HomeMy WebLinkAbout37 SE48_3115 NCC comments G Berman Report 03_06_19
TO:
Nantucket
Conservation
Committee
FROM:
Maureen
Phillips
for
the
Nantucket
Coastal
Conservancy
Team
RE:
The
2018
Independent
Expert
Review,
Greg
Berman,
February
1,
2019
DATE:
March
6,
2019
We
read
this
latest
report
from
Mr.
Berman
with
great
interest,
as
it
is
the
first
report
since
any
major
storms
have
impacted
the
area
of
the
SBPF
project.
We
believe
this
review,
as
well
as
the
2016
and
2017
reviews,
confirm
our
continued
position,
and
the
Commission’s
earlier
findings,
that
the
project
will
have
harmful
impacts
on
the
resources
protected
by
the
law
and,
therefore,
that
reasonable
alternatives
are
the
best
—
and
only
—
solution
to
the
concerns
about
environmental
harm
(both
to
the
immediate
and
downdrift
areas),
public
safety,
public
access
to
a
public
beach,
and
more.
Because
Mr.
Berman
was
requested
to
limit
this
review
“on
the
observed
and
potential
impacts
to
coastal
processes
of
the
existing
and
proposed
geotube
array,”
our
comments
will
also
generally
be
so
limited.
Our
previous
position
regarding
the
necessity
of
considering
reasonable
alternatives
stands.
We
believe
the
following
to
be
a
fair
distillation
of
Mr.
Berman’s
summary
of
particular
threshold
issues:
• The
SBPF
projects
will
never
be
in
stasis;
the
environment
is
too
dynamic.
• Extension
of
the
returns
will
be
required
repeatedly
in
a
losing
battle
to
prevent
end
scour.
• Therefore,
the
adjacent
beaches
are
suffering
and
will
continue
to
suffer.
• It
is
not
feasible
to
artificially
provide
the
amount
of
beach
nourishment
that
will
be
necessary
to
prevent
the
need
for
such
extensions.
• Extending
the
project
fourfold
would
accelerate
the
destruction
of
the
returns
and
the
scouring
process
because
of
the
greater
reduction
of
natural
sand
replenishment
caused
by
the
longer
project.
We
have
highlighted
sections
of
Mr.
Berman’s
Report,
dated
February
1,
2019,
below
that
deserve
special
attention:
all
emphases
[bold]
are
ours,
and
NCC
comments
are
so
labeled.
Berman
Report,
February
1,
2019,
page
2:
During
lower
wave
energy
the
geotubes
stay
covered
with
sand
and
have
minimal
negative
interaction
with
coastal
processes.
During
even
minor
storm
events
portions
of
the
geotubes
Maureen
Phillips/NCC
Comment
to
ConCom
2
are
exposed,
and
are
likely
reflecting
wave
energy
in
a
similar
way
to
a
Coastal
Engineering
Structure
(CES)
during
this
period.
Due
to
the
scale
of
this
project
(947’
length)
there
is
a
high
potential
for
currents
to
set
up
parallel
to
the
smooth
exposed
geotube
during
storm
conditions,
which
can
rapidly
scour
the
end
of
the
array.
Erosion
doesn't
stop
in
areas
adjacent
to
a
shoreline
stabilization
project
and
“holding
the
line”
can
become
more
and
more
difficult
over
time.
An
analysis
on
the
useable
lifespan
of
the
upland
properties
and
eventual
retreat
(or
abandonment)
of
the
array
might
be
helpful.
NCC
Comment:
The
Town
should
be
thinking
about
retreat
and
abandonment,
not
long-‐term
maintenance.
The
adverse
impacts
of
this
project
would
increase
substantially
if
the
project
were
extended
to
almost
4,000
feet.
Berman
Report,
February
1,
2019,
page
3:
While
the
erosion
rates
along
this
shoreline
can
be
highly
variable,
it
is
highly
likely
that
much
of
the
beach
sediment
at
the
site
has
come
from
updrift
areas,
as
opposed
to
the
site.
There
is
a
very
large
natural
volume
of
sand
moving
along
this
stretch
of
shoreline
which
helps
preserve
the
width
of
downdrift
beaches
and
dunes.
However,
even
with
this
natural
volume
and
the
artificially
placed
sediment
nourishment,
sand
cover
on
all
portions
of
the
geotube
array
appears
to
have
been
difficult
to
maintain.
[See
also,
page
5
infra.]
NCC
Comment:
Uncovered
geotubes
act
as
a
coastal
engineering
structure
(CES).
(Photo
below
taken
by
Susan
Landmann
in
March
2018.)
Maureen
Phillips/NCC
Comment
to
ConCom
3
(Berman
Report,
February
2019,
page
3
continued.)
Most
important
would
be
finding
the
“right”
compensatory
nourishment
volume
and
requiring
that
volume
be
put
down
every
year
as
a
minimum.
Then
more
sand
may
be
needed
if
filling
the
sand
template
requires
more
than
that
minimum
volume.
Ex.
8.8cy/lf/yr
as
a
minimum
to
be
placed
each
year
and
22
cy/lf/yr
as
a
minimum
template
volume
to
maintain.
Whatever
volumes
are
decided,
they
may
need
to
be
adjusted
based
on
how
often
the
geotubes
get
exposed.
NCC:
How
much
sand
is
the
Town
willing
to
have
delivered
over
existing
streets?
How
often
does
this
beach
become
a
construction
site?
Berman
Report,
February
1,
2019,
page
4:
(N)ow
data
is
available
with
the
geotube
array
experiencing
several
larger
storms
[that
occurred
in
winter
and
spring
of
2018].
While
the
array
has
not
experienced
a
tropical
storm
(i.e.
hurricane)
of
significance,
some
recent
winter
events
would
qualify
as
“testing”
the
array.
The
initial
geotube
array
was
installed
12/2013-‐1/2014.
Since
that
time
5
of
the
top
10
water
levels
have
been
observed
at
the
Nantucket
Tide
Gauge,
since
measurements
began
in
1965.
NCC
comments:
Sea
level
rise
predictions
argue
this
trend
will
continue.1
Berman
Report,
February
1,
2019,
page
7:
While
maintaining
a
beach
in
front
of
a
Coastal
Engineering
Structure
is
theoretically
possible,
at
some
time
in
the
future
(likely
tens
of
years,
not
hundreds)
it
will
not
be
feasible.
As
was
previously
mentioned,
the
proposed
project
would
be
about
7%
of
the
mostly
unarmored
eastern
shoreline
of
Nantucket
and
much
of
the
beach
sediment
in
this
area
has
likely
come
from
updrift
areas,
as
opposed
to
being
placed
at
the
site.
If
a
geotube
expansion
is
approved
erosion
will
continue
in
adjacent
areas,
as
is
occurring
now
with
the
current
extent
of
the
geotube
array.
NCC
Comment:
Erosion
is
happening
now
on
the
adjacent
beaches
and
will
continue.
According
to
testimony
submitted
by
the
Nantucket
Land
Council
consultants,
Applied
Coastal,
November
30,
2018:
“Erosion
rates
across
the
entire
proposed
project
reach
have
increased
since
the
geotextile
revetment
was
constructed.
The
increase
in
erosion
rates
associated
with
the
current
project
and
the
proposed
project
will
further
jeopardize
SBPF’s
neighbors
to
the
north
and
1
“Sea
Level
Rise
-‐
Climate
Science
Special
Report,”
https://science2017.globalchange.gov/chapter/12/
Maureen
Phillips/NCC
Comment
to
ConCom
4
south.
A
properly
designed
shoreline
stabilization
project
using
best-‐available
measures
should
not
transfer
the
burden
of
losing
a
home
or
property
from
project
location
to
the
neighboring
properties”.
[Page
2.]
Berman
Report,
February
1,
2019,
Page
7.
With
erosion
continuing
to
occur
(or
made
worse)
at
the
end
of
the
structure,
properties
adjacent
to
the
structure
will
often
request
an
extension
of
the
CES
to
cover
their
property
(aka
“chasing
erosion”).
The
geotube
array
has
been
designed
with
returns
so
that
it
is
not
compromised
by
scour.
One
of
the
dangers
of
“holding
the
line”
with
a
CES
is
that
the
array
will
artificially
protrude
further
seaward
than
the
rest
of
the
shoreline.
Flanking
may
occur
if
adjacent
properties
continue
to
erode
naturally,
while
the
project
site
maintains
a
shoreline
position
further
seaward
to
protect
the
homes.
NCC
Comment:
The
SBPF
project
was
designed
with
returns
(extensions
on
each
end)
which
were
to
protect
the
adjoining
properties
from
being
scoured
(damaged
by
excessive
wave
energy
caused
by
the
geotubes).
Unfortunately,
this
technique
has
not
succeeded
with
this
project,
and
repairs
to
the
extensions
for
the
original
project
were
needed
after
the
FIRST
season
of
significant
storms.2
In
this
extremely
dynamic
local
environment,
combined
with
ever-‐worsening
storm,
tide
and
sea-‐level
rise
conditions
due
to
global
warming,
scouring/flanking
appears
to
be
inevitable.
Extending
the
project
would
extend
the
damage,
as
there
does
not
appear
to
be
any
chance
that
the
local
environment
will
“calm
down,”
nor
that
the
multiple
destructive
impacts
of
global
warming
will
disappear.
The
above
image
an
example
from
Hardings
Beach,
in
Chatham,
of
an
armored
property
(CES)
that
was
allowed
to
exist
further
seaward
than
the
rest
of
the
shoreline
properties.
This
configuration
has
major
implications
for
wave
energy
and
sediment
transport,
as
well
as
a
lack
of
“walkable
beach”
at
high
tides.
Wave
reflection
can
exacerbate
erosion
on
the
2
In
September
2018,
SBPF
applied
for
an
Amended
Order
of
Conditions
to
address
end-‐scour
issues.
The
request
stated
that
50-‐foot
extensions
were
required
at
either
end
of
the
geotube
revetment
“to
preserve
the
integrity
of
the
geotube
system
and
to
avoid
continued
erosion
at
the
ends.”
[Emphasis
added.]
See
page
2,
https://nantucket-‐ma.gov/DocumentCenter/View/23137/Amended-‐Order-‐of-‐Conditions-‐Request-‐SBPF-‐-‐87_105-‐
Baxter-‐Road-‐48_Various-‐SE48_2824?bidId=
Maureen
Phillips/NCC
Comment
to
ConCom
5
adjacent
beach
and
the
property
may
affect
sediment
transport
parallel
to
shore
(similar
to
a
groin).
While
this
type
of
setting
is
different
from
Baxter
Road,
it
is
provided
to
illustrate
the
potential
ramifications
of
“holding
the
line”
for
too
long.
NCC
FINAL
COMMENTS
Many
times
over
the
years,
we
have
provided
data
and
comments
about
various
aspects
of
the
Baxter
Road
project.
It
is
unfortunate
that
SBPF
appears
to
dismiss
these
comments
cavalierly
without
providing
any
factual
or
scientific
basis
for
dismissing
them.
Mr.
Berman’s
independent
report
supports
the
views
we
have
expressed
in
the
past,
as
demonstrated
in
the
analysis
provided
in
this
memorandum.
The
applicant
(SBPF)
has
the
burden
of
proving
that
it
satisfies
regulatory
standards,
and
challenges
to
the
accuracy
or
scientific
basis
of
its
assertions
by
others
should
not
be
waved
aside
without
exploration.
Of
course,
the
issues
are
often
highly
complex,
requiring
scientific
knowledge
to
evaluate.
Mr.
Berman’s
has
such
knowledge,
and
his
independent
report
supports
our
comments
in
this
letter.
We
have
always
believed
that
the
threshold
issues
are:
1.
whether
this
project
is/will
be
destructive
of
the
environment
in
a
way
that
violates
legal
protections,
and,
for
the
second
2.
whether
feasible
alternatives
exist.
The
answer
to
these
questions
in
both
cases
is
“Yes.”
We
find
Mr.
Berman’s
report
unequivocal
about
the
first
issue,
and,
for
the
second,
we
have
provided
extensive
materials
regarding
development
of
alternatives
in
the
past.
For
ease
of
review,
we
will
provide
a
summary
in
a
separate
document.
We
are
also
deeply
concerned
about
the
changing
representations
made
by
the
SBPF
on
numerous
crucial
issues.
We
believe
that
the
Conservation
Commission
needs
to
be
especially
vigilant
in
its
review
of
pertinent
evidence
to
be
sure
that
it
considers
the
actual,
primary
evidence
provided
by
scientific
experts,
particularly
those,
such
as
Mr.
Berman,
who
offer
candid
peer-‐review
assessments.
The
Conservation
Commission
needs
to
be
particularly
careful
in
assessing
this
primary
evidence,
rather
than
relying
on
SBPF’s
re-‐characterization
of
the
evidence
supplied
by
others.
The
purpose
of
neutral
peer-‐review
analysis
is
to
provide
the
Conservation
Commission
with
reliable
evidence
that
is
not
slanted
to
serve
proponents’
views.
The
Conservation
Commission
should
also
look
closely
to
determine
whether
the
proponents
of
the
project
have
taken
inconsistent
positions
on
crucial
matters,
since
inconsistencies
expose
areas
where
assertions
may
be
questionable
and
should
not
be
taken
at
face
value.
Maureen
Phillips/NCC
Comment
to
ConCom
6
Again,
we
ask
that
you
deny
the
application
for
the
extended
project.
Maureen
Phillips
for
NCC
Coordinating
Team
Elin
Anderwald,
Rick
Atherton,
Burton
Balkind,
Joyce
Berruet,
Peter
Brace,
Barbara
Bund,
Sunny
Daily,
Susan
Landmann,
Susan
McFarland,
Catherine
Nickerson,
Maureen
Phillips,
Linda
Spery,
Liz
Trillos,
Mary
Wawro,
Karen
Werner,
and
D.
Anne
Atherton