HomeMy WebLinkAboutSave Twin Brooks Comment Letter
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DATE : September 8, 2025
TO: Barnstable Conservation Commission
FROM: Save Twin Brooks, Inc.
RE: 268 Stevens Street Pump Station
CC: Barnstable DWP, Town Manager, and
Southeast Regional DEP Gerard.martin@mass.gov
Comments on Notice of Intent (NOI) – DEP File # 003-6308 August 19, 2025 Submitted by
Apex Companies, LLC for the Town of Barnstable
Thank you for the opportunity to comment on the August 19, 2025, NOI submitted by Apex
Companies, LLC (Matt St. Pierre, Senior Project Manager) on behalf of the Applicant, Griffin
Beaudoin, Town of Barnstable. We appreciate the project's goal to improve water quality in the
Lewis Bay watershed by connecting approximately 46 parcels to the municipal sewer, but the
means to achieving that goal are damaging the wetlands in the watershed.
We submit the following observations and requests regarding this NOI:
1. Wetland Flags Sketch Inadequacy:
The “Resource Area Flags” sketch (p. 51 of the NOI and shown below) is unprofessional
and unclear—lacking scale, north arrow, certification, and ownership. It also appears to
conflate Aunt Betty’s Pond and Fawcett’s Pond, which are neither adjacent nor the same
body of water. Is this freehand sketch meant to serve as Appendix D: Wetlands
Delineation Documentation? Please require the applicant provide a professional version
of the project’s wetlands delineation. The hearing should be continued until the plan is
submitted and the public may review it.
2. FEMA Floodplain Inconsistency:
The cover letter states the project is outside the FEMA floodplain, but 45 Mitchell’s Way
falls within it according to Mass Mapper and Barnstable GIS (see attached maps).
3. SWPPP and NPDES Discrepancy:
The signed cover letter by Matt St. Pierre of Apex Companies, LLC accompanying the
NOI package states that no Stormwater Pollution Prevention Plan (SWPPP) is required.
However, a SWPPP by GZA is included in the submission, beginning on page 156.
Please confirm the applicant will file under the NPDES Stormwater Permit Program,
which governs discharges from municipal construction activities.
4. Unpermitted Wetlands Discharge:
(a) Provide data on gallons discharged into Stewart’s Creek during dewatering (July 21–
August 25, 2025).
(b) Require an ecological damage assessment for wetland areas starting at 45 Mitchell’s
Way and downstream along Stewart’s Creek.
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5. Downstream Wetland Impacts:
The unpermitted discharge entered Stewart’s Creek and flowed into Lewis Bay, possibly
contributing to beach closures at Keyes Beach and Eugenia Fortes Beach due to water
quality issues and ecoli contamination (see postings below).
6. Abutter Notification Letter Issue:
The standard abutter notification letter shown on p. 51 is blank and does not reflect what
was actually sent. Please submit the actual letter for the public record and ensure full
compliance with NPDES notification requirements.
7. Superfluous information in the NOI: The filing comprised over 800 pages and included
a substantial volume of superfluous material, which significantly hindered the public’s
ability to conduct a meaningful and efficient review. To preserve the integrity and
accessibility of the review process, the applicant should be precluded from submitting
excessively voluminous and irrelevant documentation in future filings.
We firmly request that this hearing be continued until the applicant has both provided and
reviewed the items listed above. We also wish to formally express concern with the process—
specifically, that unpermitted activities were allowed to proceed, and that Town officials denied
their occurrence. Acknowledgment of these failures, along with a commitment from the Town of
Barnstable to uphold higher standards moving forward, is both necessary and overdue.
Sincerely,
Angela Rutzick Kim McGuire
Angela Rutzick Karen (Kim) McGuire
Co-Presidents
Save Twin Brooks Inc.
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268 Stevens Street NOI DEP File # SE 003-6308
Appendix D Wetlands Delineation, page 51
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Town of Barnstable GIS Flood Zone Layer in Green
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