Wetlands Board Packets

SUFFOLK WETLANDS BOARD AGENDA FOR August 18, 2016 PREPARED BY THE CITY OF SUFFOLK DEPARTMENT OF PLANNING A MEETING WILL BE HELD AT 6:00 P.M. IN THE SUFFOLK CITY COUNCIL CHAMBERS IN SUFFOLK CITY HALL PLEASE CALL TO CONFIRM YOUR ATTENDANCE THE PLANNING DEPARTMENT AT 514-4060 PRIOR TO 12:00 NOON ON WEDNESDAY, AUGUST 17, 2016 GEOFFREY HINSHELWOOD CHAIRMAN  AGENDA SUFFOLK WETLANDS BOARD August 18, 2016 6:00 P.M. I. Call to Order II. Roll Call III. Approval of Minutes • July 21, 2016 IV. Public Hearings – VMRC#16-0900, submitted by Chuck Archer of Inlet Marine on behalf of Hillpoint Virginia, LLC for the construction of a 5-foot by 200-foot community pier with handrails within the Hillpoint Estates Subdivision. The project is located at the end of Bowman Drive and will access the Nansemond River. VMRC16-0679, submitted by Jim Cahoon of Bay Environmental, Inc., agent, on behalf of Brian Mullins of BC Marina, LLC, property owner and applicant, for the renovation and redevelopment of an existing marina, including replacement and construction of a new bulkhead; riprap; new floating docks and boat slips; new boardwalk and piers; a new marina and attached deck; and dredging of Bennetts Creek. This property is located at 3301 and 3305 Ferry Road along Bennetts Creek; further identified as Zoning Parcels 12*49 and 12*49*1, zoned RR, Rural Residential Zoning District. V. Restoration Hearings – None VI. Permit Extensions – None VII. Old Business – None VIII. New Business – None IX. Compliance and Inspections – None X. Adjournment  MINUTES SUFFOLK WETLANDS BOARD July 21, 2016 6:00 P.M. The meeting of the Suffolk Wetlands Board was held on Thursday, July 21, 2016, at 6:00 p.m., in the City Council Conference Room of the City Hall Building, 442 West Washington Street, Suffolk, Virginia. MEMBERS: STAFF: Geoffrey Hinshelwood Karla Williams, Associate City Attorney Jeffrey Colley Robert Goumas, Interim Director of C. Robbie Johnson Planning & Community Development Darius Davenport David Parks, Principal Planner Sidney Hazelwood Amanda Beck, Planner II ROLL CALL: The meeting was called to order by Chairman Hinshelwood. The roll was then called by Mr. Parks and the Chairman was informed that a quorum was present. APPROVAL OF THE MINUTES: The minutes of the previous meeting were approved as written. ELECTION OF OFFICERS: Geoffrey Hinshelwood was nominated as Chairman. This nomination was passed by a voice vote of 5 to 0. 1 Darius Davenport was nominated for Vice-Chairman. This nomination was passed by a voice vote of 5 to 0. OLD BUSINESS: Mr. Parks gave a bi-annual update on the River Bluff Living Shoreline. He advised that as required by the approving condition, staff will provide an update on the project twice a year for three years from the completion date of December 18, 2014. Therefore, staff will provide an update until December 18, 2017. Mr. Parks showed pictures from his site visit on July 21st. BOARD MEMBERS SITE VISITS: Mr. Goumas advised that staff has evaluated this proposal and believe it would be a valuable program and it would benefit the board members to go out and observe the sites, prior to the meeting. However, at this time, staff is not in a position to successfully initiate this program. Currently, the department is under staff, but once we are fully staff we will be able to implement the program in the future. Ms. Williams advised that she is hoping by the next month (September) we will have full staff and be able to implement the field trips. She advised that she sees the need for the board to see the sites that they are evaluating and deciding on. She also advised that since the board does not have applications every month, staff could approach it on a case by case basis, instead of having a standard date. 2 Mr. Goumas reiterated that once we are fully staff, staff is interested and willing to accommodate the board. He wants to make sure that when staff is out in the field on the site visits, the office is properly staffed. NEW BUSINESS: Mr. Johnson inquired about the public comment period. Ms. Williams advised that there is no prohibition against the public speaking – posing a question to the board. However, she does not see a need to a special agenda item to be added to the agenda. Mr. Johnson made a motion for a section called “public comment period” to be added to the agenda. Ms. Williams advised that the bylaws will need to be amended. However, she advised that under “New Business” the Chairman could see if anyone in the public had any comments or concerns. The board asked Ms. Williams to bring back at the next meeting the guidelines that City Council uses for non-agenda speakers. ADJOURNMENT: There being no further business, the meeting was adjourned. 3  SUFFOLK WETLANDS BOARD MT: MT: MT: MT: 2ND: 2ND: 2ND: 2ND: TO: TO: TO: TO: July 21, 2016 ATTENDANCE VOTE: VOTE: VOTE: VOTE: BOARD MEMBERS PRESENT ABSENT YES NO YES NO YES NO YES NO Colley, Jeffrey X Davenport, Darius X Hazelwood, Sidney X Hinshelwood, Geoffrey X Vroman, Robert X Johnson, C. Robert X O’Berry, Brad X Barnum, Steven - Alternate X Joyner, David - Alternate X  STAFF REPORT DESCRIPTION PROPOSED PROJECT: VMRC#16-0679, for the renovation and redevelopment of an existing marina, including replacement and construction of a new bulkhead; riprap; new floating docks and boat slips; new boardwalk and piers; a new marina and attached deck; and dredging of Bennetts Creek. APPLICANT: Submitted by Jim Cahoon of Bay Environmental, Inc., agent, on behalf of Brian Mullins of BC Marina, LLC, property owner and applicant. LOCATION: The property is located at 3301 and 3305 Ferry Road along Bennetts Creek. PERMIT HISTORY: There has been one previous permit for this property. In 2006 VMRC#06-1000 was filed after the fact to permit an increase in the number of boat slips, another floating dock, and to relocate an existing shedding bin. The permit was denied by the Suffolk Wetlands Board, and the after the fact additions were removed. Also, the applicant was notified by the Planning Division that this was an increase in intensity of use and would require a conditional use permit for the zoning district to be approved for use. VIMS REPORT: A VIMS report for this property was completed and submitted to the City of Suffolk Wetlands Board on August 10, 2016. There are no other VIMS reports for this property. STAFF ANALYSIS ISSUE This property consists of a vacant marina and restaurant, both in disrepair. Currently, on site there are two floating docks, five finger piers, 26 boat slips, and an open-pile pier. The existing 392 linear feet of bulkhead has started to fail, as evidenced on a site visit during which erosion behind the bulkhead was present. The existing boat ramp has accumulated sediment from lack of use, and will be removed by the applicant. The shoreline is defined along the marina proper by the bulkhead and restaurant, and to the southeast by a saltmarsh vegetated with Spartina alterniflora; most of the uplands for this site are existing impervious surfaces consisting of gravel and concrete, although the uplands directly behind the existing building at 3301 Ferry Road is mature trees and shrubs. The applicant is requesting to renovate and redevelop the existing marina and restaurant. The proposed project will involve removal of all the existing floating docks, finger piers, and boat slips to construct a 550-foot floating dock with fourteen (14) 24-foot finger piers; one 46-foot finger pier; three 40-foot finger piers; and four 30-foot finger piers. The main floating dock will be connected to a 143-foot floating dock, which will be accessible from the shoreline via a 4-foot by 26-foot gangway. Forty-four boat slips will be associated with the new floating dock in addition to 5 additional mooring piles. Additionally, the applicant is proposing to build a floating dock directly adjacent to the bulkhead and the future restaurant, to be used as a multi‐use area for marina related events and as a staging area for restaurant patrons. North of the proposed restaurant will be devoted to a marina store and fueling dock. The fueling station will have Wetlands Board August 18, 2016 VMRC16-0679 Page 2 of 4 employee access to the floating dock via a 6-foot by 24-foot open-pile pier and 3-foot by 12-foot gangway. The fueling station is proposed to house a 2,000 gallon gas tank and a 2,000 gallon diesel tank. South of the proposed restaurant the applicant will reframe and redeck an existing 120-foot open- pile pier and construct an additional shoreline access point to the peninsula with a 5-foot by 24- foot extension. To protect the shoreline from increased boat activity at the marina the applicant is proposing to install 1,005 linear feet of bulkhead in addition to 514 linear feet of riprap along the shoreline of the saltmarsh. Sections B2-B3 and also just under the existing restaurant will be more than 2-foot channelward of the existing bulkhead. As listed in the submitted JPA application, the applicant has noted the B2 section is designed to alleviate a potential trash trap and eddy currents caused by a more perpendicular bend in the bulkhead. Additionally, the section across the existing boat ramp has been aligned to generally match the alignment of the 2- foot channelward section south of the existing restaurant primarily due to the fact that there is no bulkhead on the landward side of the boat ramp and there is no known bulkhead under the existing restaurant. The bulkhead will have permanent impacts to 120 square feet of vegetated wetlands, 1,698 square feet of nonvegetated wetlands, and 920 square feet of subaqueous lands. The applicant is proposing to compensate for impacts to vegetated wetlands through the purchase of 205 square feet of credits from the Libertyville Road Tidal Mitigation Bank. The last work associated with this application is dredging of Bennetts Creek. In preparation of a functional marina, the applicant is also requesting to dredge 1,200 cubic yards of maintenance dredging of the boat basin, as well as 3,706 cubic yards of new dredging of Bennetts Creek. The boat basin will be dredged to 3-feet below mean low water, and the rest of the dredging will be to 5-feet below mean low water. The plans submitted with this application note that dredging will be at least 17-feet from the vegetated wetlands adjacent to the peninsula. Of the proposed work, the Wetlands Board will need to consider the approval or denial to permit for the bulkhead and the riprap, as a portion of the bulkhead work fall within the Board’s jurisdiction and also the toe of the riprap. The floating docks, piers, and dredging is outside of the Wetlands Board jurisdiction and therefore will be permitted by the VMRC. A Buffer Restoration Plan will be required for all of the work proposed by the applicant, and will be handled through a Chesapeake Bay Preservation Area Exception Request as the applicant’s proposal is increasing the impervious area within the 100-foot Resource Protection Area Buffer. Land disturbance due to completion of this application, and the proposed new buildings for the marina, will be revegetated according to the Riparian Buffers Modification and Mitigation Manual and will be reviewed through a Chesapeake Bay Exception Request by the Suffolk Planning Commission. CONSIDERATIONS AND CONCLUSIONS 1. The Center for Coastal Resources Management notes that this section of bank along Bennetts Creek is stable, but does note the area of the existing marina as an area of special concern, and recommends enhancing and maintaining the marsh on both sides of Bennetts Creek. The Comprehensive Coastal Resource Management Portal also shows private oyster grounds leases along this section of Bennetts Creek, particularly listing an historic aquaculture site at the marina itself. Wetlands Board August 18, 2016 VMRC16-0679 Page 3 of 4 2. The applicant is proposing 2 separate cross sectional designs for the bulkhead design, 3 cross sections for the design of the riprap, an elevational view for the dredging activities, a cross section for the open-pile pier, and construction details for the floating docks. 3. Projected Impacts: a. Rip Rap – The applicant is proposing to install 514 linear feet of riprap along the shoreline of the saltmarsh. A minimum cut of one foot to stabilize the toe of the riprap is required, with a slope of 1:1.5, and the applicant will fill approximately 2-feet for the new proposed grade to manage storm water on site. The toe of the riprap is in Wetlands Board jurisdiction, starting right at the mean high water line, and the applicant is proposing to install the riprap landward of the existing wetlands vegetation so as not to cause any loss of wetlands vegetation. b. Bulkhead – Installation of 1,005 linear feet of bulkhead, including replacing 392 linear feet of existing bulkhead, will have minimal impact on subaqueous lands along sections B4-B6. Sections B1-B3 will have minimal impact to non-vegetared wetlands as well as permanently impact 120 square feet of vegetated wetlands from B2 to the existing bulkhead shown on the plans. The applicant has noted that this northern most portion of the bulkhead is more than 2-feet channelward of the existing bulkhead to alleviate a potential trash trap and eddy currents caused by a more perpendicular bend in bulkhead; additionally, the section of the bulkhead between B4-B5 has additional encroachment primarily due to the fact that there is no bulkhead on the landward side of the boat ramp nor under the existing restaurant, so it is more than 2-feet channelward to align it with the southern portion of the proposed bulkhead. For the permanent impacts to 120 square feet of vegetated wetlands the applicant is proposing to compensate through the purchase of 205 square feet of credits from a tidal wetland mitigation bank. It should be noted that bulkhead installation, according to the CCRM, shall be limited to navigational channels, which this project will comply with. c. Open-pile Pier – This pier is existing and the applicant is proposing only to reframe and redeck the structure, therefore there should be no impact to wetlands. This action is exempt from the Wetlands Board’s action. d. Floating Docks – The proposed floating docks will be built upon non-vegetated wetlands and subaqueous lands within Bennetts Creek and there should be no impact. This action is exempt from the Wetlands Board’s action. e. Finger Piers – Similar to the floating docks the proposed finger piers should have no adverse impact. There will be no wetland vegetation impacted by the construction. This action is exempt from the Wetlands Board’s action. f. Mooring Piles – The applicant is proposing to install 5 mooring piles west of the floating docks, which will have minimal impacts to subaqueous lands. This action is exempt from the Wetlands Board’s action. g. Dredging – No vegetated wetlands should be impacted by the proposed dredging Wetlands Board August 18, 2016 VMRC16-0679 Page 4 of 4 of the boat basin and Bennetts Creek. Specifically, the applicant has noted that there is an average distance of 18-feet from the toe of dredging to the edge of the vegetated marsh. The dredging is occurring below mean low water, with no impacts to vegetated wetlands, and is outside of Wetlands Board jurisdiction and exempt from action by the Board. The applicant should ensure this will not negatively impact any private oyster lease holders. 4. Due to the impacts within the Resource Protection Area of the Chesapeake Bay Preservation Area Overlay District the applicant will be required to submit a Buffer Restoration Plan in accordance with Unified Development Ordinance Section 31- 415(d)(1)(D), Buffer Area Requirements. The applicant will be required to show the restoration of impacted areas due to the redevelopment of the marina, which staff will handle through a Chesapeake Bay Preservation Area Exception Request as the applicant’s proposal is increasing the impervious area within the 100-foot Resource Protection Area Buffer. The Exception Request will be reviewed concurrently with the required site plan for the proposed work to construct new buildings and associated site improvements for the marina, and will be reviewed by the Suffolk Planning Commission. 5. This shoreline project will be required to obtain a land disturbance permit through the Department of Public Works. An erosion and sediment control plan will have to be prepared by the applicant and submitted to Public Works prior to any work being done on site. No building permit will be issued prior to Public Works approving the erosion and sediment control plan. RECOMMENDATION Due to the existing conditions on site, and the existing bulkhead failure, staff believes that the site in question is appropriate for the renovation and redevelopment of the existing marina. Therefore, staff recommends approval of Joint Permit Application VMRC#16-0679 with the following condition: 1. The applicant is required to have an approved erosion and sediment control plan prior to any land disturbance at 3301 and 3305 Ferry Road. 2. The applicant will purchase 205 wetland credits as mitigation for the permanent impact to 120 square feet of vegetated wetlands for this project. This purchase will be made prior to the issuance of the Wetlands Permit. No construction activity will be allowed prior to the purchase of these credits. Attachments  Exhibit A – Zoning/Land Use Map  Exhibit B – VMRC Application  Exhibit C – 2016 VIMS Report  GENERAL LOCATION MAP 5*3 3 44 66 11 22 ** 44 88 11 22 ** AA 11 22 9 ** 33 9 0 12 *4 8 12 *6 1 ** 44 0 11 22 88 ** 33 11 22 12 *4 8 B 12 *3 8 A E A VE 12 *3 5 E BE R WI N 12 *4 9 A * 22 11 22 ** 44 99 JJ * 12*49J*3 12 *4 9 E 12*4 LN 9J * 11 M 2 ** 44 99 * 44 99 HH II 11 22 * 11 22 ** 44 99 JJ * FAR * 44 99 BB 11 2 11 22 * YEATE S 9 KK 11 22 ** 44 9 DR LEE 12 *4 9 * 22 11 22 ** 44 99 * FF 12 *1 2 A *4 ** 44 99 11 22 FERRY RD 12 *3 4 B R ID G E RD B R ID G E R D 12 *1 2 M 11 22 12 *3 4 A 12 *3 4 C s 4 CC CREEK FRONT ** 33 4 LN 12 *1 2 ** CC AA 12 *3 4 E *1 VMRC16-0679 12R *20 BENNETTS CREEK 12 R *2 0 5 12 R *2 0 5 1 in = 5 0 0 ft 4 55 11 22 RR ** 11 999 44 12 *3 2 9 66 9 11 22 RR ** 11 99 9 11 22 RR ** 11 911 22 RR ** 11 9 0 33 11 22 RR ** 22 0 8 11 22 RR ** 11 99 8 11 22 RR ** 11 99 77  JOINT PERMIT APPLICATION VMRC#16-0679 CONDITIONS 1. The applicant is required to have an approved erosion and sediment control plan prior to any land disturbance at 3301 and 3305 Ferry Road. 2. The applicant will purchase 205 wetland credits as mitigation for the permanent impact to 120 square feet of vegetated wetlands for this project. This purchase will be made prior to the issuance of the Wetlands Permit. No construction activity will be allowed prior to the purchase of these credits.  VMRC16-0679 ZONING / LAND USE MAP 11 22 ** 44 88 5*3 3 44 66 11 22 ** AA 11 22 9 ** 33 9 Zoned 0 12 *6 1 ** 44 0 11 22 33 88 RR 11 22 ** 12 *4 8 B 12 *3 8 A E A VE E BE R WI N 12 *4 8 * 22 11 22 ** 44 99 JJ * 12*49J*3 12 *4 9A 12 *4 9 E 12 *1 2 A *4 12 *3 5 LN * 11 Zoned 11 22 ** 44 99 JJ * 12*4 9J ** 44 99 HH * 44 99 II 11 22 M BB 11 22 * FAR 9 11 22 ** 44 9 YEATE S 9 KK 11 22 ** 44 9 LEE RL DR * 22 11 22 ** 44 99 * ** 44 99 FF 11 22 FERRY RD 12 *4 9 B R ID G E R D Zoned 12 *3 4 Zoned B R ID G E R D B-2 O-I Zoned Zoned 12 *3 4 C RL 12 *1 2 M B-1 11 22 4 CC 12 *3 4 A s ** 33 4 Zoned CREE KFRO NT LN RU ** CC AA 12 *3 4 E *1 12 *1 2 1 in = 5 0 0 ft BENNETTS CREEK 12R *20 12 R *2 0 5 Zoned 4 55 11 22 RR ** 11 99 RR 1 9 66 9 77 9 1 22 RR ** 11 9 11 22 RR ** 11 99 9 11 22 RR ** 11 9 12 *3 2 9 44 0 33 11 22 RR ** 11 9 8 11 22 RR ** 11 99 8 11 22 RR ** 22 0  VIMS Tidal Shoreline Management Recommendation (VMRC #16-0679) Applicant: Bennett’s Creek Marina, LLC Address: 3301 Ferry Road, Suffolk, VA Waterbody: Bennett Creek Date: August 10, 2016 Preferred Options for Shoreline Management The shoreline best management practice(s) recommended in this report reflect(s) the preferred approach for shoreline stabilization from a broad coastal ecosystem viewpoint, and is (are) based on VIMS comprehensive coastal resource management guidance to preserve and maintain tidal wetland ecosystems in the face of coastal development and sea level rise. The goal of the recommended approach is to foster the sustainability of shoreline resources using living shoreline designs where appropriate and applying traditional shoreline hardening only in areas where site conditions make them necessary. These recommendations reflect the Commonwealth’s preferred approach for shoreline stabilization using living shoreline treatments whenever adequate erosion control can be achieved. The comprehensive coastal resource management guidance recommendation is based on the natural resources and physical characteristics of the shoreline and is not dependent upon the project being proposed. Information on the natural resources and physical characteristics of a shoreline is collected during the VIMS shoreline inventory conducted as part of the development of each locality’s Coastal Comprehensive Resource Management Portal (CCRMP). The VIMS shoreline inventory includes data such as: bank condition, nearshore depth, fetch, bank height, presence of beach and/or wetlands, location of primary structures, existing shoreline structures, and bank cover. The data is collected via observations made from a small vessel on the water or remotely at the desktop using high resolution imagery. Every attempt has been made to ensure that these data are reliable and accurate. However limitations such as inability to access a shoreline, tide stage, image quality, as well as changes to shorelines occurring post inventory, affect the data accuracy. A geo-spatial model that is based on the comprehensive coastal resource management guidance is used to determine the preferred shoreline management recommendations. An interactive Comprehensive Map Viewer delineating the preferred approaches for your locality can be accessed at http://ccrm.vims.edu/ccrmp/index.html. The ecosystem scale of the model is not specifically detailed to individual parcels. In some instances, conditions of a parcel such as the presence of existing erosion control structures, narrow lot size, and proximity of primary buildings to the shoreline may cause the larger scale ecosystem based approach to be difficult to achieve. In these cases, the shoreline management recommendation derived from the CCRM Decision Tree Tools may be an alternative option and if so will be provided at the end of the report. To access the Coastal Management Decision Tree Tools go to: http://ccrm.vims.edu/decisiontree/. Page 1 of 4  Coastal Ecosystem Based Recommendation Details (16-0679) If active erosion is occurring along this shoreline, the preferred approach for erosion control to preserve and maintain tidal wetland ecosystems is to: This is a low energy shoreline. Providing stabilization and wave attenuation through riparian and marsh vegetation would generally be recommended along the entire shoreline. However, the use of preferred shoreline management options is sometimes limited by choices already made on the shoreline, such as the construction of the existing marina. Shorelines containing marinas, canals, and commerical or industrial areas with bulkhead or wharf are considered Areas of Special Concern. The preferred shoreline best management practices within Areas of Special Concern will depend on the need for and limitations posed by navigation access. Page 2 of 4 Bulkhead replacement: Bulkhead is not a preferred shoreline stabilization method from a marine environmental viewpoint. However, due to the developed upland conditions and use of the site as a marina, construction of replacement bulkhead is the most practical option for shoreline stabilization at this location. If bulkhead replacement is the only viable option, the new bulkhead should be in the same alignment or landward from the original bulkhead position to avoid impacts. New bulkhead: Vegetation approaches (riparian buffer and marsh buffers) should be the first option considered when conducting an alternatives analysis for shoreline management options. Vegetation approaches are preferred shoreline best management practices to preserve and maintain tidal wetland ecosystems, where they are appropriate. Vegetation buffers should be included whenever and wherever possible. Revetments are preferred along these shorelines where erosion protection is necessary and vegetation alone is not sufficient. Bulkhead should be limited to restricted navigation areas only. Bulkheads sever the connection between the upland and the intertidal area interrupting the natural water/land continuum to the detriment of natural shoreline ecosystems. Efforts to eliminate impacts at the proposed fuel dock area are recommended. Riprap: The area proposed for riprap revetment is outside the navigation area. Providing stabilization and wave attenuation through riparian and marsh vegetation is generally recommended in these low energy areas. However, the effectiveness of some preferred management options may be limited by decisions already made on the upland, such as the construction of the parking lot in close proximity to the marsh. To reduce impacts on the tidal shoreline ecosystem, erosion control measures beyond vegetation in this area is only warranted in our opinion if erosion is occurring, indicating the vegetation is not sufficient to protect the integrity of the parking area. The placement of the revetment outside of the wetlands does not eliminate all impacts to the tidal shoreline resource. Revetments sever the connection between the upland and the marsh area interrupting and sometimes eliminating natural processes and functions that occur at this ecologically essential intersection, limiting the ability of the natural system to perform vital functions and reducing the probability that tidal ecosystems and shoreline resources will be sustained in the future. Page 3 of 4 Non-Erosion Control Items: Piers/Boat Slips: Piers and other structures have shading impacts on wetlands and waters. The limitation on sunlight exposure reduces the production of all photosynthetic plants including marsh grasses and micro algae in the area of a pier. The loss of the vegetated community and the associated primary production results in an adverse change in the habitat services of the impacted area. However, this is replacement of an existing structure and locating the pier where there is no wetlands vegetation, as proposed, is preferred. Pier placement and orientation should be designed to eliminate or minimize the need for dredging. Since this is an existing marina, the following recommendations should already be in place: Plans to address oil spills in the waterway, and on the upland as necessary; provision of pump-out facilities and restrooms and promotion of their use can reduce bacterial pollution; sufficient garbage receptacles should be provided and maintained to reduce solid waste in the waterway. Signs to encourage proper handling of garbage and waterway stewardship should be posted. Use of pump-out facilities and the proper handling of garbage should be promoted with signage on site. Piers do offer structure in the aquatic environment. This structure has been shown to serve as habitat for attached organisms and finfish. Dredging: Dredging has the potential to impact many of the services provided by and for the natural marine/estuarine ecosystem. The marine and aquatic organisms that live in and near the sub-tidal bottom are one component of the ecosystem most at risk from dredging operations. The normal assemblage of organisms varies with location and depth, but all can be considered an integral part of the marine/aquatic ecosystem. Dredging eliminates the existing bottom-dwelling organisms. The timeline for recovery of this community and the ecological services it provides is not well known. The water column provides habitat for both swimming and drifting life forms, including both resident and migratory fish and invertebrates, and the larval forms of fish and shellfish. Good water quality is required for these organisms and the healthy functioning of this environment. Dredging re-suspends bottom sediments in the water column, which adversely impacts water quality. When material to be dredged includes fine- grained sediments such as silt that remain in suspension for a long time, the adverse impact to water quality can be widespread in both area and time. Dredging can cause a significant disruption of the marine environment, and it often must be repeated in order to maintain water depths. If the dredging can be shown to be essential to facilitate the operation of the existing facility, there is no apparent alternative. To reduce impacts to the marine environment, dewatering and disposal of dredged material in upland sites away from the shoreline is preferable to overboard disposal. Page 4 of 4