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Home My WebLink AboutDMF Comment Letter Cornwall to Barnstable ConCom 8-22-23The 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 August 16, 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 Craig S. and Maria T. Cornwall to re-permit and construct a pier, gangway, and float at 40 Waterman Farm Road on the Centerville River 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 (Boesch et al. 1984, Deegan et al. 2000). The Centerville River has been identified by MA DMF as diadromous fish passage, migration, and/or spawning habitat for alewife (Alosa pseudoharengus), blueback herring (Alosa aestivalis), white perch (Morone americana), and American eel (Anguilla rostrata) (MA DMF 2023). MA DMF offers the following comment for your consideration: • A new pier has the potential to negatively impact nearby aquatic resources and fisheries in a variety of ways (Logan et al. 2022). While some of these impacts can be avoided or reduced with best management practices, others are unavoidable and will result in permanent impacts to shellfish habitat and associated fisheries access. Support piles will directly displace bottom 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. 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. • 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 (Logan et al. 2018a, Logan et al. 2018b). Current plans show a pier width of 4 feet and 4 feet of clearance between the lowest stringer and salt marsh. Current plans do not meet the 1.5:1 Drafted 2016; Updated 2023 2 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. • Grounded floats can disturb bottom sediments, resulting in turbidity and direct impacts to benthic habitat. To minimize impacts, MA DMF recommends that the bottom of a proposed float be at least 1.5 feet (18 inches) above the substrate in all coastal or estuarine habitats at MLW (Logan et al. 2022). The float as proposed does not maintain this minimum clearance at MLW; MA DMF recommends installing float stops to maintain a 1.5-foot clearance above the substrate at MLW. • 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, Environmental Analyst MA Division of Marine Fisheries cc: Charles Rowland, Sullivan Engineering and Consulting, Inc. John Logan, Emma Gallagher, Malik Neron, Kara Falvey, Maggie Leary, Matt Camisa, MA DMF Amy Croteau, Barnstable Shellfish Constable Robert Boeri, CZM Reference: 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. 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 Logan, J.M., A. Davis, C. Markos, K.H. Ford. 2018a. “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 Logan, J.M., S. Voss, A. Davis, K.H. Ford. 2018b. “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 Drafted 2016; Updated 2023 3 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 MA DMF. MassGIS Data: Diadromous Fish. https://www.mass.gov/info-details/massgis-data- diadromous-fish. 2023.