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Home My WebLink About27 SE48_3115 SBPF Response to Quidnet Squam HOwners 2_11_19 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 21597/2018/Expanded Project/NOI/Public Hearing Comments March 1, 2019 Nantucket Conservation Commission Via Electronic Mail and U.S. Mail 2 Bathing Beach Road Nantucket, MA 02554 Subject: Response to Comments from Quidnet Squam Association comments dated February 11, 2019 on the Expanded Baxter Road and Sconset Bluff Storm Damage Prevention Project (DEP File No. SE 48-3115) Dear Commission Members: On behalf of the Siasconset Beach Preservation Fund (“SBPF”), Epsilon Associates, Inc. (“Epsilon”) submits response to comments submitted by the Quidnet Squam Association in two separate letters, one was submitted by the Quidnet Squam Association Board and the other was submitted by Peter and Maria Kellner. Both letters addressed the same issues to which responses are proved below. 1. The project adversely affect public rights to the beach. To ensure public rights are adequately protected, the SBPF will need to secure a License from the Town of Nantucket to use a portion of the beach for the Expanded Project. When granting a License the Town considers public rights to the beach along with other public benefits provided by the proposed use. This issue will be addressed through the Licensing process. 2. The project has been shown to cause downdrift damage and erosion. During the Winter of 2018-2019 the barrier to Sesachacha Pond was breached and the Polpis Road was damaged. This assertion is not supported by shoreline monitoring data. See responses submitted to the Commission on 02 November 2018, 30 November 2018 and 04 January 2019, as well as the presentations on 05 November 2018 which addressed erosion rates. There is no evidence of accelerated erosion post-geotube construction that exceed historic observations. 3. The Town is working on a Coastal Resiliency Plan to set priorities in response climate change. Sconset and the area below the Sankaty Bluff are not a priority. The Sconset Coastal Bank has been eroding for decades and the SBPF has been evaluating and pursuing various methods, in theory and in practice, to stabilize this Nantucket Conservation Commission 2 Re: DEP File No. SE 48-3115 March 1, 2019 Coastal Bank. See the Nantucket Conservation Commission presentation made at the 01 October 2018 Public Hearing during which stabilization alternatives and the project permitting history were presented. Advancing an island-wide resiliency plan does not preclude property owners or the Town from advancing projects to protect dwellings and public infrastructure from erosion, respectively, during the planning process. 4. The SBPF have not been candid about their compliance with existing permit requirements. The SBPF documented compliance with the current Order of Conditions (“OOC”) during the 01 October 2018 Public Hearing, and in writing with the response to comments letter dated 02 November 2018. 5. The Association expressed concerns about the financial solvency of the SBPF and recommend that SBPF provide a bank letter of credit to guarantee the fulfillment of its financial obligations Pursuant to OOC Special Condition No. 36 the SBPF maintains an escrow account to ensure funds are available to remove the geotubes should that be necessary. We believe the responses provided herein as well as the rest of the record for this matter (DEP File No. SE48-3115) adequately addresses the concerns of the Quidnet Squam Association. Sincerely, EPSILON ASSOCIATES, INC. Dwight R. Dunk, LPD, PWS, BCES Principal cc: MassDEP-SERO J. Posner, SBPF A. Gasbarro, Nantucket Eng. & Survey S. Cohen, Cohen & Cohen Law, PC G. Wood, Ruben and Rudman, LLP G. Thomson, W.F. Baird & Assoc. L. Smith, Epsilon R. Hamilton, Woods Hole Group