20230797 Ver 1_DMF Comments_20230728

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
KATHY B. PAWLS
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: 28 July 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 (Sporobolus alterniflorus), black needlerush (Juncus
roemerianus), bullrush (Scirpoides holoschoenus), glasswort (Salicornia euroaea), and sea ox-
eye (Borrichia frutescens). 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 Arendel[ Street I P.O. Box 769 I 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 habitat. The water depth of the
connecting waters range from -1' MLW to -10' MLW, depending on location. A 450' x 50'
access channel would extend to the ICW. 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
habitat for the access channel, with four components. In -kind mitigation is proposed to offset
impacts to SAV and wetlands. 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 and wetlands to waterways within the region due to sea level rise, storm -based erosion, and
boating impacts.
1. The primary mitigation is constructing a breakwater to reduce wave energy to
enhance SAV habitat at 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
allows shallow draft watercraft to pass through. The proposed mitigation plan
would place approximately 861' of riprap to create a sill and breakwater between
two spoil islands, where water depths range from 1 to 5' MLW. The base of the
sill/ breakwater would range from 12' to 18' wide. On either side of the
breakwater, QuickReef revetment is proposed — approximately 800' on the western
island and 650' on the eastern island, and five feet wide.
2. Directly south of the AIWW and proposed ramp and west of the breakwater, living
shoreline protection using 1,062 linear feet (LF) of QuickReef revetment would be
placed along the west end of the spoil island at MLW/normal low water (NLW)
with associated marsh planting landward of the sill.
3. A permanent water quality monitoring station and at least five SAV monitoring stations
would be established in selected Bogue Sound locations. Monitoring stations would be
selected based on consultation with resource agencies.
4. On both sides of the boat basin entrance, living shoreline protection of the project area
shoreline would be installed with five sections of QuickReef revetment totaling 464'.
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, blue 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). Salt marsh is also a critical nursery and foraging grounds for the
majority of North Carolina's estuarine dependent fishery species, including spot, croaker, blue
crab, and penaeid shrimp. Fringing marsh provides a shallow protective corridor for fish
migration through the system. Fish abundance and diversity is greater in SAV and salt marsh than
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

sand bottom (NCDEQ 2016).
DMF has significant concerns with the direct loss of existing SAV and coastal wetland resources
from this project, as well as the indirect and cumulative impacts (i.e., prop scarring of SAV, erosion
of marsh, and impacts on fish species utilizing these resources). 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. There is also a large existing public boat ramp in
Emerald Isle on the opposite site of Bogue Sound. The town is currently planning an alternate
dredged channel that would result in additional SAV impacts. Assessment of cumulative impacts
from both ramps is needed. Based on what has been provided, DMF requests additional information
to fully assess the proposal's potential impacts to resources of concern for DMF. The concerns and
additional information needed are detailed below, along with descriptions of potential measures to
address DMF's concerns.
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.
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. Considering the
proposed user capacity, changes to the facility design could be included to minimize impacts.
This includes lowering the trailer capacity to reduce boating related impact and modifying the
ramp design to trap sediment and runoff at the top of the ramp. DMF requests additional
information regarding the potential for incorporation of these measures into the design and the
need for these to be included in the design. If these measures are not included, the application
should provide an explanation of why minimization measures for addressing sediment and
pollutant runoff from the ramp are not included.
The project proposes the boat basin water depth to be -6.2' (-7.2' including the proposed 1' of
"allowable overdredge") and the access channel -5' extending to the waterway. Although the final
boat basin design meets the flushing requirements per the consultant's flushing analysis, the
proposed depth will still degrade water quality and circulation within the basin and water quality
in the adjacent ORW waters of Bogue Sound. The proposed depth is also deeper than needed for
navigation in the surrounding shallow estuarine waters. Insufficient information regarding the
selected depth was provided. The application materials reference the number of vessels from 16'
to 35' long registered in Carteret, Craven, Jones, and Pitt Counties. A simple online search
indicates that vessels under 35' in length typically only require 3' of depth. Therefore,
justification for the requested depth should be provided or the proposed depth reduced. Reducing
the depth and width of the entrance channel could reduce direct impacts to SAV and should be
considered. An assessment of the impacts associated with varying entrance widths could help to
show minimization of impacts to SAV, should it be found that a particular width is least
negatively impactful.
The proposed sill structures may help minimize impacts in the areas they've been proposed.
However, the SAV along and wetland shorelines of neighboring properties - as well as those
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

further from the project area - may face increased and/or persistent impacts due to additional 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 the 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 application and mitigation plan provides insufficient information regarding measures to be
included to minimize impacts to surrounding properties other than those immediately adjacent to
the proposed ramp.
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. However, specifics and confirmations were not
provided in the application to allow adequate review. Therefore, the applicant should have
discussions with those federal agencies prior to permit approval 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 and coastal wetlands. 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 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 a sound
method 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 and that the ratio be increased to
account for cumulative boating related impacts and uncertainty. 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.
An extensive amount of living shoreline using QuickReef revetment is proposed on the two spoil
islands as mitigation to protect existing marsh and the integrity of the spoil island — the northwest
sill would be 1,0621f, and the two sills adjoining the breakwater are 1,405 if total. In some areas,
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

however, existing SAV occurs in close proximity to the sill. Increased wave attenuation from the
revetment structure could result in additional SAV loss. Insufficient information was provided in
order to adequately and accurately assess these impacts, and any potential impacts from these
structures to the SAV in the surrounding area. To minimize potential impacts, DMF recommends
that the living shoreline be reduced in linear footage where least necessary and maintain a
minimum buffer of 20' from existing SAV and/or SAV that has been documented during the
previous 10 growing seasons.
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 measures are working. This would allow
adaptive modification to the mitigation plan 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 justification
provided is also insufficient. The applicant provided boat launch user data for one day out of one
year, which is an insufficient sample size, particularly considering the potential impacts associated
with this proposal. The data provided shows a need on that particular day but does not show that
there is a consistent need for additional launch facilities.
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. Additional information should be provided
that sheds light on how the "no reasonable alternative" conclusion was made. Additionally, it was
noted that WRC was approached to be a partner in this project in 2017 but decided against due to
resource (impacts to existing SAV) concerns. Additional information should be provided
describing why this site was selected after a potential resource agency partner determined that
potential resource impacts were too great to proceed.
State of North Carolina I Division of Marine Fisheries
3441 Arendell 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.aregis.com.
State of North Carolina I Division of Marine Fisheries
3441 Arendell 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 hqp://www.arc ig s.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 offered, the proposed project would undermine SAV gains in this area.
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. This project would be inconsistent with the
NCDEQ's 2021 CHPP that calls for protecting existing SAV and restoring habitat coverage to a
coastwide goal of 191,000 acres. Furthermore, there is no proposed remediation should it be
found that the proposed minimization/mitigation measures are ineffective or unsuccessful, or if
impacts exceed expectations.
Based on the above discussion, DMF requests that the permit application be placed on hold until
all applicable information has been received by the resource agencies. Should the application
proceed as -is without the requested additional information, DMF would recommend denial of the
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28551
252-726-7021

permit due to the significant impacts associated with the proposal. The instances of insufficient
information being provided are detailed above. Also, a number of ways to minimize concerns for
DMF have been provided throughout this memo. The additional information needed is
summarized below.
• Include runoff/pollutant avoidance/minimization measures for the ramp or provide
justification as to why that won't be included in the design.
• Additional details regarding the necessity for the proposed boat basin depth and an
analysis of the impacts that this deeper water could have on the surrounding area.
• An assessment of the potential impacts associated with varying basin entrance widths.
• Measures to address impacts to neighboring/surrounding properties that do not currently
have shoreline protection and are not included in the protection in this application.
• A definitive answer and proposed location of any No Wake Zones to be included.
• Address the inconsistencies with impact values and the lack of units of measurement.
• Additional information to justify the large width and height of the proposed breakwater
for mitigation.
• Additional details regarding the proposed monitoring (i.e., locations ofsites, specifics of
monitoring, success criteria, who will undertake these efforts, etc).
• An assessment of potential impacts to SA associated with the placement of QuickReef
material.
• Additional information regarding how the "No Reasonable Alternative" conclusion was
made.
• Additional information regarding the site selection, considering this site was known to
have significant SA in 2017.
• Additional boat launch user data to support the purpose and need of this facility.
• Provide remediation plan to be imposed should the project result in greater impacts than
expected or if the mitigation measures are unsuccessful.
• Assessment of cumulative impacts on sensitive environments and species associated with
this proposal and the proposed alternative channel route for the WRC Emerald Isle ramp.
Cumulative impacts would include, but are not limited to, impacts associated with
continued daily use of the ramp and channel, construction -related impacts, and any
efforts to minimize these impacts).
Thank you for consideration of our comments and concerns. Please contact Jimmy Harrison at
[phone] or at james.harrison&deq.nc.gov with any further questions or concerns.
State of North Carolina I Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021