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HomeMy WebLinkAboutSE48_2824 Hill Law on behalf of Greenhills 2019 Annual review comments6 Beacon Street, Suite 600 Boston, MA 02118 p:617-494-8300 f: 617-307-9010 Dennis A. Murphy dgusmurphy@gmail.com 781-588-7881 March 11, 2021 VIA EMAIL: jdodd@nantucket-ma.gov & Jcarlson@nantucket-ma.gov Nantucket Conservation Commission 2 Bathing Beach Rd. Nantucket, MA 02554 Re: Siasconset Beach Preservation Fund (“SBPF”) 2019 annual review (SE48-2824) Dear Commissioners: This firm represents Robert Greenhill, 8 & 16 Hoicks Hollow Road, Nantucket, whose property includes nearly three quarters of a mile along ‘Sconset Bluff between Sankaty Head and Sesachacha Pond. For reference, in the Woods Hole Group Survey, the Greenhill property extends from profiles 96 to 97. We write to accept the Commission’s invitation to comment at the upcoming public hearing on this matter scheduled for March 22, 2021. It has been over a year since SBPF’s consultant submitted the 2019 annual report (Epsilon 3/2/2020) required by the Order of Conditions (“OOC”) for the geotube project. Given the long lag time, it might be helpful to make the 2020 annual report publicly available, or even the most recent information if the full report is not yet complete, to see if the latest data is consistent with the trends noted in the 2019 annual review. The negative effects from the deficit in sand mitigation – in violation of the OOC – are readily observable from the Greenhill property. The Commission’s own peer review expert, Greg Berman of Woods Hole, concluded that SBPF’s failure to adhere to the sand nourishment required by the OCC may lead to erosion at downdrift properties like the Greenhill’s: Exposure of the geotube array for extended periods due to the lack of sand will likely result in negative effects. Additionally, if there are direct observations of increased erosion downdrift of the geotube array, then a portion of that erosion may be due to the reduction in volume provided by the project. (Berman 12/8/20, p . 7) Mr. Greenhill first raised concerns about this project to the Commission over five and a half years ago in September 2015. Unfortunately, those concerns seem to have come to fruition. As a result, we have retained our own coastal ocean engineer, Dave Kriebel, PE, 6 Beacon Street, Suite 600 Boston, MA 02118 p:617-494-8300 f: 617-307-9010 of Coastal Analytics LLC. (CV attached) Dr. Kriebel, a recently retired Professor in the Ocean Engineering Program at the United States Naval Academy, has reviewed the 2019 Annual report, Mr. Berman’s peer review, and Epsilon’s response, and will be available to share his review and analysis with the Commission on March 22. A copy of his preliminary comments dated today are enclosed. We look forward to discussing the matter with the Commission at the upcoming hearing. Very truly yours, /s/ Dennis A. Murphy Dennis A. Murphy Enlc. 1 DAVID L. KRIEBEL, Ph.D., P.E. DLKriebel@gmail.com 410-703-5146 EXPERTISE Coastal and Ocean Engineering, including ocean waves, wave forces, wave-structure interaction, sediment transport and erosion processes, marine soil mechanics and foundations, sea level rise and coastal flooding, tsunamis and coastal hazards; naval architecture, including ship generated waves, effects of passing vessels, vessel berthing and mooring, and response of floating structures. EDUCATION Doctor of Philosophy, Coastal and Ocean Engineering, University of Florida, 1987 Master of Civil Engineering, University of Delaware, 1982 Bachelor of Science, Civil Engineering, Pennsylvania State University, 1980 EXPERIENCE Ocean Engineering Program, United States Naval Academy, Annapolis, Maryland Professor, 1996-present, Associate Professor, 1992-1996, Assistant Professor, 1987-1992 Adviser to Superintendent as co-Chair, Sea Level Rise Advisory Council, 2015-present. Development of strategy for institutional adaptation to future sea level rise, technical liaison with City of Annapolis, State of Maryland, and Army Corps of Engineers and other federal agencies on sea level rise adaptation. Department Chair, Naval Architecture and Ocean Engineering Department, May 2012-2016. Responsible for administration of 20 member academic department. Director, Ocean Engineering Program, 2000-2009. Responsible for curriculum, facilities, student recruiting, assessment, and faculty development in ocean engineering. Director, Hydromechanics Laboratory, 1996-2002. Responsible for budgeting, personnel, and facilities for major wave/towing tank laboratory. Scientific Director responsible for technical studies and reports. Teaching in areas of coastal engineering, ocean wave mechanics, random wave analysis, wave loading, offshore structural analysis, marine soil mechanics and foundations, marine environmental engineering, naval architecture, and ocean engineering capstone design. Research for National Science Foundation, Office of Naval Research, Naval Facilities Engineering Command, Army Corps of Engineers, and US Coast Guard. Other service activities: Chair of Naval Academy Curriculum Committee, Member Promotion and Tenure Committee, Member Institutional Research Committee, Faculty Senate Representative and member of Faculty Senate Executive Committee, and Senior Academic Adviser for Ocean Engineering 2 Coastal Analytics LLC, Millersville, MD President, 1987-present. Consultant in Coastal and Ocean Engineering. Selected projects: Independent coastal engineering consultant, Town of Jupiter Island, FL, 2013-present. Develop of Flood-Load Provisions for National Building Code of Canada, subcontractor to Coulbourne Consulting, Annapolis, MD Wind-wave analysis for design of breakwater for Palmer Station, Antarctica, subcontractor to R&M Consulting Engineers, Anchorage, AK, 2019 Review of coastal storm tides and flooding for Shaktoolik, AK, for Kawarek, Inc. Subcontractor to McKnight and Assoc., 2019. Lead instructor, SAGE Short Course on Coastal Resiliency, Boston, MA, 2018 Scientific Resolution Panel, National Institute of Building Sciences, served on committee to resolve dispute over FEMA flood insurance map, San Bruno, CA, 2018 Preliminary design of terminal groin for retention of beach fill, Holgate, NJ, 2018 Expert witness, Barge breakaway due to wake wash, Mississippi River, 2018 Scientific Resolution Panel, National Institute of Building Sciences, served as Chair of committee to resolve dispute over FEMA flood insurance map, Rye, NH, 2017 Engineering forensic investigation of floating breakwater failure during storm, Ashland, WI, for Norther States Power/Xcel Energy, 2016. Wind-wave analysis for design of breakwater for Seward Marine Industrial Center, Seward, AK, subcontractor to R&M Consulting Engineers, Anchorage, AK, 2014-2016. Engineering forensic investigation of ship allision with cooling water intake structure, RockTenn Corp., Hopewell, VA, 2014 Expert witness from 2008-2013 for Apache Corporation analyzing extreme waves and wave crest elevations in case involving jack-up rig failure in 2005 in Hurricane Rita. Independent Technical Review, Unalaska Floating Breakwater, for US Army Corps of Engineers, Unalaska, AK, 2009 Expert witness for floating dock failure and marina impacts, Anchorage, AK, 2008 Peer-review of Dredge Material Management Plan, Calcasieu River and Pass, Louisiana, for Battelle Memorial Institute, 2008 Expert witness for State Farm Insurance Company, Hurricane Katrina cases involving homeowners insurance claims and flood/wave effects, 2007-2009 Expert witness involved in court-supervised mediation regarding relocation of revetment, Annapolis, MD, 2006 3 Investigation of beach profile variability for storm water outfall design, Virginia Beach, VA, URS Corporation, 2006 Third-party review of marina failure and proposed floating breakwater, Cliffside Marina, Whittier, AK, 2006 Expert witness on ship generated waves and shoreline impacts, Marlborough District Council, Blenheim, New Zealand, 2005 Peer review of “Recommended Residential Construction for the Gulf Coast,” FEMA 550, for URS Corporation, 2006. Expert witness, investigation of storm water outfall failure, Virginia Beach, VA, for Greeley and Hansen, 2004 Independent investigation of coastal erosion impact of Canaveral Harbor on Brevard County beaches, for Secretary of the Army, 2001-2002. Investigation of debris impact loads during floods, for American Society of Civil Engineers and the Federal Emergency Management Agency, 1999-2000. Peer review of FEMA’s “Coastal Construction Manual,” for Greenhorne and O’Mara, 1997. Development of partial safety factors for flood loads on coastal buildings, for American Society of Civil Engineers and Federal Emergency Management Agency, 1996-1997. Independent review of Beachfront Management Program, for South Carolina Department of Health and Environmental Control, 1995. Development of Northeaster Risk Index, for Delaware Emergency Management Agency and Delaware Department of Natural Resources and Environmental Control, 1995. Peer review of methodology used to establish Coastal Construction Control Line, for Florida Department of Environmental Protection, 1994. Independent review of Barrow Beach Nourishment Project, for North Slope Borough Science Advisory Board, Barrow, Alaska, 1994. Developer of EDUNE numerical model for simulating beach and dune erosion associated with hurricanes and northeasters. Numerical model widely used in state agencies and private engineering firms for evaluating erosion hazards due to hurricanes. Army Corps of Engineers, Anchorage, Alaska Coastal/Hydraulic Engineer, 1982-1983 Project engineer for feasibility studies of small-boat harbors at Kodiak, Whittier, and Hydaburg. Engineering analysis for St. Paul Island breakwater, Dillingham harbor closure structure, False Pass channel improvement, and environmental permit for Port of Nome. Field installation, equipment procurement, and analysis of wind and wave data for Alaska Coastal Data Collection Program. 4 AWARDS Bob Dean Coastal Scholar Award, American Shore and Beach Preservation Association, 2015. U.S. Naval Academy, Civilian Faculty Teaching Award, 2004 Presidential Young Investigator Award, National Science Foundation, 1991-1996 PROFESSIONAL REGISTRATION Registered Professional Engineer, Alaska, #12567 Registered Professional Engineer, Virginia, #024354 Certified Coastal Engineer, Diplomate of Academy of Coastal, Ocean, Port, and Navigation Engineers, 2010. PROFESSIONAL ACTIVITIES President, Coasts, Oceans, Ports, and Rivers Institute (COPRI) of the American Society of Civil Engineers, 2008-2009, also member of Board of Directors 2005-2010. Member, Coastal Engineering Research Board, May 2012-2016, appointed by Secretary of Army to serve as one of three civilian advisors to U.S. Army Corps of Engineers to direct the Corps’ research and development activities in coastal engineering. Voting Member, ASCE-7 Committee on Minimum Design Loads for Buildings and Other Structures, American Society of Civil Engineers Structural Engineering Institute, 2018-present. Member, ASCE 7 Committee on Tsunami Loads and Effects, American Society of Civil Engineers, 2011-present Member, ASCE-7 Committee on Flood Loads, American Society of Civil Engineers, 2018-present Post-Tsunami Engineering Investigation, Tohoku Region, Japan, American Society of Civil Engineers, 2011. Post-Tsunami Engineering Investigation, Phuket, Thailand, American Society of Civil Engineers, 2005 Board of Directors, Association of Coastal Engineers, 2004-2006 U.S. Representative, International Standards Organization (ISO) Working Group on Structural Design for Waves and Currents, 2002-2004. U.S. Representative, International Towing Tank Conference, Committee on Environmental Modeling, 1996-2000 Editorial Board, ASCE Journal of Waterway, Port, Coastal and Ocean Engineering, 1989-1994 5 PUBLICATIONS Judge, P.K., Buxton, J.A., Sheahan, T.C., Phetteplace, E.R., Kriebel, D.L., & Hamin, E.M, “Teaching across disciplines: a case study of a project-based short course to teach holistic coastal adaptation design.” Journal of Environmental Studies and Science, 10, 341–351 (2020). Bain, D.M., Underwood, S., Laczo, T., Dowling, M., and Kriebel. D.L, 2018, “Rapid Coastal Adaptation Assessment at City of Annapolis,” Proc. International Conf. on Coastal Engineering, ASCE. Kriebel, D, Lynett, P., Cox, D., Petroff, C., Robertson, I., and Chock, G., 2017, “Energy Method for Approximating Overland Tsunami Flows,” Journal of Waterway, Port, Coastal, and Ocean Engineering, Vol 143, No 5. Kriebel, D, and Kloster, R., 2017, “Sediment Budget for Port of Nome, Alaska,” US Army Corps of Engineers, Alaska District. Tran, R. M. and Kriebel, D.L., 2016, “Evaluation of Shallow Water Wave Forces on Vertical Walls,” Proceedings of Coastal Structures and Solutions to Coastal Disasters Conference, American Society of Civil Engineers. Kriebel, D.L, Geiman, J.D, and Henderson G.R., 2015, “Future Flood Frequency under Sea-Level Rise Scenarios.” Journal of Coastal Research: Volume 31, Issue 5: pp. 1078 – 1083. Kriebel, D.L, and Geiman, J.D., 2014, “A Coastal Flood Stage to Define Existing and Future Sea-Level Hazards.” Journal of Coastal Research: Volume 30, Issue 5: pp. 1017 – 1024. Chock, G, Robertson, I., Kriebel, D., Frances, M., and Nistor, I., 2013, “Tohoku Japan Tsunami of March 11, 2011 Performance of Structures,” Structural Engineering Institute, ASCE. Kriebel, D.L., 2011, “The Need for a Tidal Flood Stage to Define Existing and Future Sea Level Hazards,” Proc. Solutions to Coastal Disasters Conf., Anchorage, AK Fredriksson, DW; Steppe, CN; Wallendorf, L; Sweeney, S; Kriebel, D., 2010, “Biological and hydrodynamic design considerations for vertically oriented oyster grow out structures,” Journal of Aquacultural Engineering, Vol 42, No 2, pp. 57-69. Kriebel, D., 2010, “Mooring Loads due to Perpendicular Passing Ships, ASCE Ports 2010 Conference, Jacksonville, FL, April 2010. Kriebel, D., 2008, “Probabilistic Performance of Beach Fill,” Proc. International Conference on Coastal Engineering, Hamburg, Germany, Sept 2008. Kriebel, D, 2007, “Oblique Wave Interaction with Wave Screens and Wave Barriers,” Coastal Structures 2007, Venice, Italy, July 2007. Kriebel, D., and Seelig, W., 2007, “Mooring Loads due to Parallel Passing Ships, ASCE Ports 2007 Conference, San Diego, March 2007. Kriebel, D., 2006, “Laboratory Tests of Mooring Loads due to Passing Vessels, Prevention First 2006 Conf., California State Lands Commission, Long Beach, Sept 2006. 6 Hughes. S., Kriebel, D., Winer, H., Bodgett, E. and Seabergh, W., “Laboratory Measurements of Wave Forces on Heavily Overtopped Vertical Wall,” International Conf. on Coastal Engineering, San Diego, Sept 2006. Dalrymple, R., and Kriebel, D., 2005, “The Engineering Impact of the Tsunami in Thailand,” The Bridge, Journal of the National Academy of Engineering, Vol. 35, No. 2, Wash., D.C. Kriebel, D. and Dalrymple, R., 2005, “The Impact of the 26 Dec 2004 Tsunami on Coastal Infrastructure in Thailand,” in report by the Task Committee on Lifelines in Earthquake Engineering, EERI, American Society of Civil Engineers. Torum, A., Goda, Y., Burcharth, H., Kortenhaus, A., and Kriebel, D., 2005, “Wave and Current Forces,” Report of Working Group, International Standards Organization. Kriebel, D., 2005, “An Empirical Model for Ship Generated Waves,” Waves 2005 Conference, Madrid, submitted. Kriebel, D., 2005, “A Design Method for Timber Wave Screens,” Proc. 29th Intl. Conf. on Coastal Engineering, Lisbon, in press Kriebel, D., 2004, “Design Guidelines for Timber Wave Screens,” U.S. Naval Academy Engineering Report EW-1-04, July 2004. Smith, W.G. and Kriebel, D., 2004, “Design of Timber Wave Screens,” Proceedings of Ports ’04 Conference, American Society of Civil Engineers, May 2004. Kriebel, D., Weggel, J.R., and Dalrymple, R.A., 2003, “Independent Coastal Engineering Study of Canaveral Harbor and the Brevard County Shore Protection Project,” Proc. National Conference on Beach Preservation Technology, Feb 2003. Judge, C. and Kriebel, D., 2002, Shallow Water Tow Tests to Investigate Rise, Trim, Squat, and Wave Elevation, US Naval Academy, Division of Engineering and Weapons Technical Report EW-03-02, 26 August 2002. Kriebel, D., Seelig, W., Judge, C. 2003, “Development of a Unified Description of Ship-Generated Waves.” In Proceedings of the U.S. Section PIANC Annual Meeting, Roundtable, and Technical Workshops (CD-ROM), PIANC USA, Alexandria, VA, USA. Waters, J., Mayer, R., and Kriebel, D., 2003, “Dredging-Related Impacts of Current and Future Trends in the International Shipping Industry,” Proc. 3rd Conf. Dredging and Dredged Material Disposal, Orlando Kriebel, D., and Seelig, W, 2002, “A unified description of ship-generated waves,” Proc Intl. Conf on Coastal Engineering, Cardiff, Wales, ASCE. Kriebel, D. and Wallendorf, L., 2001, “Air Gap Model Tests on a MOB Module,” Proc. 10th Intl. Conf. on Offshore and Polar Engineering, Stavanger, Norway, June 2001. Kriebel, D. and Finlayson, W.,2001, “Ocean Engineering Design Experience at the U.S. Naval Academy,” Proc. Oceans 2001 Conference, Honolulu, HI, Nov 2001 7 Kriebel, D., 2001, “Wave Amplification and Air Gap Tests on a MOB Module,” Proc. 24th US-Japan Marine Facilities Panel, US-Japan Cooperative Program in Natural Resources, Honolulu, HI. Kriebel, D., “Breaking Waves in Intermediate Depths with and without Currents,” Proc. 27th Intl Conf on Coastal Engineering, Sydney, Australia, July 2000. Kriebel, D., Buss, L., and Rogers, S., 2000, “Debris Loads During Floods,” report prepared for American Society of Civil Engineers Structural Engineering Institute. Kriebel, D. and Alsina, M., 2000, “Simulation of Extreme Waves in a Background Random Sea,” Proc. of 9th Intl. Conf. On Offshore and Polar Engineering, Seattle, WA. Mayer, R., Waters, J., and Kriebel, D., 2000, “Design & Maintenance of Deep-Draft Navigation Channels - A Comparison of Current Practice with U.S. and International Guidance,” Institute for Water Resources, U.S. Army Corps of Engineers, Alexandria, VA, November 2000. Mayer, R., Waters, J., and Kriebel, D., 2000, “Design & Maintenance of Deep-Draft Navigation Channels - An Overview of Current Practice with an Annotated Bibliography,” Institute for Water Resources, U.S. Army Corps of Engineers, Alexandria, VA, July 2000. Kriebel, D., Berek, E., Chakrabarti, S., and Waters, J., 1999, “Wave-Current Loading on a Shallow Water Caisson: An Evaluation of the API Recommended Practice,” Journal of Waterway, Port, Coastal, and Ocean Engineering, Vol. 125, No. 1, pp. 29-38. Kriebel, D. and Wallendorf, L., 1999, “Physical Model Tests on a Generic MOB Module,” Prof. Conf. On Very large Floating Structures, Honolulu, HI, Sept. 1999 Falzarano, J., Kalyan, U., Rodriguez, W., Vassilev, R., and Kriebel, D., “MOB SBU Transit Draft Dynamics and Stability Analytical Study,” 3rd Intl. Conf. on Very Large Floating Structures,@ Honolulu, 1999, pp. 562-566. Kriebel, D, 1999, “Performance of Vertical Wave Barriers in Random Seas,” Proceeding of Coastal Structures ‘99 Conference, Santander Spain, June 1999 Gilman, J. and Kriebel, D., 1999, “Partial-Depth Pile-Supported Wave Barriers: A Design Procedure,” Proceeding of Coastal Structures ‘99 Conference, Santander Spain, June 1999 Kriebel, D. "Nonlinear Wave Interaction with a Vertical Circular Cylinder: Wave Forces," Journal of Ocean Engineering, Vol. 25, No. 7, 1998, 597-605. Kriebel, D., White, G., Mouring, S., Mehta, K., and Smith, D., 1998, “An Investigation of Load factors for Flood and Combined Wind and Flood,” report prepared for American Society of Civil Engineers Structural Engineering Institute. Kriebel, D., Sollitt, C., and Gerken, W., 1998, “Wave Forces on a Vertical Wave Barrier,” Proc. 26th Intl. Conf. On Coastal Engineering, Copenhagen, June 1998, pp. 2069-2081 Buchmann, B., Skourup, J., and Kriebel, D.,1998, “Second Order Wave Interaction with a Large Structure,” 26th Intl. Conf. on Coastal Engineering, Copenhagen, pp. 1613-1624. 8 Chakrabarti, S. and Kriebel, D., 1997, “Wave Kinematics for Simulated Shallow Water Storm Waves - Analysis and Experiments,”Journal of Ocean Engineering, Vol.24, No. 9, pp. 835-865. Chakrabarti, S, Kriebel, D., and Berek, E., 1997, “Forces on a Single Pile Caisson in Breaking Waves and Current,” Applied Ocean Research, Vol. 19, No. 2, pp. 113-140. Kriebel, D., 1997, “Use of Transient Waves in Wave Barrier Model Testing,” Proceedings of 3rd International Symposium on Ocean Wave Measurement and Analysis, Virginia Beach, VA. Kriebel, D.L, Berek, E.P., Chakrabarti, S.K., and Waters, J.K., 1996, “Wave-Current Loading on a Shallow Water Caisson,” Proceedings of 28th Offshore Technology Conference, Houston, Texas, Paper OTC 8067, May 1996 Kriebel, D. and Bollmann, C., 1996, “Wave Transmission Past a Vertical Wave Barrier,” Proc. 25th Intl. Conf. On Coastal Engineering, Orlando, Sept. 1996 Dawson, T., Kriebel, D., and Wallendorf, L., 1996, “Markov Description of Wave Crest Statistics,” Journal of Offshore Mechanics and Arctic Engineering, Vol. 118, No. 1, pp. 37-45. Kriebel, D., Dalrymple, R., Pratt, A., and Sakovitch, V., 1996, “A Shoreline Risk Index for Northeasters,” National Conference on Natural Disaster Reduction, Washington, D.C., pp. 225-235 Kriebel, D., and Waters, J., 1995, "Model Testing of a Deep Water Compliant Tower," Proceedings Offshore Mechanics and Arctic Engineering Conference, Copenhagen, Kriebel, D., and Waters, J., 1995, "Model Testing of a Deep Water Compliant Tower," Proc. 14th Intl. Offshore Mechanics and Arctic Engineering Conference, Copenhagen, Vol. B, pp. 1-9. Water, J.K., Kriebel, D.L., Johnson, J., Chakrabarti, S.K., and Berek, E.P., 1995, “ Model Tests of Extreme Wave Loading on a Shallow Water Caisson,” Proceedings of American Towing Tank Conference, College Station, Texas Kriebel, D., Dalrymple, R., and Dean, R., 2005, “Evaluation of Ideal Present Profile Methods for Beachfront Management,” project report to South Carolina Department of Health and Environmental Control. Kriebel, D., 1994, "Swash Zone Wave Characteristics from SUPERTANK," 24th Intl. Conf. on Coastal Engineering, Kobe, Japan, pp. 2207-2221. Mayer, R., and Kriebel, D., 1994, "Wave Runup on Composite-Slope and Concave Beaches," 24th Intl. Conf. on Coastal Engineering, Kobe, Japan, pp. 2325-2339. Kriebel, D., and Smith, J., 1994, "Wave Transformation Measurements at SUPERTANK," Coastal Dynamics '94 Conference, Barcelona, pp. 233-247. Kriebel, D., and Dawson. T., 1994, "Evolution of Wave Breaking in Random Seas," Intl. Symposium on Waves - Physical and Numerical Modelling, Vancouver. Cox, D., Kobayashi, N., and Kriebel, D.,1994, "Numerical Model Verification using SUPERTANK Data," Coastal Dynamics '94 Conference, Barcelona, pp. 248-262. 9 Mayer, R., and Kriebel, D., 1994, "Wave Runup on Curvilinear Slopes," Proceedings of Beach Preservation Technology Conference, Tampa, pp. 442-453. Dawson, T., and Kriebel, D., 1994, "Nonlinearity in Crest-Trough Statistics of Bretschneider Seas," 13th Intl. Offshore Mechanics and Arctic Engineering Conference, pp. 27-36. Kriebel, D., and Dawson, T., 1993, "Nonlinearity on Wave Crest Statistics," 2nd Intl. Symp. on Ocean Wave Measurement and Analysis, ASCE, New Orleans, pp. 61-75. Dawson, T., Kriebel, D., and Wallendorf, L., 1993, "Breaking Waves in Laboratory Generated JONSWAP Seas," Journal of Applied Ocean Research, Vol. 15, No. 2, pp.85-94. Kriebel, D.L., 1993, "Nonlinear Runup of Random Waves on a Large Vertical Cylinder," Proceedings 12th Offshore Mechanics and Arctic Engineering Conference, Glasgow, pp. 49-56. Dawson, T., and Kriebel, D., 1993, "Experimental Study of Wave Groups in Ocean Swell," Proceedings 12th Offshore Mechanics and Arctic Engineering Conference, Glasgow, pp. 1-8. Kriebel, D.L and Dean, R.G., 1993, "Convolution Method for Time-Dependent Beach Profile Response," Journal of Waterway, Port, Coastal, and Ocean Engineering, ASCE, Vol. 119, No. 2, pp. 204-226. Kriebel, D.L., 1993, "Vertical Wave Barriers: Wave Transmission and Wave Forces," 23rd Intl. Conf. on Coastal Engineering, Venice, Italy, pp. 1313-1326. Davies, B. and Kriebel, D., 1993, "Model Testing of Wave Transmission Past Reef Breakwaters," 23rd Intl. Conf. on Coastal Engineering, Venice, Italy, pp. 1115-1128. Creed, C., Dalrymple, R., Kriebel, D., and Kaihatu, J., 1993, "Equilibrium Beach Profiles with Random Seas," 23rd Intl. Conf. on Coastal Engineering, Venice, Italy, pp. 1973-1986. Kriebel, D. and Dawson, T., 1993, "Distribution of Crest Amplitudes in Severe Seas with Breaking," Journal of Offshore Mechanics and Arctic Engineering, ASME, Vol. 115, No. 1, pp. 9-15. Kriebel, D., 1992, "Nonlinear Wave Runup on Large Circular Cylinders," Proceedings Civil Engineering in the Oceans Conference, College Station, Texas, pp. 173-187. Seelig, W., Kriebel, D., and Headland, J., 1992, "Broadside Current forces on Ships," Proceedings Civil Engineering in the Oceans Conference, College Station, Texas, pp. 326-340. Kriebel, D.L, "Nonlinear Wave Interaction with a Vertical Circular Cylinder, Part II: Wave Runup," Ocean Engineering, Vol. 19, No. 1, pp. 75-99. Kriebel, D.L. and Dawson, T.H., 1991, "Nonlinear Effects on Wave Groups in Random Seas," Journal of Offshore Mechanics and Arctic Engineering, Vol. 113, No. 2, pp. 142-147 Kriebel, D., Kraus, N., and Larson, M., 1991, "Engineering Methods for Cross-Shore Beach Profile Response," Proceedings Coastal Sediments '91 Conference, Seattle, pp. 557-571 10 Dawson, T.H., Kriebel, D.L., and Wallendorf, L.A., 1991, "Experimental Study of Wave Groups in Deep Water Random Waves," Journal of Applied Ocean Research, Vol. 13, No. 3, pp. 116-131 Dawson, T. and Kriebel, D., 1991, "Statistics of Breaking Waves in Deep Water random Seas," Proceedings 1st Intl. Offshore and Polar Engineering Conference, Edinburgh, pp. 39-46.. Kraus, N., Larson, M., and Kriebel, D.,1991, "Evaluation of Beach Erosion and Accretion Predictors, Proceedings Coastal Sediments '91 Conference, Seattle, pp. 572-587. Kraus, N. Gingerich, K., and Kriebel, D., 1991, Editors of Coastal sediments' 91 conference proceedings, ASCE. Editors, Volume 1 Kriebel, D.L., 1990, "Nonlinear Wave Interaction with a Vertical Circular Cylinder, Part I: Diffraction Theory," Ocean Engineering Journal, Vol. 17, No, 4, pp. 345-377 Kriebel, D.L, 1990, "Nonlinear Wave Interaction with a Vertical Circular Cylinder, Part I: Diffraction Theory," Ocean Engineering Journal, Vol. 17, No, 4, pp. 345-377 Kriebel, D.L, 1990, "Recent Advances in Numerical Modelling of Dune Erosion," Proceedings 22nd Intl. Conference on Coastal Engineering, Delft, The Netherlands, pp. 2304-2317 Kriebel, D.L., and Zseleczky, J., 1990, "Evaluation of Viscous Damping Models for Single-Point-Mooring Simulation," U.S. Naval Academy, Div. Engr. and Weapons, Rpt. EW-9-90. Kriebel, D.L., 1988, "Storm Erosion and Sea Level Rise Considerations for Beach Nourishment," Proceedings Conf. on Beach Preservation Technology, Gainesville, Florida, pp. 139-150. Kriebel, D.L., 1988, "Nonlinear Diffraction by a Vertical Cylinder," Proceedings 21st Intl. Conference on Coastal Engineering, Malaga, Spain, pp. 17-31. Kriebel, D.L., 1987, "Beach Recovery Following Hurricane Elena," Proceedings Coastal Sediments '87 Conf., New Orleans, pp. 990-1005. Kriebel, D.L., Dally, W.R., and Dean, R.G., 1986, "An Undistorted Froude Model for Surf Zone Sediment Transport," Proceedings 20th Intl. Conference on Coastal Engineering, Taipei, pp. 1296-1310. Kriebel, D.L., 1986, "Verification Study of a Dune Erosion Model," Shore and Beach, Vol. 54, No. 3, pp. 13-21. Bodge, K.R. and Kriebel, D.L., 1986, "Storm Surge and Wave Damage Along Florida's Gulf Coast From Hurricane Elena," Proceedings Conf. on Beach Preservation, Ft. Lauderdale, pp. 156-177. Kriebel, D.L. and Dean, R.G., 1985, "Numerical Simulation of Time-Dependent Beach and Dune Erosion Due to Severe Storms," Coastal Engineering, Vol. 9, pp. 221-245. Kriebel, D.L., Dally, W.R., and Dean, R.G., 1987, "Beach Recovery Mechanisms Following Severe Erosion Events," Report 86/016, Dept. of Coastal and Oceanographic Engineering, Univ. of Florida. 11 Kriebel, D.L. and Dean, R.G., 1985, "Estimates of Erosion and Mitigation Requirements Under Various Scenarios of Sea Level Rise and Storm Frequency for Ocean City, Maryland," in EPA 230-10-85-013, ed. J.G. Titus, U.S. Environmental Protection Agency. Kriebel, D.L. and Dean, R.G., 1984, "Beach and Dune Response to Severe Storms," Proceedings 19th Intl. Conference on Coastal Engineering, Houston, pp. 1584-1599. Smith, O., Kriebel, D., and Bales, J., 1983, “The Alaska Coastal Data Collection Program,” Proc. Coastal Zone ’83 Conference. 1 11 March 2021 Nantucket Conservation Commission 2 Bathing Beach Rd. Nantucket, MA 02554 Re: Siasconset Beach Preservation Fund (SBPF) 2019 Annual Review (SE48-2824) Dear Commissioners: Thank you for the opportunity to provide comments on the 2019 Annual Review from the SBPF regarding the Sconset geotube project. I have recently been retained by Mr. Robert Greenhill to review all aspects of the project as they relate to his properties. Given that I have just started my review, I will keep my remarks short and focused on just three issues. By way of background, I have worked on coastal projects in other states, notably in Florida, where an action at one location has been documented to cause erosion miles away and years later due to a disruption to the normal longshore sediment transport processes. In these cases, mitigation in the form of sand placement in the active littoral zone is required to maintain the normal rate of longshore sediment transport and to prevent further erosion downdrift. Some of my observations at these other locations apply to the Sconset situation. Shortfall in Mitigation A first observation, based on the Annual Review, is that the placement of sand as mitigation appears to be lagging the behind the required rates and volumes. Based on my understanding, mitigation in the amount of 22 cy/ft/yr is required. For the initial project length, this equates to 18,744 cy/yr for the first two years, while for the existing project length this equates to 20,834 cy/yr since 2015. The 2019 Sand Delivery and Contribution Report, Table 1, documents the actual placement volumes. In the figure below, I have graphed the cumulative placement volumes starting with the March 2014 value. The solid curve and square symbols show the cumulative mitigation requirement. The dashed curve and circular symbols show the actual placement accumulated over the years since March 2014. It is clear that, despite the initial placement in March 2014 exceeding the required first-year mitigation volume, subsequent mitigation has been well below the required rate. This is in general agreement with the findings of Mr. Greg Berman who presented similar data in tabular form in his independent review. 2 Since 2014, the average placement rate has been at about 60% of the rate required. The gap between the cumulative required mitigation and the actual mitigation has been widening. While a large volume was placed in 2019, this did not make up the cumulative deficit. Projections based on the slopes of the trend line are clear: mitigation is well below target and the cumulative shortfall is growing. Compatibility and Effectiveness of Mitigation A second observation is that neither the Sand Delivery report nor the Annual Review demonstrate that the that mitigation sand placement is fully effective in achieving the normal goals of sand mitigation. As is normally understood in coastal engineering and coastal geology, sand mitigation would involve placement of beach-compatible sand in the zone of normal wave activity where the sand would “feed” the longshore transport in a way that mimics natural processes. In this regard, I was first surprised that the Sand Delivery report does not contain any analysis showing that the placed sand has grain size characteristics that match those of the native beach sand. Perhaps this has been done in the past. But any sand placed as mitigation should have a grain size composition similar to the native beach sand, and should be free of fine materials. If fine materials are present in the fill, these should not be considered compatible and should not be counted as effective mitigation. 3 The effectiveness of mitigation also depends on where the material is placed relative to the zone of normal water levels and wave action. The reports give the impression that mitigation sand is being placed on top or over the geotubes, in some cases being retained there from year to year. In my opinion, effective mitigation is not achieved by stacking sand higher on top of the project where it is out of reach of waves, but should be achieved by placing sand in front of the project where it is readily available to the normal wave climate. This means that sand should be placed seaward of the geotubes to the extent possible. This would not only put sand where it is needed for its primary function as mitigation, but would secondarily also protect the geotubes from being exposed and possibly undermined. Adaptive Management A third observation is that the proposed Adaptive Management approach does not result in effective or complete mitigation. Mitigation requirements are typically based on some long-term trends and are not set on a year to year basis. Under natural conditions, longshore transport may move more sand some years and less others, but should feed downdrift beaches at some long- term average rate. As a result, mitigation sand should be placed at this average rate, and the volume of sand remaining in or above the design template from a prior year should not be subtracted from the mitigation requirement for a current year. Adapting each year’s mitigation placement based on what is already stored in the design template will surely provide less sand over time than is needed to meet the long term average rate of longshore transport. The goal of mitigation should probably be to NOT have any excess sand in the template and to ensure that the full mitigation volume is available in front of the geotubes on the active beach. After all, the primary goal of mitigation is not to protect the geotubes, but to protect downdrift beaches. I thank the Commission for the opportunity to comment on the 2019 Annual Review. Sincerely, David L. Kriebel, PhD, PE Coastal Analytics LLC Indialantic, FL dlkriebel@gmail.com 410-703-5146