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

Resource Area Impacts
Based on the information included in the DEIR, it appears that the preferred altemative
limits impacts to resource areas such that it may not require a variance from the Wetlands Protection
Act as discussed in the ENF and may restore an area of salt marsh that is currently impacted by a
stormwater outlet. CZM notes that the flood zones, resource areas, and resource impact estimates
included in the DEIR appear to be based on available GIS overlays, not actual delineations. While
these mapping tools are adequate to generally characterize these features, use of appropriate FEMA
flood maps, field delineation of resource boundaries, and quantification of impacted resources and
associated mitigation will be required as the project proceeds through permitting.
Endangered Species Management
According to the DEIR, MassDOT has been coordinating review with the Natural Heritage
and Endangered Species Program and the National Marine Fisheries Service to address potential
impacts to rare species, Essential Fish Habitat (EFH), and non-EFH species in the Merrimack.
According to the DEIR, the preferred altemative will not result in impacts to these resources. CZ~
recommends that MassDOT continue to consult with these agencies throughout the permitting
process to assure these habitat impacts are minimized. According to the Massachusetts Division of
Marine Fisheries (D1Y.£F), a time-of-year (TOY) restriction may not be necessary to protect
diadromous fish species within the Merrimack River if cofferdam installation can be staged to allow
only one cofferdam to be installed at anyone time, thereby limiting impacts to 50/0 of the river width
at a given time. If this condition cannot be met, DMF recommends a TOY of March 1 to
November 1. CZM advises that the proponent continue to consult with DMF throughout
permitting and construction to assure that in-water work impacts are minimized.
Stormwater Management/ Wat~rQuality
The DEIR states that major stormwater management improvements will be constructed to
achieve compliance with stormwater standards where the highway layout is relocated or expanded.
Most of the existing stormwater discharges would remain in current condition, with only some of
these discharges improved or relocated. CZM recommends that MassDOT consider designing and
implementing improvements to existing stormwater management discharges wherever feasible as
part of this major redevelopment project. As stated in the DEIR, CZM recommends that
MassDOT continue to coordinate with state agencies in development of a stormwater management
system that fully complies with the Massachusetts Stormwater Standards.
The proposed project is subject to CZM federal consistency review, and therefore must be
found to be consistent with CZM's enforceableprogram policies. For further information on this
process, please contact Bob Boeri, Project Review Coordinator, at 617-626-1050 or visit the CZM
web site at www.state.ma.us/czm/fcr.htm.
BKC/kg/bb
cc:
Kathryn Glenn
CZM North Shore Regional Coordinator
Rachel Freed, Acting Section Chief
Northeast Regional Office; MA DEP
NancyB~er .
Northeast Regional Office, MADEP
David Slagle,
MA DEP Wetlands and Waterways