DMF COMMENT Landry and Allen to Concom 9-6-22The Commonwealth of Massachusetts
Division of Marine Fisheries
251 Causeway Street, Suite 400, Boston, MA 02114
p: (617) 626-1520 | f: (617) 626-1509
www.mass.gov/marinefisheries
CHARLES D. BAKER KARYN E. POLITO BETHANY A. CARD RONALD S. AMIDON DANIEL J. MCKIERNAN
Governor Lt. Governor Secretary Commissioner Director
August 30, 2022
Barnstable Conservation Commission
Town Hall
200 Main Street
Barnstable, MA 02601
Dear Commissioners:
The Division of Marine Fisheries (MA DMF) has reviewed the request for Amended Order of
Conditions by Marc Landry and Nancy Allen for the proposed construction of a boardwalk with
kayak racks and a platform at 494 Elliot Road on the Centerville River in the Town of
Barnstable. Changes to the initially proposed plans include a change in boardwalk location and
the addition of an in-water fixed 6’ x 12’ platform with stairs. The project was reviewed with
respect to potential impacts to marine fisheries resources and habitat.
The proposed boardwalk would overly salt marsh vegetation. Salt marsh provides a variety of
ecosystem services, including habitat and energy sources for many fish and invertebrate species
[1–3].
The Centerville River has been identified as important habitat for white perch (Morone
americana) and tomcod (Microgadus tomcod) and is important migration habitat for alewife
(Alosa pseudoharengus) and American eel (Anguilla rostrata).
The Centerville River acts as winter flounder (Pseudopleuronectes americanus) spawning
habitat. Winter flounder enter the area and spawn from January through May; demersal eggs
hatch approximately 15 to 20 days later. The Atlantic States Marine Fisheries Commission has
designated winter flounder spawning habitat as a “Habitat Area of Particular Concern” (HAPC).
The 2020 Southern New England/Mid Atlantic management track stock assessment indicates
that although overfishing is not occurring, the stock remains overfished. Spawning stock biomass
in 2019 was estimated to be 32% of the biomass target [4]. Given the status of the winter
flounder stock, every effort should be made to protect the species and its spawning habitat.
MA DMF offers the following comments for your consideration:
• The narrative states that grated decking will be used to reduce shading impacts from the
proposed boardwalk. While MA DMF supports the use of grated decking, it should not be
used as a substitute for adequate decking height as a means of reducing shading impacts
to underlying salt marsh vegetation. MA DMF conducted two field studies to assess the
relationship between shading, marsh growth, and dock design; these studies collectively
indicated that a height to width (H:W) ratio of 1.5:1 reduced shading and marsh loss
relative to the typically required 1:1 H:W ratio for both traditional plank decking and
grated decking designs. Grated decking alone did not reduce shading impacts or
associated marsh loss [5-6]. As a result, grated decking should not be used as a substitute
for adequate height above salt marsh vegetation. MA DMF recommends establishing a 6-
foot minimum separation between stringers and salt marsh and/or reducing pier width to
maintain a 1.5:1 H:W ratio across the full extent of the marsh [7].
• Current plans do not clearly show the location of the proposed kayak racks. MA DMF
recommends the kayak racks be located outside of the salt marsh habitat to reduce
shading on salt marsh vegetation. If construction plans do not allow kayak racks to be
located outside the salt marsh habitat, then MA DMF recommends that the racks be
reduced in size or removed.
• Construction activity, including staging of construction material and equipment as well as
equipment transit to and from the construction site, should avoid intertidal habitat to the
greatest extent practicable. As much work as possible should be conducted from the
upland portion of the project site to minimize impacts and avoid compaction of sediment.
Any work in the intertidal zone should be limited to low tide such that work is conducted
in the “dry.”
Questions regarding this review may be directed to Amanda Davis in our New Bedford office at
Amanda.davis@mass.gov.
Sincerely,
Amanda Davis
Environmental Analyst
MA Division of Marine Fisheries
cc:
Arlene Wilson, A.M. Wilson Associates, Inc.
John Logan, John Sheppard, Emma Gallagher, MA DMF
AD/eg
References:
1. Boesch DF, Turner RE. Dependence of fishery species on salt marshes: the role of food
and refuge. Estuaries. 1984;7: 460–468.
2. Deegan LA, Garritt RH. Evidence for spatial variability in estuarine food webs. Mar Ecol
Prog Ser. 1997;147: 31–47.
3. Deegan LA, Hughes JE, Rountree RA. Salt marsh ecosystem support of marine transient
species. In: Weinstein MP, Kreeger DA, editors. Concepts and Controversies in Tidal
Marsh Ecology. Kluwer Academic Publisher, The Netherlands; 2000. pp. 333–365.
4. ASMFC. 2020. Southern New England Mid-Atlantic Winter Flounder 2020 Assessment
Update Report. http://www.asmfc.org/uploads/file/6008bd822020_SNE-
MA_WinterFlounderAssessmentUpdate.pdf
5. Logan, J.M., A. Davis, C. Markos, K.H. Ford. 2018. “Effects of docks on salt marsh
vegetation: An evaluation of ecological impacts and the efficacy of current design
standards.” Estuaries and Coasts 41:661–675. https://doi.org/10.1007/s12237-017-0323-1
6. Logan, J.M., S. Voss, A. Davis, K.H. Ford. 2018. “An experimental evaluation of dock
shading impacts on salt marsh vegetation in a New England estuary.” Estuaries and
Coasts 41:13–24. https://doi.org/10.1007/s12237-017-0268-4
7. Logan, J.M., A. Boeri, J. Carr, T. Evans, E.M. Feeney, K. Frew, F. Schenck, and K.H.
Ford. 2022. A review of habitat impacts from residential docks and recommended Best
Management Practices with an emphasis on the northeastern United States. Estuaries
Coasts 45: 1189–1216. https://www.mass.gov/doc/dock-bmp-
recommendations/download