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Final Environmental Impact Report - Whittier Bridge/I-95 ...

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<strong>Whittier</strong> <strong>Bridge</strong>/I-<strong>95</strong> Improvement Project FEIR<br />

Chapter 2.0: Response to Comments on the <strong>Environmental</strong> Assessment/Draft <strong>Environmental</strong> <strong>Impact</strong> <strong>Report</strong><br />

Response: The comment is noted.<br />

DEP-33: The results of the GHG analysis indicate an increase of 38,406 kg/day in C02eq between existing conditions<br />

and both build and the no build alternative. The report concludes that while the traffic analysis shows a reduction in<br />

queuing and delay, the C02 emissions' differential between these scenarios is below the detection limit.<br />

Consequently, it was not necessary for the proponent to conduct a comparative analysis among the build<br />

alternatives. MassDOT notes that the project does not add additional capacity but creates conformity between a<br />

section of the roadway and the existing lane configuration to its north and south, which accounts for its negligible<br />

impact on GHG emissions and mode shifts.<br />

Response: The comment is noted.<br />

DEP-34: Although not quantifiable in terms of GHG tons reduced, the project will incorporate TDM measures that<br />

support reductions in VMT including constructing a Shared-Use Path on the <strong>Whittier</strong> <strong>Bridge</strong> that will connect the<br />

Salisbury Ghost bike trail with the Newburyport park and ride lot that is also being expanded by over 100 new parking<br />

spaces. MassDOT also commits to maintaining its existing range of TDM measures including working with mass<br />

transit providers to ensure that bus transit will not be disrupted during the construction period.<br />

Response: The comment is noted. The park and ride expansion at Exit 57 in Newburyport was<br />

completed in 2011.<br />

2.3.2 Massachusetts Natural Heritage and Endangered Species Program<br />

The NHESP submitted a comment letter dated November 25, 2011.<br />

NHESP-1: The project falls within Priority and Estimated Habitat for the Shortnose Sturgeon (Endangered), Atlantic<br />

Sturgeon (Endangered), and Bald Eagle (Endangered). MassDOT has been in early coordination with our office<br />

regarding the permitting of the project pursuant to the Massachusetts Endangered Species Act 321 CMR 10.00<br />

(MESA). The project requires a direct filing with NHESP for compliance with MESA and its implementing regulations.<br />

The Proponent must submit any NOI for this project for review in compliance with the Wetland Regulations (WPA)<br />

and MESA. Once these filing have been submitted, the NHESP can issue a formal determination pursuant to WPA<br />

and MESA.<br />

Response: The Notices of Intent for the project have been submitted to the conservation<br />

commissions in Newburyport, Amesbury and Salisbury with copies provided to the NHESP as of<br />

December 1, 2011.<br />

NHESP also submitted a copy of the correspondence to the three conservation commissions on the<br />

NOI applications, dated December 21, 2011.<br />

NHESP-2: The NHESP finds that this project, as currently proposed, will not cause adverse effects to the habitat of<br />

state-listed rare wildlife (310 CMR10.58(4)(b) and 10.59).<br />

Response: The comment is noted.<br />

NHESP-3: The NHESP notes that the project may require coordination with NMFS and compliance with their<br />

conditions to avoid impacting the Shortnose Sturgeon. If NMFS has indicated that it will not require additional<br />

conditions for Shortnose Sturgeon, or elected not to comment, this project will not constitute a "take" of these species<br />

(321 CMR 10.18(2)(a). If NMFS has required conditions for the Shortnose Sturgeon, then, all required conditions<br />

must be adhered to in order to avoid a "take" of these species (321 CMR 10.18(2)(a). If project plans change, the<br />

applicant must contact the NHESP prior to any work for further guidance.<br />

2-31

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