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HomeMy WebLinkAboutDMF Revised Plan and Response Letter - Aug 31 88 Route 6A Sandwich, MA 02563 T 508.255.6511 B0633-0020 August 31, 2026 Amanda Davis, Environmental Analyst Massachusetts Division of Marine Fisheries 836 S Rodney French Blvd, New Bedford, MA 02744 Re: Craigville Beach Road Bridge Repair Project – SE3-6406 Response to Comments and Request for Additional Information Dear Ms. Davis: Please find our proposed revised approach addressing the comments provided by the Massachusetts Division of Marine Fisheries to the Barnstable Conservation Commission for the submitted Notice of Intent (NOI) associated with the Craigville Beach Road Bridge Repair Project (SE3-6406). We request additional clarification to confirm that the proposed revised approach will satisfy all restrictions at the site. Furthermore, we request a waiver be considered for the Spring time-of-year (TOY) restriction. Comments about the project are reiterated below in italics, while our responses are provided in normal font. Division of Marine Fisheries Comments 1) A time-of-year (TOY) restriction is recommended on in-water work from January 15 to June 30 to protect sensitive life stages of diadromous species and winter flounder. A fall TOY is also recommended, to protect diadromous fish species during their fall migration, from September 1 to November 15. The Town of Barnstable Harbormaster requested the channel to be unobstructed from May 1st through October 31st. The resulting TOY restriction in aggregate would be from January 15th through November 15th. We request clarification on this TOY restriction from DMF to understand the activities that would still be allowed to occur at the project site. • Would installed cofferdams and turbidity curtains be permitted to remain in place during the TOY restriction as long as fish passage is maintained through the site? • Would work within the areas isolated by a cofferdam and turbidity curtain be allowed to continue during the TOY restriction? • Would removal of the cofferdams and turbidity curtains be permitted to occur during a TOY restriction? The repair of the Craigville Beach Road bridge is being scheduled to be completed ahead of the New England Wind 1 offshore wind farm. Transmission cables from the wind farm are planned for a proposed landing site at Craigville Beach and through this project site. This available window to complete the repair of the Craigville Beach Road bridge is a critical consideration for this project. Once New England Wind 1 commences construction, the bridge repair project will not be able to be performed concurrently. This can delay critical repairs to the 2 bridge, degrade the condition of the bridge, and can result in further and more costly repairs required in the future. Given the availability to complete the necessary repairs over this winter season, based on the current recommended TOY restrictions, all in-water work would need to be completed before January 15th. This timeline may not be feasible to bid the project, award the project to a contractor, and the contractor to procure, mobilize, and install the cofferdams. Furthermore, as part of our response to comment #3, we are considering removing the turbidity curtains from the project, subject to MassDEP approval part of the 401 Water Quality Certification. This would result in placing riprap in the channel where there would be no restrictions to fish passage through the work zone. We ask for the following clarifications: • Would DMF consider a waiver request for the spring TOY restriction? 2) MA DMF may be able to offer a fall TOY restriction waiver provided a Water Control and Diversion Plan is developed and submitted for review, comments, and approval. Water Control and Diversion Plans should incorporate best management practices that maintain adequate flow, protect diadromous species, and minimize turbidity. Water diversion plans should be sent to Brad Chase (brad.chase@mass.gov), Stephanie Berkman (Stephanie.Berkman@mass.gov), and Amanda Davis (Amanda.Davis@mass.gov) for review. See responses and requested clarification in other comments. 3) Current plans show a bottom anchored turbidity curtain placed through salt marsh and across the Centerville River both upriver and downriver of the bridge. This proposed placement could impact salt marsh and will interrupt fish passage and flow. MA DMF recommends maintaining uninterrupted flow by either removing the turbidity curtains from the scope of work, or placing the turbidity curtain(s) along the river and parallel to the abutments rather than across the river. Turbidity curtains should not be anchored withing salt marsh habitat. Turbidity curtains are proposed to limit the spread of suspended sediment outside the work area. The proposed turbidity curtains are part of the Best Management Practices (BMPs) to avoid, minimize, and mitigate environmental impacts. We are considering removing the turbidity curtains from the project; however, this would be subject to approval from MassDEP through the Section 401 Water Quality Certification of the Federal Clean Water Act. Tighe & Bond proposes the following alternative construction sequence and removed turbidity curtain as shown in the sketch included as Attachment 1. • Install sediment control barrier along riprap above MHW (purple). The placement of the sediment control barrier will be installed to minimize to the extent practicable voids between the existing riprap and the sediment control barrier. • Install cofferdams (blue) at the four corners of the bridge and perform abutment repairs and riprap placement within the cofferdams. Remove cofferdams. • Dump riprap along the abutment face on the channel slope to the dimensions shown on the drawings. No turbidity curtains or bypass is proposed for this work. The placement of riprap will be performed in a careful manner to minimize disturbance of sediment. 3 • Excavate along southwest retaining wall to perform retaining wall repair within contained area with sediment control barrier. Backfill and restore riprap armoring along embankment slope. • During low tide, place proposed riprap along the toe of the slope as shown on the plans. No turbidity curtain or sediment control barrier is proposed for this work. Riprap shall be clean and placement of riprap will be performed in a careful manner to minimize disturbance of sediment. • Perform remaining tasks in the roadway and bridge top side. The revised approach would eliminate the turbidity curtains from being anchored within the salt marsh habitat and eliminate the turbidity curtains from being a barrier to fish passage. As discussed previously, the removal of the turbidity curtains will be subject to MassDEP approval. We considered orienting the turbidity curtains parallel to the abutments and performing work in phases. Due to the low clearance of existing bridge, orienting the turbidity curtain parallel to the abutments would block access for equipment necessary to perform the work. In addition, this approach would require a phased approach and removing the turbidity curtain from the first phase, reinstalling the turbidity curtains for the second phase, then removing them again most likely within the spring TOY restriction. 4) The NOI states an anticipated 350 square feet of permanent impacts and 1,410 square feet of temporary impacts for a total of 1,760 square feet of salt marsh impacts. The larger 1,410 square feet of anticipated temporary impacts has the potential to include permanent impacts if construction activities result in marsh loss given that the temporary impact area directly abuts the riprap construction zone. A monitoring and mitigation plan should be developed to assess and mitigate for any construction-related impacts to salt marsh habitat. A marsh monitoring plan and construction protocol will be developed and submitted 21 days prior to start of construction. A pre -construction meeting will also be held on site with Conservation Com mission to review the construction protocol and controls before work begins. Summary We hope these responses have satisfactorily answered your initial comments, and your clarification of our questions is appreciated. We are happy to discuss any of these responses, or any additional questions you may have. Should you require any additional information, please feel free to contact me at (508) 304-6354 or via email at AJHoule@tighebond.com. Sincerely, Tighe & Bond, Inc. Amanda Houle, PWS, CERP PRINCIPAL ENVIRONMENTAL SCIENTIST J:\B\B0633 Barnstable \020 - Craigville Beach Road Bridge\Permitting \NOI\Response Letter\DMF VVVVVVVVVVVVVVVVVVVVVVVV VVVVVV VVVVVVVVVVVVVVV VVVVVVVVVVVVVVVVV VVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVVV VV V V VVVV V V VVVVVV VV V V VVVVVVVVVVVV V V V VVVVVVVVVVVVVVVVV VV V VV VVV V VVV V V VVVVV V V VVVVVVVVV VVVVVVVV V VV VVV VVV VVVVVVVVVVVVVVVVVS 45° 36' 24" E 495.00'34567 AS SHOWN SITE PLAN 00 20'40' SCALE: 1" = 20' CHECKED BY: DRAWN BY: FILE: APPROVED BY: DATE: PROJECT NO: MARK DATE DESCRIPTION B0633-020_Civil.dwg JULY 2026 B0633-020 SCALE:Plotted On:Jul 17, 2026-3:33pm By: JManLast Saved: 7/17/2026Tighe & Bond:J:\B\B0633 Barnstable\020 - Craigville Beach Road Bridge\Drawings\AutoCAD\Sheet\B0633-020_Civil.dwgDESIGNED BY: THIS DOCUMENT IS RELEASED TEMPORARILY FOR PROGRESS REVIEW ONLY. IT IS NOT INTENDED FOR BIDDING OR CONSTRUCTION PURPOSES. 90% DESIGN Proposed Bridge Repair Town of Barnstable Craigville Beach Road over Centerville River B-01-002 (AED) J. Man S. Sak B. Gargan J. Man N A D 8 3 N SHEET 4 OF 17