My View
By Bruce Ritter
Iwould like to respond to several of the points raised by Jen Eldridge in the Sept. 26, 2006 Nantucket Independent's "Voices From the Bluff."

1. MEPA and NMF [sic] have clearly stated that this project will have vast, detrimental effects on the environment.

In the Massachusetts Environmental Policy Act (MEPA) letter of certification, Secretary Bowles stated that the project had provided adequate information,

sufficiently avoided or minimized impacts, and provided appropriate mitigation strategies. Specifically: "I find that the FEIR adequately addresses the issues remaining from the Certificate on the Draft EIR and provides adequate information to understand project impacts and provides state agencies with information necessary to make their required Section 61 Findings. The proponent has met its obligations under MEPA to avoid or minimize impacts wherever possible, and to develop mitigation commensurate with impacts in those areas where impacts are unavoidable. The MEPA review of the project is concluded."

During the final MEPA review process, the project received 75 comment letters from agencies, organizations, and individuals. Over 60 of these letters were written in support of the project. The National Marine Fisheries Service (NMFS) most recently submitted a comment letter in January 2007. We are continuing to coordinate with them through the federal permit review process facilitated by the US Army Corps of Engineers and believe that many of their concerns have been resolved as project design has evolved.

2. I am shocked that SBPF is not more prepared at these [Commission] meetings.

We are providing written answers (available at the Conservation Commission) to every individual question asked at the public hearings. Time constraints at the meetings, rather than lack of preparation, prevented our team from answering many of the public's questions at that time. Certain questions related to detailed construction operations may not be definitively answered; in these instances, we have used our professional judgment to present options that the dredge contractor may pursue. At the permitting stage, detailed construction specifications are typically not provided nor required; however, the Commission may impose conditions on the dredging operations relevant to the protection of resource areas.

3. SBPF is relying on sketchy data and computer models.

Beach nourishment is a tried and tested method of combating severe erosion. Our engineering team has designed and constructed over 60 beach nourishment projects, with clients that have been with them for 20 years. The rigorous design process incorporated several types of data, two state-of-the-art computer models, and professional judgment based on the performance of previous projects. Data evaluated includes: shoreline change maps going back to 1846; more than a decade of beach survey data from the project area; over 26 years of wave and wind data in the area; and wave and current data measured immediately off the bluff specifically for our project (these sensors collected data during the passage of Hurricane Wilma). This data was then employed in state-of-the-art 3D models that can account for currents, waves, and sand transport. Engineers next applied their experience to interpreting model results. The beach has been designed to withstand a 50-year storm five years following construction, and we are confident that the beach will perform as designed.

We also have been conducting a multiyear sampling program to characterize biological resources within the area. Extensive sampling for finfish, shellfish, ichthyoplankton and benthos has been ongoing since summer 2005, as frequently as biweekly. Habitat studies via side-scan sonar, dive surveys, and video surveys commenced in 2005 and were recently completed. Shorebird monitoring has been occurring for over seven years by various organizations; waterbird surveys began in December 2005. The presence of marine mammals (as well as sea turtles) has been assessed by reviewing 10 years of sighting data maintained by the North Atlantic Right Whale Consortium (1996-2005), as well as by interfacing with local fishermen. The amount of biological data collected is equal to or greater than that collected by comparable projects.

Independent consultants hired by the Town's Board of Selectmen, Applied Technology & Management (ATM), concurred that the project has been designed and evaluated at an appropriate level, based on review of the Final Environmental Impact Report (FEIR): "The information, analysis and data provided within the document are consistent with accepted practice for beach nourishment design and evaluation. The level of care and due diligence delineated within the FEIR is to accepted standards. The beach and borrow area designs have sufficient technical basis."

4. Given the need [for renourishment,] the beach and ocean bottom will never have time to "recover" and "return to normal."

Shorelines exposed to intense ocean energy are naturally dynamic. Coastal processes manipulate both the intertidal benthos and the subtidal substrate, thus the "normal" state of the ecosystem is in constant flux. Organisms living under these conditions are adapted to this dynamic environment to increase survival and successful larval recruitment to subsequent generations. Research indicates that soft-sediment benthic organisms should recover in 1-3 years. Suspension and deposit-feeding organisms such as polychaete worms, amphipods, decapod crustaceans and bivalve mollusks possess life-histories that allow them to emerge and re-borrow during disturbance events, and also possess larvae with long-range dispersal capabilities. As a result, adjacent populations, as well as larvae carried through sediment transport will provide a basis for population recovery.

Additionally, recovery tends to occur more rapid- ly when the nourished substrate matches the original substrate and when the percentage of silt and clay is low. Our project meets both these criteria, with a compatible sediment size and less than 1 percent silt or clay. At the borrow site, there will be no permanent change in substrate, again indicating that recovery will be relatively rapid. The renourishment interval will initially be five years; however, this interval will likely lengthen over time. Therefore, we feel that organisms will have adequate time to recover in between nourishment cycles.

The flora and fauna populating the currently exposed cobble regions at Sconset are typical of intertidal and subtidal habitats with sand/grave/cobble communities, and are extremely resilient to intense wave action and scouring by dislodged material during storm events. Red and brown macroalgal species and encrusting sponges dominate the cobble substrate at 'Sconset. Populations of these organisms are able to withstand disturbance regimes, with new vegetative growth and larval spawning occurring each spring. As cobble areas are covered and uncovered, new larval settlement will continue to occur, leaving the overall populations of these organisms intact.

5. I think SBPF's dredging project will upset this delicate balance [of the shoals] forever.

The borrow site is located in 30-50 feet of water inshore of the Bass Rip Shoal, not on the shoal, and will not destabilize the shoal or reduce its ability to protect the Island from storms. Even during an extreme event (a 50- year storm), modeling results show that dredging will not change existing wave patterns, sediment transport, or currents in the nearshore environment. This is because the borrow site is very small in relation to the shoals (roughly equivalent to 0.1 percent of the entire shoal structure east of Nantucket, or roughly 2 percent of the portion of the shoal structure nearest to shore), and impacts are too minor and too far away to propagate to the shoreline. Further, excavation of the borrow site will not affect the shoals or shoal crests.

Although there will be short-term impacts to benthos, the sand mining is proposed in a highly dynamic location where there is no significant aquatic vegetation and benthic organisms present are highly adaptable and hence are expected to recover within 1-3 years of disturbance. Moreover, recognizing the importance of protecting threatened and endangered species (e.g., whales and turtles), the Proponent will post a trained marine endangered species observer onboard the dredge during operation and on-shore offloading.

6. I do not see how this project is good for Nantucketers as a whole.

Since the beginning of the project design process, we have sought ways to provide direct benefits to all Nantucketers. We will preserve 'Sconset Beach and make available two public access stairways; protect the Town Sewer Beds (which would cost the Town approximately $5-7 million to relocate); create and expand protected shorebird nesting habitat (especially important since the historic nesting area at Low Beach has not yielded chicks the past two years); and protect Town infrastructure and roadways (such as Codfish Park Road, which is used for emergency access to approximately 50 homes). Further, as we have said both in recent public hearings and in our written permit documents dating back to 2005, one of our goals is saving the historic homes of Baxter Road and 'Sconset Village.

7. We can always move or rebuild structures, we cannot recreate complex ocean systems or restore cobble bottom.

Moving houses is an option we've pursued over the past 15 years that is no longer feasible. Most of the nearby landward lots are now occupied, or homes have already been moved to the most landward part of their lots. Also, moving homes does nothing to slow erosion. Left unchecked, erosion will claim all of Baxter Road and significant parts of Codfish Park and 'Sconset Village within the foreseeable future. The value of these areas is recognized by Nantucket's Planning and Economic Development Commission (NPEDC), which describes Sconset as a "living community that continues to have a strong sense of itself" and declares that the layered history of homes along Baxter Road "and their open stance on the bluff is a marvelous aspect of the town" (NPECD, 2004). The proposed beach nourishment will preserve and enhance the beauty and history of what currently exists. Finally, if for some reason it is decided not to pursue the project beyond the first nourishment, the project can be "undone" by simply stopping renourishment, which will cause the beach system to return to present conditions within a few years.

We acknowledge that cobble bottom will unavoidably be impacted due to construction, and while the majority of this cobble will be uncovered in the years following nourishment, some cobble will likely be covered longer than that. For this, we are pursuing the creation of new hard bottom habitat areas. Also, it should be pointed out that the cobble that is being covered was previously covered by beach less than a century ago when a much wider beach existed at 'Sconset and Codfish Park, yet fishing was quite good at that time given that many fishermen lived in Codfish Park.

8. SBPF should create a detailed and educated mitigation plan.

We have been carefully developing our hard bottom mitigation plan, which we presented at the October 1 Conservation Commission hearing, with considerable input from regulatory bodies, affected stakeholders, and the general public. In designing our program, we have consulted with artificial reef and fish habitat creation professionals in New Jersey, Maryland, Rhode Island, and Virginia. We are also following guidelines developed by the Atlantic and Gulf States Marine Fisheries Commissions (AGSMFC) and the Massachusetts Division of Marine Fisheries which address issues such as material selection, testing, and placement. The AGSMFC has found that concrete is a suitable, high-quality material for use in artificial reef creation, based on the monitoring of reefs created from various material types dating back to the 1950s.

A study conducted by the New Jersey Bureau of Marine Fisheries on various options for reef habitat concluded that concrete is equal to natural rock in providing a substrate for the successful colonization of marine organisms when promoting fish habitat creation. Monitoring results have also consistently demonstrated an increase in biological productivity at the reef creation sites. For example, in Jamestown, R.I., local fishermen were promoting fishing at the reefs within a year of their construction. Permitting of the reef will occur concurrently with the beach nourishment project, and reef creation will be a clear stipulation in our local and state permits.

9. SBPF should be required to post a significant bond [for project impacts].

We will be placing funds in escrow to be used in the event of adverse impacts. We are willing to provide direct compensation to fishermen who experience a demonstrated lower catch as a result of the project, and are continuing to discuss an appropriate framework

with the fishermen. I