20230797 Ver 1_DMF Comments_20231201

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
SUBJECT: Western Carteret Boat Ramp Proposal and Mitigation Plan, Carteret County,
follow up memo
DATE: 17 November 2023
A North Carolina Division of Marine Fisheries (DMF) Fisheries Resource Specialist reviewed
the CAMA Major permit application, mitigation plan, and associated documents for the proposed
Western Carteret Boat Ramp and submitted comments for the project in July 2023. The DMF
requested additional information and potential minimization measures due to impacts to
submerged aquatic vegetation (SAV) and coastal wetlands, and water quality degradation in
open shellfish harvest waters (SA-ORW). The DMF reviewed Carteret County's October 2023
response to DMF and offers the following response.
The proposed project is in Newport, North Carolina (Carteret County), and consists of dredging
an upland boat basin and access channel for a public boat launch facility on Bogue Sound. The
waters at this location are classified as Outstanding Resource Waters (ORW); SA and are open to
shellfish harvesting. Submerged aquatic vegetation is documented within the dredge footprint of
the access channel and the surrounding waters. There are also coastal wetlands within the project
site that would be directly impacted by the project.
The public boat launch facility is proposed to include a 159-space boat trailer parking lot, six
launch ramps and three floating piers, an upland boat basin with depth -7.2' NAVD88 (-6.2'
target depth plus 1' allowable overdredge). A 50' by 450' channel from the basin into the sound
and AIWW would be dredged to access the basin, resulting in 0.78 acres (33,977 ft2) of direct
impacts to SAV and 2,212 ft2 of impacts to coastal wetlands.
Two outstanding issues exist with the permit application before DMF can fully assess
environmental impacts of the project.
1) Permission from owner of spoil island to construct mitigation project.
Since DMF submitted its initial comments, we have learned that the applicant does not have
permission from the owner of the spoil island to construct the breakwater and QuickReef sill.
Without written permission, the mitigation plan is speculative, and no permitting decisions
should be made without having a confirmed mitigation plan. Should the mitigation project get
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021

permission, DMF has some additional unaddressed concerns and suggested changes to the
mitigation plan.
2) Flushing model results as required by NC Division of Water Resources
Because the applicant has not provided the correct flushing data needed to North Carolina
Division of Water Resources' (DWR), DMF does not have enough information to know whether
the current basin and channel design is sufficient for flushing or how much it could be modified
to improve water quality. The DMF defers to and supports the position of DWR on the minimum
width of the entrance channel that will be sufficient.
Remaining concerns of DMF
The county's response did not include any design changes to minimize habitat and water quality
impacts associated with the project. Additional information was provided by the applicant but
primarily re -stated information from the original application. No additional information was
provided to reduce impacts to SAV. The DMF objects to the project due to significant impacts to
critical fish habitat and includes below the specific remaining concerns.
Boat ramp facility
Additional details regarding the necessity for the proposed boat basin and access channel depth
and an analysis of the impacts that this deeper water could have on the surrounding area.
The DMF disagrees with the applicant that -7.2' NAVD88 (-6.2' NAVD88 target depth +
V allowable overdredge), water depth is necessary in the basin and access channel. The
North Carolina Wildlife Resources Commission (WRC) generally requires 4' MLW for
public boat ramp facilities. Reducing the depth would reduce water quality concerns and
would allow the required channel length to be shorter, thus reducing the dredge footprint
in SAV habitat. Reducing the access channel width would also reduce the dredging
impacts to SAV habitat and potentially reduce water quality degradation to ORW open
shellfish harvest waters.
A definitive answer and proposed location of any No Wake Zones to be included.
The county provided a sketch of the area to be included in the No Wake Zone and
restated that they would work with WRC to secure a No Wake Zone. A No Wake Zone as
depicted by the applicant would be very helpful in reducing boat wake related impacts to
nearby coastal wetlands, and improve boater compliance to stay within the marked
channel, thus reducing boating related damage to SAV. Written confirmation by WRC
and/or the US Coast Guard that the No Wake Zone will be permitted is necessary to
consider the benefit of the action.
An assessment of potential impacts to SAV associated with the placement of QuickReef material.
No documentation was provided other than subjective observations and literature from
other areas. This is a topic of uncertainty raised at the October 2023 Living Shoreline
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021
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Workshop as a research need. Therefore, the DMF requests a 10' buffer between existing
SAV and placement of QuickReef material. The location of SAV present within 20' of
QuickReef should be documented and provided to DMF. Monitoring of these locations of
SAV should be incorporated into the monitoring plan.
Additional boat launch user data to support the purpose and need of this facility.
The applicant also did not address the request for additional information regarding the
survey of nearby launch facilities. The one -day survey that was reported occurred on a
Saturday in late June — this likely represents peak use before July 4th weekend, rather than
typical use. Subsequent repetitions throughout the year would provide a more accurate
representation of launch user data. The narrative and response mention the number of
registered vessels in Carteret, Craven, Jones, and Pitt Counties, but only surveyed
existing facilities in Carteret County. There is no breakdown of the number of vessels by
individual counties, or data showing the extent of those vessels traveling to Carteret
County launch facilities, making the additional information irrelevant to the need for
such a large boat ramp. The applicant did not offer to reduce the number of trailer
parking spaces to reduce cumulative impacts to SAV and wetlands from heavy boat
traffic. The DMF continues to request a reduction in maximum capacity, by at least 30%
(maximum of 111 trailer spaces).
Additional information regarding how the "No Reasonable Alternative" conclusion was made.
The response indicates that the property was selected because it was devoid of SAV
based on State -supplied SAV data. However, in 2017, the WRC was considering this
location for a potential boat launch facility. After the area was surveyed by DMF and
DCM staff, the WRC decided not to pursue this location due to the significant impacts to
SAV that would occur as a result of the project. The response does not indicate that any
sort of ground-truthing survey was completed to verify the mapping data. As State -
provided mapping shows SAV along the project site shoreline throughout history (though
possibly not within the exact dredging footprint), completing a preliminary survey would
have shown that the applicant did their due diligence, as was the case in 2017. The
response from the County also failed to include the 2020 SAV data, which shows that
2020 mapping found expanded SAV along the shoreline compared to 2013.
Mitigation Project
Additional information to justify the large width and height of 'the proposed breakwater for
mitigation.
The design height is based on a maximum height of one ft above MHHW. DMF requests
the height be reduced to not extend above MHHW, rather than one ft above.
Additional details regarding the proposed monitoring (i.e., locations of sites, specifics of
monitoring, success criteria, who will undertake these efforts, etc).
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021
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The mitigation ratio was calculated by taking the area of the access channel dredge and
breakwater footprints and reducing the impact by the proportion of the area that had
vegetation at the time of the survey. However, transects were 30m apart and therefore did
not quantify total SAV coverage and could have easily missed SAV patches. Also,
imagery indicates that SAV has slowly been increasing in extent in this area and could
continue to do so if not dredged. Since the entire dredge footprint of the access channel
and the footprint of the breakwater will no longer support SAV, the entire acreage should
be used as the impact area (1.02a). Since the mitigation site is 4.27a, the mitigation ratio
is 4.18. Additional mitigation should be added to reach a 7:1 ratio as proposed by the
applicant. Because success criteria depend on the extent of seagrass coverage, monitoring
transects should be closer together to accurately assess coverage change — 1 Om apart or
less. At the end of five years, annual results should be reviewed by resource agencies to
determine if additional monitoring time is needed.
Additionally, the proposed monitoring includes two surveys per year to account for
seasonal species differences, but only one survey was completed to develop the
mitigation plan. A fall survey will likely produce different results than a single spring
survey. Without having a pre -project fall survey, DMF would like clarification on how
SAV change will be assessed. The applicant's response also did not address DMF's
comment recommending that monitoring results be summarized and reported annually to
allow for adaptive management.
Thank you for your consideration of our comments and concerns. Please contact Jimmy Harrison
at [phone] or at james.harrison(d),deq.nc.gov with any further questions or concerns.
State of North Carolina Division of Marine Fisheries
3441 Arendell Street I P.O. Box 769 Morehead City, North Carolina 28557
252-726-7021
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