HomeMy WebLinkAboutNarrative 6.3.2026Down Cape Engineering, Inc.
PROJECT NARRATIVE
Notice of Intent
#681 Route 28
West Yarmouth, MA
Project Introduction
The applicant respectfully submits this Notice of Intent application in support of the
construction of a stone revetment along the shoreline of Parker's River at 681 Route
28. The subject property is an approximately 2.2-acre parcel located within a
commercial zoning district. The site is currently developed with a restaurant and fish
market, originally constructed in 1966 and 1945, respectively, per the Town
Assessor's records. The property falls entirely within Land Subject to Coastal Storm
Flowage (AE el. 11), (AE el. 12), and (AE el. 13), within the Limit of Moderate Wave
Action. It should be noted that no work is proposed within any areas mapped as
Priority Habitat or Estimated Habitat for Endangered Species by the Massachusetts
Natural Heritage and Endangered Species Program (NHESP). A Coastal Bank exists
along the top of the existing stone revetment. The property abuts Parker's River along
its eastern portion, with the proposed work taking place within Parker's River and its
100-foot Inner Riparian Zone.
The regulatory and permitting history for the site is summarized as follows. The
existing stone revetment was licensed in 1991 under License No. 2647 and is recorded
at the Barnstable Registry of Deeds in Deed Book 7567 Page 261. In May 2011,
Coastal Engineering Co., Inc. filed a Notice of Intent for approximately 60 linear feet
of revetment repairs to the northern portion of the structure; that work was
subsequently completed under the issued Order of Conditions. In July 2022, Coastal
Engineering Co., Inc. filed a Request for Determination of Applicability in connection
with an emergency repair to the southern revetment section, which was followed by a
Notice of Intent filing in September 2022 to formally authorize the completed
emergency work. During the intervening period, the unprotected shoreline segment
between the northern and southern revetment sections continued to erode, resulting in
the partial loss of the existing asphalt parking surface. In October 2023, Coastal
Engineering Co., Inc. filed a Notice of Intent proposing a sheet pile wall seaward of
the eroding section; however, that structure was never installed. The present filing
proposes a redesigned approach to address the ongoing erosion along this segment of
shoreline
Proposed Work
The proposed work consists of the construction of a stone revetment along an
approximately 40-linear-foot section of unprotected shoreline that has deteriorated as
a result of ongoing tidal scouring. The proposed revetment will be constructed using
armor stone and bedding stone of varying sizes, placed at a slope of 1.25H:1 V to
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effectively absorb wave energy and provide long-term stability. Toe stones will be
embedded approximately five feet below existing grade to provide resistance against
future scour undermining. The proposed revetment will connect to and be generally
consistent in extent and elevation with the two existing licensed revetment sections
immediately to the north and south.
Portions of the proposed revetment will extend past the mean low water line, with
portions being placed within Parker's River. The proposed alignment generally
follows the existing revetment footprint, with minor variations to accommodate the
transition between existing sections and the more gradual slope. The proposed work is
not anticipated to obstruct navigation within Parker's River, as the existing revetment
structures to the north and south already define the shoreline configuration in this
area.
Incidental erosion of the existing asphalt parking surface into Parker's River has
occurred as a result of the unprotected shoreline condition. Upon completion of the
proposed revetment, the disturbed parking area will be restored to its pre -erosion
condition. Native coastal vegetation tolerant of salt spray will be planted along the top
of the revetment. A code -compliant safety fence will be installed between the restored
parking area and the vegetated strip.
310 CMR 10.25 Land Under the Ocean & Town of Yarmouth Wetland
Protection Regulations §4.01
The proposed stone revetment will extend past the mean low water line, placing
portions of the work within Land Under the Ocean as defined under 310 CMR 10.25.
No dredging is proposed as part of this project. Armor and bedding stones will be placed
at and below existing grade to accommodate anticipated scour, The existing grade
below the mean low water line will be disturbed during construction but will not be
permanently altered or raised.
The proposed revetment is not anticipated to adversely affect water circulation within
Parker's River. On the contrary, by filling the depression created by the loss of shoreline
protection, the revetment is expected to restore more uniform flow patterns and reduce
localized turbulence currently associated with the scoured low point. The project area
falls outside of MassDEP's mapped eelgrass beds. The placement of natural armor and
bedding stone will not alter the grain size distribution of existing sediments, and no
adverse impact to water quality is anticipated from the use of these natural materials.
The Division of Marine Fisheries (DMF) has identified Parker's River as a winter
flounder spawning habitat, thereby designating this area as a Habitat of Particular
Concern. In accordance with this designation, all in -water construction activities will
be restricted to the approved construction window and will not take place between
January 15 and June 15 of any year. The project is not within any areas mapped as
Priority Habitat or Estimated Habitat for Endangered Species by the Massachusetts
Natural Heritage and Endangered Species Program (NHESP).
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310 CMR 10.30 Coastal Banks & Town of Yarmouth Wetland Protection
Regulations K05
A Coastal Bank is present along the top of the existing stone revetment, delineated in
accordance with MassDEP Policy 92-1. The proposed project will impact
approximately 40 linear feet of Coastal Bank. The existing revetment was originally
licensed in 1991 and, as an armored structure, does not function as an active sediment
source. The proposed project will not adversely affect the shoreline, as the work is
confined to filling the actively eroding gap between two existing licensed revetment
sections. Flood control capacity will remain unaltered, and the completed revetment
will provide enhanced protection to existing structures situated landward of the
proposed work.
Section 4.05(3)(a) of the Town of Yarmouth Wetland Protection Regulations
prohibits the construction of new bulkheads, revetments, seawalls, groins, or other
coastal engineering structures along a Coastal Bank. The Applicant acknowledges that
the proposed structure constitutes a new revetment section; however, the prohibition
under §4.05(3)(a) is understood to be intended to protect Coastal Banks that function
as active sources of sediment to the littoral system. The Coastal Bank at this location
has been fully armored since 1991 and provides no sediment supply function.
Additionally, the existing restaurant and fish market located on the parcel were both
constructed prior to August 10, 1978, meeting the requirements for new construction.
310 CMR 10.34 Land Containinst Shellfish & Town of Yarmouth Wetland
Protection Regulations 44.08
A letter issued by the Division of Marine Fisheries in connection with the October 2023
Notice of Intent filing confirmed that the project site falls within mapped shellfish
habitat supporting bay scallop, blue mussel, softshell clam, and northern quahog. The
proposed work will result in temporary disturbance of the substrate during construction.
Because no dredging is proposed, the shellfish habitat is expected to recover and return
substantially to its former productivity upon completion of construction, consistent with
the performance standards of 310 CMR 10.34(5).
As discussed under the previous section for Land Under the Sea, the proposed
revetment is not expected to negatively affect water circulation. The placement of
natural stone materials will not alter sediment grain size distribution, and no water
quality impacts are anticipated. The project area is not located within an Area of Critical
Environmental Concern (ACEC).
310 CMR 10.58 Riverfront Area
Parker's River, a tidally influenced saltwater river, flows along the eastern boundary of
the subject property. The property falls within both the 100-foot Inner Riparian Zone
and the 200-foot Outer Riparian Zone of the Riverfront Area. Two existing revetment
sections, originally licensed in 1991 under License No. 2647, occupy the shoreline to
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the north and south of the proposed work area. The proposed revetment is generally
consistent in horizontal extent with the existing licensed structures. An alternatives
analysis addressing the requirements of 310 CMR 10.58(4) is provided as part of this
narrative.
Land Subject to Coastal Storm Flowage & Town of Yarmouth Wetland
Protection Regulations K10
The property is located entirely within Land Subject to Coastal Storm Flowage (AE
el. 11), (AE el. 12), and (AE el. 13) within the Limit of Moderate Wave Action. All
the proposed work will take place outside of the Limit of Moderate Wave Action.
The proposed stone revetment will require the placement of fill to match the grade of
the adjacent existing revetment sections and to restore the eroded shoreline to a stable
condition. Approximately 42 cubic yards of fill is associated with the proposed work.
No significant alteration of existing upland site grades is proposed beyond that
directly associated with the revetment footprint. Based on the proposed design, no
adverse impacts to flood storage or flood conveyance capacity are anticipated during
storm or flood events.
Construction Protocol
All construction equipment and materials will access the work area through the
existing paved roadway utilizing the paved parking lot. Prior to commencement of
any site work, a pre -construction meeting shall be arranged to include the responsible
contractor and Conservation Administrator.
The construction sequence will proceed as follows: (1) Staging of equipment and
materials shall take place within the designated staging area; (2) Construction of the
stone revetment, including placement of bedding stone and armor stone; (3)
Restoration of the asphalt parking lot to its previous condition; and (4) final site
stabilization to include coastal vegetation and a code -compliant safety fence.
Alternatives Analysis
In accordance with the performance standards of 310 CMR 10.58(4)(b), an alternatives
analysis has been conducted to evaluate feasible options for stabilizing the eroding
shoreline segment at 681 Route 28. The following alternatives were considered:
Alternative 1: No Action
Under the no -action alternative, the approximately 40-foot gap in the existing revetment
would remain unprotected. Continued tidal scouring would be expected to accelerate
the erosion of the exposed shoreline and the adjacent parking surface, with ongoing loss
of fill material into Parker's River. This alternative would not halt the erosion of the
asphalt parking lot into the waterway and would leave the existing licensed revetment
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sections vulnerable to failure as the unprotected gap continues to widen. The no -action
alternative is not considered feasible given the ongoing adverse impacts to both the
resource area and the existing commercial infrastructure.
Alternative 2: Soft Shoreline Stabilization
Soft stabilization techniques, such as coir logs, were evaluated as a potential alternative
to hard armoring. However, given the intensity of the tidal and wave energy at this
location, as evidenced by the progressive scouring that has occurred despite the
presence of the adjacent revetment sections, it has established that vegetative or
biodegradable stabilization measures are not expected to provide adequate long-term
protection at the proposed work location. Soft stabilization is best suited to low -energy
shoreline environments and is not considered a feasible primary stabilization strategy
at this site.
Alternative 3: Stone Revetment (Proposed)
The proposed stone revetment represents the preferred alternative and is consistent in
type, extent, and function with the existing licensed revetment sections to the north and
south. The use of armor stone at a 1.25H:1 V slope with embedded toe protection is
appropriate for the energy environment of this shoreline and has been demonstrated to
be effective at this specific location. This alternative minimizes impacts to the
Riverfront Area and other resource areas by limiting the work footprint to the 40-foot
gap between existing structures, rather than proposing new or expanded armoring
beyond the existing licensed extent. For these reasons, the proposed stone revetment is
identified as the least environmentally damaging practicable alternative that will
achieve the necessary shoreline stabilization objective.
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