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HomeMy WebLinkAbout10 SE48_3115 Epsilon Presentation 11_05_18 PRINCIPALS Theodore A Barten, PE Margaret B Briggs Dale T Raczynski, PE Cindy Schlessinger Lester B Smith, Jr Robert D O’Neal, CCM, INCE Andrew D Magee Michael D Howard, PWS Douglas J Kelleher AJ Jablonowski, PE Stephen H Slocomb, PE David E Hewett, LEED AP Dwight R Dunk, LPD David C. Klinch, PWS, PMP Maria B. Hartnett ASSOCIATES Richard M. Lampeter, INCE Geoff Starsiak, LEED AP BD+C Marc Bergeron, PWS, CWS 3 Mill & Main Place, Suite 250 Maynard, MA 01754 www.epsilonassociates.com 978 897 7100 FAX 978 897 0099 Projects:\21597 Lighthouse\2018\Expanded Project\NOI November 7, 2018 Mr. Jeff Carlson Via U.S. Mail & Electronic Mail Natural Resources Director, Town of Nantucket Conservation Commission Office 2 Bathing Beach Road Nantucket, MA 02554 Subject: DEP File No. SE048-3115 - Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project Dear Mr. Carlson: Attached please find for the record a hard copy of the Power Point file presented at the November 5, 2018 Notice of Intent Public Hearing for the above referenced project. An electronic copy of this presentation is also being submitted by email for your use. Sincerely, EPSILON ASSOCIATES, INC. Dwight R. Dunk, LPD, PWS, BCES Principal encl.: Power Point Presentation “Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project” dated November 5, 2018 cc: J. Posner, SBPF S. Cohen, Cohen & Cohen Law G. Wood, Rubin and Rudman Notice of Intent Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project November 5, 2018: Meeting #3 Sept 2018 Existing Project Jute/Coir Envelopes Meeting Agenda 1.Overview 2.Sediment Transport 3.Sand Mitigation •Mitigation Requirement •Beach Profile Surveys •Bathymetry Profile Surveys •Nearshore Cobble/Boulder Surveys •Sand Source 2 1. Overview 3 4 Existing Geotube Project 5 Proposed Geotube Project 6 Proposed Geotube Project Sand Mitigation Summary Protocol Summary: Complete construction placing 22 cy/lf of compatible sand on the template. Periodically contribute sand to the littoral drift system by covering exposed tubes after erosion events. “What was Contributed from the Template?” Determine volume of sand contributed to the littoral drift system during the winter storm season. Replace sand on the template with the volume of sand contributed to the littoral drift system the previous year or up to 22 cy/lf, whichever is greater, to “top it off.” 7 Sand Mitigation Consistent with Regulations and Policy Proposed sand mitigation complies with the MA Wetlands Protection Act regulations/performance standards and the Nantucket Wetlands Bylaw regulations/performance standards: –Protects the stability of the Coastal Bank, and –Is the best available measure to supply sediment to other downdrift coastal wetland resource areas. Proposed adaptive sand mitigation is the “best available measure” and meets the MA CZM Coastal Hazard Policy #1. Evaluation of coastal profile data and nearshore cobble/boulder survey results reveal the existing geotube project has no apparent negative effects to adjacent coastal wetland resource areas and sand mitigation has been maintaining the coastal system. The sand mitigation volume each year will be based on the losses the previous year, i.e. short-term contribution rate rather than long-term average erosion rate. 8 Adaptive Management Protocol Comparison 9 Comparison of Existing Sand Replenishment Requirements and the Proposed Adaptive Management Protocol Existing Requirements (OOC SE 48-2824) Proposed Protocol 32. Sand mitigation shall be at a rate of 22 cubic yards per linear foot (cy/lf) per year in accordance with the following schedule: Place sand on the template before the winter storm season equal to the volume of sand contributed off the template the previous storm season or to refill the template to 22 cy/lf, whichever is greater. 32(b). Maintain a minimum 2 foot cover over the Geotubes to protect them from UV degradation Maintain 2 feet of sand cover on the template to protect the tubes from UV degradation. 32(c). Annually in September-November: ensure a substantial portion of the sand template volume (l0-15 cy/lf) is available at the onset of the winter storm season. Throughout the winter, place additional sand on an as-needed basis, 1. Place sand on the template before the winter storm season: a) volume of sand contributed off the template the previous storm season or b) refill template up to 22 cy/lf, whichever is greater. 2. Re-cover exposed geotubes within 10 business days, in accordance with the replenishment trigger in the Milone & MacBroom November 12, 2013 letter 32(d). Delivery tickets from sand supplier shall be provided annually to the Department and the NCC Will continue to follow this condition to document the total volume of sand provided on a yearly basis. 34(c.) Failure to repair and/or replace damaged geotextile tubes in a timely manner. If repair or replacement cannot be accomplished within 30 days from the date of the damage, SBPF shall notify the Department and the NCC before 30 days have elapsed and provide a repair schedule for Department review and approval. Follow this condition for repairs or replacement of damaged geotubes. Sand management, re-cover exposed geotubes within 10 business days unless unsafe work condition. SBPF will notify the Conservation Commission if geotubes cannot be re-covered within 10 business days and provide a schedule to re-cover exposed tubes. Offshore Submarine Bars Dynamic Littoral Drift System 10 Sediment Transport – Northward With Great Point and Submarine Bar Buildup Dynamic Littoral Drift System 11 Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project DEP File#: SE48-3115 Anticipated Topics for October 22, 2018 •Sediment Transport •Sand Replenishment Protocols Sediment Transport – Southward with beach/dune accretion at Sewer Beds Dynamic Littoral Drift System 12 Figure 3. Shoreline change plot utilizing data from the 77th Southeast Nantucket Beach MonitoringReport, dated September 2018. This figure is set-up differently than Figure 3 from the September 2018 Monitoring Report. This figure is set up to assist the reader in visualizing the shoreline changes pre- and post-geotube installation. The perspective is that you are looking at the shoreline (x-axis) from the ocean. South is to the left, north is to the right. The average rate of shoreline retreat (erosion of land) is plotted above the x-axis (negative y-axis values toward the top) while the average rate of shoreline advance (beach expansion toward the ocean) is plotted below the x-axis (positive y-axis values toward the bottom). Applied Coastal Research and Engineering Comments Rate of Shoreline Change 13 Woods Hole Group Data Rate of Shoreline Change 14 Woods Hole Group Data Rate of Shoreline Change 15 South North Woods Hole Group Data Rate of Shoreline Change 16 Station ID Pre-Geotube Annual Erosion Rate (cy/yr) Post-Geotube Annual Erosion Rate (cy/yr) 11/94 to 12/01 12/01 to 9/13 9/13 to 9/18 South of Existing Geotube System 88 -5.9 -4.3 0.5 89 -7.8 -1.6 -1.4 90 -8.7 -0.6 -0.3 90.6 -7.3 -0.7 -0.1 Project Area North of Existing Geotube System 92 -1.8 -1.2 -0.8 92.5 -3.0 -0.1 -2.1 93 -4.4 0.2 -2.1 94 -3.7 -0.4 -2.0 95 -3.6 -1.1 -2.5 Annualized Volumetric Changes for Three Time Periods 2. Sediment Transport 17 Sediment Transport Mechanisms •Cross-shore transport •Longshore Transport •Diffusion 18 Cross-shore Transport •Movement of sand onshore and offshore •Results in movement of shoreline but is not technically erosion as the volume remains the same •Landward extent is the top of the unprotected bluff •Seaward extent is between -25 feet and -35 feet, MLW. 19 Cross-shore Transport •Best evident in summer and winter profiles From: Steve Earle, Physical Geology, Pressbooks. 20 Cross-shore Transport •Interestingly, profiles on the east coast of Nantucket do not show markedly different winter and summer profiles •However, the principle is similar in that sand is redistributed across the profile based on storms and then calmer periods 21 Cross-shore Transport ~2,000’ 22 Cross-shore Transport •Profile 95 23 Cross-shore Transport •Profile 95 24 Cross-shore Transport •Profile 95 25 Cross-shore Transport ~1,500’ 26 Cross-shore Transport •Profile 88 27 Cross-shore Transport •Profile 88 28 Cross-shore Transport •Profile 88 29 Cross-shore Transport •Bluff face collapse is a cross-shore transport process •Undercutting at the base of the bluff occurs during a storm event •Timing of bluff failure could be during the storm event or well after the storm event 30 Cross-shore Transport •Relevance to the Geotextile Tube System •Cross-shore transport does not directly result in downdrift erosion •The geotextile tubes avoid periodic loss of sand from the bluff (and the bluff cannot be naturally rebuilt) •This can/will happen periodically on adjacent shorelines regardless of the geotextile tube project given a large enough storm event 31 Longshore Transport •North and south movement of sand 32 Longshore Transport 33 Longshore Transport •Driven by waves arriving at an angle to the beach Oblique Waves 34 Longshore Transport •Variation in longshore transport causes erosion and accretion •Transport in > transport out  accretion •Transport out > transport in  erosion •This can happen naturally along different sections of the shoreline •The geotextile tube project area has a naturally higher erosion rate than areas to the north and south 35 Longshore Transport •The magnitude of longshore transport is a function of: •Wave height •Wave angle •Wave period •Grain size •Offshore beach slope 36 Longshore Transport •Where does longshore transport occur? •Mostly in the breaker zone •Some in the swash zone Swash Breaking Zone Longshore Transport •Greatest longshore component in the breaking zone •Second maxima in the swash zone (beach face) From Pilkington (2007). Coastal Hydrodynamics and Transport Processes, Danish Hydraulics Institute. 38 Longshore Transport •Relevance to Geotextile Tube System •Sand is not transported longshore at the highest elevations along the beach face •Sand transport is primarily in the wave breaking zone and secondarily as part of runup •Once there is sufficient sand in the system as a whole, then sand will be moved alongshore at natural rates 39 Diffusion •A form of longshore transport •Spreading loss due to a “perturbation” (bump) in the shoreline From Dean, R.G. (2002). Beach Nourishment: Theory and Practice, World Scientific 40 Diffusion •Relevance to the Geotextile Tube system •Potentially applicable at Sconset due to excess sand being placed in front of the geotube system •Would increase movement of sand from in front of the geotube system to adjacent beaches •Not readily apparent reviewing existing shoreline data •Small offset, short length and large wave climate creates quick diffusion •Increases longshore distribution of sand placed by SBPF 41 Summary •Sand from higher portions of the bluff are pulled to lower sections of the beach profile and then transported alongshore •SBPF’s overfilling in front of the geotextile tube system puts additional sand in the system adjacent to the project as well 42 3. Sand Mitigation 43 3. Sand Mitigation 44 •Mitigation Requirement •Beach Profile Surveys •Bathymetry Profile Surveys •Nearshore Cobble/Boulder Surveys •Sand Source Coastal Bank Performance Standard: 310 CMR 10.30(3) (a) Coastal engineering structure or modification shall be designed so as to minimize, using best available measures, adverse effects on adjacent or nearby coastal beach. 45 Project Compliance: Sand Mitigation is incorporated into the design to minimize adverse effects to adjacent beaches because it is a best available measure. Mitigation – Requirement Coastal Bank Performance Standard: 310 CMR 10.30(3) continued 46 Best Available Measures is defined at 310 CMR 10.4 as: “..the most up- to-date technology or the best designs, measures or engineering practices that have been developed and that are commercially available.” In the Notice of Intent and at our last Conservation Commission meeting (October 1, 2018) we reviewed the extensive alternatives analysis that this project has evaluated over the last 20 plus years and we demonstrated that the Proposed Project meets the above definition. Mitigation – Requirement 47 Project Compliance (a. continued): Sand Mitigation Coastal bank Sediment contribution rate for Proposed Project has been calculated using standard approach: Sediment Contribution = Project Length x Bank Height x Retreat Rate Project Length = 2,873 ft Bank Height = 74 ft Retreat Rate = 2.8 ft/yr Calculated Coastal Bank Sediment Contribution Rate = 7.7 cy/lf/yr Coastal Bank Performance Standard: 310 CMR 10.30(3) (continued) Mitigation – Requirement (Calculating Mitigation Volume) 48 Lots Length 59-87 1,978 ft 105-119 895 ft Total 2,873 ft Length Mitigation – Requirement (Calculating Mitigation Volume) 49 Average Coastal Bank Height = 74 feet 74 ft Height Mitigation – Requirement (Calculating Mitigation Volume) 50 Annual Retreat Rate = 2.8 ft/yr Average of transects in NOI: Table 2-2 provides transects for 107-119 Baxter Rd and Table 2-3 provides transects for 71-85 Baxter Rd. This average retreat rate for the Proposed Project is significantly lower than the retreat rate for the reach of bluff at the Existing Project of 4.6 ft/yr. Retreat Rate * * Mitigation – Requirement (Calculating Mitigation Volume) •Greater Sand Volume with Project: Sand is eroded from the template during coastal storms and sediment transport makes this sand available to the regional Sconset littoral drift system at a greater volume than would be available without the Project. •Provides Interest of Storm Damage Prevention: Mitigation sand is available to downdrift Coastal Beaches and Land Under the Ocean which rebuilds the volume of sand in these Resource Areas that is lost to sediment transport. This in turn enables these downdrift coastal landforms to continue to provide a buffer from coastal storm waves (Interest of Storm Damage Prevention). •Bulldozer Speeds Geotube Re-covering: Proposed adaptive sand management program involves SBPF funding the use of a project-dedicated bulldozer so that sand can be moved to cover exposed geotubes as quickly as possible after coastal storms. 51 Coastal Bank Performance Standard: 310 CMR 10.30(3) (continued) Mitigation – Requirement Coastal engineering structures (other than bulkheads and groins) may be permitted only upon a clear showing that no other alternative exists to protect a structure that has not been substantially improved or public infrastructure built prior to 9/78, from imminent danger. Project Compliance: •Alternatives Analysis: previously reviewed. •Project Protects: Baxter Road and other public infrastructure. •Project Preserves: an entire historic largely pre-78 community, which includes pre-78 homes to which various alterations have been made and a number of post-78 homes. 52 Nantucket Coastal Bank Performance Standard: 2.05 B(1) Existing Project Jute/Coir Envelopes Mitigation – Requirement Projects shall be restricted to activity determined by the Commission to have no adverse effect on bank height, bank stability, ...or the use of a bank as a sediment source. Project Compliance: No adverse effect on: •Bank Height: Project will preserve rather than adversely affect bank height. •Bank Stability: Project will maintain bank stability by protecting the lower bank from wave-induced erosion. Vegetation plantings on the upper bank face will also prevent rain- and wind-induced erosion. •Sediment Source: Project provides sand mitigation and includes monitoring of adjacent and downdrift beaches. 53 Nantucket Coastal Bank Performance Standard: 2.05 B(3) Mitigation – Requirement Mitigation - Requirement Follows MA Office of Coastal Zone Management (CZM) Coastal Hazards Policy #1: Preserve, protect, restore, and enhance the beneficial functions of storm damage prevention and flood control provided by natural coastal landforms, such as dunes, beaches, coastal banks, land subject to coastal storm flowage, etc. Coastal Engineering Structure requirement: •Only feasible alternative •Compatible sediment must be periodically placed in the littoral system to compensate for sediment lost to the system * Lost to system = volume of sand no longer available to system due to presence of coastal engineering structure. 54 54 Mitigation - Requirement Follows MA Office of Coastal Zone Management (CZM) Coastal Hazards Policy #1 (continued): Sediment Mitigation Volume based on: •Calculation of the long-term average annual erosion rate of the coastal landform at the site. •Short-term rates* can be considered if the issuing authority determines that the short-term rate is more indicative of current and future conditions due to alterations along the shore. •Proposed Project has calculated project site specific rates. 55 55 Mitigation – Existing Project Calculated Sediment Contribution for the Coastal Bank at the Existing Project Site was 12-14.3 cy/lf/yr for pre-construction condition. Annual Placement of 22 cy/lf/yr – Even if the sand template already contains a substantial volume of sand. Existing Sand Template: Contributed on average 13.5 cy/lf/yr (2016-2018)* which is generally consistent with pre-construction conditions. * This three-year period does not include initial construction sand volume and better represents annual average template maintenance volume: (2016 = 11.3 cy/lf; 2017 = 8.9 cy/lf; 2018 = 20.3 cy/lf) Problem: Annual placement of 22 cy/lf/yr leaves significant volume of sand in template at end of each season. Creates an unsafe oversteepened top-heavy bank. 56 56 57 Calculated Sediment Contribution = Project Length x Bank Height x Retreat Rate Project Length = 2,873 ft Bank Height = 74 ft Retreat Rate = 2.8 ft/yr Calculated Coastal Bank Sediment Contribution Rate for Proposed Project = 7.7 cy/lf/yr or 22,122 cy/yr. Actual Contribution of 22 cy/lf/yr correlates to 63,206 cy/yr which is 2.9 times calculated sediment contribution rate for Coastal Bank in Proposed Project area. Proposed Adaptive Template Management Plan: Refill template to 22 cy/lf before storm season. Mitigation – Proposed Project Sand Mitigation – Proposed Adaptive Approach •Beginning of Storm Season: Refill template with volume of sand contributed off template previous season, or up to 22 cy/lf, whichever is greater. •After Storm Erosion: Replenish sand over Geotubes with sand from template. •Placement with dedicated Bulldozer: Within 10 business days replace sand over Geotubes using Project dedicated bulldozer funded by SBPF. •Adaptive Approach is Preferred: Avoids overfilling template which causes: •Covering existing vegetation. •Creating overly steep access ramps resulting in difficult pedestrian and vehicle access for template management. 58 59 Sand Mitigation – Other Projects? Woods Hole Group’s Report, (NOI, Attachment E) Supplemental Historic Analysis of Survey Data a t Siasconset, Nantucket, MA, December 2016 WHG conducted background research on other projects with Orders of Conditions requiring sand mitigation - 10 projects: 2 on Nantucket, 1 on Martha’s Vineyard and 7 on Cape Cod. •Timeframe: 1986-2016 •Hard and soft engineering solutions •Shoreline reaches: 100 ft – 1,800 ft •Annual sand mitigation: 65 – 1,100 cy/yr •Volume based on: bank height, project length & bank retreat rate •The proposed Sconset project is many times larger than these other approved projects Beach Profile Surveys 60 61 Beach Profile Surveys – Summary Woods Hole Group’s Report, (NOI, Attachment E) Supplemental Historic Analysis of Survey Data at Siasconset, Nantucket, MA December 2016 WHG conducted supplemental data analysis on beach profile survey data in Existing Geotube area focusing on shoreline change, volume change and bathymetry. 62 Beach Profile Surveys – Summary Woods Hole Group’s Report* (Continued) Strong correlation (linear relationship) exists between the shoreline position (MLW) and beach sand volume in representative profiles, before and after Geotube installation. * These data are presented quarterly to the Conservation Commission. To date 77 quarterly surveys have been completed by WHG. 63 Beach Profile Surveys – Summary Woods Hole Group’s Report (Continued) Cumulative Shoreline Change in Project Area ~ 20 years. Profile 91 •Net shoreline loss since 1994 ~ 110 ft •Since 2005 – long-term erosion with periodic accretion events. •Post Geotube similar to overall trend. 64 Beach Profile Surveys – Summary Woods Hole Group’s Report (Continued) Cumulative Shoreline Change in Squam Area . Profile S •Net shoreline advance ~30 ft since 1994. •Variable shoreline – relatively stable since 2007 •Post Geotube similar to overall trend. 65 Beach Profile Surveys – Summary Woods Hole Group’s Report (Continued) Cumulative Shoreline Change in Codfish Park Area. Profile 84 •Late 1990’s shoreline threatening Codfish Park Road. •Overall shoreline advance ~130 ft since 2000. •Relatively stable since 2003-2004. •Post Geotube similar to overall trend. •High degree of variability. •Post-Geotube similar to Pre-Geotube •No evidence of accelerated erosion Post-Geotube exceeding historical observations. 66 Beach Profile Surveys – Summary Woods Hole Group’s Report (Continued) Cumulative Shoreline Change at 6 profiles in Geotube Project Area and immediately adjacent areas. Bathymetry Profile Surveys 67 Bathymetry Profile Surveys 68 Woods Hole Group’s Report Surveys conducted from shoreline (MLW) out to depth of -40 feet 69 Bathymetry Profile Surveys – Summary Woods Hole Group’s Report (Continued) Bathymetry Transects at Project Area since 2008. Data depicts a Stable Profile. 70 Bathymetry Profile Surveys – Summary Woods Hole Group’s Report (Continued) Bathymetry Transects at Squam Area since 2008. Data Depicts a Stable Profile. 71 Bathymetry Profile Surveys – Summary Woods Hole Group’s Report (Continued) Bathymetry Transects at Codfish Park Area since 2008. Depicts Large-scale Dynamic Shoal Changes. 72 Beach and Bathymetry Surveys – Findings Woods Hole Group’s Report, (NOI, Attachment E) Findings: •No statistically meaningful trend to Long-term shoreline changes: These data exhibit a high degree of variability on short and long time scales. •Present shoreline is similar in position to the shoreline position 8-10 years ago. •Recent shoreline changes since Geotube installation exhibit similar patterns. •Geotube project influence is not significant and/or the associated mitigation is effectively helping to maintain the coastal system. 73 Beach and Bathymetry Surveys – Findings Woods Hole Group’s Report (Continued) Findings (continued): •Strong correlation exists between the shoreline position and volume of sand in the profile. •Bathymetry data offshore Sconset Project Area features a generally stable profile. •Beach response since geotubes were installed is similar to past measured shoreline changes. These data suggest that the sand volume required can be reduced to offset the long-term sand volume erosion rate in the project area. 74 Beach and Bathymetry Surveys – Findings Woods Hole Group’s Report (continued) Findings (continued): •Generally, there have not been apparent adverse effects to adjacent coastal landforms since the placement of the existing geotube project. •Beach performance trends since installation of geotubes are similar to historic trends before geotubes. •Documented large natural variability precludes a purely quantitative statistical measure of project performance and impacts. •Data indicate that the geotube project influence is not significant and/or the associated sand mitigation is effectively helping to maintain the coastal system. Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project DEP File#: SE48-3115 Anticipated Topics for October 22, 2018 •Sediment Transport •Sand Replenishment Protocols Nearshore Cobble/Boulder Surveys 76 Nearshore Cobble/Boulder Surveys Sconset Beach Underwater Video Survey Report Epsilon Associates and CR Environmental, October 2018 •Underwater video surveys were conducted in nearshore off Geotube project in 2016, 2017 and 2018. •2018 report summarizes survey results for 2018 and compares with previous 2016 and 2017 surveys. •Reports presented to Conservation Commmission after each survey. 77 Underwater Video Trackline Map 78 Percent Cobble/Boulder at Trackline Intersections JUN 2016 79 Underwater Video - Screen Shot Project Area Nearshore (200 ft from beach) JUN 2016 80 Underwater Video - Screen Shot Project Area (700 ft from beach) JUN 2016 81 Percent Cobble/Boulder at Trackline Intersections JUN 2017 82 Underwater Video - Screen Shot Project Area Nearshore (200 ft from beach) JUN 2017 83 Underwater Video - Screen Shot Project Area (700 ft from beach) JUN 2017 84 Percent Cobble/Boulder at Trackline Intersections JUN 2018 85 Underwater Video - Screen Shot Project Area Nearshore (200 ft from beach) JUN 2018 86 Underwater Video - Screen Shot Project Area (700 ft from beach) JUN 2018 87 Nearshore Cobble/Boulder Surveys JUN 2018 JUN 2017 JUN 2016 88 Nearshore Cobble/Boulder Surveys Sconset Beach Underwater Video Survey Report Epsilon Associates and CR Environmental, October 2018 Findings: • Continues to be significant natural variability of nearshore habitat. •Cobble/boulder cover increases as you go farther offshore. • Highest concentration of cobble/boulders continued to be found in same general areas. •June 2018 survey indicates that a productive widespread cobble/boulder habitat continues to be located just offshore the Geotubes and there is no indication that habitat is being covered by sand mitigation. 89 Sand Sources Sand Sources •Proposed Sand Source –Island and Off-Island Sand Pits 90 90 Sand Mitigation Summary •Proposed sand mitigation: complies with the MA Wetlands Protection Act regulations/performance standards and the Nantucket Wetlands Bylaw regulations/performance standards for coastal wetlands resource areas in Project Area. Protects the interests of Storm Damage Prevention and Flood Control. •Proposed adaptive sand mitigation: meets the Coastal Hazard Policy of MA CZM. •Nearshore cobble/boulder surveys: –Show continued prevalence of cobble/boulder habitat located directly offshore from Project. –No apparent negative effects due to Geotube Project. •Sand mitigation volume each year will be based on the losses the previous year. 91 92 Thank You 92