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the to coastal currents will respond to dredging and removal of large volumes of sand from Frying Pan Shoals. There is potential for significant short-term and long-term physical and biological impacts from dredging shoal habitat.
Frying Pan Shoals is characterized by a high fish production, a high benthic faunal density, and species diversity. The Shoals are critically important for fisheries as it demarcates the boundary where the Labrador Current flowing south collides with the Gulf Stream Current flowing north. This biogeographical boundary plays a key role in supporting shrimp, the snapper-grouper complex, coastal migratory pelagic species, and highly migratory species by generating localized areas of high productivity. Upwelling in frontal eddies and summer bottom intrusions driven by the Gulf Stream contribute to this productivity by providing nutrient rich waters and a succession of biological responses (Lee et a!. 1991).
Shoal habitat is defined by such factors as exposure, sediment texture, depth, and rugosity. The NMFS is primarily concerned about the impacts of dredging on prey resources and foraging habitat provided by the Frying Pan Shoal complex. Benthic invertebrate communities consisting of crustaceans, worms, and mollusks are diverse and productive despite the high-energy disturbance regime affecting the Shoal complex. Infaunal species provide important trophic linkages coupling benthic-pelagic ecosystems. Many of the organisms utilizing these habitats also provide trophic linkages between inshore and offshore populations. Succession and recovery of benthic communities established in shallow high-energy environments may reflect the adaptation of communities that occur in these habitats to frequent disturbance from episodic storm events (Normandeau Associates 2014). Potential impacts caused by dredging include physical removal of benthic faunal communities and disturbance of foraging habitat for fish and invertebrates. Dredging can also affect benthic communities by altering sediment transport characteristics of a shoal favoring sedimentation instead of resuspension. Benthic impacts are expected to be reflected in measures of abundance, biomass, and taxa richness. Several practices have been suggested to reduce recovery times for benthic communities following dredging events. Most important is ensuring dredging activities do not create a depression in which fine sediments deposit and collect. This may change the sediment composition and associated infaunal assemblages, which is essential for recovery and recolonization (Byrnes et a!. 2004; Crowe et a!. 2016). Also, timing of dredging prior to the peak recruitment period of spring and summer, along with the preservation of local refuge patches to maximize the rate and success of benthic recolonization have also been suggested to improve recovery times (Byrnes et a!. 2004; Brooks et al. 2006).
The NMFS believes dredging and alterations of habitat on Frying Pan Shoals could affect spatiotempora! longshore movements of migratory fish species by disrupting feeding behavior (i.e., movement based on patchy food availability) and by disrupting a significant orientation cue for migration. Frying Pan Shoals serve as a migratory corridor for many species that traverse the coastal waters of the Southeast. Data on fish migration through North Carolina’s cape-associated shoal complexes are sparse (Schwartz 1989). Anadromous species are the most common and well known fish to exhibit longshore migratory behavior. Anadromous species have complex lifecycles where individuals migrate great distances along the continental shelf and then return to their natal rivers to spawn. In the Southeast, Atlantic sturgeon, shortnose sturgeon, striped bass, American shad, and blueback herring move along and across the shoal habitat multiple times
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Dredging Best Management Practices The NMFS requests the District develop best management practices (BMPs) to minimize the adverse effects from dredging the shoal-complex and provide these for review before the District makes its final decision on the proposed permit modification. For example, limiting the dredging to the prevailing downdrift flanks of the shoals and limiting the depth of the dredge cuts to ten feet may be good practices. Dredging within the shoal-complex should be limited to the portions of the shoal expected to fill in most quickly once dredging has stopped. Environmental windows (seasonal restrictions) should be used to limit the timing of dredge and disposal activities to protect fish during sensitive life stages.
Impacts to Aquatic Resources of National Importance Several fish and invertebrates known to inhabit the project area are ARNI in accordance with Section 906(e)(1) of the Water Resources Development Act of 1986 (PL 99-602), including bluefish, spotted seatrout, croaker, southern flounder, blue crab, Spanish mackerel, pompano, and penaeid shrimp. These species utilize sandy shoals for spawning, refuge, foraging, or nursery areas. As proposed, the work could directly and permanently eliminate a substantial amount of sandy shoal habitat. Indirect impacts to this habitat and the ARNI that depend upon the Shoals also may result from the altered wave climate caused by removing a substantial portion of the Shoal. These indirect and cumulative impacts from the proposed action include increased turbidity and sedimentation from placement of fill in the aquatic environment and loss of food production functions performed by sandy shoals.
EFH Conservation Recommendations Section 305(b)(4)(A) of the Magnuson-Stevens Act requires the NMFS to provide EFH Conservation Recommendations for any federal action or permit which may result in adverse impacts to EFH. Therefore, the NMFS recommends the following to ensure the conservation of EFH and associated fishery resources: 1. The excavation of Frying Pan Shoals for terminal groin maintenance and beach nourishment should be eliminated from the project design. The NMFS would reconsider this recommendation based on receipt of additional environmental analysis performed including an EFH Assessment addressing the proposed permit modifications. 2. An alternatives analysis should be done to identify whether Frying Pan Shoals is the least environmentally damaging practicable alternative sand source the Village could use during the remainder of the permit period. This analysis should include examination of additional offshore sources, including those in the Outer Continental Shelf, capable of providing beach compatible sand. 3. A physical and biological monitoring plan for the offshore borrow areas should be developed to more accurately determine impacts to shoal habitat. The objectives of the monitoring should include documenting the extent and grain-size distribution of the material filling the excavation sites. Environmental monitoring should also document biological components of the ecosystem, including fish, invertebrates, and infauna, to quantify recovery and whether the actual impacts to EFH are within acceptable limits.
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