Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
Administrative
1.
The Board of Trustees of the Freeholders and Commonality of the Town of
Southampton has notified DEC that the placement and manipulation of sand
on the beach between the toe of the primary dune and the ocean as proposed
will require the approval of that body. It has expressed concern that the Village
has not consulted or otherwise contacted it to discuss issues of concern and
application requirements for the project.
RESPONSE: The jurisdiction of the Trustees over beaches in an
incorporated village is currently the subject of litigation that is pending
before the Appellate Division, Second Department. Approval of the Trustees
will be sought upon completion of the application process with the NYSDEC
and US Army Corps of Engineers, if in fact Quogue Village decides to take
the project forward, and the approval of the Trustees is legally required.
2.
The Village's consultant is not qualified to design and propose the project under
consideration. Such a project should only be considered if it proposed by the
US Army Corps of Engineers.
RESPONSE: The team of consultants subcontracted by First Coastal
Corporation, the Village consultant, includes professional engineers, coastal
geologists, marine biologists, and coastal zone management specialists. These
consultants have been involved in dozens of beach and dune restoration projects
throughout the East coast. First Coastal Corporation, regularly brings in
support from credentialed, experienced, and licensed experts as required (i.e.—
research, data development, engineering, etc.) The project investigation,
formulation, and design follow the standard of accepted practices of the US
Army Corps of Engineers as expressed in the Coastal Engineer Manual of the
US Army Corps of Engineers. Coastal restoration projects are reviewed on their
merits.
3.
All permit application and project design materials should be available for
public review at the public library in Quogue.
RESPONSE: The permit application, which includes project design materials, is and
has regularly been available at the Quogue Public Library, the Quogue Village Hall,
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
online at WWW.QUOGUEBEACHES.ORG. A comprehensive and exhaustive review
and analysis of the Quogue ocean shoreline, entitled “Feasibility Report –
Shoreline Erosion Assessment and Plan for Beach Restoration – Village of Quogue,
NY” (herein, the “Feasibility Report”) was included in the permit application, and
has been distributed separately at public events.
Project Need I Alternatives
4.
The proposed project is not necessary.
AND
5.
The problematic erosion area is a small fraction of Quogue's overall ocean
frontage. This erosion should be addressed with a solution centered on the
problem area, not the full 2.7 miles of ocean shoreline. Note: Please provide
a comprehensive response to this comment which clearly establishes the
need for the proposed Village-wide scale of the project.
RESPONSE: The purpose of the project is to maintain the integrity of the entire
barrier island system and to prevent the breaching of the barrier island, which
occurred in West Hampton Dunes in 1992/1993. Breaching of the barrier island
is a very real concern that is highlighted by the breaching of the dune west of the
Quogue Village Beach during Sandy. A breach in the barrier island will
devastate the ecology, economy and social fabric of Quogue. The wetlands and
bays will be covered in sand, the tax base of Dune Road (25% of the Village total)
will be devastated and the deep connection that Quogue residents have with the
ocean and beach will be severed.
The validity and necessity of this project are described in the Feasibility Report.
This report documents a deficit of approximately 500,000 cubic yards of sand
relative to an “ideal, healthy beach” and that the Quogue ocean shoreline is
experiencing an annual deficit of 60,000 cubic yards of sand, or 600,000 cubic
yards of sand in the last ten years. The proposed nourishment program of
approximately 1.1 million cubic yards of sand is intended to restore the ocean
shoreline to an “ideal, healthy beach” and to mitigate the loss of 600,000 cubic
yards over the next ten years. The annual sand deficit was calculated after a
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
comprehensive review of all historical documents including beach profiles, aerial
photos, offshore surveys, and a review of previous studies conducted by the US
Army Corps of Engineers, New York State, Village of Quogue and various
universities. This sand deficit is based on upon actual measurements of 53
separate profiles over twenty years and is accurate to a reasonable degree of
scientific certainty.
The Village’s consultants conducted a detailed inventory of the present beach
condition through a comprehensive survey of beach profiles collected every 300
feet along 16,162 linear feet of shoreline (14,325 feet within the Village)
extending 3,500 feet offshore. These 53 separate profile measurements confirmed
the presence of near-shore bar systems, variation in the underwater beach
relative to those bars, and provided the basis for developing a sediment budget
for the Village of Quogue. These 53 separate profiles were compared against
previously collected profile data from the US Army Corps of Engineers and
NYSDEC in order to calculate the sand volume change over the last 20 years at
each of the 53 profile locations. The individual profile volume changes were then
computed to create a sediment budget along the entire ocean shoreline of the
Village of Quogue. This quantitative analysis of shoreline volume change over the
last 20 years is the standard accepted practice throughout the coastal scientific
and engineering community for calculating the volume changes on beaches and
developing a sediment budget.
The result of this sediment budget is the fact that the ocean shoreline in Quogue
has a sediment deficit of approximately 500,000 cubic yards of sand with respect
to an “ideal, healthy beach” and that the Quogue ocean beach is experiencing a
net sediment loss of 60,000 cubic yards per year over the last 20 years. This
information is detailed in the Feasibility Report, specifically on pages 21 to 45,
and in Appendix 1 and Appendix 2. The Village’s consultant allocated the Quogue
ocean shoreline into three reaches based upon common characteristics, identified
as Reach 1 (3,685 feet or 25.7% on the West end); Reach 2 (5,364 feet or 35.5%
in the center); and Reach 3 (5,276 feet or 36.8% on the East end) (See Figure C
on page IV of the Feasibility Report). The quantitative analysis of the 53 beach
profiles referenced above found that Reach 1 is experiencing a sediment loss of
15,453 cubic yards per year, Reach 2 is experiencing a sand loss of 22,466 cubic
yards per year, and Reach 3 is experiencing a loss of 22,101 cubic yards per year.
Thus, all three Reaches in the Village of Quogue are experiencing a net loss of
sediment annually. Reach 2 and Reach 3 (10,640 linear feet, or 74%) of the
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Response to Public Comments
NYSDEC Application No. 1-4736-01875
Quogue ocean shoreline is experiencing the most significant annual sand loss.
The finding of the Village’s consultants agree both qualitatively and
quantitatively with all previous studies of the Quogue shoreline, including those
studies conducted by the US Army Corps of Engineers, NYSDEC, and Village of
Quogue. There are 56 different studies referenced by the Village’s consultants
which may be found on pages 71, 72, and 73 of the SDBF report.
6.
A detailed, public, cost -benefit analysis should be done to determine
whether it is appropriate for the Village to undertake such a large scale
project.
RESPONSE: Should the resource agencies approve the proposed action and
issue a permit---then the Village as the sponsoring agency will determine
whether it is in the best interests of the Village to proceed with the project.
That determination could include a detailed cost/benefit analysis if it is
deemed necessary or desirable. Making the expense of such a cost/benefit
analysis before the environmental review is completed would be a waste of
money. Even if it is cost effective, if there is no permit, then public money is
spent for no purpose.
7.
The ocean beach has been building and eroding seasonally, and in response
to major storm events, for thousands of years. Let nature take its course.
RESPONSE: The documented erosion and ongoing sand loss on the
Quogue ocean beaches is both progressive and unprecedented. This
erosion occurs both on the beach and dune, which is easily observable, and
in the near-shore area under the water, which is can only be measured by
conducting extensive underwater measurements. It is precisely these
measurements that are referenced in the Feasibility Report described in
detail above, and which extend along the entire 14,325 feet of Quogue
ocean shoreline.
The Village prepared a Generic Environmental Impact Statement (GEIS)
in 1997 that included an analysis of shoreline change from 1830 to 1979.
The analysis concluded that all areas of the Quogue ocean shoreline are
eroding on average of 1.5 feet per year, with the most significant erosion in
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
the eastern half of the Village at approximately 2 feet per year.
In addition to these documented changes, a visual observation of beach
conditions since 1993 also shows a progressive erosion of the dune along
approximately 5,650 linear feet of ocean shoreline, from 244 Dune Road,
at the Quogue/Southampton boundary line, to 148 Dune Road, just east of
the Quogue Beach Club. The beach and dune system along this 5,650
linear feet of beach has shown no sustained natural recovery since 1993.
The loss of beach and dune is well documented through the frequent
artificial renourishments of upland sand by private owners that have lost
dunes. These dune restorations are the subject of numerous permits issued
by the NYSDEC and the Village of Quogue and have spread progressively
from east to west in this section of shoreline over the last two decades.
Approximately 25 permits have been issued for dune restoration over the
last decade covering the area from 244 Dune Road to 148 Dune Road,
which is almost 6,000 linear feet. Approximately 5 permits were issued
since Super Storm Sandy for the area west of the Quogue Village Beach.
This was an area previously unaffected by erosion, were the “hot spot” of
erosion has extended. These permits cover approximately 1,000 linear feet
of shoreline.
8.
The relatively few homeowners who feel threatened by the current beach
conditions should consider designing, proposing and undertaking a project
which addresses the problem/s at their few properties which doesn't involve
the whole Village oceanfront.
RESPONSE: The sand deficit on the Quogue ocean shoreline affects all
116 oceanfront properties along the Village’s 14,325 linear feet of
shoreline, as well as the integrity of the barrier island system that provides
critical flood and erosion protection to the mainland of Quogue. The ocean
dunes in Quogue were breached by Super Storm Sandy in 2012 for the first
time since 1962. It is likely that if the eye of Sandy had come ashore closer
to Quogue, the surge from that storm would have extended all the way
across Dune Road.
The Generic Environmental Impact Statement (GEIS) commissioned by the
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
Village of Quogue in 1997 also concluded that the entire shoreline of
Quogue is undergoing long term erosion from 1830 to 1979 (see Figure 4
on page 25b of that report). The rate over that period of time was 1.5 feet
per year, with higher rates of 2 feet per year for the eastern half of the
Village ocean shoreline.
Beach restoration is the only natural-based, system-wide approach that will
directly address the documented Village-wide sand deficit. The proposed
project is based upon specific scientific and engineering measurements of
Quogue’s shoreline and application of sound principles of coastal science
and engineering. These measurements and principles are summarized above
and described in detail in the Feasibility Report.
9.
The relatively few homeowners affected by beach erosion in Quogue
should consider relocating their homes landward.
RESPONSE: This rate of erosion will continue with or without the
homes on Dune Road. Removing or relocating homes will not change
the rate of erosion. The continued erosion is because of the
documented annual 60,000 cubic yard sand deficit. Merely re-locating
the homes does not at all address the underlying issue of barrier
island degradation and the vast starvation of sand. The dune and
beach continue to be diminished and the dune was breached during
Super Storm Sandy. Continued degradation and eventual breaching of
the barrier island is more likely without intervention. Only beach
nourishment will address the annual sand loss, naturally nourish the
beach, and protect the barrier island from breaching.
10. The Village, as the project sponsor and applicant, has not discussed or
considered feasible alternatives to the proposed action.
RESPONSE: The Village has and continues to investigate every practicable
alternative to address beach and dune erosion, including regulations, sand
fencing and beach nourishment. The Village conducted a Generic
Environmental Impact Statement (GEIS) in 1997 entitled “Examination of
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
Options to Control Beach Erosion in the Village of Quogue”. This report
examined a series of options, including No Action, Relocation, Soft
Structures, Semi Hard Structures and Hard Structures. The result of this
GEIS was the adoption of Chapter 146: Sand Dunes and Ocean Beach
Management Law in 1999, as well as amendments to Chapter 80: Coastal
Erosion Hazard Areas.
The Village has developed a well-rounded set of regulatory and active beach
and dune management programs including:
a. Chapter 146: Sand Dunes and Ocean Beach Management Law (adopted as a Local Law No. 1-1999, adopted 4-16-1999) This local
law requires the use of dune crossovers to access over the dune and
establishes the ability of the Village to conduct beach nourishment that
may include scraping sand from the beach. It further obligates
oceanfront owners to erect sand fence annually to collect windblown
sand and to plant beach grass as directed by the Village.
b. Chapter 80: Coastal Erosion Hazard Areas – (Adopted by the Board
of Trustees of the Village of Quogue 12-7-1988 by L.L. No. 10-1988).
This local law requires all new development to be set back from the dune,
provides for dune cross overs to access the beach and prevents mining of
the dune for sand. This local law was amended in 1999 to prohibit the
use of “hard” structures.
c. Chapter 95: Flood Damage Prevention Law – (Adopted by the Board
of Trustees of the Village of Quogue 3-19-1998 by L.L. No. 1-1998). This
local law limits development in flood plain areas, including dune area,
and imposes criteria for construction.
d. Chapter 118 - Article V: Use of Ocean Beach Area – (Adopted 7-191991 as part of L.L. No. 4-1991). This local law prohibits the operation
of motor vehicles within dune areas.
Under Chapter 146, the Village has annually erected sand fence throughout the
entire ocean beach for the last 15 years. The Village has also routinely conducted
beach scraping activities when the permit conditions required by the New York
State DEC are met. Beach scraping is the collection of a limited amount of sand
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
from the beach area (approximately 2.2 cubic yards of sand per linear foot of
beach) and the placement of that sand into the adjacent dune to bolster the dune.
This beach scraping occurred most recently in 2013, 2012 (prior to Sandy), and
2010. Up until 2010 the beach scraping was conducted only along the ocean
shoreline east of the Quogue Village Beach. However, in 2012 and 2013 beach
scraping was extended westward almost to the Quogue Beach Club at 132 Dune
Road.
Beach nourishment is the only comprehensive alternative that directly addresses
the problem and uses an environmentally sensitive approach. Merely placing
sand fence, planting beach grass and harvesting sand simply has not worked and
will not work because of the sand deficit.
Alternatives include armoring the shoreline with steel, stone or wood, which is
prohibited under the Village’s 1997 GEIS. Other alternatives, such as offshore
breakwaters and groins/jetties were rejected because they can have significant
adverse impacts and do not bring additional sand to the beach. All of these
techniques either do not address the problem or come with significant
environmental consequences.
11. As an alternative to the proposed action, enhanced bypassing of sand across
the Shinnecock Inlet should be explored.
RESPONSE: The sand bypass program implemented at Shinnecock Inlet
in 2004 already bypasses the maximum amount of sand around the inlet.
The maximum amount of sand to be bypassed is calculated by the observed
trapping of sand at the inlet, which is 50% of the annual transport rate.
Moreover, all of the sand that is deposited within the designed deposition
basin in the inlet is bypassed to Tiana Beach. There is no ability on the
part of the Village or other agencies to increase the amount of sand
bypassed. Moreover, by-passing at Shinnecock Inlet alone will not address
or solve the annual sand loss of Quogue’s beaches.
The Shinnecock Inlet was opened by the 1938 Hurricane, which also
breached fourteen other locations between Moriches and Shinnecock
Inlets, including three inlets in the Village of Quogue. Numerous reports
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
and studies have documented that the inlet has been trapping sand since
1938 and the US Army Corps of Engineers issued a 1995 report indicating
that the Inlet had trapped 7,900,000 cubic yards of sand since 1938.
Based on this report and others, the erosion that started at Shinnecock
Inlet in 1938 took almost 60 years to progress the six miles from
Shinnecock Inlet to the eastern boundary of Quogue.
In response to that report and local pressure, the US Army Corps began in
2004 by-passing sand as far as Tiana Beach, approximately two miles west
of the Inlet. Approximately 750,000 cubic yards of sand have been
bypassed since 2004. The Corps of Engineers bypassed 500,000 cubic
yards of sand in 2010 and 250,000 cubic yards of sand bypassed in 2004.
Based on the historic rate of sand movement from east to west, it will be
another 40 years before the sand placed at Tiana Beach reaches the
Village of Quogue. Meanwhile the annual sand loss of 60,000 cubic yards
per year will continue. Even then bypassing would only maintain the
status quo and never catch up with the approximately 8,000,000 yards of
sand trapped by the inlet before bypassing began and the approximately
2,400,000 cubic yards of sand that will be lost by Quogue beach over the
next 40 years.
12. How can the proposed action be taken seriously by the Village and the
regulatory agencies when the US Army Corps of Engineers Fire Island to
Montauk Point plan (FIMP) does not recommend any action to reinforce or
expand Quogue Beach?
RESPONSE: The proposed beach restoration project is predicated upon a
science based, factual evaluation of the annual loss of sand from Quogue’s ocean
beach and the undeniable fact that the erosion of the beach and dune has been
moving progressively from east to west over the last 20 years. The environmental
review process of the project is also based on a review of the best available
scientific knowledge and the application of the NYS Environmental Quality
Review Act (SEQRA) through the various technical permit program requirements.
In 2007, the US Army Corps of Engineers recommended a feeder beach in East
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
Quogue as part of the Fire Island to Montauk Point Project (FIMP). This feeder
beach was intended to partially offset the sand loss described in the Feasibility
Report. However, no design volume or project length was ever developed. More
recently in 2013, the Corps recommended a beach 90 feet wide with a dune of 13
feet high along the barrier beach from Shinnecock Inlet to Moriches Inlet. This
report has yet to be submitted to Congress for approval. In fact, the FIMP
project, which was authorized by Congress in 1960 and originally recommended
a 100 foot wide beach and 20 foot high dune, has only completed construction on
approximately 7 miles of the 85 mile long authorized project in the last 54 years.
Therefore, the Corps has repeatedly recommended beach nourishment in the
Quogue oceanfront, but has not ever completed any construction.
Project Cost I Funding Mechanisms, Etc.
13. The proposed project is too costly.
RESPONSE: This question is premature. Issues related to cost will be
addressed after the environmental review and if a permit is issued.
14. All Village taxpayers should not have to pay for a project which will
directly benefit a relative few.
RESPONSE: There is no Village taxpayer cost associated with the
permitting and environmental review of the proposed project. The Save
the Dunes and Beaches Foundation, Inc. (a 501 (c)(3) charitable
organization) has paid for all costs associated with the preparation of the
environmental permit applications. A review of the cost of the project, the
benefits, and who will pay for the project will be undertaken by the Village
of Quogue after all environmental review permits are issued.
15. Since the problem erosion area is relatively small and confined, financial
responsibility for addressing the erosion should rest with the affected property
owners. These affected property owners should consider a much smaller scale,
less costly project to deal with the localized problem.
RESPONSE: This is not a localized problem. The Feasibility Report shows
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
that this entire oceanfront is suffering from a negative sediment budget. This
finding is consistent with every other scientific evaluation of the Quogue
ocean shoreline, including the GEIS conducted by the Village of Quogue in
1999 that found an average of 1.5 feet of erosion per year from 1830 to 1979
and up to 2 feet per year in the eastern half of the Village.
One of the key parameters in the success of a beach nourishment project is
the length of the project. The performance of the project is equal to the
square of the length. In other words, a two mile project is four times better
than a one mile project. The shorter project would degrade much more
rapidly than the project that is two or three miles long. Moreover, the cost of
a beach restoration project is based upon two parameters a) mobilization
and demobilization of the dredge which costs between $3,000,000 and
$4,500,000 and b) cost per cubic yard of sand, which is between $10 and $16
per cubic yard. The mobilization costs are irrespective of the number of
yards dredged. In other words, it is a fixed cost that will not change
regardless of the number of cubic yards dredged. The cost per cubic yard is
based largely on the distance from the sand source, the expected weather
conditions and the amount of sand to be dredged.
The project formulation must follow scientific and engineering “best
practices” in order to be successful. Project formulation by political or
expedient practices has a much higher risk of failure.
16. Since the longevity of large scale beach nourishment projects nationwide is
variable at best and poor at worst, all concerned need to understand that the
long term efficacy of the proposed project is not guaranteed. Funds expended
to carry out the project could be wasted and there could be the expectation of
the expenditure of additional funds to re-nourish the beach after the material
from the first nourishment erodes.
RESPONSE: Beach nourishment is widely accepted as the most cost effective
method of combating erosion. Moreover, beach nourishment is the only
method that resembles the natural system of sandy dunes and beaches. As a
result, beach nourishment is recognized by environmental permit regulators as
having the least environmental impact and provides for natural beach and
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
dune, flood and erosion protection.
The project investigation, formulation, and design follow the generally
accepted standards and principles of coastal science and engineering. The
specific project formulation is based on quantitative beach profile
measurements taken over the last 20 years.
The purpose of the proposed application is to review the potential
environmental impacts of the proposed beach nourishment project, not the
economic impacts. The economic impacts will be vetted by the Village of
Quogue, if and when the required environmental permits are obtained.
17. The Village needs to undertake a cost -benefit analysis to determine
whether such a large expenditure of municipal funds is justified by the
project benefits which can reasonably be expected from the action.
RESPONSE: The Village of Quogue will be undertaking an economic
evaluation of the project if and when the environmental permits are
obtained.
18. The supply of suitable sand within a reasonable distance offshore of
the Village, like the Village's budget, is finite and should be used only
when absolutely necessary.
RESPONSE: The Feasibility Report and explanation above provide
ample evidence of the importance of the renourishment project. The
Quogue ocean beaches are losing 60,000 cubic yards of sand annually.
9 The dunes and beaches in the eastern half of the Village have shown
progressive erosion and no long term recovery over the last decade. This
is reflected in the Village’s 1997 GEIS as well.
The sand resources offshore are robust and compatible with the Quogue
beach sand. The permitting process included a separate geotechnical
report of the available sand sources (which is also available at the
Quogue Village Hall, Quogue Library, on demand, and at
WWW.QUOGUEBEACHES.ORG) as well as reviewing the US Army
Corps of Engineers geotechnical studies that were conducted in 1985.
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NYSDEC Application No. 1-4736-01875
Both of these studies document the presence of approximately 7.53
million of cubic yards of compatible sand within designated borrow sites
identified in the studies and millions more is likely available in areas yet
to be studied. The sand supplies offshore are sufficient and compatible.
The 1,100,000 cubic yards of sand proposed includes approximately
500,000 cubic yards to return to the beach profile to a “healthy”
condition and an additional 600,000 cubic yards of sand to account for
an additional 10 years of sand loss at the calculated rate of 60,000 cubic
yards per year.
The sand resources considered for this project are the same areas or
adjacent to those presently used by the US Army Corps of Engineers for
the beach restoration project in the Village of Westhampton Dunes,
Hamlet of Westhampton, Village of Westhampton Beach. These locations
are in 45 to 55 feet of water, and located more than one mile offshore of
the beach. This location is considered to be safely seaward of the active
shore face, which is generally considered to extend to only 25 to 28 feet
of water. Thus, removing sand from these designated areas will have no
impact on the beaches and sandbars of the Village of Quogue, or
adjacent areas.
19. The expenditure of $15 million by the Village for this project should be the
subject of a vote by all Quogue residents.
RESPONSE: This issue is not a matter of concern for the present
environmental review. Approval of the environmental permits does not
obligate the Village to construct the project. A decision to construct the
project will be the responsibility of the Village of Quogue.
20. The proposed project will do nothing to protect against flooding from
the bay. Bay side property owners, who are already in the position of
having to pay increased flood insurance premiums after Sandy, will
find themselves also paying increased Village taxes to support a project
which will not directly benefit them.
RESPONSE: The entire Village of Quogue and its residents will be adversely
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Response to Public Comments
NYSDEC Application No. 1-4736-01875
affected by any breach, especially those on the waterfront including anyone on
the bay front of Dune Road. A breach would erode the tax base, public services,
and property values throughout the Village, and the quality of life. The allocation
of the project costs is a matter for local determination by the Quogue Board of
Trustees after public input.
21. As the public only has legal access to the portion of the beach seaward of
the line of mean high water in front of private property, the proposed
project seems like a very large public expense which will do little to
increase the area of the beach available to the public.
RESPONSE: The land that will be created by this project will be below
the mean high water line. The area of the beach will be increased by this
nourishment. In any event, the purpose of this project is to protect against
beach erosion and a potential breach of the barrier island, and not to
increase the area of beach available to the public.
Village Governance I Municipal I s s u e s
22. The Village of Quogue needs to hold a public forum at which all issues
associated with this project can be discussed.
RESPONSE: The Village has held and will continue to hold public forums
on this issue. The Village has a long history of public discussion of
beaches, including preparation of a Generic Environmental Impact
Statement in 1997. The Village has facilitated numerous forums for the
discussion of coastal flooding and erosion since 1997 and the decision to
submit a permit application to the environmental regulatory agencies was
made at a public meeting of the Village Board of Trustees. If and when the
environmental permits are issued, the Village will conduct additional
public forums on the question of financing and ask for public input.
23. The consultant hired by the Village for this project is not objective and is
biased toward the proposed project design.
RESPONSE: Beach nourishment is widely accepted as the preferred method of
beach erosion control and was recommended as a “soft” solution in the
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Response to Public Comments
NYSDEC Application No. 1-4736-01875
Village’s 1997 GEIS. A wide range of alternatives were discussed and
reviewed in the 1997 GEIS and of all the alternatives evaluated, beach
restoration is the only approach to squarely address the cause of erosion and
flooding, which is the loss of 60,000 cubic yards of sand annually. The proposed
project will generate a restored beach that is environmentally compatible, for
which permits can be issued and will provide meaningful flood and erosion
protection.
24. The affected landowners may have contributed to or even caused their
own problems with the development decisions they made on their
properties.
RESPONSE: The erosion of the Village of Quogue ocean beaches extends
out to a water depth of 20 feet below sea level, which is over 1,000 feet
offshore. This information was only discovered through the careful
measurement of beach profiles and comparison with previous beach
profile information. The recession of the Quogue ocean shoreline is the
result of an annual sand loss of 60,000 cubic yards as documented most
recently in the SDBF report and as concluded by every other research
study conducted on this Quogue shoreline. The annual loss of sand
degraded the Quogue dunes and beaches to the point that Super Storm
Sandy was able to breach the dunes for the first time since 1962.
25. The Village of Quogue may have contributed to the problems in the
eroding area by issuing local land use and building authorizations for
development requiring variance relief from the Coastal Erosion
Management minimum standards.
RESPONSE: The erosion of the Quogue ocean shoreline is the result of an
annual sand loss of 60,000 cubic yards of sand per year over at least the last
20 years. This loss of sand extends from the dune to a depth of 20 feet of
water. While the DEC in 2010 questioned some of the decisions in Quogue
relative to the Coastal Erosion Hazard Area, these were addressed
comprehensively by the Village in February of 2011. The Village of Quogue
strictly enforces the Coastal Erosion Hazard Law. The erosion of the beach
is the result of sand starvation.
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NYSDEC Application No. 1-4736-01875
26. The current development pattern on the barrier island in Quogue is unwise
and unsustainable. The very large, very expensive, permanent homes
which now exist on the oceanfront engender in the owners’ the
understandable desire to protect them, at almost any cost, against the forces
of nature, to the detriment of the beach and dunes. In the not so distant past,
many people contented themselves with much smaller, less permanent, less
valuable beach cottages, structures which they could afford to lose and/or
replace if they were damaged by erosion or storms.
RESPONSE: The current development pattern on Dune Road is consistent
with both Village and State laws and regulations. No dunes have been
diminished as the result of development. The dune and beach system is
being actively undermined by an annual sand loss of 60,000 cubic yards of
sand. This sand deficit will continue to degrade the dunes and beaches,
resulting in an eventual barrier island breach if action is not taken to
resupply the natural sand.
27. Is the Village proposing this project to protect a small number of houses,
or to protect the natural protective feature of the beach?
RESPONSE: The purpose of this project is to protect the natural
protective features of the dune, beach and barrier island that supply
natural flood and erosion protection. The entire 14,325 feet of Quogue
ocean shoreline is experiencing erosion. Approximately 74% or 10,640
linear feet is suffering the most critical sand loss. Quogue’s oceanfront is
presently losing 60,000 cubic yards of sand per year or 600,000 cubic
yards over the last decade. Sand needs to be supplied to the beach in
order to restore the natural protective feature of the dune, beach, and
barrier island, and avoid a breach of the barrier island similar to what
happened in West Hampton Dunes in 1992.
28. Oceanfront property owners must know that they are taking on
considerable risk when they purchase or otherwise acquire their
properties. These property owners, not the municipality, should be
responsible for maintaining them.
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NYSDEC Application No. 1-4736-01875
RESPONSE: The purpose of the proposed project is to restore the supply
of natural sand to the dune and beach, which is presently suffering a loss of
60,000 cubic yards of sand annually. If the dunes and beaches continue to
degrade, the barrier island may be breached and all property owners in
Quogue will suffer. The reality is that private property owners cannot on
their own undertake a project of this type. Questions of cost and allocation
thereof will be considered after the environmental permits are issued.
29. Pursuing a beach nourishment project while at the same time allowing the
installation of geotubes, sand cubes and other shoreline stabilization
structures is a contradiction in approaches.
RESPONSE: The proposed project is fully consistent with the Village GEIS
approved in 1997. The restoration of the natural sand supply to the dunes
and beaches will significantly reduce the need for individual property owners
to undertake protective measures. The need for individual protective
measures such as geotextiles will become minimized if a more
comprehensive solution is achieved. The Village Code allows such measures
because they are reversible. The Village Code prohibits hard structures.
Environmental I Natural Resources Impacts
30. The proposed project may have a negative impact on the physical
structure and organisms inhabiting the 100 acre borrow site on the ocean
floor.
RESPONSE: The proposed project of beach nourishment utilizes offshore
areas of sand called “borrow areas.” Extensive environmental and
geotechnical reviews of these borrow areas are conducted prior to their
consideration for use. Some of these studies have been conducted by the
US Army Corps of Engineers and the NYS Department of Environmental
Conservation in support of the Fire Island to Montauk Point Project
(FIMP, see for example
http://www.nan.usace.army.mil/Missions/CivilWorks/ProjectsinNewYork/
FireIslandtoMontaukPointReformulationStudy/FIMPReports.aspx) and
some have been conducted in the course of the permitting application for
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Response to Public Comments
NYSDEC Application No. 1-4736-01875
this project. In all cases, the selected borrow areas are found to have
very low biological activity and in all cases, the recovery rate and any
impacted area is very rapid, often within one growing season.
31. The project may have a negative impact on the material placement area,
which is the entire ocean frontage of the Quogue Village. In particular, the
deepening of the borrow area may result in more energetic, powerful
waves reaching the beach and increasing erosion rates for the nourished
beach.
RESPONSE: The biological flora and fauna of sandy beaches are
extremely resilient because of the need to respond to natural beach changes
induced by both storms and seasons. For example, storms can change the
beach by over 100 feet in a day and it is not uncommon for the beach to
recover that 100 feet in a week or so. As a result of these common
conditions, sandy beach flora and fauna have naturally adapted to
significant changes in beach conditions. Detailed studies by the US Army
Corps of Engineers and universities have documented rapid regrowth of
sandy beach flora and fauna. See for example, Final Report for The Army
Corps of Engineers New York District's Biological Monitoring Program for the
Atlantic Coast of New Jersey, Sea Bright to Manasquan Inlet, Beach Erosion
Project.
Moreover, wider beaches provide greater habitat for a variety of nesting
shorebirds and other flora and fauna, including endangered species such as the
piping plover and least tern.
The Corps of Engineers has conducted a detailed wave refraction analysis of
the borrow sites proposed for this project in 1980 (see Fire Island Inlet to
Montauk Point Long Island NY Beach Erosion Control & Hurricane Protection
Project, Supplement No 2 to General Design Memorandum No 1 Moriches to
Shinnecock Reach, US Army Corps of Engineers, NY District, July 1980,
Appendix G.) and found that the proposed borrow sites will produce “no
significant changes to wave energy”. This is logical since the borrow sites are
in 45 to 60 feet of water and even the largest waves from Super Storm Sandy
were only 31 feet. Thus, the largest waves from Sandy could not physically
interact with the sea floor.
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Response to Public Comments
NYSDEC Application No. 1-4736-01875
32. All existing erosion control structures should be removed from the
ocean beach if the proposed project is constructed.
RESPONSE: The Village has and will comply with all applicable
regulations regarding the installation of erosion control structures. While
the Village may elect to address this matter, it is not germane to the
issuance of environmental permits.
33. The impact of the proposed project on the ocean beaches to the east and
west of Quogue has not been evaluated I considered and should be.
RESPONSE: The areas of the east and west of any beach restoration project
undertaken in Quogue will experience the benefits of a wider sandy beach.
Erosion Protection I Project Efficacy
34.
The application materials submitted provide no long term guarantee that the
project will be effective. IE: That the material placed and graded on the beach
and dunes will remain in place to provide protection for a period of time
which justifies the effort and expense of the project.
RESPONSE: Beach nourishment is presently being used effectively on
Long Island from Coney Island all the way east to Sagaponack and
Bridgehampton. Beach nourishment is an accepted practice for shoreline
erosion control that is used by the US Army Corps of Engineers, New York
State Department of Environmental Conservation, Suffolk County and the
City of New York, as well as states on the east, gulf and west coasts of the
United States. The beach restoration project in Westhampton Dunes is an
example of a local successful project. The beach was originally constructed
in 1997 and was awarded the “Best Restored Beach in America” in the
summer of 2012, just prior to Super Storm Sandy. True to form, the restored
beach and dune at Westhampton Dunes protected the barrier island from
breaching (as it had in 1992) and protected public property, roads,
wetlands, and the mainland from storm surge associated with Super Storm
Sandy.
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
35.
The benefits of beach fill projects from offshore borrow sources have been
shown to be short lived in many east coast locations, requiring subsequent
nourishment cycles to maintain the project design template. Has this fact been
taken into consideration for the Quogue project?
RESPONSE: The need and design of the proposed beach restoration project is
fully detailed in the Feasibility Report that is available at the Village and
summarized in Responses 4-5 above. The investigation, formulation, and design
process undertaken in the Feasibility Report are consistent with the US Army
Corps of Engineers Coastal Erosion Manual and take in to consideration
historic erosion rates as documented in the Feasibility Report. The proposed
project is designed to last for 10 years. The desirability of additional
nourishment at the end of the design period can be evaluated at that time.
36.
Has any type of investigation or analysis been undertaken to gain a better
understanding of the nature and mechanism of the erosion "hot spot" area
which is affecting some Quogue properties and may be the main driver of the
project under consideration? Is there enough known about this phenomenon to
expect that the proposed project might correct it or address it in a permanent
way, or to suggest an alternative project design or measure which might
address the "hot spot" directly without pumping sand onto 2.7 miles of beach?
RESPONSE: There has been a comprehensive and exhaustive review and
analysis of the Quogue ocean shoreline that is summarized in the Feasibility
Report. The source of erosion and plan for restoration are summarized in
Response 4-5 above. The Feasibility report quantitatively identifies 100% of
the 14,325 linear feet of Quogue shoreline as undergoing chronic, long-term
erosion. Seventy four percent, or 10,640 linear feet, is undergoing the most
significant erosion. The Feasibility report identifies the erosion “hot spot” as
expanding continuously westward over the last 20 years, beginning at 244
Dune Road in the 1990s and presently located in the vicinity of 148 Dune Road
after Super Storm Sandy. The dune and beach in that entire area has shown no
sustained recovery during this period. Thus, the SDBF report (as well as the
1999 GEIS) recognized that the entire ocean shoreline of Quogue is eroding
and that the erosion “hot spot” is not a fixed location, but rather originates at
the eastern boundary of the Village and is continuously expanding westward
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
affecting a greater and greater number of properties every year.
37.
It should be understood that the proposed project, if implemented, would not
be significantly protective of the barrier island if the area were to experience a
storm with similar characteristics to the 1938 hurricane.
RESPONSE: Higher, wider beaches and dunes always offer greater
protection against flooding and erosion. This common axiom of coastal
resiliency may be found in the Village’s GEIS published and adopted in 1997
(see specifically page 41, “The main objective is to build and maintain the
most formidable sand dune system possible to protect the backbarrier
environments and buildings from the surf zone during storm impact.”).
Providing sufficient sand to maintain the beach is a critical foundation for
building and maintaining a healthy dune system and a protective barrier
island. There is no question that the addition of a wide, sandy beach will
significantly increase flood and erosion protection for the Village of Quogue.
38.
Beach nourishment, while a stopgap measure, seems to have less negative
effects than the installation of hard shoreline stabilization structures.
RESPONSE: Beach nourishment is the only option that directly addresses the
source of erosion, the result of sediment starvation by Shinnecock Inlet in an
environmentally compatible manner and is permitted under the rules and
regulations of New York State. Wide, sandy beaches provide the first line of flood
and erosion defense, create sandy beach habitats for shore-nesting birds,
recreational area for people, and are the foundation of a healthy barrier island
system that can protect Dune Road and the Quogue mainland from flooding and
erosion.
39.
The project description provided with the application is not complete
because it does not include the periodic re-nourishments of the initial project
which will undoubtedly be required.
RESPONSE: This project is designed to restore a healthy beach profile and
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Quogue Beach Restoration Project
Response to Public Comments
NYSDEC Application No. 1-4736-01875
account for up to ten years of annual sand loss. The project investigation,
formulation, and design are clearly identified in the Feasibility Report and
are based upon generally accepted principles of coastal science and
engineering as identified in the US Army Corps of Engineers Coastal
Engineering Manual.
40.
The proposed project will do nothing to address the flooding I storm surge
which engulfs the barrier island from the bay side.
RESPONSE: This statement is correct. This project is not intended to
address bayside flooding. However, to the extent that the barrier island is
prevented from breaching, the bayside of Dune Road will be protected.
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