19801_COMFORT SUITES_19980402 (2)

CAMA -AND DAtEDGE -AND F16L
GENERAL
PERMIT N`161 019801- G
'as authorized by the State of North Carolina
Department of Environment, Health, and Natural Resources and theCoastt I Resources Commission
in an area of environmental concern pursuant to 15A NCAC d�%r• gweq
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Applicant Name ��' l'r u' -S a � `� ��� �s) Phone Number �?�
N` Address P/e e-Q_s/
rCity __ A441 Zly-11 State Vf,' zip
Project Location (County, State Road—Water Body, etc.) 047 f Q • -A3 1%
Type of Project Activity r, >+r - .,n rsra /,' ; �• ,
PROJECT DESCRIPTION I SKETCH
Pier (dock) length
Groin length
max, distance offshore
Basin, channel dimensions
cubic yards
Boat ramps dimensions
Other
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F6,; This permit is subject to compliance with this application, site
Ri drawing and attached general and specific conditions. A'y )
�F violation of these terms may subject the permittee to a fin , ��
imprisonment or civil action; and may cause the permit to be-
come null and void.
This permit must be on the project site and accessible to the
t
permit officer when the project is inspected for compliance.
1 P P
._ The applicant certifies by signing this permit that 1) this pro-
ject is consistent with the local land use plan and all local
ordinances, and 2) a written statement has been obtained from
h;.ad1acent riparian landowners certifying that they have no
objections to the proposed work.
issuing date
attachments 6 //f ;0'd0
ri
In issuing this permit the State of North Carolina certifies that
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this project is consistent with the North Carolina Coastal application fee S0
` Management Program.
applicant's signature
,.,-_,
it officer's signature
expiration date

Comfort Suites
c/o Mr. Dan Foley
Foley & Foley Contractors, Inc.
P.O. Box 3482
New Bern, NC 28564
Dear Mr. Foley:
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF COASTAL MANAGEMENT /,V'
March 31, 1998
This correspondence is in reference to CAMA General Permit #018594-C that
I issued to the Comfort Suites on February 10, 1998. This permit authorized the
reconfiguration of their docking facilities located on the Neuse River, in New Bern,
North Carolina. At that time, I was led to believe that proper notification was given
to both riparian property owners and proceeded with permit issuance. However, as
you may recall from our numerous telephone conversations, it has come to my
attention that Mrs. Elizabeth Civils, the upstream property owner was not properly
informed. Therefore, I must revoke CAMA General Permit #018594-C. We have
discussed this matter over the telephone and you have agreed to stop work on the
project. This letter will serve as formal notification that the permit is no longer valid
and that any work authorized by the permit must immediately be stopped.
I am aware that as of this date you have properly notified Mrs. Civils and have
asked that a valid permit be issued authorizing the work. Once I have reviewed the
new information provided I will proceed with permit issuance if appropriate. If you
have any questions regarding this matter, please don't hesitate to contact me at my
Morehead City Office (919-808-2808).
Sincerely,
M. Ted Tyndall
Coastal Management Rep.
cc: Charles Jones - Assistant Director, DCM
l tI
MOREHFAD CITY OFFICE
HEBTRON PLAZA II 151-8 HIGHWAY 24 MOREHEAD CITY NC 26557
PHONE [phone] FAX 91 S-247-8980
AN EQUAL OPPORTUNITY /AFFIRMATIVE ACTION EMPLOYER - 80% RECYCLEO/10% POST -CONSUMER PAPER

ai SENDER:
v ■Completemitems 1 and/or 2 for additional services.
tll ■Coplete items 3, 4a, and 41b.
01 ■ Print your name and address on the reverse of this form so that we can return this
2 card to you.
SI > ■Attach this form to the front of the mailpiece, or on the back if space does not
d permit.
y ■ Write "Return Receipt Requested" on the mailpiece below the artidle number.
■The Return Receipt will show to whom the article was delivered and the date
C delivered.
0
o 3. Article Addressed to: 4a. Article Number
0.
E �l� \� 4b. Service Type
SRN !y
❑ Registered�� /�/-p C
❑ Express Mail rCp
❑ Return Receipt for W andi
7. Date of Deliv
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p5. Received By: (Print Name) 8. Addressee's dd,`_�l
and fee is paid)
I also wish to receive the
following services (for an
extra foe): 4i
1. ❑ Addressee's Address
2. ❑ Restricted Delivery
Consult postmaster for fee. -EL
g b. signature: (Addressee or Agent)
{ P X
d
ified
rn
Insured c
COD
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requested
PS Form 3811, December 1994 102595-97-6-0179 Domestic Return

UNITED STATES POSTAL SERVICE
2 M ccA USP
• Print your name, address nd ZIP Code in this box •
FOLEY &IOLEY
M AR IN E.CONTRACTORS, INC.
P.O. Box 3482
New Bern, North Carolina 28564-3482
4131tiltil441f1!l�iftiSfl�E{t{f1

SENDER:
■Complete items 1 and/or 2 for additional services. I also wish to receive the
■Complete items 3, 4a, and 4b. following services (for an
■ Print your name and address on the reverse of this form so that we can return this extra feel:
card to you.
■Attach this form to the front of the mailpiece, or on the back if space
permit.
■Write'Return Receipt Requested'on the mailpiece below the article
■The Return Receipt will show to whom the article was delivered and
delivered.
3.�Article
�Addressed to
re—A
1 C) \ CC) C
Ps f=orm 3811, December 1994 102595-97-8-0179 Domestic Return R
ai
does not
1. ❑ Addressee's Address
2
number.
2. ❑ Restricted Delivery
W
the date
., r
Consult postmaster for fee.
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'd
4a. Article Number
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4b. Service Type
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❑mastered 0--CUMed
❑ Express Mail ❑ Insured
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❑ Return Receipt for Merchandise ❑ COD
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7. Date of Delivery
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o
Addressee's'Address (Only if requested
and fee is paid)
t i
Ps f=orm 3811, December 1994 102595-97-8-0179 Domestic Return R

UNITED STATES POSTAL SERVICE
First-CJass Mail
Postage & Fees Paid
USPS
Permit No. G-10
0 Print your name, address, and ZIP Code in this box •
Fog,X, AI ARN7RACTORS, INC.
P.O. Box 3482
New Bern, North Carolina 28564-3482

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120 WEST FIRE TOWER ROAD
POST OFFICE BOX 8088
GREENVILLE, N.C. 27835-8088
TELEPHONE [phone]
FACSIMILE [phone]
UNIVERSITY CORPORATE CENTER
127 RACINE DRIVE
POST OFFICE BOX 7068
WILMINGTON, N,C. 28408-7068
TELEPHONE [phone]
FACSIMILE [phone]
WARD AND SMITH, P.A.
ATTORNEYS AT LAW
1001 COLLEGE COURT
POST OFFICE BOX 867
NEW BERN, N.C. 28563-0867
TELEPHONE [phone]
FACSIMILE [phone]
February 27, 1998
VIA TELECOPIER
ORIGINAL VIA CERTIFIED MAIL
RETURN RECEIPT REQUESTED
N.C. Division of Coastal Management
Post Office Box 769
Morehead City, North Carolina 28557
RE: Comments re Comfort Suites Docks and Gazebo
Dear Sir:
SUITE 2400
TWO HANNOVER SQUARE
FAYETTEVILLE STREET MALL
POST OFFICE BOX 2091
RALEIGH, N.C. 27602-2091
TELEPHONE [phone]
FACSIMILE [phone]
MAR 0 2 1998
With reference to CAMA General Permit No. 018594-C issued February
10, 1998 and the Exemption from CAMA permit issued the same date,
notice of which was received February 17, 1998 by Mrs. Harvey
Civils and the undersigned, we wish to offer the following comments
on behalf of Mrs. Civils.
Unnecessarily Endangers Adjoining Property.
Our client is strongly opposed to the construction of these two
structures on the grounds that they will unnecessarily endanger her
property. The facilities are proposed to be constructed at a very
vulnerable location on the Neuse River. This site is on the open
part of the Neuse facing eastward near Union Point, and is directly
in the path of any storm tracking up the Neuse River. As evidenced
by the damage caused by Hurricane Bertha in 1996 (see enclosed
photos taken immediately after the hurricane), this location on the
river is especially vulnerable to storm damage. At that time,
several boats that were docked at the Comfort Suites docks,
together with large sections of the docks themselves, were blown
into Mrs. Civils yard and against her house, causing damage to her
dwelling, bulkhead and yard. Similar damage surely would have
occurred again during Hurricane Fran in September 1996, but for the

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 2
fact that the docks had already been destroyed six weeks earlier
during Hurricane Bertha.
It is an absolute certainty that there will be other major storms
and hurricanes impacting this vulnerable portion of the Neuse
River. It is just a matter of time. When such storms occur, Mrs.
Civils property, because of its location relative to the Comfort
Suites docks, will again be in the direct path of boats and docks
from the Comfort Suites, crashing against the shore and into her
house and yard.
We do not contend that all docks on the Neuse River or elsewhere on
the coast inherently endanger adjoining properties. Our contention
is that Division of Coastal Management staff must evaluate the
location, size, proximity to adjoining properties, and directional
relationship to nearby properties of each proposed dock in order to
fulfill their regulatory responsibility. The staff should also
consider the availability of intervening protective structures or
land features, history of damage to adjoining properties, and other
relevant factors in making a determination regarding "unnecessary
endangerment." This determination is best made in the context of
an individual CAMA permit. In fact, the General Permit rules do
not authorize issuance of a General Permit and require that an
individual permit be obtained if the proposed structure "might"
endanger adjoining properties. 15A N.C. Admin Code § 7H .2004(e).
We understand that the CAMA staff historically has relied on the
fact that a docking facility must obtain a building permit that
demonstrates the facility is constructed in conformance with the
state building code. While the integrity of the structure is
important in minimizing the risk to adjoining properties, we do not
believe it is the only factor that should be considered. We
contend that no wooden gazebo or small boat dock, no matter how
well .constructed, can withstand the forces of a major storm or
hurricane in certain particularly vulnerable locations. This fact,
together with the existence of residences or other occupied
structures immediately downwind from the proposed docking facility,
should be sufficient to deny an application for a permit under 15A
N.C. Admin. Code § 7H .2000.
It is also noteworthy that the permit issued to the Comfort Suites
does not include any condition requiring that compliance with the
state building code be demonstrated or even that a building permit
be obtained. Thus, Division staff has no way of knowing whether

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 3
the lone feature of its present "unnecessary endangerment"
determination is being fulfilled.
Docking Facility Especially Objectionable
Mrs. Civils finds the reconstruction of the docking facility
nearest her property to be especially objectionable. In addition
to the threat posed to her property by this dock, its location and
configuration assures .that any boats using the dock must turn in
front of her property and enter the slips from the north side.
This will have the effect of increasing the noise, fumes and other
undesirable impacts associated with boating activity immediately in
front of one's property. In Mrs. Civils' case, these facilities
will also significantly detract from her view of the river, being
positioned directly in her line of site down the river. In short,
she does not understand why she must bear the undesirable impacts
of a commercial dock constructed for the benefit of an adjoining
commercial venture. At the very least, she believes these docks
should be incorporated into the pier and gazebo structure or
configured so that boats using the docks are not forced to navigate
exclusively in front of her home.
She also requests that the representation made by the Comfort
Suites that it will not rent slips or provide other commercial
services at the docking facility or pier/gazebo structure be
incorporated into the exemption and/or permit as an express
condition.
Ouestionable Legal Authority for Exemption
We also question the validity of the exemption granted with respect
to the docking facility. This exemption was purportedly granted
under an emergency policy for which no one in the Division could
produce a rule or citation. We ultimately were referred to the
Governor's Office for information concerning any emergency
declarations following Hurricane Bertha. Unless the Division can
provide some legal support for its exemption policy, we question
whether the exemption granted to the Comfort Suites to reconstruct
the dock is legally valid. In addition to the possible absence of
any supporting authority, it is unclear as to whether the Comfort
Suites obtained its exemption in a timely manner. We could find no
record of an application for an exemption filed prior to the
expiration of the exemption policy on July 31, 1997 (which we are
informed by CAMA staff was extended until October 31, 1997).

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 4
Adequacy of Notice to Adjoining Property Owners
Finally, we question the adequacy of the notice provided to
adjoining property owners. Mrs. Civils is unable to determine
whether she ever received notice of the original permit application
in 1991 or the modified permit in 1993. One thing is clear. It is
clear that inadequate notice was provided to Mrs. Civils last month
regarding the Comfort Suites general permit application for the
pier and gazebo structure. On that occasion, a document that did
not pertain to the CAMA permit was mailed to Mrs. Civils by
certified mail, return receipt requested. According to Ted
Tyndall, a green card showing that the item was signed for was
provided by the Comfort Suites to the Division. No copy of the
documents mailed to Mrs. Civils was provided to the Division. Only
after we investigated this permit application further did it come
to light that inadequate notice had been provided. The contractor
involved quickly offered to apply for a new permit and re -notice
Mrs. Civils by providing the correct documents, as required by law.
That incident leads us not only to question CAMA's notice
requirements generally, where no proof of what documents were
mailed to adjoining property owners is required to be submitted to
the Division, but also to wonder whether the same faulty notice
procedure may have been employed in 1991 and 1993. CAMA file
records only show a certified mail receipt in October 1991.
Reportedly, a copy of the documents mailed to Mrs. Civils do not
appear in the file. Thus, if some unrelated documents are mailed,
as was the case in January 1998, how can adjoining property owners
learn of their legal right to comment on an application within the
specified period? Furthermore, how can the Division be sure its
permit is valid if there is no proof that adjoining property owners
were served with the correct documents? In summary, there is no
proof that adequate notice was ever provided by the Comfort Suites
with regard to the original structures and, thus, the exemption for
the docking facility would be invalid if the original permit was
invalid. We request that the Attorney General's Office review this
situation and provide a legal analysis and opinion concerning the
adequacy of each notice required in this instance by the rules, the
validity of the applicant's certification of notice and the
validity of the resulting permits issued to Comfort Suites.
In conclusion, we ask that you give serious consideration to Mrs.
Civils concerns regarding these facilities. They will
unnecessarily endanger her property, as proven by the damage she

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 5
sustained in 1996 (without compensation by the Comfort Suites or
their boat tenants), and will result in adverse noise and other
undesirable impacts. She is particularly concerned about the
location and proximity of the docking facility presently being
reconstructed.
Yours very ruly,
Frank H. Sheffie Jr.
FHS: fs
NBMAIN\315118.1
Enclosures
cc: Mrs. Harvey Civils
Mrs. Eleanor Civils

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REFERENCE.' PROPERTY -LINE BEARINGS AND DISTANCES
PER CERTIFIED/SEALED DOCUMENTS/DRAWINGS —7
PROPOSAL III
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REV.A
EDIT/REVISE PLAN PER CUSTOMER
COMMENTS/SPECIFICATIONS. BY:RGS:1-20-98
PA 1 n ON CIVIL
FENE ENGINEERING ENVIROMMEN AL
NEW BERN, NORTH CAROLINA - [phone]
* COMFORT SUITES *
NEW BERN, NORTH CAROLINA
DOCK/PIER RECONSTRUCTION, GAZEBO ADDITION
SITE/SKETCH PLAN
scat. ,a
1/4 m 1'—d'
Data. 1-20-98 Appoww Dr.
"eat 0 2095 C*dfnw RGQL—B02 ShImL 2 of 4

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2x8 PT DECK
2x8 PT STRINGERS
FINGER PIER ATTACHMENT
w/ 1/2 0 THRU—BOLTS
5/8"0 GALV.THRU—BOLT w/
OGEE OR FLAT WASHERS
*195'-11 1/2"
5/8"0 GALVANIZED LAG BOLT(s)
STRINGER—to—PILING w/
OGEE OR FLAT WASHER (TYP)
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NOTE: ALL HARDWARE TO BE HOT DIPPED GALVANIZED
BOARDWALK C
ENCE: DETAIL—ANGLE ANCHOR
x8 PT BRACE(s)
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BOARDWALK A, B 5/8"O GALV.LAG BOLTS, PIER—to—STRINGER TOLBOTT MS OFO BE CUT
DEC BOARDSSH BOARDWALK D FINGER PIER
UNLESS OTHERWISE NOTED 5/8"0 GALV.LAG BOLTS, STRINGER—to—PILING-5/8"0 GALV.LAG BOLTS, STRINGER—to—PILING
r-5/8"0 GALV.LAG BOLTS. STRINGER—to—PILING r-5/8"0 GALV.LAG BOLTS, STRINGER—to—PILING
FINGER PIER I A, fY' nnon
2x8 PT DECKING
6'-0" BOARD
42'-0"
2'-5 1/2"2'-5 1/2"
2x8 STRINGERS 2x8 PT DECKING
--Iw 11
• 2x8 PT BRACE(s)
6'-3"
5'-9"
INDICATES PILING CENTERLINE
MAY VARY t 1" PER
PILING DIAMETER USED
5/8"0 GALV.THRU—BOLT
EXISTING RIVER BOTTOM
6 —O" BOARD
2'-5 1 2"
II
--
2x8 PT
RINGERS
DOCK/PIER RECONSTRUCTION, GAZEBO ADDITON
4'-3"
li
*2Ll'-7'
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Prot—tr 2095
QARD" �
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BOARDWALK A, B 5/8"O GALV.LAG BOLTS, PIER—to—STRINGER TOLBOTT MS OFO BE CUT
DEC BOARDSSH BOARDWALK D FINGER PIER
UNLESS OTHERWISE NOTED 5/8"0 GALV.LAG BOLTS, STRINGER—to—PILING-5/8"0 GALV.LAG BOLTS, STRINGER—to—PILING
r-5/8"0 GALV.LAG BOLTS. STRINGER—to—PILING r-5/8"0 GALV.LAG BOLTS, STRINGER—to—PILING
FINGER PIER I A, fY' nnon
2x8 PT DECKING
6'-0" BOARD
42'-0"
2'-5 1/2"2'-5 1/2"
2x8 STRINGERS 2x8 PT DECKING
--Iw 11
• 2x8 PT BRACE(s)
6'-3"
5'-9"
INDICATES PILING CENTERLINE
MAY VARY t 1" PER
PILING DIAMETER USED
5/8"0 GALV.THRU—BOLT
EXISTING RIVER BOTTOM
6 —O" BOARD
2'-5 1 2"
2'-5 1/2-
2"2x8
--
2x8 PT
RINGERS
DOCK/PIER RECONSTRUCTION, GAZEBO ADDITON
2x8 PT INGERS
2x
--
4-
2x8PT BRACE(s) •
DOCK/PIER RECONSTRUCTION, GAZEBO ADDITON
4'-3"
*2Ll'-7'
Dot 1-20-98
Prot—tr 2095
3 PT DECKING
PRE—APPROVED EQUAL OR FABRICATED PART;
GALVANIZED 2 1/2 x 2 1/2 x 1/4" ANGLE(s)
ACCESS PIER 1 2"
1 2" BOLT HOLES
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RN RN
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9/160 FINGER PIER
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BEND ANGLE
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DETAIL - ANGLE ANCHOR
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REFERENCE SHEET 2of4 FOR SITE SKETCH PLAN,
AND SHEET 4of4 FOR GAZEBO PLANS.
FEB 0 5 1998
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EDIT/REVISE PLAN PER CUSTOMER
COMMENTS/SPECIFICATIONS. BY:RGS:1-20-98
RRAYBON Crm
-ENGINEERING ENVIROMENTAL
NEW BERN, NORTH CAROLINA — [phone]
* COMFORT SUITES *
NEW BERN, NORTH CAROLINA
DOCK/PIER RECONSTRUCTION, GAZEBO ADDITON
PLANS, DETAILS
..pR0 ad s,:
Dot 1-20-98
Prot—tr 2095
cwdmsm RGQL—DO1
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24'-0"
2x8x8'L FT DECK BOARDS SHOWN
DECK PLAN
1/41 = 1'-0■
SECTION A—A
1/4' = 1' -
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24'-0" BOARD
FOUNDATION PLAN
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CUT FLUSH TO BOTTOM OF
DECK BOARDS
8'-0' PENET RATION
OF RIVER BOTTOM
SECTION B—B
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REF.10'N PT PILINGS, TOP
0 t9'-0'AFF DECK,
ROOF BEARING
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FLOORROOF PLAN_
1/4 9 = 17"?
FRONT ELEVATION -
1/4' = 1'-0"
TRAILING TO MATCH ■
1NG POOL SIDE,
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WELDED TO POST BASE 2x4xG'L BLOCKING
• � 2x6 PT DECK
1/2' GALVANIZED THRU—BOLT
POST MOUNTING 02) —2x12 PT BAND
2)-2x12 PT BAND
2x10 PT TRIM/LAP w/ 5/8' 2)-2x12 PT BAND
GALVANIZED THRU—BOLT(s)
- 5/8' GALVANIZED
THRU—BOLT(s)
REFERENCE SHEET 2of4 FOR SITE SKETCH PLAN,
AND SHEET 3of4 FOR DOCK/PIER PLANS.
OPTIONAL _ HANDRAIL MOUNTING
BOLTING DETAIL
1/20
CARO
FEB 0 5 1998
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EDIT/REVISE PLAN PER CUSTOMER
COMMENTS/SPECIFICATIONS. BY:RGS:1-20-98
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FEB -12-98 THU 10:32
120 WEST FIRE'COWER ROAD
POST OFFICE BOX 8086
OTELEPHONE(91 1355-30348
FACSIMILE [phone]
UNIVE13SI.1TTY AORIPO RAATE ENTER
POST OFFICE BOX 7069
WILMINGTON, N.C. 234116-70513
TELEPHONE (81 D) 392-5100
FACSIMILE [phone]
WARD AND SMITH, P.A.
'ATTORNEYS AT LAW
1001 COLLEGE COURT
POST OFF E BO% 867
NEW BEEN. N- G. 28683-0867
TELEPHOMF
FACSIMILE 199)
9)630-2 21
February 12, 1998
Via Fs��?m__nd U.S Mail
Mr. Charles Jones
North Carolina Division of Coastal Management
Hestron plaza TI, 151•-B
.Highway 24
Morehead City, North Carolina.28557
RE: Public Records Request
Aggrieved Party: Elizabeth Civils
Our File 96-0436(C)
Dear Charles:
P, 02
SUITE 2409
TWO MANNOVER SQUARE
FAyET-TpVILLE STREET LL
POST OFFICE BOX 2991
RALEIGH, N -C. 27602-21391
FACSIMIEE(98116)) 838-1 070
Through your kind assistance, we have reviewed and copied portions
of the file concerning the original. construction of the dock and
pier at the Comfort Suites in New Bern, North Carolina. As you
know, the comfort Suites intends to replace those docks following
their destruction by Hurricane Bertha.
We understand that significant changes in the dock and pier
necessitate the issuance of a new LAMA permit.
Our client, Mrs_ Elizabeth Civils, who resides adjacent to the
Comfort Suites, continues to have strong objections to the project
and wishes to monitor closely the development of the dock
replacement plans.
ecords Act, N.C.
Under provisions of the worth Carolina
requestingRcopies of any new
Gen. Stat. pec. 132-1, �-�•, royals, drawings,
or amended permit applications, permit app
construction plans or other correspondence received into or issued
from your office regarding the dock replacement plans by Comfort
Suites. This request applies both to documents presently in hand

FEB -12-98 THU 10:32 P.03
WARD AND SMITH, P.A.
Mr. Charles Jones
February 12, 1998
Page 2
and those received in the future during the permitting/approval
process.
If your office finds it too burdensome to copy and mail such
documents, we will be glad to send personnel to your office to
review and copy the documents at our expense. We would ask that
you notify us when such documents have been received into or
produced by your office. You may call me or, in my absence, my
paralegal, Doug Lindeman at the telephone number listed above.
Please give me a call if you have any questions or reservations
regarding this request. As always, we appreciate your assistance
in addressing CAMA issues.
Yours truly,
�Z�
Frank H. Sheffield, Jr.
FHS: del
NBMAIN\313550.1
cc: Mrs. Elizabeth Civils
Airs. Eleanor Civils

-CERTIFIED MAIL
RERL'CE REQUESTED
Dear
This letter is to notify you as an adjacent riparian landowner of
plans to construct
Mr. /Mrs.
on their property located at.
Ne. The sketch on the reverse
in
side accurately depicts the proposed construction -
Should you have no objections to this proposal, please check the
statement below, sigh and -date the blanks below the statement,
and return this letter to:
as soon as possible.
Should you have objections to this proposal, please send your
written coments to the NC Division of Coastal. Management, P. 0.
Box 769, Morehead City, NC 28557. written comments must be
received within ten fXOj da s of receipt of this notice.
Failure to respond in either method within ten (10 da s will be
interpreted as no objection.
sincerely,
I have no objection to the project as presently
- —
and hereby waive. that richt of objection as
proposed
provided in General Statute 113-229.
I have objections to the prosect as predentlY proposed
--
and - have enclosed comments.
Signature
DATE:

15 NCP,C -/H .13D2 has been proposed to be amended as follows:
.1102 J'hPF-Rdti>AL PROCEDURLS
(b) he applicant must provide:
(1) confirmation that a written statement has been obtained
signed by the adjacent riparian property owners
indicating that they have no objections'to the proposed
work, or,
(2) confirmation that the ad-acent riparian property owners
have been notified by certified mail of the proposed
work. Such notice should instruct adjacent property
owners to provide any corti-rents on the proposed
development in writing for consideration by permitting
officials to the Division of Coastal ?fanagement within
10 days of receipt of the notice, and, indicate that no
response will be3.Iiterpreted as no objection. DCM
staff will review all comments and determine, __based on
their relevance to the potential impacts of the
proposed—project, - if the proposed project can be
approved by a General Permit. If DCM staff finds that
the com-nents are worthy _of more in-depth review, the
ap2licant will be notified that he must_. submit, an
application for a major development permit.
History Note: Statutory Authority G.S. 113A -107(a);
113.-107(b); 113A -113(b); 113A-3.18.1; 113A-124;
Eff. March 1, 1984;
Anianded Eff. January 1, 1990; December 1, 1987.
TOTAL F.02

d
120 WEST FIRE TOWER ROAD
POST OFFICE BOX 8088
GREENVILLE, N C. 27835.8089
TELEPHONE [phone]
FACSIMILE [phone]
UNIVERSITY CORPORATE CENTER
127 RACINE DRIVE
POST OFFICE BOX 7068
WILMINGTON, N.C. 28406.7068
TELEPHONE [phone]
FACSIMILE [phone]
WARD AND SMITH, P.A.
ATTORNEYS AT LAW
1001 COLLEGE COURT
POST OFFICE BOX 887
NEW BERN, N.C. 28583.0867
TELEPHONE [phone]
FACSIMILE 1919) 638-2121
February 27, 1998
N.C. Division of Coastal Management
Post Office Box 769
Morehead City, North Carolina 28557
RE: Comments re Comfort Suites Docks and Gazebo
Dear Sir:
SUITE 2400
TWO HANNOVER SQUARE
FAYETTEVILLE STREET MALL
POST OFFICE BOX 2091
RALEIGH, N.C. 27802.2091
TELEPHONE [phone]
FACSIMILE [phone]
COPY
With reference to CAMA General Permit No. 018594-C issued February
10, 1998 and the Exemption from CAMA permit issued the same date,.
notice of which was received February 17, 1998 by Mrs. Harvey
Civils and the undersigned, we wish to offer the following comments
on behalf of Mrs. Cavils.
Unnecessarily Endangers Adjoining Property.
Our client is strongly opposed to the construction of these two
structures on the grounds that they will unnecessarily endanger her
property. The facilities are proposed to be constructed at a very
vulnerable location on the Neuse River. This site is on the open
part of the Neuse facing eastward near Union Point, and is directly
in the path of any storm tracking up the Neuse River. As evidenced
by the damage caused by Hurricane Bertha in 1996 (see enclosed
photos taken immediately after the hurricane), this location on the
river is especially vulnerable to store( damage. At that time,
several boats that were docked at the Comfort Suites docks,
together with large sections of the docks themselves, were blown
into Mrs. Ci.vils yard and against her house, causing damage to her
dwelling, 'bulkhead and yard. Similar damage surely would have
occurred again during Hurricane Fran in September 1996, but for the

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 2
fact that the docks had already been destroyed six weeks earlier
during Hurricane Bertha.
It is an absolute certainty that there will be other major storms
and hurricanes impacting this vulnerable portion of the Neuse
River. It is just. a matter of time. When such storms occur, Mrs.
Civils property, because of its location relative to the Comfort
Suites docks, will again be in the direct path of boats and docks
from the Comfort Suites, crashing against the shore and into her
house and yard.
We do not contend that all docks on the Neuse River or elsewhere on
the coast inherently endanger adjoining properties. Our contention
_s that Division of Coastal Management staff must evaluate the
location, size, proximity to adjoining properties, and directional
relationship to nearby properties of each proposed dock in order to
fulfill their regulatory responsibility. The staff should also
consider the availability of intervening protective structures or
land features, history of damage to adjoining properties, and other
relevant factors in making a determination regarding "unnecessary
endangerment.." This determination is best made in the context of
an individual CAMA permit. In fact, the General Permit rules do
not authorize issuance of a General Permit and require that an
individual permit be obtained if the proposed structure "might"
endanger adjoining properties. 15A N.C. Admin Code § 7H .2004(e).
We understand that the CAMA staff historically has relied on the
fact that a docking facility must obtain a building permit that
demonstrates the facility is constructed in conformance with the
state building code. While the integrity of the structure is
important in minimizing the risk to adjoining properties, we do not-
believe
otbelieve it is the only factor that should be considered. We
contend that no wooden gazebo or small. boat dock, no matter how
well constructed, can withstand the forces of a major storm or
hurricane in certain particularly vulnerable locations. This fact,
together with the existence of residences or other occupied
structures immediately downwind from the proposed docking facility,
should be sufficient to deny an application for a permit under 15A
N.G. Admin. Code § 7H .2000.
It is also noteworthy that the permit issued to the Comfort Suites
does not include any condition requiring that compliance with the
state building code be demonstrated or even that a building permit
be obtained. Thus, Division staff has no way of knowing whether

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 3
the lone feature of its present "unnecessary endangerment"
determination .is being fulfilled.
Docking F'acil ity Especially Obj ec ti nable.
Mrs. Civi.ls finds the reconstruction of the docking facility
nearest her property to be especially objectionable. In addition
to the threat posed to her property by this dock, its .Location and
configuration assures that any boats using the dock must turn in
front of her property and enter the slips from the north side.
This will have the effect of increasing the noise, fumes and other
undesirable impacts associated with boating activity immediately in
front of one's property. In Mrs. Civils' case, these facilities
will also significantly detract from her view of the river, being
positioned directly in her line of site down the river. In short,
she does not understand why she must bear the undesirable impacts
of a.commercial dock constructed for the benefit of an adjoining
commercial venture. At the very least, she believes these docks
should be incorporated into the pier and gazebo structure or
configured so that boats using the docks are not forced to navigate
exclusively in front. of her home.
She also requests that the representation made by the Comfort
Suites that it will not rent slips or provide other commercial
services at the docking facility or pier/gazebo structure be
incorporated into the exemption and/or permit as an express
condition.
• - .�5 9� _733 - ._ .-0 F -M -50113M
We also question the validity of the exemption granted with respect
to the docking facility. This exemption was purportedly granted
under an emergency policy for which no one in the Division could
produce a .rule or citation. We ultimately were referred to the
Governor's Office for information concerning any emergency
declarations following Hurricane Bertha. Unless the Division can
provide some legal support for its exemption policy, we question
whether the exemption granted to the Comfort Suites to reconstruct
the dock is legally valid. In addition to the possible absence of
any supporting authority, it is unclear as to whether the Comfort
Suites obtained .its exemption in a timely manner. We could find no
record of an application for an exemption filed prior to the
expiration of the exemption policy on July 31, 1997 (which we are
informed by CAMA staff was extended until October 31, 1997).

WARD AND SMITH, P.A,
N.C. Division of Coastal Management
February 27, 1998
Page 4
Adequacy of Notice to Adjoining Property Owners.
Finally, we question the adequacy of the notice provided to
adjoining property owners. Mrs. Civils is unable to determine
whether she ever .received notice of the original permit application
in 1991 or the modified permit in 1993. One thing is clear. It is
clear that inadequate notice was provided to Mrs. Civils last month
regarding the Comfort Suites general permit application for the
pier and gazebo structure. On that occasion, a document that did
not pertain to the CAMA permit was mailed to Mrs. Civils by
certified mail, return receipt requested. According to Ted
Tyndall, a green card showing that the item was signed for was
provided by the Comfort Suites to the Division. No copy of the
documents mailed to Mrs. Civils was provided to the Division. Only
after we investigated this permit application further did it come
to light that inadequate notice had been provided. The contractor
involved quickly offered to apply for a new permit and re -notice
Mrs. Civils by providing the correct documents, as required by law.
That incident leads us not only to question CAMA's notice
requirements generally, where no proof of what documents were
mailed to adjoining property owners is required to be submitted to
the Division, but also to wonder whether the same faulty notice
procedure may have been employed in 1991 and 1993. CAMA file
records only show a certified mail receipt in October 1991.
Reportedly, a copy of the documents mailed to Mrs. Civils do not
appear in the file. Thus, if some unrelated documents are mailed,
as was the case in 3anuary 1998, how can adjoining property owners
learn of their legal right to comment on an application within the
specified period? Furthermore, how can the Division be sure its
permit is valid if there is no proof that adjoining property owners
were served with the correct documents? In summary, there is no
proof that adequate notice was ever provided by the Comfort Suites
with regard to the original structures and, thus, the exemption for
the docking facility would be invalid if the original permit was
invalid. We request that the Attorney General's Office review this
situation and provide a legal analysis and opinion concerning the
adequacy of each notice required in this instance by the rules, the
validity of the applicant's certification of notice and the
validity of the resulting permits issued to Comfort Suites.
In conclusion, we ask that you give serious consideration to Mrs.
Civils concerns regarding these facilities. They will
unnecessarily endanger her property, as proven by the damage she

WARD AND SMITH, P.A.
N.C. Division of Coastal Management
February 27, 1998
Page 5
sustained in 199E (without compensation by the Comfort Suites or
their boat tenants), and will result in adverse noise and other
undesirable impacts. She is particularly concerned about the
location and proximity of the docking facility presently being
reconstructed.
Yours very truly,
FHS: fs Frank H. Sheffield, Jr.
NBMAIN\315118.1
Enclosures
cc: Mrs. Harvey Civils
Mrs. Eleanor Civils

MISCELLANEOUS PERMIT
CITY OF NEW BERN
,, BOX 1129, NEW BERN NC 28563
636--4003
FAX [phone]
MASTER PERMIT #: -
PERMIT #: 98-00169 DATE ISSUED: 02/11/98
PROJECT #- 98--- EA REF #: __------___
PROJECT ADDRESS:
LOCATION: 218 EAST FRONT STREET
SUBDIVISION:
OWNER NAME: REGINALD PO'TEAT
ADDRESS: PO BOX 339
CI'T'Y : LALURINBURG
LOT #:
BLK #:
PHONE: [phone]
STATE: NC ZIP: 28353
CONTRACTOR: FOLEY & FOLEY
PHONE:
ADDRESS: 1.810 OLD AIRPORT ROAD STATE: NC ZIP:
CITY: NEW BERN
ENGINEER:
ARCHITECT:
PROP. USE: RESIDENTIAL
WORK: RECONFIGURE THE DOCKING FACILTY AND CONSTRUCT GAZEBO
DESC:
VALUATION: ` 30000.00 FEES DUE: 65.00
FEES PAID: 65.00
SPECIAL CONDITIONS: _ WORK CLASS: NEW SQ. FTG:
FIRE ZONE: OCCP TYPE: R
USE ZONE: CNST TYPE: VU
APPLICATION ACCEPTED BY PLANS CHECKED BY APPROVED FOR ISSUANCE BV
�. N 0 T I C E ** k
THIS PERMIT BECOMES NULL AND VOID IF WORK OR CONSTRUCTION AUTHORIZED IS
NOT COMMENCED WITHIN 6 MONTHS, OR IF CONSTRUCTION OR WORK IS SUSPENDED,
OR ABANDONED FOR A PERIOD OF 6 MONTHS AT ANY TIME AFTER WORK IS STARTED
I HEREBY CERTIFY THAT I HAVE READ AND EXAMINED THIS DOCUMENT AND KNOW
THE SAME TO BE TRUE AND CORRECT. ALL PROVISIONS OF LAWS AND ORDINANCES
GOVERNING THIS TYPE OF WORK WILL BE COMPLIED WITH WHETHER SPECIFIED
HEREIN OR NOT. GRANTING OF A PERMIT DOES NOT PRESUME TO GIVE AUTHORITY
TO VIOLATE OR CANCEL THE PROVISIONS OF ANY OTHER STATE OR LOCAL LAW
REGULATING CONSTRUCTION OR THE PERFORMANCE OF CONSTRUCTION.
----------------- - -
----
( SIGNATURE OF CONTRACTOR OF AUTHORIZED AGENT) DATE
02-11-98
(APPROVED BY) DATE

CITY OF NEW BERN, N.C.
DEPARTMENT OF INSPECTION
�«►,�..►,- BUILDING INSPECTOR
r rye_ rwrt �.yr,.
BUILDER MUST REMOVEALL RUBBISH
^^ (40 9
PERMISSION IS HEREBY GRANTED FOR A Y --
Permit To Build 7 .
Permit 14615 Date
Owner, a 1 l 8
` Story Units
Building on Q V 6 (, (SLA�— 5 i—
Street
To be used as YLCAti- .t✓ cl acv- G-�d
General Contractor G
Electrical Contractor
Plumbing Contractor
Mechanical Contractor
Architect/Engineer
Estimated Cost d 000
Fee Collected _ G,5- C)D
Inspection Made
Remarks Y �� 40
This building is to erected or altered in accordance with the Ordinances of the
City of New Bern, N.C. and the General Building Laws of the State.
HELP KEEP OUR CITY &EAN AND
7
I
1
x..

-� R"11 n1hiG
No.
5
i
PERM -11.
Builder Must Remove All Rubbish_
Dated. -2' I 1 1998
THIS BUILDING IS TO BE ERECTED IN ACCORDANCE WITH THE OFDTHE STATE F THE
CITY OF NEW BERN AND THE GENERAL BUILDING LAWS
PLUMBING, WIRING AND INSULATION MUST BE
INSPECTED BEFORE WALLS ARE ENCLOSED
CERTIFICATE OF OCCUPANCY REQUIRED
CITY OF NEW BERN

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FEB -27-98 FRI 16:10 WARD AND SMITH NEW BERN FAX N0. 9196362121 P,02
1?0 WEST FIRE TOWER ROAD
POST OFFICE SQX Bag
GHEENVILI.E, N.0 27031-1006
%j.CPHO>re (0181 885.5030
FAC51MILE. (910) 760-86e6
UNIVERSITY CORPORATP CEN'rr-Ft
127 RACINE DRIV4
POSTOFPIOF 9Qx 1000
vnLMI11rirgN. N.In, 35408-7050
�t ixek1c+na (910) anz-5100
FACSIMILE(910)392-2393
WARD ANU SMITH, P.A.
ATTORNEYS AT LAW
1001COLLEGC•COURT
POST OFFICH ®OX 047
NEW g�RN, N C 2e6s2•aea>•
TELEPHONE (919►683. 1000
FACSIMILE j91 1636.2121
February 27, 7.998
SUIrE 2400
TWO HANNOVER 84U+ARE
FAYE.TTEVILLE STREET MALL
0OS7OPPICE Box 2091
RAIale H, NC 27602.2001
TELEPHONE (sig) age -1800
FACSIMILE (ois) 038-1$117
FEB 2 7 1993
QEi .N&T, VIA ZEU'U 'mo i
N.C. Division of C:oaszal Management
Inst Office Box 769
Morehead City, Norte Carolina 28557
RC: Comments )-e C'amfori: Suites Docks and Gazebo
Dear Sir:
With ref-'erence to CAMA General Permit No_ ()18'194-C issued rebruary
10, 1998 and the l.Jxemption from CAMA permit issued the same date,
notice of Witch was received February 17, 1998 by Mrs. Harvey
Civils and the undersigned, we wish to offer ttLe following comments
on behalf of Mrs. Civi,ls.
U n e C e s,,: aXjj y,_fkXU
our client is strongly opposed to the const=:uGtion of these two
structures on the grounds that, they will unnecossar-ily endanger her
property. Th'a facilities are proposed to be r•onst.ructed at a very
vulnerable location on the Neuse River. This site is on the open
pAxt of the Neuse Eacing eastward near Union Point, and is directly
in the path of any storm tracking up the Neuse River. As evidenced
by the damage caused by Htir_ ricane Bertha 11, 1996 ( see enclosed
photos taken .urmerliately after the hurricane), this location on the
river is especially vulnerable to storm dam -age. At that time,
several boat::> that were docked at the Comfort Suites docks,
together with large sections of the docks themselves, were blown
into Mrs;. Cavils yard and against her house, taus ging damage to her
dwelling, bulkhead and yard. Similar damage surely would have
occurred agaiii dux tng Hurricane Fran in September 1996, but for the

FEE -27-96 FRI 16:10 WARD AND SMITH NEW BERN FAX N0. 9196362121
WARD SAND SMITH, P.A,-
1� .C. Division of Coastal Management
February 27, 1.998
Page 2
P. 03
FEB 2 7 1998
CO
fact thdv the docks had already been destroy£.d si.x weeks earlier
during .Hurricane Bertha,
it is ars absolute certainty that there will be, other major storms
and hurricanf!$ impacting this vulnerable portion of the Neuse
River. It .is just. a matter of time. When such storms occur, Mrs.
Civils property, Because of its location relative to the Comfort
Soltes docks, will again be. in the direct path of boats and docks
trom the Comfort Suites, crashing against the+ shore and into her
house and yard.
Ula do not contend that al]. docks on the Neuse liver or elsewhere on
the coast inherently endanger adjoining properi.ies. Our contention
is that Davi �ii.on of Coastal.. Management staff must evaluate the
location, sire, proximity to adjoining properties, and direction,al.
relationship =.o nearby properties of each proposed dock in order to
fulfill their regulatory responsibility. ThE, staff should also
consider the a.vaiLab.ility of intervening protective structures or
land features, hiutory of damage to adjoining properties, and other
relevant. factors in making a determination regarding "unnecessary
endangerment_" This determination is beat made in the context of
-an individual CPKA permit. In fact, the Genaral Permit rules do
not; authorize issuance of a General Permit and require that an
individual permit: be obtained Lf the proposed structure "might"
endanger adjotninq properties. 15A N.C. Admit; Code § 7H .2004(e)-
We
2009(e)_
We understand that the CAMA staff historicai.,.y has relied on the
fact that a docking ,facility must obtain a building permit that
demonstrates the facility is constructed in conformance with the
state building code. While the integrity of the structure is
ilnpor_ tan t in minir:i.i z ing the x i ,,3 k to adjoining proper r ties, we do not
believe it is the QTL1y factor that should be considered. We
,:;ontend that no wooden gazebo or small boat dock, no matter how
well, constructed, can wit.hst<ind the forces r)f a major storm or
hurricane in c.e.rtain particularly vulnerable locations. This fact,
together with the existence of residences or other occup.led
:icructuxes immediately downwind from the proposed docking facility,
ihould be sufficient Lo deny an application for a permit under 15A
N.C. Admin. Code § 711 .2090.
[;_ is also ncd ewot t-hy that the permit issued to the Comfort. Suites
does not include any coridit.ion requiring that compliance with the
:state building code be demon-strated or even that a building permit
be obtained. Thus, Division staff has no wav of knowing whether

FEB -27-9B FRI 16:11 WARD AND SMITH NEW BERN FAX N0. 9196362121 P,04
WARD AND SMITH, P.A.
N.C. Division of Coastal Management
Fp:bruary 27, 1999
Page 3
the lone featuie of its present
determination is being fulfilled.
M c s. Civ'i 1,-; f -incts tt
nearest her property t
to the threat posed to
configu.i�atior) assures
front of hex prouert}
This will. have thc, eff
undesirable impacts as:
front of one's properl
will also sigrd,fl.crantl
Positioned di.-ectly in
she does not understan
pit a commercial clock i
FEB 2 7 1998
"unnecessary endangerment"
., xeconstruction of ti-te docking :Facility
,a bw especially objectionable. In addition
her property by this cloc)c, Its location and
that any boats using the dock must turn in
and enter the slips from the north side.
.c,t of increasing the noise, fumes and other
oci,ated with boating activity immediately in
y. In Mrs. Civils' cane, these facilities
y detract from her view of the river, being
her line of site down the river. In short,
i why she must bear the undesirable impacts
,onstructed for the benr:fit of an adjoining
commercial venture. At the very least, she: believes these docks
should be incorporated into the pier and ;azcbo structure or
configured so than boats using the docks are not forced to navigate
(:,cclusively iii front of her- home.
:7iln also req-apsts that the representation shade by the Comfort
>ultes that it will not rent slips or provide other commercial
aki-rvices at the docking Eaci,li.ty or pier/t.iazebo structure be
i.nc:orporated into the exemption, and/or pe-cmit as an express
condition.
_V Rtign,
W(3 also question the validity of the exemption granted with respect
to the docking facility. This exemption was purportedly granted
,ruder arc emergency policy for which no one irc the Division could
produce a rule oz citation. We ultimately were referred to the
Governor's Office for information concerning any emergency
declarations Following Hurricane Bertha. Un.1-ass the Division can
provide some legal support for its exemption policy, we question
whether the exemption granted to the Comfort Suites to reconstruct
the dock is legally valid. ]n addition to tho possible absence of
auy supporting authority, it is unclear as to whether the Comfort
:3u.ttes obtained its exemption in a timely manner. We could find no
record of an application for an exemption filed prior to the
nxpixation of the exemption policy on July 31: 1991 (which we are
informed by CAMA staff was extended until oct,iber 31, 199-Y).

FEB -27-98 FRI 16,12 WARD AND SMITH NEW BERN FAX NO. 9196362121
WARD AND SMITH, P.A.
Nd C. Divi$ioD of Coastal. Management
Tebruary 27, 1996
?age 4
P. 05
FEB 2 7 1998
14'.inally, we question the adequacy of tho notice provided to
adjoining p-roperty owners-, Mrs. Civils is unable to determine
whether she ever received notice of the original permit application
Ln 1991 or the mo,li f i.ed permit in 1.993. One thing is clear. It is
r'.fear that inadecptate notice was provided to Mts. civils last month
.(=gaxding the Comfort Suites general permit application for the
J)Ler and gaze'.no st.rtict.ure. On that occasion, a document that did
not pertain to the (3.W permit was mailed to Mrs. Civils by
c.4-artified mail, return receipt requested. According to Ted
Tyndall, a green card showing that the item was signed for was
provided by the Comfort Suites to the Divi.si.:)n. No copy of the
docame5nts mailed to Mrs. Civils was provided tt, the Division. Only
a Eter we in.ve.3tigrated this permit application further did it come
Lo light that inadequate notice had been provided. The contractor
involved quicrkiy offea-ed to apply for a new permit and re --notice
Mrs. Civics by providing the correct documents, as required by law.
That inciden,- lc!ads us not only to question CAMA' s notice
requirements generally, where no proof of what documents were
rnalled to adjoining property owners .is required to be submitted to
t_he. Division, but x150 t0 wonder whether the same faulty notice
pcocedu.re may have been employed in 1991 a,id 1993. LAMA file
i:facords only show a certiCied mail receipt-' in October 1991.
Reportedly, a copy of the documents mailed tt-1 Pers. Civils do not
appear in the file. Thus, if some unrelated documents are mailed,
as was the care .in January 1998, how can adjoining property owners
Learn of their legal right to comment on an application within the
specified per. i.od? Furthermore, how can the Division be sure its
permit is valid it: there is no proof that adjoining property owners
were served with the correct documents? In summary, there is no
iaroof that adequate notice was ever provided by the comfort Suites
With regard tc.� the oricli.naL structures and, tht,es, the exemption fox
!_tie docking facility would be invalid if the original permit was
uval.id. We request that the Attorney Generals Office review this
:a.i.tuation and provide a legal analysis and opi.n.i.on concerning the
adequacy of_ each notice required in this instae:ce by the rules, the
validity of the applicant's cerLificatLon of notice and the
staLidity of the resulting permits issued to C,)mfort Suites.
rte eanclus,ion f
we risk that. YOU give
serious c rnsideration to
Mrs.
k:xvi]_s corncerns
rec1ard.ing these
facilities.
They
will
lazznecessarily
cndanrler• her property,
as provFn by
the damage
she

FEB -27-98 FRI 1612 WARD AND SMITH NEW BERN FAX N0. 9196362121 P.06
WARD AND SMITH, P.A.
N.C. Division of 'Coastal, Management
February 27, 1998
Page 5
:3ustained in 1996 (without compensation by the Comfort Suites or
Cheir boat tenants), and will result in adverse noise and other
jade;>irable impact -s. She is particularly concerned about the
.1ocwat ion and proximity of the docking facility presently being
recoristxucted.
Yours vary t;rui y,
Frank H. Shef£.i,31d, Jr.
F }{S : is
M11M Ilq\3].5119.1
s�nclosures
�c.: Mrs_ Harvey Civils
Mrs. Eleanox Ci.vil.s
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