20230797 Ver 1_More Info Requested_20230803

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
RICHARD E. ROGERS, JR.
Director
NORTH CAROLINA
Environmental Quality
August 3, 2023
DWR Project #20230797
Carteret County
ELECTRONIC COPY
Carteret County
ATTN: Eugene Foxworth
210 Turner Street
Beaufort, NC 28516
Subject Property:
241 Morada Bay Drive - Newport - Bogue Sound
Western Carteret County Boat Ramp
REQUEST FOR MORE INFORMATION
Dear. Mr. Foxworth,
On June 5, 2023, the Division of Water Resources (DWR) received your CAMA major development
permit application and associated documents to allow for impacts associated with the construction
of a public boat launch facility including entrance channel and high ground basin excavation,
associated ramp access, shoreline stabilization and upland amenities adjacent to Bogue Sound
Outstanding Resource Waters Area (SA;ORW). The application also included a primary seagrass
mitigation proposal. The Division of Water Resources (DWR) has additional questions regarding the
proposed development and has determined that additional information will be necessary to
complete the review of your permit application. The application is on hold until all of the
following information has been received by our office.
Additional Information Requested:
Mr. James Harrison Fisheries Resource Specialist with the Division of Marine Fisheries (DMF) sent a
memorandum on July 28, 2023, outlining significant concerns the proposed boat ramp construction
would have on fisheries resources. Specifically, the concerns are related to the direct loss of SAV and
coastal wetlands resources, as well as indirect and cumulative impacts associated with the
construction and use of the facility as proposed. DMF memorandum is attached for reference.
Similarly, Mrs. Maria Dunn, Coastal Coordinator for the North Carolina Wildlife Resource Commission
(WRC), through interagency discussions, has expressed significant concerns regarding impacts
associated with development of the boat launch facility. At the time of this letter no formal comments
from WRC have been received.
North Carolina Department of Environmental Quality I Division of Water Resources
4NORT�HCv 127 Cardinal Drive Ext. Willmington, North Carolina 28i405-5406
NORTHCAROUNA 910.796.7215
Department ofEnvlronmantal Duali�

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
West Carteret County Boat Launch
DWR Project #20230797
Page 2 of 5
DWR Modeling and Assessment branch staff reviewed the memorandum subject: Flushing Analysis
for the Western Carteret County Boat Launch Project and are seeking additional information on the
TOPEX/POSEIDON global tidal model utilized. Branch staff are unfamiliar with the MIKE21
model. Models must be publicly available for replication by DWR staff, and all data used to populate
models must be included. Please submit a modeling plan to DWR for approval.
DWR has concerns regarding inconsistent calculations for wetland and aquatic resource impacts
within the application materials. The values for impacts on the DCM application are inconsistent
with the impacts described in the narrative and mitigation plan. The DCM major permit application
documents are inconsistent with the development impacts described in the narrative. For example,
the application lacks information in the shoreline stabilization section describing how the upland
basin shoreline will be stabilized once excavated. The submitted plan drawings show rip rap
shoreline stabilization along the perimeter of the upland basin. The DCM major permit application
documents are also inconsistent with the wetland and SAV impacts described in the narrative. The
narrative and application materials should be revised to clearly indicate all of the aspects of the
project and individual design elements. The mitigation area described in the application as to
`establish suitable environmental conditions for seagrass growth over approximately 3.34 acres of
subtidal area in the Sound' should be clearly identified. The area to be evaluated and monitored
post -construction should be clearly defined within the application.
DWR has significant concerns regarding the proposed location of the Quickreef revetement landward
of the existing and mapped SAV along the shoreline of the mainland project area as well as the
mitigation site. Those concerns are specific to the Quickreef revetment providing protection for the
proposed marsh planting on the landward side of the revetment, while also creating a potentially
erosive condition from wave action on the waterward side of the revetment resulting in secondary
impacts to SAV. As proposed, several sections of the Quickreef are located within 5-10 feet of existing
SAV.
Based on the boat registration information contained in the narrative and maximum length of vessels
capable of being transported on NC DOT roadways, it is reasonable to assume the draft of the boats
will be limited to less than 4 feet. Please justify the need for a final project depth of -7.2 feet based
on the need to provide launching for vessels limited in length by NCDOT (max. 60 feet truck and
trailer combined) and supported by the 60 feet long proposed parking spaces and documented
application materials listing average boat length to be 24 feet.
Further investigation into the infilling rates for channels similarly aligned perpendicular to the
AIWW should be conducted. DWR has concerns that increased infilling rates would result in frequent
maintenance excavation events to maintain access. If the infilling occurs from slough or sediment
transport in the nearshore environments, additional SAV and habitat losses can be expected based
that based on frequency and duration excavation events.
Water quality within Outstanding Resource Waters of Bogue Sound is `rated as excellent based on
physical, chemical and biological information.' Consideration should be given to implementing
additional stormwater control measures to prevent sediment and pollutant run-off into the waters
of the upland basin. It is unclear from the provided plan if the infiltration basin labeled E4 will be
utilized to divert and treat pollutant run-off at the top of the ramp.
D E Q �J North Carolina Department of Environmental Quality I Division of Water Resources
127 Cardinal Drive Ext. WiQmington, North Carolina 28405-5406
NORrH CAROLINA �/ 910.796.7215
oepanmem or environmental auaii

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
West Carteret County Boat Launch
DWR Project #20230797
Page 3 of 5
MITIGATION PLAN:
The mitigation plan states SAV loss can be attributed to "boating (wake and prop scar) impacts" yet
the project as designed would increase "boating' by constructing "the largest boat launch facility in
the State" within an area of Bogue Sound where SAV has been consistently identified and increasing
in abundance. Although mitigation has been proposed, construction of the boat launch facility would
likely subvert SAV growth and establishment in the Outstanding Resource Waters of Bogue Sound.
Therefore, it is necessary that the mitigation plan be developed that has measurable goals for success,
a financial commitment to ensure continued success, a long range (5-year) implementation and
monitoring plan, as well as a remedial action (restoration) plan should the project fail to meet the
success criteria metrics.
Additional information should be provided regarding implementation monitoring to evaluate the
extent to which the mature site mirrors the planned design. Below are some suggested protocols:
1) preparation of an as -built survey of the entire project area after construction to verify
your planned target elevations and to provide a baseline against which to measure future
changes during the requested 5-year monitoring period. This is supported by the
mitigation plan that states the mitigation meadow.
2) A random stratified design should be used to determine the placement of individual
sampling plots along each transect.
3) Plots should be visited and evaluated twice annually during the period of peak biomass
recommended by DMF for species composition and precent cover.
4) Success Criteria must be established for the project design. Specifically, metrics for
success should be established, such as percent cover, mortality, etc.
5) Remediation and/or Restoration information should be provided should the project fail
to meet the success criteria and/or result in significant adverse impacts to resources.
6) The financially responsible party committed to post -construction monitoring, mitigation
success and restoration or remediation of potential inadvertent impacts must be clearly
identified.
There exists a significant potential for this type of experimental mitigation as well as other projects
proposed in the area to result in secondary impacts to the mitigation and shorelines adjacent to the
ramp that cannot be properly evaluated at this time. Specifically, residents of the Town of Emerald
Isle have claimed shoreline losses because of the increased boat traffic adjacent to their shorelines
since the current largest boat launch facility was constructed near their homes. The Town of
Emerald Isle has been investigating alternate channel locations from the ramp across Bogue Sound
to the AIWW in response to those residents' concerns. Additionally, as previously mentioned, while
the Quickreef may provide protection on the landward side for SAV recruitment and establishment,
it may create scour on the waterward side that results in additional losses of SAV along the AIWW.
The DWR is required to evaluate projects to ensure that impacts to surface waters and wetlands
have been avoided and minimized and to ensure that any remaining surface waters or wetlands and
any surface waters downstream, continue to support existing uses during and after project
completion in accordance with 15A NCAC 02H .0506 (b)(1). As proposed, DWR has significant
concerns that the direct, indirect, and cumulative impacts associated with the construction of boat
launch facility including, but not limited to, coastal wetland excavation, entrance channel
excavation including SAV, upland basin excavation and use of the facility would have negative
impacts on existing aquatic resources and to the downstream surface waters resulting in a violation
of the following Water Quality Standards:
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
127 Cardinal Drive Ext. WiUmington, North Carolina 28405-5406
NORTH CAROLINA 910.796.7215
Depanmem of Envlmnmenml Dual

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
West Carteret County Boat Launch
DWR Project #20230797
Page 4 of 5
15A NCAC 02B .0201 ANTIDEGREDATION POLICY
(f) Activities regulated under Section 404 of the Clean Water Act (33 U.S.C.1344) which require
a water quality certification as described in Section 401 of the Clean Water Act (33 U.S.C.
1341) shall be evaluated according to the procedures outlined in 15A NCAC 2H .0500.
Activities which receive a water quality certification pursuant to these procedures shall not
be considered to remove existing uses. The evaluation of permits issued pursuant to G.S.
143-215.1 that involve the assimilation of wastewater or stormwater by wetlands shall
incorporate the criteria found in 15A NCAC 2H .0506(c) (1)-(5) in determining the
potential impact of the proposed activity on the existing uses of the wetland per 15A NCAC
2H.0231.
15A NCAC 02B .0221 TIDAL SALT WATER QUALITY STANDARDS FOR CLASS SA WATERS
(1) Best Usage of Waters: shellfish ingfor market purposes and any other usage specified by the
"SB" or "SC" classification;
(2) Conditions Related to Best Usage: waters shall meet the current sanitary and bacteriological
standards as adopted by the Commission for Public Health and shall be suitable forshellfish
culture. Any source of water pollution which precludes any of these uses, including their
functioning as PNAs, on either a short-term or a long-term basis shall be considered to be
violating a water quality standard,
15A NCAC 02B .0225 OUTSTANDING RESOURCE WATERS
(2) Saltwater: Water quality conditions shall be maintained to protect the outstanding resource
values of waters classified ORW. Management strategies to protect resource values shall
be developed on a site -specific basis during the proceedings to classify waters as ORW. New
development shall comply with the stormwater provisions as specified in 15A NCAC
02H .1000. Specific stormwater management requirements for saltwater ORWs are
described in 15A NCAC 02H .1007. New non -discharge permits shall meet reduced loading
rates and increased buffer zones, to be determined on a case -by -case basis. No dredge or
fill activities shall be allowed if those activities would result in a reduction of the beds of
submerged aquatic vegetation or a reduction of shellfish producing habitat as defined in
1SA NCAC 031 .0101(b)(20)(A) and (B), except for maintenance dredging, such as that
required to maintain access to existing channels and facilities located within the
designated areas or maintenance dredging for activities such as agriculture. A public
hearing is mandatory for any proposed permits to discharge to waters classified as ORW.
The DMF memorandum recommends changes to the design and alternatives analysis of the project
to support the purpose and need for the impacts associated with the development of a boat launch
facility at this site. Please be advised DWR shares the concerns expressed in the DMF memo and to
prevent redundancy will not reiterate those concerns in this letter, but instead has attached the
memo to this letter in support of those recommendations and requests. Please revise your
application in accordance with the recommendations of the resource agencies. If the concerns of the
resource agencies are not resolved the DWR will move to deny your application as required by 15A
NCAC 21-1.0506.
Pursuant to Title 15A NCAC 02H .0502(e) the applicant shall furnish all the above requested
information for the proper consideration of the application. If all the requested information is not
received in writing within 30 calendar days of receipt of this letter, the DWR will be unable to approve
the application and it will be returned. The return of this project will necessitate reapplication to the
DWR for approval, including a complete application package and the appropriate fee.
D E Q �J North Carolina Department of Environmental Quality I Division of Water Resources
127 Cardinal Drive Ext. WiQmington, North Carolina 28405-5406
NORrH CAROLINA �/ 910.796.7215
oepanmem or environmental auaii

West Carteret County Boat Launch
DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73 DWR Project #20230797
Page 5 of 5
Please respond in writing within 30 calendar days of receipt of this letter by sending three (3) copies
of all of the above requested information to the 401 & Buffer Permitting Unit, 1617 Mail Service
Center, Raleigh, NC 27699-1617.
Please contact Holley Snider at 910-796-7303 or [e-mail] or myself at 910-796-
7218 or morella.sanchez-kingOncdenr.gov if you have any questions or concerns.
Sincerely,
EDocuSigned by:
� 5�,�, 6,
8554BOF62DED464.-
Morella Sanchez -King, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ
Enclosures: DMF Memorandum dated July 28, 2023
CC: Stephanie Goss, DWR, Raleigh -EC
Greg Bodnar, DCM Morehead City Office -EC
Heather Styron, DCM Morehead City Office -EC
Sarah Hair, USACE Wilmington Regulatory Field Office -EC
Maria Dunn, WRC-EC
Todd Bowers, EPA Region 4
Doug Huggett, Consultant -EC
DWR 401 & Buffer Permitting Branch file - LF
WiRO
D E Q�� North Carolina Department of Environmental Quality I Division of Water Resources
127 Cardinal Drive Ext. WiUmington, North Carolina 28405-5406
NORTH CAROLINA 910.796.7215
Depanmem of Envlmnmenml Dual

DocuSign Envelope ID: 717F1084-806E-407D-959E-71CD914BCF73
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: 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 Arendel[ Street I P.O. Box 769 I Morehead City, North Carolina 28557
252-726-7021

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
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

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
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

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
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

DocuSign Envelope ID: 717F1084-806B-407D-959E-71CD914BCF73
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':////www.arc ice.
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 atw'-///`/www.arcgis.co
www.arcgis.com/
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 1 Morehead City, North Carolina 28557
252-726-7021

DocuSign Envelope ID: 717F1084-806E-407D-959E-71CD914BCF73
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 ".////www.arc ig sue.
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":////www.arc.ig s.com.
www.arcgis.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 at9A4P1WHRWJWQTj§4i with any further questions or concerns.
eq.nc.gov
State of North Carolina I Division of Marine Fisheries
3441 Arendel[ Street I P.O. Box 769 1 Morehead City, North Carolina 28557
252-726-7021