20201153 Ver 2_DMF comments_20211220

TO: Gregg Bodnar, NCDCM Assistant Major Permits Coordinator
FROM: James Harrison, NCDMF Fisheries Resource Specialist
SUBJECT: Bell Investment Group, Carteret County
DATE: 20 December 2021
A North Carolina Division of Marine Fisheries (DMF) Fisheries Resource Specialist has
reviewed the permit application for proposed actions that may impact fish and/or fish habitats.
The proposed project is located at 4700 South Shore Drive, Morehead City, within Carteret
County, North Carolina. The proposed work is part of the development of a six-lot subdivision.
On the Peletier Creek side of the property, the applicant is proposing to construct six 2-slip
docks, each consisting of one wet slip and one boatlift, covered and uncovered platforms, and
finger piers. The applicant is also proposing a 370’ keystone retaining wall landward of the
normal high water (NHW) line and coastal wetlands On the Bogue Sound side, the applicant is
proposing to construct six observation piers with platforms. Along the eastern side of the
property, the applicant is proposing to install a 145’ vinyl bulkhead extension that would connect
to the existing unfinished bulkhead that runs along the Bogue Sound side of the property. No
submerged aquatic vegetation (SAV) was observed within Peletier Creek, but SAV was observed
within the footprint of the structures proposed to extend into Bogue Sound. Water depths in the
area of the proposed observation platforms were less than -2’ normal low water (NLW).
SAV is an important habitat type for a wide variety of reasons. Areas that support SAV growth
provide numerous aquatic species with refuge, forage, and spawning habitat. SAV also provides
natural shoreline protection, serving as a natural wave attenuator. Additionally, SAV provides
water quality services (i.e., nutrient uptake and oxygenation), and is often used as a bioindicator
of water quality. As this area has well-established SAV habitat, DMF is concerned with the
potential for the proposed six observation platforms on Bogue Sound to impact SAV habitat
during construction and after construction due to shading and potential prop scarring.
The DMF requests additional information and likely project design changes to the project to
accurately assess potential impacts and adequacy of avoidance and/or minimization measures.
The lots are all waterfront and will have docking access on the basin side of their lots. Therefore,
the applicant should provide the purpose and need for additional platforms over SAV habitat. If
the viewing platforms are necessary, a SAV survey will be needed so that structures can be
located to avoid and minimize the impacts to SAV. This survey should be completed during the
April through October active growing season, ideally closer to the middle as this is the period of
peak productivity. The results of this survey should be used to determine a project design that

will result in minimal SAV impact, such as siting the structures over minimal SAV and piling
installation between patches/beds of SAV. Also, the design should be adjusted from individual
observation piers and platforms to one pier that serves the entire community. This would
minimize the shading impacts associated with individual structures, as well as those associated
with the actual construction. The structure should also be extended so that the terminus is located
outside of mapped SAV. Any platform covering should also be of an open design (i.e., pergola-
style) rather than fully covered, as this will minimize shading impacts. Other means of reducing
shading below the pier include higher elevation above the water surface, increased spacing
between slats, and/or using plank decking that has open spacing (e.g. fiberglass grating). Finally,
any permit issued should be conditioned on no formal or informal docking along the observation
pier/platform being added in the future, regardless of ownership of the property.
Thank you for consideration of our comments and concerns. Please contact Jimmy Harrison at
[phone] or at [e-mail] with any further questions or concerns.