Hughes to Concom 9-13-22The 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
September 13, 2022
Barnstable Conservation Commission
367 Main Street
Hyannis MA 02601
Dear Commissioners:
The Division of Marine Fisheries (MA DMF) has reviewed the Notice of Intent (NOI) by Helen
Hughes to remove an existing pier, ramp, and float and replace the structures with a permanent
access boardwalk, pier, gangway, and two 6 foot by 16.5 foot floats at 94 Long Beach Road
within the Centerville River in the Town of Barnstable. A shellfish survey performed by BSC
Group on April 5, 2022 found ribbed mussels (Geukensia demissa) within the salt marsh habitat
and no shellfish within the substrate. The project was reviewed with respect to potential impacts
to marine fisheries resources and habitat.
The project site overlies 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 project site lies within mapped shellfish habitat for northern quahog (Mercenaria
mercenaria). Subtidal waters within the project site have habitat characteristics suitable for this
species. Land containing shellfish is deemed significant to the interest of the Wetlands Protection
Act (310 CMR 10.34) and the protection of marine fisheries.
The Centerville River has been identified by MA DMF as diadromous fish passage, migration,
and/or spawning habitat for alewife (Alosa pseudoharengus), blueback herring (Alosa aestivalis),
and American eel (Anguilla rostrata).
MA DMF offers the following comments for your consideration:
• Construction plans indicate rebuilding the wooden access that overlies salt marsh and
leads up to the proposed pier. This is an opportunity to raise the access to a higher
elevation above the salt marsh and reduce shading impacts. 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 between
the base of horizontal stringers and salt marsh reduced shading and marsh loss relative to
the typically required 1:1 H:W ratio [4-5]. MA DMF recommends establishing a
minimum 1.5:1 H:W ratio across the full extent of the marsh to reduce shading impacts
[6].
• Any activities requiring a barge should be coordinated to avoid barge grounding or
operation in intertidal habitat or shallow water (less than 2 feet between motor skeg and
substrate) over mapped shellfish habitat.
• 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
in mapped shellfish habitat. 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:
Daniel A. Ojala, Down Cape Engineering, Inc.
John Logan, Emma Gallagher, MA DMF
Robert Boeri, CZM
AD/eg
References:
1. Boesch, D.F. and R.E. Turner. 1984. “Dependence of Fishery Species on Salt Marshes:
The Role of Food and Refuge.” Estuaries 7(4):460-468. https://doi.org/10.2307/1351627.
2. Deegan, L.A. and R.H. Garritt. 1997. “Evidence for spatial variability in estuarine food
webs.” Marine Ecology Progress Series 147:31-47.
https://doi.org/10.3354/MEPS147031.
3. Deegan, L.A., J.E. Hughes, and R.A. Rountree. 2000. “Salt marsh ecosystem support of
marine transient species.” In: M.P. Weinstein and D.A. Kreeger, eds. Concepts and
Controversies in Tidal Marsh Ecology: Kluwer Academic Publisher, The Netherlands.
pp. 333-365
4. 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.
5. 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.
6. 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