HomeMy WebLinkAbout2014_4_25 SBPF Submission_201404281416500430Response to Questions from Commission, 3/19/14 and 4/2/14 1
BAXTER ROAD TEMPORARY STABILIZATION PROJECT
NOTICE OF INTENT (DEP FILE NO. SE 048-2610)
RESPONSES TO QUESTIONS FROM NANTUCKET CONSERVATION COMMISSION AND
THE PUBLIC ASKED AT PUBLIC HEARINGS ON MARCH 19 AND APRIL 2, 2014
April 25, 2014
To assist the Commission and the public with the review of the NOI, SBPF is presenting
specific responses to the topics that were covered at the public hearings on March 19, 2014
and April 2, 2014. The format of this document is to present a brief summary of each
comment or question in bold followed by a response in regular text.
QUESTIONS/COMMENTS FROM CONSERVATION COMMISSION MEMBERS
AND THE PUBLIC
I. DESIGN
a) Engineering Basis of Design
1. Explain how the wave run-up calculations are done and why project height
requirement is realistic.
See attached engineering design memo from Ocean and Coastal Consultants
(OCC) with a revision date of April 15, 2014. The attached Figure 1 is a
graphic representation of the elevations presented in OCC’s design memo.
2. Review whether tubes alter parameters included in OCC’s design memo and
provide a description of how the tubes are included in the wave run up
calculation.
See attached engineering design memo from OCC with a revision date of
April 15, 2014. Wave runup is calculated specific to the geotube
configuration; none of the other parameters are altered by the presence of
the geotubes. Wave runup on the geotubes during a 100-year storm event
will be lower than wave runup on the adjacent portions of the unprotected
coastal bank, due to the coastal bank’s much steeper slope.
b) Planting Plan for the Project:: demonstrate appropriateness of American beachgrass
on coastal bank; remove juniper as an option for woody vegetation; remove
fertilizer as an option; address retaining portion of upper 5 to 7 feet for swallows.
Response to Questions from Commission, 3/19/14 and 4/2/14 2
The Massachusetts Office of Coastal Zone Management (CZM) specifically
recommends the use of American beachgrass as the top species for stabilizing
coastal banks, due to its fast-growing, dense root system and its tolerance of salt
spray and exposure to wind and waves.
(http://www.mass.gov/eea/agencies/czm/program-areas/stormsmart-coasts/coastal-
landscaping/coastal-bank.html). As stated by CZM, American beachgrass can hold
windblown sediments onto bank or bluff faces and bind the soil using its fast-
growing, dense root system, which allows other species to colonize at the same site.
Beachgrass has been used successfully for a number of years at various locations
along Baxter Road immediately south of the project area (see attached Photographs
1-2 for a few examples of beachgrass on Baxter Road) and is appropriate for this site.
American beachgrass has also been approved by the Conservation Commission for
use on coastal banks along the north shore of Nantucket. Finally, while fertilizer is
recommended by the USDA NRCS, the proponent will accept a condition that
fertilizer not be used, assuming an otherwise acceptable Order of Conditions, if the
Commission finds it objectionable.
Once the beachgrass has been established, other native woody vegetation
recommended in the above-referenced CZM website will be planted in the
following years, including: Bearberry, Beach Heather, Bayberry, Beach Plum, and
Creeping Juniper. Common juniper has been excluded as a potential vegetation
type since it has been noted that it does not appear to be native to the coastal bank.
The upper 5-7 feet of the coastal bank will not be vegetated and will instead be
reserved for swallow habitat.
c) Failure Criteria for the Project
Failure criteria for the project have been updated to indicate “failure” if the
Applicants do not adequately maintain, monitor, and mitigate the geotubes within
the stipulated timeframes or within a reasonable cure period if there is delay outside
the control of the Applicants due to weather or otherwise. The following failure
criteria are recommended:
1. Failure to provide the required sand mitigation volume (currently specified
as 22 cy/lf/yr) on an annual basis (defined as April 1 through March 31).
This provision shall not be construed to signify failure in the event of a
reasonable weather-related delay in providing all or part of the nourishment.
2. Failure to conduct the required shoreline and post-storm monitoring, as
described in Section III. below. This provision shall not be construed to
signify failure in the event of a reasonable weather-related delay(s) in
providing the required monitoring and reporting.
Response to Questions from Commission, 3/19/14 and 4/2/14 3
3. Failure to repair and/or replace the geotextile tubes in a timely manner from
storm-related or other types of damage. In general, geotextile tubes will be
repaired or replaced within 30 days of when the damage is identified. If
repair or replacement cannot be accomplished within the 30 day window,
the Commission will be notified and a repair schedule will be provided.
This provision shall not be construed to signify failure in the event
reasonable efforts are being pursued to repair and/or replace the geotextile
tube(s) in as expeditious a manner as possible.
4. Excessive change in updrift or downdrift beach cross section that can be
attributed to the project. Quantitative failure for updrift and downdrift
impacts is difficult to develop with certainty at this time. If annual transects
suggest changes are occurring as compared to historic data collected by
SBPF over the past 15+ years, the Department of Public Works and SBPF
will meet with Conservation Commission staff and determine if they believe
the changes are a result of the project, and an appropriate course of action
will be determined. Such a determination will consider:
i. Whether areas immediately adjacent to the project are eroding in
excess of historic erosion rates. If the project is causing acceleration
of shoreline erosion downdrift of the structure, immediately adjacent
areas would experience that erosion first before it would be
experienced much farther downdrift. Therefore, changes in
shorelines farther away from the project area are more likely to be
attributed to factors besides the project if there is no evidence of
increased erosion immediately adjacent to the project; and
ii. The ongoing erosion of the adjacent unprotected sections of coastal
bank and how the volume of this erosion compares to the sand
mitigation volume. If ongoing surveys show that the immediately
adjacent unprotected coastal bank is contributing an equal or lesser
volume than the mitigation sand volume, changes in downdrift
beaches are less likely to be attributed to the project.
After a review of the monitoring results, the appropriate course of action will
be determined and may include: a change in the placement of the template
sand, an increase in the volume of mitigation sand, or if those adjustments are
not effective in correcting the problem, system removal.
In the event of failure, the following will occur:
1. The Conservation Commission will be immediately notified through its staff.
Response to Questions from Commission, 3/19/14 and 4/2/14 4
2. Following mutual agreement by the Department of Public Works and the
Conservation Commission staff, an appropriate course of action to address
the situation will be devised, which may include removal of the geotextile
tubes if no other remedy is feasible. If removal is ordered, the geotextile
tubes will be cut and removed. Removal will require use of an excavator or
similar equipment on the beach to pull the geotextile up, leaving the sand in
place.
3. Following removal of the geotextile, the sand will be spread along the toe of
the slope and left in place.
d) Assessment of biodegradable materials (jute/coir) for third or fourth tier of
protection.
As stated in our October 25, 2013 and November 1, 2013 submissions, coir and
jute are not recommended because they lack durability to withstand storm
conditions experienced regularly at the site and are likely to require frequent
replacement, and because this location has little or no ability to absorb additional
bank loss. The degradation of the terraces would result in continued bank failure
and ongoing maintenance. As stated in our March 13, 2014 submission, it is
expected that jute bags would be torn open by storm wave forces and may need to
be replaced as often as 1-3 times per year. Frequent replacement of jute/coir
products results in additional truck traffic and added costs. The 4th row of jute/coir
is unlikely to withstand the required loading and shear stresses caused by a
bulldozer and/or excavator used when spreading the annual mitigation sand volume
and when covering areas expected to be exposed by wave action. The use of
jute/coir for the 3rd tier of protection is even more certain to fail because it is subject
to greater exposure during storms resulting in system failure and causing serious
difficulties in sand delivery. These materials are therefore not considered a feasible
option.
e) Explain whether the project is temporary or permanent.
In the spring of 2013, efforts were initiated to permanently protect the homes and
infrastructure along Baxter Road that were threatened by the eroding bluff. Due to
time constraints, the geotube project was proposed to protect the most endangered
section while the long-term protection project was pursued. The long-term
protection project includes the identification and establishment of an alternative
roadway for access and relocation of utilities in the event of failure of the existing
infrastructure. In this light, the Applicant seeks an Order of Conditions for three
years, with the understanding that such Orders generally may be extended three
times in one year intervals by the Commission. This project will serve as an
“interim” protection system covering the time period until this requested Order
would either be replaced by a subsequent Order by the Commission for an
Response to Questions from Commission, 3/19/14 and 4/2/14 5
expanded coastal engineering structure to protect all threatened portions of Baxter
Road or it becomes moot due to a total failure of the bluff. Removal of this
“interim” geotube project is proposed only if there is a failure of the protection
system triggering such under the Order, or if a long-term, expanded coastal
engineering structure replacing it is not approved.
II. CONSTRUCTION
a) Provide a construction narrative describing completed work and ongoing work.
Construction Narrative
Construction proceeded according to the following sequence:
1. In order for construction equipment to access the work site, approximately 64
cubic yards of fill and hardener was placed on the bank face at Hoick’s Hollow
to create a curved access ramp onto the beach (see attached Photographs 3-5).
2. A 336 excavator was moved to the project site from Hoick’s Hollow. The
excavator was used to dig a trench into the beach to approximately elevation
0.0 MLW, which is the design depth of the lowest tier of geotubes. [Note: All
construction vehicles were moved off of the beach to the Hoick’s Hollow
staging area at the end of each work day, where they were fueled the following
morning prior to tracking back to the work area.] The trench was approximately
35 feet wide and ran parallel to the bluff along the entire approximately 900
foot project area. It was sized to accommodate the width of the lowest geotube
tier, which included the scour apron with an integrated anchor tube as well as
the 45 foot circumference geotube itself. The trench filled naturally with water
because of its elevation.
3. Excavated material from the trench was temporarily stockpiled immediately
seaward of the trench in a windrow, or continuous pile of excavated sand,
approximately 25 feet wide at the top and approximately 40-45 feet wide at the
bottom. This windrow functioned as a stockpile for excavated material, as a
dike to protect the trench which served as the water source for the slurry, and as
a work platform for a D6 bulldozer and a 320 excavator used to feed sand into
the hopper for the slurry pump. This initial windrow was significantly wider
than subsequent windrows or dikes, due to the substantial volume of material
removed from the associated trench, which had to be wide enough to
accommodate the tier 1 geotube, scour apron, and the anchor tube. Elevation
+5.4 MLW (i.e., somewhat higher than the elevation of the HTL at +5.11
MLW) was staked near the start of construction; the initial windrow was located
completely landward of the HTL. The seaward edge of the initial windrow
represented the most seaward limit of work. (See letters from Epsilon Associates
Response to Questions from Commission, 3/19/14 and 4/2/14 6
to Elizabeth Kouloheras at MassDEP dated April 10, 2014 and to Mr. Kevin
Kotelly of the US Army Corps of Engineers dated February 26, 2014, both of
which were copied to the Commission.)
4. The first 300 foot section of scour apron with integrated anchor tube was rolled
out inside the trench from north to south. The anchor tube extended to
approximately 5-feet from the seaward edge of the bottom tier of geotubes,
which were rolled out on top of it. After the first section of scour apron/anchor
tube was in place, the first of the nine (9) unfilled 100 foot long, 45 foot
circumference geotubes that make up the lowest tier was laid out on top of the
apron at the appropriate distance from the slope.
5. The first 100 feet of the lowest tier geotube was filled using the slurry filling
system that was used throughout the installation. The slurry filling system
involved a 320 excavator scooping sand from the windrow (i.e., excavated
beach sand) into the slurry hopper, which was integrated with the hydraulic
pump to create an 80/20 water-to-sand slurry mixture. The slurry mixture was
pumped through an 8 inch flexible pipe inserted into geotextile sleeves sewn on
to portholes in the top side of the geotubes. The pipe filled the geotubes one
porthole at a time. As the tube approached its intended height in each location,
the flexible pipe was moved to the next sleeve/porthole continuously filling the
geotube from north to south. Portholes are spaced approximately every 20 feet
in the lowest tier geotubes. Once the geotube was nearly filled, the slurry pipe
was moved back to the northern most porthole to complete a “topping off”
sequence. Once each porthole was fully filled, the slurry pipe was removed
and the porthole sleeves were rolled up and tucked into the geotube leaving a
void of approximately 1 cubic foot. This void was filled with high-strength
concrete. The concrete was mixed by hand in a wheel barrow using 80lb bags
of pre-mixed concrete. These concrete plugs were then covered with a
geotextile patch attached with Premium PL construction adhesive.
6. The second and third 100 foot sections of the lowest tier geotube were filled
sequentially, in the same manner as the first 100 foot section. Each 100 foot
section of the tubes was overlapped, or shingled, with the adjacent geotube so
there was no gap between them.
7. Once the first 300 foot section (three 100 foot tubes) was complete, the 300 foot
integrated anchor tube was filled using the same slurry pumping system.
8. This process was repeated two more times until the entire approximately 900
foot lowest tier was completed (including both the lowest tier geotube and the
anchor tube/ scour apron). At this point the entire 900 foot trench was still
open.
Response to Questions from Commission, 3/19/14 and 4/2/14 7
9. The first section of the second tier of geotubes was rolled out and filled, this
time from south to north. Each section of the second and third tiers of the
geotubes was 225 feet long instead of 100 feet. Some sand from on-island pits
(“pit sand”) was delivered over the top of the bank by a conveyor belt (see
Template Sand Delivery in next section). This sand was spread behind
(landward of) the lowest tier to make a “bench” for the first 225 foot section of
the second tier.
10. On January 2 and 3, 2014, a storm caused the original windrow/dike to wash
into the initial trench, filling it with the native material in the windrow.
11. The next step after the storm was to dig a new, narrower trench seaward of the
anchor tubes that was wide enough only to provide an adequate water source
for the slurry system. Excavated material from the trench was placed in a
windrow on the seaward side of the trench. This windrow was significantly
narrower than the initial windrow described in #3 above, due to the lower
volume of material excavated to make the water supply trench. The narrower
trench and windrow were both located landward of the HTL. The purpose of
the trench was to provide a water source to the slurry pumping system that was
free from seaweed to avoid clogging the pump. The trench filled in naturally
from the bottom and was not connected to the Atlantic Ocean unless wave
setup and runup broke through the windrows/dikes.
12. The rest of the second (tier 2) geotube layer (three more 225 foot tubes) was
rolled out south to north and placed in alignment with the southern end of the
bottom geotube. The scour apron from the lower tier was rolled up the back
(landward) side of the bottom tier ending on the back (landward) half of the top
of the lowest tier tubes. The scour apron for the second tier was rolled out on
top of this section of the lower apron and underneath the location of the next
tier geotube, on top of the bench, so that when the second tier was filled, the
two overlapping scour aprons were “pinched” together between the two tiers of
tubes. This process was later repeated between the second and third tier tubes.
The geotube layers were terraced providing approximately 7.5 feet of overlap
with the tier below.
13. The tier 2 geotubes were filled with a sand slurry (as described in #5 above)
using pit sand as a sand source. The pit sand was delivered to one of the two
delivery points located at 87/91 and 99/101 Baxter, loaded onto a conveyor and
dumped over the top of the bank. As the sand reached the bottom of the bluff
face, it was pushed by the dozer on top of the bench landward of the tier 2
geotubes and scooped with an excavator into the slurry hopper to feed the slurry
process. The slurry hopper and hydraulic slurry pump were staged on the
bench behind (landward of) the tier 2 geotubes.
Response to Questions from Commission, 3/19/14 and 4/2/14 8
14. The scour aprons were again pulled behind the back (landward) side of the
newly filled tier 2 geotubes and partially over their topside, and the tier 3
geotube layer was placed upon the next layer of scour apron, again pinching
them together. The tier 3 geotubes were again staggered so as to provide
approximately 7.5 feet of overlap with the tier 2 geotube layer.
15. The tier 3 geotubes were filled with a sand slurry (as described in #5 above)
using pit sand as the sand source. The water source for the slurry was obtained
by excavating a trench seaward of the tier 3 geotube, in a location similar to the
water source trench used for the tier 2 geotube. The water source trench was
maintained using the excavated sand to create dikes at its seaward side. The
dikes for the water supply trench were narrower than the initial windrow
described in #3 above, and the water supply trench and dikes were both located
landward of the HTL. The water source trench was re-excavated and the
associated dike was rebuilt on a daily or every-other-day basis during the
approximately 10 days of tier 3 geotube construction, as moon tides contributed
to higher water levels that typically filled in the water source trench each night.
Windrows of pit sand were created on the landward side of the water supply
trench. These windrows also served as the staging area and sand source for the
slurry equipment for the third tier, as there was no longer room on the back
(landward) side of the second tier to stage the hydraulic slurry pump and
hopper.
16. The area landward of the tier 3 geotube (the “bench”) was backfilled with pit
sand. The fill was installed to an elevation matching the top of the filled tier 3
geotube. The scour apron was laid flat on the back (landward) side of the third
tube prior to backfilling the bench. This scour apron has a small 3’
circumference anchor tube attached to it; no excavation into the bank was
required to place the scour apron or anchor tube.
17. While filling the third tier, plastic sheathing was used in between the geotubes
that were being filled and the seaward windrow on which the hopper and slurry
pump were stationed. The purpose of laying the plastic sheathing down was to
help direct the runoff water which was being filtered out of the tubes as they
were filled with sand, so that this water didn’t erode the windrow immediately
seaward of the tubes being filled, and destabilize the work platform on which
the equipment was located. This plastic sheathing was placed on top of the tier
2 geotube and under the unfilled tier 3 geotube. When the tier 3 geotube was
filled the plastic sheeting was collected and reused. Regrettably, it has become
evident that some sections of this sheathing appeared to have been buried
during this process, perhaps during one of the storm events that occurred as the
construction was underway, and were accidentally left behind. These pieces of
plastic were collected as they were exposed during subsequent, post-
Response to Questions from Commission, 3/19/14 and 4/2/14 9
construction storms. It is not believed that there is any remaining plastic in the
project area. If any is uncovered from future geotube exposure during future
storm events, it will be removed.
18. Once all geotubes were filled, the entire structure was covered with pit sand.
The sand cover at the end of the initial installation was approximately 3 to 5 feet
thick above the top tier, and measured approximately 30 feet wide at the
platform (the flat area) directly on top of the geotubes and approximately 30 feet
along its seaward slope, from the top of the template down to the beach surface
at an angle of approximately 35 degrees. The sand was spread using the
excavators and the bulldozer.
19. A trough drain that was intended to redirect surface runoff from the top of the
bluff in a manner that avoided added bluff face erosion was installed at 91
Baxter as described below in the Bank Drain section and as described in
previous submissions to the Commission. The reason it was installed at this time
was in order to simplify the construction process since it could be easily buried
while the final sand delivery to the template from the top of the bank was
nearing completion. Recognizing in the midst of the drain installation process
that it had not been permitted and that it would be subject to a future approval
by the Commission, the trough was never connected to the conductor pipe.
Construction Access
All construction equipment accessed the beach from Hoicks Hollow. All
construction vehicles were fueled in the Hoicks Hollow parking lot area; the
hydraulic pump was filled on the beach using a small transfer tank. Typically two
excavators, a bulldozer, a skid steer, and a small crew transport “buggy” were used
on the beach. All other equipment operated out of the sand delivery areas at 87/91
and 99/101 Baxter Road.
Template Sand Delivery
Sand was delivered from island pits to the site via 10 wheel dump trucks. The
dump trucks delivered the sand to one of the two sand delivery areas at 87/91
Baxter Road and 99/101 Baxter Road. Temporary concrete blocks were stacked to
create bins in which to dump and scoop the sand. A loader was used to keep
pushing the sand to the backside of these bins, where an excavator then loaded the
sand from the delivery areas onto a conveyor belt. The conveyor belt transferred
the sand over the edge of the bluff, where gravity transported it to the geotubes.
Once the sand was delivered to the geotubes, a bulldozer and excavator worked
together to distribute the sand evenly over the entire system. These machines spread
sand in sequence so that they avoided driving on top of the geotubes until they had
a sufficient sand cover.
Response to Questions from Commission, 3/19/14 and 4/2/14 10
Future sand delivery after the face of the bluff is vegetated will be done using three-
foot-diameter polyethylene pipes supported above the bank face using 4”x4” braces.
The same sand delivery locations will be used. The equipment to be used will
include a bulldozer and an excavator, depending on the volume to be delivered.
Sand delivery by dump truck is expected to be limited to the off-season in order to
avoid safety and disruption factors that could be experienced during the busy
summer months.
Returns
Returns will be installed by field-fitting 15-foot circumference geotextile tubes at a
45-degree angle between the seaward face of the geotubes and the face of the
unprotected bluff. No excavation into the bluff will be performed to install the
returns. The bottom of the returns will be installed to a depth of +3 to +4 MLW
due to the need to avoid shoring and general constructability considerations. The
top of the returns will extend to the elevation of the top geotube (approximately
elevation +20-21 MLW if limited to the three tiers currently in place). Any material
excavated from the beach to install the returns will be used to backfill the area
around the trench upon completion of installation.
The construction of these returns will be done mainly with a skid steer, in a similar
fashion to how the jute terraces are built and maintained in other locations on the
bluff. Since the returns will consist of smaller (15-foot circumference) geotubes, no
slurry mixture or dikes will be required – the geotubes will be filled with dry sand
obtained from island pits. An excavator may be required, based on timing and how
much of the sand template at the ends needs to be displaced, which depends on the
size of the ends at that time.
Vegetation
The proposed vegetation for initial planting is American beachgrass. To ensure
vegetation efforts are successful, a minor addition of sand is needed to prepare the
planting bed prior to planting by smoothing out some of the deeper rills and
gullies. This sand will be provided from on-island sand pits by the conveyor belt
system utilized during the geotube construction process. This smoothing is only
needed at 93 and 97 Baxter Road (i.e., those areas outside of the sand delivery
locations). The use of a biodegradable erosion control fabric or jute netting is also
proposed to protect soil from wind and water erosion, and retain moisture to
facilitate establishment of vegetation. Once the beachgrass has been established,
other native woody vegetation recommended in the above-referenced CZM website
will be planted in the following years, including: Bearberry, Beach Heather,
Bayberry, Beach Plum, and Creeping Juniper. Common juniper has been excluded
as a potential vegetation type since it has been noted that it does not appear to be
Response to Questions from Commission, 3/19/14 and 4/2/14 11
native to the coastal bank. The upper 5-7 feet of the coastal bank will not be
vegetated and will instead be reserved for swallow habitat.
Planting of vegetation will not require equipment on the beach or any access via
Hoick’s Hollow. Planting will be accomplished by men working on the face of the
bluff, with access from the top.
Bluff Face Augmentation
During the construction process, additional sand was placed on the upper bluff at or
near the sand delivery locations at 87/91 and 99/101 Baxter Road. Sand was also
added to the face of the upper bluff at 93 Baxter Road (see Photograph 6). Sand was
delivered over the edge of the coastal bank via a conveyor belt staged at the top of
the coastal bank, as it was during the rest of the project. As stated in the document
entitled “Supplemental Information for March 19, 2014 Hearing” submitted to the
Commission on March 14, 2014, it has been observed that this sand acted to protect
the face of the bluff because it increased infiltration of rain and surface water runoff
and also attenuated soil erosion from rain and surface water flows. In the areas
where the face of the bluff was not augmented with additional sand, surface water
flows continued to erode that portion of the bluff above the geotubes. Mark Haley
of Haley & Aldrich, in his previously-submitted memo dated March 12, 2014, has
indicated that: “Adding sand to the face of the slope, especially near the top of slope
where the slope is near vertical, will greatly increase the stability of the bluff.”
Surface Water Drain
A subsurface drain for surface water runoff was installed at 91 Baxter Road, parallel
to and approximately 10 feet seaward of the roadway, for a distance of
approximately 41 feet. The subsurface drain consists of an 18 inch deep x 18 inch
wide trough that is lined with filter fabric and holds a 4” diameter corrugated pipe.
The trough is backfilled with ¾ inch gravel. The subsurface drain collects
stormwater runoff and directs it to another 4” diameter PVC pipe that runs down the
face of the bank and terminates at the toe of the bluff, in a pit containing ~3 cy of
gravel placed in the sand template behind the geotubes. No excavation into the
bank or beach occurred to install the gravel trough or the PVC pipe that runs down
the face of the bank; this pipe was placed within sand added to the bank face or the
sand template on top of the geotubes. The pipe was never connected and is not
functioning. SBPF is not requesting permission to connect the pipe at this time and
is instead requesting permission to abandon it in place, with a requirement to
remove the pipe if it becomes exposed.
Response to Questions from Commission, 3/19/14 and 4/2/14 12
b) Provide an updated as-built plan.
An updated as-built plan was submitted on April 25, 2014. The revised as-built
plan incorporates information from a survey conducted by WHG on April 4, 2014
and includes updated shoreline contours, an updated top of bank position, and the
position of the sand template. Additionally, the as-built includes the surveyed
position of the seaward face of the tier 2 geotube, which was largely exposed during
the time of the survey and was generally coincident with the toe of the sand
template (see Photographs 7-8).
III. PROJECT IMPACTS, MONITORING, AND MITIGATION
a) Describe the project’s monitoring protocols, including a response to the question
about off-shore monitoring.
Bi-Annual Surveys (Shoreline and Offshore):
The project will continue to have WHG perform shoreline surveys on a bi-annual
basis. Surveys will be conducted each spring (typically in March or April) and each
fall (typically in September or October). The spring survey will extend from the toe
of the bank or dune to the -5 Mean Low Water (MLW) contour; the fall survey will
include offshore bathymetry, as they have for the past several years, and will extend
from the toe of the bank or dune to a distance of approximately 2,000 to 3,000 feet
offshore or -25ft to -35 ft MLW92, whichever is less. Surveys will be conducted
along the established transects, with the following modifications (Figures 2-3):
o Additional transects spaced every 100-feet will be added to the area within
300-feet of the project’s ends.
o Additional transects will be added to the project area.
o Additional transects will be added near Quidnet and Squam.
o Some of the densely-spaced transects located several thousand feet outside
the project limits that were originally designed to closely monitor now-
removed projects will be eliminated, to provide a more uniform profile
spacing throughout the entire monitoring area. The attached Figures 2 and 3
show all the proposed transects.
As part of the bi-annual surveys, the top of the coastal bank will also be monitored
at those profile locations within the project area and within 300 feet of its ends.
Response to Questions from Commission, 3/19/14 and 4/2/14 13
Post-Storm Reports
Post storm reports will be completed following all significant storms. A storm will
be considered “significant” if there are sustained winds over 40 miles per hour
(MPH) over at least a 6 hour time period.
The geotube installation will be visually inspected following significant storm events
throughout its life. The inspection and subsequent report will consist of:
o Photo-documentation of the condition of the geotube and nourishment sand
within the project area.
o Estimate of the volume of sand lost from the sand template.
o Estimate of the beach level in front of the seaward geotube to determine if
replenishment is needed. If replenishment is needed, an estimated volume
of sand and schedule for delivery will be provided.
o Identification of the location of any exposed geotextile.
o Identification of any repair required to the geotextile.
o Visual observation of the ends of the tubes to determine if flanking is
occurring.
Results of the inspection will be submitted in writing to the Conservation
Commission and Town of Nantucket Public Works Director, as soon as possible
after a storm event, typically within 3-7 days of the end of the storm. If inspection
reveals that repair work is needed, the Public Works Director will coordinate having
this completed as soon as possible. The schedule of repair will be determined
based upon the severity of the work required. For example, repair of torn geotextile
will be completed as soon as the beach is accessible for such activity.
Analysis of Results
Results of the monitoring will be compiled into an annual report in the spring of
each year. Analysis of the data is proposed as follows:
o Review beach transect data to estimate accretion and erosion distances at
each monitored transect.
o Calculate accretion and erosion volumes at transect locations.
o Compare top of bank locations and estimate bank retreat over the previous
12 months.
Response to Questions from Commission, 3/19/14 and 4/2/14 14
o Calculate bank volume loss in the project area and 300 feet north and south.
o Submit data and computations to the Conservation Commission for review
with a recommendation for changes to nourishment program if required.
b) Describe sand nourishment program and demonstrate the sand template will be
contributed to the littoral system.
As stated in our November 1, 2013 submission, the bank retreat data indicate that
the average annual volume eroded from the bank is 14.3 cubic yards (cy)/linear
foot(lf). This volume is calculated specific to the project area and is based on (1) a
determination of the average annual coastal bank retreat rate and (2) a
determination of the volume (from the top of the coastal bank down to the toe)
associated with the average annual retreat rate. As previously stated, the applicant
is willing to accept a requirement of 22 cy/lf as part of an Order of Conditions that is
otherwise acceptable. The state Department of Environmental Protection (DEP), in
its cover letter dated December 10, 2013 that approved the Emergency Certification
Request for the 4- geotube system, stated that it expects that the increased volume of
mitigation sand will mitigate any potential downdrift impacts and will address the
differences between geotextile and coir/jute tubes:
“The implementation of the nourishment plan will mitigate any potential
difference in down drift impacts between the four Geotube design and the
hybrid design approved in the Town's Certification.”
The 22 cubic yards per linear ft (cy/lf) of sand will be delivered in accordance with
the following schedule:
o Provide the initial cover of 22 cy/lf during and/or immediately following
construction.
o Annually in April starting in 2014: Provide additional sand and/or adjust the
existing template sand to obtain a minimum of 2 feet of cover over the
geotubes to protect them from UV degradation. The volume of any sand
placed in April will be recorded and counted towards the annual 22 cy/lf
requirement.
o Annually in September-November starting in 2014: Place an additional
volume of sand, to ensure a substantial portion of the sand template volume
(10-15 cy/lf) is available at the onset of the winter storm season. Throughout
the winter, place additional sand on an as-needed basis, in accordance with
the replenishment trigger presented in our November 12, 2013 letter (i.e., if
half the vertical height of the lowest geotube is exposed, place a minimum
of 2 cy/lf). If the balance of the 22 cy/lf volume is not placed in its entirety
Response to Questions from Commission, 3/19/14 and 4/2/14 15
during the 2014-2015 winter, the balance of the sand will be placed by
March 31, 2015.
o Delivery tickets from sand suppliers will be provided to the Conservation
Commission to document the total volume of sand provided on an annual
basis (April 1- March 31 of any given year).
The sand template is expected to be available to the littoral system, and may even
be contributed more during storms than the adjacent unprotected sections of the
coastal bank for the following reasons:
o The sand cover is located seaward of the toe of the coastal bank, by
approximately 30 to 40 feet. It will therefore be available to the littoral
system during lower wave energy events that do not reach all the way to the
toe in unprotected areas.
o The sand cover is composed of loose, unconsolidated sand that is more
readily erodible than the native sand in the coastal bank.
The above expectations were demonstrated during the recent storm on March 26,
2014. A review of preliminary water level data suggests that this storm was less
than a 10-year storm event according to FEMA’s metrics. The sand cover on the
geotube was depleted by 1.5 – 2.5 cy/lf. The sand terraces immediately south of
the project area were approximately half deflated, and so contributed only
approximately 0.25 cy/lf. Thus, the sand template contributed more sand to the
littoral system than either the adjacent unprotected bank or the jute/coir terraces in
use south of the geotube project.
During larger storms, wave runup would be expected to increase. As the wave
runup increases, most of the sand template will be subject to direct wave attack and
thus available to the littoral system.
o Wave runup in a 10-year storm will be approximately +16.5 ft MLW, which
is halfway up the third geotube.
o Wave runup in a 20-year storm will be approximately +18.5 ft MLW, which
is near or at the top of the third geotube.
o Wave runup in a 50-year storm will be approximately +21.2 ft MLW, which
is at or above the top of the third geotube.
o Wave runup in a 100-year storm will be approximately +24.2 MLW, which
is above the third geotube.
Response to Questions from Commission, 3/19/14 and 4/2/14 16
These calculations show that wave runup will be high enough during major storms
such that the sand template will be available to the littoral system, either by being
directly subject to wave runup or by collapsing down as lower parts of the template
erode (for elevations of the constructed geotubes, see attached Figure 1 and Cross-
Section of updated As-Built).
The sand template will continue to be placed as shown on the sketch entitled
“Figure 1 – Approximate Sand Template” appended to the document entitled
“Response to Letter from Nantucket Land Council dated February 18, 2014,”
submitted on March 13, 2014. This configuration can accommodate approximately
14-15 cy/lf. If more than this volume is set out at one time, the additional volume
will either be placed on top of the existing sand template (approximately a 1 foot
increase in the vertical height of the template will be required to accommodate each
additional 1 cy/lf of mitigation sand), or the additional volume will be placed in a
berm at the toe of the coastal bank within several hundred feet of the project’s ends.
Additionally, the project area and surrounding areas will be monitored following
storms, and if there is any evidence of less sand contribution from the project area
than from immediately adjacent areas, the placement of the template can be
adjusted.
c) Describe expected impacts to the beach within the project area.
The beach in front of the geotubes is expected to respond in a manner similar to the
beach at 79 Baxter Road, where a beach is still present in front of the terraces but a
peninsula shape has begun to form. Like the terrace installation at 79 Baxter Road,
the geotube project will likely still have a beach in front of it due to the significant
sand mitigation component of the project.
There could be localized scour along the base of the geotubes from storm activity.
The tubes were designed to account for this possibility without failure. It is
anticipated that scour holes will fill in naturally or the sand template above the
tubes will fill them in. It is notable that during the recent March 2014 storm, the
lowest tier of buried geotubes had become partially exposed but the beach was
rebuilt in less than 24 hours.
IV. REGULATORY COMPLIANCE
a) Describe how public access will be provided.
The sand template will be gently sloped along its ends so that beachgoers can walk
up and across the sand template if they desire. The attached photographs show
individuals traversing the template (Photographs 9-11). The only time a pathway
over the geotube may not be available is immediately after storms when some repair
Response to Questions from Commission, 3/19/14 and 4/2/14 17
of or addition to the sand template may be required. In general there is expected to
be access in front of the geotubes during most weather conditions. Only during
certain combinations of wind, tide and storm surge will access across the top of the
geotubes be needed to traverse the beach.
SBPF supports adding access from the top of the bluff to the top of the erosion
protection system with additional stairs but believes it is premature to install stairs
now for the following reasons. First, the upper bank face is not yet currently
stabilized (through plantings and/or sand augmentation) and may not be safe for
stair construction. Additionally, there may be some adjustments to the placement of
the sand template as the project gains experience over the next year or two, which
may impact staircase placement and/or construction. SBPF expects to be in a
position to permit and install additional stairs if desired by the Commission as part
of the long-term protection project that will be addressed within three year life of
this Order of Conditions, or its extension. Currently, the public can access the
beach to the north of the project at Hoick’s Hollow and to the south via the staircase
at 65/67 Baxter Road and numerous other stairs between that location and Sconset
village and the Sconset beach access in Codfish Park.
b) Describe how the project will provide for potential Piping Plover nest site(s) north of
the Hoick’s Hollow accessway.
Piping plovers are said to have historically established a nesting site to the north of
the Hoick’s Hollow accessway. The general piping plover protection window is
from April 1 to the end of August. The window during which nesting may occur is
from April 1 through July 1. The state “Guidelines for Managing Recreational Use
of Beaches to Protect Piping Plovers, Terns, and their Habitats”, prepared by NHESP
in 1993, states that unfledged chicks may be present from late May though late
August, with the earliest record piping plover hatching occurring on May 22.
Equipment access through the Hoick’s Hollow accessway during the period of April
1 – August 31 is expected to be limited. The primary work that may occur is
restoration of the sand template, which may require up to 1-2 weeks of daily access
on and off the beach (daily access is required for equipment refueling). No other
activities are anticipated to require use of the Hoick’s Hollow accessway during the
period of April 1 – end of August. In particular, vegetation work can be accessed
from above and will not require the use of Hoick’s Hollow. Additionally, the
returns can be installed after the end of August to accommodate any nests or
unfledged chicks, if required.
The following protocols are proposed to monitor for Piping Plover nests and chicks.
Any work requiring the use of Hoick’s Hollow is expected to occur within April,
when one or more nest(s) may be present but the presence of unfledged chicks is
highly unlikely.
Response to Questions from Commission, 3/19/14 and 4/2/14 18
o During periods when Hoick’s Hollow will be in use, monitoring will occur
weekly from April 1 to July 1. If no equipment access is planned for a given
week, no monitoring will be conducted.
o If no nests or chicks are observed within 1000 yards of Hoick’s Hollow, by
July 1 of any given year, no further monitoring will be required for the
season.
o If nests or chicks are observed within 1000 yards of Hoick’s Hollow prior to
July 1, monitoring will continue to occur on a weekly basis until all chicks
have fledged. An equipment escort will also be provided as described in the
following bullet. If no equipment access is planned for a given week, no
monitoring will be conducted.
o If nests are found within 100 yards of the Hoick’s Hollow accessway, or if
unfledged chicks are present within 1000 yards of the Hoick’s Hollow
accessway, a shorebird monitor will escort all equipment on and off the
beach.
c) Describe whether the project is still considered a Limited Project.
While the applicants respect the opinion of Town Counsel that the project meets the
criteria for a Limited Project, the state DEP has provided guidance that it would not
consider the project to be a Limited Project. Therefore, the Applicants have
amended the relevant pages of the NOI form (see attached) to reflect this.
d) Describe the resolution of the Enforcement Order
The Applicants were instructed that the four items included in the Enforcement
Order issued by the Conservation Commission on 2/5/14 should be included in the
Notice of Intent as the method to follow for their resolution. Each item has been
described above; the below bullets summarize where information on each item can
be found and the proposed action to be taken:
o Installation of stormwater drainage pipe: described above in Section II.a. The
Applicants are requesting permission to leave it disconnected and abandon it in
place unless and until an approval is granted at some time in the future, with a
requirement to remove it if it becomes exposed.
o Use of concrete plugs in geotube portholes: described above in Section II.a,
and in the document entitled “Supplemental Information for March 19, 2014
Hearing” submitted on March 14, 2014. The Applicants are requesting approval
for this as a component of the overall project, which was not described in
advance but is a standard method for sealing geotubes in this setting.
Response to Questions from Commission, 3/19/14 and 4/2/14 19
o Excavation of the coastal beach below the Mean High Water mark: described
above in Section II.a and in the letters from Epsilon Associates to Elizabeth
Kouloheras at MassDEP dated April 10, 2014 and to Mr. Kevin Kotelly of the US
Army Corps of Engineers dated February 26, 2014, both of which were copied
to the Commission. The referenced information demonstrates that work was not
occurring seaward of the Mean High Water mark. (Also, as previously reported,
the US Army Corps of Engineers has determined that, after careful review of the
situation, they will not be taking any further action.)
o Placement of sand on the face of the coastal bank outside the sand delivery
areas: described above in Section II.a, which states that the only sand
placement outside the sand delivery areas was at 93 Baxter Road. The
Applicants request approval of this sand placement at 93 Baxter Road.
e) Demonstrate that the project is considered with all applicable state and local
performance standards.
For a complete discussion of all applicable state and local performance standards,
see the below document on the following page.
Baxter Road Temporary Stabilization Project 1 Consistency with Wetlands Regulations
Epsilon Associates, Inc.
CONSISTENCY WITH STATE AND LOCAL WETLANDS REGULATIONS
1.0 Wetland Resource Areas
Work associated with the Project will be located in the following coastal wetland resource areas
subject to the Wetlands Protection Act (WPA), local Bylaw, and the respective state wetlands
regulations and local wetlands regulations (see Figure 4):
Coastal Bank;
Coastal Beach; and
Land Subject to Coastal Storm Flowage (LSCSF).
The Natural Heritage and Endangered Species Program (NHESP) Estimated and Priority Habitat of
Rare and Endangered Species Map does not show priority habitats for state-protected species and
estimated habitats for rare wildlife along the coastal bank and coastal beach in the project area (see
Figure 5). While other unlisted wildlife species may be present in the Project area (likely on a
transient basis); swallows are the only known (unlisted) nesting species within the Project area. To
maintain areas where unlisted swallow species can nest, the Project will not vegetate a 5 to 7 foot
section at the top of the coastal bank to reserve this section for swallows’ nests.
2.0 Compliance with State Wetlands Regulations
The installation of the Project will require authorization under the WPA for work occurring within
the following wetland resource areas: Coastal Bank, Coastal Beach, and Land Subject to Coastal
Storm Flowage. The protected interests within the wetland resource areas the project area include
storm damage prevention, flood control, and protection of wildlife habitat.
The following sections assess Project compliance with the state wetlands regulations for each
resource area.
Coastal Bank (310 CMR 10.30)
Coastal Bank is defined at 310 CMR 10.30(2) as “the seaward face or side of any elevated landform,
other than a coastal dune, which lies at the landward edge of a coastal beach, land subject to tidal
action, or other wetland.”
The state wetlands regulation at 310 CMR 10.30 includes the following conditions:
“WHEN A COASTAL BANK IS DETERMINED TO BE SIGNIFICANT TO STORM DAMAGE
PREVENTION OR FLOOD CONTROL BECAUSE IT SUPPLIES SEDIMENT TO COASTAL
BEACHES, COASTAL DUNES OR BARRIER BEACHES, 310 CRM 10.30(3) through (5) SHALL
APPLY.’
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“WHEN A COASTAL BANK IS DETERMINED TO BE SIGNIFICANT TO STORM DAMAGE
PREVENTION OR FLOOD CONTROL BECAUSE IT IS A VERTICAL BUFFER TO STORM WATERS,
310 CMR 10.30(6) through (8) SHALL APPLY.”
The coastal bank in the Project area supplies sand to nearby coastal landforms; therefore, it is
significant to storm damage prevention and flood control. The coastal bank in the Project area also
is significant to storm damage prevention and flood control because it is a vertical buffer to storm
waters. The following sections describe how the Project design complies with state regulations for
coastal banks (310 CMR 10.30(3) through (8)).
310 CMR 10.30(3) – Performance Standard
“No new bulkhead, geotube, seawall, groin or other coastal engineering structure shall be
permitted on such a coastal bank except that such a coastal engineering structure shall be
permitted when required to prevent storm damage to buildings constructed prior to the effective
date of 310 CMR 1.21 through 10.37 or constructed pursuant to a Notice of Intent filed prior to
the effective date of 310 CMR 10.21 through 10.37 (August 10, 1978), including
reconstructions of such buildings subsequent to the effective date of 310 CMR 10.21 through
10.37, provided that the following requirements are met:
(a) a coastal engineering structure or modification thereto shall be designed and
constructed so as to minimize, using best available measures, adverse effects on
adjacent or nearby coastal beaches due to changes in wave action, and
(b) the applicant demonstrates that no method of protecting the building other than the
proposed coastal engineering structure is feasible.
(c) Protective planting designed to reduce erosion may be permitted.”
Project Compliance: The Project is necessary to prevent storm damage to buildings constructed
prior to August 10, 1978, including reconstructions of such buildings. The buildings requiring
protection are on both the seaward and landward sides of Baxter Road; the lots on the landward
side of Baxter Road are also threatened by loss of access to their homes due to the loss or closure of
Baxter Road. The status of the lots in terms of which have pre-1978 structures or houses on them
are included on the attached Figure 6 and Table 1 and are summarized below.
o Lots with pre-1978 structures on the seaward side: Lots 93 and 97
o Lots with pre-1978 structures on the landward side: Lots 91, 99, 101, 105
o End lots (including returns): Lot 87
Thus all lots meet the state requirement for pre-1978 protection. The Project conforms to the other
requirements of this regulation, as described below:
Baxter Road Temporary Stabilization Project 3 Consistency with Wetlands Regulations
Epsilon Associates, Inc.
Coastal Engineering Structure: With respect to subsection (a) above, the project has been designed
and will be constructed using best available measures to minimize adverse effects on adjacent or
nearby coastal beaches caused by changes in wave action. Best Available Measures are defined at
310 CMR 10.04 as “the most up-to-date technology or the best designs, measures or engineering
practices that have been developed and that are commercially available.” SBPF has evaluated
and/or constructed numerous other shore protection alternatives in the Sconset project area. This
proposed coastal engineering structure has benefited from all of the experience gained during these
projects. For this project the Applicants have evaluated alternative slopes and geotextile tube
configurations in an attempt to minimize changes in wave action that might have adverse effects on
beaches in the Project area. The sloped, bermed design of the geotextile tubes will minimize wave
reflection. The end returns have been proposed on a 45-degree angle to minimize flanking and
focusing of wave energy onto adjacent, unprotected areas of the bank. Additionally, the
incorporation of an extensive sand mitigation program (as described in Section III.b. above) will
mitigate impacts to adjacent and/or downdrift beaches. Finally, the geotextile material has been
selected as having the required strength and durability for the coastal environment at Sconset.
No other feasible protection: With respect to subsection (b) above, there is no other feasible
method of protecting the existing buildings in the Project area in the long-term other than the
proposed project. Alternatives evaluated to the current design are described in the letters from
Milone & MacBroom dated October 1, 2013, October 25, 2013, and November 1, 2013.
Sand Mitigation: Sand mitigation consists of the placement of compatible sand on the geotextile
tubes and downdrift beach areas. This sand mitigation calculation and protocol is described above
in Section III.b. and in the letters from Milone & MacBroom dated November 1, 2013, November
12, 2013, and November 19, 2013. An updated sand delivery schedule is repeated above in
Section III.b. and was included in the project’s March 14, 2014 submission.
Protective Plantings: With respect to subsection (c) above, the Project design includes native
vegetation plantings to protect the upper bank face and reduce runoff-related erosion. The
vegetation is described in Section I.b. above.
310 CMR 10.30(4) - Performance Standard
“Any project on a coastal bank or within 100 feet landward of the top of a coastal bank, other than
a structure permitted by 310 CMR 10.30(3), shall not have an adverse effect due to wave action on
the movement of sediment from the coastal bank to coastal beaches or land subject to tidal action.”
Project Compliance: The Project is being permitted under 310 CMR 10.30(3), and thus this
standard does not apply.
310 CMR 10.30(5) - Performance Standard
“The Order of Conditions and the Certificate of Compliance for any new building within 100 feet
landward of the top of a coastal bank permitted by issuing authority under M.G.L. c. 131, § 40 shall
contain the specific condition: 310 CMR 10.30(3), promulgated under M.G.L. c. 131, § 40,
Baxter Road Temporary Stabilization Project 4 Consistency with Wetlands Regulations
Epsilon Associates, Inc.
requires that no coastal engineering structure, such as a bulkhead, geotube, or seawall shall be
permitted on an eroding bank at any time in the future to protect the project allowed by this Order
of Conditions.”
Project Compliance: This standard does not apply to this NOI because the proposed Project does
not include the construction of any new buildings.
310 CMR 10.30(6) - Performance Standard
“Any project on such a coastal bank or within 100 feet landward of the top of such a coastal bank
shall have no adverse effects on the stability of the coastal bank.”
Project Compliance: The Project has been designed to maintain the stability of the coastal bank;
thus, it complies with this standard. The project will reduce or eliminate weave-inducing scarping
at the toe, which has been the principal cause of erosion of the coastal bank.
310 CMR 10.30(7) - Performance Standard
“Bulkheads, geotubes, seawalls, groins or other coastal engineering structures may be permitted on
such a coastal bank except when such bank is significant to storm damage prevention or flood
control because it supplies sediment to coastal beaches, coastal dunes, and barrier beaches.”
Project Compliance: The Project is designed to stabilize the existing bank face in accordance with
310 CMR 10.30(3) and mitigation will be provided as described above. The state DEP has clearly
indicated that 310 CMR 10.30(3) and 310 CMR 10.30(7) are read together and that the project is in
compliance with both standards, especially since 310 CMR 10.30(3) states that a coastal
engineering structure “shall be permitted” to protect pre-1978 homes from storm damage. In its
cover letter dated December 10, 2013 that approved the Emergency Certification Request for the 4-
geotube system, the state DEP asserted that the project was in compliance with the performance
standards for coastal engineering structures on coastal banks:
In reviewing the extensive information in the Request and the Certification that documented
the threat presented by storm-related erosion, the Department also applied the criterion at
310 CMR 10.30(3) which provides that a coastal engineering structure "shall be permitted"
to protect homes constructed prior to 1978 from storm damage. This regulation creates an
exception to the general rule that precludes the installation of hard armoring of coastal
banks. Based on the facts presented in the Request, this exception applies to the homes
identified in the area subject to the determination of an emergency.
310 CMR 10.30(8) - Performance Standard
“Notwithstanding the provisions of 310 CMR 10.30(3) through (7), no project may be permitted
which will have any adverse effect on specified habitat sites of rare vertebrate or invertebrate
species, as identified by procedures established under 310 CMR 10.37.”
Baxter Road Temporary Stabilization Project 5 Consistency with Wetlands Regulations
Epsilon Associates, Inc.
Project Compliance: The Project area is not within estimated or priority habitat indicated on the
most recent Estimated Habitat Map of State-Listed Rare Wetlands Wildlife published by the NHESP
(NHESP 2008 Atlas, MassGIS). Equipment access through the Hoick’s Hollow accessway may be
in proximity to protected shorebird nesting sites; a shorebird monitoring plan is included in Section
IV.b. above.
Coastal Beaches (310 CMR 10.27)
Coastal Beach is defined at 310 CMR 10.27(2) as “unconsolidated sediment subject to wave, tidal
and coastal storm action which forms the gently sloping shore of a body of salt water and includes
tidal flats. Coastal beaches extend from the mean low water line landward to the dune line, coastal
bankline or the seaward edge of existing man-made structures when these structures replace one of
the above lines, whichever is closest to the ocean.”
The state wetlands regulation at 310 CMR 10.27(2) includes the following conditions:
“WHEN A COASTAL BEACH IS DETERMINED TO BE SIGNIFICANT TO STORM DAMAGE
PREVENTION, FLOOD CONTROL, OR PROTECTION OF WILDLIFE HABITAT, 310 CMR 10.27(3)
through (7) SHALL APPLY.”
The coastal beach in the Project area dissipates wave energy, reduces the height of approaching
waves, and acts as a sand source to nearby coastal landforms. It also provides habitat for non-listed
and listed foraging shorebirds. As such, the coastal beach is significant to storm damage
prevention, flood control, and the protection of wildlife habitat. As discussed below, the Project is
designed to comply with state regulations for coastal beaches 10.27(3) through (7).
310 CMR 10.27(3) – Performance Standard
“Any project on a coastal beach, except any project permitted under 310 CMR 10.30(3)(a), shall
not have an adverse effect by increasing erosion, decreasing the volume or changing the form of
any such coastal beach or an adjacent or downdrift coastal beach.”
Project Compliance: As explained above, the Project is being permitted under 310 CMR
10.30(3)(a). Therefore, this standard does not apply.
310 CMR 10.27(4) – Performance Standard
“Any groin, jetty, solid pier or other such solid fill structure which will interfere with littoral
drift, in addition to complying with 310 CMR 10.27(3), shall be constructed as follows:
(a) It shall be the minimum length and height demonstrated to be necessary to maintain
beach form and volume. In evaluating necessity, coastal engineering, physical
oceanographic and/or coastal geologic information shall be considered.
Baxter Road Temporary Stabilization Project 6 Consistency with Wetlands Regulations
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(b) Immediately after construction any groin shall be filled to entrapment capacity in height
and length with sediment of grain size compatible with that of the adjacent beach.
(c) To transfer sediments to the downdrift side of the inlet or shall be periodically
redredged to provide beach nourishment to ensure that downdrift or adjacent beaches
are not starved of sediments.”
Project Compliance: This standard does not apply. The Project is located above the zone of littoral
drift (i.e., at the landward edge of the coastal beach).
310 CMR 10.27(5) – Performance Standard
“Notwithstanding 310 CMR 10.27(3), beach nourishment with clean sediment of a grain size
compatible with that on the existing beach may be permitted.”
Project Compliance: The Project includes the annual placement of 22 cy/lf of clean sand, of a grain
size compatible with that on the existing beach.
310 CMR 10.27(6) – Performance Standard
“In addition to complying with the requirements of 310 CMR 10.27(3) and 10.27(4), a project
on a tidal flat shall if water-dependent be designed and constructed, using best available
measures, so as to minimize adverse effects, and if non-water-dependent, have no adverse
effects, on marine fisheries and wildlife habitat cause by:
(a) alterations in water circulation,
(b) alterations in the distribution of sediment grain size, and
(c) changes in water quality, including, but not limited to, other than natural fluctuations in
the levels of dissolved oxygen, temperature or turbidity, or the addition of pollutants.”
Project Compliance: This standard does not apply. The Project does not include any work on a
tidal flat, which is defined at 310 CMR 10.27(2) as “any nearly level part of a coastal beach which
usually extends from the mean low water line landward to the more steeply sloping face of the
coastal beach, or which may be separated from the beach by land under the ocean.” All proposed
Project activities will occur on the coastal bank and at the toe of the coastal bank on a narrow strip
of the coastal beach well landward of and above the steeply sloping beach face.
310 CMR 10.27(7) – Performance Standard
“Notwithstanding the provisions of 310 CMR 10.27(3) through 10.27(6), no project may be
permitted which will have any adverse effect on specified habitat sites or rare vertebrate or
invertebrate species, as identified by procedures established under 310 CMR 10.37.”
Baxter Road Temporary Stabilization Project 7 Consistency with Wetlands Regulations
Epsilon Associates, Inc.
Project Compliance: The Project area is not within estimated or priority habitat shown on the most
recent Estimated Habitat Map of State-Listed Rare Wetlands Wildlife published by the NHESP
(NHESP 2008 Atlas, MassGIS – see Figure 5). Equipment access through the Hoick’s Hollow
accessway may be in proximity to protected shorebird nesting sites; a shorebird monitoring plan is
included in Section IV.b. above.
Land Subject to Coastal Storm Flowage
Land Subject to Coastal Storm Flowage is defined at 310 CMR 10.04 as “… land subject to any
inundation caused by coastal storms up to and including that caused by the 100-year storm, surge
of record or storm of record, whichever is greater”
The Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM) for the
Project area, which defines the 100-year storm elevations, is provided in a separate attachment.
Project Compliance: There are no performance standards in the state wetlands regulations for Land
Subject to Coastal Storm Flowage (LSCSF). However, since LSCSF overlays the coastal beach and
the coastal bank up to the 100-year storm elevation as shown on the project plans, the relevant
performance standards have been reviewed and addressed above.
3.0 Compliance with Local Wetlands Regulations
The Project requires authorization under the Nantucket Wetlands Bylaw for work occurring within
the following wetland resource areas: Coastal Bank, Coastal Beach, and Land Subject to Coastal
Storm Flowage. The protected interests within these wetland resource areas include storm damage
prevention, flood control, protection of wildlife habitat and wetland scenic views.
Nantucket Coastal Banks (Section 2.05)
“Bank (coastal)” is defined in Section 1.02 of the local wetlands regulations as “the seaward face or
side of any elevated land form, other than coastal dune, which lies at the landward edge of coastal
beach, coastal dune, land subject to tidal action or coastal storm flowage, or other coastal wetland.
Any minor discontinuity of the slope notwithstanding, the top of the bank shall be the first
significant break in slope as defined by site specific topographic plan information, site inspection,
wetland habitat evaluation, geologic origin, and /or relationship to land subject to coastal storm
flowage. A bank may be partially or totally vegetated, or it may be comprised of exposed soil,
gravel, stone or sand. A bank may be created by man and/or made of man-made materials. A bank
may or may not contribute sediment to coastal dunes, beaches and /or to the littoral drift system. A
bank may be significant as a major source of sediment, as a vertical buffer, for wildlife habitat and
for wetland scenic views.”
Performance Standards for work on coastal banks are set forth in Section 2.05 B of the local
wetlands regulations, which provides that “Coastal Banks or Land within 100 feet of a Coastal Bank
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shall be presumed significant to the Interests Protected by the Bylaw as referenced in Section A,
therefore the following regulations shall apply.”
The Project does not include structures subject to the performance standards listed below, and
hence they are excluded from the following discussion:
Section 2.05 B(2) (piers);
Section 2.05 B(4) (elevated walkways);
Section 2.05 B(6) (septic leach facility); and
Section 2.05 B(8) (buildings).
The remaining applicable sections of the local wetlands regulations pertaining to coastal bank are
addressed below.
Section 2.05 B(1) – Performance Standard
“No new bulkheads, coastal geotubes, groins, or other coastal engineering structures shall be
permitted to protect structures constructed, or substantially improved, after 8/78 except for public
infrastructures. Bulkheads and groins may be rebuilt only if the Commission determines there is no
environmentally better way to control an erosion problem, including in appropriate cases the
moving of the threatened buildings and/or public infrastructure. Other coastal engineering
structures 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: The Project objectives are to protect pre-1978 public infrastructure (Baxter
Road and associated utilities) and to preserve the pre-1978 structures in the project area, including
those homes on the landward side of Baxter Road which are threatened by loss of access due to the
closure or loss of Baxter Road. Within the project area from 87-105 Baxter Road, many houses
have already been moved off the lots; and the remaining structures have already been moved on
their existing lots and have no further room to move. Several homeowners have even acquired
rights to move into the county road layout immediately adjacent to the paved portion of Baxter
Road.. Baxter Road itself cannot be moved; there is no alternative layout in the immediate vicinity
that can accommodate a new major north-south roadway such as Baxter Road. At best, multiple
east-west access point would need to be established to the existing Baxter Road to circumvent those
portions of Baxter Road that had been breached. Further, alternative road or utility access provides
no protection for the waterside lots and short-term benefit for the landside lots.
The imminent danger to public infrastructure and pre-1978 homes on both sides of Baxter Road
and both on and off the applying lots, is documented in the previously submitted memos from
Epsilon Associates dated November 1, 2013 and November 25, 2013. These memos demonstrate
the average long-term rate of retreat of the bluff from 85-107A Baxter Road has been 4.6 feet/year,
though erosion greater than or less than this rate can occur in a given year. Indeed, last year, in
particular locations, the edge of the bluff retreated landward as much as 40 feet, as presented in the
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previously submitted memo from Epsilon Associates dated November 25, 2013. The Town of
Nantucket had already concluded that “certain private homes located on or near Siasconset Bluff
and Baxter Road, a public way, may be imminently threatened with damage and/or loss and
destruction due to severe erosion of the bluff which has intensified since the winter of 2012-2013…
[and] an emergency exists that threatens public roads and other assets from imminent destruction”
(Memorandum of Understanding between the Town of Nantucket and Sconset Beach Preservation
Fund, Inc. entered into July 5, 2013, previously submitted). Indeed, on October 9, 2013, in an
amendment to the Memorandum of Understanding, the Town of Nantucket identified “an
immediate need for emergency measures to protect Baxter Road and the associated utilities
temporarily, in order to maintain vehicular access and utility service to the residential properties on
Baxter Road… and there is an emergency need for an emergency response action plan outlining
how the Town will provide emergency vehicular access, water supply and sanitary services to the
residences at the north end of Baxter Road in the event of a failure of the roadway and that there is
also a need for long-term planning for the potential eventual loss of Baxter Road…” (a copy of the
Amendment to the Memorandum of Understanding was previously submitted).
The Project does not involve rebuilding any bulkhead or groin. No other alternative is feasible to
satisfy the project objectives. Alternatives evaluated to the current design are described in the
letters from Milone & MacBroom dated October 1, 2013, October 25, 2013, and November 1,
2013.
Section 2.05 B(3) - Performance Standard
“All projects shall be restricted to activity determined by the Commission to have no adverse effect
on bank height, bank stability, wildlife habitat, vegetation, wetland scenic view, or the use of a
bank as a sediment source.”
Project Compliance: The Project will not have any adverse effect on bank height, bank stability,
wildlife habitat, vegetation, wetland scenic view, or the use of a bank as a sediment source as
described below.
Bank height: The Project will preserve rather than adversely affecting bank height, as it does
not involve any work which would lower the bank height.
Bank stability: As designed, the Project is intended to 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.
Wildlife habitat: The Natural Heritage and Endangered Species Program (NHESP) Estimated
and Priority Habitat of Rare and Endangered Species Map does not show priority habitats
for state-protected species and estimated habitats for rare wildlife along the coastal bank
and coastal beach in the project area (see Figure 5). While other unlisted wildlife species
may be present in the Project area (likely on a transient basis); swallows are the only known
(unlisted) nesting species within the Project area. To maintain areas where unlisted swallow
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species can nest, the Project will not vegetate a 5 to 7 foot section at the top of the coastal
bank to reserve this section for swallows’ nests. Equipment access through the Hoick’s
Hollow accessway may be in proximity to protected shorebird nesting sites; a shorebird
monitoring plan is included in Section IV.b. above.
Vegetation: Planting beach grass and other native vegetation on the bank face will enhance
vegetation in the Project area. Native vegetation will be planted from above the sand
template up to 5 to 7 feet below the top of the coastal bank.
Wetland scenic view: The project with sand cover will have wetland scenic views similar to
bank appearance before it was denuded by erosion. Planting of beach grass and other
native vegetation over the majority of the rest of the coastal bank will also enhance the
wetland scenic view of the overall coastal bank. The presence of the sand cover will
contribute to wetland scenic view.
Sediment Source: With respect to the bank as a sediment source, although the Project is
designed to stabilize the existing bank face in accordance with local performance standard
Section 2.05 B(1) and state performance standard 310 CMR 10.30(3), the Project also
proposes to provide sand mitigation in the amount of 22 cy/lf annually. The Project has
also committed to a substantial monitoring program described in Section III.a. above.
Section 2.05 B(5) - Performance Standard
“All projects which are not water dependent shall maintain at least a 25-foot natural undisturbed
area adjacent to a coastal bank. All structures which are not water dependent shall be at least 50
feet from a coastal bank.”
Project Compliance: “Water Dependent Projects or Uses” are defined in the local wetlands
regulations as “projects which require direct access for their intended use and therefore cannot be
located out of the Area Subject to Protection under the Bylaw. Examples include but are not
limited to: docks, piers, boat landings, boathouses, marinas, stairs to beaches, and boardwalks over
wetland vegetation. Projects which benefit from wetlands access but which do not require it are
not water dependent uses. Examples include: restaurants, dwellings, and commercial enterprises
servicing marine-related uses such as fish markets, repair facilities, ships’ chandleries, and general
use recreational trails.”
The Project is water dependent because direct access to the coastal bank and coastal beach is
required to achieve the intended purpose of the Project in stabilizing the coastal bank to provide
storm damage prevention and flood control. This Project cannot be located out of the coastal bank
and coastal beach resource areas.
While the Applicants believe that the Project constitutes a water dependent use, because it can
only be performed within the wetlands resource areas (coastal bank and coastal beach) which it is
intended to protect, and accordingly no waiver is required for the Project from the provisions of
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Sections 2.02.B(6) and 2.05.B(5) as to water dependent uses, the Applicants nonetheless include a
waiver request in Section 4.0 below.
Section 2.05 B(7) - Performance Standard
“In areas of an eroding coastal bank, the distance from all new structures to the coastal bank shall
be at least 20 times the average annual erosion rate or 100 feet, whichever is the lesser. The
average annual erosion rate shall be determined by averaging the annual erosion over a 150-year
period ending with the date the NOI was filed, or if no NOI was filed, the date construction began.
If erosion data is not available for the 150 year period, the Commission shall determine the average
annual erosion rate from such lesser time for which erosion data is available. In cases where
documentation can be provided to show that the use of the I50-year period is inappropriate to
existing coastal shoreline characteristics and trends, alternate shoreline change rates may be used
with the approval of the Commission.”
Project Compliance: This regulation is designed to ensure a substantial setback for new structures
built on the land above an eroding coastal bank. The Project does not involve construction of any
new buildings or other structures at the top of the coastal bank that might require future protection;
therefore, this standard does not apply.
Nantucket Coastal Beaches (Section 2.02)
“Beach” is defined in Section 1.02 of the local wetlands regulations as “unconsolidated sediment
subject to wave, tidal, or storm action which forms the gently sloping shore of a body of water,
including land which is separated from other land by a body of water or marsh system. Beaches
extend from the mean low water line landward to the dune line, bank line, or the edge of existing
man-made structures, when these structures replace one of the above lines, whichever is closest to
the defining water body.”
Performance Standards for coastal beaches are set forth in Section 2.02 B of the local wetlands
regulations, which provides that “[a] Coastal Beach, Tidal Flat or Land within 100 feet of a Coastal
Beach or Tidal Flat shall be presumed significant to the interests Protected by the Bylaw, as
referenced in Section A, therefore the following regulations shall apply:”
Project activities on the coastal beach consist of: (1) installing the lowest tier of the geotextile tube
beneath the landward edge of the coastal beach and the upper two ties on top of the coastal beach,
adjacent to the coastal bank; (2) placement of the sand template as mitigation; (3) temporarily
accommodating construction equipment and personnel access to construct the proposed geotextile
tubes; and (4) periodic access for construction equipment and personnel to maintain the project.
The Project does not include activities or structures subject to the following performance standards,
and hence they are excluded from the subsequent discussion:
Section 2.02 B(3) (dredging);
Section 2.02 B(5) (septic systems);
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Section 2.02 B(6) (non-water dependent activities)1;
Section 2.02 B(7) (new buildings); and
Section 2.02 B(8) (vehicular access for houses and recreational areas).
The remaining applicable sections of the local wetlands regulations pertaining to coastal beach are
addressed below.
Section 2.02 B(1) – Performance Standard
“The provisions of Section 2.01 B(1-8) (Land Under the Ocean) shall apply to coastal beaches and
tidal flats.”
Project Compliance: “Land Under the Ocean” is not defined in the local wetlands regulations.
Therefore, in accordance with Section 1.02, “To the extent not defined herein or in the Bylaw,
words used in the Bylaw or in the regulations shall have the definitions contained in the
Massachusetts Wetlands Protection Act (M.G.L. c. 131, sec. 40) and the rules and regulations
promulgated thereunder.”
“Land Under the Ocean” is defined in the state wetland regulations at 310 CMR 10.25(2) to mean
“land extending from the mean low water line seaward to the boundary of the municipality’s
jurisdiction and includes land under estuaries.”
The Project does not involve any work seaward of the mean low water line; therefore, none of the
performance standards at Section 2.01 B(1-8) of the local wetlands regulations apply. However,
even if these performance standards did apply, the Project does not include activities or structures
subject to the following performance standards:
Section 2.01 B(1) (improvement and maintenance dredging);
Section 2.01 B(2) (dredging);
Section 2.01 B(3) (residential piers);
Section 2.01 B(4) (commercial piers);
Section 2.01 B(5) (commercial or residential piers);
Section 2.01 B(6) (aquaculture); and
Section 2.01 B(9) (non-water dependent project).
If Section 2.01 B were applicable, the only standards in Section 2.01 B that would be relevant are
those provided in 2.01 B(7) (coastal engineering structure) and 2.01 B(8) (water dependent project),
which are both discussed below for informational purposes only:
1 While the Applicants believe that the Project constitutes a water dependent use, because it can only be
performed within the wetlands resource areas (coastal bank and coastal beach) which it is intended to
protect, and accordingly no waiver is required for the Project from the provisions of Sections 2.02.B.6 and
2.05.B(5) as to water dependent uses, the Applicants nonetheless include a waiver request in Section 4.0
below.
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Section 2.01 B(7) – Performance Standard
“No new bulkheads or coastal engineering structures shall be permitted to protect structures
constructed or substantially improved after 8/78. Bulkheads may be rebuilt only if the Commission
determines that there is no environmentally better way to control an erosion problem, including in
appropriate cases the moving of the threatened building. Other coastal engineering structures may
be permitted only upon a clear showing that no other alternative exists to protect a structure built
prior to 9/78, but not substantially improved, from imminent danger.”
Project Compliance: Project compliance with this standard is presented in the discussion for
Section 2.02B(2) below.
Section 2.01 B(8) – Performance Standard
“Water dependent projects shall be designed and performed so as to cause no adverse effects on
wildlife, erosion control, marine fisheries, shellfish beds, storm damage prevention, flood control,
and recreation.”
Project Compliance: As described in Section 2.05 B(5), the Project is water dependent because it
requires direct access to the coastal bank and landward portion of the coastal beach.
Wildlife: See previous discussion under Section 2.05 B(3).
Erosion Control: The Project will have a positive effect on erosion control, as it will protect
the bank from wave-induced erosion and sand mitigation will be added to mimic the
natural sand supply from the coastal bank.
Marine Fisheries and Shellfish beds: No Project activities will occur seaward of Mean High
Water, and hence the Project will not have any adverse effects on marine fisheries or
shellfish beds.
Storm damage prevention and flood control: Storm damage prevention and flood control
will benefit from the Project since it will protect the coastal bank and sand mitigation will
be added to mimic the natural sand supply from the coastal bank.
Recreation: The Project will not adversely impact recreational uses along the beach or in
the water, as it will be located on the coastal bank and a portion of the coastal beach.
Public access is further discussed in Section IV.a. above.
Section 2.02 B(2) – Performance Standard
“No new bulkhead or coastal engineering structure shall be permitted to protect structures
constructed, or substantially improved, after 8/78. Bulkheads may be rebuilt only if the
Commission determines there is no environmentally better way to control an erosion problem,
including in appropriate cases the moving of the threatened building. Other coastal
engineering structures may be permitted only upon a clear showing that no other alternative
Baxter Road Temporary Stabilization Project 14 Consistency with Wetlands Regulations
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exists to protect a structure built prior to 9/78, and not substantially improved, from imminent
danger.”
Project Compliance: Project compliance with this standard is discussed below.
Protect Buildings: The Project is necessary to prevent storm damage to buildings
constructed prior to 1978. The buildings requiring protection are on both the seaward and
landward sides of Baxter Road; the lots on the landward side of Baxter Road are also
threatened by loss of access to their homes due to the loss or closure of Baxter Road. The
status of the lots in terms of which have pre-1978 structures or houses on them are included
on the attached Figure 6 and are summarized below.
o Lots with pre-1978 structures on the seaward side: Lots 93 and 97
o Lots with pre-1978 structures on the landward side: Lots 91, 99, 101, 105
o End lots (including returns): Lot 87
Not all of the pre-1978 homes may meet the specific criteria for not being “substantially
improved2;” therefore, a waiver request from this provision is included in Section 4.0
below.
Alternatives: Although numerous alternatives have been considered and evaluated (or even
implemented previously in the Project area), no suitable alternatives to the proposed Project
exist which would satisfy the objective of providing long-term protection for existing
structures that pre-date September 1978 and have not been substantially improved.
Alternatives evaluated to the current design are described in the letters from Milone &
MacBroom dated October 1, 2013, October 25, 2013, and November 1, 2013.
Imminent Danger: The criteria used to define those properties in imminent danger are
described above under Section 2.05 B(1).
Section 2.02 B(4) - Performance Standard
“Clean fill of a compatible grain size may be used on a Coastal Beach, but not on a Tidal Flat,
only if the Commission authorizes its use, and only if such fill is to be used for a beach or dune
nourishment project. All possible mitigation measures shall be taken, as determined by the
Commission, to limit the adverse effects of the fill.”
Project Compliance: Project compliance with this standard is discussed below.
2 “Substantially Improved” is defined in Section 1.02 of the local wetlands regulations as: “cumulative expansion of
habitable space greater than twenty percent (20%).” “Habitable Space” is defined in Section 1.02 of the local wetlands
regulations as: “space in a structure for living, sleeping, eating or cooking. Bathrooms, toilet compartments, closets, halls,
storage or utility space, and similar areas are not considered habitable space.”
Baxter Road Temporary Stabilization Project 15 Consistency with Wetlands Regulations
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Clean Fill: Sand mitigation will consist of placing clean, beach-compatible sand into the
littoral system.
Tidal Flats: The Project does not involve placement of sand on any tidal flats.
Section 2.02 B(9) – Performance Standard
“The Commission may impose such additional requirements as are necessary to protect the
Interests Protected by the Bylaw.”
Project Compliance: As described above in Section 310 CMR 10.30(3), the Project has been
designed using best available measures to stabilize the coastal bank and protect existing landward
structures and public infrastructure while simultaneously avoiding, minimizing, and mitigating for
potential impacts. All of the interests protected by the Bylaw have been considered during the
process of Project design.
Nantucket Land Subject to Coastal Storm Flowage (Section 2.10)
“Land Subject to Coastal Storm Flowage” is defined in Section 1.02 of the local wetlands
regulations as “land subject to any inundation caused by coastal storms up to and including that
caused by the 100-year storm, surge of record, or storm of record, whichever is greater.”
Performance Standards for Land Subject to Coastal Storm Flowage (LSCSF) are defined in Section
2.10 of the local wetlands regulations, which provides that “Land Subject to Coastal Storm Flowage
or Land within 100 feet of Land Subject to Coastal Storm Flowage shall be presumed significant to
the interests Protected by the Bylaw, as referenced in Section A, therefore the following regulations
shall apply:”
The Project does not include activities or structures subject to the following performance standards,
and hence they are excluded from the subsequent discussion:
Section 2.10 B(2) (use of pollutants or septic systems);
Section 2.10 B(3) (underground fuel tanks); and
Section 2.10 B(4) (new buildings).
The applicable Sections 2.10 B(1) and 2.10 B(5) are discussed below.
Section 2.10 B(1) – Performance Standard
“The work shall not reduce the ability of the land to absorb and contain flood waters, or to buffer
inland areas from flooding and wave damage.”
Project Compliance: The Project will not reduce the ability of LSCSF to absorb and contain flood
waters. By stabilizing the bank face and providing protection at the toe of bank, the Project will
enhance the coastal bank’s function of buffering inland areas and buildings from storm damage.
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Section 2.10 B(5)
“The Commission may impose such additional requirements as are necessary to protect the
Interests Protected by the Bylaw.”
Project Compliance: As described above in Section 310 CMR 10.03(3), the Project has been
designed using best available measures to stabilize the coastal bank and protect existing landward
structures while simultaneously avoiding, minimizing, and mitigating for potential impacts. All of
the interests protected by the Bylaw have been considered during the process of Project design.
4.0 Waiver Request
The Applicants request a waiver from the following local performance standard for Coastal Beaches
and/or Coastal Banks.
Section 2.02 B(2): Not every pre-1978 structure in the project area (on both the
landward and seaward sides of Baxter Road) may meet the definition of not
“substantially improved”3; therefore, a request to waive Section 2.02 B(2) is hereby
made in connection with the proposed construction of the geotextile tubes placed
beneath or on top of the landward end of the coastal beach. This waiver request
presents full justification for the waiver in accordance with the criteria in Section 1.03(F)
of the Nantucket Wetland Regulations.
Section 2.02 B(6) and 2.05 B(5): While the Applicants believe that the project
constitutes a water dependent use, because it can only be performed within the
wetlands resource areas (coastal bank and coastal beach) which it is intended to protect,
and accordingly no waiver is required for the Project from the provisions of Sections
2.02 B(6) and 2.05 B(5) as to water dependent uses, the Applicants hereby requests a
waiver from those provisions, without prejudice to the Applicant’s position that no such
waiver is required. In the event of an appeal from any Order of Conditions issued by
the Commission on this NOI, SBPF reserves its right to assert that this waiver is not
required by the Regulations.
The Applicants also request any other waiver that the Commission deems appropriate.
3 The pre-1978 house status of the homes in the project area is presented on Figure 5. In 310 CMR 10.30 it is
provided that coastal engineering structures “shall be permitted” to protect pre-1978 homes. DEP expressly
finds that the project is within the scope of that provision. There is a parallel provision in the Nantucket
Wetlands Regulations. We note the “20% change” language incorporated into certain aspects of the portions
of the Nantucket Wetlands Regulations which address pre-1978 structures. That language does not of course
apply to infrastructure. Nothing in this request is, or is intended to be, a waiver, admission, or
acknowledgement adversely affecting any claim or argument available to SBPF that a municipality has
jurisdiction or authority to impose more stringent limitations on projects that “shall be permitted” under the
Wetlands Protection Act Regulations than those provided for in those Regulations. SBPF expressly reserves
all of its rights with respect thereto.
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Epsilon Associates, Inc.
The basis for each of the requested waivers is that, given existing conditions, the Project will not
adversely impact the interests identified in the By-law. Further, there is a certified emergency in the
project area, with an imminent threat to both public infrastructure and pre-1978 structures, and
there are no reasonable conditions or alternatives that would allow the Project to proceed in
compliance with the regulations.
Ocean and Coastal Consultants, Inc. (OCC) performed coastal analyses to determine
design conditions and proposed geometry for the emergency stabilization project along
Sconset Bluff. This memo provides a brief summary of methodologies, calculations
and results which demonstrate that the proposed 4-tiered, stacked geotextile tube
design with toe at 0.0 feet MLW and crest at +26.0 feet MLW is appropriate as a
means to protect the pre-1978 homes along the landward and seaward sides of Baxter
Road and Baxter Road. The formulae and methodologies utilized are based on standard
coastal engineering practice and design as endorsed by the U.S. Army Corps of
Engineers (USACE) and Federal Emergency Management Agency (FEMA).
As we show below, the design of the project starts with the offshore wave height and
then calculates how wave heights, wave setup, and wave runup will occur specific to
the project site based on actual nearshore conditions and the stillwater elevation at the
site as defined by FEMA.
Design Recurrence Interval:
The 1%-chance-annual storm, also referred to as a "100-year" storm, has a 1% chance
of being equaled or exceeded in any given year. This recurrence interval is the standard
of measure by FEMA for flood mapping and mitigation as well as the USACE for their
Hurricane and Storm Damage Risk Reduction System. There is a 5% chance that this
magnitude storm will occur during the 5-year design life permitted under the
temporary authorization.
Recorded wave data for 1982-2008 from NOAA buoy 44008 indicate numerous
occasions when the significant wave height exceeded 10 meters (exceeding the 1%
offshore wave height of 28.8 feet) and numerous occasions when the dominant wave
period exceeded the 1% design value of 15 seconds. These data suggest that 1% storm
conditions are experienced at the site on a much more frequent basis than once every
100 years. While the USACE Wave Information Studies (WIS) Hindcast data was
used to determine the deepwater significant wave height for the project (as described
below), this buoy is significant as it is 54 nautical miles southeast of Nantucket and has
over 26 years of recorded wave height and period data that were used to corroborate
MEMO
TITLE Sconset Coastal Analysis Summary
DATE 6 December 2013 revised April 15, 2014
TO SBPF
COPY Epsilon Associates
FROM Azure Dee Sleicher, P.E.
PROJECT NO 210019.1
ADDRESS Ocean and Coastal
Consultants, Inc.
35 Corporate Drive
Suite 1200
Trumbull, CT 06611
TEL 203-268-5007
FAX 203-268-8821
WWW ocean-coastal.com
PAGE 1/4
PAGE 2/4
that the 1% chance deepwater conditions offshore of Nantucket determined through
WIS are not only possible, but also have been exceeded.
The project must be designed for the coastal environment at Sconset. Designing to
anything less than the 1% storm conditions risks a chance of failure during major
storms or even lower magnitude storms that occur in rapid succession when protection
is most needed. For these reasons, the 1% storm is an appropriate level of design for
this project and is the minimum design level required to abate the emergency.
Stillwater Level (SWL):
The stillwater level is the projected elevation of flood waters in the absence of waves
resulting from wind or seismic effects. In coastal areas, stillwater elevations are
determined when modeling coastal storm surge. "Storm surge" is typically SWL
combined with wave setup. However, the effective FEMA Flood Insurance Study
dated November 6, 1996 indicates the 1% SWL (without wave setup) at Sconset is
equal to 10.2 feet MLW, approximately 0.2 to 2.2 feet above the bluff toe. Wave setup
must be calculated separately (see below). This SWL value is likely underestimated at
this point in time based on sea level rise, which has been reported by NOAA to be
approximately to 3.0 mm/year, as well as other factors, but is being used as best
available data for this project.
Deepwater Significant Wave Height and Peak Period:
The 1% deepwater significant wave height and peak period, 28.8 feet and 15.2 seconds
respectively, were determined from statistical analysis of USACE Wave Information
Studies (WIS) Hindcast data for station 63073. This station is located approximately
13.5 nautical miles east of Sconset and based on a data set from 1980-1999. The
hindcast data provide a valuable source of wave data needed in coastal engineering
design. This wave height is an offshore, deepwater wave height used as a basis for
offshore to nearshore wave transformation models (including wave setup calculations),
but is not used in wave runup calculations or design of the geotube structures. The
wave runup and design calculations use a depth-limited breaking wave at the toe of the
bluff. As stated previously, NOAA buoy 44008 indicates numerous occasions when
these values were exceeded, indicating that there is a real likelihood that this storm will
occur.
Toe of Bluff:
The toe of the bluff ranges from approximately elevation +8.0 to +10 feet MLW based
on the LIDAR survey conducted in July 2013. 8.0 feet was used as the toe elevation in
the analyses.
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Wave Setup:
Wave setup is an increase in the stillwater level shoreward of the wave breaking zone
caused by the onshore flux of momentum against the beach. Wave setup was
calculated using the deepwater significant wave height and average slope of the
nearshore zone of Sconset according to the direct integration method (DIM) prescribed
by FEMA. Wave setup was calculated to be 3.9 feet.
Design Water Depth:
The 1% design water depth at the toe of the bluff equals the stillwater level plus wave
setup minus the mudline at the toe of the bluff: 10.2 feet + 3.9 feet – 8.0 feet = 6.1 feet.
Design Wave Height:
The deepwater significant wave height will break as it approaches shore. The wave
impacting the bluff and geotube structure will be limited by the depth at the toe
calculated above. The wave height to water level "breaker" index is typically 0.78 (per
USACE) which means the water depth of 6.1 feet will allow a maximum breaking
wave height of 4.8 feet, which is rounded to 5 feet [6.1 x 0.78 = 4.8 feet].
Wave Crest Elevation:
Approximately 70% of the wave height lies above the water line. The crest elevation of
the breaking wave is therefore equal to the stillwater level + wave setup + 0.7(H),
where H is the Design Wave Height:
10.2 feet + 3.9 feet + (0.7*4.8 feet) = 17.5 feet MLW
Wave Runup:
Wave runup is the dynamic extent of wave uprush on a beach or structure above the
stillwater level. Wave runup on the stacked geotube system was calculated in
accordance with USACE Coastal Engineering Manual (CEM) methodology for berm
configuration based on the proposed geometry (Equation VI-5-7) in which the tube
above is set back from the front of the tube below to create a berm. Wave runup was
calculated to be 10.1 feet, which is measured above the stillwater elevation.
Structure Crest Elevation:
The maximum extent of wave uprush on the structure calculated for the 1% storm
recurrence interval equals the storm surge (SWL + wave setup) plus wave runup. The
storm surge is expected to be at approximate elevation 14 feet MLW (10.2 feet + 3.9
PAGE 4/4
feet), which is 4-6 feet above the toe of the bluff. The wave runup is expected to be
approximately 10 feet above that, giving us a total recommended height of 14-16 feet
above the toe of the bluff. This should be the minimum elevation of the top of the
proposed structure to prevent damage from wave runup and subsequent overtopping. A
45 foot circumference geotube is approximately 6.5 feet high when filled. A four (4)
tube configuration with base at 0 feet MLW elevation will have a top elevation at +26
feet MLW providing sufficient protection for the 1% storm.
Scour:
The beach at the toe of the coastal bank varies in elevation over the course of an
average year. The beach level at the toe of the coastal bank on the 2013 LIDAR
survey was approximately +8 feet MLW. During an average winter, Northeaster
storms can lower the beach level up to 3 to 5 feet below that level. It is critical that the
geotube system be designed for potential scour. As confirmed by J. Richard Weggel,
Ph.D., P.E., D.CE, Professor Emeritus Department of Civil, Architectural &
Environmental Engineering at Drexel University below, wave-induced scour is the
leading cause of geotube failure:
“Wave forces also act on the tube, but they generally act to push the tube shoreward
while gravity acts to displace the tube seaward. While much attention is paid to wave
forces, direct wave action rarely results in failure, rather it is wave-induced scour that
leads to failure. Observations suggest that tube displacement is most often seaward
indicating that are not wave forces, per se, that displace the tubes. Rather, the tubes
are undermined when the beach in front scours and the scour hole propagates
landward under the tube generating its failure. That is, the beach slope steepens
locally as scour progresses beneath the tube until the tube falls seaward into the scour
hole.” J. Richard Weggel
USACE recommends that a scour depth of 1.5 times the wave height be considered for
areas with moderate to severe scour potential such as the case with Sconset Beach. The
1% breaking wave height at the structure toe is approximately 5 feet so a scour depth
of at least 7.5 feet should be considered. Rounding this to 8 feet brings the bottom of
the geotube to the 0.0 feet MLW elevation.
Figure 1
Basis of Coastal Engineering Design
Sconset Bluff Emergency Project Nantucket, Massachusetts
THIS DRAWING IS NOT TO SCALE
100-YEAR STORM SURGE ELEVATION
BEACH ELEVATION
AT TOE OF BANK
100-YEAR WAVERUNUP ELEVATION
~EL 20'
EL 24'
~EL 14'
EL 0'
S1
Q1
Q2
Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community
G:\Projects\Lighthouse\2013\WHG_Profiles\fig1_coast_area_REV.mxd
Figure 2WHG Survey Lines - Wauwinet to Sewer Beds
Baxter Road Nantucket, MA
LEGEND
Basemap Imagery: World Imagery Map Service, ESRI
Project Area Properties
WHG Survey Line
New WHG Survey Line
WHG Survey Lines to Be Removed
°0 1,100 2,200550Feet1 inch = 2,200 feetScale 1:26,400
WAUWINET
SEWER BEDS
SQUAM
QUIDNET
SIASCONSET
SesachachaPond
AtlanticOcean
LIGHTHOUSE
see Figure 2for zoom-in toProject Area
BAXTER
ROADSANKATY ROADSANKATY HEAD
ROADISABELLE'S WAYPOL
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ANNES LANE
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Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community
G:\Projects\Lighthouse\2013\WHG_Profiles\fig2_project_area_REV.mxd
Figure 3WHG Survey Lines - Project Area
Baxter Road Nantucket, MA
LEGEND
Basemap Imagery: 2013 Col-East/2011 ESRI
Participating Properties
WHG Survey Line
WHG Survey Lines to Be Removed
New WHG Survey Line
°0 200 400100Feet1 inch = 400 feetScale 1:4,800
BAXTER ROADSANKATY ROAD
99
97
87
101
105
93
91
Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community
G:\Projects\Lighthouse\2014\Geotube\3-wetlands_fema.mxd
Figure 4DEP Wetlands and FEMA Flood Zones
Baxter Road Nantucket, MA COASTAL BEACHCOASTAL BEACH
LEGEND
Basemap: 2013 Aerial Imagery, Col-East, Inc.°0 50 10025Feet1 inch = 100 feetScale1:1,200
Project Parcel
Land Subject to Coastal Storm Flowage*
Wetland Resource Area: Coastal Bank
*Defined by FEMA 100-Year Floodplain
COASTAL BEACHCOASTAL BEACH
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Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community
G:\Projects\Lighthouse\2014\Geotube\4-nhesp.mxd
Figure 4Natural Heritage and Endangered Species Program
Baxter Road Nantucket, MA
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LEGEND
NHESP 2008 Estimated Habitats for Rare Wildlife: For Use with the MA Wetlands Protection Act Regulations (310 CMR 10)
NHESP 2008 Priority Habitats for State-Protected Rare Species
NHESP 2014 Massachusetts Certified Vernal Pools
NHESP Potential Vernal Pools: NOT equivalent to Certified Vernal Pools!.
!.
Basemap: 2013 Aerial Imagery, Col-East, Inc.°0 50 10025Feet1 inch = 100 feetScale1:1,200
Project Parcel
SesachachaPond
AtlanticOcean
AREA LOCUS
BAXTER
ROADSANKATY ROADISABE
L
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'S
WAY
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I
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R
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BAYBERRY LANE
53
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Source: Esri, DigitalGlobe, GeoEye, i-cubed, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP,swisstopo, and the GIS User Community
G:\Projects\Lighthouse\2014\Geotube\5-year_built.mxd
Figure 6Pre-1978 House Status
Baxter Road Nantucket, MA
LEGEND
Basemap: 2013 Aerial Imagery, Col-East, Inc.
Pre-1978 House Status
Pre-1978
Post-1978
Vacant
Not Specified
°0 150 30075Feet1 inch = 300 feetScale1:3,600
Photograph 1. Well-established American Beachgrass on Coastal Bank at 67 Baxter
Road.
Photograph 2. Well-established American Beachgrass on Coastal Bank at 67 Baxter
Road, with Adjacent Unvegetated Section of Coastal Bank.
Photographs 1-2
Baxter Road Nantucket, MA
,j g
Photograph 3. Hoick’s Hollow Accessway Improvements.
Photograph 4. Hoick’s Hollow Accessway with Access Ramp.
Photographs 3-4
Baxter Road Nantucket, MA
Photograph 5. Hoick’s Hollow Accessway (View from Top).
Photograph 6. Sand on Bluff Face at Two Sand Delivery Locations and at 93 Baxter Road.
Image obtained from the Facebook page of the Nantucket Coastal Conservancy
Photographs 5-6
Baxter Road Nantucket, MA
Photograph 7. Exposed Seaward Edge of Tier 2 Geotube During April 4, 2014 Shoreline Survey.
Photograph 8. Exposed Seaward Edge of Tier 2 Geotube During April 4, 2014 Shoreline Survey.
Photographs 7-8
Baxter Road Nantucket, MA
Photograph 9. Southern End of Sand Template on April 16, 2014.
Photograph 10. Individual Traversing Sand Template on April 16, 2014.
Photographs 9-10
Baxter Road Nantucket, MA
Photograph 11. Individual Traversing Sand Template on April 15, 2014.
Photograph 11
Baxter Road Nantucket, MA
wpaform3.doc • rev. 1/3/2013 Page 2 of 8
Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands
WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
l
City/Town
A. General Information (continued)
6. General Project Description:
Construction of geotube system to stabilize coastal bank supporting Baxter Road and associated
infrastructure. Vegetation of upper bank face. See attached narrative.
7a. Project Type Checklist:
1. Single Family Home 2. Residential Subdivision
3. Limited Project Driveway Crossing 4. Commercial/Industrial
5. Dock/Pier 6. Utilities
7. Coastal Engineering Structure 8. Agriculture (e.g., cranberries, forestry)
9. Transportation 10. Other
7b. Is any portion of the proposed activity eligible to be treated as a limited project subject to 310 CMR 10.24 (coastal) or 310 CMR 10.53 (inland)?
1. Yes No If yes, describe which limited project applies to this project:
2. Limited Project
8. Property recorded at the Registry of Deeds for:
Nantucket
a. County
b. Certificate # (if registered land)
c. Book
d. Page Number
B. Buffer Zone & Resource Area Impacts (temporary & permanent)
1. Buffer Zone Only – Check if the project is located only in the Buffer Zone of a Bordering
Vegetated Wetland, Inland Bank, or Coastal Resource Area.
2. Inland Resource Areas (see 310 CMR 10.54-10.58; if not applicable, go to Section B.3,
Coastal Resource Areas).
Check all that apply below. Attach narrative and any supporting documentation describing how the
project will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location.
For all projects affecting other
Resource Areas, please attach a narrative explaining how the resource
area was delineated.
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
a. Bank
1. linear feet
2. linear feet
b. Bordering Vegetated W etland
1. square feet
2. square feet
c. Land Under
Waterbodies and Waterways
1. square feet
2. square feet
3. cubic yards dredged
wpaform3.doc • rev. 1/3/2013 Page 3 of 8
Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands
WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
l
City/Town
B. Buffer Zone & Resource Area Impacts (temporary & permanent) (cont’d)
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
d. Bordering Land Subject to Flooding
1. square feet
2. square feet
3. cubic feet of flood storage lost
4. cubic feet replaced
e. Isolated Land Subject to Flooding
1. square feet
2. cubic feet of flood storage lost
3. cubic feet replaced
f. Riverfront Area
1. Name of Waterway (if available)
2. Width of Riverfront Area (check one):
25 ft. - Designated Densely Developed Areas only
100 ft. - New agricultural projects only
200 ft. - All other projects
3. Total area of Riverfront Area on the site of the proposed project:
square feet
4. Proposed alteration of the Riverfront Area:
a. total square feet
b. square feet within 100 ft.
c. square feet between 100 ft. and 200 ft.
5. Has an alternatives analysis been done and is it attached to this NOI? Yes No
6. Was the lot where the activity is proposed created prior to August 1, 1996? Yes No
3. Coastal Resource Areas: (See 310 CMR 10.25-10.35)
Check all that apply below. Attach narrative and supporting documentation describing how the project
will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location.
Online Users: Include your document transaction number
(provided on your receipt page) with all supplementary information you
submit to the Department.
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
a. Designated Port Areas Indicate size under Land Under the Ocean, below
b. Land Under the Ocean
1. square feet
2. cubic yards dredged
c. Barrier Beach Indicate size under Coastal Beaches and/or Coastal Dunes below
d. Coastal Beaches 35,500 sf
1. square feet
2. cubic yards beach nourishment
e. Coastal Dunes
1. square feet
2. cubic yards dune nourishment
wpaform3.doc • rev. 1/3/2013 Page 4 of 8
Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands
WPA Form 3 – Notice of Intent
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Provided by MassDEP:
MassDEP File Number
Document Transaction Number
l
City/Town
B. Buffer Zone & Resource Area Impacts (temporary & permanent) (cont’d)
Size of Proposed Alteration Proposed Replacement (if any)
f. Coastal Banks 900 feet
1. linear feet
g. Rocky Intertidal Shore s
1. square feet
h. Salt Marshes
1. square feet
2. sq ft restoration, rehab., creation
i. Land Under Salt Ponds
1. square feet
2. cubic yards dredged
j. Land Containing Shellfish
1. square feet
k. Fish Runs Indicate size under Coastal Banks, inland Bank, Land Under the
Ocean, and/or inland Land Under Waterbodies and Waterways, above
1. cubic yards dredged
l. Land Subject to Coasta l Storm Flowage
35,500 sf
1. square feet
4. Restoration/Enhancement If the project is for the purpose of restoring or enhancing a wetland resource area in addition to the
square footage that has been entered in Section B.2.b or B.3.h above, please enter the additional amount here.
a. square feet of BVW
b. square feet of Salt Marsh
5. Project Involves Stream Crossings
a. number of new stream crossings
b. number of replacement stream crossings
C. Other Applicable Standards and Requirements
Streamlined Massachusetts Endangered Species Act/Wetlands Protection Act Review
1. Is any portion of the proposed project located in Estimated Habitat of Rare Wildlife as indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetland Wildlife published by the Natural Heritage and Endangered Species Program (NHESP)? To view habitat maps, see the Massachusetts
Natural Heritage Atlas or go to http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/priority_habitat/online_viewer.htm.
a. Yes No If yes, include proof of mailing or hand delivery of NOI to:
Natural Heritage and Endangered Species Program
Division of Fisheries and Wildlife
100 Hartwell Street, Suite 230
West Boylston, MA 01583
October 1, 2008
b. Date of map
Table 1. Construction Dates of Baxter Road Properties 51 – 120 Baxter Road Property Owner Property Address Map/Parcel Date of Initial Construction of Main Dwelling (& Cottages/Garages as Noted); references to other outbuildings are only noted if they were referenced in HDC files Alterations, etc.per Building Dept. Records &Moves per Building Dept. Records and Historic Structures Files Note: year noted is year applied/permit issued Richard S. and Linda M. Mackay 120 Baxter Road 48-33 House: 1983 1983 – Single family dwelling Sconset Trust, Inc. 119 Baxter Road 48-7 1987 – Moved to 82 Baxter Road Stephen B. Cohen 117 Baxter Road 48-9 House: By 1923/ 1978 Garage: By 1923 1978 – Single family dwelling 1988 – Moved on same lot 2001 – New deck piers & rails (issued?) 2005 – Moved to 116 Baxter Road Stephen B. Cohen 116 Baxter Road 48-34 2005 – 117 Baxter moved to this lot 2012 – Replace windows, rakes, fascia, soffit, gutters & cornerboards Donald E. Claudy, Trustee 115 Baxter Road 48-10 House: By 1923/ 1925 1983 – Structural repairs, new deck, interior reno 1987 – Alter and renovate, raise roof, new windows & doors 1988 – 2nd floor addition, window & door changes 1988 – Relocate house on same lot, add steps - sewer Rick Hinchey, Trustee 114 Baxter Road 48-35 House: 1984 1984 – Dwelling 1998 – Repair & replace 8 windows Kyle L. Latshaw and Loretta A. Yoder 113 Baxter Road 48-11 House: Since 1940 1988 – Move on same lot Ann B. Furrow 112 Baxter Road 48-36 2005 – 99 Baxter moved to this lot, add basement 1494 sf finished space, 1st floor add 314 sf, 2nd floor existing, 5 beds/5 baths Patrick T. Ryan, Trustee 110 Baxter Road 48-37 House: 2001 2nd Dwelling: 2005 2001 – 2 story, 4 bed, 4 bath dwelling – septic 2005 – Construct 1 DU; 1st floor 615 sf – 2nd dwelling 2006 – Finish basement 550 sf
John P. and Susan D. Deangelis 109 Baxter Road 48-12 Since 1940 1988 – Moved from “Lot A to Lot B”/111 Baxter Road (109 & 111 are combined) 1988 – Alter and repair dwelling 1996 – Renovate 1st 1012 sf, basement 980 sf, rec room, bath, storage, add 450 sf 2nd 2 br, bath, 1 du (note: plans show new dormers, replace windows, new porch, etc.) Whitney A. Gifford, Trustee 108 Baxter Road 48-38.1 House: 2001 2nd Dwelling: 2005 2001 – Build 2 story 4 br 1 du 2005 – Construct 1 du finished full cellar (2nd dwelling) Whitney A. Gifford, Trustee 107A Baxter Road 48-14 Whitney A. Gifford, Trustee 107 Baxter Road 48-14.1 William B. & Marilee B. Matteson 106 Baxter Road 48-39 Garage by 1940 1998 – 105 Baxter moved to this lot 2004 – pool w/fence 2004 – renovate garage William B. & Marilee B. Matteson 105 Baxter Road 48-15 By 1940 1975 – Moved per HDC file 1988 – Moved on same lot; add & alter (per plans, alterations appear to be new decks and lattice at large deck) 1998 – Moved to 106 Baxter James E. Walker, III and Deborah C. Walker 104 Baxter Road 48-40 2001 – 101 Baxter moved to this lot; necessary repairs and maintenance 2007 – Cover existing deck w/porch roof 2011 – Enclose porches 1st & 2nd floor, add bath . . . James E. Walker, III and Deborah C. Walker 101 Baxter Road 48-17 By 1940 1984 – Permit noted on file cover, but permit is not in file (work performed is not indicated) 1988 – Moved per HDC file 1989 – “Move” noted on file cover, but permit is not in file 2001 – Emergency move to 104 Baxter David S. and Dorothy O. Bailey 100 Baxter Road 48-42 House: 1983 Garage Apt.: 2004 Shed: Since 1940 1983 – Construct 2 story, 4 bedroom single family dwelling, deck 2004 – Relocate dwelling and 1 story addition – sewer on same lot 2004 – 2 story 1 br 1 bath garage apt. Ann B. Furrow 99 Baxter Road 48-18 House: By 1940 Garage: Since 1940 1975 – Moved per HDC file 1988 – Moved on same lot 1999 – Renovate entire DU (no exterior changes per application) 2005 – Moved to 112 Baxter Road 2010 – Move 400 sf storage shed onto lot from 97 Baxter and place on slab foundation – no plumbing 2013 – Emergency demolition of garage due to
coastal erosion Janice S. Savery et al. 98 Baxter Road 48-43 House: 1980 1980 – 1 story 2 BR, 2 Bath DU – sewer 2005 – Renovate kitchen 160 sf, renovate baths 112 sf & replace front door w/like kind 2006 – Porch roof and outside shower stall 2006 – Demo shed 2006 – Construct shed Lawrence C. and Margaret McQuade 97 Baxter Road 48-19 House and Guesthouse: Since 1940 Garage: 1982 1972 - Addition 1975 – Moved per HDC file 1982 – Garage 1982 – Addition (enlarge one room, enclose porch) 1988 – Moved on same lot 1988 – Move garage 1989 – Addition 1996 – Renovate 2nd floor bath & deck and mudroom additions 1998 – Add 839 sf unfinished 2nd floor to 3 br 1 du, 297 sf 1st addition, reno 160 sf kitchen area 2005 – demo 24’ x 16’ section of studio due to bank erosion 2010 – Move 400 sf storage building off lot to 99 Baxter 2010 – Moved part to 7 Plainfield leaving 720 sf portion for conversion to 1 DU 2010 – Convert & relocate existing remaining elements per plans for new 1 DU . . . Alexander Webb, III and Laura R. Webb 96 Baxter Road 48-44 House and Guesthouse Since 1940 2007 – Replace windows & doors, extend deck 8’ x 12’, arbor at front door Daniel T. Korengold, Trustee 94 Baxter Road 48-45 Steven T. and Erin P. Freeman 93 Baxter Road 48-21 House: 1950/1951 Garage Apt.: ND 1992 – Relocate garage on same lot 1992 – Relocate 1 DU on same lot 2005 – Renovate 140 sf kitchen, 2 full baths 100 sf, new walls living room & new floor in family room “interior only” 2010 – Relocate dwelling on same lot 2010 – Relocate garage on same lot Daniel T. Korengold, Trustee 92 Baxter Road 48-23 House and Shed: Since 1940 New Dwelling and Garage/Studio: 2005 2005 – Demo garage 2005 – Move 1 DU 1133 sf dwelling to 18 Irving 2005 – Construct garage w/studio 2005 – Construct new dwelling full cellar finished Daniel T. Korengold, Trustee 91 Baxter Road 48-22 Laurance J. Guido, MD FACS et al. 90 Baxter Road 49-5 House: 1996 1996 - Dwelling
Samuel and Ann Furrow 87 Baxter Road 49-8 House: 1976 1976 – One family dwelling 1988 – Add and alter dwelling 1988 – Enclose existing porch 1989 – Add 192 sf and alter 972 sf to existing dwelling 1990 – alterations (“interior change”) 2003 – renovate kitchen 1st floor & renovate 2nd fl master bedroom and bath area, shingle roof) 2007 – relocate 1 DU on same lot on 5 ft crawl space 2013 – Demolish 2 story single family dwelling . . . Clark M. Whittemore, Jr., Trustee 86 Baxter Road 49-36 House: By 1940 Garage: 1983 1983 – Garage 1995 – 16’ x 17’ deck 1996 – Add 2nd floor br & bath 2002 - Shed Jay W. Wertheimer, Trustee 85 Baxter Road 49-35 House: 1925/By 1940 Guesthouse: Since 1975 Garage: Since 1940 2006 – Demo existing 748 sf dwelling 2010 – Prepare dwelling to move off lot; amended to reflect move off of primary structure to 47 Monomoy 2010 – Prepare dwelling for move off lot . . . (cottage) 2011 – Demo garage (amended to move off) Note: other permit numbers are noted on face of file, but are not inside file Juliet F. Hunter, Trustee 84 Baxter Road 49-37 House and Garage: Since 1940 1991 – Kitchen and bedroom addition Marie Dostalier et al. 83 Baxter Road 49-34 House: Since 1940 1982 – Extension of existing kitchen 1991 – Addition of sunroom and roof over dining room 2001 – Relocate dwelling and place on new foundation on same lot East Eden, LLC 82A Baxter Road 49-38 House: 1993 1993 – 2 story 2 bedroom single family dwelling 1996 – bed, bath & shed addition 82 Baxter Road, LLC 82 Baxter Road 49-39 House: By 1923 1987 – 119 Baxter moved to this lot (& build deck per application) William D. and Deborah F. Cohan 81 Baxter Road 49-33 House: By 1923 New House: 1994 1993 – Demolish 1393 sf 1 story 3 br 1 du 1993 – 2 story, 4 bedroom single family dwelling 2001 – addition to dwelling, add deck, renovate 1st floor Joshua Posner and Eileen Rudden 80 Baxter Road 49-40
Helmut F. and Caroline S. Weymar 79 Baxter Road 49-23 House: 1916/By 1923 Shed: ND Per HDC file: 1987-1988 North Wing, Porch, Deck Roof Walk Reconstructed 1989 – Demo shed 1989 – Alter & add to single family dwelling 1997 – Add 278 sf to 1st floor deck 1 du 1999 – Replace windows, redo roofwalk Caroline S. Weymar, Trustee 78 Baxter Road 49-41 House: 1990 1990 – 2 bedroom single family dwelling 1993 – 16’ x 16’ deck to rear of 1 du 1994 – Change 2nd floor to 3 br’s – 4 br total 1 du 2002 – Construct 100 sf addition along/w 3 shed dormers Joshua Posner and Eileen Rudden 77 Baxter Road 49-31 House: Since 1940 Shed: ND 2005 – Demo 558 sf bunkhouse 2006 – Move existing house on same lot, add finished full basement, add sunroom & garage Caroline S. Weymar, Trustee 76 Baxter Road 49-42 Combined w/3 Bayberry Lane b dept. file Sankaty Bluff Group, LLC 75 Baxter Road 49-30 House: 1922/ By 1923 Garage: By 1923 2002 – Add dormer, add 2 decks, reno interior 2004 – Add dormer & windows to existing garage, replace garage doors, add storage loft, construct pergola Linda Mason, Trustee 3 Bayberry Lane 49-43 1991 – Renovate 3 br 1 du both floors, doors & windows 1992 – add 238 sf br over porch, deck 1 du 1992 – Renovate garage to living space Joan R. Brecher et al. 73 Baxter Road 49-27 House: 1920 Garage: ND 1986 – Addition of 2nd story bathroom 1989 – Construct addition 1989 – Build 10’ x 14’ addition to garage for storage 2012 – Demolish 350 sf of 1st floor, relocate on same lot, add 150 sf 1st kitchen, reno baths, reside wall & roof James K. McAuliffe, Trustee 72 Baxter Road 49-44 House: Since 1940 Garage: 1993 1993 – Total renovation of single family dwelling 1993 – Construct garage 1996 – Renovate and convert garage to heated studio w/bath 1998 – Build one story addition for a master bathroom 2008 – Pool 2008 – Construct cellar under studio, remove non-conforming shed, relocate entry door 2012 - Shed
John C. Merson and Carol Bunevich 71 Baxter Road 49-26.1 House: 1932/ 1939 Garage: 1932 1982 – Bedroom addition 2004 – Repair/replace walls, reno bath (interior only) 2005 – Construct deck at east entrance & outside shower 2009 – Dismantel cottage/garage 2009 – Relocate 1 du on same lot, remove additions, construct finished full cellar, reno 1st flr 1500 sf & add 2nd fl 400 sf Susan Wilner and David Golden, Trustees 70 Baxter Road 49-45 House: 1940 New House and Garage Studio: 2000 Guesthouse: Since 1940 1989 – Alter interior/add windows & deck 2000 – Build a 2 story 4 br 1 du 2000 – Garage studio 2000 – Move 1 du 1740 sf to 4 Lincoln St. 2000 – Move 1 du off to 4 Lincoln St., 1200 sf Richard and Marianne L. Moscicki 69 Baxter Road 49-25 Dwelling & Garage Apt.: Since 1940 New House: 1996 1996 – Build 2 story 5 br 1 du 1920 sf 1st 1830 sf 2nd 1997 – Move garage to 320R Milestone 1997 – Move house to 320R Milestone 1999 – Add wet bar and powder room in basement Whitney A. Gifford, Trustee 68 Baxter Road 49-47 House: By 1938 1996 – Add 5068 frenchwood door and window side of 1 du & amendment to remove existing wall, replace ceiling and floor, install 6’0” x 6’8” patio door 2004 – Renovate 1st and 2nd floor, add 2nd floor Morning Light, LLC 67 Baxter Road 49-24 House: 1930; Garage: ND 1979 – Construct 5’6” x 9’ and 5’6” x 16’ additions 2001 – Relocate DU on same lot for setback compliance 2002 – Repairs and reshingle side & roof, red fire proof shingles on roof (note: it looks like this is permit is for the garage) 2002 – Reno of relocated DU, 2 new decks – sewer; add porch & 2nd floor deck Thomas and Sharmila Tuttle 65 Baxter Road 49-23 House: 1895; Garage & Shed: ND 2001 – Raise house to provide cellar, completely renovate 3 story 1 DU 2001 – Reno shed 2001 – Reno garage Elizabeth Singer 64 Baxter Road 49-51 2006 – Shed NOTE: GIS shows tennis court on property Elizabeth Singer 63 Baxter Road 49-22 House: 1890/ 1892 Garage Apt.: By 1923 (was a stable) 2nd Dwelling: 2004 Garage and Store 2002 – Reno existing dwelling unit approx.. 3000 sf reroof & shingle walls 2004 – Demo guest house/garage 2004 – 2nd dwelling 2005 – Demo shed 2007 – Garage and store room
Room: 2007 Shed: By 1923 Ann R. Healey, Trustee et al. 62 Baxter Road 49-52 Ann R. Healey, Trustee et al. 61 Baxter Road 49-21 House: 1893-4/1893 Beach house: ND Garage: By 1923 2004 – Repair existing porch decking & joists – reroof 2800 sf trim 1 du & amendment to reshingle, renovate kit, laundry & 4 baths, foundation repairs, 1st flr girder replacement, insulate & add heat, upgrade plumbing & electrical ABCET, LLC 60 Baxter Road 49-53 Kevin F. Dale, Trustee 59 Baxter Road 49-20 House: 1905/ By 1923 Shed: ND Garage/Workshop: 1996 1991 – Rebuild shed 1991 – Rebuild front porch, alter windows & doors, reside & reroof & amendment to add 121 sf porch enclosure, bed, bath 1996 – Build garage/workshop 1999 – Remove enclosure on 166 sf porch – add steps and door 2003 – Replace fixtures & tile in 3 baths 2011 – Raise dwelling & place on new full foundation; finish basement BR, 2 BA, LR; reno 495 sf, add 97 sf 1st, reno 153 sf 2nd ABCET, LLC 58 Baxter Road 49-54 House: Since 1938 1987 – Install new bath fixtures & kitchen facilities (“garage to dwelling” per file cover) 1999 – Relocate on same lot, demo part & add 1 story 1 du 1138 sf 680 sf habitable basement ABCET, LLC 56 Baxter Road 49-55 Stephen W. Kidder, Trustee, et al. 55 Baxter Road 49-18 House: 1890 1973 – Addition (library) 1998 – Relocate dwelling on same lot, new finished cellar, renovate remaining 2 stories - porch ABCET, LLC 54A Baxter Road 49-122 ABCET, LLC 54 Baxter Road 49-125 Stephen W. Kidder, Trustee, et al. 53 Baxter Road 49-17 House: 1925/ 1930 Garage: 1930 1987 – Addition to garage 1987 – 850 sf addition 1988 – 16 ½ sf addition 1997 – Repair & replace chimney 2000 – Replace windows & doors on 1 du 2007 – Renovate kitchen, bath & office 800 sf on 2nd fl renovate 3 bathrooms 350 sf 2011 – Remove existing beach stairs and rebuild new deck and stairs 52 Baxter Road, LLC 52 Baxter Road 49-57 House: Since 1938 1988 - Addition
Fifty-One Baxter Road, LLC 51B Baxter Road 49-16 House: 1886/ 1887 Garage and Shed: ND 2nd Dwelling w/Garage: 2009 1991 – Repair windows, shingle, decking, pantry flr 1991 – Add 8’6” x 14’ to existing 2nd flr BR 1 BU no heat 1994 – Add 126 sf 1st flr kitchen and 72 sf 2nd fl bath & improve baths on 2nd flr 1994 – demo shed 1995 – demo garage 2009 – Relocate building on new finished full basement 1905 sf – add 255 sf & reno 1st flr 2025 sf, 2nd flr reno 1349 sf – windows and doors & amendment to reframe porch and replace sunroom walls & ceiling, new windows 2009 – Build 2 story, one bed 1DU 807 sf 1st inc. garage 283 sf 2nd 2011 – Remove existing beach stairs & replace w/new 51A Baxter Road 49-16.1 F:\WpS\SBPF, Inc\Table of Homes 1978 or earlier.docx