My View
By John Osborn

The following My View is written in response to "Voices Away from the Bluff," featuring David Roby, published in the November 28 issue of The Nantucket Independent.

While Mr. Roby advocates that we should simply let Baxter Road and Sconset Village slip away, I believe this would be devastating to the island and

wish to address several of his specific comments.

1) Beach nourishment is a tried and tested practice with predictable outcomes.

We disagree with Mr. Roby that we cannot predict any outcome from beach nourishment. Unlike the terraces which were very innovative, beach nourishment is a standard practice along many coastal communities. Beach nourishment has been practiced for over a century, leading to significant scientific advances in modeling and understanding its impacts. We evaluated potential impacts from the project along the nearshore and at the borrow site using state-of-the-art modeling combined with wave/current measurements and conservative assumptions. Our project engineers considered not only model output, but also their experience with actual construction of over 60 projects, to design the project and assess its potential impacts. These models were not available or used to assess the potential performance of terraces or the dewatering systems.

We believe many of the concerns expressed by Mr. Roby and others about the terraces are being resolved through SBPF's new design for the terraces, which uses fewer wooden posts and a different fabric configuration. During Noel, no material was lost from the terraces repaired with this new design. We will continue using this new design and are working on getting it permitted for the entire terraced area. Once beach nourishment is complete, we will no longer use terraces but will instead stabilize the bank by placing additional sediment to bring it to a more gradual angle and planting it with native vegetation.

2) The project will provide many benefits.

While Mr. Roby dismisses the project's benefits, we believe the following benefits cannot reasonably be ignored: saving a treasured part of Nantucket's history at Sconset Village, improving public access to the beach, maintaining natural sediment flow and supply along the beach, providing habitat for protected shorebird species, maintaining an important part of the Town's tax base, and preserving a magnificent stretch of shoreline. We acknowledge that the project will result in some unavoidable coverage of cobble habitat (less than 5%) and are proposing to replicate this habitat in locations chosen by local fishermen. Losing Sconset because we chose to do nothing would be devastating, especially when there is a feasible way to save this beautiful piece of Nantucket history.

3) The project has received favorable review from state environmental agencies. Beach nourishment is the state's preferred shoreline protection method.

Mr. Roby's statement that the project "poses unacceptable risk" to the ecosystem is unsupported by Massachusetts environmental law and regulations. The Massachusetts Environmental Policy Act requires the Massachusetts Secretary of Energy and Environmental Affairs to facilitate a broad public review of projects that require state actions to avoid damage to the environment. On January 29, 2007, Secretary Bowles issued a MEPA Certificate stating that the Sconset Beach Nourishment Project had complied with the MEPA statute and required no further review. Specifically, Secretary Bowles wrote: "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." Furthermore, the MA Wetlands Protection Act encourages the use of beach nourishment as a best practice for addressing problems of shoreline erosion. The beach nourishment proposal has been supported by the Massachusetts Office of Coastal Zone Management, the state agency responsible for overseeing the multiple uses of the Massachusetts coastline. Finally, the Natural Heritage and Endangered Species Program, which is responsible for administering the Massachusetts Endangered Species Act, stated in its comment letter to the Secretary of Environmental Affairs that the beach nourishment project will likely improve and create nesting habitat for piping plovers and least terns between Low Beach and Hoick's Hollow.

4) The project has been deemed feasible by outside experts.

Beach nourishment has been shown to work throughout the United States and around the world. Independent experts have reviewed the project and have determined its design is technically sound. The primary concern is with the coverage of offshore cobble, not the feasibility of the project as Mr. Roby indicates. SBPF is also concerned about the cobble and thus is proposing to mitigate for any cobble that is covered. Again, experience and science shows that mitigation can be highly successful and the SBPF is proposing a pilot project to demonstrate success of the mitigation concept prior to imple- mentation of the beach nourishment project.

5) Long-term impacts from the project will be minimal.

Mr. Roby is mistaken in his assessment that the project will result in major long-term impacts to the ecosystem. The U.S. Army Corps of Engineers undertook a 7-year monitoring program to assess the impacts of a beach nourishment project completed in New Jersey that was 10 times larger than the one proposed for Sconset. Based on monitoring adult fish, benthic species, shorebirds, fish eggs and larvae, turbidity and suspended sediment, stomach content analyses, and surveys with recreational fishermen, the study concluded that there was no longterm impact to the marine environment. Nearshore recovery occurred within 2 to 6.5 months; offshore recovery occurred within 2 to 2.5 years.

Further, the marine environment along the Sconset coast is primarily defined by wave energy, tidal currents, and sand movement. All of the species that occur in the area do so because of these factors. Because the Sconset project will not change any of these factors, environmental impact will be short-term. As for the hard bottom that will be covered by sand, SBPF will establish new hard bottom close to the project area, a practice that has been successful in other states for mitigating impacts to buried limestone reefs.

6) Relocating structures is not a viable option for an entire community.

We disagree with Mr. Roby that the only option is "relocation of the threatened buildings." Agencies responsible for implementing national and state environmental policies, including the Massachusetts Environmental Policy Act Office and the US Army Corps of Engineers, concurred that we had adequately evaluated potential alternatives. The alternatives we considered were: simply doing nothing, moving houses, structural options (such as sea walls, revetments, and groins), beach nourishment, and various upland and offshore sand sources. Our analysis demonstrated that beach nourishment was the preferred option and that moving an entire community was infeasible. While moving structures is viable for a very limited number of structures, it is simply not possible to move an entire community and have it remain a community. Ultimately, all of Baxter Road and Sconset Village would need to be moved. We feel it is far better to protect the existing community than to let one of Nantucket's historic highlights simply slip away.

7) Beach nourishment provides an environmentally responsible means of protecting our homes and Sconset Village.

We cannot understand Mr. Roby's comment that "we should not seek to avoid" losing our homes by implementing beach nourishment. We all seek to avoid losing our homes every time we weatherproof

them, repair them, or buy homeowner's insurance.

Further, detailed scientific studies do not support Mr. Roby's claim of a "massive disruption" from the project. The previously-mentioned longterm studies conducted by the Army Corps of Engineers in New Jersey demonstrated that nearshore organisms recovered after beach nourishment in 2 to 6.5 months. Additionally, beach nourishment does not alter existing, natural sediment transport processes; rather, it simply adds more sand to the beach so that these natural processes can continue without threatening nearby structures. Overall, we feel that losing Baxter Road and Sconset Village would be far more disruptive to the island than carefully implementing a well-designed beach nourishment project.

8) We are proposing a pilot mitigation program to demonstrate the efficacy of our mitigation concept prior to the implementation of beach nourishment.

Mr. Roby questioned the impacts of dredging and the efficacy of replacing hard bottom habitat. Numerous studies have been completed by scientific and government agencies that have assessed the impacts of sand dredging and beach nourishment. Studies of borrow sites including a comprehensive study by the National Research Council concluded that sandy benthic habitats fully recover within one to three years after disturbance. Studies by the New Jersey Division of Fisheries and Wildlife have documented creation of fish habitat using boulder, concrete and other materials. Despite the abundance of independent data to support the fact that the environment will recover quickly and that hard bottom habitat can be successfully replicated, SBPF is proposing to implement a pilot mitigation program that will place boulders in the water in early spring 2008 and evaluate benthic colonization and fish habitat usage in the subsequent year before beach nourishment commences. This will provide site specific information on habitat recovery associated with the proposed hard bottom mitigation.

9) We risk far more by doing nothing than by implementing a proven shoreline protection method.

Beach nourishment is a proven method for stabilizing eroding shorelines, and the project at Sconset is far from being an experiment as Mr. Roby states. The coastal engineering consultants for SBPF have constructed over 60 beach nourishment projects. Throughout the design process, we have consistently sought to avoid or minimize impacts, and SBPF is willing to demonstrate we can mitigate the unavoidable impact to cobble habitat prior to implementing the project. We agree that the stakes are high, in that the do nothing approach Mr. Roby advocates ensures the destruction of the Sankaty Bluff.

Sincerely,

- John Osborn