HomeMy WebLinkAboutNOI 8.7.2025Yarmouth Conservation Commission • 1146 Route 28 South Yarmouth, MA 02664-4492
Tel. (508)-398-2231 Ext. 1288
Rev 6/2025 Page 1 of 2
Administrative Checklist
Notice of Intent
General Information:
All filings must be made on Town of Yarmouth forms. The filing deadline is two weeks prior to the next
scheduled Conservation Commission meeting for new applications. Failure to follow this Checklist shall
result in an Administratively Incomplete Application and will not be advertised for a Public Hearing. Refer to
the meeting schedule. Contact the Conservation Office if you need assistance.
Submitting an Application:
Does the property have any outstanding/expired Orders of Conditions? If so, please file a Request
for Certificate of Compliance for each outstanding/expired Order, as the Commission may not issue a
new Order until any outstanding/expired Orders have been closed and recorded. (*see page 2)
Hardcopy filing dropped off or mailed to the Conservation Office including:
1 Administrative Checklist
1 complete NOI application WPA form 3 with original signatures. Typed signatures will not be accepted.
Detailed narrative of the project including existing & proposed conditions, construction sequence, type of
equipment, staging locations, drainage and stormwater, erosion controls, invasive species management
and alternative analysis. The narrative shall include how the project meets performance standards per
310 CMR 10.0 & TOY Wetland Regulations, delineation sheets (if BVW or vegetated wetlands are
present) or other resource area calculations, and supporting information.
1 100’ radius map, current abutters list identifying the property owners who are to be notified per 310
CMR 10.00 and abutter notification form. Abutters list must be certified by the Town Assessor’s office.
The Assessor’s office requires 7 days advance notice. All abutters must be notified via certified mail.
Certified Mail Receipts (PS Form 3800) for all abutters. Green cards to be submitted at the hearing.
1 original and 7 copies of the plan, folded separately, right side out with title and project address visible.
All plans shall reference NAVD1988 unless otherwise noted. See plan requirements
Yarmouth’s share of State filing fee: Separate check made payable to “Town of Yarmouth”
(refer to NOI Wetland Fee Transmittal Form)
By-law filing fee: Separate check made payable to “Town of Yarmouth”
Legal ad fee: Separate check made payable to “Town of Yarmouth”
Please list project property’s street address on checks. Refer to Fee Schedule
DEP share of the fee (refer to NOI form) shall be sent to: Dept. of Environmental Protection
Box 4062
Boston, MA 02211
CONSERVATION
OFFICE
N/A
Yarmouth Conservation Commission • 1146 Route 28 South Yarmouth, MA 02664-4492
Tel. (508)-398-2231 Ext. 1288
Rev 6/2025 Page 2 of 2
DEP Submittal and Digital filing
If you are filing with MassDEP using eDEP, please include a copy of the submittal confirmation with your
application.
If not filing via eDEP, a PDF of your application, plan, and all other supporting information must be sent
VIA EMAIL the same day to DEP, Southeast Region at SERO_NOI@mass.gov with the subject line in
the email per DEP’s request listed as “YARMOUTH - NOI - Street Address - Applicant Name” and
copied bdirienzo@yarmouth.ma.us and jjerolimo@yarmouth.ma.us. We must receive a copy of
this email with the application as proof that it has been submitted to DEP.
Initial below
I CERTIFY that all on-site requirements will be completed by noon on the Friday prior to the hearing
date. All proposed structures must be staked, and all relevant resource areas and buffer zones must be
staked or flagged.
Please consult the Yarmouth Wetland Regulations, page 17. Without proper staking your project may be
deemed incomplete and be continued to the next hearing date.
I understand that in person representation is required at the scheduled hearing to present to the
conservation commission
If Applicable
Certified Mail Receipt for Massachusetts Natural Heritage and Endangered Species Program
Certified Mail Receipt for Massachusetts Division of Marine Fisheries. If filing via email, CC
bdirienzo@yarmouth.ma.us and jjerolimo@yarmouth.ma.us
Waterway’s jurisdiction – Any coastal projects such as, but not limited to, docks, piers, bulkheads,
revetments, dredging and boardwalks shall require submittal of all Notice of Intent, plans and
supplemental information to the Town of Yarmouth Waterways/Shellfish Committee via the Natural
Resources office by certified mail or hand delivery. The applicant or his/her representative must provide
the Conservation office with proof that this has been done or the filing will not be accepted.
Other Requirements
o Does the proposed project meet the applicable regulations of the Town of Yarmouth Zoning bylaws? Do
you need to file with the Yarmouth Board of Appeals? If so, you must file with ZBA after conservation
permitting is completed.
o If a vacant lot, have you completed and received a determination for the Building Department for a lot
inquiry form?
*To view all Conservation files/permits for the property address online, go to www.yarmouth.ma.us/LF
N/A
N/A
N/A
N/A
wpaform3.doc • rev. 12/4/2023 Page 1 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
Important:
When filling out
forms on the
computer, use
only the tab key
to move your
cursor - do not
use the return
key.
Note:
Before
completing this
form consult
your local
Conservation
Commission
regarding any
municipal bylaw
or ordinance.
A. General Information
1. Project Location (Note: electronic filers will click on button to locate project site):
27 Aunt Edith's Road
a. Street Address
South Yarmouth
b. City/Town
02664
c. Zip Code
Latitude and Longitude: 41.657955
d. Latitude
-70.191526
e. Longitude
51
f. Assessors Map/Plat Number
97
g. Parcel /Lot Number
2. Applicant:
Lance
a. First Name
Willsey
b. Last Name
N/A
c. Organization
1 Newbrook Circle
d. Street Address
Chestnut Hill
e. City/Town
MA
f. State
02167
g. Zip Code
(617) 413-6333
h. Phone Number
N/A
i. Fax Number
lancedwillsey@gmail.com
j. Email Address
3. Property owner (required if different from applicant): Check if more than one owner
a. First Name
b. Last Name
c. Organization
d. Street Address
e. City/Town
f. State
g. Zip Code
h. Phone Number
i. Fax Number
j. Email address
4. Representative (if any):
Dillon
a. First Name
Lance
b. Last Name
Crawford Land Management
c. Company
88 Route 6A, Suite 2B
d. Street Address
Sandwich
e. City/Town
MA
f. State
02563
g. Zip Code
(508) 477-1346
h. Phone Number
N/A
i. Fax Number
dillon@crawfordlm.com
j. Email address
5. Total WPA Fee Paid (from NOI Wetland Fee Transmittal Form):
$610
a. Total Fee Paid
$292.50
b. State Fee Paid
$317.50
c. City/Town Fee Paid
wpaform3.doc • rev. 12/4/2023 Page 2 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
A. General Information (continued)
6. General Project Description:
The project proposes installing a fiber roll array on a coastal bank and restoration plantings. The
existing stairs will be replaced by a raised set of steps, and portions of the patio that are damaged will
be repaired.
7a. Project Type Checklist: (Limited Project Types see Section A. 7b.)
1. Single Family Home 2. Residential Subdivision
3. Commercial/Industrial 4. Dock/Pier
5. Utilities 6. Coastal engineering Structure
7. Agriculture (e.g., cranberries, forestry) 8. Transportation
9. Other
7b. Is any portion of the proposed activity eligible to be treated as a limited project (including Ecological
Restoration Limited Project) subject to 310 CMR 10.24 (coastal) or 310 CMR 10.53 (inland)?
1. Yes No If yes, describe which limited project applies to this project. (See 310 CMR
10.24 and 10.53 for a complete list and description of limited project types)
2. Limited Project Type
If the proposed activity is eligible to be treated as an Ecological Restoration Limited Project (310
CMR10.24(8), 310 CMR 10.53(4)), complete and attach Appendix A: Ecological Restoration Limited
Project Checklist and Signed Certification.
8. Property recorded at the Registry of Deeds for:
Barnstable
a. County
b. Certificate # (if registered land)
25265
c. Book
0042
d. Page Number
B. Buffer Zone & Resource Area Impacts (temporary & permanent)
1. Buffer Zone Only – Check if the project is located only in the Buffer Zone of a Bordering
Vegetated Wetland, Inland Bank, or Coastal Resource Area.
2. Inland Resource Areas (see 310 CMR 10.54-10.58; if not applicable, go to Section B.3,
Coastal Resource Areas).
Check all that apply below. Attach narrative and any supporting documentation describing how the
project will meet all performance standards for each of the resource areas altered, including
standards requiring consideration of alternative project design or location.
wpaform3.doc • rev. 12/4/2023 Page 3 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
B. Buffer Zone & Resource Area Impacts (temporary & permanent) (cont’d)
For all projects
affecting other
Resource Areas,
please attach a
narrative
explaining how
the resource
area was
delineated.
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
a. Bank
1. linear feet
2. linear feet
b. Bordering Vegetated
Wetland
1. square feet
2. square feet
c. Land Under
Waterbodies and
Waterways
1. square feet
2. square feet
3. cubic yards dredged
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
d. Bordering Land
Subject to Flooding
1. square feet
2. square feet
3. cubic feet of flood storage lost
4. cubic feet replaced
e. Isolated Land
Subject to Flooding
1. square feet
2. cubic feet of flood storage lost
3. cubic feet replaced
f. Riverfront Area Bass River - Coastal
1. Name of Waterway (if available) - specify coastal or inland
2. Width of Riverfront Area (check one):
25 ft. - Designated Densely Developed Areas only
100 ft. - New agricultural projects only
200 ft. - All other projects
3. Total area of Riverfront Area on the site of the proposed project: 34,650
square feet
4. Proposed alteration of the Riverfront Area:
1,432
a. total square feet
1,432
b. square feet within 100 ft.
0
c. square feet between 100 ft. and 200 ft.
5. Has an alternatives analysis been done and is it attached to this NOI? Yes No
6. Was the lot where the activity is proposed created prior to August 1, 1996? Yes No
3. Coastal Resource Areas: (See 310 CMR 10.25-10.35)
Note: for coastal riverfront areas, please complete Section B.2.f. above.
wpaform3.doc • rev. 12/4/2023 Page 4 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
B. Buffer Zone & Resource Area Impacts (temporary & permanent) (cont’d)
Check all that apply below. Attach narrative and supporting documentation describing how the
project will meet all performance standards for each of the resource areas altered, including
standards requiring consideration of alternative project design or location.
Online Users:
Include your
document
transaction
number
(provided on
your receipt
page) with all
supplementary
information you
submit to the
Department.
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
a. Designated Port Areas Indicate size under Land Under the Ocean, below
b. Land Under the Ocean
1. square feet
2. cubic yards dredged
c. Barrier Beach Indicate size under Coastal Beaches and/or Coastal Dunes below
d. Coastal Beaches 375
1. square feet
21
2. cubic yards beach nourishment
e. Coastal Dunes
1. square feet
2. cubic yards dune nourishment
Size of Proposed Alteration Proposed Replacement (if any)
f. Coastal Banks 85
1. linear feet
g. Rocky Intertidal
Shores
1. square feet
h. Salt Marshes
1. square feet
2. sq ft restoration, rehab., creation
i. Land Under Salt
Ponds
1. square feet
2. cubic yards dredged
j. Land Containing
Shellfish
1. square feet
k. Fish Runs Indicate size under Coastal Banks, inland Bank, Land Under the
Ocean, and/or inland Land Under Waterbodies and Waterways,
above
1. cubic yards dredged
l. Land Subject to
Coastal Storm Flowage
1. square feet
4. Restoration/Enhancement
If the project is for the purpose of restoring or enhancing a wetland resource area in addition to the
square footage that has been entered in Section B.2.b or B.3.h above, please enter the additional
amount here.
a. square feet of BVW
b. square feet of Salt Marsh
5. Project Involves Stream Crossings
a. number of new stream crossings
b. number of replacement stream crossings
wpaform3.doc • rev. 12/4/2023 Page 5 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
C. Other Applicable Standards and Requirements
This is a proposal for an Ecological Restoration Limited Project. Skip Section C and
complete Appendix A: Ecological Restoration Limited Project Checklists – Required Actions
(310 CMR 10.11).
Streamlined Massachusetts Endangered Species Act/Wetlands Protection Act Review
1. Is any portion of the proposed project located in Estimated Habitat of Rare Wildlife as indicated on
the most recent Estimated Habitat Map of State-Listed Rare Wetland Wildlife published by the Natural
Heritage and Endangered Species Program (NHESP)? To view habitat maps, see the Massachusetts
Natural Heritage Atlas or go to http://maps.massgis.state.ma.us/PRI_EST_HAB/viewer.htm.
a. Yes No If yes, include proof of mailing or hand delivery of NOI to:
Natural Heritage and Endangered Species Program
Division of Fisheries and Wildlife
1 Rabbit Hill Road
Westborough, MA 01581
2021
b. Date of map
If yes, the project is also subject to Massachusetts Endangered Species Act (MESA) review (321
CMR 10.18). To qualify for a streamlined, 30-day, MESA/Wetlands Protection Act review, please
complete Section C.1.c, and include requested materials with this Notice of Intent (NOI); OR complete
Section C.2.f, if applicable. If MESA supplemental information is not included with the NOI, by
completing Section 1 of this form, the NHESP will require a separate MESA filing which may take up
to 90 days to review (unless noted exceptions in Section 2 apply, see below).
c. Submit Supplemental Information for Endangered Species Review∗
1. Percentage/acreage of property to be altered:
(a) within wetland Resource Area
percentage/acreage
(b) outside Resource Area
percentage/acreage
2. Assessor’s Map or right-of-way plan of site
2. Project plans for entire project site, including wetland resource areas and areas outside of
wetlands jurisdiction, showing existing and proposed conditions, existing and proposed
tree/vegetation clearing line, and clearly demarcated limits of work ∗∗
(a) Project description (including description of impacts outside of wetland resource area &
buffer zone)
(b) Photographs representative of the site
∗ Some projects not in Estimated Habitat may be located in Priority Habitat, and require NHESP review (see https://www.mass.gov/ma-
endangered-species-act-mesa-regulatory-review).
Priority Habitat includes habitat for state-listed plants and strictly upland species not protected by the Wetlands Protection Act.
∗∗ MESA projects may not be segmented (321 CMR 10.16). The applicant must disclose full development plans even if such plans are
not required as part of the Notice of Intent process.
wpaform3.doc • rev. 12/4/2023 Page 6 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
C. Other Applicable Standards and Requirements (cont’d)
(c) MESA filing fee (fee information available at https://www.mass.gov/how-to/how-to-file-for-
a-mesa-project-review).
Make check payable to “Commonwealth of Massachusetts - NHESP” and mail to NHESP at
above address
Projects altering 10 or more acres of land, also submit:
(d) Vegetation cover type map of site
(e) Project plans showing Priority & Estimated Habitat boundaries
(f) OR Check One of the Following
1. Project is exempt from MESA review.
Attach applicant letter indicating which MESA exemption applies. (See 321 CMR 10.14,
https://www.mass.gov/service-details/exemptions-from-review-for-projectsactivities-in-
priority-habitat; the NOI must still be sent to NHESP if the project is within estimated
habitat pursuant to 310 CMR 10.37 and 10.59.)
2. Separate MESA review ongoing.
a. NHESP Tracking #
b. Date submitted to NHESP
3. Separate MESA review completed.
Include copy of NHESP “no Take” determination or valid Conservation & Management
Permit with approved plan.
3. For coastal projects only, is any portion of the proposed project located below the mean high water
line or in a fish run?
a. Not applicable – project is in inland resource area only b. Yes No
If yes, include proof of mailing, hand delivery, or electronic delivery of NOI to either:
South Shore - Bourne to Rhode Island border, and
the Cape & Islands:
Division of Marine Fisheries -
Southeast Marine Fisheries Station
Attn: Environmental Reviewer
836 South Rodney French Blvd.
New Bedford, MA 02744
Email: dmf.envreview-south@mass.gov
North Shore - Plymouth to New Hampshire border:
Division of Marine Fisheries -
North Shore Office
Attn: Environmental Reviewer
30 Emerson Avenue
Gloucester, MA 01930
Email: dmf.envreview-north@mass.gov
Also if yes, the project may require a Chapter 91 license. For coastal towns in the Northeast Region,
please contact MassDEP’s Boston Office. For coastal towns in the Southeast Region, please contact
MassDEP’s Southeast Regional Office.
c. Is this an aquaculture project? d. Yes No
If yes, include a copy of the Division of Marine Fisheries Certification Letter (M.G.L. c. 130, § 57).
wpaform3.doc • rev. 12/4/2023 Page 7 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
C. Other Applicable Standards and Requirements (cont’d)
Online Users:
Include your
document
transaction
number
(provided on
your receipt
page) with all
supplementary
information you
submit to the
Department.
4. Is any portion of the proposed project within an Area of Critical Environmental Concern (ACEC)?
a. Yes No If yes, provide name of ACEC (see instructions to WPA Form 3 or MassDEP
Website for ACEC locations). Note: electronic filers click on Website.
b. ACEC
5. Is any portion of the proposed project within an area designated as an Outstanding Resource Water
(ORW) as designated in the Massachusetts Surface Water Quality Standards, 314 CMR 4.00?
a. Yes No
6. Is any portion of the site subject to a Wetlands Restriction Order under the Inland Wetlands
Restriction Act (M.G.L. c. 131, § 40A) or the Coastal Wetlands Restriction Act (M.G.L. c. 130, § 105)?
a. Yes No
7. Is this project subject to provisions of the MassDEP Stormwater Management Standards?
a. Yes. Attach a copy of the Stormwater Report as required by the Stormwater Management
Standards per 310 CMR 10.05(6)(k)-(q) and check if:
1. Applying for Low Impact Development (LID) site design credits (as described in
Stormwater Management Handbook Vol. 2, Chapter 3)
2. A portion of the site constitutes redevelopment
3. Proprietary BMPs are included in the Stormwater Management System.
b. No. Check why the project is exempt:
1. Single-family house
2. Emergency road repair
3. Small Residential Subdivision (less than or equal to 4 single-family houses or less than
or equal to 4 units in multi-family housing project) with no discharge to Critical Areas.
D. Additional Information
This is a proposal for an Ecological Restoration Limited Project. Skip Section D and complete
Appendix A: Ecological Restoration Notice of Intent – Minimum Required Documents (310 CMR
10.12).
Applicants must include the following with this Notice of Intent (NOI). See instructions for details.
Online Users: Attach the document transaction number (provided on your receipt page) for any of
the following information you submit to the Department.
1. USGS or other map of the area (along with a narrative description, if necessary) containing
sufficient information for the Conservation Commission and the Department to locate the site.
(Electronic filers may omit this item.)
2. Plans identifying the location of proposed activities (including activities proposed to serve as a
Bordering Vegetated Wetland [BVW] replication area or other mitigating measure) relative to
the boundaries of each affected resource area.
wpaform3.doc • rev. 12/4/2023 Page 8 of 9
4
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
South Yarmouth
City/Town
D.Additional Information (cont’d)
3. Identify the method for BVW and other resource area boundary delineations (MassDEP BVW
Field Data Form(s), Determination of Applicability, Order of Resource Area Delineation, etc.),
and attach documentation of the methodology.
4. List the titles and dates for all plans and other materials submitted with this NOI.
Shoreline Stabilization & Restoration Plan
a.Plan Title
Crawford Land Management
b. Prepared By
Jen Crawford
c.Signed and Stamped by
8-5-2025
d.Final Revision Date
1"=10'
e.Scale
Existing Conditions Plan
f. Additional Plan or Document Title
3-7-2025
g.Date
5. If there is more than one property owner, please attach a list of these property owners not
listed on this form.
6. Attach proof of mailing for Natural Heritage and Endangered Species Program, if needed.
7. Attach proof of mailing for Massachusetts Division of Marine Fisheries, if needed.
8. Attach NOI Wetland Fee Transmittal Form
9. Attach Stormwater Report, if needed.
E.Fees
1. Fee Exempt: No filing fee shall be assessed for projects of any city, town, county, or district
of the Commonwealth, federally recognized Indian tribe housing authority, municipal housing
authority, or the Massachusetts Bay Transportation Authority.
Applicants must submit the following information (in addition to pages 1 and 2 of the NOI Wetland Fee
Transmittal Form) to confirm fee payment:
001259
2.Municipal Check Number
8/6/2025
3.Check date
001262
4.State Check Number
8/6/2025
5.Check date
Jennifer
6.Payor name on check: First Name
Crawford
7.Payor name on check: Last Name
noifeetf.doc • Wetland Fee Transmittal Form • rev. 10/11 Page 1 of 2
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands
NOI Wetland Fee Transmittal Form
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Important: When
filling out forms
on the computer,
use only the tab
key to move your
cursor - do not
use the return
key.
A. Applicant Information
1. Location of Project:
27 Aunt Edith's Road
a. Street Address
South Yarmouth
b. City/Town
c. Check number
d. Fee amount
2. Applicant Mailing Address:
Lance
a. First Name
Willsey
b. Last Name
N/A
c. Organization
1 Newbrook Circle
d. Mailing Address
Chestnut Hill
e. City/Town
MA
f. State
02167
g. Zip Code
(617) 413-6333
h. Phone Number
N/A
i. Fax Number
lancedwillsey@gmail.com
j. Email Address
3. Property Owner (if different):
a. First Name
b. Last Name
c. Organization
d. Mailing Address
e. City/Town
f. State
g. Zip Code
h. Phone Number
i. Fax Number
j. Email Address
To calculate
filing fees, refer
to the category
fee list and
examples in the
instructions for
filling out WPA
Form 3 (Notice of
Intent).
B. Fees
Fee should be calculated using the following process & worksheet. Please see Instructions before
filling out worksheet.
Step 1/Type of Activity: Describe each type of activity that will occur in wetland resource area and buffer zone.
Step 2/Number of Activities: Identify the number of each type of activity.
Step 3/Individual Activity Fee: Identify each activity fee from the six project categories listed in the instructions.
Step 4/Subtotal Activity Fee: Multiply the number of activities (identified in Step 2) times the fee per category
(identified in Step 3) to reach a subtotal fee amount. Note: If any of these activities are in a Riverfront Area in
addition to another Resource Area or the Buffer Zone, the fee per activity should be multiplied by 1.5 and then
added to the subtotal amount.
Step 5/Total Project Fee: Determine the total project fee by adding the subtotal amounts from Step 4.
Step 6/Fee Payments: To calculate the state share of the fee, divide the total fee in half and subtract $12.50. To
calculate the city/town share of the fee, divide the total fee in half and add $12.50.
noifeetf.doc • Wetland Fee Transmittal Form • rev. 10/11 Page 2 of 2
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands
NOI Wetland Fee Transmittal Form
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
B. Fees (continued)
Step 1/Type of Activity Step 2/Number
of Activities
Step
3/Individual
Activity Fee
Step 4/Subtotal Activity
Fee
1A
1
$110
$110
2C
1
$500
$500
Step 5/Total Project Fee: $610
Step 6/Fee Payments:
Total Project Fee: $610
a. Total Fee from Step 5
State share of filing Fee: $292.50
b. 1/2 Total Fee less $12.50
City/Town share of filling Fee: $317.50
c. 1/2 Total Fee plus $12.50
C. Submittal Requirements
a.) Complete pages 1 and 2 and send with a check or money order for the state share of the fee, payable to
the Commonwealth of Massachusetts.
Department of Environmental Protection
Box 4062
Boston, MA 02211
b.) To the Conservation Commission: Send the Notice of Intent or Abbreviated Notice of Intent; a copy of
this form; and the city/town fee payment.
To MassDEP Regional Office (see Instructions): Send a copy of the Notice of Intent or Abbreviated Notice of
Intent; a copy of this form; and a copy of the state fee payment. (E-filers of Notices of Intent may submit these
electronically.)
51/ 94/ / /
WESTMORELAND ROSAMOND W TR
ROSAMOND WESTMORELAND FAMILY
TRU
565 WEST END AVE
APT 15C
NEW YORK, NY 10024
51/ 95/ / /
GATTO STEPHEN
29 ROYAL COURT
NORWOOD, MA 02062
51/ 97/ / /
WILLSEY LANCE
WILLSEY PAMELA J
1 NEWBROOK CIR
CHESTNUT HILL, MA 02167
51/ 98/ / /
WILSCHUT ROY TR
ROY WILSCHUT REV LVG TRUST
20172 SE BRIDGEWATER DR
JUPITER, FL 33458
51/ 96/ / /
AUNT EDITH'S RD ASSOC INC
C/O HOLLY BRODERICK
1 AUNT EDITHS RD
SOUTH YARMOUTH, MA 02664
51/ 102.2/ / /
STADTLER JOHN W
STADTLER SUZANNE M
1080 NORTH ST
WALPOLE, MA 02081
51/ 102.1/ / /
HAGGERTY MARK
RUSSO-HAGGERTY JEANNE
85 COLTS CROSSING
CANTON, MA 02021
Please use this signature to certify this list of propertiesabutting within 100' of the parcel located at:27 Aunt Ediths Rd., South Yarmouth, MA 02664Assessors Map 51, Lot 97______________________________________Andy Machado, Director of AssessingJuly 23, 2025
NOTIFICATION TO ABUTTERS UNDER THE
MASSACHUSETTS WETLANDS PROTECTION ACT &
TOWN OF YARMOUTH WETLAND BY-LAW, CHAPTER 143
In accordance with the second paragraph of the Massachusetts General Laws Chapter 131, Section 40,
you are hereby notified of the following:
A. The name of the applicant is: Lance & Pamela Willsey
B. The applicant has filed a Notice of Intent with the Yarmouth Conservation Commission, seeking
permission to remove, fill, dredge or alter an Area Subject to Protection under the Wetlands
Protection Act (MGL c. 131 s. 40 & Town of Yarmouth Wetland By-Law, Chapter 143).
C. The address of the lot where the activity is proposed is: 27 Aunt Ediths Road, South Yarmouth,
MA 02664
D. Proposed work is: Installation of a fiber roll array, repair of slumping portion of patio,
replacement of existing stairs, and associated restoration work. Walkway to the dock behind
the property will not be impacted under this permit.
E. Copies of the Notice of Intent may be examined at the Yarmouth Town Hall at the Conservation
Commission office between the hours of 9:00 a.m. and 4:00 p.m. Monday thru Friday. For more
information, call (508) 398-2231 ext. 1288.
F. Copies of the Notice of Intent may be obtained from either the applicant or applicant’s
representative. Applicant’s phone number: 508-280-9212
Or Applicant’s representatives phone number: 508-477-1346
G. Information regarding the date, time and place of the public hearing may be obtained by calling
the Yarmouth Conservation Commission office at (508) 398-2231 ext. 1288
H. Person sending this notification (applicant, representative or other)
Name: Crawford Land Management - Representative
Address: 88 Rt 6A
Town: Sandwich State: MA Zip: 02563
Telephone: 508-477-1346
NOTES :
• Notice of the public hearing, including date, time and place will be published at least five (5)
days in advance in a newspaper of general circulation.
• Notice of the public hearing, including date, time and place will be posted in the Town Hall not
less than forty-eight hours in advance.
• You may also contact the Southeast Regional Office of the Department of Environmental
Protection at (508) 946-2800 for more information about this application.
1
Land Management
Plan & Project
Narrative
88 Route 6A, Suite 2B
Sandwich MA
508.477.1346
info@crawfordlm.com
WWW.CRAWFORDLM.COM
PREPARED FOR
27 Aunt Edith Road
South Yarmouth, MA 02664
DATE
July 23rd, 2025
2
PROJECT INTRODUCTION
This project is located at 27 Aunt Edith’s Road in South Yarmouth, MA. The property is located
adjacent to Bass River. It includes a salt marsh, flood zone, coastal beach, and a coastal bank, as
well as all corresponding bufferzones. The property is not located within Estimated or Priority Habitat
as designated by NHESP, and is not located within an Area of Critical Environmental Concern. This
project proposes to install a fiber roll array and supplemental nourishment along a portion of coastal
bank. The existing patio will be reconstructed where it has been impacted by erosion. The existing in
grade stairs will be removed to allow for the construction of the fiber roll array, and will be replaced
by an elevated stairway. On the top of the southern portion of the bank, restoration plantings will be
installed.
AERIAL PHOTO COURTESY OF MASSMAPPER.
27 AUNT
EDITHS ROAD
BASS RIVERAUNT
ED
I
THS
ROADPLEASANT STREET
3
EXISTING CONDITIONS
This property is an existing developed single-family residence adjacent to Bass River. The property
extends to the waterfront on it’s southeastern side, north of this is a public dock accessible by a
maintained footpath from Aunt Edith’s Road. Resource areas on the property include salt marsh,
coastal beach, coastal bank, and a Floodzone VE at elevation 13 and a Floodzone AE at elevation
11 and 12.
Above the coastal bank is a fence, with lawn on the landward side of it. A patio with a firepit is at
the top of a portion of the bank, and is experiencing some damage due to the scarp on the coastal
bank. The firepit, and waterfacing side of the patio is noticeably shifting. On either side of this patio,
there is a naturalized area outside of the fence. However, much of the understory is invasive and
non-native species.
Invasive and non-native species found on or near this coastal bank include autumn olive (Elaeagnus
umbellata), beach rose (Rosa rugosa), English ivy (Hedera helix), and oriental bittersweet (Celastrus
orbiculatus). Native species on the property include northern bayberry (Myrica pensylvanica), and
most of the trees. These native trees include black oak (Quercus velutina), black cherry (Prunus
serotina), and eastern white pine (Pinus strobus).
The existing coastal bank form is relatively short in height, but in the southeastern part of the property
it is steeply sloped, and has been scoured by wave activity. A steep bank like this can exacerbate
scour which can undermine the stability of the bank and cause slumping.
PROPOSED ACTIVITIES
Wave action is eroding the coastal bank on the property, and it is threatening the stability of
the upland. To address this issue, a fiber roll array will be installed on the bank, and covered with
sacrificial nourishment. This fiber roll array will consist of 5 rows of fiber rolls at its tallest, arranged at a
2:1 slope. The bottom of the array is buried in the beach at approximately elevation 2 to protect the
toe of the bank. The top of the array will reach to approximately elevation 7, the top of the coastal
bank. The southern side of the array will only require 3 rows, ranging from approximately elevation
2.75 to approximately elevation 6.2. The scarp in this area is not as severe as it is elsewhere. Beach
nourishment sand will cover the rolls, and be replaced as needed. Hightide bush (Iva frutescens) and
plugs of American beachgrass (Ammophila breviligulata), spike grass (Distichlis spicata), switchgrass
(Panicum virgatum), seaside goldenrod (Solidago sempervirens), and salt meadow cordgrass
(Spartina patens) will be planted in the project area to provide greater stability.
The patio on the top of the coastal bank is noticably slumping due to erosion. This patio will be
reinforced or reconstructed in kind if some portion needs to be removed during the installation of
the fiber roll array. The steps on the coastal bank, connecting this patio to the beach, are in grade.
As such they will need to be removed to accomodate the fiber roll array. A raised set of stairs is
proposed to replace them after the fiber rolls are installed.
Due to the patio repairs and stair replacement in the 35’ Buffer to the top of the coastal bank,
a mitigation area is proposed in accordance with the wetland protection regulations (Town of
Yarmouth Wetland Protection Regulations 6.02-3). This area will be inbetween the fence and the top
of the bank. Invasive species will be removed, such as autumn olive (Elaeagnus umbellata), beach
rose (Rosa rugosa), English ivy (Hedera helix), and oriental bittersweet (Celastrus orbiculatus). Native
shrubs in the area will remain and be managed to encourage new dense growth. In addition native
species will be planted including sweet fern (Comptonia peregrina), swamp rose-mallow (Hibiscus
grandiflorus), beach plum (Prunus maritima), and native roses (Rosa virginia or carolina).
4
SCARP ON COASTAL BANK BELOW PATIO
EROSION ON BANK IN BETWEEN PUBLIC DOCK AND PATIO NOTE CANTILEVERED TREE TO BE REMOVED
5
IMPACT OF EROSION ON EXISTING PATIO ABOVE THE COASTAL BANK
EXISTING IN GRADE STEPS TO REPLACED WITH ELEVATED STAIRS
6
PROJECT ACTIVITY TIMELINE
INITIAL FIBER ROLL INSTALLATION
•Complete all initial implementation work (fiber roll array & elevated staircase) prior to storm
season, if possible, given availability of materials, contractor schedule, etc.
•Establish a limit of work prior to beginning any work. No work is to occur below Mean High Water.
•See the Shoreline Stabilization Plan for more information on construction and equipment access.
NOURISHMENT (WINTER/EARLY SPRING)
•Nourish array in accordance with the plans.
•Install planting according to Shoreline Stabilization & Restoration Plan specifications.
INITIAL INVASIVE SPECIES MANAGEMENT (TO BE COMPLETED AT SAME TIME AS FIBER ROLL
INSTALLATION)
•Remove all approved vegetation with the aid of small tracked equipment, where feasible.
•Dispose of all resulting debris off-site.
•Seed and blanket and/or hydroseed with tackifier throughout the restoration area with specified
seed mixes.
RESTORATION PLANTING
•Plantings to be installed after invasive species are approximately 80% controlled.
•Plantings to be installed in the spring or fall unless a temporary, above-ground irrigation system
has already been installed and a water supply is available immediately upon planting.
•If feasible, install a temporary, above-ground irrigation system to provide supplemental water to
all plantings for 2-3 growing seasons or until plants are fully established.
MAINTENANCE OF RESTORATION AREA
•Begin maintenance treatments (selective foliar and hand weeding) in April/May to target cool
season species.
•Cool season grasses may need to be flail mowed or trimmed in June/July to encourage
establishment of warm season species.
•Continue maintenance treatments through the summer into September/October.
MAINTENANCE OF FIBER ROLL ARRAY
•Monitor project area and perform assessments after a significant weather event to determine
how the installation is performing and if any changes or additions to the installation are necessary
•Nourish the installation with compatible sediment as necessary to maintain design profiles as
shown on the plan. Nourishment needs may vary from year to year for volume and frequency.
•Any areas of the installation or componeneds that are damaged, degraded, or exposed will
either be repaired/replaced or the exposed portions will be removed.
7
OBSERVED PLANT SPECIES IN PROJECT AREA
NATIVE SPECIES OBSERVED
Native to Barnstable County:
Myrica pensylvanica Northern Bayberry
Prunus serotina Black Cherry
Pinus strobus Eastern White Pine
Quercus velutina Black Oak
Aggressive Species:
Toxicodendron radicans Poison ivy
INVASIVE & NON-NATIVE SPECIES OBSERVED
Elaeagnus umbellata Autumn Olive
Rosa rugosa Beach Rose
Hedera helix English Ivy
Celastrus orbiculatus Oriental Bittersweet
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Performance
Standards
Narrative
88 Route 6A, Suite 2B
Sandwich MA
508.477.1346
info@crawfordlm.com
WWW.CRAWFORDLM.COM
PREPARED FOR
27 Aunt Edith Road
South Yarmouth, MA 02664
DATE
July 23rd, 2025
9
310 CMR 10.00: The Wetlands Protection Act
10.27: Coastal Beaches
(3) Any project on a coastal beach, except any project permitted under 310 CMR
10.30(3)(a), shall not have an adverse effect by increasing erosion, decreasing the
volume or changing the form of any such coastal beach or an adjacent or downdrift
coastal beach.
This project is intended to reduce erosion and increase the resilience of the coastal
beach by restoring the coastal bank landform. 100% biodegradable coir fiber rolls will
stabilize the landform to reduce erosion, and supplemental annual nourishment will
help preserve the beach elevation and form.
(4) Any groin, jetty, solid pier, or other such solid fill structure which will interfere with littoral
drift, in addition to complying with 310 CMR 10.27(3), shall be constructed as follows:
N/A. No solid fill structure is proposed.
(5) Notwithstanding 310 CMR 10.27(3), beach nourishment with clean sediment of a grain
size compatible with that on the existing beach may be permitted.
Nourishment is proposed using clean sediment with a grain size compatible with that
on the existing beach.
(7) Notwithstanding the provisions of 310 CMR 10.27(3) through (6), no project may be
permitted which will have any adverse effect on specified habitat sites or rare vertebrate
or invertebrate species, as identified by procedures established under 310 CMR 10.37.
No specified habitat sites of rare vertebrate or invertebrate species is identified on site.
10.30: Coastal Banks
(3) No new bulkhead, revetment, seawall, groin or other coastal engineering structure
shall be permitted on such a coastal bank except that such a coastal engineering
structure shall be permitted when required to prevent storm damage to buildings
constructed prior to the effective date of 310 CMR 10.21 through 10.37 or constructed
pursuant to a Notice of Intent filed prior to the effective date of 310 CMR 10.21 through
10.37 (August 10, 1978), including reconstructions of such buildings subsequent to the
effective date of 310 CMR 10.21 through 10.37, provided that the following requirements
are met:
N/A. No coastal engineering structure is proposed.
(4) Any project on a coastal bank or within 100 feet landward of the top of a coastal
bank, other than a structure permitted by 310 CMR 10.30(3), shall not have an adverse
effect due to wave action on the movement of sediment from the coastal bank to
coastal beaches or land subject to tidal action.
The coastal bank will be stabilized with biodegradable coir fiber rolls in order to
preserve and protect the shoreline. However, these features will be covered with
sacrificial nourishment, which will be able to move to coastal beaches and land
subject to tidal action. Sediment supply will not be diminished as a result of proposed
work. The fiber rolls will also be planted with native species.
10
(5) The Order of Conditions and the Certificate of Compliance for any new building within
100 feet landward of the top of a coastal bank permitted by the issuing authority under
M.G.L. c. 131, § 40 shall contain the specific condition: 310 CMR 10.30(3), promulgated
under M.G.L. c. 131, § 40, requires that no coastal engineering structure, such as a
bulkhead, revetment, or seawall shall be permitted on an eroding bank at any time in the
future to protect the project allowed by this Order of Conditions.
Noted
(6) Any project on such a coastal bank or within 100 feet landward of the top of such
coastal bank shall have no adverse effects on the stability of the coastal bank.
The stability of the bank will ultimately be improved by proposed work. Coir fiber rolls
will help protect and/or stabilize the coastal bank from erosion and scour until native
plants establish.
(7) Bulkheads, revetments, seawalls, groins or other coastal engineering structures may be
permitted on such a coastal bank except when such bank is significant to storm damage
prevention or flood control because it supplies sediment to coastal beaches, coastal
dunes, and barrier beaches.
N/A. No coastal engineering structure is proposed.
(8) Notwithstanding the provisions of 310 CMR 10.30(3) through (7), no project may be
permitted which will have any adverse effect on specified habitat sites of rare vertebrate
or invertebrate species, as identified by procedures established under 310 CMR 10.37.
No specified habitat sites of rare vertebrate or invertebrate species is identified on site.
10.32: Salt Marshes
(3) A proposed project in a salt marsh, on lands within 100 feet of a salt marsh, or in a
body of water adjacent to a salt marsh shall not destroy any portion of the salt marsh
and shall not have an adverse effect on the productivity of the salt marsh. Alterations
in growth, distribution and composition of salt marsh vegetation shall be considered in
evaluating adverse effects on productivity. 310 CMR 10.32(3) shall not be construed to
prohibit the harvesting of salt hay.
No portion of the salt marsh will be destroyed or adversly effected by proposed work.
No work is proposed within the salt marsh.
(4) Notwithstanding the provisions of 310 CMR 10.32(3), a small project within a salt marsh,
such as an elevated walkway or other structure which has no adverse effects other than
blocking sunlight from the underlying vegetation for a portion of each day, may be
permitted if such a project complies with all other applicable requirements of 310 CMR
10.21 through 10.37.
N/A. No small project is proposed within a salt marsh.
(5) Notwithstanding the provisions of 310 CMR 10.32(3), a project which will restore or
rehabilitate a salt marsh, or create a salt marsh, may be permitted in accordance with
310 CMR 10.11 through 10.14, 10.24(8), and/or 10.53(4).
N/A. No restoration or rehabilitation of a salt marsh is proposed.
11
(6) Notwithstanding the provisions of 310 CMR 10.32(3) through (5), no project may be
permitted which will have any adverse effect on specified habitat sites of Rare Species,
as identified by procedures established under 310 CMR 10.37.
No specified habitat sites of rare vertebrate or invertebrate species is identified on site.
10.58 Riverfront Area
(4) General Performance Standard. Where the presumption set forth in 310 CMR 10.58(3)
is not overcome, the applicant shall prove by a preponderance of the evidence that
there are no practicable and substantially equivalent economic alternatives to the
proposed project with less adverse effects on the interests identified in M.G.L. c.131 § 40
and that the work, including proposed mitigation, will have no significant adverse impact
on the riverfront area to protect the interests identified in M.G.L. c. 131 § 40. In the event
that the presumption is partially overcome, the issuing authority shall make a written
determination setting forth its grounds in the Order of Conditions and the partial rebuttal
shall be taken into account in the application of 310 CMR 10.58 (4)(d)1.a. and c.; the
issuing authority shall impose conditions in the Order that contribute to the protection of
interests for which the riverfront area is significant.
(a) Protection of Other Resource Areas.
All performance standards for other resource areas are met or exceeded.
(b) Protection of Rare Species.
No specified habitat sites of rare vertebrate or invertebrate species is identified on site.
The proposed project will result in an increase in native species diversity and wildlife
habitat.
(c) Practicable and Substantially Equivalent Economic Alternative
See attached alternatives analysis.
(d) No Significant Adverse Impact.
The proposed project has no significant adverse impact on the riverfront area. The
hardscape is only repairing or removing and replacing the existing hardscape in the
riverfront area, it increases native vegetation and nourishes the beach in the riverfront
area, and it reduces erosion potential.
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TOWN OF YARMOUTH WETLAND PROTECTION REGULATIONS
4.03 Coastal Beach
Any activity which is allowed on a coastal beach or tidal flat or within 100 feet of a
coastal beach or tidal flat shall not have an adverse effect on the coastal beach or tidal
flat by:
(a) Affecting the ability of the waves to remove sand from the beach or tidal flat;
No proposed work will affect the ability of the waves to remove sand from the beach.
The project proposes nourishment which will be able to move to coastal beaches
and land subject to tidal action. Sediment supply will not be diminished as a result of
proposed work.
(b) Disturbing the vegetative cover, if any, so as to destabilize the beach or tidal flat;
Approved at Public Meeting October 17, 2024 and published October 31, 2024
Any vegetation disturbed during the installation process will be replaced with native
salt marsh species and the soil stabilized to protect from erosion.
(c) Causing any modification of the beach or downdrift beach that would increase the
potential for storm or flood damage;
N/A. Project will not increase the potential for storm or flood damage.
(d) Interfering with the natural movement of the beach or tidal flat;
N/A. Project will not interfere with the natural movement of the beach.
(e) Causing artificial removal of sand from the beach or downdrift beach;
N/A. No removal of sand is proposed, and area will be nourished with compatible
sediment after installation.
(f) Removing seaweed or substrate from the coastal beach in the intertidal zone
(between MLW and MHW) that provides valuable habitat and potential for
sandaccretion, unless deemed a public health emergency by the Director of Health.
N/A. No work will take place within the intertidal zone.
4.05 Coastal Bank
(a) No new bulkhead, revetment, seawall, groin or other coastal engineering structure
shall be permitted on a coastal bank that provides significant sediment to an adjacent
or downdrift coastal beach; except that such a coastal engineering structure shall be
permitted when required to prevent storm damage to buildings constructed prior to
August 10, 1978, including re-construction of such buildings subsequent to the effective
date of these regulations, provided that the following requirements are met:
N/A. No coastal engineering structure is proposed.
(b) Any project on a coastal bank or within 100 feet of the top of a coastal bank, other
than a structure permitted under section 4.05, (3), (a), shall not have an adverse effect
due to wave action on the movement of sediment from the coastal bank to coastal
13
beaches or land subject to tidal action or flooding, and shall not have an adverse effect
on the stability of a coastal bank.
The coastal bank will be fronted by biodegradable coir fiber rolls in order to preserve
and protect the shoreline, and to enhance the stability of the bank. However, these
features will be covered with sacrificial nourishment, which will be able to move
to coastal beaches and land subject to tidal action. Sediment supply will not be
diminished as a result of proposed work.
4.06 Salt Marshes
(a) A proposed project in a salt marsh, on land within 100 feet from a salt marsh, or in a
body of water adjacent to a salt marsh shall not destroy any portion of the salt marsh
and shall not have an adverse effect on the productivity of the salt marsh. Alterations
in growth, distribution and composition of salt marsh vegetation shall be considered in
evaluating adverse effects on productivity.
No portion of the salt marsh will be destroyed or adversly effected by proposed
work. No work is proposed with in the salt marsh. Any vegetation disturbed during the
installation process within 100’ of the marsh will be replaced with native species.
(b) Notwithstanding the provisions of section 4.06, (3), (a), a small project within a salt
marsh, such as an elevated walkway or other structure which has no adverse effects
other than blocking sunlight from the underlying vegetation for a portion of each day,
may be permitted if such a project complies with all other applicable requirements of
these regulations.
N/A. No small project is proposed within a salt marsh.
(c) Notwithstanding the provisions of section 4.06, (3), (a), a project which will restore or
rehabilitate may be permitted; provided, however, that this section shall not be construed
to allow the alteration of one salt marsh on a given site by or contingent upon the
creation or restoration of another.
N/A. No restoration or rehabilitation of a salt marsh is proposed.
14
ALTERNATIVES ANALYSIS
The project as proposed is located within a riverfront area, and as such requires an analysis
of practicable and substantially equivalent economic alternatives.
One alternative is to leave the bank in it’s current condition. In this case the small increase
in coverage on the bank (which results from the removal and replacement of the stairs) can
be avoided. However, the existing steps are unsafe, and pose a risk to the homeowners that
use them, whereas the replacement stairs will provide safe access to the waterfront. In this
scenario, the bank will continue to erode away as it is currently. Eventually the stairs, fence,
and patio may fall into the beach, and become marine debris or navigational hazards. Trees
have already begun to fall off the bank due to this erosion, damaging it even further.
This issue of marine debris may be avoided with the removal of the patio and stairs. However,
the removal of these hardscape elements will create more disturbance in the buffer zone to
the top of the coastal bank than leaving them in place will. In addition, without the proposed
mitigation work, the coastal bank will continue to be occupied with non-native and
invasive shrubs. The mitigation work and planting proposed is far more beneficial for local
biodiversity.
Offering beach nourishment may temporarily slow erosion on the bank, but even with near
constant upkeep it will not offer enough protection to prevent the issues described above
as nourishment is purposefully sacrificial. The near constant replenishment it would require
would not be economic for the applicant nor would it be desirable for the other houses on
the street. Furthermore, it will result in more, repetitive disturbance on the bank and beach.
The project as proposed is the best option for native biodiversity, and ensuring the stability
of the bank and upland areas, without substantial changes to the existing use and
maintenance of the property.