Table 3

Table 3. Summary of Key Issues Identified by Agencies that can Affect Preparation of Beach Nourishment Project Environmental Projects.

Name of Project/Source	Major Issues Identified	Applicability to Decision-Makers
ERP No. DB-COE-E30032-FL Rating EC2, Palm Beach County Beach Erosion Project, Updated Information concerning Shore Protection for the Ocean Ridge Segment from the Martin County Line to Lake Worth Inlet and from the South Lake Worth Inlet to the Broward County Line, Palm Beach, Martin and Broward Counties, FL. Source: http://www.epa.gov/EPA-IMPACT/1996/May/Day-31/pr-16606.html.	EPA expressed environmental concerns regarding the long term consequences of this action and other beach nourishment projects planned for the county's shoreline. Additional information derived from the mitigation and subsequent monitoring plan was determined to be necessary to determine how this project fits into the larger issue of the environmental consequences of proposed shoreline protection.	Cumulative impacts of other similar proposed beach nourishment projects are of central importance to the review agencies and should be fully addressed. Otherwise, delays will result when agencies ask for more information about this issue. Cumulative issues are a normal part of every NEPA Environmental Document and should be included in the scope of work when projects are bid out. A complete environmental document is needed to pass the agency review process. All issues need to be identified and addressed up front when completing the environmental documentation process.
ERP No. F-COE-C39009-NY, Atlantic Coast of Long Island Jones Inlet to East Rockaway Inlet Storm Damage Reduction Project, Construction, Long Beach Island, Nassau County, NY. Source: http://www.epa.gov/EPA-IMPACT/1998/September/Day-04/i23943.html.	EPA had no objections to the Corps' proposed storm damage protection project. However, EPA recommended that the proponent fully evaluate cumulative impacts prior to issuance of the Record of Decision (ROD), and commit to a flexible beach nourishment schedule in the ROD.	EPA approved the project, but under the condition requested that cumulative impacts be more fully evaluated prior to issuance of formal approval in the NEPA "Record of Decision" (the final document of approval for a NEPA project). Note that the EIS process is a formalized process involving a series of steps and resulting in the ROD. EPA can condition the ROD to specify a schedule of beach nourishment. By working with the agencies, issues surrounding scheduling can be resolved.
ERP No. D-COE-E30037-FL Rating EC2, Brevard County Shore Protection Study, Implementation, Beach Restoration Project, Brevard County, FL. Source: http://www.epa.gov/EPA-IMPACT/1996/October/Day-25/pr-17091DIR/pr-17091.html.	Summary: EPA expressed environmental concerns regarding the longterm consequences of inundating hard-bottom habitat as well as how this action meshes with other similar anticipated beach nourishment projects. The additional information derived from the mitigation and subsequent monitoring plan will be necessary to determine how this project fits into the larger issue of the environmental consequences of proposed shoreline protection.	Complete identification and coverage of all environmental issues during preparation of the environmental document will help avoid delays caused by agency comments and inquiries. Impacts on hard bottom communities has been clearly identified in various other studies as being an important issue. Had this issue been addressed more effectively, it would not have cause a delay. EPA has also identified cumulative impacts as being a key issue of concern.
ERP No. D-COE-C39010-NJ Rating EC2, Lower Cape May Meadows—Cape May Point Feasibility Study, Ecosystem Restoration, New Jersey Shore Protection Study, Cape May County, NJ. Source: http://www.epa.gov/fedrgstr/EPA-IMPACT/1998/March/Day-27/i8110.htm and http://www.epa.gov/EPA-IMPACT/1998/October/Day-16/i27874.htm and http://www.epa.gov/EPA-IMPACT/1997/September/Day-12/i24199.htm.	EPA expressed environmental concerns over the potential impact to benthic communities and water quality from beach nourishment maintenance activities, water quality, and the potential cumulative impacts associated with this and other erosion/storm damage protection projects in New Jersey. Key issues included impacts on aquatic biota, water quality, intertidal habitat, shallow water habitat, migratory bird species, and cultural resources.	This illustrates the need for objective and thorough documentation of existing conditions in the NEPA documents.
Fort Pierce, Florida Beach Nourishment Project Source: http://www.epa.gov/EPA-SPECIES/1999/May/Day-28/e13556.htm.	Corps of Engineers and NMFS were petitioned by local environmental groups concerning failure to prepare complete NEPA evaluation of hard bottom communities near Fort Pierce, Florida (Capron Shoals). Petition requested NMFS to consider evaluation of new endangered species of bryozoans.	This petition was denied based on inadequate evidence that these were new species. This illustrates the need to conduct thorough baseline assessments of endangered species (and all ecological conditions) at sand removal sites.
US Fish and Wildlife Service, Department of Interior; Endangered and Threatened Wildlife and Plants; Final Determination of Critical Habitat for Wintering Piping Plovers. Final Rule, July 10, 2001. Source: http://www.epa.gov/EPA-IMPACT/2001/July/Day-10/i16905a.htm.	The USFWS recently designated 137 areas along the coasts of North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi, Louisiana, and Texas as critical habitat for the wintering population of the piping plover (Charadrius melodus). This includes approximately 2,891.7 kilometers (km) (1,798.3 miles [mi]) of mapped shoreline and approximately 66,881 hectares (ha) (165,211 acres [ac]) of mapped area along the Gulf and Atlantic Coasts and along margins of interior bays, inlets, and lagoons.	All environmental documents need to assess whether piping plover wintering sites are located in areas impacted by beach nourishment projects. It is very important to accurately document existing conditions at fill placement areas in order for the NEPA document to be complete.
Intent to Prepare a Draft Environmental Impact Statement (DEIS) for Dare County Beaches, Dare County, North Carolina. Agency: U.S. Army Corps of Engineers, DoD. Action: Notice of Intent. Source: http://www.epa.gov/EPA-IMPACT/1997/July/Day-23/i19334.htm.	A significant issue to be addressed in the DEIS is a determination of the most appropriate time of year for dredging and beach nourishment.	This illustrates the importance of a thorough and objective documentation of baseline conditions, particularly with regard to endangered species. If several species are present together, and in combination with other issues such as fisheries and/or entrainment impacts, the timing of dredging may be very limited.
Draft Environmental Impact Statement for the Raritan Bay and Sandy Hook Bay, Hurricane and Storm Damage Reduction Study, Port Monmouth, New Jersey. Agency: U.S Army Army Corps of Engineers, DoD. Action: Notice of Availability. Source: http://www.epa.gov/EPA-IMPACT/2000/March/Day-10/i5839.htm.	The selected plan without mitigation would directly and indirectly impact approximately 14.89 acres (ac) of wetland and upland areas. Permanent and temporary conversion of native marsh habitats. Mortality and short-term decrease in reproductive success of aquatic and terrestrial wildlife species due to construction. Long-term loss or gain of wildlife habitat resources. Direct, short-term impact on benthic resources. Implementation of the selected plan can provide benefits to horseshoe crabs (Limulus polyphemus), migratory birds, and the federally threatened piping plover (Charadrius melodus). No areas were identified as containing potential environmental contamination, or were considered to pose a great risk to human health. Subsurface testing was performed and evidence of Native American occupation was found in the vicinity of the selected plan's footprint. Short-term negligible impacts to air quality and traffic are expected only during construction.	Beach nourishment projects can impact wetlands, endangered species, wildlife, benthic habitats, water quality, and the entire range of critical resources. The NEPA document must address these issues up front and in a complete manner. Mitigation measures are important because they show the agencies how adverse impacts are to be avoided, reduced, or minimized. Beach nourishment projects can provide benefits to various marine species. However, the benefits are controversial in some cases, such as the loggerhead turtle, for example, because the color of the sand might affect nesting ability. By addressing this type of issue up front in the NEPA document, and by proposing, for example, nesting monitoring program, these issues can be effectively addressed. The NEPA document should focus more detail on important issues, and less detail on minor issues. This saves time and money.
Provisional Section 404 Permit and Draft Environmental Assessment of Proposed Relocation of Mason Inlet, New Hanover County, NC. Agency: Public Affairs Office, United States Army Corps of Engineers, Wilmington District, Wilmington, North Carolina November 13, 2001NR 01-11-13. Source: USACE 2001. http://www.saw.usace.army.mil/pao/Press%20Releases%202001/P-R%20Nov13-01.PDF.	Provisional Section 404 permit for major dredging project of Mason Inlet, NC, including a beach nourishment component. Permit condition limits construction work to the period November 15 to March 30 in order to protect fisheries. The applicant must also comply with the USFWS Biological Opinion, which lists 27 conservation measures, 19 reasonable and prudent measures, and 26 terms and conditions to protect piping plovers, manatees, sea beach amaranth, and sea turtles. Permit requires a management plan for project uplands, including intertidal shoals and inlet shoulders. Plan must be reviewed annually and a report made on its effectiveness. Applicant required to provide docking and loading facilities to aid the NC Division of Marine Fisheries with its oyster seeding program, and construct a marsh and tidal creek at an existing Atlantic Intracoastal Waterway (AIWW) disposal area. A further set of conditions requested by resource agencies require the permit holder to monitor Mason Creek, Banks Channel, and the beach nourishment areas. Annual reports of these data were required to document project impacts and the mitigation effectiveness. These data are required to be analyzed at each maintenance event to insure that project impacts, including cumulative effects, are reasonable, that the mitigation is appropriate, and that the maintenance cycles are as widely spaced as practicable. New Hanover County also required to accept responsibility for future maintenance requirements at the intersection of Mason Creek and the AIWW, which may occur as a result of the dredging of Mason Creek. County also agreed to purchase a parcel of property on Masonboro Island for protection of shorebirds, particularly the piping plover.	This is an example of a major dredging project covered by an EA as opposed to an EIS.