HomeMy WebLinkAboutJohn O'Dea SECI-ShellfishMaps-Comments_04-11-2023April 10, 2023
Town of Barnstable
Conservation Commission
230 South Street
Hyannis, MA 02601
Re: Shellfish Habitat Maps
Dear Commissioners,
I would like to take this opportunity to provide public comment on the pending
updated Shellfish Habitat Maps. I am unable to attend this evenings meeting, but do hope
to participate in the future discussions.
First and foremost, although a few regular consultants are closely monitoring these
discussions on the Shellfish Maps, I believe the Commission should be aware that the vast
majority of the public is NOT aware of these discussions or the implications that they have.
I would urge the Commission not to hastily act on these maps during three consecutive
meetings in April given their own continued questions/concerns with the methodology.
I would like to remind the Commission that as far back as the December 2011
update meeting minutes indicate that the rating system was considered by the Commission
to be “imperfect”, and a work in progress….and yet 12 years later – with an abundance of
resources available to improve on the system – it is still described as a “start”.
The rating system is admittedly subjective, and at best heavily biased.
In the 20+ years the maps show a substantial increase in areas considered to be
“significant” to shellfish, while evidence suggests that if anything there has been a decrease
in shellfish stock, water quality, and bottom sediments.
I would also note that although the Commission narrates the map as only a
presumption, that presumption has only willingly been overcome by the Commission a
couple of times in the 20+ year history, and to the best of my recollection – never in the
Three Bays area.
If not using this updating as an opportunity to finally improve the rating system, I
would at least suggest that this is an opportunity for the Commission to clearly define what
would overcome the presumption of the maps. Commissioner Sampou outlined three
clear requirements for shellfish habitat, and collectively it should be very easy to generate
graph templates of what might fall within suitable habitat criteria. Barring this sort of
further definition, the Commission is effectively forcing applicants toward appeal, which is
an undo burden on the applicants – and the Town resources.
Further, it appears, if not directly stated, that the increases in “significance” may be
due in part to the Shellfish Rating Group, Shellfish Committee, and Natural Resources
Department considering the area around the existing piers to be lost habitat - “out of the
fisheries”, and that the ratings represent the significance of the areas left between those
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structures. With this understanding I would question if modifications to existing piers
should be treated differently. Should not the presumption in these cases be that the area
labeled as Not significant?
I would ask the Commission to remember that the harbors should be considered a
shared resource – and that equal weight should be given to the non-shellfish residents,
property owners, recreational, and commercial boating interests.
I trust this meets your present needs.
Very truly yours,
John O’Dea, P.E.
Sullivan Engineering & Consulting, Inc.