19961054 Ver 2_Public Comments_20110523

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ABBRA!\
Dedicated to the Marine Service and Repair Industry
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May 19, 2011
Ms. Cyndi Karoly
NC Division of Water Quality
401 Oversite & Permits Unit
1650 Mail Service Center
Raleigh, NC 27699-1605
Dear Ms. Cyndi Karoly,
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I am writing on behalf of the American Boat Builders and Repairers Association to ask
the NC Division of Water Quality and the Army Corps of Engineers to uphold the
variance given by the Coastal Resource Commission to Bennett Brothers Yachts, Inc. for
dredging a small portion of their marina to remove silt that has left their walkway and
some of their docks in the mud.
ABBRA is a non-profit membership organization that is dedicated to professionalism
in the boat building and repair industry. Bennett Brothers Yachts, Inc. has been one of
our members since 2009 and provides outstanding service to not only their customers but
to the industry as a whole.
Since they built their facility in 1997 Bennett Brothers Yachts, Inc. has been the epitome
of what a good boatyard is-a boatyard that not only provides economic value to the
surrounding community, a home to visiting boaters, a safe haven for boaters during
hurricanes, a world-class repair yard, but also a steward of their waterfront environment.
They were the first boatyard in the area to install pumpout facilities to every slip to
ensure waste was not being dumped overboard, they embraced industry best management
practices for any upland repairs and maintenance they undertook to prevent polluted
runoff from entering the waters, and they built their overall facility with the environment
in mind. They voluntarily signed up to be inspected for the state's clean marina
designation and were certified as such and continue to maintain that status.
The silt that has built up over the years in their marina basin was unforeseen when the
facility was built as it was constructed over a deep river conducive to shipping traffic. For
whatever reason, the siltation has increased leaving the marina's public access walkway,
which abuts the shore, and one dock capable of holding six or more boats unsafe to the
point both will soon be unusable. While this may seem to be a small portion of this
50 Water Street
Warren, Rhode Island 02885
Phone: [phone] • Fax: [phone]
Email: info(a abbra.m_, Web site: Aww.abbra.m2
AMERICAN BOAT BUILDERS & REPAIRERS ASSOCIATION, INC.
business, a boatyard relies on the income from every slip, whether for transient boats,
long-term docking customers, or short-term repair business. It is not just six slips, but
rather home to a steady stream of paying customers, all contributing not only to the
business, but to the local economy.
While prime nursery area should be protected, it should not be at the expense of a facility
that has been there for years, doing a job that has been part of the Cape Fear River for
centuries. If the entire river, excluding the shipping channel, is prime nursery area it
seems that dredging this one small area would have minimal impact on the overall fishery
and a variance for this work should be upheld.
Thank you for your consideration.
Sincerely,
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Pamela Lendzion
ABBRA President