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Home My WebLink AboutDMF Letter Hahn to Concom 2-28-23The Commonwealth of Massachusetts Division of Marine Fisheries 251 Causeway Street, Suite 400, Boston, MA 02114 p: (617) 626-1520 | f: (617) 626-1509 www.mass.gov/marinefisheries MAURA HEALEY KIMBERLEY DRISCOLL REBECCA TEPPER RONALD S. AMIDON DANIEL J. MCKIERNAN Governor Lt. Governor Secretary Commissioner Director February 24, 2023 Barnstable Conservation Commission 200 Main St Hyannis MA 02601 Dear Commissioners: The Division of Marine Fisheries (MA DMF) has reviewed the Notice of Intent (NOI) by Angela Hahn, to construct and maintain a 4’ wide footpath through a wooded coastal area, and construct access stairs, a dock, ramp, float, and kayak racks at 150 Bay Road within Shoestring Bay near the outlet of the Santuit River in the Town of Barnstable. Float stops are proposed to maintain 1.5 feet of clearance between the float and substrate at mean low water. Grated decking is proposed over salt marsh. The project was reviewed with respect to potential impacts to marine fisheries resources and habitat. The project site overlies 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 Santuit River has been identified by MA DMF as diadromous fish passage, migration, and/or spawning habitat for alewife (Alosa pseudoharengus), blueback herring (Alosa aestivalis), and American eel (Anguilla rostrata). Shoestring 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. A shellfish survey conducted by Megalodon Environmental LLC on November 18, 2021 found ribbed mussels (Geukensia demissa) within the project area. Land containing shellfish is deemed significant to the interest of the Wetlands Protection Act (310 CMR 10.34) and the protection of marine fisheries. MA DMF offers the following comments for your consideration: • A new pier has the potential to negatively impact nearby fisheries resources and habitats in a variety of ways [5]. While some of these impacts can be avoided or reduced with best management practices, others are unavoidable and will result in permanent impacts to fisheries habitat and associated fisheries access. Support piles will directly displace bottom habitat and salt marsh habitat, and piles may cause further indirect impacts that negatively affect bordering habitats. Leachates from any pressure treated wood used for support piles or decking may also negatively impact nearby shellfish. Associated boating activity could result in prop dredging if the float is installed in insufficient water depth relative to the size of vessels using the structure. The support piles, float, and adjacent footprints will likely not be accessible to commercial or recreational fisheries. • Thru-Flow™ decking (grated decking) is proposed to reduce shading impacts to salt marsh production. MA DMF conducted two field studies to assess the relationship between shading, marsh growth, and dock design; these studies collectively indicated that a height to width (H:W) ratio of 1.5:1 reduced shading and marsh loss relative to the typically required 1:1 H:W ratio for both traditional plank decking and grated decking designs [5-7]. Grated decking alone did not reduce shading impacts or associated marsh loss. As a result, grated decking should not be used as a substitute for adequate height above salt marsh vegetation. MA DMF recommends establishing a 6-foot minimum separation between the lowest hanging stringer and salt marsh and/or reducing pier width to maintain a 1.5:1 H:W ratio across the full extent of the marsh. • If approved, MA DMF recommends avoiding placement of piles in salt marsh vegetation to the extent practicable. Salt marsh habitat will be impacted by this project. Questions regarding this review may be directed to Amanda Davis in our New Bedford office at Amanda.davis@mass.gov. Sincerely, Amanda Davis Environmental Analyst MA Division of Marine Fisheries cc: Arlene M. Wilson, A.M. Wilson Associates, Inc. John Logan, Emma Gallagher, MA DMF Robert Boeri, 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. 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. Logan, J.M., A. Boeri, J. Carr, T. Evans, E.M. Feeney, K. Frew, F. Schenck, and K.H. Ford. 2022. A review of habitat impacts from residential docks and recommended Best Management Practices with an emphasis on the northeastern United States. Estuaries Coasts 45: 1189–1216. https://www.mass.gov/doc/dock-bmp- recommendations/download 6. Logan, J.M., A. Davis, C. Markos, K.H. Ford. 2018. “Effects of docks on salt marsh vegetation: An evaluation of ecological impacts and the efficacy of current design standards.” Estuaries and Coasts 41:661–675. https://doi.org/10.1007/s12237-017-0323 7. Logan, J.M., S. Voss, A. Davis, K.H. Ford. 2018. “An experimental evaluation of dock shading impacts on salt marsh vegetation in a New England estuary.” Estuaries and Coasts 41:13–24. https://doi.org/10.1007/s12237-017-0268-4