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HomeMy WebLinkAbout20230797 Ver 1_Other Agency Correspondence_20230814Ero- August 11, 2023 Ms. Liz Hair Wilmington Regulatory Field Office 69 Darlington Avenue, Wilmington, North Carolina 28403 North Carolina Coastal Federation Working Together for a Healthy Coast Sent via email: sarah.e.hair@usace.army.mil. Dear Ms. Hair, The North Carolina Coastal Federation respectfully submits the following comments regarding the Carteret County permit application for the construction of a boat ramp on Bogue Sound by Carteret County within the Ocean community. Since approximately 2018, the Federation has been collaborating with the county to develop an environmentally responsible project on this land. The proposed boat ramp area, which was originally designated as Phase IV of the Morada Bay subdivision, had plans for around 65 houses along the waterfront area of this property. The remaining acreage on the property inland of the proposed ramp, which is also now under county ownership, was destined for future development, potentially comprising significant additional residential development and a commercial zone along Highway 24. Thanks to $7.4 million in funding from various public and private sources, including the North Carolina General Assembly, N.C. Land and Water Fund, the Navy, and N.C. Parks and Recreation Trust Fund, the county was able to acquire the property and dedicate the entire 66-acres for public "recreation uses." Notably, over 24-acres of the 66-acre parcel have already been placed under perpetual conservation easements, including a two -acre permanent easement along the forested Bogue Sound waterfront —preventing the development of waterfront homes with docks. As part of this land acquisition, the Federation independently procured 10-adjacent acres for its new headquarters and a public event center, a venture that is independent yet complementary to the county's boat ramp proposal. Our project adheres to distinct criteria, involving no new water -based development and positioned at a considerable distance from mean high water, resting on sandy soils devoid of wetlands. It's important to mention that a segment of our Northeast Regional Office Headquarters & Central Regional Office Southeast Regional Office 637 Harbor Road, P.O. Box 276 3609 N.C. 24 • Newport, NC 28570 309 W. Salisbury Street Wanchese, NC 27981 252-393-8185 Wrightsville Beach, NC 28480 252-473-1607 www.nccoast.org 910-509-2838 00 North Carolina Coastal Federation project falls within the 575-foot Outstanding Resource Waters Area of Environmental Concern under the Coastal Area Management Act (CAMA). Additional context and background further inform the Federation's comments. Having lived within proximity of the proposed boat ramp site for over 65 years, I have closely monitored the status of fishery habitats and water quality in the adjoining waters of Bogue Sound. Owing to the Intracoastal Waterway and the substantial boat traffic it attracts, water quality and submerged aquatic vegetation (SAV) resources along the mainland shoreline here have notably deteriorated over the past few decades. Some agencies seem to be under the mistaken impression that SAV and water quality are improving at this location — I can testify from six decades of close observations that these resources are becoming significantly more degraded over time. Having also assisted with the SAV survey submitted with the application, I can attest that the SAV in this area is patchy at best, not the lush meadow the screen grabs from the SAV map makes it out to be. SAV exists in the green areas of the survey, but it is not a consistent coverage. Larger boats causing significant ocean -size waves contribute significantly to shoreline erosion and degradation of SAV resources, while smaller trailer -sized boats have comparatively less impact. Recollections from my youth highlight dense seagrass meadows that once adorned the mainland shoreline, now conspicuously absent. The patchy SAV resources now present are just a skeleton of the lush SAV meadows that used to stretch along the entire mainland shoreline in this area. Bottom sediments in the vicinity have turned from a denser and firm footing (such as still exists in Bogue Sound south of the spoil islands away from the federal channel) that existed in my childhood, to now a mucky and silty texture. The shoreline erosion and loss of salt marshes have only exacerbated the degradation of SAV resources as sediments and silt from this erosion moves offshore. Whenever large boats speed by this location, their tremendous wakes stir up all this muck and sediment and cause high turbidity levels that undoubtedly violate state water quality standards. This perpetually muddy water during the active boating season is concentrated between the spoil islands and mainland shoreline and contributes to SAV declines. This area's distinctive features include dredge spoil islands lining the southern side of the Intracoastal Waterway. These islands previously had much higher elevations that supported trees and provided rich bird habitat. In the past few decades, they have witnessed dramatic subsidence and erosion especially since their creation in the 1930s. Their erosion has transformed them into intertidal salt marshes that are still rapidly declining in elevation and extent. The Federation and county have collaborated with Dr. Jud Kenworthy, a nationally and international respected SAV expert retired from NOAA. He helped us recognize the critical role these artificially formed islands play in buffering SAV and maintaining water quality against the impacts of boat traffic in the federally maintained channel. Though seemingly counterintuitive, a comprehensive examination spanning over five years has led me to conclude that the boat ramp project can yield environmental benefits. Opting against the project does not arrest the rapid decline in SAV resources and water quality in this location. North Carolina Coastal Federation While taking "no action" avoids immediate project impacts, it fails to instigate a comprehensive strategy to address fundamental environmental concerns. Rejecting this project would frustrate county government, state legislators, and other backers who have proposed and funded this initiative in the public interest. The county's proactive mitigation strategy signifies its dedication to tackling existing water quality and SAV challenges. This presents an opportunity for environmental agencies, the public, and local, state, and federal entities to collaboratively address these environmental issues proactively. The conservation efforts integral to the project have already contributed a measure of environmental protection that residential and commercial development on this property would not have achieved. Over 24-acres have been permanently conserved, and additional unutilized land for the boat ramp could further augment these conservation areas, providing valuable open space for public recreation. The county has also already supported the installation of a living shoreline along the waterfront protected by the conservation easement, and this project has reduced sedimentation and turbidity caused by erosion. Preservation of the maritime forest along the waterfront prevents its transformation into cleared homesites, each with docks. Distinguishing this boat ramp from others is its ample undeveloped acreage, which serves as a buffer to the facility. Significantly, the facility's construction site boasts permeable soils, promoting natural stormwater infiltration. Due to the natural slope of the land, runoff from most of the parking areas will drain away from the sound, spreading and infiltrating it into wooded and protected conservation zones. Consequently, most stormwater runoff generated by the facility can infiltrate, meandering laterally through groundwater into forested lands before reaching Sikes Creek's headwaters hundreds of yards north of the parking areas. This creek drains eastward for approximately a mile before flowing into the estuarine waters behind the Cannons Gate subdivision. The proposed stormwater system adheres to ORW rules and remains open to further agency recommendations for enhancement. Additionally, the parking lot design has incorporated nature -based solutions to its fullest extent, with significant investment being made in pervious pavement to reduce runoff volumes. Because of the nature of this land and the amount of undeveloped acreage surrounding it, the boat ramp should not contribute polluting runoff to Bogue Sound. Given the cumulative impact of boat traffic on SAV and water quality in Bogue Sound, concerns about this project should extend to considering the larger picture. Addressing cumulative impacts necessitates a comprehensive approach, transcending singular permit decisions. This project presents an opportunity to engage in a more holistic manner, a practical reality since cumulative impacts apply to public and private boat docks, marinas, waterfront homes with docks, and similar installations. Contrarily, denying this ramp based on cumulative impact apprehensions would suggest the need to halt and deny all additional future projects introducing more boat traffic to Bogue Sound. It's a fact that the cumulative impact of existing residential and commercial boat docks greatly exceeds the boat traffic in the sound that this publicly owned facility will facilitate. Moreover, the rarity of a $10+ million public investment by the government to create a public boat ramp with substantial surrounding natural area to North Carolina Coastal Federation buffer its impacts assures this scenario remains uncommon, while setting a positive precedent if ever repeated. While the mitigation strategy strives to counterbalance unavoidable environmental effects of the ramp, it alone won't suffice to reverse the existing declining water quality and SAV resources along Bogue Sound's mainland side. A more extensive endeavor is required to safeguard the dredge spoil islands and alleviate the rapid erosion of the mainland shoreline, an effort the county supports. This endorsement is evident in its support of the Federation's restoration endeavors, unrelated to this project. The Federation has worked with the county's design team to minimize impacts to coastal wetlands by moving the preferred basin/channel location to a portion of the shoreline where most of the salt marsh has eroded away in recent years. In addition, the county has agreed to install living shorelines along the full extent of its shoreline, and we have worked to design that component of the project with its engineers. Furthermore, to further reduce shoreline erosion that causes lack of water clarity and smothers SAV (erosion that is already occurring), the Federation has prioritized to work with mainland waterfront property owners within a mile of the project site for the use of funds appropriated by the N.C. General Assembly to cost -share living shorelines, and is also spending part of those appropriations to install living shorelines along the spoil islands in work that is not part of the mitigation proposal. As recommended by the N.C. Division of Marine Fisheries, the Federation encourages exploring the use of a "No Wake" zone around this project area to eliminate many anticipated project impacts. This no wake restriction should apply not only to the proposed new access channel for the ramp, but also to a portion of the Intracoastal Waterway (at least between Marker 33 and 34). Eliminating the big wakes that are now generated by large speeding boats in the vicinity of the ramp would be huge opportunity to completely offset and eliminate many of the existing and future concerns about shoreline erosion, damage to SAV, and degraded water quality that can be attributed to existing concentrated boat traffic in this location. This action is probably also warranted for safety reasons as well. Just as we have speed limits elsewhere in the nation on federal navigation channels to protect manatees, imposing this safeguard at this location would eliminate a long-standing and persistent cause of environmental declines of essential fish habitats along this shoreline. Finally, it is important to keep in mind that this is a public project funded by taxpayers to provide access to the state's public trust waters for those not fortunate enough to own waterfront property. It will serve millions of people in the coming decades. The project is in the public interest and should be evaluated to include those benefits that aren't typically a result of privately owned development projects. In conclusion, the county's application signifies a well-intentioned endeavor uniting various stakeholders to proactively address the adverse environmental trends in Bogue Sound. Such initiatives could ignite further partnerships and forward -thinking actions, surpassing mere reactions to individual development proposals. The scrutiny of agencies can improve the North Carolina Coastal Federation project by infusing fresh perspectives and fostering a collaborative process, ultimately enhancing this exceptional project in the public's interest. Critique or opposition alone will not secure Bogue Sound's long-term preservation; it will instead expedite its decline. Best regards, r Todd Miller Executive Director Attachments: A. 1939 photo of project site to show dramatic changes in spoil islands B. 1983 photo of project site to show dramatic changes in spoil islands C. 2020 photo of project site to show dramatic changes in spoil islands cc: NC DCM NC DWR NC DMF NC WRC USFWS NOAA EPA North Carolina Coastal Federation Attachment A: 1939 Photo — Note size of spoil islands and tree cover NQUiRY # 5906545.5 YEAR: 19s9 .; r IN Q North Carolina Coastal Federation Attachment B: 1983 Photo — Note Changes North Carolina Coastal Federation ns Attachment Q ZOZO Photo — Island R about to be breeched across from project site cr At— y �.