20181471 Ver 1_DMF comments_21081220

Strickland, Bev
From: Staples, Shane
Sent: Thursday, December 20, 2018 12:09 PM
To: Bodnar, Gregg
Cc: Deaton, Anne; Dunn, Maria T.; Mairs, Robb L; Twyla Cheatwood - NOAA Federal
Subject: Robin Comer - DMF comments
Attachments: Robin Comer Campground and Marina - DMF Comments.pdf
G regg,
Attached are NCDMF comments for the Robin Comer project for the campground and marina. We are still requesting
further minimization of the project size due to concerns over habitat impacts. Let me know if you need anything further.
Shane
Shane Staples
Fisheries Resource Specialist
Division of Marine Fisheries
North Carolina Division of Environmental Quality
252-948-3950 office
[e-mail]
943 Washington Square Mall
Washington, NC 27817
1

ROY COOPER
far'. Governor
MICHAEL S. REGAN
Secretary
Coastal Management BRAXTON C. DAVIS
ENVIRONMENTAL QUALITY RECEIVED EIVE D Director
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WARO
October 23, 2018
MEMORANDUM:
TO: Shane Staples
Division of Marine Fisheries
FROM: Gregg Bodnar
Major Permits Processing Coordinator
SUBJECT: CAMA Permit Application Review
Applicant: Robin Comer
Project Location: 418 Wetherington Landing Rd., Stella, NC 28582
Proposed Project: To develop a 56 space campground. Associated with the campground would be
a 96 slip marina and kayak launch.
Please indicate below your agency's position or viewpoint on the proposed project and return this form by
November 14, 2018. If you have any questions regarding the proposed project, please contact Gregg
Bodnar, Permit officer at [phone]. When appropriate, in-depth comments with supporting data is
requested.
REPLY: This agency has no objection to the project as proposed.
agency has no comment on the proposed project.
I/ This agency approves of the project only if the recommended changes are
incorporated. See attached.
This agency objects to the project for reasons described in the attached comments.
SIGNED e���� G'` DATE i 21-;2
State of North Carolina I Environmental Quality 1. Coastal Management
Morehead City Office 1400 Commerce Avenue I Morehead City, NC 28557
2528082808

IJJ10170] ITAUZIIk%F
TO:
Gregg Bodnar, Assistant Major Permits Coordinator
FROM:
Shane Staples, Fisheries Resource Specialist
SUBJECT:
Robin Comer, Campground Development and Pier
DATE:
12/20/18
ROY COOPER
Governor
MICHAEL S. REGAN
STEPHEN W. MURPHEY
Utzcror
A North Carolina Division of Marine Fisheries (DMF) Fisheries Resource Specialist has reviewed the
subject permit application for proposed actions that impact fish and fish habitats. The applicant proposes
the development of land adjacent to the White Oak River near Stella, NC to construct a 56 space
campground with associated upland development as well as a 96 slip marina in the White Oak River to
service this development and the neighboring development also owned by the applicant. The White Oak
River is designated as a primary nursery area (PNA) by the Marine Fisheries Commission in the project
area. PNA's are areas deemed as critical to the survival and recruitment of larval and juvenile fish and
crustaceans. The project area is mostly shallow soft bottom habitat composed of soft and firm mud with
detritus which provides a prime foraging habitat for most of North Carolina's estuarine species at some
point during their life history. DMF has maintained two juvenile trawl sampling stations less than a half
of a mile upstream of this site. Consistently the stations have yielded high abundances of PNA indicator
species such as spot, croaker, southern flounder, and blue crabs; in the fall sampling of each year brown
shrimp show up in high abundance sometimes in numbers exceeding all other species sampled (NCDMF,
unpub. data).
Upon initial receipt and review of the project plan NCDMF requested modifications via email on 11/7/18
to portions of the project that may have led to an agency objection due to the potential for significant
negative impacts to critical PNA habitat. Original plans showed an observation platform at the most
waterward and deepest point of the marina and not the docking facilities. Revised marina plans received
on 12/3/18 show a main pier l Oft wide extending approximately 348 ft from the shoreline with 4 docking
piers 146 ft x 6 ft extending to the East and West. A 20 ft x 50 ft observation platform is located along the
main pier approximately 120ft from the shoreline. The approximate coverage area where docking and
boat activity would be expected is approximately 300 ft x 155 ft and the water depths in this area range
from -2.45 ft to -3.0 ft and normal water level. The updated plans have the 4 docking "t's" moved 23 ft
The updated plans from 12/3/18 also eliminated the proposed bulkhead behind coastal wetlands, that
already had a rip rap toe revetment, removing the Division's concerns over potential negative impacts to
the coastal wetlands for that portion of the project.
Initial concerns over the number of slips proposed and request to minimize habitat impacts have still not
been fully addressed in the most recent project design and NCDMF still has concerns over potential
negative impacts to shallow bottom habitat in the area due to the sheer size of the facility and the number
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of vessels that the facility could service in an area re water depths are marginal (-2.45 ft to -3.0 ft) for
such a development. As proposed the docking facility would have impacts on an area larger than a
football field in water designated as PNA habitat. Because the site is located in the upper White Oak
River, there will be a large increase in boat use in a sensitive and productive habitat area, and degradation
of nursery habitat from bottom disturbance and toxins from motorized vessel use is likely. Additionally,
the large footprint of the marina will impede public trust rights to fishing and navigation. The NCDMF
therefore objects to the project unless the docking facility is reduced in size in order to minimize habitat
impacts. Specifically, the NCDMF request the number of slips be reduced to no more than the number of
lots in the development (56) and that these slips be placed in the deepest water available to help prevent
prop kicking. Due to the seasonal and transient nature of campground residents a reduction of slips to less
that 56 is preferred. The applicant has also stated the neighboring facility has an agreement to have slips
at this facility, but the neighboring property already has water access via a private boat ramp on site and a
docking facility with permanent and transient docking available. The applicant states the width of the
marina doesn't allow for the facility to extend into the deepest water due to encroaching on the riparian
lines; a reduction in the number of slips could allow for a narrower design that may allow slips to be
water averaging closer to -3 ft. While stated in the application that each slip will have a boat lift
associated with it, NCDMF would like to emphasize the importance of the part of the development to
limiting PNA bottom impacts. Boat lifts in each slip would significantly reduce the potential for boats
repeatedly resting on or near the bottom during lunar and wind tides. In the event that construction is
phased, as suggested in applicant correspondence from 12/3/18, that may result in limited number of slips
being constructed due to the demand, NCDMF would request that the slips in the deepest water be
developed fust as they would have less potential for bottom impacts. The NCDMF stated concerns over
the potential sedimentation or shoaling that can occur around large docking facilities due to the changes in
current flow in an area and will reiterate that in this PNA habitat any future requests for dredging would
likely face objection due to the negative impacts to shallow bottom habitat that would result from such
activity.
Contact Shane Staples at [phone] or shane.staples( ,ncdem.gov with further questions or
concerns.
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