Gap Analysis of the Nantucket Hazard Mitigation Plan

Sponsor: Nantucket Town Manager’s Office
Sponsor Liaison: Chuck Larson, Gregg Tivnan
Student Team: Benjamin Amado, Madeline Kasznay, Ryan Smith
Abstract: The Nantucket Town Manager’s office tasked us to identify gaps between the 2019 Hazard Mitigation Plan (HMP) and existing town plans, policies, and procedures. We found that clear and consistent application of the HMP is difficult because it affects a wide array of town departments with a diversity of overlapping functions and responsibilities that are not always clearly demarcated and no single department has the authority to implement its recommendations. We recommend the town update its plans and policies for better integration.
with the HMP, hire a floodplain manager and one or more town engineer(s), and consider expanding the Sustainability Working Group to involve more departments, such as the Department of Public Works.

Report: Gap Final IQP Report

Presentation: Gap Final Presentation

Executive Summary

The Nantucket Town Manager’s Office asked us to develop a comprehensive assessment
of the town’s bylaws, regulations, and codes related to hazard damage prevention, to ensure
consistency between the 2019 Hazard Mitigation Plan and all documents and departments
relevant to infrastructure or development projects in the town. The town is required to perform
such a gap analysis to make sure that the town has a coordinated and effective approach to
mitigate the adverse impacts of natural hazard events.
We accomplished this goal through the following objectives:

1. Review Nantucket’s plans, policies, and legislation related to hazard mitigation.
2. Conduct case studies of town buildings and infrastructure to identify inconsistencies in
the plans, policies, and legislation and their application in managing hazards.
3. Examine how other towns have implemented their Hazard Mitigation Plan.
4. Propose how to rectify inconsistencies and ambiguities by modifying the HMP and/or
existing laws, policies, and processes.

From our research, we conclude that a comprehensive implementation of the HMP is
difficult to achieve because it affects a wide variety of departments that all have overlapping
responsibilities and functions that aren’t always clear. There is a bewildering set of town plans,
policies, and bylaws that intersect with the goals and recommendations of the HMP. The plans,
policies, and bylaws have grown organically over many years which has created policy,
procedural, and jurisdictional conflicts as well as grey areas of uncertainty. Holly Backus and
PLUS have been given the responsibility to administer the HMP but lack the power to implement
or enforce few of the HMPs recommendations directly. There is often little coordination or
oversight of separate hazard mitigation projects, especially those conducted by different entities
at different times (such as the Easy Street bulkheads), which leads to less effective hazard

Based on our findings and conclusions we have six recommendations.

1. We recommend the creation of a position for floodplain manager to serve as a key
point of contact for all information relating to the floodplain. This person would
oversee any project within the floodplain to improve the flow of information and enhance
consistency in application of the HMP. A floodplain manager also opens up the
possibility for more FEMA grants due to the added expertise that having someone in this
position would provide. This would result in reduced flood insurance prices for
2. We recommend creating a position for a Town Engineer or an Engineering
Department. This position would provide the town with more consistency in regard to
the technical aspect of any project in the town. This person or department would oversee
projects on the island from an engineering perspective, and coordinate with the
engineering consultants. This would ensure that every project on the island is meeting a
specific standard of engineering design quality and construction quality.
3. We recommend the expansion of the Sustainability Workgroup to include a
member from DPW. This workgroup contains town staff members from various
different departments including Town Administration, Planning and Land Use Services,
and Natural Resources. This workgroup could be more effective if it contained a member
from DPW as it is a large department with a lot of reach. Expanding the workgroup to
include more departments such as the DPW means that each member of the group can
advocate for sustainable practices within their own departments, through the development
of department-specific plans and projects. This will in turn create a larger town-wide
focus on sustainability, and the workgroup can serve as a place for coordination and
communication between departments.
4. We recommend giving additional regulatory powers to the Coastal Resiliency
Advisory Committee, CRAC, and the Conservation Commission, ConComm. This
recommendation will ensure that there is more regulation along Nantucket’s coastline.
We recommend that CRAC be given the authority to advise ConComm in addition to
their current role of advising the select board. ConComm currently enforces the Wetlands
Protection Act but could be given more regulatory power enabling them to also regulate
more general projects along the coast. The Conservation Commission will also play a
critical role in the enforcement of recommendations in the Coastal Resiliency Plan, which
is being developed by CRAC and follows up on actions listed in the Hazard Mitigation
5. We recommend updating Building with Nantucket in Mind. An ongoing project
“Resilient Nantucket” is attempting to strike the delicate balance between adapting
buildings to withstand hazards, and ensuring that these measures do not tarnish the
historic integrity of the buildings. This project will serve as an addendum to “Building
with Nantucket in Mind”. Though this is an ongoing effort, it seems as though this type
of project is exactly what Nantucket needs in order to prepare itself for future flooding
events, coastal erosion and sea level rise, while also protecting the valuable historic
character of the island.
6. We recommend updating Rules and Regulations Regarding the Subdivision of
Land. This document was last updated in 1999, and states that “flood prone” areas are
defined as those listed on the Department of Housing and Urban Development’s Flood
Hazard Boundary maps from 1974. It is in great need of an update to keep in line with the
current needs of Nantucket.

We make these recommendations with the understanding that budgetary constraints may
limit the likelihood of all of the recommendations becoming a reality. We feel that these
recommendations will go a long way in losing the gaps that we found during the course of this