HomeMy WebLinkAboutPublic comment AM Wilson Asociates 8.18.2025, 8.28.2025, 9.2.2025A.M. Wilson Associates Inc.
August 28, 2025
Yarmouth Conservation Commission
1146 Route 28
South Yarmouth, MA 02664
RE: SE83-2492 / Brahmst Goat Farm
Comments on Additional Materials
(our file 2.2271.00)
Dear Commissioners:
On behalf of my clients, neighbors of 88 & 100 Mill Lane, I wanted to provide
comments on materials provided by the applicant in SE83-2492 to the Commission
and posted to your website between 8/21/25 and 3:30PM 8/28/25. In particular,
these materials include the "Coir Log Berm/Swale Detail" and the NRCS
Conservation Practice Standard for Contour Buffer Strips.
The berm/swale detail provided appears to be for installation on a flat surface.
Understanding that the drawing is noted as "Not to Scale", it appears that the intent
is to set the Coir log into a trench so that half its diameter - 4" - will be above grade
with a bare dusting of loam over the top. Despite the drawing title, no swale is
shown. It is, therefore, impossible to know the depth or width, and thus the holding
capacity, of the swale and whether it would be created on the upgradient or
downgradient side of the Coir log. With, essentially, no cover on the coin log, it will
be very difficult to grow anything over its top. With no information on the
permeability of the native soil on which the installation will be set, nor the amount of
water to be entrained in any particular storm event, it is impossible to know how
effective the design will be in, say, a 2 yr, 5 yr, or 10 yr rainfall event, especially
when the ground is frozen and a very shallow swale might be filled with ice. Since
the installation requires excavation, fill and, based on verbal description at the
hearing, is intended to be set on the buffer line, work would be closer than 8' to the
wetlands resources on the site. Unfortunately, revised plans requested were not
available to review. However, considering the applicants unwillingness to consider
a larger buffer, this scenario is likely. I believe this needs a plan more reflective of
20 Rascally Rabbit Road 508 420-9792
Unit 3 FAX 508 420-9795
Marstons Mills, MA 02648 amwilsonassoc@amwilsonassociates.com
the site conditions and with significantly more backup information if you are to judge
the berm/swale's effectiveness and environmental impact.
The NRCS document is interesting in that it sets a minimum buffer width of 15', twice
the average of what is proposed by applicant. It also suggests that the percent slope
should be a factor in establishing buffer width, with buffers larger than 15' where
slopes are greater than 2%. The applicant has not provided you with slope
information. Nor is there an analysis comparing the impact of 30 goats grazing on
those slopes versus cutting crops in similar areas. However, this, apparently, is
another NRCS BMP which the applicant intends to ignore.
Finally, I believe that your Bylaw and Regulations at Sec 143-7(C) and Part 7, 7.01
allow a waiver if the project cannot provide the 35' buffer required by the Sec 6.01.
As part of such a request, there must be a showing that the project as designed is at
least as protective of the interests of the Bylaw as it would be if it complied with the
relevant design standard. They must also show that there is no alternative and that
the project has an overriding public interest.
The applicant has given you no quantitative data on: pollutant production/control
from the goat pasturing and vegetable/flower gardens; pollutant uptake in a 35'
naturally vegetated buffer vs the 8' on average proposed buffer; run-off and
infiltration data on his berm alternative; drainage information for roofs, the manure
handling facility, drives, access and parking areas shown and not shown but
required; estimated quantities of manure to be produced and composted onsite in
summer and winter; how much of the manure will be used onsite and how much
disposed of offsite in summer and winter. Without this data there is no way for you to
compare the proposed design to a regulatory compliant design for the project.
Consequently, you cannot make the findings required for the granting of a waiver.
Thank you for your consideration.
0)
Respectfully submitted,
A.M. WILSON ASSOCIATES, INC.
I
Arlene ilson, PWS
Principal Environmental Planner
Cc: DEP
Yarmouth Building Commissioner
Yarmouth Board of Health
A.M. Wilson Associates Inc.
August 18, 2025
Yarmouth Conservation Commission
1146 Route 28
South Yarmouth, MA 02664
RE: SE83-2492 88 & 100 Mill Lane, Yarmouth Port
Proposed Goat Farm
(our file 2.2271.00)
Dear Commissioners:
My office has been retained by a neighbor of the proposed goat farm at 88 & 100 Mill
Lane, Yarmouth Port to review and comment on the plans, NOI and support materials
filed with your office under SE83-2492 on behalf of Natasha and Oliver Brahmst, Mill
Pond Creek LLC including the site plan revised through 8/14/25 and supplemental
information posted to the Town website on the morning of 8/15/25. I have also
watched the video of the 8/7/25 project hearing. My comments are set forth below.
I believe the project needs to be treated as NEW.AGRICULTURE. Although the
Bilezikians, the original developers of the site, operated it as a "gentleman's farm"
for a number of years, it has been some time since the property owner's goal has
been to run the facility as a commercial, i.e. money -making operation. I have seen
no documentation in your file to support the claim that the property is "in
agriculture". Further, the Assessing Department taxes both properties as
Residential. The definition of Agriculture adopted by the Commission just over a
year ago (attached) references only on -going commercial activities associated with
agriculture as qualifying for exemptions. It appears that the Brahmst filing is to
establish a commercial agricultural use where none exists now. The current
application, then, must conform to the Commission's regulations. Because future
modifications may well be exempt once the facility becomes a working commercial
operation, it is important to capture not only current alterations, but those described
in limited detail as apt to be proposed at some point in the future.
Initially, there seems to be an issue relative to resource delineation. Based on Mr.
Ojala's description at the 8/7/25 hearing, the outlet from the farm pond wetland
system which is located along the boundary of 88 & 100 Mill Lane and which
ultimately empties into Mill Pond, flows year-round. It is, then, a River by definition
20 Rascally Rabbit Road 1 508 420-9792
Unit 3 FAX 508 420-9795
Marstons Mills, MA 02648 amwilsonassoc@amwilsonassociates.com
and its Riverfront should be shown on the plan. The buffer to the northerly Coastal
Bank also seems to continue to be missing.
It appears that potential project impacts fall into 3 main categories: erosion/siltation
control, wildlife impacts, and water quality/prevention of pollution concerns.
Erosion/siltation concerns are related to the fenced areas which will be used for
goat paddocks. It is very difficult to determine from the plan where the goats will be
pastured. It appears, however, that they will be excluded from areas around and to
the west of the two dwellings, land which is predominately outside of wetlands
jurisdiction, but will be allowed to graze in the areas south of the barn, east of the
driveway to the house on 88 Mill Lane, and north of the abandoned cranberry bog,
all of which is within wetlands jurisdiction. These seem to be the same areas
highlighted in yellow and labelled as "pasture" on the attached copy of the
recorded property plan from 2011.
The proposed fence location would violate your regulation 4.10(3) (a) (vi & viii) &
6.01(2,3, & 4) in that it would ignore not only your 35' buffer but, essentially, any
buffers at all. The vast majority of the strip running between the dwellings and
abandoned bog, slopes toward the bog and contains irrigation. Should the goats
cause disruption of the vegetation and/or soil surface, the irrigation system and/or
natural precipitation will wash sediment into the wetland. This situation also occurs
north of the bog where the slope runs north to the salt marsh and on the west side of
the composting area where the fenced area slopes toward the farm pond and stream
outlet.
We believe soil and vegetation cover impacts resulting in erosion and sedimentation
will be difficult to avoid considering the actual density of animals. Ms. Brahmst notes
in her narrative that her current NY operation has 40 goats pastured on 10 acres.
That equates to 1/4 ac per animal. She says the proposed Mill Lane operation will
have 32 animals (30 goats and 2 donkeys) pastured on 6 acres, a reduction of space
per animal from 1/4 ac to 1/s acre. This might not be significant if it were true.
Unfortunately, it is not.
The combined properties, based on the attached recorded 2011 Down Cape plan
and the current site plan show only ±5.23 acres of upland (including Coastal Banks)
on the combined properties. Mr. Ojala said animals would not be allowed in the
wetlands, so, at best there would be 0.16 acres per animal if the goats were allowed
to graze freely across the entire upland including the area of the yard around the
pool, the patios, ball court and parking area for the main house, the proposed
2
garden and the footprint of the buildings, themselves. If however, they only graze in
the previously demarcated pasture areas, that is a space of only ±1.64 acres. This
would provide only ±0.05 acres, ±2,232 sq ft of space per animal, a significant
reduction in space from her NY facility. At this density, which is significantly less
than the Town Health Department recommendation, maintaining a healthy
vegetative cover on pasture areas will be quite difficult.
When figuring the actual animal density, there is also the issue of the number of kids
anticipated annually and the duration of their stay on -site. It is possible that the
spring season, when the ground is apt to be wet and susceptible to greater damage,
could actually see 40 or more animals in the limited pasture, rather than 32.
The answer to this problem of erosion and sedimentation is to: enforce the
Commission's 35' buffer by moving the fence to the buffer line; require native shrub
plantings in buffers where none now exist; and eliminate the automatic irrigation
system in the buffers. Construction of a low - ±1' - berm along the paddock line
and/or buffer limit would help to contain farm related erosion, sedimentation and
runoff. This would also conform to the MDF&A manure management best practices
sheet provided by the applicant to which she says the operation will conform.
The current post and rail fencing has no impact on wildlife movement. Chain link
fence set to or into the ground will likely have adverse wildlife impacts, especially
for small animals attempting to move back and forth from uplands to wetlands and
water bodies. There should be a height limitation on the fence and occasional
sections where 6" of ground clearance is provided. It should also, as noted
previously, be moved back to the buffer limit and to the Top of the Coastal Bank.
Then comes the issues of water quality protection and pollution prevention.
These are adversely impacted by allowing the goats to utilize areas that slope
toward wetlands and waterbodies where runoff, exacerbated by the automatic
irrigation system, will carry feces into adjacent wetland. Collecting manure only
every third day will not sufficiently mitigate the pollutant load if the irrigation is run
every day and/or it rains/snows during the 3-day interval between pick ups.
Enforcing your 35' buffer and requiring the buffer to be planted will provide
significant mitigation. However, the buffer to the farm pond and its outlet stream,
because the stream is a direct discharge to Mill Pond, should be increased to a full
50'. Construction of low berms, ±1', along buffer limits would help to contain
nutrient enhanced runoff and limit sedimentation, as well.
3
Other mitigating measures should include: prohibiting irrigation in the period
between goat grazing and manure pick up in any particular grazing area; requiring
daily manure pick up in the winter; and requiring manure pick up prior to any
predicated storm of 1/a" of rainfall.
The manure composting facility is within the Riverfront to the farm pond outlet and,
thus, is within your jurisdiction. It is interesting to note that the 8/14/25 site plan
revision actually moves the composting shed closer to the farm pond and its outlet
channel. The land where the shed is proposed slopes toward the stream which
outlets directly to Mill Pond. Although Ms. Brahmst's narrative now says the area of
the shed will be graded flat, no grading is shown on the site plan.
You need to ensure the shed is big enough. Here, the facility will need to store total
daily manure production. It appears that the capacity of the composting shed will be
less than 50 cu yds. The manure will need to be trucked off -site periodically and
more frequently in the off season. However, no vehicular access to the shed is
shown. Drainage facilities for the roof of the barn and shed are not shown. You
should require the applicant to provide significantly more information to prove that
the composting facility will not threaten surface or groundwater.
Water quality testing in the farm pond for total nitrogen, total phosphorus, and fecal
coliform at the beginning of May, July and September of each calendar year with
results reported to you and the Board of Health would show whether or not the
facility were having adverse impacts on wetland interests.
If the commercial garden is only 1/7 acre, there will be lots of extra composted
manure. (Interestingly, the garden shown on the plan scales only ±145' x 80'; more
like 1/4 acre.) If the manure is used on -site, it could overload the capacity of adjacent
wetlands and waterways to deal with the excess nutrient load. If it is not to be used
on -site, where will it go?
The owner's management plan says there will be no manure handling management
until the second year. What happens during the first year? You should require
implementation of manure management from the time the first animal is brought to
the site.
Once you approve this project and the owners begin operation, you will lose the
ability to regulate farm related operations, including construction of up to 4,000 sf of
new farm related buildings, so it is important to add protective regulations now. You
should consider including conditions such as:
0
• All new drives and parking areas will require permeable surfaces.
• No composted manure use on any surface within 35' of a wetland, waterbody
or coastal bank.
• No new building or structure including parking areas and farm stands within
50' of any vegetated wetland, water body or coastal bank.
• No irrigation use or compost applications outside of active growing seasons or
within 35' of a wetland, coastal bank, or waterbody.
• Paths and boardwalk to be limited to 4' wide.
• Prohibition on vehicular maintenance and repair in open areas and/or areas
without impermeable surfaces.
• Storage of herbicides, pesticides, fertilizers and fuels only in enclosed areas
with impermeable floors and suitable containment approved by the Board of
Health and in accordance with local, state, and federal regulations.
You had requested a list of BMPs to be employed. The spread sheet provided does
not do that. Rather, it references multiple documents which run to hundreds of
pages and include BMPs for a wide range of situations most of which are not relevant
to the proposed project, expecting you to weed through the materials to decide
which references are being applied. This is completely unresponsive to your
request. The applicant should provide you with only relevant BMPs and descriptions
of methodologies to be employed to ensure compliance therewith.
Finally, you should require a complete plan which actually shows and labels:
• the limits of proposed paddock areas;
• all garden, fields and orchards;
• access to all of the above as well as to the compost shed and other planned
facilities;
• proposed parking areas for employees and guests, farm vehicles and
equipment;
• all proposed topographic changes;
• dimensions of proposed structures;
You should not close the hearing until those plans and required descriptive
materials are filed, and a final public review completed.
Since this will be a commercial operation including, at a minimum, selling of
produce, selling of livestock, and short-term leasing of animals for off -site vegetation
control, you may want to confer with the Building Commissioner to see if Site Plan
Review is required and to ensure that you will have direct input to those
proceedings.
5
You should also require that you be provided with copies of all submissions made to
the Board of Health and any permits issued by that Board and other Town Agencies.
Thank you for your consideration.
Respectfully submitted,
A.M. WILSON ASSOCIATES, INC.
Arlene M. Wilson, PWS
Principal Environmental Planner
attachments:
MGL Ch. 128 sec. IA
Pl BK 641 pg. 57
Revised Project Narrative
Cc: DEP
Yarmouth Building Commissioner
Yarmouth Board of Health
L
Part I ADMINISTRATION OF THE GOVERNMENT
Title XIX AGRICULTURE AND CONSERVATION
Chapter 128 AGRICULTURE
Section 1A FARMING, AGRICULTURE, FARMER; DEFINITIONS
Section IA. "Farming" or "agriculture" shall include farming in all of its
branches and the cultivation and tillage of the soil, dairying, the
production, cultivation, growing and harvesting of any agricultural,
aquacultural, floricultural or horticultural commodities, the growing and
harvesting of forest products upon forest land, the raising of livestock
including horses, the keeping of horses as a commercial enterprise, the
keeping and raising of poultry, swine, cattle and other domesticated
animals used for food purposes, bees, fur -bearing animals, and any
forestry or lumbering operations, performed by a farmer, who is hereby
defined as one engaged in agriculture or fanning as herein defined, or on
a farm as an incident to or in conjunction with such farming operations,
including preparations for market, delivery to storage or to market or to
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Good Hope Farm Plan for 88 & 100 Mill Lane Yarmouth Port, Massachusetts
Flowers and Produce. Good Hope is a small team of dedicated, creative, flower -
and farm -loving people currently operating in South Salem, New York. Our
family farm cultivates gorgeous, lovingly grown flowers in the Hudson Valley,
and now plans to continue its traditions in Yarmouth Port, Massachusetts.
Goat Husbandry. We are a no -cull herd of Nigerian Dwarf goats, registered with
New York State and respected for our top-notch care. Our goats receive annual
vaccinations and as needed veterinary oversight. Each year, we offer goat
husbandry classes in partnership with Westchester Community College to
educate students in responsible herd management.
We are committed to responsible growing and sustainably. All animal and plant
waste is composted into nutrient rich mulch and soil which is composted and
returned to the earth for future growth and soil restoration.
1. Executive Summary
Good Hope Farm is a small family farm originally based in South Salem, New
York, now relocating and reducing in scale to Yarmouth Port, Massachusetts.
Current operations focus on:
• Sustainable goat herd management with emphasis on goat kid sales and
potential ecological services for invasive plant management
• Field -grown flowers and vegetables for retail sale, CSA, and event design.
2. Legacy Operations in New York State
Agricultural Background:
• Good Hope Farm operates within a licensed New York State Agricultural
District established over 8 years ago specifically to support its use
• 40 goats rotationally grazed on pasture across 10+ acres
• Goat kid sales
• 1+ acres in flower and vegetable production
• Seasonal farm stand, and
• Established floral/event design services
The farm is now undergoing full relocation and reduction of operations to
Massachusetts.
3. Projected Massachusetts Practices (Yarmouth Port — 3-Year Plan)
Phase I: Year 1— Establishment and Compliance
• File MA LLC documentation to register Good Hope Farm as an operating
entity
• Update Site Plan (Completed by Down Cape)
• Apply for fence and gate permit to protect livestock from predator threats,
especially coyotes
• Apply for stable permit and farm license with the Yarmouth Board of
Health to authorize animal housing and farm operations
• File Notice of Intent with Town of Yarmouth Conservation Commission to
fully restore agricultural use and assess impact on any wetlands or
protected zones
• Reduce goat herd to 30 head for initial scale operations with two guardian
miniature donkeys
• Utilize existing 6 acres of pasture land for rotational goat grazing
• Fall breeding for spring kidding season
• Restore 1/2 acre of garden beds for cut flower and vegetable cultivation
• Implement manure management plan: Compost all manure on -site outside
of 100-foot setback zones. Composting will either occur mechanically in
an in -vessel system or in a three bin compost system. The resulting
compost be turned regularly and used as soil amendment for crops
• Assess fruit tree production potential on existing trees
Phase II: Year 2 — Infrastructure & Feasibility Exploration
• Begin Floral and produce production moving dahlia tubers in Fall
• advertise and screen adopters for goat kids in Spring
• Implement manure management plan:
• Compost all manure on -site outside of 100-foot setback zones. Compost
will be turned regularly and used as soil amendment for crops offer goats
for targeted invasive plant management
• Repair existing irrigation systems for crop and pasture needs
• Explore feasibility of dairy operation in coordination with MA Department
of Agricultural Resources
Phase III: Year 3 — Full Operations and Certification
• If viable, introduce creamery activity with revised 3-year approval under
MDAR
• Expand bouquet and vegetable CSA delivery within Cape Cod region
• Consider feasibility of application for USDA Organic certification for crops
and florals
4. Updated Agricultural Production Plan
Goat Herd Management (MA).
• 30 goats grazing on 6 acres with emphasis on goat kid sales and invasive
species management
• Rotational goat grazing with in the pasture
• Repair and complete predator fencing
• Finalize manure composting procedures
• Regular veterinary oversight
Flowers and Vegetables:
• 1/2 acre of restored garden beds in MA, including heirloom and
pollinator -friendly varieties
• Integrated pest management and seasonal succession planting
Irrigation:
• Upgrade legacy control systems with drip and timer -controlled irrigation
• Rainwater collection and drought contingency strategy
5. Updated Compliance and Filing Steps Massachusetts:
• File Notice of Intent (NOI) with Yarmouth Conservation Commission
o For Farm
o For Fencing (if Request for Determination is insufficient)
• Register with the Conservation District to obtain farm registration number
• Submit Fence & Gate Permit as needed
o Conservation
o Building Department
o Old Kings Highway
• Apply for Stable Permit and Goat License with Yarmouth Board of Health
• Implement manure composting plan
Good Hope Farm Soil Management and Conservation Plan
Good Hope is committed to responsible soil stewardship, ecological preservation,
and sustainable farming practices see the attached addendum highlighting the
best practices Good Hope will continue to employ.
Soil management practices at Good Hope are grounded in science and
conservation. Soil testing will be conducted every three years using the Modified
Morgan method, and whenever possible only organic fertilizers are applied —and
only as needed —based on those soil test results. Nutrients when needed are
applied exclusively when crops are actively growing, and never on saturated or
frozen soils thereby ensuring minimal runoff potential and maximum
absorption by crops. Records of all soil amendments and applications will be
maintained as part of our nutrient management plan. All floral and vegetable
cultivation is confined to the existing garden site.
In terms of animal husbandry, Good Hope employs rotational grazing through a
managed hay feeding system as hay feeding areas are rotated in tandem with
paddock use. Our animals are only on the pasture from 8 am until sunset. No
animals are left in the field after sunset or before sunrise- ever. The animals are
housed in stalls in the pre-existing barn with impermeable flooring. Outside in
the pastures, animals are moved regularly to ensure manure is distributed evenly
and no single area is overburdened. The grass will also be monitored to ensure no
large concentrations of manure. In order to avoid erosion, the grass will be kept
in good condition with irrigated watering as needed. Any excess hay residue
from feeding stations will be collected and composted to prevent smothering of
vegetation or buildup of organic material in sensitive areas. Any patches or- holes
will be remedied and reseeded in short order and the goats will be moved as
necessary to allow for regrowth and restoration. In high traffic areas such as
gates and doors, gravel will be added as necessary to avoid stripping of grass -
this has the added benefit of assisting in minimizing hoof trimming.
Manure management at Good Hope is executed with rigor and care following a
comprehensive set of Best Management Practices (BMPs). Our goal is to protect
soil and water quality, support plant and animal health. Animal manure is
collected from stalls every day or other day depending on the season and from
pastures regularly- we anticipate this being every three days. All collected
manure and pine shavings are composted in accordance with best industry
practices relying largely on parasitic fly predators and natural traps to disrupt fly
breeding and support soil health.
Collected manure will be stored on a covered three -sided structure on an
impervious graded pad to prevent nutrient runoff and leaching into groundwater.
All storage areas are carefully sited with appropriate setbacks from wetlands and
water sources.
Currently we are choosing between two composting methods both of which
comply with best management practices. We will either utilize a three pile
composting approach or a mechanized in -vessel composting system such as the
316 BIOvator, or similar in -vessel composting system. The Biovator in -vessel
system achieves highly controlled mechanized composting conditions.
Both approaches will process animal waste efficiently and minimize odors and
pathogens. Both approaches will maintain the required internal temperatures
above 130V for the required time period —conditions that meet pathogen
reduction standards and produce a stable, high -quality compost.
Best practices are not a one -size -fits -all framework; they must be adapted to
each farm's specific environment and operations. As a safety net, we retain a
contingency plan: should we ever generate more waste or compost than our
storage facility can store or waste that the Biovator can process in a reasonable
timeframe—which we currently do not anticipate —we will arrange for excess
material to be carted off in a covered sealed trailer to an appropriate waste facility
or farm for onward composting.
Regardless of the method we chose, all will operate on an impervious surface and
be covered on three sides and meet or exceed federal and state standards and
pathogen reduction requirements through the controlled conditions in full
compliance with federal and state laws and Massachusetts best practices.The
finished compost would be applied to our vegetable and floral cultivation areas
only during the active growing season, based on soil test results and crop
nutrient requirements. Nutrients are never applied to frozen or saturated soils.
We have based this composting practice on our long established practices in New
York. Storage capacity is based on our actual operational experience- not
estimates.
Good Hope relies primarily on sustainable, organic practices and natural pest
control methods. However, in limited cases where pest pressure endangers crops
or animals, their use may be necessary. In such instances, applications are
handled with utmost care and in full compliance with best management
practices. Our approach is rooted in Integrated Pest Management with careful
pest monitoring. If needed, only targeted, reduced -risk products are selected. We
actively support beneficial insects through native pollinator plantings and, when
needed, augment ecological balance through the seasonal releases of
commercially- raised beneficial species.
Good Hope will utilize a preexisting, low -impact irrigation system installed
during its previous flower and vegetable production years. This system, limited
to lawns, pastures and in cultivated zones is limited to pasture grass areas or
drip -based watering, greatly reducing water consumption and overspray or
runoff. Automated for efficiency with conservation in mind, the system
incorporates early morning watering, plant -specific delivery, and automated
weather -based skips based on atmospheric conditions. This approach supports
crop vigor, conservation and soil integrity.
Through these practices, Good Hope ensures that its agricultural use remains not
only environmentally responsible, but also aligned with the region's goals for
habitat protection, water quality, and sustainable land stewardship. We have
spoken directly with John Locke, our local National Resources Conservation
Service (NRCS) representative, who did read our farm plan and agrees it
directionally aligns with NRCS guidelines. Our next task from him is registering
with Farm Service Agency (FSA) and continuing to work with him through site
visits and other recommendations so that our practices are in complete
alignment with NRCS conservation standards and appropriate for the scale and
sensitivity of our site. Mr. Locke did caution that if we are not applying for
financial assistance through NRCS this will not be priority review due to their
very constrained resources and therefore they will not become directly involved
in this project beyond issuing technical recommendations. He also confirmed
that the NRCS does not become a party to or otherwise participate in local board
hearings or provide formal opinions or oversight on town permitting matters.
Prepared For: Good Hope Farm, Yarmouth Port, MA
Prepared By: Natasha Brahmst May 29, 2025, Updated August 13, 2025
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A.M. Wilson Associates Inc.
September 2, 2025
Yarmouth Conservation Commission
1146 Route 28
South Yarmouth, MA 02664
RE: SE83-2492 / Brahmst Goat Farm
88 & 100 Mill Lane, Yarmouth Port
(our file 2.2271.00)
Dear Commissioners:
After review of the 3 new/revised plans provided by the applicant on 8/28/25, we
have some continuing concerns.
1) Showing relevant information on 3 different sheets makes analysis of the
project unnecessarily difficult. For instance, not showing the sprinkler
locations on the Stormwater Flow Sheet makes it difficult to assess impacts of
irrigation flows.
2) There is still no grading shown for the manure shed, only a note that says it
will be graded flat. The same is true for the manure trailer parking area which
shows up for the first time here. How will a contractor know whether to cut or
fill to make the pad area flat?
3) It appears that the drainage from the garden, together with the excess
nutrients it may carry from composted goat manure will be funneled directly
to the channel into Mill Pond.
4) It appears from the description that the manure storage trailer area is
proposed as a carport type structure. Again, there is no grading on the plan
to show how the pad will be made "flat". There is no descriptive material to
tell you: when the trailer will be used; what its capacity will be; or how often it
will be emptied.
20 Rascally Rabbit Road 508 420-9792
Unit 3 FAX 508 420-9795
Marstons Mills, MA 02648 amwilsonassoc@amwilsonassociates.com
5) My concerns about the berm/swale detail as expressed in my 8/28/25 letter
are not alleviated by the revised site plan. The details still show no swale. It
is impossible to tell from Note E whether the installation is proposed for the
upgradient or downgradient side of the fence. There seems to be no berm at
the fence around the farm pond and its outlet, nor along the salt marsh on the
north side of the property. Consequently, sheet drainage flows with their
burden of manure nutrients and bacteria can run directly to the salt marsh and
the pond outlet to Mill Pond.
6) No vehicular access is shown to the garden. How will the composted manure
be hauled to that area and how will produce be taken away?
7) Note D says that there will be a strip of mowed grass of unspecified width to
"control invasives" between the pasture fencing and the wetland limits. This
means that the buffer of native vegetations will not be 8' wide, but likely only
4' wide, in spite of your regulation requiring a 35' wide buffer of native
vegetation. If the berm is on the wetland side of the fence, the buffer likely
will be only 2' wide.
8) The sprinkler heads in the pasture area between the north side of the
abandoned bogs and the salt marsh seem to be set so as to guarantee that
fresh manure in that pasture area will be washed into the salt marsh.
These plans raise more questions and concerns than they answer. We would urge
the Commission to require:
• Quantitative information about manure/compost nutrient loading.
• Actual plan sections at 1" = 20' scale around the compost shed and manure
storage area that show proposed grading for and around the structures, their
support pads and their drainage facilities.
• Drainage calculations to show that a single 6'x4' drywell with 2' of stone can
handle the runoff from the 524 sf of the 2 new buildings and almost 300 sf of
travel surface that will likely drain to it in at least a 10-year event and
preferably a 25-year event.
2
• Show in several detail sections (preferably one on the west side of the pond
outlet, one on the west side of the bog adjacent to the manure storage trailer,
and one on the north side running to the salt marsh) at 1 "=10' how the fence,
berm, swale, mowed grass strip, and BVW limit layout so that you can see the
true width of the proposed native buffer.
• Show all the site features — those existing, including irrigation; and those
proposed, including all structures, accesses and grading — on a single plan.
• Provide the required analysis to prove that the waiver from the Commission's
buffer requirement (and even the 50%+ departure from the SCS BMP)
provides the same environmental protection, especially for water quality, that
would be provided if the 35' buffer rule were met.
This information should be required and provided prior to making any decision on
the project.
Thank you for your consideration.
Respectfully submitted,
A.M. WILSON ASSOCIATES, INC.
Arlene M. Wilson, PWS
Principal Environmental Planner
Cc: DEP
Yarmouth Building Commissioner
Yarmouth Board of Health
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