site. A detailed monitoring plan was provided in the permit application as Section 11.0 Monitoring on pages 23 through 25 of the project narrative which committed the applicant to more in-depth monitoring than is typically proposed for a shoreline stabilization project. The permittee is concerned about the precedent set by additional in-depth monitoring requirements as to our knowledge no shoreline stabilization project permitted to date in North Carolina has required such monitoring (the only monitoring required for the Hammocks Beach State Park Living Shorelines was monitoring of erosion at the gaps to monitor for scour so that gaps could be closed/baffled if scouring/erosion occurs). Nonetheless, in the interest of scientific information gathering purposes and to further the science and practice of living shorelines, and not to be tied to any success criteria or future actions associated with the proposed living shoreline, the NC Coastal Federation has agreed to fund 3 years of monitoring at the proposed project by independent researchers with East Carolina University and the University of North Carolina at Chapel Hill under the direction of Drs. Rachel Gittman and Joel Fodrie. As such, Section 11.2 Marsh and Seagrass Vegetation Sampling shall be edited to read: To characterize intertidal marsh vegetation and intertidal to subtidal seagrass at each location, we will delineate ten (10) intertidal to subtidal shore perpendicular transects per substrate type (Natrx, Quick Reef, Oyster Catcher) and at two (2) control locations (no structure installed) for a total of 50 transects. Transect locations will be selected using restricted random sampling (restricted to be at least 10 meters (m) apart to maintain independence and to have seagrass within 30 meters of the marsh edge) per substrate type (N=4, including no structure) using a random number generator and a grid system across the study site (Heckles et al. 2002). Transects will begin at the shrub -scrub vegetation or high-water line and extend seaward. Marsh plots will be established at 3- or 5-m intervals along each transect beginning at the upper marsh edge and ending at the low marsh edge (per Gittman et al. 2016). The length of each transect and total number of marsh plots established will depend on the marsh width from seaward edge to upland vegetation at each site. Percent cover by marsh plant species will be estimated using NCVS cover categories per 0.25-m2 plot (Daoust and Childers 1998). We will continue the transect into subtidal areas up to 30 in seaward of the marsh edge. Sampling plots beginning at the lower marsh edge will occur every meter along each transect and seagrass percent cover by species will be quantified using Braun-Blanquet percent cover methodology in 0.25-m2 quadrats in accordance with APNEP Tier 2 Comment Response Letter 8 March 2024 Major Permit Application for Proposed Living Shorelines at the Pine Knoll Shores Aquarium (PA- 1139), Pine Knoll Shores, North Carolina monitoring protocols. Surface elevation will be measured at each plot using a Trimble Virtual Reference Station (VRS; Trimble, Sunnyvale, California, USA), Real Time Kinematic (RTK), Global Positioning System (GPS). North American Vertical Datum of 1988 (NAVD88) elevations will be obtained using these methods. Transects will be sampled once per year in the spring/summers of 2024, 2025, and 2026. It is estimated that field time alone to complete the SAV and marshgrass sampling detailed above will require 60 to 100 hours per monitoring event for a total of 180 to 300 hours with an additional 80 to 100 hours of data analysis and reporting per event (240 to 300 hours total) for a total man-hour estimate of 420 to 600 hours or between $84,000 and $120,000. We have also added a layer to the ArcGIS Online project viewer provided with the project narrative and available at ht1ps://arc2.is/lz80y00 showing a 30-foot buffer from the waterward edge of all proposed living shoreline structures so that resource and regulatory agencies can better visualize the distance between the proposed structures and previously mapped SAV populations. We trust that this response satisfies the current holds on the permit application and that a permitting decision can be made promptly. If you have any additional questions, please contact me at (252) 333-9852 or mary-mar ag ret&nativeshorelines.com. Sincerely, NATIVE SHORELINES s 141? Mary -Margaret S McKinney, RF Director of Coastal Restoration cc: Dr. Lexia Weaver, NC Coastal Federation Juan Cervera, NC Parks, permittee Dr. Carol Price, NC Aquariums Dr. Rachel Gittman, East Carolina University Dr. Joel Fodrie, the University of North Carolina at Chapel Hill Michael Meilinger, NCDWR Maria Dunn, NCWRC James Harrison, NCDMF Sarah Hair, USACE