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HomeMy WebLinkAboutPeerReview_ReponseLetter_7-26-23 Engineers Environmental Scientists Software Developers Landscape Architects Planners Surveyors 349 Main Street, Route 28, Unit D / West Yarmouth, MA 02673 / 508-778-8919 July 26, 2023 Town of Yarmouth Conservation Commission 1146 Route 28 South Yarmouth, MA 02664 Attn: Brittany DiRienzo, Conservation Agent RE: Response to Greg Berman's 2023 Peer Review: Proposed Maintenance Dredging and Beach Nourishment at Crowell Beach, Crowell Beach Association, West Yarmouth, Massachusetts, BSC Job #50769.00 Dear Ms. DiRienzo and Members of the Conservation Commission: BSC Group, Inc. is pleased to submit this response to Greg Berman's 2023 peer review of the proposed maintenance dredge and beach nourishment project at Crowell Beach in West Yarmouth (the Site) on behalf of our client, the Crowell Beach Association c/o Carl Valeri. Greg Berman, a coastal processes specialist from Woods Hole Sea Grant and Cape Cod Cooperative Extension has reviewed a Notice of Intent Application filed with the Yarmouth Conservation Commission dated 3/30/2023 for proposed maintenance dredging and beach nourishment within the intertidal zone at Crowell Beach in West Yarmouth. Mr. Berman also completed a review of a similar proposal back in 2016. His more recent review Includes his findings from the 2016 proposal review. His recommendations from 2016 still apply with a few added considerations. Below we have listed Mr. Berman's recommendations/ considerations and our responses to them. Greg Berman's 2023 recommendations/ considerations: 1. If any nourishment (from dredging and/or upland sources) occurs, the Conservation Commission may way to require a monitoring plan that focuses on potential Impacts to the tidal creek and salt marsh. a. Response: No nourishment from upland sources will be used. Any nourishment sand will be dredged material. Dredge material from Crowell Beach will be used first and if more nourishment sand Is needed then only other clean dredged material will be used for beach nourishment. BSC Is happy to Include annual monitoring of the S ite. The applicants would like to dredge and nourish the beach annually (once a year). Prior to dredging and nourishing, a pre-dredge/pre-nourishment survey would be completed to determine how much material should be dredged to match the channel profile and the amount of sand needed to bring the beach back to the permitted profile. If more sand Is needed than is dredged to bring the beach up to the permitted profile, then the applicants would find compatible beach sand that Is available from another dred ge project. BSC can also photo document the tidal creek and channel to monitor these areas. 2. While a beach profile was added to the site plans (revised 6/28/2023), there Is still no Information on the plans or project narrative as to two very Important aspects of this project: (1) How often does 349 Main Street, Route 28, Unit D / West Yarmouth, MA 02673 / 508-778-8919 the applicant desire to dredge the creek and apply the material as beach nourishment? (2) The desired volume and frequency of beach nourishment to be "trucked in". a. Response: As mentioned above the applicant would like to dredge the channel and nourish the beach once annually. The desired volume of beach nourishment to be "trucked in" would be whatever Is needed to bring the existing beach profile back up to the permitted beach profile. The volume would be dependent on how much sand Is needed based on the pre-nourishment survey. Again, the "trucked in" sand would still be clean dredged material and not from upland sources. 3. Any new sediment (I.e., the "trucked in" volume) to the area has the potential to create negative Impacts by migrating into the creek and marsh. Even the dredge sediment used for beach nourishment may be transported more quickly than natural processes, but with much fewer potential Impacts than new sediment being added to the system. a. Response: When nourishing the beach, we will start by using the dredged material from the creek. If additional sediment Is needed to be "trucked in" then this sediment will also be clean dredge material and only placed in the location at the end of the road (above the high tide line). The sediment will not be from upland sources. By starting with the dredged material from the creek this will minimize and possibly eliminate the need to "trucked in" material. 4. The site plans do not Indicate the date of topographic data. The existing conditions may be very different and new topographic data might need to be collected. a. Response: Prior to any dredging and beach nourishment a pre-dredge survey and pre- nourishment survey would be completed to determine the volume of sand to be dredged and volume of sand needed for beach nourishment. Therefore, new topographic data would be collected prior to each dredging and nourishment event. Greg Berman's 2016 recommendations/ considerations: 1. The site plans (dated 10/18/16) use topographic data from 07/11/16. The existing conditions on 11/03/16 are very different from 07/11/16 and new topographic data might need to be collected. It Is possible that the nourishment material Is proposed to fill the channel right now. This could push the channel further north and lead to erosion at Parcel 72, or the channel might erode the places sediment much faster than anticipated. a. Response: As mentioned above, BSC would perform a pre-dredge and pre-nourishment survey to determine the volume of sediment to be dredged and volume of sediment required to bring the beach profile back up to the permitted profile. Therefore, new topographic data would be collected prior to each dredging and nourishment event. Mr. Berman states that not dredging the channel could lead to erosion at parcel 72. The proposed project will protect this parcel from erosion by maintaining the channel location away from the stone revetment wall bank. This project is being proposed annually which will maintain protection to Parcel 72. 2. There Is already sand being transported north onto wetland vegetation and into the tidal creek. If winds and waves occur from the west there Is chance that some of the proposed nourishment may be transported to this area, potentially plugging up the channel and affecting over 6 acres of wetlands. a. Response: By annually performing maintenance dredging of the tidal creek this will help ensure that that channel does not get plugged up as Mr. Berman mentions Is a possibility. There are 6 acres of wetlands upstream of the tidal creek Inlet and If the tidal creek ever plugged up, those six acres of wetlands could be seriously Impacted. If the channel is plugged up, then no tidal waters would be able to enter/exit the six acres of wetlands which would also surely have major Impacts on the vegetation and biology living in those six acres of wetlands. 349 Main Street, Route 28, Unit D / West Yarmouth, MA 02673 / 508-778-8919 3. There Is currently sediment coming from the southeast into the site. If you want to keep the Inlet In a fixed position, you'll need to keep dredging the Inlet to "reset the timer" on channel meander. If the channel could be dredged deeper or if a trap could be dredged on the southeast side of the channel It might prolong the time between dredging events. a. The applicant proposed to dredge the channel annually to keep the channel in a somewhat fixed position over time. By dredging annually, we will "reset the timer" on channel meander annually. We are not proposing to dredge the channel deeper or to dredge a trap on the southeast side of the channel. This would require improvement dredging beyond the previously approved footprint, which would void the existing approved chapter 91 dredge permit. 4. This site would be best managed cooperatively. Dredging of the Inlet could be performed in conjunction with beach nourishment. With a larger project, and high beach, the channel might last longer in the desired location. Dredged sand Is likely much cheaper and more compatible to the beach than sand from an upland site. a. This Is exactly what we are proposing to do; manage the site cooperatively and perform the dredging in conjunction with the beach nourishment. We are no longer proposing to have beach nourishment come from upland sources. Only clean dredge material would be used as beach nourishment. The association has teamed up with the new homeowner to better manage the site as recommended by Mr. Berman. Please review this response letter and let me know if you have any questions or require additional information at (508) 778 - 8919. Sincerely, BSC GROUP, INC. Paul Mancuso, WPIT Wetland Scientist cc: Crowell Beach Association c/o Carl Valeri, 47 Crowell Road, West Yarmouth, 02673 Division of Marine Fisheries, Southeast Marine Fisheries Station, Attn: Environmental Reviewer, 836 South Rodney French Blvd, New Bedford, MA 02744 Massachusetts Department of Environmental Protection, Southeast Regional Office, 20 Riverside Drive, Lakeville, MA 02347 Yarmouth Waterways Committee, Attn: Karl van Hone, Director of Natural Resources, 424 Route 28, West Yarmouth, MA 02744