HomeMy WebLinkAboutNarrative 9.1.2026
P.O. Box 4012, Plymouth, Massachusetts 02361 617-529-3792 | www.ecrwetlands.com
VEGETATION MANAGEMENT PROPOSAL
TO:
Todd Wakefield
FROM: Brad Holmes
DATE: August 31, 2026
RE: 23 Erik’s Path, Yarmouth
Environmental Consulting & Restoration, LLC (ECR) is pleased to provide this Vegetation
Management Plan to accompany the Notice of Intent application for the proposed Coastal Bank
stabilization activities at 23 Erik’s Path in Yarmouth (the site). The goal of the Vegetation
Management Plan is to restore and enhance the buffer zone to Follins Pond with a native plant
community as part of the proposed project. The proposed plan also includes vista pruning to
allow for better views of Follins Pond. The plan has been designed to remove non-native
invasive plant species, install new native plantings, and manage the area to improve the overall
capacity of the resource areas and buffers to protect the interest of the MA Wetland Protection
Act (MA WPA) and the Town of Yarmouth Wetland Bylaw (the Town Bylaw).
Vegetation Management Activities
Vegetation management is proposed on the Coastal Bank leading to Follins Pond. The
management area is identified on the site plan prepared by WRS Engineering. Management
activities include hand removal and selective herbicide application of non-native invasive plant
species. Invasive species identified onsite include Burning Bush (Euonymus alatus) and
Oriental Bittersweet (Celastrus orbiculatus). Additionally, there is an extensive amount of
English Ivy (Hedera helix) that is impacting the existing native vegetation at the site. English Ivy
is an aggressive invasive plant not listed on the Massachusetts Invasive Species List but is
significantly impacting this site. Furthermore, the plan includes planting of native species and
ongoing monitoring/maintenance of the site.
Removal of Non-Native Invasive Species – The woody invasives are proposed to be treated
and removed from the site utilizing the “cut & paint” method. The targeted plants will be
flagged in the field by the overviewing botanist, flush cut at the base of their stem, and then
removed from the site. Upon cutting, the stems will be painted with herbicide to prevent
stump sprouting and ultimately kill off the remaining root mass. The herbicide product
proposed for usage will be chosen by the licensed herbicide applicator to include
coordination of the product details with the Conservation Agent prior to application. Though
labor intensive, this technique prevents herbicide exposure to non-target plants. All
herbicide use will be completed by a licensed herbicide applicator in compliance with
manufacturer guidelines.
Post herbicide treatment, follow up treatments will follow the methodology described above.
The cut invasive plant materials should be transported to licensed disposal facility to
properly dispose of the invasive plant material to ensure no further infestations offsite.
P.O. Box 4012, Plymouth, Massachusetts 02361 617-529-3792 | www.ecrwetlands.com
Planting Native Species – Following the treatment and removal of the non-native invasive
species within the management area, the restoration area should be enhanced with new
native plantings. Once the invasives have been removed, the management area shall be
inspected by the overviewing wetland specialist to determine the quantity and placement
location of new plants. Based on the overall project area of approximately 3,650 square feet
with an estimated coverage of approximately 40% non-native invasive and 60% native, ECR
estimates that approximately 12 saplings and 30 shrubs will be needed during the planting
project. These numbers are calculated using saplings spaced 12 feet on center and shrubs
spaced 8 feet on center, which follows DEP’s Inland Wetland Replacement Guidelines.
Once installed, the root zones of the new plants will be covered with natural mulch or wood
chips. The intent of new plantings will be to fill-in the areas void of vegetation following
removal of invasives and restore the capacity of the buffer zone to protect the interest of the
MA WPA and the Yarmouth Wetland Bylaw. Proposed new plantings are shown on the
attached plan. Any plant substitutions should be coordinated with the Conservation Agent
and chosen from the plant list found at:
https://www.umass.edu/agriculture-food-environment/landscape/fact-sheets/trees-shrubs-
for-coastal-environments-freshwater-resource-buffer-zones
The proposed vegetation management plan has been designed to be implemented over time.
The management is proposed over the life of the Order of Conditions (3 years). Monitoring and
reporting of the success of the management project will follow the anticipated special conditions
of the Order of Conditions.
Mitigation Planting Area – In order to permit a past patio replacement project, mitigation planting
is proposed within the inner buffer zone. Approximately 1,275 square feet of mitigation is
proposed consisting of the removal of existing lawn area and replacement with native vegetation
as shown on the attached plan. The mitigation project will involve the following activities:
1. Prior to the start of work, erosion control barriers will be installed along the downgradient
limit of the restoration/mitigation area.
2. Prior to planting, the existing lawn within the restoration/mitigation area will be removed
to expose the underlying native topsoil.
3. The area will then be hand-planted with a mixture of native low-growing shrubs and
grasses suitable for the coastal environment.
4. Upon completion of planting, the restoration/mitigation area, including the root zones of
the installed vegetation, will be mulched with a light layer of natural wood chips.
5. Erosion control barriers will remain in place until all site work has been completed and
the area is fully stabilized, at which time they will be removed and properly disposed of.
6. The applicant will provide supplemental irrigation as necessary to promote establishment
and maintain healthy vegetation.
7. The mitigation area will be inspected each fall for a period of two years to identify non-
native invasive species and other undesirable vegetation. Any such vegetation observed
will be manually uprooted and removed from the mitigation area.
Vista pruning- Vista pruning is also proposed to improve the health of the existing trees and to
improve the vista to Follins Pond. Proposed vista pruning will follow the Town of Yarmouth’s
Vista Pruning Guidelines. The removal of hanging vines, specifically the extensive Oriental
P.O. Box 4012, Plymouth, Massachusetts 02361 617-529-3792 | www.ecrwetlands.com
Bittersweet and English Ivy, has impacted native vegetation, and pruning of tree limbs is
proposed. Additionally, the trees have been improperly cut in the past for views to the pond and
should be properly pruned by an Arborist to improve the health and form of the trees. For more
information, please refer to the attached Photograph Pages attached.
Upon review of this Vegetation Management Proposal, please contact me at (617) 529 – 3792
or brad@ecrwetlands.com with any questions or requests for additional information.
23 Erik’s Path, Yarmouth
Site Photographs 04/27/2026
Photograph #1 – Example of severely impacted Black Oak tree with Oriental Bittersweet and English Ivy, which
are proposed for removal as part of the management plan.
Photograph #2 – Another view of the impacted trees within the proposed vegetation management area on the
Coastal Bank.
23 Erik’s Path, Yarmouth
Site Photographs 04/27/2026
Photograph #3 – Example of Burning Bush shrubs on the Coastal Bank proposed for removal.
Photograph #4 – View across the maintained yard towards the top of the Coastal Bank. Notice the vine
impacted tree and poorly formed tree, which requires pruning to improve tree form.
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Performance Standards Narrative, Alternatives Analysis, and Construction Protocol
A. PROPERTY DESCRIPTION
The property is located on Follins Pond in Yarmouth, MA; a tidal waterbody with hydraulic connection
to Nantucket Sound. The project site is situated along the shoreline of the pond in an area subject to tidal
fluctuation and periodic storm inundation. The property is located on a developed residential lot with an
existing single-family dwelling and associated landscaped areas.
The area upland of the coastal bank consists of lawn and landscaped vegetation extending from the
existing dwelling down toward the shoreline. The coastal bank slopes toward the water and transitions
into a coastal beach, salt marsh and land under ocean. The shoreline has experienced ongoing erosion,
resulting in a scarped bank and loss of vegetative cover in certain areas. Erosion has increased over the
last 10 years due to escalating tidal action caused by various restrictions in the river, as well as the decline
of native bank vegetation resulting from a rapid increase in invasive species.
The area along the shoreline has a 3’-4’ vertical and over vertical scarp which cannot support any
vegetation at this point. Evidence of continued erosion and displacement of materials indicates that the
existing scarp will continue to increase, eventually taking all the vegetation with it. The bank currently
shows signs of instability due to increased wave action, tidal fluctuation, and storm events.
B. PROJECT DESCRIPTION
This proposal includes the following:
- Installation of coir logs with minor fill to create a stable bank toe
- Installation of native plantings to establish a vegetated buffer
- In-kind replacement of the existing licensed pier and float
C. PERFORMANCE STANDARDS
The resource areas associated with the project are Coastal Bank, Salt Marsh, Land Under the Ocean, Land
Containing Shellfish, and Land Subject to Coastal Storm Flowage (LSCSF). Please see below for the
performance standards narrative for the State Wetlands Protection Act 310 CMR and Town of Yarmouth
Wetland Regulations. The project, as proposed, will not have adverse effects on surrounding resource
areas.
LAND UNDER THE OCEAN
310 CMR 10.25 / YARMOUTH WETLAND REGULATIONS 4.01
WHEN LAND UNDER THE OCEAN IS DETERMINED TO BE SIGNIFICANT TO THE
PROTECTION OF MARINE FISHERIES, SHELLFISH, WILDLIFE HABITAT, OR FLOOD
CONTROL, THE FOLLOWING PERFORMANCE STANDARDS SHALL APPLY:
310 CMR 10.25(3) A proposed project in Land Under the Ocean shall not cause adverse effects by
changing the ability of the land under the ocean to provide marine fisheries habitat and shellfish habitat
functions.
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Yarmouth 4.01 Any activity within Land Under the Ocean shall not adversely affect marine fisheries,
shellfisheries, wildlife habitat, flood control, or water quality.
The proposed project includes in-kind replacement of the existing licensed pier, ramp, and float within
the existing footprint and configuration.
The proposed dock replacement will maintain existing site conditions and will not result in additional
adverse impacts to Land Under the Ocean. No expansion, enlargement, or intensification of use is
proposed.
The project, as proposed, will not adversely affect marine fisheries habitat, shellfish habitat, wildlife
habitat, flood control, or water quality.
Therefore, the project as proposed can be permitted under 310 CMR 10.25 and Yarmouth Wetland
Regulations 4.01.
COASTAL BANKS
310 CMR 10.30 / YARMOUTH WETLAND REGULATIONS 4.05
WHEN A COASTAL BANK IS DETERMINED TO BE SIGNIFICANT TO STORM DAMAGE
PREVENTION OR FLOOD CONTROL, THE FOLLOWING PERFORMANCE STANDARDS
SHALL APPLY:
310 CMR 10.30(3) On coastal banks significant to storm damage prevention and flood control, no project
shall have an adverse effect by increasing the potential for storm damage or flood damage caused by
erosion or accretion.
Yarmouth 4.05 Any activity on a coastal bank shall not have an adverse effect by increasing the potential
for storm damage, flood damage, erosion, or loss of wildlife habitat.
The proposed work is located within Coastal Bank associated with Follins Pond. Portions of the existing
coastal bank have experienced erosion, vegetation loss, and reduced stability.
The proposed work includes installation of coir logs, minor grading, invasive species management, and
native vegetative restoration to improve the stability and function of the coastal bank.
The proposed project will improve shoreline stability and reduce continued erosion while maintaining the
natural function of the coastal bank.
The project, as proposed, will not increase the potential for storm damage, flood damage, erosion, or loss
of wildlife habitat.
Therefore, the project as proposed can be permitted under 310 CMR 10.30 and Yarmouth Wetland
Regulations 4.05.
SALT MARSHES
310 CMR 10.32 / YARMOUTH WETLAND REGULATIONS 4.06
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WHEN A SALT MARSH IS DETERMINED TO BE SIGNIFICANT TO THE PROTECTION OF
MARINE FISHERIES, PREVENTION OF POLLUTION, STORM DAMAGE PREVENTION, FLOOD
CONTROL, OR WILDLIFE HABITAT, THE FOLLOWING PERFORMANCE STANDARDS SHALL
APPLY:
310 CMR 10.32(3) A proposed project in a salt marsh, on lands within 100 feet of a salt marsh, or in a
body of water adjacent to a salt marsh shall not destroy any portion of the salt marsh and shall not have an
adverse effect on the productivity of the salt marsh.
Yarmouth 4.06 Any activity within or adjacent to a salt marsh shall not destroy any portion of the salt
marsh or adversely affect the productivity or ecological function of the resource area.
Salt Marsh is present adjacent to the project area as shown on the attached plans. Both high marsh and
low marsh were encountered onsite and are shown on the project plans.
The proposed project has been designed to avoid adverse impacts to the adjacent salt marsh. No heavy
machinery or equipment shall operate within the marsh. Access for construction shall be from the
applicant’s property or from a working barge in accordance with the construction plans.
A minimum of three proposed pilings will be driven around the salt marsh in association with the in-kind
replacement of the existing licensed pier, ramp, and float. The proposed dock height will maintain the
required minimum clearance over the marsh, and the decking will utilize ¾-inch board spacing to allow
adequate light penetration to the marsh below.
The proposed work will not destroy any portion of the salt marsh or adversely affect salt marsh
productivity, ecological function, tidal flow, or wildlife habitat.
The project, as proposed, will not have adverse impacts to the salt marsh and is expected to improve
adjacent resource area conditions through shoreline restoration and vegetative enhancement.
Therefore, the project as proposed can be permitted under 310 CMR 10.32 and Yarmouth Wetland
Regulations 4.06.
LAND CONTAINING SHELLFISH
310 CMR 10.34 / YARMOUTH WETLAND REGULATIONS 4.08
WHEN LAND CONTAINING SHELLFISH IS DETERMINED TO BE SIGNIFICANT TO THE
PROTECTION OF SHELLFISH RESOURCES, THE FOLLOWING PERFORMANCE STANDARDS
SHALL APPLY:
310 CMR 10.34(3) A proposed project within Land Containing Shellfish shall not adversely affect the
productivity of shellfish beds or the habitat required to support shellfish populations.
Yarmouth 4.08 Any activity within Land Containing Shellfish shall not adversely affect shellfish habitat,
shellfish productivity, water quality, or sediment conditions necessary to maintain shellfish resources.
Land Containing Shellfish is present within the project area as shown on the attached plans. A portion of
the existing dock is located within Land Containing Shellfish.
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The disturbance to this resource area consists of removing and constructing wood pilings associated with
the in-kind replacement of the existing licensed pier, ramp, and float. The proposed work has been
designed to avoid adverse impacts to this resource area.
The float will maintain the required minimum height above the bottom at low tide. Disturbance
associated with the construction effort is expected to be minimal and will not adversely affect shellfish
habitat or shellfish productivity.
The proposed project will not alter the existing bottom substrate and therefore will not result in
significant impacts related to alterations in water circulation, sediment grain size distribution, natural
drainage from adjacent land, or water quality. This includes, but is not limited to, fluctuations in salinity,
dissolved oxygen, nutrients, temperature, turbidity, or the addition of pollutants.
The project, as proposed, will not result in long-term adverse impacts to water quality, sediment
conditions, or habitat conditions within Land Containing Shellfish.
Therefore, the project as proposed can be permitted under 310 CMR 10.34 and Yarmouth Wetland
Regulations 4.08.
LAND SUBJECT TO COASTAL STORM FLOWAGE
YARMOUTH WETLAND REGULATIONS 4.10
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;
ii. reducing the ability of the land to buffer more inland areas from flooding and wave damage;
iii. 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;
iv. displacing or diverting flood waters to other properties or resource areas;
v. causing ground, surface or saltwater pollution triggered by coastal storm flowage;
vi. reducing the ability of the resource to serve as a wildlife habitat and migration corridor; and
vii. preventing the migration of resource areas such as salt marsh due to sea level rise.
The proposed work will not reduce flood storage capacity, obstruct floodwaters, increase flood
elevations, redirect flood flows, or adversely affect storm damage prevention functions.
The proposed stabilization and restoration measures are low-impact and designed to improve shoreline
resilience, stabilize degraded coastal bank conditions, and enhance vegetative cover.
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The proposed project is expected to improve existing degraded conditions while maintaining the flood
control and storm damage prevention functions of LSCSF.
Therefore, the project as proposed can be permitted under Yarmouth Wetland Regulations 4.10.
TIDAL AND ESTUARINE DOCKS AND PIERS
YARMOUTH WETLAND REGULATIONS 3.01
The proposed project includes in-kind replacement of the existing licensed pier, ramp, and float within
the existing footprint and configuration.
The proposed dock replacement will maintain existing site conditions and will not result in additional
adverse impacts to surrounding resource areas. No expansion, enlargement, or intensification of use is
proposed.
Construction activities associated with the dock replacement will be temporary in nature and will be
completed in accordance with the construction plans. The proposed work has been designed to minimize
temporary construction-related impacts to adjacent resource areas.
The project, as proposed, will maintain the functional characteristics of the existing licensed dock
structure and will not create adverse impacts to tidal or estuarine resource areas.
Therefore, the project as proposed can be permitted under Yarmouth Wetland Regulations 3.01.
VARIANCE REQUESTS
Pursuant to Part 7, Section 7.01 of the Yarmouth Wetland Regulations, the Applicants request the
following variances for the replacement of the existing licensed pier, ramp, and float. The proposed work
will maintain the existing licensed footprints and will not adversely affect surrounding resource areas.
DOCK WIDTH
YARMOUTH WETLAND REGULATIONS 3.01(2)
Yarmouth Wetland Regulations 3.01(2) limits rebuilt piers to a maximum width of four feet, measured
inside pile to inside pile.
The Applicants request a variance from the maximum dock-width requirement to allow the existing
licensed pier to be replaced within its existing footprint, as shown on the project plans.
The proposed work will not expand the existing dock footprint or adversely affect surrounding resource
areas.
Therefore, the requested variance can be granted pursuant to Yarmouth Wetland Regulations Part 7.
HEIGHT ABOVE SALT MARSH
YARMOUTH WETLAND REGULATIONS 3.01(4)
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Yarmouth Wetland Regulations 3.01(4) requires rebuilt piers to achieve a minimum height-to-width ratio
of 1.5:1 across the full extent of the structure that overlies salt marsh, measured between the lowest
horizontal stringer and the salt marsh.
The Applicants request a variance from the required height-to-width ratio to allow the existing licensed
pier to be replaced and raised as shown on the project plans.
The pier will be constructed with a minimum one-inch spacing between deck boards to allow light
penetration to the salt marsh below. The proposed work will not destroy any portion of the salt marsh or
adversely affect salt-marsh productivity.
Therefore, the requested variance can be granted pursuant to Yarmouth Wetland Regulations Part 7.
FLOAT DEPTH
YARMOUTH WETLAND REGULATIONS 3.01(11)
Yarmouth Wetland Regulations 3.01(11) requires a minimum water depth of three feet at Mean Low
Water on the seaward side of a float and 2.5 feet on the landward side.
The project plans show a water depth of three feet at the seaward side of the float. The Applicants request
a variance from the minimum landward-side float-depth requirement to allow the existing licensed float
to be replaced within its existing footprint.
No dredging, bottom excavation, expansion, or relocation of the float is proposed. Maintaining the
existing float location avoids additional resource-area disturbance that could result from relocating the
float farther seaward or dredging to obtain additional water depth. The proposed work will not adversely
affect water circulation, sediment conditions, shellfish habitat, or water quality.
Therefore, the requested variance can be granted pursuant to Yarmouth Wetland Regulations Part 7.
D. EXISTING PATIO AND RETAINING WALL DESCRIPTION
An existing brick patio was present on the property when Todd and Tilynn Wakefield purchased the
residence in 2008. Historical photographs indicate that the brick patio existed in substantially the same
location and footprint as early as 2004. Photographs documenting the patio’s existence prior to the
Wakefields’ ownership are included with this filing.
23 Eriks Path
Figure 1: Image of the original patio.
Figure 2: Image of the patio following installation.
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Figure 3: Google Earth image documenting the original patio, with an overlay showing the patio
replacement installed in 2012.
In 2012, the existing brick patio was removed and replaced with a bluestone patio within substantially the
same footprint. At that time, a retaining wall associated with the patio area was also constructed. The
work was completed by contractor Bob Speakman.
According to the property owners, Mr. Speakman advised them that no local or state permits were
required for the patio replacement and retaining wall construction at the time the work was performed.
Based on that representation, the property owners proceeded with the improvements without submitting
permit applications.
The patio and retaining wall have remained in place since construction was completed in 2012. Historical
photographs documenting site conditions before and after the improvements are included as part of this
filing for the Commission’s review.
E. ALTERNATIVES ANALYSIS
OPTION 1: Current Proposal — Install coir logs with minor fill to create a stable bank toe, remove
invasive species, plant native species, and replace the existing licensed pier, ramp, and float in kind. This
option restores native habitat, stabilizes the coastal bank, maintains water access, and preserves existing
licensed structures. Therefore, this is the preferred alternative.
OPTION 2: Regrade the bank and plant only. To accomplish this, the entire bank would need to be
regraded, eliminating all remaining vegetation and habitat and resulting in the loss of approximately 3–4
trees. This option also does not address the replacement of the existing pier and float infrastructure.
Therefore, this is not a viable option.
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OPTION 3: Do nothing and allow the site to continue to degrade. Erosion would persist until a 10–12-
foot vertical bank forms, eliminating safe access to the water via the permitted stairs, pier, and dock. This
would result in continued habitat degradation and loss of shoreline stability. Therefore, this is not a viable
option.
F. CONSTRUCTION PROTOCOL
All work shall be completed in accordance with the approved plans and under the supervision of WRS
Engineering LLC.
Construction access shall be from the applicant’s property and/or from a working barge, as shown on the
approved plans. The use of a working barge will minimize impacts to surrounding resource areas during
construction activities associated with the coastal bank restoration and in-kind replacement of the existing
licensed pier, ramp, and float.
Construction materials shall be staged in the driveway or on the working barge. Construction staging and
access have been designed to minimize impacts to surrounding resource areas.
No heavy machinery or equipment shall operate within the salt marsh. All work adjacent to sensitive
resource areas shall be completed in a manner that minimizes temporary disturbance.
Coir logs shall be free of inorganic materials and installed in accordance with the approved plans. All
work associated with coastal bank restoration and dock replacement shall be completed in accordance
with accepted engineering and construction practices.
Appropriate erosion controls shall be installed prior to commencement of work and maintained
throughout construction.
All disturbed areas shall be stabilized immediately upon completion of work.
G. PRE-CONSTRUCTION MEETING
Prior to construction, a pre-construction meeting shall be held on-site with the Contractor, Property
Owner, Conservation Commission and/or Agent, and the Project Manager (WRS Engineering LLC). The
purpose of the meeting is to clearly delineate the limits of work and access, as well as the staging area.
The Contractor will describe the proposed means and methods for performing the work within the
requirements of the plans, order of conditions, and construction protocol. The Contractor will comply
with mitigation measures as established by the Conservation Commission.
H. POST-CONSTRUCTION MEETING
Upon completion, but prior to equipment being removed from the site, a post-construction meeting shall
be held on-site with the Contractor, Property Owner, Conservation Commission and/or Agent, and the
Project Manager (WRS Engineering LLC). The purpose of this meeting is to determine that the project
has been satisfactorily completed in accordance with all permits, and that no additional work or
mitigation is required by the Contractor.
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I. RESTORATION OF PROJECT AREA
Upon completion of construction, any and all areas disturbed by the construction effort shall be restored,
to the extent practicable, to their pre-construction conditions, to the satisfaction of the property owner
and Conservation Agent. All disturbed marsh or vegetated areas shall be revegetated with indigenous
plant or grass species to match pre-construction conditions in the surrounding areas, or as determined
during the pre-construction meeting.