20160326 Ver 1_WRC Comments_20170417

Strickland, Bev
From:
Dunn, Maria T.
Sent:
Monday, April 17, 2017 3:58 PM
To:
Scarbraugh, Anthony; Staples, Shane
Subject:
RE: Elite Management Group, LLC
Attachments:
CMDF -Elite Management_NCWRC.pdf
Maria T. Dunn
Coastal Coordinator
NC Wildlife Resources Commission
943 Washington Sq. Mall
Washington, NC 27889
office: 252-948-3916
fax: [phone]
www.ncwildlife.org
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
From: Scarbraugh, Anthony
Sent: Monday, April 17, 2017 9:24 AM
To: Staples, Shane <[e-mail]>; Dunn, Maria T. <[e-mail]>
Subject: Elite Management Group, LLC
Could I get your comments concerning the 20 slip marina, travel lift and bulkhead?
Thanks
Anthony Scarbraugh
Environmental Senior Specialist
Division of Water Resources — Water Quality Regional Operations
Department of Environmental Quality
252 948 3924 office
anthony.scarbraugh(a)ncdenr.gov
943 Washington Square Mall
Washington, NC 27889
Email correspondence to and from this address is subject to the

North Carolina Public Records Law and may be disclosed to third parties.

IQ North Carolina Wildlife Resources Commission
Gordon Myers, Executive Director
MEMORANDUM
TO: Gregg Bodnar
Division of Coastal Management
North Carolina Department of Environmental Quality
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: April 3, 2017
SUBJECT: CAMA Dredge/Fill Permit Application for Elite Management, LLC, Perquimans
County, North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the permit
application with regard to impacts on fish, wildlife, and public access resources. The project site is
located at 101 N. Granby Street adjacent to a NCWRC public access area and NC Seafood Park Authority
site adjacent the Perquimans River in Hertford, NC. Our comments are provided in accordance with
provisions of the Coastal Area Management Act (G.S. 113A-100 through 113A-128), as amended,
Sections 401 and 404 of the Clean Water Act, as amended, and the Fish and Wildlife Coordination Act
(48 Stat. 401, as amended; 16 U.S.C. 661 et seq.).
The applicant proposes to construct a 20 -slip docking facility, travel lift piers, bulkhead, and associated
infrastructure for a boat / barge repair and maintenance facility. Details on the upland development was
not provided, but water dependent development includes a 20 -slip docking facility for vessels up to 50' in
length that has slip depths varying from -4' to -5.5' NWL, two travel lift piers, the closing and filling of a
36' by 120' unfinished boat ramp, riprap, and other shoreline stabilization reinforcements. The
Perquimans River at this location is classified SB by the Environmental Management Commission and is
designated an anadromous fish spawning area (AFSA) by the NCWRC.
We have reviewed the permit application and believe there is insufficient information to adequately
determine the impacts this project will have on wildlife resources. Items of concern include the following:
• The project proposal did not include a complete development layout. It is difficult to understand
the project's overall scope if it is not presented during this process.
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

CMDF—Elite Management, LLC Page 2 April 3, 2017
• A 20 -slip marina should have a marina management plan to address emergency action toward
spills, location of spill and safety equipment, presence of a dockmaster, docking rules, and other
contact information.
• A vessel maintenance yard has the potential to introduce considerable toxins into the adjacent
water body depending on type of maintenance performed at the facility and means to contain
waste. Details regarding services provided and management practices must be provided to insure
the site will not introduce toxins to the area.
• The site is adjacent to a NCWRC boating access area (BAA). There is concern that the extended
20 -slip facility may further congest the area once the BAA and Perquimans Marine Park are built
out.
• The Perquimans Marine Park was designed to contain industrial type facilities "in the hill" to be
accessed by the dredged basin. This design allows easier containment of spills and minimizes
user conflict with the public. It also was a reason to justify allowing an access channel to be
dredged from the Marine Park to the channel within the Perquimans River. Discussion should be
provided as to why this facility is not proposed in the Marine Park.
• The Perquimans River is a designated AFSA. Any permitted in -water work should adhere to a
February 15 — June 30 moratorium.
We appreciate the opportunity to review and comment on this permit application and look forward to
forthcoming information. Please do not hesitate to contact me at [phone] or at
maria. dunnkncwildlife. org