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Home My WebLink About19970947 Ver 2_More Info Received_20110112M - 0 °1 A-1 O J_ January 7, 2011 Mr. Chad Coburn Senior Environmental Specialist NCDENR Division of Water Quality 127 Cardinal Drive Extension Wilmington, NC 28405 R'1 A IV D k,•.,_ 2011 )ER RE: DWQ Project # 97-0947v2 - Joshua's Landing - Request For More Information Dear Mr. Coburn, Thank you for your letter of December 17, 2010. We are very concerned about the possible denial of our application unless we can satisfy DWQ with additional information. Hopefully, the contents in this response will be sufficient to meet your information needs. First let me say that all of the six homeowners in Joshua's Landing strongly support a clean and vibrant ecosystem in Hewlett's Creek. We are all for clean water, a healthy marine fishery, and responsible management of our environment. We all were extremely upset over the significant adverse impact of the many sewage spills into our creek. As an example of responsible environmental action, our first POA President, Mort Neblett, spent a lot of money and worked with DCM and other state agencies to clean up an old dump on the eastem-most lot on Hewlett's Creek. That portion of the creek-side here in Joshua's Landing has been completely cleaned-up and restored. We want to do the right thing for the environment. You mentioned that based on comments provided from DMF and WRC, DWQ has determined our project would have potential to cause a significant adverse impact (my emphasis) to the surrounding Primary Nursery Area and would violate Tidal Salt Water Quality Standards. We have not been provided a copy of the DMF or WRC comments but based on your letter we infer the primary concern is the depth of the water. It might help to summarize the history of Joshua's Landing's docks and slip areas. As state records will confirm, Joshua's Landing's docks were originally permitted by DCM and constructed in 1997. There were renovations to the center community dock in question signed off on by DCM on 9/21/2005 however, this renovation did nothing to change the 4 existing slips. The four slips were designed for a maximum 18' boat. ............................ January 7, 2011 Page 2 As shown in our application, the average low water mark based on NAVD88 Datum is 1'.5" at the edge of the floating dock (bow) and about 1'.8" at the other end (stern). Without any evidence to the contrary, we assume this was the approximate mean low water depth when the docks were first permitted and constructed. Of course, actual low water depth varies based on the tides and can be more or less at certain times of the year. My boat with a 115 HP motor (2,500 Ibs estimated weight), as an example, has an estimated draft of 8" to 10" when moored in my slip. We acknowledge water depth is a concern but this condition has existed since the day these slips we originally permitted. If the underlying issue with permitting the proposed Jet Dock system is water depth, please allow us to explain. One of the advantages of the Jet Dock system is its buoyancy. We contend that a boat on a Jet Dock sits higher from the bottom than a boat not on it. Here is a quote form Mark Vondriska, Assistant Director, Jet Dock Systems who responded to my email on January 3, 2011. "The bow (front) of the Jet Dock typically only drafts about 1 inch of water where the stern (back) of the Jet Dock typically drafts about 4 to 5 inches of water with a 2,500 pound boat on it. This can be seen in the multiple photos on our website. The back of the Jet Dock is only 9 inches tall and a Jet Dock keeps the stern of the craft completely out of the water so the most a Jet Dock would ever draft would be 9 inches but it typically only drafts 4 to 5 inches. If there is no craft on the Jet Dock it will only draft an inch or less because of the amount of buoyancy in the cubes." I am enclosing copies of pictures provided by Jet Dock Systems showing typical 18' boats with motors on the exact size Jet Dock system that we are proposing in our project. Keep in mind that the Jet Dock cubes are 20" x 20" and 16" tall. Notice how high the Jet Dock keeps the boats out of the water. The draft is the lowest at the stern where, in our case, the water is deeper. Just for your information, Larry Carpenter and I already purchased our Jet Docks in late 2009 and we have quite an investment at stake. We were unaware at the time that we needed a CAMA permit. Of course, ignorance of the law or state regulations is no excuse and we removed the Jet Docks within 48 hours so as to gain compliance as soon as possible. We have been working on this for about 14 months now. We are not experts in your field, or that of marine fisheries, nor wildlife resources. We were looking at this from a practical, layman's point of view. These Jet Docks are simply floated in like a watercraft and tied to the cleats of a dock just like a boat. That is it from an installation standpoint. We reasoned the Jet Dock to be a watercraft on top of which our boat would sit to keep it out of the salt water. The Jet Dock would sit in the exact same slip space that our boats are moored. Granted the Jet Dock covers more water area than our boats but, as we have tried to demonstrate, keeps more clearance from the bottom. January 7, 2011 Page 3 We humbly ask that you consider this additional information favorably. As responsible citizens, we really do not understand how four Jet Docks in our existing slips where our boats are moored anyway would constitute significant adverse impact, violate Tidal Salt Water Quality Standards, and be a source of water pollution. We certainly do not want to cause any harm to the environment nor the marine fisheries. Thank you for your time and we look forward to your response. Very Sincerely, J L?y? Frederick C. Campau III Secretary & Treasurer Joshua's Landing POA 6016 Joshua's Landing Lane Wilmington, NC 28409 CC: Ian McMillan - DWQ 401 Oversight and Express Unit, Raleigh Paul Pascarosa - ESC Carolinas, LLP, Wilmington Larry Carpenter - Joshua's Landing, Wilmington January 7, 2011 Page 4 Jet Dock Photograph Example and Subsequent Depth of Draft. #A, Photograph 1. Vacant Jet Dock depicting 1-2" draft. Photograph 2. 18' Hydrasport depicting 4-5" draft. January 7, 2011 Page 5 Photograph 3. 18' Hewes depicting 4-5" draft..