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also occur to nesting areas and or prime nesting sites could be removed when the washover area is dredged. Artificial lighting from developed beachfront areas could also disorient females and
hatchling sea turtles causing them to head inland rather than out to sea. Other risks include their
potential to be attracted to feeding opportunities at the proposed jetties that will expose them to
injury by boat traffic, fishing lines and plastic debris.

The BA states that sea turtles and the piping plover could be negatively impacted, the Service has
to interpret this. statement as a "may affect". Therefore, upon finalization of the BA,.the Service
anticipates recommendation to the Corps that formal section 7 consultation be initiated on this
project.

The Service recommends the Corps identify conservation measures (timing activities, educational
programs, monitoring) that will avoid and minimize impacts to potentially impacted species and
designated critical habitat units and incorporate them into the BA. The Service is willing to work
with the Corp to identify such measures and provide further recommendations for improving the BA
prior to finalizing the document.