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Home My WebLink AboutEpsilon Response to the Conservation Commission Regarding Monitoring Report Criteria Letter SE48_2824 PRINCIPALS Theodore A Barten, PE Margaret B Briggs Dale T Raczynski, PE Cindy Schlessinger Lester B Smith, Jr Robert D O’Neal, CCM, INCE Michael D Howard, PWS Douglas J Kelleher AJ Jablonowski, PE Stephen H Slocomb, PE David E Hewett, LEED AP Dwight R Dunk, LPD David C Klinch, PWS, PMP Maria B Hartnett ASSOCIATES Richard M Lampeter, INCE Geoff Starsiak, LEED AP BD+C Marc Bergeron, PWS, CWS Alyssa Jacobs, PWS Holly Carlson Johnston Brian Lever 3 Mill & Main Place, Suite 250 Maynard, MA 01754 www.epsilonassociates.com 978 897 7100 FAX 978 897 0099 Projects:\21597\2013 Emergency Project\Monitoring and Work Reports\ October 31, 2019 Mr. Jeff Carlson Nantucket Conservation Commission 2 Bathing Beach Road Nantucket, MA 02554 Subject: SE44-2824 Baxter Road and Sconset Bluff Storm Damage Prevention Project Dear Mr. Carlson, We are in receipt of your letter dated October 23, 2019 regarding shoreline surveys pursuant to Special Condition 27, which seeks the continuance of the shoreline surveys performed by the Woods Hole Group on a quarterly basis for three years. This condition also allows the Siasconset Beach Preservation Fund (“SBPF”) to request a reduced monitoring program after three years by requesting an Amended Order of Conditions. Condition 27 reads: “The ongoing beach monitoring/survey program currently conducted by the Woods Hole Group shall continue. The monitoring program shall be conducted on a quarterly basis for the first 3 years [emphasis added] in order to timely identify beach impacts that may be attributable to the Geotubes and to assess whether the mitigation program is adequate. Beach profiles shall be taken on a quarterly basis along the 44 proposed profile lines. Beach profiles shall be taken from the top of the coastal bank, coastal dune or Geotube seaward to the -5 foot ML W contour. Beach profile data and analysis shall be submitted to the Department and the NCC within 30 days of completion of the quarterly survey. Following 3 years of quarterly surveys, SBPF may request to amend the Order of Conditions to alter the monitoring program. [emphasis added]” The SBPF submitted the Notice of Intent (“NOI”) for the geotube extension project (DEP File No. 48-3115) in January 2018 in accordance with SE48-2824 Special Condition 18 which restricted any requests to extend the shoreline protection project to after January 1, 2018. Special Condition 18 also stated that: “… The Commission will make its best efforts to review and decide such an application within 120 days. …” Mr. Jeff Carlson 2 Nantucket Conservation Commission October 31, 2019 The Public Hearing on the extension project was opened September 17, 2018. Given the language in Special Condition 18 we expected a decision in January 2019. The decision however was not issued until June 2019. During the 6-month period (January 2019 to June 2019) i.e. Quarters 1 and 2 of 2019, we expected the hearing to close several times and that the Commission would issue a decision on the extension project. We expected at a minimum that the Commission would allow the survey monitoring program to be reduced from quarterly to semiannually since that had been clearly supported by Mr. Berman and because that was not an ongoing line of inquiry during the nine-month hearing process. We note that for five years, 2013 through 2018, the SBPF conducted and submitted quarterly shoreline surveys and during that time the surveys did not reveal any adverse effect to adjacent beaches. The results of those surveys show significant variability in the shoreline with some periods exhibiting accretion and other periods exhibiting erosion. One of the conclusions from the 79th survey, reads as follows: “… Although there is substantial variability, no post-geotube changes have yet been observed that deviate substantially from past observations. The present shoreline is at a similar location as ~10 years ago at many profiles.” The results of the 79th survey show that the shoreline is about where it was approximately 8 to 10 years ago in many locations, see Figures 6 through 12 which includes the geotube area and the shoreline some 1,200 feet to the south (Profile 90 – Figure 6) and some 1,050 feet to the north (Profile 93 – Figure 12). We acknowledge that two quarterly surveys were not submitted. The Commissioners may recall that Josh Posner with SBPF suffered a serious illness this past winter / spring, and his illness contributed to scheduling delays and missed surveys. We provide this information as context, and we regret having not formally notified you of the missed surveys or requested as a separate action to change the survey monitoring frequency. After the Order of Conditions was issued in June 2019, the Quarter 3 survey was scheduled and completed as quickly as the contractor could schedule it. The report was submitted to the Commission as the 79th Survey. The Quarter 4 survey is scheduled. SBPF will continue with the quarterly monitoring going forward in time until such time as the DEP issues a Superseding Order which we trust will allow for a reduced frequency or the Commission issues an Amended Order. Please consider this letter a formal request to change the required survey monitoring frequency from quarterly to twice per year. This topic of reduced shoreline monitoring frequency has been discussed over the past several years. Reduced frequency has been proposed in all annual reports and the Commission’s peer reviewer, Mr. Greg Berman, commented on this request in his review dated April 17, 2017: Mr. Jeff Carlson 3 Nantucket Conservation Commission October 31, 2019 “2.3 Shoreline Monitoring – The requested reduction to 2 profiles per year is reasonable based on the collected data so far as well as more consistent with MassDEP guidance. However the MassDEP guidance is based on strictly nourishment projects, not necessarily projects with a CES that needs to be monitored to ensure no negative impacts.” Semi-annual monitoring is consistent with the monitoring protocol in the MassDEP Beach Nourishment Best Practices Guide (MassDEP, 2007), which suggest seasonal surveys for a year or so, followed by annual surveys for monitoring beach nourishment projects. The National Research Council also recommends a similar approach to beach profile monitoring, which suggests reducing the frequency of surveys over time (National Academy Press, 1995). The established logic behind these common shoreline monitoring frequency standards is that natural short-term volatility of shoreline location and volume is such that no statistically valid conclusions regarding sustained changes in shoreline behavior can be drawn from observations less than 6-12 months apart. To be consistent with standard engineering practice, which typically is focused on capturing an eroded “winter” profile along with a recovered “summer” profile after more quiescent periods, if there will be two surveys per year, one survey is proposed for late winter / early spring and the other is proposed in late summer. The SBPF also has consistently conducted post-storm inspections and provided that information along with the documentation of post-storm maintenance to the Commission on a timely basis. In closing, the SBPF is again on track to conduct quarterly monitoring going forward until such time as the issuing authorities allow a reduced frequency of semi-annual shoreline monitoring. Sincerely, EPSILON ASSOCIATES, INC. Dwight R. Dunk, LPD, PWS, BCES Principal cc: J. Posner, SBPF S. Cohen, Cohen & Cohen law, PC G. Wood, Rubin and Rudman, LLC N. Corcoran, DER-SERO