Loading...
HomeMy WebLinkAboutCorrespondence on updated plan 4.29.2021 Grant, Kelly From:Grant, Kelly Sent:Thursday, April 29, 2021 3:15 PM To:Daniel A. Ojala, PE PLS Cc:'Priscilla Leclerc' Subject:71 Smiths Point Road SE83-2277 Hi Dan I am reviewing the revised plan before issuing the Order for this project and I still have concerns with the labeling of the coastal dune. I have reviewed the previous material prepared by Horsley and Witten and have the following comments: 1. The H&W delineation is from 2000. The methodology and guidance from the state has changed since this delineation was done. This doesn’t mean it needs to be revisited at this time but I think clarification is needed based on the current methodology. 2. Your primary dune ‘landward limit’ line is unlabeled on the old plan and I doubt that this is actually the landward limit of the primary dune given that it is at the highest elevation point in some places. 3. Based on the regulatory definition and guidance provided in the state’s Coastal Resource Area Manual I believe the primary dune landward limit more closely follows the landward limit of the VE zone line. This is actually seaward of the delineated line is some sections, in the low point between the dunes. This make a lot more sense. 4. The H&W report states: “The resulting inland boundary of the coastal dune is shown on the plan. Coastal Dunes include both primary and secondary dune systems.” I believe that they show just the landward limit of the coastal dunes as one line. I agree with that line as it is shown on the plan. 5. You mentioned that there is upland vegetation which indicates a change from dune to upland. The coastal manual states: Vegetation on back dunes could consist of typical dune vegetation, varying from beach grass to beach plum (Prunus maritima), or more complex and dense upland plants, varying from shrub growth to low forests, such as maritime forests. The secondary dunes may have more upland vegetation and still be considered part of the regulatory dunes. 6. The H&W report refers to the secondary dunes as regulatory dunes but considered them to be less significant to the interests of the regulations, which allowed the previous project to proceed in this location. I agree with this assessment and believe that it also applies to this project to the extent that the proposed work is within the buffer zone to a secondary dune. 7. So, based on this information I suggest the following plan corrections: a. Remove the landward limit of the primary dune – this not considered accurate and is not necessary for this project. b. Leave the VE zone line on the plan as it approximates the landward extent of the primary dune c. Re-label the “relic dune landward limit” line as “landward limit of coastal dune (secondary dune)” d. Leave the reference to Primary Dune area (as indicated by the curving arrows) but change the Relic Dune Area label to Secondary Dune Area. With these changes I will issue the Order of Conditions. Thanks Kelly Grant Conservation Administrator Town of Yarmouth 508-398-2231 Ext 1288 1