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HomeMy WebLinkAboutNarrative 1.21.2026Land Management Plan & Narrative 88 Route 6A, Suite 2B Sandwich MA 508.477.1346 info@crawfordlm.com WWW.CRAWFORDLM.COM PREPARED FOR 10 & 20 Susan Road Yarmouthport, MA 02675 DATE January 2nd, 2026 2 AERIAL PHOTO COURTESY OF MASSMAPPER. PROJECT INTRODUCTION This project is located at 10 & 20 Susan Road in Yarmouthport, MA abutting Follins Pond to the east. The properties are adjacent to one another, and are both owned by the same property owner. This project proposes the installation of a coir fiber roll array along a portion of the Coastal Bank which is subject to continuous wave action which has been eroding and exacerbating a scarp along the face of the bank. Proposed work would occur within a Coastal Bank resource area and its associated buffer zones as well as Flood Zone AE (el. 9). FOLLINS POND LAGOON 3 EXISTING CONDITIONS 10 & 20 Susan Road are located on the south end of Susan Road in Yarmouthport. Follins Pond abuts the properties to the east, and a tidal lagoon abuts the properties to the west. 10 Susan Road is developed as a single-family residence with an existing dwelling, paved drive, decks, and other site appurtenances. Additionally, there are concrete retaining walls and steps fronting 10 Susan Road to the east which lead to the water, as well as a stone groin on the north end of 20 Susan Road. Lastly, permission was granted to construct a pier, ramp and float (License #10803) extending from 10 Susan Road. 20 Susan Road is an undeveloped lot. For the most part, the shoreline of this lot has not been altered/ reinforced, but it has experienced continuous erosion along the face of the bank, which exhibits a scarp along its length. It’s evident that the bank is actively eroding in several areas, where there is a lack of vegetative cover and recently exposed sandy soils. Within the proposed project area, the Coastal Bank is naturalized with vegetation, although much of the vegetation is invasive or non-native and aggressive. Invasive trees on the bank are primarily black locust (Robinia pseudoacacia) and tree of heaven (Ailanthus altissima); black locust is the predominant tree species. There are several scattered native tree species, such as black cherry (Prunus serotina), white oak (Quercus alba), black oak (Quercus velutina) and hickory (Carya sp.). The understory layer is not well-developed, and is mostly characterized by invasive vine species like Oriental bittersweet (Celastrus orbiculatus) and patchy instances of native grasses. PROPOSED PROJECT ACTIVITIES This project proposes the installation of a coir fiber roll array along a portion of the coastal bank. The fiber roll array is intended to protect the existing profile of the coastal bank landform and prevent future scouring and slumping. The array would be four rows high and would extend from approximate elevation 5.5 to approximate elevation 0.5. The fiber roll array was designed to fit the existing form of the bank and would be a maximum slope of 1:1, and the array was designed to taper back into existing grade at the end to reduce the potential for end scour. High-density, 20” diameter fiber rolls made of biodegradable coir would be anchored into underlying sediment every 30” along the length of the array using duckbill anchors made of galvanized cable, anchors, and copper crimps. The array would be covered with 900- or 1000-gram coir matting to help slow UV degradation if exposed. Additionally, the array would be nourished with compatible sediment at the toe of the bank at an approximate 2:1 slope, and would then be planted with American beachgrass culms at 12” on center with 2 culms per hole. Construction access would be from the existing paved driveway across turf lawn, and work would be completed using a mini tracked skid steer and a mini excavator. All work will be completed from the top of the bank and no work will be completed below mean high water. Several trees located within the proposed fiber roll array footprint would need to be removed to facilitate installation. If left in its current condition, it’s likely that the bank would continue to erode and cause further scouring and slumping that would result in trees falling over or becoming windthrown, further diminishing the integrity of the bank. The live trees proposed for removal are invasive black locust or tree of heaven, and many of the trees for removal are already undercut and exhibit exposed roots. In total, ten live invasive trees and one dead standing tree would need to be removed. Any invasive or dead trees proposed for removal to facilitate installation of the fiber roll array will be replaced 3:1 with native shrubs, yielding a total of 33 proposed shrubs. In addition, 2 native oaks are proposed at the top of the bank to replace biomass in the canopy. Additionally, a 5’ wide buffer strip is proposed to be created at the top of the bank that would be planted with native grasses and herbaceous perennials. The addition of native trees, shrubs, grasses and perennials at the top of the bank will improve the stability of the bank and will help hold sediment in place. Native shrubs also enhance wildlife habitat, as several migratory bird species prefer early successional habitat characterized by dense shrub cover, and deer browse on the new growth of woody shrubs. 4 MANY EXISTING TREES ARE UNDERMINED AND ARE LIKELY TO FALL OR DIE NATURALLY INVASIVE VINES COVER A LARGE PORTION OF THE BANK PROPOSED ACCESS TO BE FROM ACROSS EXISTING LAWN EXISTING COASTAL BANK PROFILE EXISTING EROSION AND SCOUR ALONG THE COASTAL BANK 5 PROJECT ACTIVITY TIMELINE INITIAL INSTALLATION (FALL/WINTER) • Complete all initial implementation work prior to storm season, if possible, given availability of materials, contractor schedule, etc. • First, establish a limit of work prior to beginning any work. No work is to occur below Mean High Water (el. 4.33). Work will need to occur from the upland side of the installation. • Then excavate the areas for installation of the fiber roll array to the elevations specified on the plan and stake out the edge of the fiber roll array to ensure locations match those shown on the plan. PLANTING (SPRING OR FALL) • Plantings to be installed after all work associated with the installation of the fiber roll has been completed. • 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. • Seed the top of the array with the CLM Custom Restoration Seed Mix and plant according to the plan. MAINTENANCE (3 YEARS MINIMUM) • Monitor the 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 components that are damaged, degraded, or exposed will either be repaired/replaced or the exposed portions will be removed. 6 Performance Standards Narrative 88 Route 6A, Suite 2B Sandwich MA 508.477.1346 info@crawfordlm.com WWW.CRAWFORDLM.COM PREPARED FOR 10 & 20 Susan Road Yarmouthport, MA 02675 DATE January 2nd, 2026 7 310 CMR 10.00: The Wetlands Protection Act 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. Only soft shoreline stabilization measures are 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 fronted by biodegradable coir fiber rolls in order to preserve and protect the shoreline. The array 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. (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. (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, which is increasingly at risk of eroding, scouring and slumping. (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. Only soft shoreline stabilization measures are 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. N/A. No specified habitat sites of rare vertebrate or invertebrate species is identified on site. 8 10.57: Land Subject to Flooding (4) General Performance Standards (a) Bordering Land Subject to Flooding 1. Compensatory storage shall be provided for all flood storage volume that will be lost as the result of a proposed project within Bordering Land Subject to Flooding, when in the judgment of the issuing authority said loss will cause an increase or will contribute incrementally to an increase in the horizontal extent and level of flood waters during peak flows. Compensatory storage shall mean a volume not previously used for flood storage and shall be incrementally equal to the theoretical volume of flood water at each elevation, up to and including the 100-year flood elevation, which would be displaced by the proposed project. Such compensatory volume shall have an unrestricted hydraulic connection to the same waterway or water body. Further, with respect to waterways, such compensatory volume shall be provided within the same reach of the river, stream or creek. Proposed work is intended to buffer wave energy in order to protect and preserve the existing shoreline. The proposed fiber roll array is considered a “soft” shoreline stabilization solution, and is constructed of biodegradable materials which are able to absorb and buffer wave energy rather than reflect it. The fiber roll array will fit into the existing bank landform, and will not affect flood storage volume. 2. Work within Bordering Land Subject to Flooding, including that work required to provide the above-specified compensatory storage, shall not restrict flows so as to cause an increase in flood stage or velocity. Proposed work will not restrict flows or cause an increase in flood stage or velocity, as fiber rolls will be fitted into the existing coastal bank landform. 3. Work in those portions of bordering land subject to flooding found to be significant to the protection of wildlife habitat shall not impair its capacity to provide important wildlife habitat functions. Except for work which would adversely affect vernal pool habitat, a project or projects on a single lot, for which Notice(s) of Intent is filed on or after November 1, 1987, that (cumulatively) alter(s) up to 10% or 5,000 square feet (whichever is less) of land in this resource area found to be significant to the protection of wildlife habitat, shall not be deemed to impair its capacity to provide important wildlife habitat functions. Additional alterations beyond the above threshold, or altering vernal pool habitat, may be permitted if they will have no adverse effects on wildlife habitat, as determined by procedures contained in 310 CMR 10.60. Proposed work is well below the 10% / 5,000 square feet alteration threshold. The existing bank is largely dominated by invasive and non-native vegetation, and is likely to continue to erode and cause further loss of naturalized area/potential wildlife habitat. Proposed work will ultimately protect the shoreline from further erosion and replace invasive vegetation with native vegetation that is better able to stabilize soils and provide quality habitat for wildlife. (c) Protection of Rare Wildlife Species Notwithstanding the provisions of 310 CMR 10.57(4)(a) or (b), no project may be permitted which will have any adverse effect on specified wildlife habitat sites of rare vertebrate or invertebrate species, as identified by procedures established under 310 CMR 10.59. N/A. No specified wildlife habitat sites of rare vertebrate or invertebrate species is identified on site. 9 Town of Yarmouth Wetland Protection Regulations 4.05 Coastal Banks (3) Performance Standards: (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. Only soft shoreline stabilization measures are 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 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. The array 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 stability of the bank will ultimately be improved by proposed work, as coir fiber rolls will help protect and/or stabilize the coastal bank, which is increasingly at risk of eroding, scouring and slumping. 4.10 Land Subject to Coastal Storm Flowage (3)(a) General Performance Standards: Any activity within land subject to coastal storm flowage which will result in the building upon, removing, filling or altering of land shall not have an adverse effect on the interests protected by the bylaw by: i. reducing the ability of the land to absorb and contain flood waters; The proposed fiber roll array is considered a “soft” shoreline stabilization solution, and is constructed of biodegradable materials which are able to absorb and buffer wave energy rather than reflect it. The fiber roll array will fit into the existing bank landform, and will not affect flood storage volume. i. reducing the ability of the land to buffer more inland areas from flooding and wave damage; The coastal bank will still be able to buffer more inland areas from flooding and wave damage. The bank profile will remain the same, and the fiber roll array will help protect and preserve the existing bank from future erosion, scouring, and slumping. ii. increasing the elevation or velocity of flood waters, or by redirecting or increasing flows or causing channelization, in each case at the project site, adjacent or nearby properties, or any public or private way; Flood waters will not be affected by proposed work; the existing bank profile will remain the same, and the coir material will buffer wave energy rather than reflect/redirect it as a hard solution would. 10 iii. displacing or diverting flood waters to other properties or resource areas. Fences and privacy walls, including walls separating one property from another, may obstruct or divert flood flow and waves toward buildings and protected areas. Solid fences (stockade and similar) must be constructed with 6 inches of clearance below to allow the passage of floodwaters and wildlife; Flood waters will not be displaced, and no fences or privacy walls are proposed. iv. causing, or creating the likelihood of, damage to other structures on land within the flood plain as debris (collateral damage); Proposed work will not create the likelihood of damage to other structures, as fiber rolls are anchored into underlying sediment with galvanized cable, anchors and copper crimps, and are made of a soft, biodegradable material. v. causing ground, surface or saltate pollution triggered by coastal storm flowage; Proposed work creates no possibility of ground, surface or saltate pollution. vi. reducing the ability of the resource to serve as a wildlife habitat and migration corridor through activities such as, but not limited to the removal of substantial vegetative cover and/or installation of fencing and other structures which prevent wildlife migration across property; Only vegetation within the proposed fiber roll array footprint is proposed for removal. The majority of vegetation proposed for removal is invasive trees or vines, and many of the existing trees are undermined by a scarp, meaning the stability of the bank is compromised. Vegetation for removal will be replaced with native trees, shrubs and grasses which will enhance bank stability and also improve the capacity of the bank to serve as wildlife habitat and a migration corridor in the long-term. vii. prevention of the migration of resource areas such as salt marshes due to sea level rise; Resource areas will still be able to migrate as much as they are able to do so currently; the existing bank profile will remain as-is, and will only be reinforced to prevent premature bank erosion and slumping. viii. If flood control and storm damage protection functions have already been impaired, redevelopment must improve existing conditions by reducing impervious surfaces, restoring flood control and storm damage protection functions, installing native plantings, or by restoring or creating other wetland resource areas; A soft, biodegradable fiber roll array is proposed at this time, as opposed to a stone wall/ revetment, as was constructed on the neighboring property previously. The fiber roll array is an improvement over previous development/protection choices. And shall meet the following requirements; ix. Existing septic system and cesspool repairs will be allowed provided they meet all Title 5 and local Board of Health thresholds. N/A. No septic system or cesspool repairs are proposed. x. All groundwater elevations shall incorporate seasonable adjustments if test holes and or leaching components are 100 feet or closer from major estuaries. N/A. No test holes or leaching components are proposed. 11 xi. Any proposed deck, shed, or other similar structure must be securely anchored to a footing or foundation. N/A no deck, shed or other structure is proposed. xii. Any activity shall preserve existing soils, vegetation, and other natural conditions that serve as buffers to coastal flooding and storm surges. Proposed work will ultimately preserve the ability of the coastal bank to buffer coastal flooding and storm surges. The proposed fiber roll array will meet the existing profile of the bank so as not to inadvertently displace flood waters, and the array will help preserve the stability of the bank, which has been subject to continuous erosion, scour and slumping in recent years. The fiber rolls are made of a biodegradable, “soft” material which buffers and disseminates wave energy rather than reflecting it. Vegetation which needs to be removed to facilitate the installation of the array will be replaced with native trees, shrubs and grasses that will improve overall bank stability and thus improve the bank’s ability to buffer flooding. 6.01 Setbacks and Buffer Zones (1) Notwithstanding section 6.01(2) below, no new structures, including swimming and spa pools (with the exception of water dependent structures), will be allowed within 50 feet of the following Resource Areas: No new structure is proposed; only a fiber roll array and vegetation management work is proposed. (2) Minor structures up to 140 square feet total coverage such as sheds, decks, and pervious patios may be allowed closer than 50 feet to a Resource Area but no closer than 35 feet. With the exception of “Vista Pruning” as outlined in section 6.03, a 35- foot undisturbed natural vegetative buffer shall be maintained between all projects and Resource Areas mentioned in 6.01 (1), above to insulate wetland resource areas from adverse impacts stemming from development elsewhere in the buffer zone. In cases where the slope of an undisturbed buffer exceeds 18%, or in any instance where the scope or nature of the project is likely to require a greater spatial offset to wetland resource areas, the Commission reserves the right to increase buffer zone width to a more suitable dimension. No new structure or development is proposed. Only temporary disturbance may occur as a result of construction of the fiber roll array. The fiber roll array will provide a net improvement over the existing coastal bank and its buffer zone. (3) The following are prohibited within resource areas listed in 6.01 (1) and their 35-foot buffer zones: (a) Lawn grasses including “Cape Cod Lawns” (b) Landscaping (c) Fertilizers (d) Pesticides (unless part of an approved invasive species removal program) (e) Irrigation except for temporary irrigation for establishment of native plantings (f) Mulch, other than for temporary ground stabilization for one growing season. Groundcover plantings are to be used for permanent stabilization and weed control. Pesticides may be used in order to treat invasive vines on the coastal bank, and treatments would be made by MA-licensed and insured pesticide applicators. A temporary above- ground irrigation system may also be used in order to help native plantings establish on/at the top of the coastal bank. 12 (4) The following are prohibited within resource areas listed in 6.01(1) and their 50-foot buffer zones: (a) Fertilizers (b) Pesticides (unless part of an approved invasive species removal program) (c) Irrigation except for temporary irrigation for establishment of native plantings Pesticides may be used in order to treat invasive vines on the coastal bank, and treatments would be made by MA-licensed and insured pesticide applicators. A temporary above- ground irrigation system may also be used in order to help native plantings establish on/at the top of the coastal bank. (5) Lawns No new lawn is proposed. 6.02 Mitigation and Restoration (1) At a minimum, a 35-foot undisturbed buffer zone shall be retained between the landward-most wetland resource area and the limit of proposed site disturbance. Landward of the 35-foot no-disturb zone, work shall be designed to minimize the area of disturbance, to preserve as much undisturbed vegetation within the onehundred-foot buffer zone as is practicable for the proposed use. A 35-foot undisturbed buffer zone does not exist currently. Site disturbance is limited to the installation of a coir fiber roll array on the coastal bank and temporary access through the buffer zone for construction of the fiber roll array. The fiber roll array will provide a net improvement over the existing coastal bank and its buffer zone. (2) Where a 50-foot undisturbed buffer zone exists prior to the proposed work, and shall remain intact upon project completion, further buffer zone enhancement shall not be required. N/A. A 50-foot undisturbed buffer zone does not currently exist and no new or replacement hardscape or structure is proposed. (3) Where a 50-foot undisturbed buffer zone does not exist prior to the proposed work, any work proposed within the 100-foot buffer zone shall be subject to mitigation planting requirements intended to restore, in so far as is possible, both the dimensions of a 50-foot undisturbed buffer and its vegetation. For work proposed within the 100-foot buffer zone, the calculation of mitigation is set forth as follows: (a) For proposed, new or replacement hardscape or structure, whether pervious or impervious, within the 50-100-foot buffer zone, mitigation shall be 2:1. N/A. No new or replacement hardscape or structure is proposed. (b) For proposed new or replacement hardscape or minor structure, whether pervious or impervious within the 35–50-foot buffer zone, mitigation shall be 3:1. N/A. No new or replacement hardscape or structure is proposed. (c) Where a variance is sought for proposed work within the 35-foot buffer, mitigation shall be determined at the commission’s discretion. (d) In no case shall the total area of mitigation plantings required be greater than that which is necessary to restore a 50-foot undisturbed buffer in its entirety. 13 (e) If structures or hardscape already exist within the 35-50 foot buffer, then additional structures or hardscape may not be allowed within the 100 foot buffer until the 50 foot buffer and its vegetation have been fully restored. N/A. No new or replacement hardscape or structure is proposed. (4) Where mitigation or restoration of buffer zone vegetation is proposed or required under a notice of intent, it shall meet the following requirements: (a) Locally native and climate adapted plant species suited to the local growing conditions will be used. Mitigation areas should contain a diversity of woody species with varying heights sufficient for the space (at least 3 species when the required mitigation area is <300 sqft) and may be supplemented by an understory of native grasses and forbs (including ferns, herbs, groundcovers, and perennials). Native grasses and forbs alone cannot be used as mitigation. No new or replacement hardscape or structure is proposed, and thus no mitigation is required. However, trees, shrubs and grasses are proposed to re-vegetate the bank and its buffer after invasive trees are removed to facilitate installation of the fiber roll array. Proposed vegetation is all native, climate-adapted species suited to the local growing conditions, and will be sourced locally. (b) The recommended plant spacing and densities will be used as shown on the approved plant lists available on the conservation website. (c) Only temporary use of mulch may be applied under the drip line of each plant at the time of planting for moisture retention, soil stabilization, and weed control during establishment. Native groundcovers will be utilized in the spaces between larger plantings. At no time shall a mitigation or restoration area be sheet mulched. Hand weeding is allowed. No use of mulch is proposed. (d) Foundation landscape beds within the buffer zone: Proposed foundation landscape bed plantings should appear on all plans if within resource areas and the 100-foot buffer zone. Foundation beds are defined as directly abutting a dwelling/structure and are a maximum of 5 feet in width. These areas may be planted with native species, native cultivars, or non-invasive non-natives with approval from the Commission or the Conservation Administrator. No new foundation landscape beds are proposed. 6.03 Trees and other Vegetation (1) “Vista Pruning” may be allowed on a case-by-case basis subject to the following provisions. No vista pruning is proposed. 14 (2) Any trees removed in a resource area (excluding LSCSF) or buffer zone must be replaced with native and climate resilient trees, caliper inch for caliper inch as determined by the Diameter at Breast Height (DBH) of the tree. The same tree species should be planted unless otherwise approved by the Commission or Conservation Administrator. Example-if a 10-inch oak is removed, the trees planted must total 10 inches such as five 2-inch caliper trees. Several invasive trees must be removed in order to facilitate installation of the proposed fiber roll array. Many of these trees already exhibit poor health, due to the fact that the bank (and the substrate into which the trees are growing) has been eroding, leaving the tree roots exposed and the trees prone to uprooting or dying in the near future. The removal of invasive trees will prevent their spread elsewhere on the property or adjacent properties, thus protecting the integrity of native ecosystems nearby, and will help preserve the stability of the bank by eliminating the potential for those trees to fall or become uprooted and diminish the bank’s stability. Invasive and dead trees within the footprint of the proposed fiber roll array will be replaced 3:1 with native shrubs, yielding 33 proposed native shrubs. Shrubs are more suitable for planting in this location, as they do not pose the potential for becoming uprooted and threatening bank stability, and their roots are many-branching, which helps hold soils together. Two native trees are also proposed at the top of the bank to replace biomass in the canopy. Additionally, native grasses will be seeded and planted as plugs at the top of the bank where the replacement trees and shrubs are proposed, thus creating a 5’ wide buffer strip that preserves the integrity of the bank in the long-term. We would also like to note that proposing any trees for removal is only for the purpose of facilitating the installation of the fiber roll array. No construction or site development work is proposed. Ultimately, the fiber roll array will protect the bank so that it can continue to provide benefits to wildlife habitat and flood mitigation while protecting inland naturalized areas from future erosion. (3) If the parcel is mitigation constrained, the Commission may require that the trees remain, or 16 square feet of native shrubs may be planted directly abutting the existing vegetated buffer in lieu of trees for each caliper inch that space is insufficient. (4) Trees must be preserved in Land Subject to Coastal Storm Flowage wherever feasible. When trees are proposed for removal for new development or redevelopment, the Commission may require replacement with native trees at their discretion. Only trees which absolutely must be removed in order to install the fiber roll array are identified for removal on the plan. Removal is not proposed for the purposes of new development or redevelopment, but rather to facilitate the installation of a fiber roll array which will significantly improve the stability and health of the bank. Many existing trees for removal are already in poor health, and are poorly rooted and will likely not sustain much longer. The top of the bank will be vegetated with native trees, shrubs and grasses which will improve wildlife habitat and bank stability compared with the existing conditions. 15 Alternatives Analysis (1) No stabilization work is completed. The property could be left as-is without completing any stabilization work. However, there is a scarp along a large portion of the coastal bank which has been eroding the existing lawn and naturalized areas above it for several years. If left alone, this scarp would likely continue to worsen, causing loss of lawn and naturalized areas on the property. The fiber roll array only spans the portion of the bank which is nearest to the existing structure and living areas, and where the scarp is most pronounced (i.e. impacts are minimized). The proposed fiber roll array would protect this area against further erosion and essentially hold the existing landform in place, thus protecting naturalized areas behind it. (2) Nourishment and planting could be completed without the addition of one or two rows of fiber rolls. The bank could be nourished and planted without the addition of a fiber roll array. However, it’s evident that wave energy from tides and storms is frequent enough to reach the area of the scarp repeatedly and continue to scour the bank. It’s likely that nourishment and planting will need to be completed regularly to replenish material that is lost due to storms, but the fiber rolls will act as a backstop if nourishment is removed that will buffer water and wave energy and help protect against erosion and scour that would otherwise remove underlying sediment and ultimately shift the bank landform landward.