HomeMy WebLinkAboutDMF comment 5.18.2026The Commonwealth of Massachusetts
Division of Marine Fisheries
(617) 626-1520 | mass.gov/MarineFisheries
Maura T. Healey
Governor
Kimberly Driscoll
Lt. Governor
Rebecca L. Tepper
Secretary
Thomas K. O’Shea
Commissioner
Daniel J. McKiernan
Director
May 18, 2026
Yarmouth Conservation Commission
1146 Route 28
South Yarmouth, MA 02664
Dear Commissioners:
The Massachusetts Division of Marine Fisheries (MA DMF) has reviewed the Notice of Intent
(NOI) by Tony and Jane Campagna to reconstruct an existing permitted bulkhead within Parkers
River at 14 Compass Drive in the Town of Yarmouth. The applicants are proposing to move rocks
as necessary to reconstruct the western portion of the bulkhead. The project was reviewed with
respect to potential impacts to marine fisheries resources and habitat.
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].
Parkers River has been identified by MA DMF as diadromous fish passage, migration, and/or
spawning habitat for alewife (Alosa pseudoharengus), American eel (Anguilla rostrata), white
perch (Morone americana), and Atlantic tomcod (Microgadus tomcod) [3].
The project site lies within mapped shellfish habitat for American oyster (Crassostrea virginica).
Waters within the project site have habitat characteristics suitable for this species. Oyster and
quahog (Mercenaria mercenaria) were present within the project site during a shellfish survey
conducted by John Lowell on November 21, 2025. Land containing shellfish is deemed significant
to the interest of the Wetlands Protection Act (310 CMR 10.34) and the protection of marine
fisheries.
Parkers River 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 [4]. Spawning
stock biomass in 2021 was estimated to be 101% of the biomass target based on a new
2
recruitment stanza focusing only on the past twenty years [5]. 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:
• Repair of the structure should be within the same footprint as the existing structure or
landward. Any expansion of the footprint into tidal waters of the Commonwealth will
result in the loss of shellfish habitat. The proposed placement appears to meet this
recommendation.
• A portion of the proposed structure is sited abutting salt marsh vegetation and mapped
shellfish habitat. Filling of intertidal habitat will result in loss of Commonwealth public
trust tidelands. Construction should not be allowed in salt marsh habitat or in a location
which could adversely impact the salt marsh.
• The existing stone armoring on the western portion of the bulkhead has interstitial spaces
that helps deflect wave energy and provides habitat for invertebrates and shore zone
fishes during high tide. Current plans propose removing these stones as necessary during
construction. However, it is unclear if stone armoring and the ecosystem services it
currently provides will be present after the reconstruction.
• 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
in mapped shellfish habitat. Any work in the intertidal zone should be limited to low tide
such that work is conducted in the “dry”.
• If approved, any activities requiring a barge should be restricted to 2 hours before and
after high tide to prevent barge grounding in marine habitat.
• 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
3
cc:
Mark Burgess, Shorefront Consulting
John Logan, Alicia Hecht, Holly Williams, Matt Camisa, MA DMF
Victoria Cotone, Yarmouth Shellfish Constable
Patrice Bordonaro, CZM
AD/ah
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. MA DMF. MassGIS Data: Diadromous Fish. https://www.mass.gov/info-details/massgis-
data-diadromous-fish. Accessed February 8, 2023. 2023.
4. ASMFC. 2020. Southern New England Mid-Atlantic Winter Flounder 2020 Assessment
Update Report. http://www.asmfc.org/uploads/file/6008bd822020_SNE-
MA_WinterFlounderAssessmentUpdate.pdf
5. 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