20160801 Ver 1_OIB 30 Year Plan FWS reply to USACE_20161011

VJ
United States Department of the Interior
FISH AND WILDLIFE SERVICE
Raleigh Field Office
Post Office Box 33726
Raleigh, North Carolina 27636-3726
October 11, 2016
Mr. Tyler Cr unbley
U. S. Army Corps of Engineers
Wilmington Regulatory Field Office
69 Darlington Avenue
Wilmington, North Carolina 28403-1343
Subject: Town of Ocean Isle Beach 30 -Year Beach Management Plan
Brunswick County, NC
Action ID #SAW- 2016-01642
Dear Mr. Ctumbley:
This letter is in response to the U.S. Army Corps of Engineers' (Corps) Public Notice dated
September 12, 2016, concerning the Town of Ocean Isle Beach's proposed 30 -Year Beach
Management Plan. The U. S. Fish and Wildlife Service (Service) has reviewed the public notice
and has the following comments.
1. The Service recommends that an Environmental Impact Statement (EIS) be prepared for the
project. The scope of the proposed work, length of the project, and interactions with other
proposed actions warrant full consideration under the National Environmental Policy Act
(NEPA).
2. The EIS should consider a full suite of alternatives to address the project purpose and need,
including a "no action" alternative and "abandon and relocate" alternative. Interactions with
other ongoing and proposed actions should be fully considered in the analysis.
3. The Service is concerned about potential issues that may arise as a result of the proposed
terminal groin. For example, how will the terminal groin affect the recharge of the proposed
borrow area in Shallotte Inlet and the availability of material for sand placement?
4. It is unclear whether the Town of Holden Beach has been involved in discussions concerning
the use of borrow material from Shallotte Inlet.
RECEIVED
DOM WILMINGTON, NC
OCT 1.7 2016

5. The Service remains concerned about the potential impacts to listed species from long-term
inlet dredging and placement of sand. The project area is located adjacent to piping plover
wintering critical habitat and loggerhead sea turtle terrestrial critical habitat. Piping plovers, red
knots, sea turtles, and seabeach amaranth are known to be present in the project area. Mining of
the inlet and placement of sand on the beach may adversely affect these species and their critical
habitat.
6. Over the past two years, the Service has reviewed multiple project proposals at each of
several inlets in North Carolina, along with multiple proposals for beach nourishment. The
Service is concerned about the potential for broad -scale, cumulative effects on prey recovery
rates along the North Carolina beaches as multiple projects commence simultaneously or within
a short time -frame. This includes impacts to prey for shorebirds such as the red knot and piping
plover and prey for surf fishes.
7. Potential impacts to listed species and critical habitat will be addressed during formal
consultation under Section 7 of the Endangered Species Act (ESA). We have received the
Corps' request for formal consultation, and will respond to that request in a separate letter.
Thank you for the opportunity to comment. If you have questions regarding these comments,
please contact Kathy Matthews at 919-856-4520, ext. 27 or by e-mail at
<[e-mail] >.
Sincerely,
/j
Quo Pete Benjamin
1 Field Supervisor
cc: Maria Dunn, NCWRC, Washington, NC
Ken Riley, NOAA Fisheries
Todd Bowers, USEPA
Doug Huggett, NCDCM, Morehead City
Debra Wilson, NCDEQ, Wilmington
DCM WILMINGTON, NC
OCT 1 9 2016