LETTERS
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GOOD WORK

To the editor:

I think we all owe a round of cheers and thanks to the DPW of Nantucket for the remarkable clean-up job they managed after the "hurricane" nor'easter. I spent a bunch of hours during the storm and Sunday pulling large branches out of Main Street and Monument Square where I live, and where there were potential traffic hazards. By 11 a.m. Monday, the DPW had collected them all from the sidewalks and driveways and had swept the massive pieces of leaves as well. Add that to clearing the major arteries like Milestone and Madaket Roads, and one can only say, "Thanks and bravo."

Now one hopes that the town's arborist will only work as diligently to remove the large and potentially dangerous broken branches still dangling from the town-owned trees along Main Street. And that Verizon might repair their phone cables and restore phone service in less than the five days their recorded announcement "promised." They could learn a lot from the DPW.

Very truly yours,

- Stephen J. Jelin

THE PREFERRED ALTERNATIVE

The following letter is written in response to an op-ed piece written by geotechnical civil engineer Donald C. Wotring that appeared in the Oct. 31 issue of The Nantucket Independent.

To the editor:

As the project engineers for the 'Sconset Beach Nourishment Project, we appreciated Dr. Wotring's comments in the October 31, 2007 opinion column. He has obviously taken the time and effort to perform background research on beach nourishment and is raising questions based on scientific grounds. We wanted to expand and respond to a few of Dr. Wotring's points.

Questions were raised regarding biological impacts to the borrow area. The SBPF has already investigated and presented solutions to many of the concerns raised in Dr. Wotring's letter, such as the relocation of surf clams from within the borrow area prior to dredging and turbidity modeling. The maximum dredge depth of the borrow area has also been designed to ensure that the substrate is similar before and after dredging.

Dredging the borrow area will obviously alter the bathymetry within the borrow area. However, we disagree with Dr. Wotring's assertion that we cannot realistically predict impacts of dredging. Coastal engineering has advanced in its ability to accurately predict such phenomena as wave modification due to the excavation of borrow areas. The advances are based on both greater experience with the construction and monitoring of beach nourishment projects, as well as advances in coastal modeling and greater computational power available to coastal engineers. Borrow area impact analyses are performed for the large majority of borrow areas that CPE has designed. We have constructed over 60 beach nourishment projects, and defined several more borrow areas for the U.S. Army Corps of Engineers (USACE). We have successfully predicted the effects of dredging borrow areas that are much closer to shore than the one at 'Sconset. The manual Dr. Wotring quoted (EM 1110-2-330) suggests modeling of the borrow area; if such modeling were unrealistic it would not be suggested. Furthermore, we not only applied the model suggested in the manual (GENESIS) but also applied Delft-3D, which is a state-ofthe art model, not available when EM 1110-2-3301 was printed. Lastly, an independent coastal engineer hired by the town concluded that the "contention that the borrow area will have a negligible effect on the wave climate is a reasonable assertion consistent with observed performance and standard practice."

Dr. Wotring also referenced dredging of an ebb shoal but ebb shoals are related to tidal inlets, the nearest example being at Smith Point. Ebb shoals are located close to shore, in shallow water, and wrap around an inlet. We are not proposing to dredge an ebb shoal or any other kind of shoal. The proposed borrow area for 'Sconset is more than three miles offshore with an average depth of 41 feet. The closest point of the proposed borrow area is more than one quarter of a mile from the crest of Bass Rip Shoal.

As with all civil engineering projects, beaches require upkeep and monitoring. SBPF has been upfront in stating that the beach will require maintenance and that the initial and any future projects will be privately funded with no request for public funding. While many other communities have seen that the public benefit of maintaining their beaches extends beyond the homeowners fronting the beach, the SBPF members recognize that private interests will benefit therefore they are not seeking public funding.

We must also disagree with Dr. Wotring's comment that the monitoring program is "another indication of SBPF's lack of forethought and planning." A full-scale monitoring program has been proposed within the Final Environmental Impact Report that exceeds industry standard. EM 1110-2-3301 suggests that monitoring extend one mile updrift and down drift of the project. SBPF has been surveying from Wauwinet (2.4 miles north of the project area) to the Town Sewer Beds for the last 15 years.

Dr. Wotring stated that beach nourishment projects have been successful. We agree. Beach nourishment has been used for decades and has proven to be an effective means to protect and enhance hundreds of beaches throughout the coastal United States and the world. It is the preferred alternative for coastal hazards management by state and federal regulators. We are confident that it will be successful at 'Sconset as well.

- Richard Spadoni is senior vice-president and Gordon Thomson, P.E.is senior coastal engineer

of Coastal Planning & Engineering, Inc.

IN RESPONSE TO LAFARGE

The following letter is in response to the "Voices Away from the Bluff" featuring Bam LaFarge published in the Nov. 7 Nantucket Independent.

To the editor:

I would like to address several of the misrepresentations in Mr. LaFarge's statements.

1) The existing beach is not serving its natural functions of storm damage protection and shorebird habitat.

While Mr. LaFarge states that 'Sconset beach "doesn't need any help," the existing beach is so narrow that it has stopped serving some of its vital functions, including protecting the bluff and upland areas from storm damage and providing nesting habitat for protected shorebird species. Further, recreational use of the beach is also diminished by its narrow width, and the beach is occasionally impassable due to waves reaching the toe of the bluff.

2) The nourished beach will withstand storm conditions.

Mr. LaFarge's statement that "one storm could easily undo all the work of moving 2.6 to 3.1 million cubic yards of sand " is not credible. To provide some perspective, approximately 2.1 million cubic yards of sand was lost from the project area between December 1995 and June 2005, a nearly ten year period.

3) The National Marine Fisheries Service has determined there will be no significant impacts to protected species and we are collaborating with them to finalize mitigation measures.

The National Marine Fisheries Service (NMFS), while not a permitting agency, is commenting on our project via two different programs. First, the Habitat Protection Office reviews the project's potential impacts on Essential Fish Habitat (EFH) and recommends "conservation measures" to mitigate for those impacts. SBPF has coordinated with technical staff from NMFS, including in the design and implementation of the fisheries sampling plan and in the presentation of the project design and potential impacts. NMFS Habitat staff has provided comments during both the state MEPA review and through the US Army Corps of Engineers (USACE) review under the Clean Water Act. We believe that NMFS and the USACE will accept the mitigation measures along the lines we have proposed as appropriate conservation measures for EFH impacts. Second, the NMFS Protected Species Office is responsible for reviewing the project's potential impacts on marine species protected under the Endangered Species Act and the Marine Mammal Protection Act. The NMFS Protected Species Office has determined that the project will not have a significant impact on protected species (including sea turtles, whales, and fish). While mitigation measures for EFH are still being finalized, the statement that NMFS's assessment of the project is "severe" is not accurate.

4) The nourished beach will look like the existing beach.

The nourished beach at 'Sconset will look like the natural beach, as the sediment from the borrow site is an extremely close match in terms of grain size and color. The constructed beach slope will be similar to the existing, measured beach slope. Piping Plovers and Least terns, which are the only nesting species along the beach (and are only in 2 locations), are known to nest where sandy material is deposited. These shorebirds will benefit from the creation of over 80 acres of additional habitat. While sea turtles do not nest in our area, it is well established that they will heavily and successfully nest a nourished beach - further demonstrating that nourished beaches support wildlife habitat.

5) Construction will require modest amounts of equipment and will only directly inconvenience a limited area for 2-4 days.

Beach nourishment projects are typically 24-hour operations; however, the contractor will move along as the beach is built, so any particular area will only be directly inconvenienced for two to four days. Mr. LaFarge misrepresents the amount of equipment required: the project will require modest lighting (one stand containing 4 lights) and bulldozers. There will be one 30-inch wide pipeline (with only about a half-mile section in use at a given time) coming ashore and this will be raised off the bottom by approximately one foot. The contractors have safety measures in place to avoid accidents and fuel spills (federal laws govern much of this). While renourishment will be required every few years, only about half the volume of sand is needed so the construction period will be much shorter.

6) The project is proposed to protect what exists, not to spur new development.

While Mr. LaFarge indicates the project will lead to dense development, SBPF's proposal simply calls for protecting the beauty and three-century history of what currently exists; we are not proposing, and do not anticipate, any additional development. Well-designed beach nourishment projects have repeatedly shown that they protect upland areas during storms.

7) Assessment of impacts to the biological, physical, economic and social environment indicates that beach nourishment is warranted.

In regards to Mr. LaFarge's comments about the Essential Fish Habitat (EFH) assessment, the impacts to affected biological, physical, economic, and social environment have been addressed in the Expanded EFH assessment submitted to the US Army Corps of Engineers by SBPF. The assessment shows that the erosion of the Sankaty bluff will initially affect 30-40 homes, followed by Baxter Road, water and sewer utilities, and the town's sewer beds; and therefore it is in the town's long-term social and economic interests to support a solution to the erosion; that beach nourishment is the most environmentally protective (both physical and biological) means for addressing the erosion of the bluff; and that this project, with mitigation, can be completed with no long-term adverse effect to waters of the United States (the area over which the Corps holds jurisdiction).

8) The borrow site has enough sand for the initial project and a subsequent renourishment.

The existing borrow site has sufficient sediment for the first and second projects. Additional investigations will ultimately be performed to locate the additional sand sources that will be required for subsequent renourishments.

9) Mitigation will result in no net change in habitat type. A pilot mitigation project will be undertaken to demonstrate effectiveness of proposed mitigation strategies.

As sand from the beach nourishment project naturally moves offshore, the project will result in an unavoidable conversion of some 5 percent of 'Sconset's hard-bottom, cobble habitat to a sandy habitat. The mitigation site will convert sand habitat back to hard bottom. The result will be no net change in habitat type, contrary to Mr. LaFarge's assertion. SBPF has recently received a map from six local fishermen with intimate knowledge of the marine habitat in the area which suggests three potential locations for mitigation. SBPF is presently collecting site-specific information on these areas to select an area characterized by sand that can be converted to hard bottom. SBPF is also working with the fishermen to ensure that the design and location of the proposed mitigation sites both replicates the low relief rock cobble that will be impacted by the project and diversifies the available habitat by utilizing a variety of substrate types (e.g., railroad ties, reefballs) in addition to cobble. The revised mitigation plan will be submitted to the Conservation Commission and state and federal regulatory personnel in coming weeks. The plan includes a small-scale, "pilot" testing of the mitigation strategy to demonstrate its efficacy prior to implementation of the beach nourishment project and full-scale mitigation plan.

10) The project will not destabilize the shoals.

We have taken great care to ensure that we are not mining offshore shoals. The average depth of the borrow area is 41 feet and the closest point of the borrow area is over a quarter of a mile away from the crest of Bass Rip Shoal. Stateof the-art modeling has shown that there will be no adverse impacts to the shoreline or the shoals. The modeling also conservatively assumed complete dredging of the borrow area, whereas the initial nourishment will remove less than half of this volume. Thus, even a conservative assessment determined there would be no negative impacts.

11)We can choose to manage erosion so that it does not damage properties.

While Mr. LaFarge suggests we cannot control erosion, beach nourishment is not about stopping the natural processes of sand transportation and erosion; rather, it is about adding enough sand to the beach so that natural erosion can occur without damaging adjacent properties.

12) Previous erosion control efforts were very innovative: the terraces are required to be temporary and pervious yet still protected the bluff; the dewatering systems had mixed results.

The dewatering systems were very innovative and had mixed outcomes. The system at Codfish Park, after being upgraded in December 1999, operated coincidentally with significant accretion (approximately 120 feet); after it was turned off in 2002 when accretion buried its discharge pipe, erosion returned. The Codfish Park system, along with a system with similar capacity located north of Bayberry Lane, will be utilized as part of the beach nourishment project to slow erosion and lengthen the time between renourishments. The terraces are required by local regulations to be temporary and pervious; therefore, they are designed to withstand storms for only two days and fail during longer storms. While Mr. LaFarge questions the efficacy of the terraces given their required short design-life, terraced portions of the bank have retreated less than nearby unprotected sections of bank.

13) SBPF is planning to fund beach nourishment for the foreseeable future.

SBPF is planning to fund renourishments for the foreseeable future. In the event SBPF can no longer fund the project, the beach will simply return to the conditions we see today - with no

required public cost or action. I

- Jimmy Haslam