HomeMy WebLinkAbout20230797 Ver 1_Other Agency Correspondence_20230814Ero-
August 11, 2023
Ms. Liz Hair
Wilmington Regulatory Field Office
69 Darlington Avenue,
Wilmington, North Carolina 28403
North Carolina
Coastal Federation
Working Together for a Healthy Coast
Sent via email: sarah.e.hair@usace.army.mil.
Dear Ms. Hair,
The North Carolina Coastal Federation respectfully submits the following comments regarding
the Carteret County permit application for the construction of a boat ramp on Bogue Sound by
Carteret County within the Ocean community.
Since approximately 2018, the Federation has been collaborating with the county to develop an
environmentally responsible project on this land. The proposed boat ramp area, which was
originally designated as Phase IV of the Morada Bay subdivision, had plans for around 65
houses along the waterfront area of this property. The remaining acreage on the property
inland of the proposed ramp, which is also now under county ownership, was destined for
future development, potentially comprising significant additional residential development and
a commercial zone along Highway 24.
Thanks to $7.4 million in funding from various public and private sources, including the North
Carolina General Assembly, N.C. Land and Water Fund, the Navy, and N.C. Parks and Recreation
Trust Fund, the county was able to acquire the property and dedicate the entire 66-acres for
public "recreation uses." Notably, over 24-acres of the 66-acre parcel have already been placed
under perpetual conservation easements, including a two -acre permanent easement along the
forested Bogue Sound waterfront —preventing the development of waterfront homes with
docks.
As part of this land acquisition, the Federation independently procured 10-adjacent acres for its
new headquarters and a public event center, a venture that is independent yet complementary
to the county's boat ramp proposal. Our project adheres to distinct criteria, involving no new
water -based development and positioned at a considerable distance from mean high water,
resting on sandy soils devoid of wetlands. It's important to mention that a segment of our
Northeast Regional Office Headquarters & Central Regional Office Southeast Regional Office
637 Harbor Road, P.O. Box 276 3609 N.C. 24 • Newport, NC 28570 309 W. Salisbury Street
Wanchese, NC 27981 252-393-8185 Wrightsville Beach, NC 28480
252-473-1607 www.nccoast.org 910-509-2838
00
North Carolina Coastal Federation
project falls within the 575-foot Outstanding Resource Waters Area of Environmental Concern
under the Coastal Area Management Act (CAMA).
Additional context and background further inform the Federation's comments. Having lived
within proximity of the proposed boat ramp site for over 65 years, I have closely monitored the
status of fishery habitats and water quality in the adjoining waters of Bogue Sound. Owing to
the Intracoastal Waterway and the substantial boat traffic it attracts, water quality and
submerged aquatic vegetation (SAV) resources along the mainland shoreline here have notably
deteriorated over the past few decades. Some agencies seem to be under the mistaken
impression that SAV and water quality are improving at this location — I can testify from six
decades of close observations that these resources are becoming significantly more degraded
over time. Having also assisted with the SAV survey submitted with the application, I can attest
that the SAV in this area is patchy at best, not the lush meadow the screen grabs from the SAV
map makes it out to be. SAV exists in the green areas of the survey, but it is not a consistent
coverage. Larger boats causing significant ocean -size waves contribute significantly to shoreline
erosion and degradation of SAV resources, while smaller trailer -sized boats have comparatively
less impact.
Recollections from my youth highlight dense seagrass meadows that once adorned the
mainland shoreline, now conspicuously absent. The patchy SAV resources now present are just
a skeleton of the lush SAV meadows that used to stretch along the entire mainland shoreline in
this area. Bottom sediments in the vicinity have turned from a denser and firm footing (such as
still exists in Bogue Sound south of the spoil islands away from the federal channel) that existed
in my childhood, to now a mucky and silty texture. The shoreline erosion and loss of salt
marshes have only exacerbated the degradation of SAV resources as sediments and silt from
this erosion moves offshore. Whenever large boats speed by this location, their tremendous
wakes stir up all this muck and sediment and cause high turbidity levels that undoubtedly
violate state water quality standards. This perpetually muddy water during the active boating
season is concentrated between the spoil islands and mainland shoreline and contributes to
SAV declines.
This area's distinctive features include dredge spoil islands lining the southern side of the
Intracoastal Waterway. These islands previously had much higher elevations that supported
trees and provided rich bird habitat. In the past few decades, they have witnessed dramatic
subsidence and erosion especially since their creation in the 1930s. Their erosion has
transformed them into intertidal salt marshes that are still rapidly declining in elevation and
extent. The Federation and county have collaborated with Dr. Jud Kenworthy, a nationally and
international respected SAV expert retired from NOAA. He helped us recognize the critical role
these artificially formed islands play in buffering SAV and maintaining water quality against the
impacts of boat traffic in the federally maintained channel.
Though seemingly counterintuitive, a comprehensive examination spanning over five years has
led me to conclude that the boat ramp project can yield environmental benefits. Opting against
the project does not arrest the rapid decline in SAV resources and water quality in this location.
North Carolina Coastal Federation
While taking "no action" avoids immediate project impacts, it fails to instigate a comprehensive
strategy to address fundamental environmental concerns. Rejecting this project would frustrate
county government, state legislators, and other backers who have proposed and funded this
initiative in the public interest. The county's proactive mitigation strategy signifies its dedication
to tackling existing water quality and SAV challenges. This presents an opportunity for
environmental agencies, the public, and local, state, and federal entities to collaboratively
address these environmental issues proactively.
The conservation efforts integral to the project have already contributed a measure of
environmental protection that residential and commercial development on this property would
not have achieved. Over 24-acres have been permanently conserved, and additional unutilized
land for the boat ramp could further augment these conservation areas, providing valuable
open space for public recreation. The county has also already supported the installation of a
living shoreline along the waterfront protected by the conservation easement, and this project
has reduced sedimentation and turbidity caused by erosion. Preservation of the maritime
forest along the waterfront prevents its transformation into cleared homesites, each with
docks. Distinguishing this boat ramp from others is its ample undeveloped acreage, which
serves as a buffer to the facility.
Significantly, the facility's construction site boasts permeable soils, promoting natural
stormwater infiltration. Due to the natural slope of the land, runoff from most of the parking
areas will drain away from the sound, spreading and infiltrating it into wooded and protected
conservation zones. Consequently, most stormwater runoff generated by the facility can
infiltrate, meandering laterally through groundwater into forested lands before reaching Sikes
Creek's headwaters hundreds of yards north of the parking areas. This creek drains eastward
for approximately a mile before flowing into the estuarine waters behind the Cannons Gate
subdivision. The proposed stormwater system adheres to ORW rules and remains open to
further agency recommendations for enhancement. Additionally, the parking lot design has
incorporated nature -based solutions to its fullest extent, with significant investment being
made in pervious pavement to reduce runoff volumes. Because of the nature of this land and
the amount of undeveloped acreage surrounding it, the boat ramp should not contribute
polluting runoff to Bogue Sound.
Given the cumulative impact of boat traffic on SAV and water quality in Bogue Sound, concerns
about this project should extend to considering the larger picture. Addressing cumulative
impacts necessitates a comprehensive approach, transcending singular permit decisions. This
project presents an opportunity to engage in a more holistic manner, a practical reality since
cumulative impacts apply to public and private boat docks, marinas, waterfront homes with
docks, and similar installations. Contrarily, denying this ramp based on cumulative impact
apprehensions would suggest the need to halt and deny all additional future projects
introducing more boat traffic to Bogue Sound. It's a fact that the cumulative impact of existing
residential and commercial boat docks greatly exceeds the boat traffic in the sound that this
publicly owned facility will facilitate. Moreover, the rarity of a $10+ million public investment by
the government to create a public boat ramp with substantial surrounding natural area to
North Carolina Coastal Federation
buffer its impacts assures this scenario remains uncommon, while setting a positive precedent
if ever repeated.
While the mitigation strategy strives to counterbalance unavoidable environmental effects of
the ramp, it alone won't suffice to reverse the existing declining water quality and SAV
resources along Bogue Sound's mainland side. A more extensive endeavor is required to
safeguard the dredge spoil islands and alleviate the rapid erosion of the mainland shoreline, an
effort the county supports. This endorsement is evident in its support of the Federation's
restoration endeavors, unrelated to this project.
The Federation has worked with the county's design team to minimize impacts to coastal
wetlands by moving the preferred basin/channel location to a portion of the shoreline where
most of the salt marsh has eroded away in recent years. In addition, the county has agreed to
install living shorelines along the full extent of its shoreline, and we have worked to design that
component of the project with its engineers. Furthermore, to further reduce shoreline erosion
that causes lack of water clarity and smothers SAV (erosion that is already occurring), the
Federation has prioritized to work with mainland waterfront property owners within a mile of
the project site for the use of funds appropriated by the N.C. General Assembly to cost -share
living shorelines, and is also spending part of those appropriations to install living shorelines
along the spoil islands in work that is not part of the mitigation proposal.
As recommended by the N.C. Division of Marine Fisheries, the Federation encourages exploring
the use of a "No Wake" zone around this project area to eliminate many anticipated project
impacts. This no wake restriction should apply not only to the proposed new access channel for
the ramp, but also to a portion of the Intracoastal Waterway (at least between Marker 33 and
34). Eliminating the big wakes that are now generated by large speeding boats in the vicinity of
the ramp would be huge opportunity to completely offset and eliminate many of the existing
and future concerns about shoreline erosion, damage to SAV, and degraded water quality that
can be attributed to existing concentrated boat traffic in this location. This action is probably
also warranted for safety reasons as well. Just as we have speed limits elsewhere in the nation
on federal navigation channels to protect manatees, imposing this safeguard at this location
would eliminate a long-standing and persistent cause of environmental declines of essential fish
habitats along this shoreline.
Finally, it is important to keep in mind that this is a public project funded by taxpayers to
provide access to the state's public trust waters for those not fortunate enough to own
waterfront property. It will serve millions of people in the coming decades. The project is in the
public interest and should be evaluated to include those benefits that aren't typically a result of
privately owned development projects.
In conclusion, the county's application signifies a well-intentioned endeavor uniting various
stakeholders to proactively address the adverse environmental trends in Bogue Sound. Such
initiatives could ignite further partnerships and forward -thinking actions, surpassing mere
reactions to individual development proposals. The scrutiny of agencies can improve the
North Carolina Coastal Federation
project by infusing fresh perspectives and fostering a collaborative process, ultimately
enhancing this exceptional project in the public's interest. Critique or opposition alone will not
secure Bogue Sound's long-term preservation; it will instead expedite its decline.
Best regards,
r
Todd Miller
Executive Director
Attachments: A. 1939 photo of project site to show dramatic changes in spoil islands
B. 1983 photo of project site to show dramatic changes in spoil islands
C. 2020 photo of project site to show dramatic changes in spoil islands
cc: NC DCM
NC DWR
NC DMF
NC WRC
USFWS
NOAA
EPA
North Carolina Coastal Federation
Attachment A: 1939 Photo — Note size of spoil islands and tree cover
NQUiRY # 5906545.5
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North Carolina Coastal Federation
Attachment B: 1983 Photo — Note Changes
North Carolina Coastal Federation
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Attachment Q ZOZO Photo — Island R about to be breeched across from project site
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