HomeMy WebLinkAbout20110905 Ver 1_Other Agency Comments_20111222US Department oic
Homeland Securit
United States
Coast Guard
Ms Christy Wicker
U S Army Corps of Engineers
Regulatory Division
69 Darlington Avenue
Wilmington NC 28403
Dear Ms Wicker
I\- bc� 05 Voi�-f
Commanding Officer 1240 East Ninth Street
United States Coast Guard Room 2179
Civil Engineering Unit Cleveland Cleveland Ohio 44199 2060
Staff Symbol ER ce
Phone (216) 902 -6304
Fax (216) 902 6277
Email mark a lamb@uscg mil
t
t � �
11000
DEC 16 2011
The U S Coast Guard (USCG) has received your letter dated 18 November 2011 regarding our
proposed project to conduct maintenance dredging of the small boat mooring basm on an as
needed basis at USCG Sector North Carolina facility located at 2301 East Fort Macon Road
Atlantic Beach Carteret County North Carolina In addition the USCG received conditions
from the North Carolina Department of Environment and Natural Resources (NC DENR)
Division of Coastal Management (DCM) and the NCDENR Division of Water Quality (DWQ)
This correspondence provides your office with a USCG Response to Comments from Regulatory
Agencies in Enclosure (1) The USCG is responding to the following 1) comments from the
U S Army Corps of Engineers (USACE) letter to the USCG dated 18 November 2011 2)
consistency conditions from the NC DENR DCM letter to the USCG dated 31 October 2011
regarding Federal Consistency determination C11 062 and 3) certification conditions from the
NCDENR DWQ in their letter to the USCG dated 14 November 2011 regarding 401 Water
Quality Certification Approval (Certificate #3872) Project # 2011 0905 As shown in Enclosure
(2) the USCG has modified Construction Drawing C 05 to change the physical location of the
discharge pipe to assure compliance with this condition
Thank you for your attention to this matter If you have any questions please contact Mr Mark
Lamb of my staff at (216) 902 6304
Sincerely
14 ._ ----_
S PLACZ P E
Technical Director, Civil Engineering Unit
By direction of the Commanding Officer
Enclosure (1) USCG Response to Comments from Regulatory Agencies
(2) Modified Construction Drawing
Copy Stephen Rynas NCDENR DCM
Coleen Sullins NCDENR DWQ D
DEC 2 s 2011
DENR WATER OUALITy
WETLANDSAND STORMWATER BRANCH
ENCLOSURE (1)
USCG RESPONSE TO COMMENTS FROM
REGULATORY AGENCIES
Enclosure (1)
25 NTU) shall not be exceeded for the dewater system s accumulated water that will be
discharged back to Bogue Sound
Background
USCG Sector North Carolina is located dust west of Fort Macon in Carteret County North
Carolina USCG Sector North Carolina has many missions including the safeguarding of
navigational interests (governmental commercial, and private), protecting North Carolina s
coastline from pollution and marine accidents and enforcement of Federal Laws and
responsibilities under the Homeland Security Act
Maintenance dredging has been conducted in the basin in several times in the past
Existing Conditions
Since the previous dredge protect the basin area has locations that have filled into 5 to 10
MLW This is impinging on the ability to utilize the basin for the functions of the unit
The material to be dredged is expected to be a mixture of fine sand and silty sediment materials
Alternatives Analysis
Feasible alternatives to the proposed project are discussed below
The No Action Alternative Not dredging the small boat basin at USCG Sector North Carolina
would result in continued filling of the project area When the area has filled too much the
USCG would be unable to execute its mission from the Sector North Carolina
Dredging Given the need to maintain efficient operation of the Sector North Carolina s small
boat basin the only feasible alternative is dredging There are several methods of dredging
available for accomplishing the work These methods are contract hydraulic pipeline dredge
mechanical (clamshell dragline etc ) dredge, side cast dredge and special purpose (hopper)
dredge The result of dredging would be the removal of sediments lying above the 12 feet
MLW plus 1 foot allowable overdepth Impacts of the different dredging alternatives would
essentially be the same regardless of the method utilized
Given the relatively small quantity of material to be dredged (8 800 cy) the use of governmental
and/or private dredging operations in the area would be important to reduce and/or avoid the
expense of contract/commercial dredge plant mobilization and demobilization The USCG will
contract out the dredging to a commercial entity should the governmental dredge not be available
in a timely manner
Disposal of the dredged material would be dependent upon the method of dredging used and the
grain size of the material to be dredged Different disposal options are discussed below
Disposal Option 1 — Brandt Island (USACE Disposal Island)
3
Enclosure (1)
NCDWQ classifies waters within the Morehead City Channel as SA and HQW None of the
project areas (dredging or disposal sites), are located in Outstanding Resource Waters (ORW) as
defined by NCDWQ
The NC Division of Marine Fisheries does not classify the project areas (dredging and disposal
sites) as a Primary Nursery Area (PNA) in accordance with (15A NCAC 07H 0208(a)(4))
It is unlikely that any submerged aquatic vegetation (SAV) is present within the area to be
dredged since the area is routinely navigated and historically dredged The area experiences
tidal and current action in addition to sand movement
There are no shellfish beds located in the project area (15A NCAC 07H 0208(a)(2)
The project site is not designated as a Natural and Cultural Resources Area (15A NCAC
07h 0501) Since the project area has been dredged before this project is not likely to impact
any natural or cultural resources Each dredge event will be conditioned to ensure that care is
taken during all aspects of the work Any cultural resources encountered will be protected and
coordination with the USACE and the NC Department of Cultural Resources Underwater
Archaeology Unit will occur
USACE Comment 2 It is necessary for you to have taken all appropriate and practicable steps
to minimize wetland losses Please indicate all that you have done especially regarding
development and modification of plans and proposed construction techniques to minimize
adverse impacts
USCG Response 2 There are no wetlands within the limits of the proposed project action area,
therefore there will not be any wetland losses
USACE Comment 3 The MOA requires that appropriate and practicable mitigation will be
required for all unavoidable adverse impacts remaining after all appropriate and practicable
minimization has been employed Please indicate your plan to mitigate for the projected
unavoidable loss of waters or wetlands or provide information as to the absence of any such
appropriate and practicable measures
USCG Response 3 The USCG will implement the following environmental mitigations to
minimize adverse impacts to waters
Based on the project location type of work temporary nature of the work, and short term
duration of the project any environmental impacts are expected to be minimized
The USCG will not conduct in -water work from February 1 through July 31 This
moratorium incorporates all moratoriums on construction activities established by the
commenting state and Federal regulatory agencies to minimize biological and
environmental impacts
0
Enclosure (1)
Condition 7
The effluent water from the dredge spoil will not be released into open shellfish waters without
notification to Shellfish Sanitation and DWQ As shown in Enclosure (2) the USCG has modified
Construction Drawing C 05 to change the physical location of the discharge pipe to assure
compliance with this condition
Condition 8
The USCG will not conduct in -water work from February 1 through July 31 so that all
moratoriums on construction activities established by the NC Wildlife Resources Commission
(WRC) US Fish and Wildlife Service (USFWS) NC Division of Marine Fisheries (DMF) or
National Marine Fisheries Service (NMFS) to minimize biological and environmental impacts
Exceptions will require written concurrence from the applicable individual agency and
notification to the Division of Water Quality
7
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