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Home My WebLink AboutDMF commentThe Commonwealth of Massachusetts Division of Marine Fisheries (617) 626-1520 | www.mass.gov/marinefisheries MAURA T. HEALEY KIMBERLEY DRISCOLL REBECCA L. TEPPER THOMAS K. O’SHEA DANIEL J. MCKIERNAN Governor Lt. Governor Secretary Commissioner Director SOUTH COAST FIELD STATION CAT COVE MARINE LABORATORY NORTH SHORE FIELD STATION 836 S. Rodney French Blvd 92 Fort Avenue 30 Emerson Avenue New Bedford, MA 02744 Salem, MA 01970 Gloucester, MA 01930 April 24, 2024 Yarmouth Conservation Commission 1146 Route 28 South Yarmouth, MA 02664 Dear Commissioners: The Massachusetts Division of Marine Fisheries (MA DMF) has reviewed the Notice of Intent (NOI) by Cynthia Richards from the Great Island Homeowners Association to restore coastal dunes along 0 Great Island Road in the Town of Yarmouth. Emergency dune restoration activities took place in January 2024. Bulk bags of compatible sand and additional backfill sand were placed along the northern and southern stretch of the dunes. A total of 1,447 cubic yards of sand was placed over the north and south bulk bag arrays. The northern nourishment encompassed an area of 24,231 square feet and the southern nourishment encompassed a total area of 2,031 square feet. Bulk bags will serve as temporary erosion control measures for approximately two years while different adaptations are identified, designed, permitted, and constructed. During this time, additional cover over the bags is being requested up to 2 times per year to help maintain the longevity of the bags and suitable slopes for protected shorebirds. Maintenance may include repair of damaged bulk bags as necessary and nourishment of up to 2,090 cubic yards of beach-compatible sand up to twice per year to maintain the current dune profile. The project was reviewed with respect to potential impacts to marine fisheries resources and habitat. The subtidal areas abutting both nourishment zones have been mapped by the Massachusetts Department of Environmental Protection (MassDEP) as an eelgrass (Zostera marina) meadow. Eelgrass beds provide one of the most productive habitats for numerous marine species [1-2] and are designated “special aquatic sites” under the Federal Clean Water Act 404(b) (1) guidelines. Every effort should be made to avoid impacts to eelgrass. The project site lies within a horseshoe crab (Limulus polyphemus) spawning area and the species has been recorded nesting on Seagull Beach. Horseshoe crabs deposit their eggs in the upper intertidal regions of sandy beaches from late spring to early summer during spring high tides. Adult crabs congregate in deeper waters while they wait to spawn on nearby beaches at high tide. Eggs hatch approximately two to four weeks later. The 2019 benchmark stock 2 assessment indicates that the New England horseshoe crab stock status has shifted from poor to neutral [3]. Continued efforts should be made to protect the species and facilitate further stock improvement. MA DMF offers the following comments for your consideration: • In 2021 and 2022, MA DMF reviewed a similar nourishment project for the Great Island Road Resiliency Project during the NOI and MEPA phase of the permitting process. We maintain our concerns about eelgrass habitat and horseshoe crab spawning habitat in this area. • A time of year restriction should be observed to protect sensitive life stages of horseshoe crabs from sediment disposal activities on potential nesting beaches. Disposal of beach fill could bury and crush spawning adult crabs and nests; eggs in nests buried too deep may not hatch. No nourishment or beach construction activities should take place from May 1 – July 31 of any year [4]. • Any beach nourishment should be consistent with MassDEP’s Beach Nourishment Guide [5]. Beach fill material should be of appropriate slope to avoid premature loss from the beach and impacts to nearshore bottom habitat. • A planting and restoration plan should be developed for any dune grass areas that were buried during the emergency bulk sandbag and dune nourishment activities. • Eelgrass is sensitive to burial and light attenuation; as little as 2 to 4 cm of sedimentation has been shown to cause 70 to 90% mortality of eelgrass [6]. MA DMF recommends the proponent develop an eelgrass pre- and post-construction monitoring plan. The plan should be developed in consultation with state and federal resource agencies and should include detailed methods of eelgrass delineation as well as metrics and thresholds for identifying any project impacts on nearshore eelgrass beds (such as what parameters will be used and what thresholds will be considered representative of impacts). • The applicant should provide modeling estimates of the offshore migration and transport of nourishment material to provide an estimate of the potential impact of the proposed nourishment volume and footprint on nearshore eelgrass beds. • Construction equipment (e.g., excavator, delivery/dump truck) should be staged and operated upland of intertidal habitat to minimize impacts and avoid compaction of sediment. • Fuel spills from refueling of construction equipment will adversely impact sensitive resource areas. Impacts to resource areas can be avoided by prohibiting all land-based equipment from being refueled on-site. If equipment is refueled on-site, adequate containment and clean up material should be required to minimize impacts. Questions regarding this review may be directed to Amanda Davis at amanda.davis@mass.gov. Sincerely, 3 Amanda Davis Environmental Analyst MA Division of Marine Fisheries cc: Christ Gloninger, Woods Hole Group, Inc. John Logan, Malik Neron, Kara Falvey, Derek Perry, MA DMF Casaundra Healy, Yarmouth Shellfish Constable Patrice Bordonaro, CZM References: 1. Heck, K.L., Jr., T.J.B. Carruthers, C.M. Duarte, A.R. Hughes, G. Kendrick, R.J. Orth, and S.W. Williams. 2008. “Trophic transfers from seagrass meadows subsidize diverse marine and terrestrial consumers.” Ecosystems 11:1198-1210. https://doi.org/10.1007/s10021-008-9155-y 2. Jackson E.L., A.A. Rowden, M.J. Attrill, S.J. Bossey, and M.B. Jones. 2001. “The importance of seagrass beds as a habitat for fishery species.” Oceanography and Marine Biology: An Annual Review 39:269-303. https://www.academia.edu/2050183/The_importance_of_seagrass_beds_as_a_habitat_for _fishery_species 3. ASMFC. 2019. 2019 Horseshoe Crab Benchmark Stock Assessment and Peer Review Report. Prepared by the ASMFC Horseshoe Crab Stock Assessment Review Panel pursuant to NOAA Award No. NA15NMF4740069. http://www.asmfc.org/uploads/file/5cd5d6f1HSCAssessment_PeerReviewReport_May20 19.pdf 4. Evans, N.T., K.H. Ford, B.C. Chase, and J. Sheppard. 2011. Recommended Time of Year Restrictions (TOYs) for Coastal Alteration Projects to Protect Marine Fisheries Resources in Massachusetts. Massachusetts Division of Marine Fisheries Technical Report, TR-47. https://www.mass.gov/doc/time-of-year-recommendations-tr- 47/download 5. Haney, R., L. Kouloheras, V. Malkoski, J. Mahala, and Y. Unger. 2007. Beach Nourishment: MassDEP’s Guide to Best Management Practices for Projects in Massachusetts. https://www.mass.gov/doc/beach-nourishment-massdeps-guide-to-best- management-practices-for-projects-in-ma/download 6. Cabaço, S., R. Santos, and C.M. Duarte. 2008. “The impact of sediment burial and erosion on seagrasses: A review.” Estuarine, Coastal and Shelf Science 79(3):354-366. https://doi.org/10.1016/j.ecss.2008.04.021.