HomeMy WebLinkAboutNarrative Revised. 2.27.2026Project Narrative
Notice of Intent
1 South Shore Drive, South Yarmouth
Red Jacket Resort
Beach Maintenance
The area subject to this Notice of Intent is land in South Yarmouth on the immediate shore of Nantucket Sound, a
tidal water body on the south side of Cape Cod. The specific project area is a Coastal Beach that is used
recreationally as a high-density bathing beach for the vacation facility known as Red Jacket Resort.
The coastal wetland resource areas affected include: Coastal Beach, Coastal Dune, Land Subject to Coastal Storm
Flow and the area is mapped by MESA as priority habitat. The MA DEP Mouth of the River Maps ( Parkers River)
indicate the site does not contain Riverfront Area.
The dune areas were delineated according to the presence of a visual terrain rise combined with beach grass at the
boundary with the beach deposit. The minor terrain undulations that are visible at the site are transitory. The
boundary of the dune opposite the beach can be taken as the existing seawall and the existing stone jetty of Parkers
River.
Since the year 2000 the beach area has been regulated by an Order of Conditions authorizing beach maintenance in
the form of beach sediment nourishment and beach raking. (DEP File No. SE83-2230.) Beach raking occurred
routinely and sediment replenishment had been a practice prior to 2020 and other Orders of Conditions preceded
SE83-2230 for beach work. The beach sediment is of suitable quality overall and residual upland source sediment
characteristics (coarser fragments) appear in both recent samples tested for grain size. Sources for future
sediment include both dredged material and upland sand deposits provided the source sediments are compatible.
The site is being permitted for contingency sediment replenishment. Should conditions develop to trigger the
applicants’ intent is to bring the concern to the attention of the Conservation agent for documentation and
determination of the scope. The likely manner to convey the intent to proceed with nourishment will be either
photographic depiction or beach transects to graphically show a future profile to reflect a future condition at such
time that it develops. The seasonal beach raking is a more immediate activity that is intended to occur throughout
the summer season properly supervised. A future beach will likely be smaller than depicted on the plan and the
beach raking mainly acutely affects a narrow strip along the wrack line and not the entire beach.
The Order of Conditions for the beach maintenance work expired in 2025. The applicant is seeking to re-permit
activity like the activity permitted in the former Order. A site plan is attached showing the late 2025 topographical
conditions of the beach and dune areas with general specifications for the proposed activity. An access route that
is indicated on the plan, traditionally used for the beach access, is the designated route for the small rubber-tired
tractor that pulls the beach rake. Less frequently, the access route would be utilized for deliveries of suitable beach
sediment and this sediment would be added during a time of year that would be out of phase with the growing
season, a rare species restricted term or recreational season.
The proposed sediment replenishment activity is beneficial for perpetuation of the sediment supply on this beach
with the presence of continuous seawall protection measures and the beach maintenance activity can be assessed
as less intensive as the daily crowded beach use. Sediment replenishment is not an immediate concern currently
and inclusion in this application is a sound choice for contingencies.
The mapped dune deposits may be stationed off to avoid disruption from raking. Segments of simple lathe sand
drift fence along the visible dune toe is suggested and the resort management expressed interest in doing so.
A sieve report is attached indicating the grain size of the existing beach sediment. As mentioned, residuals of past
upland source material are evident. Screening to 3/8 minus grain size is advised. The specification for local
sourced replenishment sand is typically better than the DEP state standard for beach nourishment. Typically,
upland source material on Cape Cod for suitable sand has approximately 2% to 3% fines where the upper DEP
limit is 10%. The material resulting from beach maintenance raking will be placed temporarily where indicated
adjacent to the seawall in an alcove slated for this purpose and disposed of on a frequent basis to avoid any sort of
nuisance. Disposal shall be in accordance with any applicable regulations for brush, leaves, seaweed etc.
Storm water management is addressed in the NOI in a manner commensurate with the project. Although no
specific exemption from storm water standards is applicable, the nature of this work as a beach management
project with the location on a coastal beach within the flood zone, sends the activity into the category as a form of
“redevelopment” the closest applicable category and from there the standards relate to appropriate prosecution of
the maintenance activity, care of machinery, collection and confinement of trash and appropriate disposal of
resulting material.
Performance Standards Summary
The proposed activity includes two features:
1. Beach sediment replenishment
2. Beach raking of excess wrack material
The regulatory presumption is that this Coastal Beach is significant to the listed interests and the
applicant takes no issue with that. The proposed activity is not within tidelands.
The beach sediment replenishment relationship to the performance standard:
Note: The sediment replenishment activity will not be done during any period of time of year restriction,
is not anticipated to alter the beach grade significantly to any detriment to the habitat value and is not
included into a MESA – related beach management plan included for this application
(a) volume (quantity of sediments) and form; The need for beach nourishment is intended to be
assessed in the case of a severe loss of beach volume. In the even that beach nourishment is triggered by
the general observation of need, the activity will affect the interests as follows:
(b) the ability to respond to wave action. Sediment added to the beach volume will support this
interest.
(c) distribution of sediment grain size; With care taken to appropriately source the sediment there
will be no detriment to the grain size distribution. At times with upland source material there can
be variation with the littoral-derived sand but the overall Harwich outwash plain deposits would
be consistent with the sediment that was involved in the overall shore system
(d) water circulation; With beach grading maintained like the beach grade that exists and with the
activity landward of the tidelands (HTL) there will be no relationship to water circulation
(e) water quality; With appropriate clean sediment quality, either dredged – source or upland-
source with a limit on fines with the activity occurring landward of the HTL the impacts to water
quality will be consistent with regulatory expectations relating to CZM beach nourishment
guidelines.
(f) relief and elevation; The activity of replenishment of the beach deposit, should the need arise,
can have practical value by creating a slightly steeper profile as the material comes landward
toward the dune line, combined with keeping distance from the high tide line. In the event a loss
of beach volume leads to replenishment a recommended profile will be submitted for the
Commission staff review. Doing this allows high-course tides and storm tides to claim sediment
more gradually from the upper beach where the sediment placement would occur and distribute
it throughout the lower beach and into the intertidal zone. The terrain relief will be minor to be
reasonably consistent with the current terrain character. Given the propensity of sediment
replenishment projects in the case of demonstrated need, there are no adverse impacts
anticipated.
Beach raking of excess wrack material and relationship to the performance standards for Coastal
beaches.
The listed interests of Coastal Beaches that are significant to storm damage prevention and flood control
and that are also significant to marine fisheries and wildlife habitat do not include preservation of wrack
material. The topic will be address after a summary of the listed interests:
Such activity shall not have an adverse effect to :
(a) volume (quantity of sediments) and form;
(b) the ability to respond to wave action.
(c) distribution of sediment grain size;
(d) water circulation;
(e) water quality;
(f) relief and elevation.
(7) 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.
The raking is a surface effect to a limited zone and does not materially affect the physical- related
parameters listed a. thru f. above.
The proposed activity has a relationship to (7) because the beach is mapped as priority habitat. Time of
year restriction is the primary vehicle for ensuring habitat protection with additional requirements
within the restricted term.
With adherence to all requirements issued for the specific site by NHESP the activity is presumed to avoid
adverse impact to the habitat interests. To assist with ensuring that the project will be reviewed by the
NHESP with conditions incorporated into the Order of Conditions.
A beach management plan related to the specific activity of beach raking and presence piping plover
habitat follows to summarize some of the anticipated requirements. We expect that Yarmouth
Conservation Commission and NHESP review will result in contributions to the management plan outline.
Part of the management plan has been taken from Town of Yarmouth public beach management plan
information to maintain a level of municipal consistency.
Coastal land Subject to Flooding - Town of Yarmouth Regulations closely mirror the MA DEP
regulations with exception of the performance standards for Coastal Land Subject to Flooding. In this
instance the flood zone is VE. Beach nourishment logically increases, whether minor or major, the beach
volume having a beneficial effect to the interests of flood protection. A review of the list of performance
standards leaves only the concern for “saltate pollution” as a potential concern. Clean sand fill,
appropriately regulated will not cause for saltate pollution. The Yarmouth regulations specify beach
nourishment as exempt from concern for adding fill to a flood zone. The beach raking does not appear to
cause for alteration to the ground profile.