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L E T T E R S
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TOWN WEIGHS IN ON GHYC
The following letter was originally sent to Ben Lynch of the Mass. Department of Environmental Protection and is reprinted here.
Dear Mr. Lynch:
Pursuant to the Department of Environmental Protection M.G.L. Chapter 91 request for written comment the Town of Nantucket hereby submits comments regarding the above proceeding and requests a copy of written determinations when and if issued.
To begin, the applicant has neither provided a valid Order of Conditions and Water Quality Certificate, nor asked for a specific length of time for an extended term. The Town of Nantucket does not agree that a license period longer than the customary 30-year period is appropriate. In light of these facts, the DEP should find the application incomplete. We ask that the review of this application cease until the application is complete. The public review and hearing process should begin once the application is complete and available for review.
The Town of Nantucket submits the following comments for your consideration:
1. As stated above, the Town of Nantucket believes that the customary 30-year license term is appropriate in this case.
2. The secondary Water-Dependent Accessory Use is out of scale to the primary Water-Dependent Use. The primary use is an amalgam of a number of small water-dependent uses, while the secondary, accessory use is dominated by a proposed clubhouse of over twenty-one thousand square feet. The public interest is served by the primary Water-Dependent Use being the predominant use of the waterfront.
3. The travel lift and forklift operation is crucial to the safe operations of recreational and commercial boats in Nantucket waters. There are numerous vessels located in Nantucket waters that can only be removed by this method. The travel lift operation must function within the property confines of the Great Harbor Yacht Club. This provision of a storm (emergency) haul out plan provided for by special permit from the Planning Board is integral to the required removal of numerous boats from Nantucket waters prior to any major storm event. The removal of boats prior to a major storm event reduces pollution, shore-side property damage and vessel damage. The current special permit from the Nantucket Planning Board permits the operation of a crane. The applicant is now planning to use a crane for boat hauling, a slower, more complicated and less safe alternative, in the Town's opinion.
It should be noted that leaving the travel lift operation in its present location requires no dredging except for periodic maintenance of the access channel, subject to permission of the Town of Nantucket. It should be further noted that the proposed location (southeast corner of the property) of the GHYC dredging is on land partially owned by the Town of Nantucket. Any dredging would require the explicit approval of the Board of Selectmen.
4. The permit should include provisions for a public dinghy dock.
5. Provisions in the license need to be memorialized to provide off-season slips (November 1 through March 31) and parking for commercial scallopers. These slips would be provided at a reasonable fee not to exceed the amount currently charged or charged in the future by the Town of Nantucket. Consideration should be included of up to 20% of the slips be made available to the public during the summer season through the established slip lottery program coordinated by the Marine & Coastal Resources Department.
6. The applicant must be required to offer the following marine services to the general public in perpetuity:
a. Gasoline and diesel fuel
b. Vessel hauling per item #1
c. Removal and proper disposal of boat sewage and gray water
7. The applicant must provide on-site oil spill recovery and disposal equipment, utilizing trained personnel.
8. Due to severe weather conditions experienced in the project's exposed location, it is recommended that the water and electrical services are encompassed in the structural envelope of dock floats.
9. The applicant's proposed HELIX mooring installation in a shellfish bed must require that a socalled "Glowacki cap" be installed prior to the seasonal float removal (October 15th). If the specified system is unavailable a suitable alternative needs to be proposed and approved by the Marine Superintendent.
10. The Town of Nantucket has identified a dire need for a second boat ramp on the harbor at a location south of the congested business center. Almost all commercial boatyards and most private launchers are south of town. A ramp incorporated into the design on the northern edge of the property would have minimal impact on any eelgrass. An additional ramp will reduce the congestion at the established ramp north of town during the summer months and prior to major storm events, further lessening the undesirable impacts of pollution, property and vessel damage.
11. The proposed public walkway needs to be extended to circumnavigate the entire property, allowing for safe pedestrian and handicap accessibility to the general public. Viewing areas with benches would enhance the possibility of the public's passive enjoyment of the site.
12. Fixed and/or floating docks should be minimized to protect eelgrass and other natural habitat vital to native species.
13. This formal objection by the Board of Selectmen of the Town of Nantucket enumerates only a few of the issues and objections related to the Department's granting of the Chapter 91 waterways license, as requested in DEP Waterways License Application No. W06-1793, and is in addition to any formal comments, objections or other submissions made to the Department by other governmental bodies or officials of the Town of Nantucket under separate cover, including but not limited to any formal objections submitted by Town Counsel.
The significant establishment of Water-Dependent Use as it applies to the issuance of any permit can not be overemphasized. The Water- Dependent Use must be the predominant criteria for the continued use of this property.
Sincerely,
- Whitey R. Willauer Chairman, Board of Selectmen
- David Fronzuto
Superintendent, Department of
Marine and Coastal Resources
SHELLFISH CONCERNS
The following letter was originally sent by the Nantucket Shellfish Association to the hearing officer on the Great Harbor Yacht Club's Chapter 91 application and is reprinted here.
Dear Sir:
The Nantucket Shellfish Association ("NSA") is a not-forprofit membership corporation that has as its mission the preservation and enhancement of Nantucket's shellfisheries through research, education and advocacy.
Nantucket has the only remaining, self-sustaining bay scallop fishery on the East Coast, if not the world. That fishery is in great peril, from both natural and man-made causes. The harvest of bay scallops during the current season may be as low as has ever been recorded.
As your study of the Chapter 91 application of the Great Harbor Yacht Club ("GHYC") draws to a close, we are writing to reiterate the concern that we have expressed to local regulatory bodies concerning the aspects of the application that are of concern to NSA, specifically those impacting the shellfish habitat.
NSA is opposed to any plan for the waters of Nantucket which, through the location of piers, the relocation of moorings or through dredging, disturbs or destroys eelgrass beds of any density, since these beds serve as the habitat and spawning ground of shellfish, particularly bay scallops.
While GHYC has made an effort to respond to such concerns, the construction of floating docks and the related dredging, as well as the relocation of existing moorings away from the dock area, still provide a threat to what is already a precarious habitat.
The area of Nantucket Harbor affected by the GHYC application has long been a bay scallop habitat. Because bay scallops move around the harbor by their own action, as well as with currents, tidal action and the wind, an accurate census of a particular area as a bay scallop habitat can only be obtained by a periodic count of the area over a period of years. NSA is unaware of the existence of anything other than snapshot views submitted with the application. For other, less mobile shellfish such snapshots may be adequate; for bay scallops they are inadequate. (As an example of another snapshot, please see the attached survey commissioned by NSA and prepared by the Nantucket Maria Mitchell Association in November, 2005.)
Nantucket's bay scallops have been one of the island's great marine resources and attributes. In the Comprehensive Plan adopted by Nantucket's Annual Town Meeting in 2000, maintenance of the scallop fishery was adopted as a principal priority.
NSA submits that GHYC's current plans for docks, dredging and the relocation of moorings will disturb eel grass beds and a portion of the bay scallop habitat, representing a further threat to that habitat and, therefore, does not serve the public benefit.
NSA respectfully requests that approval of the GHYC Chapter 91 application be conditioned upon:
a. GHYC being permitted only to construct float(s) sufficient to maintain a launch service for its members and for the tying up of those launches, and no other docks or floats;
b. Dredging not being permitted outside of the existing channel, whether for docks or floats, for the relocation proposed by the applicant of the marine service facilities or for the relocation of moorings, except as may be minimally required to insure such launch service float(s) will not interfere with the marine services that GHYC is otherwise offering; and,
c. The forbidding of the relocation of existing moorings and/or the placing of new moorings in the area proposed for relocation.
Respectfully yours,
- Frank Dutra
Vice President
Nantucket Shellfish Association
ASAFE PLACE THANKS YOU ASafe Place would like to thank all who contributed to their first ever "Warming Up Nantucket Families" holiday donation drive, especially to Nantucket Island Resorts, who donated many, many sheets and towels. Your generosity resulted in over 20 Nantucket families receiving new blankets, towels, sheets, cleaning supplies, laundry detergent, etc. Your contribution reflects one of the important ways that the community continues to help A Safe Place be there for the many islanders we service.
As we approach our 20th anniversary, A Safe Place continues to empower survivors and assist the hundreds of women, men, children, elderly, students and businesses who seek our help and services. Thank you again for your donation. You have warmed many hearts and we know that your contribution was greatly appreciated.
- Mary Beth King
Sexual Assault Program Coordinator
A Safe Place, Inc.
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