20230797 Ver 1_DMF Comments_20230621

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
KATHY B. RAWLS
Director
TO: Gregg Bodnar, NCDCM Major Permits Coordinator
FROM: James Harrison, NCDMF Fisheries Resource Specialist
THROUGH Anne Deaton, NCDMF Permit Review Supervisor
SUBJECT: Western Carteret Boat Ramp, Carteret County
DATE: 21 June 2023
A North Carolina Division of Marine Fisheries (DMF) Fisheries Resource Specialist has
reviewed the CAMA Major permit application and associated documents regarding the proposed
Western Carteret Boat Ramp. The proposed project would be located at 241 Morada Bay Drive,
Newport, within Carteret County, North Carolina. The applicant, Carteret County, is proposing
to create a public boat launch facility with six ramps and a 159-space boat trailer parking lot with
an access channel to the Atlantic Intracoastal Waterway (AIWW). The waters at this location are
classified as Outstanding Resource Waters (ORW); SA and are open to shellfish harvesting.
There are historical records of submerged aquatic vegetation (SAV), and recent surveys found
that SAV is still present at this site.
The proposed project is located on a 67-acre parcel on the northern mainland shoreline of Bogue
Sound, approximately 1 mile east of Goose Creek and 1 mile west of Sanders Creek. The
shoreline of the site is 900' long, has an elevation of 4' along the shoreline, and contains coastal
wetlands consisting of smooth cordgrass, black needlerush, bullrush, glasswort, and sea oxeye.
Based on surveys conducted by the North Carolina Coastal Federation (NCCF), SAV, primarily
eelgrass (Zostera marina) and shoalgrass (Halodule wrightii), is present within the project area,
surrounding area, and the proposed mitigation areas. The AIWW is approximately 450' from the
south side of the project shoreline. Although this site is not a designated nursery area, nearby
Goose and Sanders Creeks are both designated as Primary Nursery Area (PNA). No shellfish
beds were observed in the area, and an existing living shoreline and sills are present to the west
of the location.
The proposed public launch facility was permitted to construct an entrance road from NC Hwy
24 (Permit # SW-2019-02188). An associated 159-space boat trailer parking lot is proposed with
1.37 acres of impervious surface within the ORW AEC. A 1.54-acre upland basin would be
created to a final depth of -6.2' mean low water (MLW) plus an additional -1' of overdredge
allowance. The excavation of the boat basin would remove approximately 28,575 cubic yards
(CY) of earthen material. The upland basin would be excavated by leaving an earthen plug
between the excavation area and waters of Bogue Sound to avoid increases in sedimentation
increases and would be stabilized with riprap. The upland basin would contain 6 boat launch
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021

ramps measuring 253.5' long and 130' wide with three 60' by 8' floating piers between the
ramps. An ADA concrete walkway and aluminum gangway would lead to a 100' by 8' floating
dock located on the west side of the basin for loading and unloading. From the boat basin, the
excavation of a 450' by 50' by -5' access channel to the AIWW is proposed. The proposed
excavation would result in impacts to 0.78 acres of bottom habitat and generate approximately
4,625 CY of material. Excavation of the access channel would remove approximately 2,212
square feet (SF) of coastal wetlands and 0.78 acres of SAV and SAV habitat. The water depth of
the connecting waters range from -1' MLW to -10' MLW, depending on location. Excavation
would utilize mechanical means and all excavated material would be temporarily stored onsite.
For shoreline stabilization along the proposed boat launch area, 464' of Quickreef sill is
proposed. Sill lengths range 79' to 100' and would be 5' wide.
The applicant has submitted a mitigation plan for the impacts to coastal wetlands and SAV/SAV
habitat for the access channel. The primary mitigation site is located on a spoil island on the
south side of the AIWW approximately 3/4 of a mile to the east of the proposed project site. The
spoil island had historically been connected; however, a breach happened that now acts as a
navigable area for small boats and watercraft. The proposed mitigation plan would place
approximately 861' of riprap to create a sill and breakwater between two spoil islands. The base
of the sill/breakwater would range from 12' to 18' wide. On either side of the breakwater,
Quickreef sills are proposed — approximately 800' on the western island and 650' on the eastern
island. Directly to the south of the AIWW, a secondary mitigation location is proposed. This area
would consist of approximately 1,062' long by 5' wide Quickreef living shoreline along the
MLW/normal low water (NLW) with associated marsh planting landward of the sill.
The mitigation plan submitted as part of the project application includes in -kind mitigation to
specifically offset impacts to SAV. The in -kind proposal is intended to be part of a concentrated
effort by the North Carolina Coastal Federation (NCCF) and Carteret County to enhance and
restore SAV resources to waterways within the region due to sea level rise, storm -based erosion,
and boating impacts. The mitigation plan includes four in -kind mitigation methods, described
below.
Method 1 (Primary Mitigation Proposal): To mitigate for losses to SAV, the mitigation
plan proposes a nature -based solution to establish suitable environmental conditions for
seagrass growth over approximately 3.34 acres of subtidal area in Bogue Sound. The area
proposed for mitigation is a series of dredge spoil islands located to the south of the
project site. These spoil islands were originally constructed as part of the expansion and
maintenance of the AIWW.
2. Method 2: Living shoreline protection for 1,062 linear feet (LF) of sand bar island
directly across from the project area.
3. Method 3: Establishing a permanent water quality monitoring station and at least five
SAV monitoring stations in selected Bogue Sound locations. Monitoring stations would
be selected based on consultation with resource agencies.
4. Method 4: Living shoreline protection of the project area shoreline on either side of the
boat channel entrance.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

SAV is a critical habitat that provides numerous benefits to a variety of recreationally,
commercially, economically, and ecologically important species, such as finfish, shellfish, and
birds, by providing habitat for foraging and refuge. Important recreational species that use
seagrass in this region include bay scallops, bule crab, penaeid shrimp, hard clam, spotted sea
trout, red drum, and flounder. SAV can improve water quality, provide natural shoreline
protection and nutrient uptake, and sequester carbon dioxide. For these reasons, the protection of
SAV habitat is a key priority issue included in the 2021 North Carolina Coastal Habitat
Protection Plan (CHPP).
DMF has significant concerns with the proposed project. Specifically, DMF is concerned with
the loss of existing SAV and coastal wetland resources as a result of this proposal, as well as the
indirect impacts (i.e., impacts on species utilizing these resources, such as fish and birds). The
proposed project would result in the direct removal of SAV habitat during the proposed
excavation. Installation of the mitigation measures (i.e., living shoreline) is expected to result in
some additional impacts to SAV habitat as well. Construction during the project and proposed
mitigation may further impact SAV through increased turbidity and unexpected direct impacts
(i.e., from construction equipment). The applicant's narrative states that the proposed facility will
be the largest public boat facility in the state, with six ramps and 159 trailer spaces. The use of
this large boat ramp facility after construction, particularly if use is as high as the applicant
expects, will concentrate local vessel traffic around SAV and likely result in continued boating
related impacts to the habitat (prop scarring/dredging, wakes, etc.). This has been observed at
another WRC boat ramp in Pender County, despite additional signage and markings. If SAV
Although stormwater infiltration measures are included in the design, such as an infiltration
basin, pervious pavement, and living shoreline, contaminated runoff from the ramp area and
vessels is likely to result in oil, gas, and other pollutants entering Bogue Sound.
The proposed sill structures may help minimize impacts in those areas. However, the SAV along
neighboring properties, as well as those further down the shoreline, may face increased impact
due to increased boat traffic associated with the presence of the proposed launch. Public concern
with these issues is evidenced by the included letter from the neighboring property owner. In
their response to the notification they received, the homeowners raised concerns with the
potential increased traffic and noise. One specific issue raised in their response is their concern
with how increased boat traffic will impact their shoreline and what would be done to protect
their property from erosion. Their property does not appear to have shoreline protection, leaving
their shoreline exposed to erosion. The mitigation plan indicates that the County supports
creating a no -wake zone and is committed to discussing this with the U.S. Army Corps of
Engineers (USACE) and U.S. Coast Guard (USCG). Any no wake zones would help to minimize
impacts associated with boating at both the project site and possibly neighboring properties.
Therefore, the applicant should have discussions with those federal agencies prior and either
have agreed upon no wake zone plans that will be put into place, or the applicant should indicate
that those no wake zones will not be put into place. Without a decisive answer on this matter,
DMF cannot accurately assess potential impacts associated with this project.
As described above, the permit application also includes a mitigation plan that aims to address
impacts to SAV. DMF would like to note that the reported impacted acres are inconsistent
throughout the application. The project narrative indicates 0.78 acres of impacts to SAV (only
accounting for the channel), while the mitigation plan indicates 0.77 acres for the channel and
0.24 acres for the sill footprint for a total of 1.01 acres of impacts. The impact acreage estimate
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

does not account for or allow the ability to update acreage of impacts that may occur during/after
construction, such as those described above as well as the potential for scour in front of the
proposed sills/breakwaters. DMF would also note that in some places in the mitigation plan,
values were provided without units of measurement (i.e., square feet, acres, percentages, etc.).
Without including units of measurement, it is unclear what the values presented represent. The
uncertainty of what is being described makes it difficult to assess the mitigation plan accurately.
Placement of a sill between the two spoil islands to reduce wave energy appears to be an
innovative means of increasing natural SAV recruitment on the southern side of it. While this
would be an excellent experimental SAV restoration project by itself, the increased boat traffic
and SAV impacts on the northern side of the sound may offset any benefit.
The 7.2 ratio estimated from the restoration will be lower if there are additional SAV impacts
related to boater use or if the area does not become fully vegetated. Should a permit be issued for
this proposal, the applicant should ensure that the appropriate expected impact acreage is
included in the initial estimate and total impacts are accounted for after project completion. The
mitigation plan is also incomplete, as Method 3 indicates a proposal to coordinate with resource
agencies on sampling locations for SAV/water quality. Rather than a brief description of intent,
more details should be included, such as the sampling locations, monitoring specifics, and who
would be responsible for the monitoring.
The plan states that the mitigation site will be monitored twice annually for five years, and that
success will be assessed at the end of the five-year monitoring period. DMF recommends that
monitoring results be summarized and reported annually to appropriate agencies rather than
waiting five years to determine if the mitigation is a success. This would allow adaptive
management if necessary.
While the application does show a need for additional access for boaters and briefly describes the
site selection process and states that no reasonable alternative locations are available to meet the
purpose and need, there is no mention of alternative sites that were assessed. The application
states that the site was selected based on a lack of SAV resources per NCDEQ data layers.
However, those layers show SAV being recorded just off the shoreline in 1981 and along most of
the project site's shoreline as far back as 2006/2008 (Figures 1-4). These images show that SAV
has been naturally expanding along this shoreline and into the project area over time. To remove
SAV in the project area would negate some of the natural, unassisted expansion that this habitat
has achieved over the last 30+ years.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

Figure 1. NCDEQ SAV mapping layer from 1981. From the NC SAV Mosaic, 1981 to 2021,
filtered for map year equaling 1981. Maps found at http://www.arc_ig s.com.
Figure 2. NCDEQ SAV mapping layer from 2006/2008. From the NC SAV Mosaic, 1981 to
2021, filtered for map year equaling 2006/2008. Maps found at http://www.arc ig s.com.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

Figure 3. NCDEQ SAV mapping layer from 2013. From the NC SAV Mosaic, 1981 to 2021,
filtered for map year equaling 2013. Maps found at http://www.arcgis.com.
Figure 4. NCDEQ SAV mapping layer from 2020. From the NC SAV Mosaic, 1981 to 2021,
filtered for map year equaling 2020. Maps found at http://www.arc ig s.com.
Although mitigation is proposed, the proposed project seems counterintuitive. The mitigation
plan states that SAV resources in the region are being lost at "alarming rates due to sea level rise,
storm -based erosion, and boating (wake and prop scar) impacts." In that quote, the application
specifically states that boating -related impacts are contributing to the decline of SAV in the area,
yet the project proposes to directly remove SAV and construct a project that will place "the
largest public boat launch facility in the State" in an area where SAV has been consistently
present and naturally expanding along the shoreline. Based on the above discussion, DMF
recommends that the permit application be denied due to the potential significant adverse
impacts to critical habitat and the species that utilize those habitats.
Thank you for consideration of our comments and concerns. Please contact Jimmy Harrison at
[phone] or at james.harrisonAdeq.nc.gov with any further questions or concerns.
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021