20230797 Ver 1_WRC Comments_20231117

North Carolina Wildlife Resources Commission
Cameron Ingram, Executive Director
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TO: Division of Water Resources
North Carolina Department of Environmental Quality
FROM: Maria T. Dunn, Coastal Coordinator
Habitat Conservation Division
DATE: November 17, 2023
SUBJECT: West Carteret Boat Ramp Proposal and Mitigation Plan, Carteret County,
North Carolina.
Biologists with the North Carolina Wildlife Resources Commission (NCWRC) reviewed the permit
application with regard to impacts on fish and wildlife resources. The project site is located at 241
Morada Bay Drive in Newport, NC adjacent to Bogue Sound. Our comments are provided in accordance
with provisions of the Coastal Area Management Act (G.S. 113A-100 through 113A-128), as amended,
Sections 401 and 404 of the Clean Water Act, as amended, the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531 et seq.), the Fish and Wildlife Coordination Act (48 Stat. 401, as amended; 16
U.S.C. 661 et seq.), the Magnuson -Stevens Fishery Conservation and Management Act (FCMA), as
amended (16 U.S.C. 1801 et seq.), and the Migratory Bird Treaty Act (16 U.S.C. 703-712 et seq.).
Carteret County has proposed to construct a public boating access area on an undeveloped lot between
NC Hwy 24 and Bogue Sound. The 159-spaced parking area would lead to a 1.54 acre excavated upland
basin with six launch ramps and three floating piers. A 50' by 450' by -5' access channel from the basin
into the sound and AIWW would be dredged, impacting 0.78-acre of submerged aquatic vegetation
(SAV). Coastal wetlands run parallel to the shoreline and would also be impacted by the basin and
channel dredging, shoreline stabilization, and overall use of the area as a public boating facility. Proposed
water depths are stated to be -6.2' MLW with +1' overdredge. To address impacts to SAV, coastal
wetlands and shallow water habitats, the applicant has presented a mitigation plan. This plan includes the
incorporation of 861' riprap sill and a breakwater between two islands, ranging in base width from 12' to
18'. On either side of the breakwater, Quickreef sills are proposed — approximately 800' on the western
island and 650' on the eastern island. The intention of this area is to propagate SAV and coastal wetland
development. Additional mitigation includes a 1062' by 5' Quickreef living shoreline along the
MLW/NWL end of the western island with associated coastal wetland planting on the landward side of
Mailing Address: Habitat Conservation • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] • Fax: [phone]

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the sill. Bogue Sound at this location is classified SA ORW by the Environmental Management
Commission and is open to shellfish harvesting.
The NCWRC has reviewed the permit application as well as the mitigation plan. Numerous scoping
meetings and discussions have occurred stating concerns with the proposal and the magnitude of impacts
to SAV, coastal wetlands, and shallow water habitats. The development of a boat ramp in this area had
been previously avoided due to such impacts. As stated during the meetings and other conversations for
this as well as other projects, avoidance and minimization of impacts to resources should be a primary
objective — especially for SAV and coastal wetlands. Avoidance and minimization of impacts to SAV,
coastal wetlands, shallow water habitats and overall Essential Fish Habitat (EFH) has been requested by
several state and federal agencies. These measures include exploration of an alternative site, reduction in
facility size, reduction in water depths (both basin and access channel), moratoria, and shoreline
stabilization design modifications (10' gaps every 100', minimal heigh of sills above MHW, etc.). The
NCWRC maintains support for these requests to avoid and minimize impacts and requests clarification of
final water depths and structure designs before any permit issuance if it is determined permit issuance is
allowed. However, if the proposal proceeds with permit issuance, it is unlikely appropriate avoidance and
minimization of resource impacts can be met. Therefore, the applicant has submitted a mitigation plan to
offset impacts.
NCWRC staff have reviewed the mitigation plan and still have concern with the project proposal. Overall,
impacts should be avoided and minimized — especially for SAV and coastal wetlands. Mitigation for
substantial impacts to these resources is not generally supported or allowed, unless for an overriding
public benefit, such as bridges to islands that provide improved hurricane evacuation access and utilities
infrastructure. Therefore, careful consideration should be given to the appropriateness of the mitigation,
functional uplift, and overall success. In -kind mitigation, monitoring, and success criteria are essential.
During the review of the mitigation plan it was noticed that the eastern island where a large portion of the
mitigation is proposed is not public land but owned by a private entity. There was no information
regarding allowance to conduct any activities on this island or any discussion on methods to ensure the
area would be placed under a conservation easement and not developed or managed in a way inconsistent
with the intended mitigative purpose. As this is an important aspect of the project, the NCWRC will not
provide further comment on the mitigation plan and requests this concern be addressed and information
provided regarding allowance and perpetual conservation. Establishing mitigation on public lands or areas
that are managed by local, state or federal entities is preferred. Such areas may include state owned
islands, state parks, game lands and wildlife refuges.
The NCWRC appreciates the opportunity to review and comment on this application and mitigation plan.
Please do not hesitate to call or email me at maria.dunn(c�r�,ncwildlife.org or [phone] as additional
information becomes available or if you need further assistance or additional information.