Gallants Channel Coalition

"Never doubt that a small group of thoughtful, committed citizens can change the world;
Indeed, it's the only thing that ever does." - Margaret Mead

Our Mission Statement: Gallants Channel Coalition is an alliance of organizations, businesses,
and citizens concerned with preserving the maritime heritage as well as protecting the tourism,
boatbuilding and maritime service industries in the town of Beaufort and Carteret County
Main Articles/Information  

NCDOT Vessel Height Survey Flawed

 

NCDOT has just completed a second vessel survey on Gallants Channel and is currently compiling the data for a second Vessel Height Survey Report to be presented to the Coast Guard. NCDOT is using this report to “negotiate” with the Coast Guard to allow them to build a 65 foot fixed span bridge. This report is being generated more than 5 years after the Coast Guard first informed NCDOT that a 65 foot fixed span bridge would not meet the current and future navigation requirements for Gallants Channel as required by federal law.

The recent 5 month survey was required by the Coast Guard to increase the sample period from the previous, grossly inadequate, 28 day sample period used in NCDOT’s first Vessel Height Survey Report (Gallants Channel Bridge Replacement Project Vessel Height Survey Report FINAL December 2012).

Unfortunately, this recent data collected in NCDOT’s 5 month survey is also insufficient to be used for a valid Coast Guard Vessel Height Survey Report for the following reasons:

  • The authorized navigation clearance for Gallants Channel was erroneously and illegally restricted to 67 feet during most of NCDOT’s 5 month sample period.

  • The sample period of 6 months is still insufficient to accurately measure the reasonable needs of navigation for Gallants Channel.

  • The method used for measuring mast heights is flawed – there is a gross margin of error in NCDOT’s calculation for mast heights.

  • The report does not meet the requirements for Navigational Evaluation put forth by the USCG BRIDGE PROGRAM REASONABLE NEEDS OF NAVIGATION WHITE PAPER Version 1.1, October 5, 2012

·

Erroneous and Illegal Authorized Navigation Clearance Restriction

 

In November 2012 the Army Core of Engineers abruptly changed the Authorized Navigation Clearance for Gallants Channel on all applicable navigation charts (charts 11541, 11545, and 11547).  This decision was based on an erroneous interpretation of federal regulation CFR 33 322.5. After several communications that ultimately involved Secretary of the Army John McHugh, it was determined that the Army Core of Engineers misinterpreted the regulation. On March 4th 2013, Secretary McHugh directed the Army Core of Engineers to withdraw the changes to the authorized clearance.  Click here to see Sec. Army Letter

In subsequent meetings with the Army Core of Engineers, it was determined that not only did the Army Core of Engineers misinterpret the regulation; they did not have authorization to change the Authorized Navigation Clearance in the first place. This apparently caused a “Catch 22” situation and the charts were not officially corrected until May 21st 2013 (Coast Guard 5th district - Local Notice to Mariners – Week 21/13).

Therefore, any vessel survey data collected during the period of December 2012 and May 21st 2013 is inadequate because vessels with heights 67 feet or more were illegally restricted from passing through Gallants Channel.

 

Navigation Survey Sample Period

 

The 5 month sample period to be used by NCDOT for their report is still inadequate for a proper Navigational Survey.

 In order to make one small change to a bridge opening schedule, the Coast Guard requires a detailed survey including 3 years of automotive traffic data. The purpose of this requirement is to protect the current needs of navigation. NCDOT is requesting to get a Coast Guard bridge permit for a fixed span bridge which will change the vertical clearance from unlimited to 65 feet and will permanently seal off a federal waterway for current and future maritime traffic. This drastic change should at least have the same 3 year waterway survey requirement as changing a single scheduled bridge opening.

The busiest times for tall masted vessels transiting Gallants Channel are spring, fall, and right before named storm events, at minimum, a maritime survey should include these sample periods.

 

Navigation Survey Data Flawed

 

The first survey report from NCDOT goes into great detail on the methodology and high tech equipment used to measure mast height. It all boils down to basic geometry. In order to accurately measure the mast height above the water, they need two very precise measurements, the angle from a fixed point to the top of the mast, and the distance from this point to the mast. Click here to see NCDOT survey report

 

The NCDOT Vessel Height Survey Report states that the Horizontal Distance used in the calculation was measured for each vessel that required a bridge opening. This is not true.

I talked to the engineer taking the samples and was told that they chose a fixed horizontal distance measured to the middle of the channel. I verified this with Kristine O’Connor, Project Manager for the Gallants Channel Bridge project. She stated that the horizontal distance could not be measured so they picked a point to the center of the railway piers. Click Here to see email from Project Manager

 

By using a fixed horizontal distance in the calculation, NCDOT is making an erroneous assumption that the mast of the vessel being measured is always in the center of the channel. Using a GIS map, I measured the distance between the railway piers as roughly 82 feet, so the midpoint would be 41 feet. It is not a reasonable assumption that a vessel’s mast would always be at the midpoint of the channel. Considering 2 way traffic and the fact that the channel does a dog-leg left at this point, it is conceivable that a vessel’s position would be off the midpoint of the channel by as much as +-20 feet or even +-25 feet.  Using NCDOT’s own calculations and varying the horizontal distance by 10, 20 and 25 feet you get substantial vessel height differences:

·         At an offset of +- 10 feet there is a difference of over +-2 feet in Vessel Elevation

·         At an offset of +- 20 feet there is a difference of over +-4 feet in Vessel Elevation

·         At an offset of +- 25 feet there is a difference of over +-5 feet in Vessel Elevation.

A good example of the probable error is SV Sans-Souci that transited Gallants Channel on November 13th  2012. NCDOT calculated the mast height at 64.8 feet and did not include it in their list of vessels that could not get under a 65 foot fixed span bridge. If this vessel was just 2 feet right of the center the calculated height jumps to 65.2 feet. There is no way to verify it because NCDOT did not include the owners name and contact information as required by the Coast Guard for vessel survey data.

For a more glaring example of the flawed method that NCDOT used to measure vertical vessel heights – just look at the NCDOT sample data for the Crystal Coast Lady in their first report. The Crystal Coast Lady was measured 28 times during NCDOT’s August 2012 sample period, the vertical heights reported using NCDOT’s measurements and calculation ranged from 29.23 feet to 45.81 feet a variation of 16.58 feet!

It appears that the method used by NCDOT to measure mast height is not valid. Without an accurate horizontal distance measurement the data obtained from the calculation is meaningless.

Navigation Survey Does not meet USCG Navigational Evaluation Requirements

 

The data vessel survey data collected by NCDOT does not appear to meet the requirements for Navigational Evaluation put forth by the USCG BRIDGE PROGRAM REASONABLE NEEDS OF NAVIGATION WHITE PAPER Version 1.1, October 5, 2012. Specifically, the NCDOT Survey does not comply with most of the requirements of the section defining Navigational Evaluations.Click Here to See USCG White Paper

 

In conclusion: This vessel survey being hastily done by NCDOT is a last minute attempt to change the prevailing decision of the Coast Guard on the bridge height requirements. The Coast Guard gave NCDOT a preliminary decision of 77 feet in May of 2012, based on over 4 years of investigation and data collection. The data currently being compiled by NCDOT was taken with illegal height restrictions imposed on Gallants Channel, an inadequate sample period, a flawed method to determine mast height, and the data not meet the Coast Guard requirements for a Navigational Survey.

 

 

Nelson Owens

Gallants Channel Coalition