20060030 Ver 2_More Info Received_20090206

ENVIRONMENTAL SERVICES, INC.
524 New Hope Road
Raleigh, NC 27610
919 - 212 -1760 / Facsimile 919 - 212 -1707
www .environmentalservicesinc.com
MEMORANDUM FEd 0
6 2009
TO: Joanne Steenhuis — NCDWQ i�,�,�•
127 Cardinal Drive Extension `
Wilmington, NC 28405
FROM: Jeff Harbour, PWSdAg
DATE: February 4, 2009
RE: Pecan Grove Elevated Boat Ramp & Associated Dredging Project No. 1472
On behalf of the applicant, ESI is submitting the following information to you in response to
your comments documented in your memo to Daniel Govom of NCDCM regarding the above
referenced project The following information is presented in the same order that it is presented
in your memo Mr Govom asked that we respond directly back to each individual commenter
Wetland Delineation — The EA states that ESI conducted a wetland delineation I actually should
have stated that I conducted a wetland assessment where I estimated the amount of wetlands
occurring onsite The amount of onsite wetlands reflected by the original 2004 delineation and
map should be considered the correct amount
Larger Boats & Shellfish Lease — Information provided by the applicant indicates that the
previous shellfish lease held by Mr Lea is no longer in effect and was waived by Mr Lea when
the applicant originally constructed the existing pier /gazebo With regard to large boats using
the area, the applicant has no information with regard to the type of vessels that will utilize the
ramp The ramp is proposed to be 12 feet wide and any boats that exceed that will have to find
suitable ramps to accommodate their larger size Obviously, discharges from on -board heads
will be discouraged and any signage required by state regulations will be used at the boat ramp
facility
Turbidity Curtains — The marine contractor will utilize turbidity curtains to mmmmize turbidity
impacts
Width of the Elevated Ramp and Alcohol Use — The volume of people utilizing the proposed
ramp will be relatively small compared to a public ramp The applicant and the marine
contractor feel that a 12 -foot wide ramp provides ample space for a boat owner to back their boat
trailer It is my understanding that the temporary easement currently being afforded to the
homeowners has a space narrower than 12 -feet wide that goes through an existing building

Therefore, it is our opinion that the current design is adequate for the intended use These types
of ramps (12 feet wide) have been built elsewhere in the southeast for both military and
recreational users Additionally, it is not the applicant's responsibility to provide the additional
protection of a wider ramp for boaters who knowingly violate the state and federal laws
regarding operating a boat under the influence of alcohol
Dredging & SAV— All dredging and offloading will occur during periods of high water to avoid
impacts to the bottom Previous work conducted on this site for the existing pier /gazebo was
conducted during high water periods with little to no bottom disturbance At the request of the
applicant, ESI is currently working directly with DMF to address their concerns associated with
this project The applicant is also considering some form of compensatory mitigation to offset
any potential impact, although no mitigation thresholds have been exceeded and this would be
considered voluntary on the part of the applicant The preferred alternative proposes dredging an
area encompassing approximately 0 08 acres with an estimated dredged volume of
approximately 213 yards3
Moratorium Dates — The contractor will comply with all mandatory moratoria dates
Offsite Alternative — The residents of Pecan Grove have been granted temporary access at a
nearby boat ramp located at the end of Lewis Road This offsite location is currently private
property and the temporary access was granted only until a permanent solution could be found
Although this offsite location does provide access to deep water, it does not meet the applicant's
stated purpose and need for the proposed elevated boat ramp, which will be located directly
adjacent to Pecan Grove The Lewis Road site was not included in the EA because it has never
been promoted as a permanent solution by anyone other than the regulatory community While
the Lewis Road site does avoid and minimize potential impacts to surface waters, other
considerations must also be taken into account, including financial considerations Mandating
the use of the offsite private property for the permanent use by the Pecan Grove residents could
possibly be viewed as a taking of private property It appears that the applicant's generosity to
the homeowners in providing temporary access is being ignored and private property rights could
be infringed upon without the proper regulatory j unsdiction to do so
The applicant and ESI respectfully request that NCDWQ look at all of the factors that are part of
this scenario The applicant has spent a lot of time and resources trying to fulfill a commitment
to the Pecan Grove residents He has made requests to improve the usability of the existing boat
ramp, but without success (denied do to dredging an area then occupied by SAV) He has
allowed temporary use of the offsite Lewis Road ramp, but can not maintain the temporary
access easement much longer due to other financial commitments The applicant respectfully
requests your support of a FONSI for his preferred alternative, which avoids direct impacts to
SAV, minimizes the amount of dredging originally proposed, and meets the purpose and need of
the applicant All environmental responsibilities will be taken very seriously and, if necessary,
the applicant may voluntarily provide some sort of compensatory mitigation, depending on
further DMF comments
Please provide your comments to Mr Daniel Govom at your earliest convenience Thank you
for your time in reviewing the EA and our responses to your concerns