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

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elative to the Merrimack River’s NFIP base floodplain- NEPA regulations require that MassDOT<br />

demonstrate the project’s compliance with EO 11988 as part of the project NEPA review<br />

process.<br />

The basic EO 11988 compliance requirement for this project is that the new <strong>Whittier</strong><br />

<strong>Bridge</strong>, when constructed, will conform to applicable NFIP base floodplain development<br />

performance standards. Because the existing bridge crosses a waterway with both a computed<br />

BFE profile and a regulatory floodway delineation, there are two critical NFIP development<br />

performance standards that project activities must meet- construction of the new <strong>Whittier</strong><br />

<strong>Bridge</strong> cannot neither result in any increases to the Merrimack River’s existing BFE profile, nor<br />

necessitate alteration to the river’s existing regulatory floodway delineation, at any point<br />

within the affected communities. If implementation of the new bridge will not meet both of the<br />

above, NFIP regulations ( and, by direct extension, the terms of EO 11988) require that<br />

MassDOT file a pre-construction Conditional Letter of Map Revision (CLOMR) with FEMA<br />

pursuant to revision of the river’s currently effective base floodplain mapping products.<br />

Engineering Methods<br />

Base Flood Hydrologic Analysis<br />

Peak base (100-year) flood discharges for the Merrimack River used in this evaluation<br />

were adopted from the Essex County FIS and are presented in Table 1. See Reference 1 for<br />

computational procedures.<br />

Base flood Hydraulic Analyses<br />

The following five step procedure as followed to determine the probable impact of the<br />

<strong>Whittier</strong> <strong>Bridge</strong> Project on the Merrimack River’s existing NFIP BFE profile and regulatory<br />

floodway delineation. This procedure is consistent with FHWA and FEMA base floodplain<br />

encroachment review guidelines set forth in References 9 (44 CFR Part 65) and 10 (23 CFR. Part<br />

650.115).<br />

1. A “hard” copy of the input file for the USACOE HEC-2 Water Surface Profile Model developed<br />

to determine the Merrimack River currently effective BFE profile and regulatory floodway<br />

delineation in Newburyport was secured from the FEMA NFIP Engineering Library in<br />

Alexandra, VA. This “Currently Effective” HEC-2 model was complied in 1977 by the USACOE<br />

NED during the Newburyport FIS. The river reach considered in the model was about 28,200<br />

feet long- extending from a point located about 13,100 ft downstream of the I-<strong>95</strong> crossing- to<br />

the Newburyport/ West Newbury Corporate Limit. The model itself consists of seven river cross<br />

sections linked along a linear river channel alignment. The USACOE apparently intended that<br />

this model serve as a means of simulating the occurrence of the Flood of March 1936 over the<br />

study river reach. So, it’s river cross section grid was deliberately assembled so as to reflect<br />

built and natural environmental conditions along the banks of river just prior to that flood<br />

event. Consequently the model did not incorporate any cross sections surveyed at the location<br />

of bridges and other shoreline structures constructed after 1936 (including the existing<br />

<strong>Whittier</strong> <strong>Bridge</strong>). Pertinent “Current Effective” HEC-2 model configuration data are presented<br />

in Appendix 1, Table 1.<br />

2. The entire content of the effective Merrimack River HEC-2 model input file was manually<br />

programmed into a contemporary, windows-based water surface profile modeling application -<br />

USACOE HEC-RAS (River Analysis System) Version 4.1. The resulting HEC-RAS model was then<br />

calibrated so as to reproduce the river’s BFE profile as shown on Flood Profile Sheet 81P of the<br />

Essex County FIS within 0.1 feet - and thus constitute a “Duplicate Effective” Merrimack River<br />

hydraulic model.<br />

3. The “Duplicate Effective” HEC-RAS model was then modified to reflect current local<br />

topographic and built environment conditions with the existing <strong>Whittier</strong> <strong>Bridge</strong> in place-and<br />

thereby yield a “Pre-Project (Existing) Conditions” HEC-RAS model. This process involved first<br />

inserting two river cross sections (one acquired just upstream and another acquired just

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