HomeMy WebLinkAboutDMF LetterThe 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
November 25, 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 WYC Sailing Education Foundation to replace an existing boat ramp in kind within West Bay
at 101 Bridge Street in the Town of Barnstable. The applicant is proposing to either install a silt
curtain prior to installing pre-cast concrete slabs or install a cofferdam prior to pouring a
concrete slab. The project was reviewed with respect to potential impacts to marine fisheries
resources and habitat.
The project site abuts salt marsh vegetation. Salt marsh provides a variety of ecosystem services,
including habitat and energy sources for many fish and invertebrate species [1-2].
The project site includes mapped shellfish habitat for American oyster (Crassostrea virginica),
northern quahog (Mercenaria mercenaria), and softshell clam (Mya arenaria). Waters bordering
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.
West Bay acts as winter flounder (Pseudopleuronectes americanus) spawning habitat. Winter
flounder enter the area and spawn from January 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 previous stock assessment, the winter flounder stock was classified as overfished with
spawning stock biomass in 2019 estimated to be only 32% of the biomass target [3]. Spawning
stock biomass in 2021 was estimated to be 101% of the biomass target based on a new
recruitment stanza focusing only on the past twenty years [4]. Given the new status of the winter
flounder stock, every effort should be made to protect the species and its spawning habitat.
MA DMF offers the following comment for your consideration:
• A time-of-year (TOY) restriction should be observed on all in-water, silt-producing
activities to protect sensitive life stages of winter flounder. No in-water, silt-producing
activities should take place from January 15th – May 31st of any year [2]. However,
work may occur within this TOY period if the proposed turbidity barrier or cofferdam is
installed outside of this TOY period.
2
• Repair of the structure should be within the same footprint as the existing structure. Any
expansion of the footprint into tidal waters of the Commonwealth will result in the loss of
shellfish habitat.
• Concrete delivery vehicles should be prohibited from washing down equipment on site.
This activity could potentially wash excess concrete and hydrocarbons into marine
resource areas.
• 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:
John ODea, Sullivan Engineering & Consulting, Inc.
John Logan, Holly Williams, Matt Camisa, Kara Falvey, MA DMF
Patrice Bordonaro, CZM
AD/kf
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. 2020. Southern New England Mid-Atlantic Winter Flounder 2020 Assessment
Update Report. http://www.asmfc.org/uploads/file/6008bd822020_SNE-
MA_WinterFlounderAssessmentUpdate.pdf
4. ASMFC. 2022. Southern New England Mid-Atlantic Winter Flounder 2022 Management
Track Assessment Report. Compiled June 2022. https://apps-
nefsc.fisheries.noaa.gov/saw/sasi.php
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
3
Resources in Massachusetts. Massachusetts Division of Marine Fisheries Technical
Report, TR-47. https://www.mass.gov/doc/time-of-year-recommendations-tr-
47/download