MY VIEW
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By Art Broll

The following My View is written in response to "Voices Away from the Bluff," featuring Jay Starr, published in the November 21 issue of The Nantucket Independent.

Mr. Starr's interview contained several observations and misstatements I would like to clarify.

1) Most of the terraces have been replaced with a new design that minimizes loss of material during storms; terracing efforts will be discontinued once beach nourishment is complete. The Codfish Park dewatering system appears to have contributed to accretion in the area and will be utilized in conjunction with beach nourishment.

Mr. Starr questioned the status and efficacy of the Codfish Park dewatering system. After it was upgraded in December 1999, this system operated concurrently with significant accretion of the beach (approximately 120 feet), until it finally had to be turned off because so much sand had accreted that its discharge pipe was buried. Once it was turned off in 2002, the trend of erosion resumed. Given its previous positive impact on maintaining and increasing beach width, the Codfish Park system (which will be reburied by the beach nourishment project) will be utilized as part of the beach nourishment project to slow erosion and lengthen the time between renourishments.

Mr. Starr also expressed questions about the terraces and their performance during Noel. The majority of the terraces have been repaired with a new design that requires fewer posts and maintains more fabric on-site during storms. As a result, during Noel, none of the jute material was lost from the terraces repaired with the new design. There is also a smaller area of terraces that are constructed from an older design; these terraces were damaged and SBPF promptly dispatched crews to clean-up all debris. SBPF is currently working with the local Conservation Commission to amend the permit for this smaller area to the new design. Once the new design is approved for use in this area as well, we expect that loss of material during storms will be minimal. Finally, we've modified the project design to eliminate terraces from use once the beach nourishment project is completed. We will instead stabilize the bank by adding additional sediment to bring it to a more gradual angle and planting it with native vegetation.

2) Beach nourishment projects over 100 times larger than 'Sconset have been successfully undertaken.

Mr. Starr is mistaken in his statement that "This size of a project has never been done before." Beach nourishment projects exceeding 2.6 million cubic yards (note that the initial 'Sconset project is now proposed at 1.8 million cubic yards) are undertaken quite regularly. Entire islands have been constructed in Dubai in the hundreds of millions of cubic yards. While this is an extreme example, our coastal engineers from Coastal Planning & Engineering have built numerous projects of several million cubic yards including Panama City at 9 million cubic yards, Chaland Headland Restoration Project at 3.4 million cubic yards, Western Fire Island and Fire Island Pines Renourishment Project at 1.1 million cubic yards, Anna Maria Island at 2 million cubic yards, and Longboat Key at 1.8 million cubic yards, to name a few. While these projects have different wave climates, nourishment intervals, specific site conditions, and fill material, the underlying principles remain the same when designing a beach project. The engineers are experienced in this field and have analyzed and presented the expected performance of the project. The proposed project has been reviewed by independent coastal engineers and found to follow standard coastal engineering practice and be a feasible project.

3) Public access will be provided to the nourished beach, during and after construction.

Unlike many coastal communities where the landowner's property includes the beach, Sconset Beach is primarily owned by the Town of Nantucket, as well as by private individuals and organizations. SBPF is requesting permission from each property owner; in return, SBPF is committed to providing improved public access to the beach. We expect that the nourished beach will provide enhanced recreational opportunities for the general public, as well as restore and create nesting habitat for protected shorebird species. Further, most of the beach will be open to the public during construction, as the contractor will only close off the immediate construction area for safety reasons.

4) SBPF has proposed multiple actions to avoid environmental impacts, as well as mitigation measures for unavoidable impacts.

SBPF has benefited from several decades of experience in evaluating the potential impacts of beach nourishment projects to avoid impacts and propose appropriate mitigation for unavoidable effects. Steps that will be taken to avoid potential impacts from the project include (1) adherence to a time-of-year restriction which will prohibit construction between January and June when cod, winter flounder, and other sensitive groundfish species spawn in the area; (2) establishment of an exclusion zone that protects the densest hard bottom habitat from being exposed to the dredge and its propellers; (3) implementation of a shellfish harvest and relay program to remove and re-seed surfclams and other commercially important shellfish from the borrow site prior to dredging; and (4) posting of a marine protection observer on the dredge during construction to prevent potential negative interactions with protected marine species. For unavoidable impacts associated with habitat burial, SBPF has proposed recreating hard bottom habitat at a site selected by a local fishermen group. While there has been a substantial amount of scientific study showing that mitigation of marine habitats has a high degree of suc- cess, SBPF proposes to prepare a portion of the mitigation a year prior to construction to demonstrate successful habitat colonization. In addition to this extensive program of impact avoidance and mitigation, SBPF will conduct detailed post-construction monitoring to demonstrate that real impacts are the same or less than that which was predicted; if impacts are greater, then additional mitigation will be required. SBPF has also proposed compensating fishermen for any lost revenue and to request a waiver from the federal 3-mile restriction on striped bass catch.

5) SBPF is committed to funding beach nourishment for the foreseeable future. SBPF will also provide financial assurances to be used in the event of adverse impacts.

SBPF is committed to funding renourishment activities for the foreseeable future. In the event SBPF can no longer fund renourishment, the beach will simply return to the conditions we experience today; no public cost or action will be required. Also, while we are confident there will be no unanticipated negative impacts from the project, SBPF will provide financial guarantees should adverse impacts occur.

6) Beach nourishment seeks to manage erosion, not to change sediment transport patterns.

While Mr. Starr states he sees "no protection from erosion," we can choose to manage erosion in an environmentally responsible way. Beach nourishment does not seek to stop the natural processes of sediment transport and erosion, rather to build a wider beach so that natural erosion and sediment transport can occur without damaging properties. Beach nourishment is therefore considered the preferred shoreline protection method in Massachusetts' environmental policies; beach nourishment is also the Federal Emergency Management Agency's (FEMA's) preferred plan for coastal hazards management.

7) Long-term impacts to fishing and waterbird habitat will be minor.

Beach nourishment is the preferred shoreline erosion control practice because it does not alter natural sediment transport processes and the marine ecology dependent on it. This position is codified in the MA Wetlands Protection Act regulations which consider beach nourishment projects preferable to coastal structures. Scientific study supports this position. For example, a recent 7-year environmental study by the US Army Corps of Engineers of a beach nourishment project in New Jersey ten times the size of that proposed for Sconset concluded that the project had no long-term impact on the marine ecology of the area. Dredging and beach building techniques are well-proven and environmental protection strategies are employed throughout the process. We believe these facts run contrary to the assertion that the project will ruin the fishing habitat in the area.

Additionally, Mr. Starr's assertion that the project will ruin habitat for birds cannot be supported. While waterbirds migrate to the areas offshore Nantucket near the borrow site, extensive surveys have shown that the primary habitat areas for the birds are outside the borrow site. The project will have no impacts on the birds' preferred habitat areas, and construction will be occurring during the months when very limited

numbers of waterbirds are present offshore, so overall impacts to waterbirds will be minor or negligible.

8) Construction will only be directly apparent in a given area for 2 to 4 days. The renourishment interval will eventually be every 5 to 7 years.

Mr. Starr incorrectly envisions a major disturbance to the beach. We've carefully considered project sequencing and operations to minimize disturbances to homeowners and vacationers in the area. We expect that construction of the project will only be directly apparent in a given area for 2 to 4 days, as the contractor will move along as the beach is being built. Most of the beach will be open during construction, as the contractors are used to working in tourist or resort areas and will only close off a small section of the beach at a time for safety considerations. The commencement of construction has been pushed back from June 1 to about July 15 to minimize summer disturbance. While the initial project will require nourishment after three years, thereafter nourishment will only be required every 5 to 7 years.

9) Many of the homeowners on the bluff have been on the island for generations.

We take great offense to the comment that our home is simply part of a portfolio. Quite the contrary, not only is this our home but we have celebrated many family milestones here over several generations. We have shared our homes and our love for this island with our children and grandchildren. We look forward to continuing to live in our home for many years to come.

Sincerely,

- Art Broll