20120288 Ver 3_WRC Comments_20170309

IQ North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Ronnie Smith
US Army Corps of Engineers, Wilmington District
And
Karen Higgins
NC Division of Water Resources
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: March 9, 2017
SUBJECT: Public Notice for Village of Bald Head Island, Frying Pan Shoals Project,
Brunswick County, North Carolina.
SAW -2012-00040
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the public notice
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, and the Fish and Wildlife Coordination Act
(48 Stat. 401, as amended; 16 U.S.C. 661 et seq.).
The Village of Bald Head Island is proposing to perform groin fillet maintenance and beach nourishment
along the shoreline of Bald Head Island, including West Beach and South Beach, with material dredged
from Frying Pan Shoals. This site proposal would be for the current request as well as future nourishment
events. An approximate 460 -acre source site has been identified on the western side of Frying Pan Shoals,
approximately I mile offshore of Bald Head Island. Sediment identified would be excavated by cutter
head dredge and pumped to shore, providing an overall site capacity of 5.2 million cubic yards. Within
this borrow area is a 9.73 exclusion zone to address historic properties / cultural resources. Physical
monitoring of the dredge borrow site would be monitored immediately after construction, annually for
three years, and biennially afterward. The footprint of each monitoring survey would include the entire
permitted site as well as the area of excavation within and any changes in morphology to the Frying Pan
Shoals formation.
This current proposal is stated to be phase two of the terminal groin installation project. Although we
understand that the initial proposal included nourishment to accompany the groin, information should be
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

Bald Head Island, Frying Pan Shoals Page 2 March 9, 2017
provided to show the need for the nourishment after structure construction. It may be that the structure has
not been in place long enough to accurately model sediment transport and need for nourishment. This is
of importance due to environmental impacts to the sediment borrow source and oceanfront beaches during
nourishment activities.
Frying Pan Shoals provides important marine fishery habitat. Removal of material from this area may
alter these habitat areas significantly. Although the NCWRC generally voices concern with impacts to
more anadromous, estuarine, and inland fish species, we strongly encourage the applicant and permitting
agencies to coordinate with and incorporate concerns and management practices recommended by state
and federal marine resource agencies.
Independent of source material location and sediment compatibility, projects that affect oceanfront
beaches and natural inlet processes such as beach nourishment, inlet dredging, inlet relocation and the
construction of hardened structures on or along beaches may adversely affect nesting sea turtles and
shorebird foraging and nesting areas. Due to the scope of this project and the documented use of the
beaches by sea turtles and shorebirds, the NCWRC has the following comments and recommendations:
— The NCWRC has an established sea turtle nesting moratorium that reduces the potential for
unintended impacts to nesting sea turtle species that frequent the coast of North Carolina. To
avoid impacts to these species, all work on the oceanfront shoreline, including mobilization and
demobilization for all beach nourishment events should be conducted outside of the sea turtle
nesting season which runs from May 1 until November 15, or until the last known sea turtle nest
has hatched.
— Oceanfront beaches on Bald Head Island provide suitable nesting, foraging and roosting areas for
multiple shorebird species. Nesting birds are sensitive to increased human activity and other
disturbances around their nesting areas. To limit unintended impacts to nesting bird species in
and near the project area, all work should adhere to the shorebird nesting period from April 1
until August 31.
— Survey and monitoring reports should be provided to the appropriate parties in a timely manner
and consultation should be done with regulatory and resources agencies prior to ceasing or
changing any survey or monitoring activity.
— As stated in our comments provided during the review of the terminal groin application, regular
nourishment events could potentially impact benthic invertebrate populations Benthic
invertebrates are an important food source for foraging birds, both resident and migratory, during
both the breeding and nonbreeding seasons. Regular beach nourishment events, such as every
five years, can reduce benthic populations when populations are not given appropriate time for
recovery.
Thank you for the opportunity to review and comment on this public notice. Please feel free to contact me
at [phone] or at maria.dunn(a�ncwildlife.org if there are any questions or comments pertaining to
this project.