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PO Box 2050 · Nantucket MA 02584
April 7, 2015
Coastal Erosion Commission
Massachusetts Office of Coastal Zone Management
ATTENTION: Coastal Erosion Commission Report
251 Causeway Street, Suite 800
Boston, MA 02114
erosion-commission@state.ma.us.
PUBLIC COMMENT
Dear Members of the Commission:
On behalf of the many residents of Nantucket, both year-round and seasonal, who are
concerned about the issues of climate change and rising sea level and the impact these realities
will have on our island, the Coordinating Team of the Nantucket Coastal Conservancy (NCC)
respectfully submits the following Public Comment on the Draft Report of the Coastal Erosion
Commission issued this January.
The mission of the Nantucket Coastal Conservancy, founded in 2012, is to protect and preserve
Nantucket’s coastal resources through education, research and advocacy, ensuring that future
generations have the opportunity to use and enjoy them.
We are particularly concerned because, with the recent proliferation of erosion-control projects
along our shoreline, Nantucket’s natural beaches are at risk. Not only do our beaches make us
who we are, they are a key driver of our economy: they are cited time and time again as the
main reason people come here to vacation, to live, to work, to raise a family and to invest. For
islanders, how we respond to increased erosion and its consequences is not only an
environmental issue, it is also an economic one.
Having worked with representatives of the Office of Coastal Zone Management (CZM) during
the formation of our local Coastal Management Plan for Town-owned land, we are conversant
with the science of coastal processes, including erosion, and the best practices of erosion control
(No Adverse Impacts) advanced by the Commonwealth professionals most knowledgeable
about these important matters. Representatives of the NCC also attended the March 19 Public
Hearing held in New Bedford in regard to the draft Report of the Commission. Members of our
Team have read the Report in depth.
NCC Public Comment Letter 2
PO Box 2050 · Nantucket MA 02584
With this information, as background, we offer the following comments:
REPORT BALANCED, BASED ON THE DATA AND THE SCIENCE
First and foremost, we commend the Commission for responding to its charge by producing a
thorough, balanced document, obviously based on the data and the science. We support the
work of the Commission and cite the members and staff for the quality of the report.
The report provides a discussion of the underlying science and a very useful inventory of
existing structures and efforts meant to reduce or avoid erosion. The science section certainly
describes the shoreline as a system, with events in one part impacting other areas.
IMPACTS ON OTHERS
Nevertheless, we believe that the report would benefit greatly from more discussion and
considerably more emphasis on the fact that measures taken by governments or by private
individuals in one area of the shoreline will impact others. We suggest adding explanations of
such impacts. (We have heard people say, in essence, that if someone wants to do something to
try to protect his or her property from erosion, then there is no reason for others to try to stop
the effort. We hope the report can help overcome such lack of understanding.)
COSTS OF EROSION-CONTROL MEASURES
A related point has to do with the costs of potential erosion-control measures. They are
expensive. They are likely to be feasible for people or towns with substantial financial resources.
In light of our main point (above), the impacts will affect (often adversely) both individuals
with fewer financial resources and also less-wealthy towns and communities.
RECONSIDER EXEMPTION FOR PRE-1978 BUILDINGS FROM PROHIBITION ON HARD
COASTAL ENGINEERING STRUCTURES
Under the Legal and Policy section, we would like to see a recommended action relative to the
exemption in the State Wetlands Protection Act (WPA) from the prohibition on hard coastal
engineering structures given to pre-1978 buildings.
Over 35 years have passed since the law was adopted prohibiting the use of hard structures
because of their adverse impacts. The science related to hard armoring is well documented,
settled and beyond question. Such structures cause irreversible damage that cannot be
mitigated because the mitigation effort is neither financially nor environmentally sustainable.
NCC Public Comment Letter 3
PO Box 2050 · Nantucket MA 02584
What is even more concerning is that, rather than narrowing this exemption, the State appears
to be expanding it, as least from our community’s perspective. In one highly visible, recent
instance, the State overrode the decision of our local Conservation Commission (an
exceptionally well-qualified board on which three PhD. scientists sit) not to permit a 900-foot
seawall below the bluff in ‘Sconset. In the Superseding Order of Conditions issued by the
Department of Environmental Protection (DEP) last December, the department not only
allowed the geotube seawall (installed under an Emergency Order) to remain, but did so even
though within the seven-lot project area, only two (2) properties have pre-1978 structures on
them. (One of these pre-1978 buildings is teetering on the edge of the bluff and appears to be
uninhabitable. See photo below, taken March 25. The other is a small ancillary structure left on
the lot when the main house was moved out of harm’s way.)
This issue of the pre-1978 exemption, and the related one of “gap” lots, will only become more
critical, as property owners bring increasing political pressure to bear on the State for more
robust erosion-control measures.
Dr. Robert Young, the Director of the Program for the Study of Developed Shorelines, a joint
venture between Duke and Western Carolina Universities, was quoted in the Nantucket Inquirer
and Mirror [December 24, 2014], as saying he believes “Massachusetts needs a new policy for
managing the coast.” Referring to the protection of pre-1978 buildings in the Commonwealth,
he opined that that exemption opens up “almost every shoreline as a candidate for coastal
engineering. Is that what the people of Massachusetts want?”
NCC Public Comment Letter 4
PO Box 2050 · Nantucket MA 02584
A recommendation in the report from the Commission to our representatives in the legislature
to address this matter would be an important first step.
GREATER EMPHASIS RE PRACTICAL STRATEGIES FOR COASTAL COMMUNIITES
We also recommend that greater emphasis, and detail, be given to practical steps coastal
communities can take, such as set-back requirements and buy-back programs. While such
initiatives are referenced in the draft report, they are not recommended as policy, according to
Bruce Carlisle, when asked about this at the hearing in New Bedford on March 19. We
recommend that the report be stronger in this regard, urging more than just further
“evaluation” of such strategies.
In closing, we reiterate that we find the draft Report of the Commission to be a solid piece of
work. It should prove helpful, especially with the revisions we recommend, to the policy- and
law-makers in our Commonwealth, as they craft coastal management initiatives designed to
assist communities like ours in dealing with climate change, rising sea level and subsequent
erosion in ways that are both environmentally and financially sustainable.
On behalf of the NCC Coordinating Team,
D. Anne Atherton
NCC COORDINATING TEAM
Peter Brace
Barbara Bund
Sunny Daily
Rita Higgins
Susan McFarland
Linda Spery
Liz Trillos
Charley Walters
Mary Wawro
Karen Werner
COPY:
Nantucket Conservation Commission
Nantucket Board of Selectmen
Nantucket Economic and Planning Commission