“The proposal and subsequent letter from VIMS downplay the current physical and biological status of the project site to justify its destruction” -Dr Richard Snyder

VMRS protest period open until February 13, 2026.

This is the only way to submit a protest.

Use the link: https://webapps.mrc.virginia.gov/public/habitat/comments/ to submit your comments.

Application Number: #2024-2360

Letters of Opposition

Dr. Richard Snyder, VIMS Professor Emeritus

Director of Virginia Institute of Marina Science Wachapreague Lab 2015-2025

Dr. James M Demarest II

Geology PhD - “Genesis and Preservation of Quaternary Paralic Deposits on Delmarva Peninsula”

What to know about the Cedar Island Resiliency Project?

Removal of Natural Oyster Reef in public grounds. 

An oyster reef, which is located in a VMRC public harvesting zone, will be removed and relocated; causing a loss of ecological function. Natural oyster reefs are an important foundation of a back barrier marsh stabilizing and trapping future sentiment in the area. 

There is no need for this project. 

The proposed dredge site or the project zone does not need to be dredged for navigation or safety. Primary purpose is not to protect Wachapreague, the nearest home is 4 miles away. It aims to slow the landward retreat, which is estimated to be 1000 year away. This is the largest experimental project to happen on our barrier islands. 

Old, Grossly misleading survey data from 2019. 

The conditions of this area described in the proposal, for which funding and permits are being sought, are based on 2019 data, and the conditions have substantially changed at the site since that time. Currently, the area to be covered with dredge spoil is heavily vegetated with upland plants on scattered small dunes distributed in a diverse matrix of high and low marsh plants.  

Per Federal law, project as proposed, has failed to mitigate environmental impacts.

Code of Virginia 62.1-44.15:21. Impacts to Wetlands states: Permits shall contain requirements for compensating impacts on wetlands…to achieve no net loss of existing wetland acreage or functions. Permits shall…not cause or contribute to a significant impairment of state waters or fish and wildlife resources”. The Army Corp Of Engineers has recommended compensatory mitigation for damages to marine ecosystems, per EPA law, and the applicant has not offered.

Zero Mitigation or Long Term Maintenance. 

No long term maintenance plan or wetland compensation plan has been given by the applicant. This proposal claims no mitigation for destroyed wetlands if the first round of planting does not hold… this would be required for any private citizen trying to do this same project on their land.  Project asks permission to turn dense vegetated wetlands into barren sand. 

This project will result in a less stable Cedar Island.  Local VIMS laboratory not consulted in design. 

10 year director of VIMS Wachapreague lab (20125-2025), Dr. Richard Snyder writes “The existing topography, extensive vegetation, and developing oyster reef would resist a storm surge better than what is being proposed” “The proposal and subsequent letter…downplay the current physical and biological status of the project site to justify its destruction”.  

Links To complete VMRC Application:

Application Link : https://webapps.mrc.virginia.gov/public/habitat/getADD.php?id=219224

View Public Comments: https://webapps.mrc.virginia.gov/public/habitat/publiccomments.php?id=20242360

For Full Habitat Management Site - Go To : https://webapps.mrc.virginia.gov/public/habitat/index.php

Use Application # 20242360 , Change Date to Jan 1, 2023 - Jan 1, 2025