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

Whittier Bridge/I-95 Improvement Project FEIR
Chapter 2.0: Response to Comments on the Environmental Assessment/Draft Environmental Impact Report
anticipated that the conservation commissions will include conditions to ensure compliance with the
wetlands regulations. As of this writing, no conditions have been disclosed by the commissions.
EEA-7: The FEIR should identify and delineate any additional wetlands impacts to occur since filing the DEIR. The
FEIR should provide updates on any consultations with MassDEP regarding wetlands impacts and should address
MassDEP's concerns that the project may require a Variance under the Wetlands Protection Act.
Response: No additional impacts to jurisdictional wetland resources beyond those described in the
DEIR will occur. In fact, the wetland impacts of the project have been reduced through the redesign
of the proposed realignment of the I-95 Northbound Exit 60 off-ramp to the Route 1 Connector in
Salisbury and the elimination of the 1,150 square feet of permanent impact to Wetland 1 that would
have resulted from the previous design of the realigned off-ramp. Wetland 1 is an isolated wetland
which is not jurisdictional under the Massachusetts Wetlands Protection Act.
MassDOT has continued its coordination with MassDEP on wetland impacts and stormwater
management system design. MassDEP‘s comments are addressed in the response to comment
EEA-8 below. MassDOT will continue to work through any issues until the project is in full
compliance with the applicable regulations.
EEA-8: MassDOT should continue to coordinate closely with MassDEP and the federal permitting agencies to
develop appropriate mitigation strategies for any unavoidable impacts to wetland resource areas. According to
comments from MassDEP, MassDOT has agreed, in the FEIR, to propose a construction access management
system that will avoid problems that could lead to unpermitted wetland resource area alteration and environmental
degradation. MassDOT has also agreed to confirm in the FEIR, the process it will adopt to ensure that access and
staging areas will not impact resource areas, that contractors will be made explicitly aware of their compliance
obligations under the WPA, and that an experienced environmental monitor will be hired for project construction
oversight and contractor compliance training through the post-construction period. The FEIR should include details of
the contractual and field oversight measures that MassDOT will undertake to ensure protection of wetland resource
areas. MassDOT is continuing coordination with MassDEP and the federal permitting agencies and is finalizing
mitigation strategies for unavoidable impacts to wetland resource areas.
Response: The methods to be used to clearly delineate and ensure protection of wetland resources
in the field have been developed and are described in section 1.4.3. As noted in the comment, a
construction management access system will be developed and will be implemented by the
design/build contractor. The contract specifications will explicitly require that the contractor ensure
no impacts to wetland resource areas beyond those approved by permitting authorities. The contract
documents and plans will include language to ensure the contractor will not work in, alter, impact or
disturb any wetland resource areas other than those areas of proposed impacts as designated and
depicted within the applicable permit applications and permitted by the regulatory agencies.
Unpermitted wetland impacts will be avoided through worker isolation techniques including
permanent and temporary chain link fence, temporary orange snow fence, compost filter tubes, and
limit of work signage. All wetlands will be re-flagged, in accordance with previously issued Orders of
Resource Area Delineations (ORADs), prior to the start of work. Compost filter tubes, fencing and
signage will delineate the permitted work areas.
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