HomeMy WebLinkAbout27 SE48_3115 SBPF Response to Quidnet Squam HOwners 2_11_19
PRINCIPALS
Theodore A Barten, PE
Margaret B Briggs
Dale T Raczynski, PE
Cindy Schlessinger
Lester B Smith, Jr
Robert D O’Neal, CCM, INCE
Andrew D Magee
Michael D Howard, PWS
Douglas J Kelleher
AJ Jablonowski, PE
Stephen H Slocomb, PE
David E Hewett, LEED AP
Dwight R Dunk, LPD
David C Klinch, PWS, PMP
Maria B Hartnett
ASSOCIATES
Richard M Lampeter, INCE
Geoff Starsiak, LEED AP BD+C
Marc Bergeron, PWS, CWS
3 Mill & Main Place, Suite 250
Maynard, MA 01754
www.epsilonassociates.com
978 897 7100
FAX 978 897 0099
21597/2018/Expanded Project/NOI/Public Hearing Comments
March 1, 2019
Nantucket Conservation Commission Via Electronic Mail and U.S. Mail
2 Bathing Beach Road
Nantucket, MA 02554
Subject: Response to Comments from Quidnet Squam Association comments
dated February 11, 2019 on the Expanded Baxter Road and Sconset
Bluff Storm Damage Prevention Project (DEP File No. SE 48-3115)
Dear Commission Members:
On behalf of the Siasconset Beach Preservation Fund (“SBPF”), Epsilon Associates,
Inc. (“Epsilon”) submits response to comments submitted by the Quidnet Squam
Association in two separate letters, one was submitted by the Quidnet Squam
Association Board and the other was submitted by Peter and Maria Kellner. Both
letters addressed the same issues to which responses are proved below.
1. The project adversely affect public rights to the beach.
To ensure public rights are adequately protected, the SBPF will need to secure a
License from the Town of Nantucket to use a portion of the beach for the Expanded
Project. When granting a License the Town considers public rights to the beach
along with other public benefits provided by the proposed use. This issue will be
addressed through the Licensing process.
2. The project has been shown to cause downdrift damage and erosion.
During the Winter of 2018-2019 the barrier to Sesachacha Pond was
breached and the Polpis Road was damaged.
This assertion is not supported by shoreline monitoring data. See responses
submitted to the Commission on 02 November 2018, 30 November 2018 and 04
January 2019, as well as the presentations on 05 November 2018 which addressed
erosion rates. There is no evidence of accelerated erosion post-geotube
construction that exceed historic observations.
3. The Town is working on a Coastal Resiliency Plan to set priorities in
response climate change. Sconset and the area below the Sankaty Bluff are
not a priority.
The Sconset Coastal Bank has been eroding for decades and the SBPF has been
evaluating and pursuing various methods, in theory and in practice, to stabilize this
Nantucket Conservation Commission 2
Re: DEP File No. SE 48-3115
March 1, 2019
Coastal Bank. See the Nantucket Conservation Commission presentation made at
the 01 October 2018 Public Hearing during which stabilization alternatives and the
project permitting history were presented. Advancing an island-wide resiliency plan
does not preclude property owners or the Town from advancing projects to protect
dwellings and public infrastructure from erosion, respectively, during the planning
process.
4. The SBPF have not been candid about their compliance with existing permit
requirements.
The SBPF documented compliance with the current Order of Conditions (“OOC”)
during the 01 October 2018 Public Hearing, and in writing with the response to
comments letter dated 02 November 2018.
5. The Association expressed concerns about the financial solvency of the
SBPF and recommend that SBPF provide a bank letter of credit to guarantee
the fulfillment of its financial obligations
Pursuant to OOC Special Condition No. 36 the SBPF maintains an escrow account
to ensure funds are available to remove the geotubes should that be necessary.
We believe the responses provided herein as well as the rest of the record for this
matter (DEP File No. SE48-3115) adequately addresses the concerns of the Quidnet
Squam Association.
Sincerely,
EPSILON ASSOCIATES, INC.
Dwight R. Dunk, LPD, PWS, BCES
Principal
cc: MassDEP-SERO
J. Posner, SBPF
A. Gasbarro, Nantucket Eng. & Survey
S. Cohen, Cohen & Cohen Law, PC
G. Wood, Ruben and Rudman, LLP
G. Thomson, W.F. Baird & Assoc.
L. Smith, Epsilon
R. Hamilton, Woods Hole Group