20230797 Ver 1_More Info Received_20240319

March 15, 2024
N.C. Division of Water Resources
c/o Stephanie Goss
127 Cardinal Drive Extension
Wilmington, NC 28405
(via email at [e-mail])
Dear Ms. Goss:
SUBJECT: Carteret County Western Boat Ramp Project —2nd Additional Information Request
This letter is in response to your February 16, 2024, request for additional information on the application
submitted by Carteret County for the proposed Western Carteret Boat Ramp Project. Your "additional
information" letter requested a written response to the additional informational items within 30 days of
receipt of the letter. This letter is also intended to respond to the November 16, 2023 comment letters by
the N.C. Division of Marine Fisheries (DMF) and the N.C. Wildlife Resources Commission (WRC), which
we would point out were not provided to us for comment until February 16, 2024. Please accept this
letter as our response to these items within the requested 30-day timeframe, which we believe to be
sufficient to prevent the N.C. Division of Water Resources (DWR) from retiring the application package.
Modelling
• DWR Modeling and Assessment branch staff reviewed the response to the request for additional
information and shared the continued concerns regarding the Flushing Analysis for the Western
Carteret County Boat Launch Project during the November 20, 2023, meeting. After review of the
submitted materials and consultation with upper management, a nonproprietary model is
needed in order to evaluate both flushing and dissolved oxygen for the proposed boat launch.
Response: The consultant team is preparing a modeling plan using a non-proprietary
model to evaluate water exchange and flushing within the basin. Once the
modeling plan has been reviewed by DWR Modeling and Assessment Branch,
the model will be executed, and the results presented in a report.

Mitigation Plan
(Please note that the responses contained in this Section were prepared in consultation with Dr. Jud
Kenworthy, noted SAV scientist and researcher)
• The proposed experimental mitigation plan includes a privately owned spoil disposal island.
Response: Due to property owner issues that are being reviewed by the County and the
potential owner of a portion of one of the islands (Paxon M. Holz Residuary
Trust), we have removed the Quickreef® sill from the intertidal zone on the
north side of this portion of the island. Removal of this section of sill does not
impact the ability to successfully implement the compensatory mitigation plan
or the ability to close in the section of island that has breached. Once property
ownership issues are resolved, we would still like to request a permit for the
Quickreef® system in this location, but it is understood that a permit cannot be
issued for this component until such time as these ownership issues are
resolved. The likely owners of this section of island (Paxon M. Holz Residuary
Trust) have are not objecting to the project, but without a legal determination
of ownership, it is understood they cannot become a co -applicant. This was
brought to our attention by the N.C. Division of Coastal Management (DCM) in
January 2024 and an updated Exhibit D in our mitigation plan (with the Block
16 boundary information) was generated at that time. The current Exhibit D
does not include any proposed work within Block 16 per Carteret County
records. Please understand that the broader goal of the seagrass restoration
work being proposed is to protect existing seagrass resources in addition to
the necessary mitigation measures to restore impacted seagrass resources.
Future island protection through living shorelines that incorporate nature -
based solutions will be important to preserve resources before significant
additional erosive impacts occur. This will hopefully include other private and
public islands and shorelines in the future.
• The mitigation plan drawings lack the mean low water boundary and waterward extent of the
existing marsh grass. The proposed inset cross section drawing in Exhibit F does not appear to
accurately depict the location, slope, and height of the Quickreef® sills within the mitigation
areas. The proposed final height of the Quickreef® sill as shown in Exhibit F is 1. 70feet above the
mean high water. DWR is requesting additional drawings that provide details including the edge
of marsh and/or mean low water contours (where applicable). The proposed height and width
does not appear to accurately account for the tidal amplitude in these areas as it relates to the
proposed slope of the structure and the mean high water level. Additional cross -sectional
drawings should be provided that depict the proposed final height and slope of the varying width
Quickreef® Sill shown on Exhibit D. The cross-section drawings should include the proposed
Quickreef® sills, mean high water level, mean low water level, edge of marsh where appropriate,
the proposed slope and final height. Please note that DWR also supports the DMF
recommendation to construct the proposed Quickreef® a maximum of one foot above the mean
high water.

Response: As requested, Exhibit D and Exhibit F have been further updated to include all
of this information. For clarification, please note that the 1.70 ft on the prior
version of our Exhibits was a dimension and not a top elevation of the sill. The
proposed maximum height of the Quickreef° Sill Sections is 1.0 ft above
MHWL. Additionally, the maximum proposed height for the rock sill at the
breach area to re -connect the islands is 1.5 ft above MHWL. This is the same
maximum height elevation we have used for several other recently permitted
projects in this area, as well as other regions in North Carolina, that suffer
from high rates of shoreline erosion. This maximum height of rock is important
for several reasons that are not unique to this situation, including:
• Our area regularly experiences higher than normal tides for long
durations.
• Boat wake wave amplitudes exceed 1.0 ft (especially from the large
power yachts that utilize the waterway).
• Coastal resilience and planning for continued sea level rise. This is
another reason to use rock for this re -connection (ability to control
max heights) since the concept of sand fill was not well -received.
The County would agree that 1.0 ft above MHWL would be sufficient for
protection along a lower energy regime shoreline scenario.
Prior to implementation of the Plan, the County will re -survey conditions at
the time to completely understand changes that have occurred in the system
before installing the rock and Quickreef° sills. All permitted alignments will be
staked and reviewed by resource agency representatives before installation.
Please see the accompanying plan updates that include updates to Exhibits D
and F as requested (cross -sections and plan view).
• Please provide DWR with clarification regarding the mitigation ratio.
Response: DWR misunderstands how the mitigation ratio was calculated. We did not
multiply the estimated area of impact at the channel dredging site (0.78 acres)
by a prescribed ratio, e.g., 2:1 or 3:1 to arrive at a mitigation area. If any of the
resource agencies have adopted a standardized mitigation ratio for seagrass
impacts, we are not aware of it. We are aware that many wetland mitigation
plans include minimum ratios, such as 2:1, 3:1 (or greater for excessive
amounts of wetland impacts). As described in our proposed mitigation plan,
we calculated the area of the mitigation site based on the following factors.
The first factor is a basic ecological understanding of how barrier islands
attenuate waves and trap sediments which promotes the establishment,
growth, and persistence of seagrasses. This phenomenon is well documented
in North Carolina as per our confirmation that the majority of seagrass acreage
lies on the shallow back barrier shelves behind the barrier islands and other
island features in the seagrass system in North Carolina (Field et al. 2021).
Next, historical aerial photographs were inspected for the dredge spoil islands
in an area of Bogue Sound to confirm the spoil islands were facilitating the
establishment, growth, and persistence of seagrass (Figures 1 & 3 in our

Mitigation Plan). This historical photography was also used to confirm that
when these islands are breached and/or eroded, the seagrasses on their
southern boundary are lost (Figure 3 in our Mitigation Plan). Applying simple
logic to these observations leads one to conclude that if we re-establish a
barrier in the breech that deflects wave energy and slows currents, it will
recreate the island -like conditions that formerly promoted the growth of
seagrass. The boundaries of the primary mitigation area (3.34 acres- See
yellow rectangle in Figure 3 of the plan) are expected to be restored with
seagrass. The mitigation areas limits are based on the width of the breech and
the extent of the shallow and deep edges of the reference seagrass meadows
behind the islands adjacent to the mitigation site. This is an empirically
derived area, not some abstract predetermined ratio. As we indicated in the
legend of Table 1 of our mitigation plan "The acres shown in the Reference Site
Column are the estimated acres of the mitigation site." (obtained as described
above). In the column under the header REFERENCE SITE, in the first cell
aligned with the ACRES row, we entered 334a. This may have caused the
reader some confusion, since the table legend narrative should have aligned
with the a superscript and should read as follows, "The acres shown in the
Reference Site Column are the estimated acres of the mitigation site "."
Alternatively, if requested, we could add a column to the table with the
header indicating "MITIGATION SITE" and insert 3.34 in the ACRES row.
Coincidently, the ratio of area at the mitigation site to the area of the
impacted site is - 3:1.
At the least, based on area, we proposed to achieve a 3:1 ratio. However, area
alone does not characterize the composition and quality of the impacted and
mitigated seagrass habitats, nor can it confirm "in kind" mitigation. Therefore,
we took a further step. We used scientifically accepted methods to
quantitatively characterize the channel dredging site (area impacted) and the
mitigation site by adopting a metric that incorporates both the area
(probability of presence) and the cover of the seagrass species (Braun Banquet
visual assessment). Both of these monitoring metrics are scientifically
accepted worldwide and have been adopted by the Albemarle Pamlico
National Estuary Partnership in the North Carolina coastwide seagrass
mapping and monitoring program. We note that DMF is an active participant
in the monitoring program and should be aware of this.
Therefore, to clarify DWR's misunderstanding, we did not arrive at the 7:1
ratio based on acres alone. To arrive at the ratio, we combined the probability
of area covered and the quality of the habitat. All of these computations are
shown in Table 3 and accompanied by supporting narrative in the text. While
it might appear as if this combined metric inflates the mitigation ratio based
on area alone, this metric actually reflects the expected increase in area of
higher quality habitat having more area where seagrass is present, a higher
cover, and a higher probability of increased seagrass species diversity with
relatively more Halodule as well, as increased resilience. In other words, by
repairing the breach and stabilizing the adjacent islands, we expect that a
multi -species seagrass meadow with a greater amount of cover will naturally
11

establish at the mitigation site by seed (Zostera) and clonal growth (Halodule
and Zostera) from adjacent reference meadows that were characterized in our
survey results.
This leads us to address another DWR concern.
• The SAV survey conducted and referenced in the mitigation and monitoring plan do not appear
to account for the seasonal variability of species of SAV documented within Bogue Sound.
Response: First of all, the timing of our survey of the impact site (May 27, 2022) and the
reference site was based on our fundamental ecological knowledge and the
historical mapping and monitoring of the seagrass ecosystem system in Bogue
Sound. The impact site is located on the northern shoreline of Bogue Sound
where the subticial and intertidal waters are significantly impacted by boat
wake wave energy, as well as the prevailing wave energy from southwest
winds. Therefore, the water is very turbid, and the sediments are unstable.
These aren't ideal conditions for seagrasses. As expected, our surveys
indicated that the impact site mostly consisted of small sparse vegetative
clones of Zostera that were derived from a seed bank and seedlings which
emerged in winter and early spring during the period of clearest water in the
system. As noted in our mitigation plan in the section titled "Seagrass
Distribution and Abundance at the Channel Dredge Site", 76 % of the quadrats
had Zostera and only 6 % had Halodule. The quadrats with Halodule were all
located in the shallow upper intertidal waters near the shoreline. The average
total seagrass cover overall was < 5 %. The seagrass composition and the cover
were similar to other marginal environments we've surveyed in Bogue Sound
and in the polyhaline waters throughout North Carolina. These results are
discussed in detail in our Plan (see quote below).
"Based on our survey results, the seagrass habitat in the vicinity of the channel
dredge site can be characterized as a sparsely covered, seasonally ephemeral
eelgrass meadow maintained annually by the recruitment of seedlings and an
abbreviated period of clonal growth in spring and early summer. These
eelgrass meadow characteristics are common throughout the North Carolina
estuarine system (Thayer et al. 1984). These are referred to as mixed semi-
annual eelgrass meadows (Jarvis et al. 2012, Bartenfelder et al. 2022). In
March 2022, prior to our surveys, visual observations during low tide detected
newly recruited seedlings across the site. In North Carolina, Zostera seeds
begin germinating in December during cooler temperatures and relatively clear
water (Combs et al. 2020). The seedlings reproduce clonally and produce both
vegetative shoots and flowers through the spring. Seeds are released from the
flowers and settle into the sediment seed bank during April and May. In June
and early July as water temperatures exceed the thermal stress threshold of
eelgrass (> 250 C) and water turbidity limits the availability of light, most of the
living plants senesce and die. At this location adjacent to the Atlantic
Intracoastal Waterway (AIW W) and with the exposure to extremely frequent
and large vessel traffic and boat wake waves, sediments are continuously
resuspended. The turbidity generated by these resuspended sediments

severely limits the amount of light needed for growth of eelgrass and the
formation of large perennial meadows in shallow water."
Using our fundamental knowledge of the seagrass system, we disagree with
the DMF/DWR assertion that our survey did not account for seasonality. The
timing of our survey targeted the species most abundant at the impact site.
While it is recognized that the growing season of the least abundant species,
Halodule, extends into the summer and early fall, we also know that based on
50 years of survey work and research, Halodule rarely flowers and doesn't rely
on seeds to disperse or establish new meadows. Therefore, what was
observed as Halodule's distribution and abundance in May likely reflects the
entire growing season for this species at the impact site in the proposed
footprint of the channel and in the surrounding area. Based on 50 years of
surveys and research, we are confident that a fall survey would have shown
little or Zostera remaining at the channel dredging site, given that this species
dies back in summer when the combination of high turbidity exacerbated by
large vessel boat wakes in the AIWW limits light and stressful summer
temperatures limit growth (Thayer et al. 1984, Bartenfelder et al. 2022)
While we don't believe it is necessary to conduct additional surveys to
characterize the seagrass meadow at the impact site in the spring and fall
seasons, we have incorporated a spring and fall season monitoring plan for the
mitigation site. Based on the surveys of the breached channel and the
reference meadows south of the existing spoil islands that was reported in our
mitigation plan, two conclusions are relevant; 1) Zostera seed recruitment in
winter and spring will play a role in restoration of the seagrass meadows at the
mitigation site and 2) Halodule is relatively more abundant in the reference
sites south of the spoil islands, therefore clonal growth and expansion of this
species with contribute to colonization of the mitigation site. It is expected
that both species will contribute to the re-establishment of seagrasses at the
mitigation site. Thus, in our monitoring plan we proposed sampling in two
seasons to capture the dynamics of both Zostera and Halodule.
• Additionally, DWR supports the DMF recommendation that the entire impact area of the dredge
channel (1.02 acres) should be calculated in the mitigation ratio due to the increases in
documented SAV coverage along this shoreline in Bogue Sound.
Response: We have incorporated 1.02 acres into the mitigation calculations. It is
displayed in TOTAL ACRES IMPACTED COLUMN in Table 1 in our mitigation
plan. Also, please be advised that we took an additional step not usually taken
with mitigation calculations based on ambiguous area ratios. We factored in
the cumulative loss of seagrass at the boat ramp channel dredge site (impact
site) over the five-year monitoring period to calculate the net gain in the
mitigation site. Below, is a quote directly from the plan.
"Success will be assessed at the end of the five-year monitoring period using
the total seagrass abundance metric (Table 1). Assuming the mitigation goal is

to replace the seagrass lost in the dredge channel we calculated the
cumulative loss of seagrass over the five-year period. Based on
the data in Table 1, the annual total seagrass abundance loss at the boat ramp
channel and the footprint of the rock sill is estimated to be 0.87 (0.73 + 0.14)
and therefore, over five years the total loss in seagrass abundance is 4.35 (5 *
0.87). For each year following the initiation of the mitigation we will calculate
the total seagrass abundance metric at the mitigation site and calculate the
cumulative gain of seagrass abundance each year."
We believe that this is a more quantitative and compelling approach to assess
the success of a mitigation by accounting for interim loss and the quality of the
habitat, and not just area gained. We also believe that this approach addresses
concerns raised in comments by DMF and DCM regarding the accounting of
cumulative impacts of boating activity after project completion. By
incorporating the area, the improved quality of the mitigated habitat, and the
cumulative loss into calculations for the mitigation ratio and the success
criteria, we are compensating for the uncertainties of how post construction
activities might affect the area of habitat around the boat channel.
Regarding the latter part of DWR's statement above; "due to the increases in
documented SAV coverage along this shoreline of Bogue Sound", we concede
that it is plausible to interpret the polygons DMF presented as potential
evidence for seagrass expansion. Unfortunately, those polygons only represent
the areal extent of seagrass (Tier 1 data) and there is no Tier 2 data
characterizing the quality of the habitat, for example, the species composition
and percent cover within the polygons. Therefore, it is equally plausible to
infer that the fluctuating size of the polygons reflects the intrinsic properties of
contracting and expanding ephemeral Zostera meadows formed annually by
seed recruitment, similar to what we characterized in our survey of the impact
site along this shoreline. Based on decades of experience in the seagrass
mapping program in North Carolina, we have observed thousands of acres of
ephemeral Zostera meadows expanding and contracting in marginal
environments like this particular shoreline in Bogue Sound. In our evaluation
of historical aerial photography on the south side of the existing intact spoil
islands, east and west of the mitigation site, we documented persistent areal
extent of seagrasses for at least 30 years (see Figure 1 in our mitigation plan).
We concede that our mitigation proposal will result in a seagrass meadow with
different structural characteristics than the meadow at the impact site.
However, the seagrass habitat that will be naturally established at the
mitigation site will be a mixed species meadow of Zostera and Holodule with
greater cover, higher biomass, and more seasonal and longer -term persistence
than the impact site. The functions of the mitigated seagrass (e.g. fisheries
habitat, nutrient cycling, sediment stabilization) will be a significant
improvement over the sparse and ephemeral habitat that exists at the impact
site.

As per DWR's insistence that we prepare an "adaptive management plan as
part of the mitigation plan to address any deficiencies that may be
discovered", we submit the following response.
As per our previous response to this request, we appeal to the permitting
agencies that they consider adopting the remedial action plan approach
approved for the N.C. Department of Transportation's Harkers Island Bridge
SAV Mitigation Plan which involved five years of post -construction monitoring
before determining the appropriate remedial action. As outlined in our
mitigation plan, we propose to construct a partial physical barrier in the spoil
island breach that will promote physical conditions suitable for the natural
recruitment of seagrasses from the adjacent and persistent meadows south of
the existing islands. In principle, this is a "nature based" solution that relies on
the confidence we have in our fundamental scientific knowledge of the
ecology, reproduction, and growth of seagrass species in North Carolina.
Alternatively, we could have proposed an "in kind" mitigation plan where we
relocate seagrasses from healthy established meadows and transplant them
into the mitigation site (Fonseca et al. 1998). Seagrass transplanting is a
commonly used seagrass mitigation practice; however it has a poor and very
uncertain track record with a probability of success known to be about 33%
(Van Katwijk 2016). Recognizing that the probability of success is less than a
coin toss and transplanting seagrass can be expensive, ranging from $10,000 to
$250,000 per acre (Fonseca 2006, Treat and Lewis 2006, Paling et al. 2009),
depending on the circumstances, we elected to propose a less expensive
approach, letting nature do the work and bare some of the cost. Allowing for a
five-year monitoring period to assess the mitigation's success while evaluating
alternative seagrass restoration methods and the cost, if needed, is a
reasonable example of an adaptive management practice. Here in North
Carolina, we have considerable experience evaluating seagrass restoration
techniques, in fact, the first seagrass restoration guidebook published in the
U.S. was produced at the NOAA Beaufort Laboratory (Fonseca et al. 1998).
There are several seagrass transplanting options in the guidebook still being
applied today, worldwide, that could be used to compensate for any
deficiencies in natural recruitment of seagrass in the mitigation site.
Furthermore, there are relatively new restoration methods that have
demonstrated some promise for improving success. For example, recently here
in North Carolina C, Sea Grant has funded a pilot study to evaluate the
potential for using eelgrass seeds to restore eelgrass meadows based on the
results of recent studies in coastal bays of Virginia. By adopting the mitigation
approach approved for the Harker's Island Bridge, the applicant will have the
time needed to fully evaluate whether a contingency plan is necessary, what
the most effective and potentially successful plan could be, and how much it
would cost.
91

Project Details
DWR has concerns regarding the justified need for a final project depth of -7.2 feet Mean Low
Water within the upland boat launch basin and access channel. DWR recommends a reduction in
the proposed final depth based on the need to provide launching for vessels limited in length by
NCDOT (max. 60 feet truck and trailer combined), supported by the 60 feet long proposed
parking spaces and documented application materials listing average boat length to be 24 feet.
The resource agencies have consistently recommended a reduction in the proposed final depth.
Please provide justification, including potential model results that may justify the need for the
proposed final project depth.
Response: We refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources.
• Additionally, the proposed final dredge depths depicted on Sheet C-300 cross sections D1 & D2
do not consistently call out the water elevations of the proposed final dredge depths. The
proposed final dredge depths depicted on Sheet C-400 do not include the one foot over dredge
allowance proposed.
Response: As was stated in the original April 23, 2023 Permit Application Narrative, the
proposed design depth for this project is 7.2' NAVD88 (-6.2' target depth plus
1.0' foot of allowable overdredge allowance). Sheet C-400 shows the design
depth for the proposed project (-6.2 NAVD88). The overdredge allowance is
simply a safety measure for the dredger.
• Please provide clarification that references the tidal datum utilized to determine proposed
depths and structures that references the changes in tidal amplitude and water elevations
described in the application, specifically, mean high water, mean high high water, mean low
water, and mean low low water.
Response: All dredge depths included in the permit application package were given
utilizing the NAVD88 datum.
• Please provide clarification that references the tidal datum utilized to determine proposed
depths and structures that references the changes in tidal amplitude and water elevations
described in the application, specifically, mean high water, mean high high water, mean low
water, and mean low low water.
Response: All dredge depths included in the permit application package were given
utilizing the NAVD88 datum.
• Please provide a cross-section drawing that accurately depicts the proposed finished side slopes.
Response: Please refer to Cross Section B1 on Sheet C-300 of the original permit drawings
for a depiction of finished side slopes,

• Please clarify if fill be placed along the shoreline. Cross section drawings provided depict
approximate existing grade.
Response: No fill will be placed along the shoreline.
Division of Marine Fisheries (DMF) Comment Letter (November 17,
2023)
• Permission from owner of spoil island to construct mitigation project.
Response: Please see the response to this item in the mitigation section of this letter.
• Flushing model results as required by NC Division of Water Resources.
Response: The consultant team is preparing a modeling plan using the non-proprietary
model to evaluate water exchange and flushing within the basin. Once the
modeling plan has been reviewed by DWR Modeling and Assessment Branch,
the model will be executed, and the results presented in a report.
• 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.
Response: We refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources, as well as to information provided in our
original permit application narrative.
A definitive answer and proposed location of any No Wake Zones to be included.
Response: We refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources. We further understand that if a Coastal Area
Management Act (CAMA) Permit is issued for this project, a permit condition
will likely be included in the CAMA permit requiring the County to pursue
permitting of such a No Wake Zone before work can begin on other portions
of the project.
• An assessment of potential impacts to SA V associated with the placement of QuickReef material.
Response: Please see the response to this item in the mitigation section of this letter. We
refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources.
• Additional boat launch user data to support the purpose and need of this facility.
Response: We refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
0101

and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources, as well as to information provided in our
original permit application narrative.
• Additional information regarding how the" No Reasonable Alternative" conclusion was made.
Response: We refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources, as well as to information provided in our
original permit application narrative.
• 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.
Response: Please see the response to this item in the mitigation section of this letter.
• Additional details regarding the proposed monitoring (i.e., locations of sites, specifics of
monitoring, success criteria, who will undertake these efforts, etc).
Response: Please see the response to this item in the mitigation section of this letter.
N.C. Wildlife Resources Commission Comment Letter (November 17,
2023)
• ....avoidance and minimization of impacts to resources should be a primary objective —
especially for SA 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.).
Response: We refer the reviewers to our responses to this issue in our September 1, 2023
Additional Information response letter to the N.C. Division of Water Resources
and our October 16, 2023 Additional Information response letter to the N.C.
Division of Coastal Resources, as well as to information provided in our
original permit application narrative.
• 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.
Response: Please see the response to this item in the mitigation section of this letter.
In closing, the County would like to continue to reiterate the importance of the proposed project to the
boating public. The need for a large public boat launch facility on the mainland side of Bogue Sound has
long been recognized, as evidenced by the appropriation by the State of North Carolina of $3,300,000 for
the development of the ramp facility, as well as $1,000,000 pledged in support of this project by the N.C.
11

Wildlife Resources Commission. It is therefore the strong belief of the County that this project will have a
significant positive benefit to the citizens of eastern North Carolina. Additionally, as outlined elsewhere
in the original permit application narrative, as well as this letter, there is no reasonable alternative site
available that would meet the purpose and need of this project along the western Shoreline of Bogue
Sound within Carteret County. The avoidance, minimization and mitigation measures proposed for
implementation associated with this project should address potential concerns with adherence to North
Carolina Water Quality Standards, thereby allowing for a positive regulatory decision to be rendered in
this situation.
The County would also like to point out that this project has strong support of the North Carolina
Legislature, as evidenced by the appropriation of $3,300,000 for the development of the ramp facility. It
should be noted that the N.C. Wildlife Resources Commission has also pledged $1,000,000 towards the
project.
The County is concerned that it appears that we are being asked to address items and issues that we
believe have been adequately addressed previously. The County also strongly believes that sufficient
evidence has already been provided that will allow for final action on our permit application. With this in
mind, and in an effort to resolve any remaining regulatory issues associated with this project, the County
would formally like to formally request a meeting between ourselves and senior leadership of the
Department of Environmental Quality, the Division of Water Resources, and the Division of Coastal
Management. Please feel free to contact me if you would like to discuss this request further.
Sincerely,
Eugene Foxwo
Assistant County Manager
cc: Ryan Davenport, Carteret County Shore Protection Office
Braxton Davis, N.C. Coastal Federation
Todd Miller, N.C. Coastal Federation
Dr. Jud Kenworthy
Brian Rubino, Quible
Gregg Bodnar, NCDCM
Doug Huggett, Moffatt and Nichol
Mark Pirrello, Moffatt and Nichol
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Attachments:
Attachment A. Conceptual Compensatory Mitigation Plan (Updated March 14, 2024)
13

REFERENCES CITED
Bartenfelder, A., W. J. Kenworthy, B. Puckett, C. Deaton, and J. C. Jarvis. 2022. The abundance and
persistence of temperate and tropical seagrasses at their edge -of -range in the western Atlantic Ocean.
Frontiers in Marine Science. 9. Doi: https://doi.org/10.3389/fmars.2022.917237
Combs, A.R., Jarvis, J.C., Kenworthy, W.J. 2020. Quantifying variation in Zostera marina seed size and
composition at the species' southern limit in the western Atlantic; Implications for eelgrass population
resilience. Estuaries and Coasts, https://doi.org/10.1007/sl2237-020-00839-5.
Fonseca, M.S., 2006. Wrap up of seagrass restoration: success, failure and lessons about
the costs of both. In: Treat, S.F., Lewis, R.R. (Eds.), Seagrass Restoration: Success,
Failure, and the Cost of Both. Lewis Environmental Services, Inc., Valrico, FL U.S.A,
pp. 169-175.
Fonseca, Mark S., W. Judson Kenworthy, and Gordon W. Thayer. 1998. Guidelines for the Conservation
and Restoration of Seagrasses in the United States and Adjacent Waters. NOAA, Coastal Ocean Program,
Decision Analysis Series No. 12. U.S. Department of Commerce, NOAA, Coastal Ocean Office, Silver
Spring, MD. 222pp.
Jarvis, Jessie C., Moore, K.A. and W. Judson Kenworthy. 2012. Characterization and ecological
implication of eelgrass life history strategies near the species' southern limit in the western North
Atlantic. Marine Ecology Progress Series 44:43-56.
Paling, E.I., Fonseca, M.S., Van Katwijk, M.M., Van Keulen, M., 2009. Seagrass. In: Perillo,
G.M.E., Wolanski, E., Cahoon, D.R., Brinson, M.M. (Eds.), Coastal Wetlands: An
Integrated Ecosystem Approach. Elsevier, pp. 687-705.
Thayer, Gordon W., W. Judson Kenworthy, and Mark S. Fonseca. 1984. The ecology of eelgrass meadows
of the Atlantic coast: a community profile. U.S. Fish and Wildl. Serv. FWS/OBS-84/02. 147pp.
Treat, S.F., Lewis, R.R., 2006. Seagrass Restoration: Success, Failure, and the Costs of
Both. Selected Papers Presented at a Workshop. Mote Marine Laboratory, Sarasota,
Florida March 11-12, 2003.
Van Katwijk, M.M., Thorhaug, A., Marba, N., Orth, R.J., Duarte, C.M., Kendrick, G.A.,
Althuizen, I.H.J., Balestri, E., Bernard, G., Cambridge, M.L., Cunha, A., Durance, C.,
Giesen, W., Han, Q., Hosokawa, S., Kiswara, W., Komatsu, T, Lardicci, C., Lee, K.-S.,
Meinesz, A., Nakaoka, M., O'brien, K.R., Paling, E.I., Pickerell, C., Ransijn, A.M.A.,
Verduin, J.J., 6sterblom, H., 2016. Global analysis of seagrass restoration: the importance
of large-scale planting. J. Appl. Ecol. 53, 567-578.
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