20170110 Ver 2_Response to Comments Letter_20181206

THE CULLIPHER GROUP, P.A.
Gregg Bodnar ENGINEERING &SURVEYING SERVICES
Division of Coastal Management
400 Commerce Ave.
Morehead City, NC 28557
Re: Shore Front RV Park—CAMA Major— Response to Informal Comments
Mr. Bodnar,
Thank you for coordinating with our office regarding comments related to the Shore Front RV Park,
have reviewed the comments forwarded to me from Shane Staples with the Department of Marine
Fisheries. I have corresponded with Mr. Robin Comer (Owner) and have the below response and/or
revisions detailed per each comment.
1. As proposed DMF may have significant concern over the potential for prop dredging to occur as
a result of normal use of the marina due to the shallow water depths.
Response: The marina layout has been revised to shift the slips further from shore by
approximately 23. This increases the water depth at each section of slips. if the wet slips
were extended all the way to the end of the previously proposed platform, Pier's E & D would
encroach over the riparian boundary. The entire dock could possibly be rotated counter
clockwise to avoid this conflict but the water depth decreases when getting closer to the
eastern riparian boundary. This shallower depth along the eastern line is why the original
layout had the marina at an angle from shore as opposed to centered within the riparian
rights.
2. The current design has an observation platform in the deepest available water instead of boat
slips.
Response: The observation platform has been removed from the end of the marina and
located between the shore and the nearest wet slips. Please see the revised layout.
3. The number of slips exceeds the number of lots in the development by 40 slips.
Response: The intent is for the marina to service the greater RV park per an agreement
between the two property owners. The Owner has made a significant investment in the
purchase of the property and the proposed investment in developing the land and marina
would result in an economic hardship on the Owner if the total number of slips were to be
reduced. We request that the financial constraint betaken into consideration for this
comment.
4. In order to reduce the potential for negative impacts to the shallow bottom PNA habitat DMF
would request that the piers with boats slips be moved to the deepest waters where the
observation platform is currently sited.
Response: The piers have been shifted further out per the comments above. Per the revised
HESTRON PLAZA TWO
151-A INC
HWY 24
MOREHEAD CITY, NC 28557
[phone]

pier location this has also reduced the total square footage of dock construction from 12,602 sf
to 12,084 sf. A reduction by 518 sf of pier surface has resulted from this revision and
correspondingly a similar reduction in impacts to the shallow bottom habitat.
5. Additionally to reduce the overall footprint and therefor potential impacts DMF would request
that the number of slips be reduced to match the number of lots on the campground. The
adjacent campground has a much smaller docking facility which seems to see limited use based
on the site visit today, aerial imagery over time, and personal accounts of staff that work in the
area frequently.
Response: Please consider responses 3 & 4 as a partial revision and response regarding this
concern. This was also discussed with the Owner and reviewed by our office. The existing
docking facility is not currently constructed in a manner that favors boating activities and is
used more as an observation/fishing pier. The proposed development of this marina is directly
tied to the lack of boating opportunities offered by the existing pier and is primary factor in
this proposed facility.
Additionally, the Owner intends to phase the construction of this marina over time by building
one-quarter of the slips each over the life of the permit or until it becomes no longer
economically feasible. This correlates with the economic hardship mentioned in response #3
but also reduces the immediate impact to the overall shallow water habitat.
6. There is still some concerns based on sediment accumulation sometimes seem around large
docking facilities. Being that this is located within the PNA designated waters of the White Oak
River DMF would likely object to any dredging in the area.
Response: This is understood and dredging is not currently being proposed. If maintenance
dredging were needed in the future the Owner understands that it may not be allowable
depending on the current rules and regulations at that time.
7. Another area where habitat impacts could be reduced would be to delete the bulkhead behind
coastal wetlands near the emergency vehicle turn -around. The shoreline here has a rip -rap
revetment along the toe of the marsh which seems to have stabilized the shoreline. The
shoreline today showed no visible signs of erosion since the last site visit in 2016. A bulkhead
behind the coastal wetlands will pinch the wetlands between the rip -rap and bulkhead and is
likely to cause the loss of these wetlands over time.
Response: The Owner has agreed to remove the bulkhead from this proposed project.
Thank you for the opportunity to revise and respond in a preliminary, informal manner. I feel that it
makes it easier to get the design where it needs to be for a final approval. If you have any questions or
further comments please let me know.
Charles M. Cullipher, P�., P.L.S.
Vice President
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