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HomeMy WebLinkAboutDMF letter Cowan to Barnstable ConComThe 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 June 6, 2023 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 (NOI) by David and Cynthia Cowan to construct a fixed height permanent walkway at 79 7th Avenue within the Halls Brook in the Town of Barnstable. 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 Halls Brook has been identified by MA DMF as diadromous fish passage, migration, and/or spawning habitat for alewife (Alosa pseudoharengus) [3]. MA DMF offers the following comment for your consideration: • A new fixed height permanent walkway has the potential to negatively impact nearby wetland resources and fisheries in a variety of ways [4]. While some of these impacts can be avoided or reduced with best management practices, others are unavoidable and will result in permanent impacts to salt marsh habitat and associated fisheries access. Support piles will directly displace salt marsh habitat, and piles may cause further indirect impacts that negatively affect bordering shellfish habitat. Leachates from any pressure treated wood used for support piles or decking may also negatively impact nearby shellfish. The support piles and adjacent footprints will likely not be accessible to commercial or recreational fisheries. • 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 between the base of horizontal stringers and salt marsh reduced shading and marsh loss relative to the typically required 1:1 H:W ratio [4-6]. Current plans do not meet the 1.5:1 H:W ratio recommendation. MA DMF recommends establishing a minimum 1.5:1 H:W ratio for pier decking across the full extent that overlies the marsh. Drafted 2016; Updated 2023 2 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: Mark Burgess, Shorefront Consulting John Logan, Emma Gallagher, MA DMF Robert Boeri, CZM References: 1. 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 2. 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. 3. MA DMF. MassGIS Data: Diadromous Fish. https://www.mass.gov/info-details/massgis- data-diadromous-fish. Accessed February 8, 2023. 2023. 4. 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 5. 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/s12237-017-0323-1 6. 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