HomeMy WebLinkAboutDMF comment 11.5.2025The 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
November 5, 2025
Yarmouth Conservation Commission
1146 Route 28
South Yarmouth, MA 02664
Dear Commissioners:
The Division of Marine Fisheries (MA DMF) has reviewed the Notice of Intent (NOI) by
Cynthia Richards of the Great Island Homeowners Association, Inc., to replace rotted timber
shims on pilings and repair stonework under the Great Island Road Bridge within Uncle Roberts
Cove in the Town of Yarmouth. The project was reviewed with respect to potential impacts to
marine fisheries resources and habitat.
The project site lies within mapped shellfish habitat for American oyster (Crassostrea virginica),
northern quahog (Mercenaria mercenaria), and softshell clam (Mya arenaria). Waters within the
project site have habitat characteristics suitable for these species. Land containing shellfish is
deemed significant to the interest of the Wetlands Protection Act (310 CMR 10.34) and the
protection of marine fisheries.
The project site abuts salt marsh vegetation. Salt marsh provides a variety of ecosystem services,
including habitat and energy sources for many fish and invertebrate species [1-2].
Uncle Roberts Cove acts as winter flounder (Pseudopleuronectes americanus) spawning habitat.
Winter flounder enter the area and spawn from January through May; demersal eggs hatch
approximately 15 to 20 days later. The Atlantic States Marine Fisheries Commission has
designated winter flounder spawning habitat as a “Habitat Area of Particular Concern” (HAPC).
In the previous stock assessment, the winter flounder stock was classified as overfished, with
spawning stock biomass in 2019 estimated to be only 32% of the biomass target [3]. Spawning
stock biomass in 2021 was estimated to be 101% of the biomass target based on a new
recruitment stanza focusing only on the past twenty years [4]. Given the new status of the winter
flounder stock, every effort should be made to protect the species and its spawning habitat.
MA DMF offers the following comments for your consideration:
• Construction activity, including staging of construction material and equipment as well as
equipment transit to and from the construction site, should avoid intertidal habitat to the
greatest extent practicable. As much work as possible should be conducted from the
upland portion of the project site to minimize impacts and avoid compaction of sediment
2
in mapped shellfish habitat. Any work in the intertidal zone should be limited to low tide,
such that work is conducted in the “dry”.
• Concrete delivery vehicles should be prohibited from washing down equipment on site.
This activity could potentially wash excess concrete and hydrocarbons into marine
resource areas.
• 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,
Amanda Davis
Environmental Analyst
MA Division of Marine Fisheries
cc:
Robert Perry, Cape Cod Engineering, Inc
John Logan, Kara Falvey, Holly Williams, Matt Camisa, MA DMF
Casaundra Healy, Yarmouth Shellfish Constable
Patrice Bordonaro, CZM
AD/kf
References:
1. Boesch, D.F. and R.E. Turner. 1984. “Dependence of Fishery Species on Salt Marshes:
The Role of Food and Refuge.” Estuaries 7(4):460-468. https://doi.org/10.2307/1351627.
2. Deegan, L.A., J.E. Hughes, and R.A. Rountree. 2000. “Salt marsh ecosystem support of
marine transient species.” In: M.P. Weinstein and D.A. Kreeger, eds. Concepts and
Controversies in Tidal Marsh Ecology: Kluwer Academic Publisher, The Netherlands.
pp. 333-365
3. ASMFC. 2020. Southern New England Mid-Atlantic Winter Flounder 2020 Assessment
Update Report. http://www.asmfc.org/uploads/file/6008bd822020_SNE-
MA_WinterFlounderAssessmentUpdate.pdf
4. ASMFC. 2022. Southern New England Mid-Atlantic winter flounder 2022 Management
Track Assessment Report. Compiled June 2022. https://apps-
nefsc.fisheries.noaa.gov/saw/sasi.php