HomeMy WebLinkAboutAOOC Red Lily Pond Assoc to ConComThe Commonwealth of Massachusetts
Division of Marine Fisheries
(617) 626-1520 | www.mass.gov/marinefisheries
MAURA T. HEALEY KIMBERLEY DRISCOLL REBECCA L. TEPPER THOMAS K. O’SHEA DANIEL J. MCKIERNAN
Governor Lt. Governor Secretary Commissioner Director
SOUTH COAST FIELD STATION CAT COVE MARINE LABORATORY NORTH SHORE FIELD STATION
836 S. Rodney French Blvd 92 Fort Avenue 30 Emerson Avenue
New Bedford, MA 02744 Salem, MA 01970 Gloucester, MA 01930
January 29, 2025
Barnstable Conservation Commission
367 Main Street
Barnstable, MA 02601
Dear Commissioners:
The Massachusetts Division of Marine Fisheries (MA DMF) has reviewed the request to Amend
Order of Conditions by the Red Lily Pond Project Association to permit the installation of
additional benthic barriers in Lake Elizabeth and Red Lily Pond in the spring of 2025. The
proponents also request to apply aquatic herbicides for invasive plant management and to
continue manual cutting and removal of aquatic macrophytes. The project was reviewed with
respect to potential impacts to marine fisheries resources and habitat.
Lake Elizabeth and Red Lily Pond has been identified by MA DMF as diadromous fish passage,
migration, and/or spawning habitat for alewife (Alosa pseudoharengus), blueback herring (Alosa
aestivalis), American eel (Anguilla rostrata), and white perch (Morone americana) [1].
MA DMF offers the following comment for your consideration:
• A time-of-year (TOY) restriction should be observed on all manual cutting of aquatic
macrophytes, benthic barrier installation/removal, and aquatic herbicide treatment
activities to protect sensitive life stages of the above-mentioned species. No macrophyte
removal, benthic barrier installation/removal, or herbicide treatment activities should take
place from March 15 – June 30 of any year [2-3].
• Benthic barrier coverage in both ponds will constitute less than 10% of the plant growth
in either waterbody (≥1% in Red Lily Pond; 2.6% in Lake Elizabeth). Th e proponent
states that benthic barriers will be installed between November 1 – March 14. This
proposed window of time for installation and removal is acceptable to MA DMF since it
is outside of the recommended TOY restriction period.
• Less than 50% of the waterbody’s surface area should be treated in any given year. In
addition, less than 50% of the shoreline should be treated in any given year since the area
is alewife spawning habitat.
• Please add MA DMF as recipients of any project reports. Reports can be sent to Amanda
Davis at amanda.davis@mass.gov.
• Fuel spills from refueling of construction equipment will adversely impact sensitive
resource areas. Impacts to resource areas can be avoided by prohibiting all land -based
equipment from being refueled on-site. If equipment is refueled on-site, adequate
containment and clean up material should be required to minimize impacts .
Questions regarding this review may be directed to Amanda Davis at amanda.davis@mass.gov.
Sincerely,
Amanda Davis
Environmental Analyst
MA Division of Marine Fisheries
cc:
Douglas Farquhar, Red Lily Pond Association, Inc
Kenneth Wagner, Water Resources Services Inc.
John Logan, Kara Falvey, John Sheppard, MA DMF
Patrice Bordonaro, CZM
References:
1. MA DMF. MassGIS Data: Diadromous Fish. https://www.mass.gov/info-details/massgis-
data-diadromous-fish. Accessed February 8, 2023. 2023.
2. Evans, N.T., K.H. Ford, B.C. Chase, and J. Sheppard. 2011. Recommended Time of Year
Restrictions (TOYs) for Coastal Alteration Projects to Protect Marine Fisheries
Resources in Massachusetts. Massachusetts Division of Marine Fisheries Technical
Report, TR-47. https://www.mass.gov/doc/time-of-year-recommendations-tr-
47/download
3. Sheppard, J.J., and B.C. Chase. 2021. Herbicides. Technical Memo, Massachusetts
Division of Marine Fisheries, New Bedford. https://www.mass.gov/doc/herbicides-and-
diadromous-fishes/download