Commission majority treats proposed fiber-roll dune restoration as coastal engineering structure; applicants asked for more evidence

Art Gasparo of Nantucket Engineering presented a bioengineered approach to stabilizing eroding coastal banks on several abutting Paco Mo properties: a reinforced fiber-roll array (sand nourishment, fiber rolls to be vegetated and tagged) similar to projects the commission has permitted. Gasparo said the work would include sand nourishment and planting to establish a vegetated bank and noted the technique had been used successfully on neighboring properties.

Commission discussion focused on definitions in the commission’s regulations. The chair read aloud the relevant regulatory text describing coastal engineering structure as any structure intended to "prevent or alleviate storm damage or modify tidal action, wave action, littoral flow, or erosion," and enumerating examples including "geotextile fabric" and "multiple rows of fencing." Several commissioners concluded the proposed fiber-roll array fits the local definition of a coastal engineering structure and must be permitted under that rubric; one commissioner expressed concern that classifying it that way would carry additional procedural and performance-standard consequences for applicants.

Commissioners pressed applicants to clarify materials and construction details, including whether the product contains monofilament that could create microplastic pollution. RJ Turcotte asked that rolls be tagged (stainless tags) rather than use monofilament. Gasparo said the applicant would provide additional information about the product, construction sequence, monitoring and long-term maintenance. The commission agreed applicants should supply further documentation and the hearings were continued to January 23, 2025 so staff and commissioners could review the additional materials.

How the commission framed the issue: several sitting commissioners said they would treat the fiber-roll array as a coastal engineering structure under local regulations, which may require a different set of findings and performance standards than a purely vegetative restoration. Applicants requested a continuance to provide technical detail and to show how the method would achieve a long-term net benefit to bank stability and vegetation.