20120288 Ver 2_Response to USACE_20170810

Burdette, Jennifer a
From: Coburn, Chad
Sent: Thursday, August 10, 2017 10:24 AM
To: Burdette, Jennifer a
Subject: FW: FPS - Response Letter to Corps
Attachments: Response to Corps -August 10_2017.pdf
FYI
From: Christian Preziosi [mailto:[e-mail]]
Sent: Thursday, August 10, 2017 9:31 AM
To: Smith, Ronnie D CIV USARMY CESAW (US) <[e-mail]>
Cc: Wilson, Debra <[e-mail]>, MacPherson, Tara <[e-mail]>, Coats, Heather
<[e-mail]>, Coburn, Chad <[e-mail]>, [e-mail], 'Chris McCall
([e-mail])' <[e-mail]>, Jeff Griffin <[e-mail]>
Subject: FPS - Response Letter to Corps
Ronnie,
Per our recent discussions, see attached letter of response submitted on behalf of the Village. As described in the letter,
the Village is currently evaluating options to prioritize the use of the previously developed Jay Bird Shoals borrow site for
near-term nourishment needs.
Let me know if you have any questions or require any additional information. Thank you for your time and assistance,
Christian
Christian Preziosi ( Environmental Consultant
Direct: 452-0001 x 1909 ( Cell: 910.471.0515 ( Fax: [phone]
Email: [e-mail]
Land Management Group, Inc. ( Environmental Consultants
3805 Wrightsville Avenue, Suite 15 ( Wilmington, NC 28403 ( www.lmgroup.net
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L M G
LAND MANAGEMENT GROUP me
Now Environmental Consultants
August 10, 2017
Mr. Ronnie Smith
U.S. Army Corps of Engineers - Wilmington District
Wilmington Regulatory Field Office
69 Darlington Avenue
Wilmington, North Carolina 28403
RE: Department of Army - Permit Modification Request (USACE Action Id. SAW -2012-00040)
Village of Bald Head Island Frying Pan Shoals Beach Nourishment Project
Additional Information in Response to Federal Agency Comments
Dear Mr. Smith:
By way of this letter and on behalf of the Village of Bald Head Island (Applicant), Land
Management Group, Inc. (LMG) (agent) is providing additional information in response to
comments transmitted by the National Marine Fisheries Service (NMFS) (letter dated June 14,
2017) regarding the Village's proposed dredging of a borrow site located on Frying Pan Shoals
(FPS) and associated nourishment of the West Beach and South Beach shorelines of Bald Head
Island, North Carolina.
In consideration of the concerns raised by NMFS and their accompanying recommendation to
explore other viable sand -source alternatives, the Village is currently evaluating options to
prioritize the use of the previously authorized borrow site located on Jay Bird Shoals (JBS)
(including both the partially recovered area dredged in 2009 and the remaining, undredged
portion of the borrow site). Currently, the only alternative borrow site available for near term
sand placement at Bald Head Island (BHI) is sand remaining in the developed JBS borrow site.
Options other than JBS and FPS are not feasible. For instance, there is not sufficient sand within
the Bald Head Creek borrow area. Moreover, only a small dredge can be utilized at that
location. Therefore, the Bald Head Creek site is not suitable for any large-scale nourishment
event. With respect to the Wilmington Harbor Channel as a potential borrow site, all sand
dredged by the Corps of Engineers (COE) in 2017/18 as part of their regularly occurring channel
maintenance will be placed on Oak Island pursuant to the Wilmington Harbor Sand
Management Plan (WHSMP). Hence, there will not be sufficient sand quantities available to the
Village in the near future.
www.lmgroup.net • Phone: [phone] • Fax: [phone]
3805 Wrightsville Ave., Suite 15, Wilmington, NC 28403
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Within the developed JBS borrow site, there is an estimated 900,000 cy of sand remaining in
the undredged portion of the site and lying outside a Cultural Resource Exclusion area.
Additionally, there is almost 1 Mcy (available) which lies within the area previously excavated in
2009. The predicted volume required to be placed on South Beach in 2018/19 is approximately
1 M cy. Subsequent to that sand placement, the Village will be the recipient of the next two (2)
federal channel maintenance/beach disposal projects. This would theoretically allow the use of
the FPS borrow area to be deferred nearly 10 years into the future. It does not, however,
obviate the need to complete the permitting for the FPS borrow site since it would likely be
required as a sand source after a major hurricane.
The use of the JBS site (if viable in terms of both sand quality and quantity) would address more
immediate nourishment needs that will require an estimated 1Mcy of material in the winter of
2018/19. Note that a long-term borrow site consisting of high volumes of beach -compatible
sand (from a borrow site exhibiting physical conditions conducive for relatively rapid recovery)
will ultimately be needed to offset long-term sand deficits along South Beach and West Beach.
To that end, the Village intends to continue its request for authorization for the use of the
proposed FPS borrow site. In the interim, use of the JBS site will likely be able to address the
more immediate nourishment needs while deferring and ultimately reducing physical
disturbance to the FPS site.
It is the intent of the Village to request a permit modification authorizing the dredging of
approximately 1Mcy of sand from the JBS site. Pending the results of updated vibracore
sampling of the infill areas of the previously dredged JBS site and the demonstration of
adequate volumes of high quality, beach -compatible sand, the Village will likely seek to dredge
750,000 cy from areas which have infilled via deposition of sand since 2009 and to obtain the
remaining needed volume of 250,000 cy from the unexcavated portion of the site. It is believed
that such a plan is deemed favorable at this time based upon the following considerations:
(1) It helps to avoid disturbance to the FPS borrow site over the next several years
(potentially up to a decade into the future);
(2) It meets the intent of the terminal groin permit condition which limits the volume of
dredging to 250,000 cy on the unexcavated portion of JBS without triggering
intensive monitoring of the Oak Island shoreline; and
(3) It addresses the requirement stipulated by both permit condition and state statute
for the Sponsor of a terminal groin project to keep the fillet of the groin full.
Upon receipt and analysis of all sediment data, the Village will prepare and submit a formal
written request to the COE (and state permitting agencies) detailing the revised, proposed
action with accompanying plan drawings. In addition, we will continue to coordinate with your
office to determine an appropriate course of action for seeking authorization for the long-term
use of the FPS borrow site. In doing so, we intend to address remaining, applicable federal
agency comments under separate correspondence in the near future. In the interim, please
www.lmgroup.net • Phone: [phone] • Fax: [phone]
3805 Wrightsville Ave., Suite 15, Wilmington, NC 28403
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feel free to contact me vial phone at 910-452-0001 or by email at cpreziosi lm rou .net
should you have any questions regarding the information provided.
Sincerely,
Christian Preziosi
Land Management Group, Inc. (permit agent)
M Chris McCall, Village of Bald Head Island
Erik Olsen, Olsen Associates
Heather Coats, DCM-Wilmington
Tara MacPherson, DCM-Wilmington
www.lmgroup.net • Phone: [phone] • Fax: [phone]
3805 Wrightsville Ave., Suite 15, Wilmington, NC 28403
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