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Home My WebLink AboutDMF Letter NOI Smith (Salt Marsh Restoration) to Barnstable 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 April 30, 2025 Barnstable Conservation Commission 367 Main Street Barnstable, MA 02601 Dear Commissioners: The Massachusetts Division of Marine Fisheries (MA DMF) has reviewed the Notice of Intent by Shannon Smith to stabilize the coastal bank, conduct salt marsh restoration activities, and to install oyster bags/castles within the intertidal area of Barnstable Harbor at 0 and 87 Salten Point Road in the Town of Barnstable. The project was reviewed with respect to potential impacts to marine fisheries resources and habitat. The project site lies within mapped shellfish habitat for northern quahog (Mercenaria mercenaria) and softshell clam (Mya arenaria). Waters within the project site have habitat characteristics suitable for these species. Land containing shellfish is deemed significant to the interest of the Wetlands Protection Act (310 CMR 10.34) and the protection of marine fisheries. The project site includes existing salt marsh vegetation. Salt marsh provides a variety of ecosystem services, including habitat and energy sources for many fish and invertebrate species [1-2] Barnstable Harbor acts as winter flounder (Pseudopleuronectes americanus) spawning habitat. Winter flounder enter the area and spawn from February through May; demersal eggs hatch approximately 15 to 20 days later. The Atlantic States Marine Fisheries Commission has designated winter flounder spawning habitat as a “Habitat Area of Particular Concern” (HAPC). In the latest stock assessment, the Gulf of Maine winter flounder biomass status is unknown and overfishing is not occurring [3]. Given the unknown biomass status of the winter flounder stock, every effort should be made to protect the species and its spawning habitat. The project site lies within a horseshoe crab (Limulus polyphemus) spawning area and the species has been recorded nesting nearby at Blish Point. Horseshoe crabs deposit their eggs in the upper intertidal regions of sandy beaches from late spring to early summer during spring high tides. Adult crabs congregate in deep waters during the day while they wait to spawn on nearby beaches at night. Eggs hatch approximately two to four weeks later. The 2024 benchmark stock assessment indicates that the New England horseshoe crab stock status continues to be neutral [4]. Continued efforts should be made to protect the species and facilitate further stock improvement MA DMF offers the following comment for your consideration: Shoreline Stabilization 2 • MA DMF supports the applicant’s proposal to protect the leading edge of the salt marsh with coir logs or matting, cobble and sediment, and native planting provided there is a monitoring plan. • MA DMF supports the applicant’s proposal to restore the elevation of the small salt marsh area landward of the proposed fiber roll array. • A time of year (TOY) restriction should be observed to protect sensitive life stages of horseshoe crabs. No sediment deposition or bank stabilization activities other than planting should take place May 1 – July 31 of any year to protect sensitive life stages of horseshoe crabs [5]. • A salt marsh monitoring plan is not included in this proposal. Key details such as the expected frequency of regular check-ins, how and who will determine if an intervention is necessary, and what will occur if the proposed project is not successful should be included in a monitoring plan. MA DMF recommends a comprehensive monitoring plan that includes a monitoring schedule and best management practices to limit the potential of generating marine debris if the coir rolls are not successful or if they are co mpromised. • Salt marsh restoration of this type is uncommon; therefore, MA DMF would appreciate seasonal updates (every 3 months) until the site is considered “restored”. Updates should include photographs, a short narrative, and should be sent to 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 . Placement of Oyster Bags and Oyster Castles in Intertidal Area • At this time, MA DMF can not fully support placing oyster bags and oyster castles within the intertidal and subtidal area of Barnstable Harbor. Barnstable Harbor is a high energy system and structures placed within the subtidal and intertidal area have potential of becoming marine debris by becoming lose, stuck, or buried. • This area is frequently used by commercial and recreational shellfish harvesters. The placement of oyster bags and oyster castles in the intertidal and subtidal area will displace suitable and productive quahog, razor clam, and softshell clam habitat. • If approved, and monitoring and intervention plan should be developed and a shellfish mitigation plans should seek input and expertise from the Barnstable Shellfish Constable. • If approved, the applicant will likely need to file for a DEP Chapter 91 Waterways permit and a General Permit. • As an alternative, the addition of ribbed mussels along the leading edge of the restored marsh could be considered as an alternative way to stabilize the marsh without altering the intertidal flats and subtidal area. 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 3 cc: Jen Crawford, Crawford Land Managment John Logan, Holly Williams, Matt Camisa, Kara Falvey, Derek Perry, Alex Boeri, Sean Terrill, Mark Rousseau, MA DMF Amy Croteau, Barnstable Shellfish Constable Patrice Bordonaro, CZM References: 1. Boesch, D.F. and R.E. Turner. 1984. “Dependence of Fishery Species on Salt Marshes: The Role of Food and Refuge.” Estuaries 7(4):460-468. https://doi.org/10.2307/1351627. 2. Deegan, L.A., J.E. Hughes, and R.A. Rountree. 2000. “Salt marsh ecosystem support of marine transient species.” In: M.P. Weinstein and D.A. Kreeger, eds. Concepts and Controversies in Tidal Marsh Ecology: Kluwer Academic Publisher, The Netherlands. pp. 333-365 3. ASMFC. 2022. Gulf of Maine Winter Flounder 2022 Management Track Assessment Report. Compiled June 2022. http://www.asmfc.org/uploads/file/63d6c2b92022_FLW_GM_RPT_Report_2022_09_01 .pdf 4. ASMFC. 2024. 2024 Horseshoe Crab Benchmark Stock Assessment Update. Prepared by the ASMFC Horseshoe Crab Stock Assessment Subcommittee pursuant to NOAA Award No. NA20NMF4740012. http://www.asmfc.org/uploads/file/663d0fcdHorseshoeCrabStockAssessmentUpdate_Apr il2024.pdf 5. 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