APPENDIX B
2008 ESPR Work Plan Certificate and Comment Letters
~
rtlie Commonwea[tli of ~assacliusetts
~cutive
Office ofrE,nergy andrE,nvironmenta{Jtffairs 100 Cam6ridge Street, Suite 900 (]3oston, :MJt 02114 DEVAL L. PATRICK
GOVERNOR
June 13,2008
TIMOTHY P. MURRAY
LIEUTENANT GOVERNOR
Tel: (617) 626-1000
Fax: (617) 626-1181
http://www.mass.gov/envir
IAN A. BOWLES SECRETARY CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ESTABLISHING THE SCOPE FOR THE 2010 SNOW AND ICE CONTROL PROGRAM ENVIRONMENTAL STATUS AND PLANNING REPORT PROJECT NAME
PROJECT MUNICIPALITY
PROJECT WATERSHED
EOEANUMBER
PROJECT PROPONENT
DATE NOTICED IN MONITOR
: 2010 Snow and Ice Control Program Environmental Status
and Planning Report : Statewide : Statewide : 11202 : Massachusetts Highway Department : May 7, 2008 As Secretary of Environmental Affairs, I hereby establish the scope for the analysis to be
presented in the 2010 Snow and Ice Control Environmental Status and Planning Report (ESPR). In
accordance with the provisions of 301 CMR 11.00 and 11.09 Special Review Procedures, this ESPR
process was established by the proponent and this office to replace the 2006 Generic Environmental
Impact Report (GEIR).
Project Description
The project consists of a description of the methods used by state agencies to control snow
and ice on roadways, the impact these methods have on the environment, and the mitigation
implemented to compensate for these impacts. The agencies participating in this ESPR process
include MassHighway, the Massachusetts Turnpike Authority (MT A), and the Department of
Conservation and Recreation (DCR)). MassHighway was the designated lead agency in preparing
the ESPR. The ESPR is to be the basis for snow and ice control on state-owned roadways in
Massachusetts. The purpose of this ESPR is to protect sensitive resource areas and determine
whether a proactive (rather than reactive) approach is needed. Three questions were posed in the
Certificate of December 1,2006 creating the ESPR process. The three questions are based on the
mapping of known sensitive areas:
o
Printed an Recycled Stock
EEA #11202 2010 ESPR Scope Certificate
June 13,2008
1. Does the nature of these sensitive areas suggest that the approach to snow and ice control
should be modified to provide better protection of these areas?;
2. Alternatively, is a purely reactive approach dictated by overriding public safety concerns?;
and
3. Can an intermediate approach be fashioned by developing up-front knowledge of expected
impacts and designing appropriate mitigation while remaining faithful to the public safety
issues?
History and Purpose of the ESPR
Prior Generic EIRs (GEIRs) were prepared in 1978, 1995, and 2006 for the Snow and Ice
Control Program. This 2010 ESPR is a continuation of this effort by MassHighway. Since 1978, the
GEIR (and now the ESPR) has provided a retrospective analysis of past trends in snow and ice
control on state highways and the environmental impacts from these snow and ice control measures.
These documents summarize the Commonwealth's snow and ice control measures at those times.
The 2010 ESPR should present an overview of the operational environment and of the planning for
snow and ice control by MassHighway. It should provide the long-range projections of
environmental conditions against which the effects of future snow and ice control can be compared.
The ESPR allows the reviewer to see historical environmental information, current information, and
the forecast of the future environmental effects of snow and ice control along the Commonwealth's
roadways. It serves as a vehicle for ensuring that long-term, broad-scope planning informs the
review and implementation of snow and ice control along state highways.
On May 7, 2008, the Proposed Scope for the 2010 ESPR was noticed in the Environmental
Monitor. While I have used that scope as a framework for this Certificate, I have modified it based
on the 2006 GEIR Scope, in response to the comments received, and internal EEA review.
Therefore, this scoping certificate is the governing document for the contents of the 2010 ESPR.
2010 ESPR Outline
The 2010 ESPR should follow the general format of the 2006 Scope for ESPR Work Plan.
The ESPR Work Plan represents a consensus, to the extent feasible, among MassHighway,
MassDEP, DCR, and the Natural Heritage and Endangered Species Program (NHESP), regarding
how the issues raised by the GEIR and the agency comments will be addressed. It should identify a
schedule for providing that information for MEP A review in the form of subsequent ESPRs. The
2010 ESPR should use the base information developed for the 2006 GEIR, present policy
considerations and an overview of MassHighway' s current and potential future role in controlling
snow and ice on state roadways, and include a status report on the MassHighway's proposed
planning initiatives and procedures.
EEA #11202 2010 ESPR Scope Certificate
June 13,2008
SCOPE
Executive Summary
The Executive Summary should provide a summary of the major sections of the ESPR, with
supporting graphics and data tables. It should be made available as a separate document to facilitate
wider distribution. The Executive Summary should be posted on MassHighway's web site. Section
1.0 through Section 5.0 should summarize the 2006 GEIR information, identify recent comments
and concerns, and identify future ESPR work.
1.0 MassHighway's Snow and Ice Control Program Operations and Policies
The ESPR should report on snow and ice control activity levels for 2004 to 2009. This
section should generally introduce the ESPR and should:
• 1.1 Describe the Snow and Ice Control Program: MassHighway's Management Structure;
Program Organization; Equipment, Facilities and Operating Cost. The ESPR should include
maps ofthe Commonwealth's roadways, highway districts and the locations of salt storage
facilities, designated reduced salt zones, municipal groundwater supplies, and Road Weather
Information Sensor (RWIS) locations. It should explain why the information in the GEIR did
not include snow and ice control data for the MTA or OCR. In order to make this snow and
ice control program statewide, the list of state agencies which provide snow and ice control
along their respective roadways was expanded. MassHighway is the lead agency in this
effort because it has the largest snow and ice control program statewide. MassHighway
should provide correspondence from the MT A, the Massachusetts Port Authority (Massport)
(Mystic/Tobin Bridge and other roads), the Massachusetts Bay Transportation Authority
(MBTA), and DCR regarding their participation and cooperation with MassHighway to
provide the necessary information to complete a statewide inventory of snow and ice
removal within the Commonwealth. In 2005, MassHighway was given the winter
maintenance responsibility for certain urban roadways managed by DCR. These Greater
Boston roadways include Centre Street, Fellsway, Fresh Pond Parkway, Jamaicaway,
McGrath Highway, Mystic Valley Parkway, O'Brien Highway, Revere Beach Parkway,
Storrow Drive, and the VFW Parkway. The ESPR should identify snow and ice control
procedures on these DCR roadways. It should discuss snow and ice removal procedures
along sidewalks and crosswalks within the right-of-way of MassHighway maintained
roadways. The ESPR should identify MassHighway policy for snow and ice removal along
sidewalks and at crosswalks. It should identify MassHighway snow disposal/dumping
guidelines.
• 1.2 Describe Historical Salt Usage vs. Winter Severity.
• 1.3 Describe Annual Training Program for Employees and Contractors.
• 1.4 Identify Salt Storage Facilities and Management Practices.
• 1.5 Describe MassHighway Vehicle Washing Practices.
• 1.6 Compare MassHighway's Snow and Ice Control Program with the Policies and
Procedures Used by other New England Transportation Agencies.
EEA #11202
2010 ESPR Scope Certificate
June 13, 2008
2.0 Environmental Resource Protection and Remediation
This section should include the following items:
•
•
•
2.1 An Update of the Reduced Salt Zones.
2.2 Salt Complaints and the Remediation Program.
2.3 Summary of Public Water Supply Sodium Data.
2.4 Summary of Recent Research Findings Related to other Environmental Resources.
2.5 Environmental Impacts Associated with the Use of Sand in Deicing Operations.
3.0 Existing Best Management Practices for Improving Road Salt Use Efficiency
This section should include the following items:
•
•
•
3.1 Anti-Icing and Pre-Wetting Techniques.
3.2 Alternative Deicers.
3.3 Road Weather Information Sensor (RWIS) Systems.
3.4 Summary of Other Best Management Practices (BMPs) including Pavement
Temperature Sensors, Snow Fences, Modified Drainage Systems, Alternative Pavements,
etc.
4.0 Roadway Infrastructure and Vehicle Corrosion Damage
This section should contain information on roadway infrastructure and vehicle corrosion
damage.
5.0 Economic Benefits of Safe Roadway Conditions
This section should provide information on the benefits of safe roadway conditions.
The ESPR should include a separate chapter on MassHighway's conclusions/
recommendations and mitigation measures that were incorporated into the ESPR. In the ESPR, the
proponent should commit to evaluating its snow and ice control program every five years to respond
to changing conditions. MassHighway should review the following topics during its evaluations:
•
•
•
•
•
Avoidance of sensitive areas for the location of salt sheds
Salt application rates
Snow-fighting equipment
Expansion or elimination of reduced salt zones
Evaluation of spreader routes to maximize efficiency and eliminate overlap
4
EEA #11202 2010 ESPR Scope Certificate
June 13,2008
• Consideration of alternative deicing chemicals, and the implementation of Best Management
Practices (BMPs) for all MassHighway construction/repaving projects within sensitive
reduced salt zones
• Salt storage management practices including housekeeping practices
• Statewide training program and materials for MassHighway personnel and snow and ice
contractors
The proponent should identify the dollar amount of its recommendations/mitigation
measures. MassHighway stated that it spends an additional $2,000 per lane mile in designated
reduce salt areas. It also reported providing $ 230,000 to 23 municipalities to upgrade their salt
storage facilities.
7.0 Response to Comments
The ESPR should address the issues raised in comment letters on the 1997 and 2006 GEIRs
and comments on MassHighway's Work Plan for the ESPR. It should include copies of all comment
letters listed at the end of the prior Certificates in 1997, 2006, and this Certificate. The ESPR should
provide a response to all comment letters within the scope of this project. MassHighway should
specifically address the issues raised in the MassDEP letter of June 6, 2008.
8.0 Circulation
The ESPR should be circulated in compliance with Section 11.16 of the MEP A regulations
and copies should be sent to the list of "comments received" at the end of this Certificate and the
Certificates on September 24, 1997 and December 1, 2006. A copy of the ESPR should be made
available for public review at the State Transportation Library.
10.0 MEP A Documentation
The ESPR should include a copy of this Certificate, and it should be made available in printed or CD-ROM format. Along with reliable information, ongoing public involvement will be key to a successful ESPR process. As part of its public information efforts, MassHighway should: • Convene one technical workshop during the public review process for MassDEP, NHESP,
DCR, Massport, Mass Turnpike, and the MBTA prior to submitting the Draft and Final
ESPR.
• Convene one public meeting as part of the MEPA hearing during the review of the Draft and
Final ESPR.
MassHighway has agreed to meet with MassDEP, NHESP, and the Area of Critical
5
EEA #11202 2010 ESPR Scope Certificate
June 13,2008
Environmental Concern (ACEC) Program Coordinator on an annual basis around Mayor June to
provide a brief update on recent changes and information related to the Snow and Ice Control
Program. It has proposed the following future ESPR Preparation Schedule:
• January 2010 - Initiate Compilation of Relevant Data (2003 - Winter 200911 0);
• January 2011 - Initiate Preparation of Draft ESPR;
• January - June 2011 - Consult/Coordinate with Resource Agencies and other Massachusetts Transportation Agencies; • December 2011 - Release Draft ESPR for Agency and Public Comment;
• January - April 2012 - Incorporate Agency and Public Comments into Final ESPR; and
• June 2012 - Release and Distribute Final ESPR.
June 13, 2008
Date
Comments received:
DCR, 311 0/08
MassHighway, 5/14/08
Connecticut River Watershed Council, 6/5/08
Norton Conservation Commission, 6/5/08
DCR,6/6/08
Stephen H. Kaiser - Friends of the Parkways, 6/6/08
WSCAC,6/6/08
Ingeborg Uhlir, 6/6/08
Boston Environment Department, 6/9/08
MassDEP, 6/6/08
11202esprscope
IAB/WG
6
cler Massachusetts
March 10, 2008
Kevin Walsh, Director of Environmental Services
Massachusetts Highway Department
Ten Park Plaza
Boston, MA 02116-2104
Re: Draft Environmental Status and Planning Report (ESPR) Work Plan for MassHighway's Snow
and Ice Control Program
(
Dear Mr. Walsh:
Thank you for providing the opportunity to review the Draft Environmental Status and Planning
Report (ESPR) Work Plan for MassHighway's Snow and Ice Control Program. DCR submits the
following comments on the Draft Work Plan, and looks forward to reviewing the final work plan when
submitted for review under the Massachusetts Environmental Policy Act (MEPA). In addition, DCR
looks forward to reaping the benefits from coordinating our efforts in applying this snow and ice
control on DCR roadways in the future.
DCR and MassHighway continue to share a strong working relationship at many levels that extends to
different projects and operations across the Commonwealth. As mentioned in the Draft Work Plan, in
2006, MassHighway began providing snow and ice control services for certain historic parkways under
the care and control ofDCR. This support and cooperation is invaluable to DCR, and we anticipate
that future cooperation and coordination between the departments will continue to provide enhanced
public benefits.
As mentioned in DCR's September 22, 2006 letter regarding MassHighway's Generic Environmental
Impact Report (GEIR), DCR has concerns about the cumulative impacts of the use of anti-icing and
deicing chemicals and sand wherever state highways, municipal roadways, DCR-maintained roads~ or
salt storage facilities are located adjacent to important water resources and other natural resources
under DCR's care and control. These include public water supplies, especially those designated as
Outstanding Resource V/aters (314 CMR 4.00); lakes, ponds, and rivers used for public recreation;
lacustrine, riverine, and wetland ecosystems, including river and stream segments identified as cold
water fisheries (314 CMR 4.00); and, the critical resources and ecosystems within designated Areas of
Critical Environmental Concern (301 CMR 12.00).
Future MassHighway/DCR Collaboration
The Secretary's Certificate and supplemental comments provided by the Department of Environmental
Protection (MassDEP) for the 2006 GEIR suggests that MassHighway and DCR, in conjunction with
MassDEP, should "develop and implement planning measures and operational practices ... applicable
for nCR parkways that are maintained by MassHighwai'. DCR acknowledges that this
recommendation is applicable to all DCR-·maintained roadways in close proximity to sensitive
resource areas in addition to roadways maintained by MassHighway. DCR is committed to provide
Department of Conservotioll and Recreation
251 Causeway Street, Suite 600
Boston r'1A 02114-2119
6J7-626-J250 617-G2(;-135} fax
ww\:v.mass.govjdcy
fJevci L. rat-rick
Ian t .. S,-:wies, S(-;uetary, Exeonivf:
MassHighway Draft ESPR Work Plan
Page 2
available information to MassHighway regarding its snow and ice program, and stands ready to work
with MassHighway to improve its data collection methods. Additional background information on
technologies such as Road Weather Information Systems (RWIS), pavement temperature sensors,
snow fences, and alternative pavements would be helpful to nCR as it assesses its current snow and
ice program.
In addition to the ACEC Program mentioned on pp. 12 and 19, nCR believes coordination during the
ESPR process should also occur with its Office of Watershed Management and storm water and
roadway management programs. nCR suggests these annual meetings should also include the topics
mentioned in the Secretary's Certificate including those under the Mitigation section (pg. 5) such as
salt application rates, expansion of reduced salt zones, or Best Management Practice (BMP)
implementation for all MassHighway and nCR road construction/repaving projects within sensitive
reduced salt zones.
Public Drinking Water Resources
For state roads in close proximity to public drinking water resources, DCR sees an additional benefit to
establishing an ongoing relationship with MassHighway whereby on an annual basis, MassHighway
shares information with DCR about anticipated snow and ice practices within roadways near
environmentally sensitive resources. Such data could include alternative techniques for de-icing or
other innovative best management practices employed by the industry. nCR's Office of Watershed
Management is available for consultation on this request. Salt application practices on nCR roads and
parkways are subject to review by the U.S. Environmental Protection Agency (EPA) as a BMP under
DCR's NPDES storm water discharge permit. The information and updates provided by MHD in the
summary will be integrated and reported with DCR' s Annual Report for Storm Water Management.
DCR would welcome the opportunity to share similar information regarding its snow and ice control
program with MassHighway as part of the ESPR process.
Sensitive Environmental Resources
DCR commends MassHighway's commitment to compile the latest information regarding the potential
effects of road salt use on environmental resources (see page 12). DCR suggests that MassHighway
work with other agencies, including DCR, MassDEP, and NHESP, to establish a definition of
environmentally sensitive areas. These areas could include rare species habitats, Zone II Wellhead
Protection Districts, wetlands, or Areas of Critical Environmental Concern. DCR supports
MassHighway's commitment to provide training with contractors for snow and ice treatment near
environmentally sensitive resources, and has appreciated being included in past trainings. DCR
encourages the additional step of integrating this recommendation into the Future ESPR Work under
1.3 Description of Annual Training Program for Employees and Contractors.
Continued collaboration between MassHighway and DCR for prioritizing ACEC communities for pilot
projects, study areas, or municipal grants related to environmentally sensitive resources and
implementing BMPs including expanding reduced salt zones, as needed, to these areas would be
greatly appreciated. DCR appreciates MassHighway's commitment in the draft Work Plan to
coordinate activities with the Kampoosa Bog Stewardship Committee. DCR would be interested in
participating in and assessing the results of a review of salt storage sheds within environmentally
sensitive areas, once a definition is agreed upon for these areas.
MassHighway Draft ESPR Work Plan
Page 3
Future ESPR Work detailed on p.12 proposes information sharing concerning use of deicer
alternatives. DCR suggests that MHD incorporate alternative deicing procedures resulting in reduced
salt application, to evaluate suitability and effectiveness of these methods in certain localized areas that
may be most sensitive to contamination from road salt runoff. DCR Office of Storm Water
Management and Division of Water Supply Protection can coordinate with MHD on these practices
and the evaluation of results.
DCR appreciates the opportunity to review and comment on this draft work plan before its formal
filing with the MEPA office, and looks forward to reviewing the formal MEPA filing. Please contact
Liz Sorenson (617-626-1394) for information related to ACEC Program issues, Chief Engineer Noel
Baratta (617-626-4948) for information related to storm water and BMP issues, Urban Parks and
Recreation Deputy Director Samantha Overton Bussell (617-626-4934) for information related to
DCR's snow and ice management program and Division of Water Supply Protection Director Jonathan
Yeo (617-626-4987) for information regarding state watershed lands and Outstanding Resource
Waters.
DCR continues to enjoy a positive working relationship with MassHighway on a variety of projects
and operations across the Commonwealth, and appreciates the opportunity to comment on this Draft
Work Plan.
cc: Elizabeth Sorenson, Joel Zimmerman, Jonathan Yeo, Noel Baratta, Samantha Overton Bussell
(DCR)
William Gage, EOEEA
CONNECTICUT RIVER WATERSHED COUNCIL
The River Connects Us
15 Bank Row, Greenfield, MA 01301
June 5, 2008
Secretary Ian A. Bowles
EOEA, Attn: MEPA Office
William Gage, EOEA No. 11202
100 Cambridge Street, Suite 900
Boston, MA 02114
Subject: Environmental Status and Planning Report Workplan for EOEA# 11202
Massachusetts Highway Department Snow and Ice Control Program
Dear Secretary Bowles,
I am submitting comments on the Environmental Status and Planning Report (ESPR) Workplan for
Massachusetts Highway Department's (MassHighway's) Snow and Ice Control program on behalf the
Connecticut River Watershed Council (CRWC). CRWC is the principal nonprofit environmental
advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed. We
submitted a comment letter on the Generic Environmental Impact Report (GEIR) when it was available
for public review in 2006. For the most part, the ESPR Workplan looks sound. Our comments are below.
1. On page 4, #1 under Future ESPR Work says MassHighway will evaluate alternative level of service
(LOS) standards for "environmentally sensitive areas." MassHighway should define what they mean by
environmentally sensitive area. We recommend establishing a buffer (50-100 ft?) around bridges
crossing or roads abutting any water body.
2. We are not sure why the City of Cambridge was singled out in Section 1.2 of the ESPR workplan,
other than MassHighway wanting to respond to their comment letter. MassHighway should commit to
frequent communication with any municipality that might be affected by state roadway segments in water
supply watersheds.
3. The GEIR was prepared in August 2006. The Secretary's Certificate did not give a due date for the
ESPR, but at the very least it should not be completed more than five years after the GEIR. The
W orkplan schedule is not rigorous enough. The Workplan was supposed to be submitted by December
31, 2007, and MassHighway should make up for lost time rather than drag out the process into 2012.
There is also no indication how often subsequent ESPRs will be prepared.
4. The Secretary's Certificate on the GEIR stated that MassHighway should send copies of the workplan
to commenters listed in the Certificate. We would like to note that CRWC was not automatically sent a
copy of the workplan; we had to request a copy after the notice came out in the Environmental Monitor.
We thank EOEEA for the opportunity to comment.
HEADQUARTERS: (413)
FAX: (413) 772-2090
772~2020
UPPER VALLEY: (802) 869~2792
E-MAIL: crwc@ctriver.org
LOWER VALLEY: (860)
WEB: www.ctriveLorg
704~0057
Connecticut River Watershed Council
Page 2
Sincerely,
Andrea F. Donlon, M.S.
River Steward
cc:
Cindy Delpapa, Massachusetts Riverways Program
Gage. Bill (EEA)
From:
Sent:
To:
Cc:
Subject:
Andrea Donlon [adonlon@ctriver..org]
Thursday, June 05, 200B 6:27 PM
Gage, Bill (EEA)
'Delpapa, Cindy (FWE)'
MassHighway ESPR work plan for snow and ice program
Attachments:
CRWC MassHighway ESPR work plan 06-05-0B.pdf
""",
CRWC
;ighway ESPR work
Dear Bill,
Attached is a comment letter on MassHighway's ESPR work plan submitted on behalf of the Connecticut River Watershed Council. EOEEA 11202. Andrea Andrea Donlon, River Steward
CONNECTICUT RIVER WATERSHED COUNCIL, INC.
15 Bank Row
Greenfield, MA 01301
phone: (413) 772-2020 ext. 205
fax: (413) 772-2090
email: adonlon@ctriver.org
Become a member today!
www.ctriver.org
1
0~/05/2008
14:37
5082850277
PAGE
Norton Conservation Commission
70 East Main Street
Norton, MA 02766
June 5, 2008
Secretary Ian A. Bowles
Executive Office of Energy and Environmental Affairs
Attn: MEPA Office
100 Cambridge St, Suite 900
Boston MA 02114
Dear Mr. Bowles,
The Norton ConselVation Commission has received the Work Plan for MassHighway's
Environmental Status and P1anning Report (ESPR) for the Snow and Ice Control
Program. Based upon review of this document, I offer the following COln.ments.
Section 1.1 describes spreader calibration certifications, incentives for better equipment
and annual training. The Norton Conservation Agent was invited to one of the annual
meetings and foun.d that it was helpful in emphasizing the need to avoid excessive
appHcations of salt. We have also observed that the stonn water management system at
the salt shed on East Main St., Norton has been. recently maintained ..MassHighway has
made attempts to address the expressed concerns of the Norton Conservation
Commission and their efforts haven't gone Ulll1oticed. Their cooperation is appreciated.
Section 1.6 describes a survey of other New England transportation agencies. As part of
the future survey, please require that M.assHighway add questions or a section. on other
states' treatment of stonn water leaving statc roads. While MassHighway is comparing
the roadway miles and annual salt usage rates etc. it might be beneficial to query other
states in their water quality treatment of anti-icing and deicing materials. Rather than
looking solely at how to reduce the amount of salt and oth.er agents, it might be beneficial
to look at a combination of usage reductions and treatment of the snowmelt together as a
more comprehensive control program particularly in environmental1y sensitive areas like
the Zone IIs and Priority Habitats.
Section 2.4 Massachusetts Rive~ay's Program suggested field data collection to assess
sodium and chloride levels in a:ffected streams and lakes. J agree with this suggestion and
request that ilie Canoe River at Rt. 495 and the Norton Reservoir at Rt. 140 be included
Ph011.e (508) 285~0275 • Fax (508) 2R5 ..0277 • cOllservation@nortoIuualls.c01TI
02
05/05/2008
14:37
5082850277
PAGE
in any field data collection. These two areas have previou.sly been discussed with MassHighway as areas of concern for the Norton Conservation Commission. Thank you. Sincer.ely, Jennifer Carlino
Conservation Agent
CC: Kevin M. Walsh, Director of Environmental Services
James P. Purcel1~ Norton Town Manager
03
cler Massachusetts
June 6, 2008
Secretary Ian A. Bowles
Executive Office of Energy and Environmental Affairs
Attn: William Gage, MEP A Office 100 Cambridge Street, Suite 900 Boston, Massachusetts 02114
Subject: EOEEA #11202, MassHighway Snow and Ice Control Program ESPR Work Plan
Dear Secretary Bowles:
The Department of Conservation and Recreation (DCR) has reviewed the Final ESPR Work
Plan sublnitted by the Massachusetts Highway Department (MassHighway) for its Snow and
Ice Control Program. In March 2008, DCR submitted comments on a draft version of the
Work Plan to MassHighway. DCR notes that the Final Work Plan does not appear to have
substantially changed from the Draft Work Plan that DCR previously reviewed. Therefore,
DCR would like to formally submit its March 2008 comments on the Draft Work Plan as the
official record of DCR comments for the Final Work Plan.
One noteworthy addition to the Work Plan is MassHighway's commitment to conduct a
research study that evaluates its existing operational procedures and identifies methods to
improve efficiency of its road salt use. DCR is available to work with MHD on its Snow and
Ice Control Program, including the development of the research study.
As noted in the March 2008 Draft Work Plan comments, please contact ACEC Director Liz
Sorenson (617-626-1394) for information related to ACEC Program issues; Chief Engineer
Noel Baratta (617-626-4948) for information related to storm water and BMP issues; Urban
Parks and Recreation Deputy Director Samantha Overton Bussell (617-626-4934) for
information related to DCR's snow and ice management program; and Division of Water
Supply Protection Director Jonathan Yeo (617-626-4987) for information regarding state
watershed lands and Outstanding Resource Waters.
Sincerely,
~
Richard K. Sullivan, Jr. Commissioner D2partrTlent of (:Or1se(\/ation and FZecreat:ori
251 CcUSe\Aray Street! Suite 600
Boston f'..1A. 02114- 2119
617-626'-1250
61.7-·626-135~
Fax
lan
Governor
8ov\'ies. Secreta!
I!,
tX2CL.Jt;'Je
Offlce of Energv & Environrnenta! j\ffairs
June 6, 2008
To:
From:
MEPA Unit of EOEEA, Room 900,
Attention: Bill Gage
100
Cambridge Street
Stephen H. Kaiser, PhD. Friends of the Parkways
MHD.Snow
andlceCo~trol PrQgrqm
EOEA #11202
The work plan needs to be expanded significantly in three primary areas:
1. Corrosion damage to vehicles
2. Corrosion damage to bridges
3. Effects of roadsalt on safety
MHD is correct that traditionally the largest component of salting damage in terms of dollars is
corrosion. We should seek to get a good quality assessment of salting damage to vehicles. MHD is partway
there in terms of identifYing the added costs of corrosion protection, but it must also identifY the effectiveness
of even this protection, since many vehicles still suffer from visible body rot, especially around wheel wells.
This factor must explicitly be included in the analysis.
Corrosion to bridges is especially critical, given the concerns about deteriorating transportation
infrastructure since the Minneapolis bridge collapse. That incident appears to have been caused by connector
plates which were only half as thick as needed, so corrosion does not appear to be a prime element in the
collapse. However, new attention has been placed on deteriorating bridges, and roadsalt is a major component
in this problem. The continued problems with the Longfellow Bridge are the result primarily of corrosion in
the deck, replaced in 1960 (atop a bridge structure originally built in 1906). The complexity of replacing the
bridge deck with minimal impacts on traffic flow and particularly the MBTA Red Line has resulted in major
cost increases ($200 million estimated project cost). Meanwhile, numerous other river bridges have been
identified as suffering from corrosion and related damage, including the Boston University Bridge and Eliot
Bridge. MHD must realize that through the use of road salt it is effectively poisoning its own bridges. The
best solution may be to have the bridge corrosion section actually authored by the MHD bridge section,
because they would be in the best position to evaluate corrosion damage with complete integrity.
The issue of road salt and safety has been a point of constant contention over the years. MHD should
summarized all past reports and comments on the safety issue, and not rely solely on a Marquette University
study. Past studies by state highway engineers have shown no connection between salting and safety, and I
have referred to these studies many times. Sadly, the result is that MHD stonewalls the existence of its own
studies.
In recent years, I have found Massport's ESPR on Logan Airport impacts to be quite informative, and I
hope that MHD can achieve a similar goal for its ESPR on Snow and Ice Control.
Page 1 of 1
Gage, Bill (EEA)
From:
Baskin, Kathleen (EEA)
Sent:
Monday, June 09, 2008 8:38 AM
To:
Gage, Bill (EEA)
Cc:
MEPA (ENV)
Subject: FW: MHO Snow & Ice Control Work Plan
Hi Bill, Attached are comments to MEPA for project # 11202, received by the Secretary on June 6. Thanks, Kathy From: Bowles, Ian (EEA) [mailto:lan.Bowles@state.ma.us] Sent: Friday, June 06, 2008 4:50 PM To: Baskin, Kathleen (EEA) Cc: Cash, David (EEA); Burt, Laurie (DEP) Subject: FW: MHD Snow & Ice Control Work Plan Kathy - can you reply or do whatever you do with comments like this? From: Alexandra [mailto:adawson@crocker.com] Sent: Friday, June 06, 2008 4:39 PM To: ian bowles Cc: wscac@rcn.com Subject: MHD Snow & Ice Control Work Plan Dear Mr. Secretary: Here are a few comments on this plan from the Water Supply Citizens Advisory Committee, a group with a long­
term interest in Massachusetts water quality. The main problem with the Work Plan is not the plan itself but the long period for development of the future ESPR. Does it really have to wait for 2012? The need for swifter action in indicated on page 11 of the present document where it is cheerfully reported that 90% of the 210 public wells with available sodium data reported sodium concentrations below 60/mg/L, and nearly 50% came in below 20 mg/L. These figures alone indicate a salt contamination problem that could affect public health, especially the health of babies" The work plan takes the data as evidence that contamination is occurring whether or not the well is close to a MHO highway, the implication being that the salt would otherwise be coming from local de-icing of roads and parking lots. This is not reassuring, and we agree with the OEP suggestion on page 11, that MHO develop a remediation protocols for sodium levels over the 20 mg/L found in wells near MHO roadways. We also agree with the comments reported in the work plan regarding LOS standards and historical road salt use. At one time, MHO's avowed standard was the "bare pavement" standard. Whether this standard has been changed or not, MHO has not shown a consistent enthusiasm for reducing salt use, despite the continuing damage to water quality, automobiles and roadside trees. A little more urgency would be welcome. Alexandra Dawson Co-exec director, WSCAC 6/9/2008 June 6,2008
Sec. Ian A Bowles
EOEA, Attn: MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114
9 2008
Dear Sec. Bowles:
The Final Work Plan for the Future Environmental Status and Planning Report
concerning the Massachusetts Highway Department Snow and Ice Control Program
includes many good features. I commend those who helped to develop this document.
These comments are intended to suggest that certain alterations to the Program can focus
on prevention instead of remediation.
1. To make the next ESPR more useful it should be prefaced by wide distribution of
current research reports related to impacts of sand, liquid deicers, etc. All of the
cooperating agencies will be better able to evaluate their actions if they have the same
information at the beginning.
2. Posting of the compiled list of related research on a web site or in the Environmental
Monitor can help to make the public aware of the latest findings with respect to
environmental impacts of snow and ice management. Local highway departments
would also be able to make use of this information.
3. Verify how much and where chemical deicing materials are actually used by Mass.
I-lighway Dept. and by contractors. Weigh out and in for every vehicle. Have GPS
tracking to verify the use is at the places designated. This will prevent mistakes or
unnecessary repeated applications.
4. Justify usage rate per lane mile with the help of#3 above. Many years ago the Mass
Turnpike Authority used over 30 tons per lane mile in a season. They poisoned the
municipal wells in the Town of Weston. Weston filed a suit against MTA and MHD.
The Turnpike Authority immediately reduced the application rate by 10 tons per
lane mile. There is no indication that the roads are any more dangerous as a result.
5. Figure out why the cost of the Reduced Salt Zones is so high. Are more man-hours
used because of repeated applications? Are training programs effective? Do other
contractors repeat applications? If testing of water supplies in the designated areas
indicates stable or reduced NaCI concentrations that is proof that the program works.
However, if other protections within a watershed have reduced the impacts of the
highway drainage, an RSZ may not be needed. For example, major changes are
underway at the Winter Street! 1-95 bridge area that are designed to reduce impacts on
the Cambridge reservoir. When they are finished that RSZ may not be needed.
6. The suggestions in #5 above apply equally to the ACEC Program.
7. Structural Damage to roads and bridges that is caused by chemical action on
reinforced concrete is out of control. Public safety should be a major concern for the
replacement or new construction of a bridge. As I told Sec. Bowles at a session on
budget items, "Stop building bridges that corrode and endanger the public.~' For
example, one proposed set of bridges north of Route 20 at 1-95 cannot be justified for
the benefit to one minor (9 acre) development while costing billions of dollars to
build and maintain. The example that comes to mind is the proposed fly-overs that
would take traffic from Route 117/Green Street to the Route 20 circle.
For over two years the bridge over Route 9 at Cedar Street in Wellesley has been held up by
netting. Visible chunks of concrete have already fallen off. This morning I must go under and
over that bridge. Each time I wonder if this will be the time one of the concrete piers gives way.
Don't build bridges like that again. Replace them with other materials that will not corrode with
each application of deicing chemicals. Minimize construction of new bridges for every developer
who puts money on the table to help build them and then leaves the repair and maintenance to
the Commonwealth.
Thank you for the opportunity to comment on the Final Work Plan for the Future ESPR for the
Mass. Highway Snow and Ice Control Program.
Very
tn!Jj2 ~_ . '/U:~ ·.
Ingeb~vfiilr
-;;;
45 Kendal Common Road
Weston, MA 02493
cc: Kevin M. Walsh, Director of Environmental Services
attn: Henry Barbaro, Wetlands {Jnit Supervisor 10 Park Plaza, Room 4260 Boston, MA02116-3973 Robert lIoward, Director of Public Works Department, Weston
Email copyto:RobertBennettat<robert.bennett@state.ma.us>
untitled
+MINNESOTA, -t7'.--of/
State Closes Bridges
In Wake of Collapse
Minnesota transportation offi­
cials have closed three busy
bridges since March, in a re­
sponse to1ast year's failure of
the Interstate 35W bridge over
the Mississippi River in Minne­
apolis.
All three closures deal with
compromised steel plates con­
necting bridge beams-identi­
fied by investigators as a key
factor in the collapse that
killed 13 people.
Minnesota seems more will­
ing than other states to put up
barricades even as engineers
across the country take a
harder look at steel truss
bridges with siprilar designs.
In the latest example, state
officials closed the Highway 43
bridge over the Mississippi
River in Wmona after an inspec­
tion found rust and corrosion
on several gusset plates, or con­
nector plates, on the span's
Wisconsin end. One of the
plates showed slight bending.
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June 9,2008
Ian A Bowles, Secretary
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, 9th Floor
Boston, MA 02114
Attention: William 'Gage, MEPA
Re: Massachusetts Highway Department Snow and Ice Control Program
Final Work Plan for the Future Environmental Status and Planning Report
EEA #11202
Dear Secretary Bowles:
The City of Boston Environment Department has reviewed the Massachusetts Highway
Department's (MHO) Highway Department Snow and Ice Control Program Final Work Plan for the
Future Environmental Status and Planning Report (ESPR Work Plan) and offers the following
comments.
In a 2006 Certificate of the then-Secretary of the former Executive Office of Environmental Affairs
included a request that the development of the ESPR Work Plan be coordinated with the
Massachusetts Port Authority (Massport), Massachusetts Bay Transportation Authority (MBTA)
and Massachusetts Turnpike Authority (MTA). Draft versions were sent to each agency; a
response was received only from Massport. MHO did not report the contents of Massport's
response.
We understand, as the MHO points out, that it has no control or shared responsibilities with the
other agencies and its policies and procedures have no bearing on their policies and procedures.
We also note that on September 24, 1997, then-Secretary Trudy Coxe issued a Certificate in
response to the Environmental Notification Form (ENF) for an MHO/Massachusetts Turnpike
Authority (MTA)/Metropolitan District Commission (MDC) Snow and Ice Control Program.
Secretary Coxe indicated her expectation that MHO would be the lead agency in preparing a
Generic Environmental Impact Report (GEIR), predecessor to ESPRs, and would solicit, but not
wait for, contributions from the MTA and MDC (now the Department of Conservation and
Recreations [OCR]). She noted that a joint effort of the agencies might be difficult due to "vastly
dissimilar levels of technology available to the agencies (e.g. computerized versus manual
dispensing apparatus), significant differences in the extent of public employee versus private
contractor utilization, and overall level of expertise in dealing with snow and ice controL"
Secretary Coxe further noted that she, "expect[ed] that the GEIR (once completed) will act as the
basis for snow and ice control on state-owned roadways in Massachusetts and I therefore
encourage the participation of the affected agencies, particularly the MDC, which is in the
BED comments - MHO Snow and Ice Control Program, Final Work Plan for the Future ESPR
EEA#11202
Page 2
Executive Office of Environmental Affairs." There was no discussion in the GEIR about attempts
to coordinate efforts with other Massachusetts transportation agencies.
It has been more than a decade since former Secretary Coxe found that a common snow and ice
control plan for state-owned roadways would be beneficial. She also identified technological
issues, snow and ice control expertise and categories of personnel to explain why a cooperative
effort might be challenging. Had transportation agencies worked with each other over the past 11
years with concentrated efforts on the identified areas of difficulty, the use of common
technologies, best practices, training resources, anti- and deicing-chemicals and the results of
research and overall expertise might now be serving the Commonwealth through cost-savings
and increased effectiveness and safety. This cooperation should be a goal of the Commonwealth
and we urge the Secretary to take the steps necessary with other Executive Agencies to move
toward this end.
We suggest that the ESPR include:
• the identification of areas where MBTA, OCR, Massport and MTA rights-of-way
(ROW);
• a detailed discussion of the benefits of standardized snow and ice control policies
and practices; and
• the responses from the state agencies/authorities that have replied to the MHO.
As we noted in our October 16, 2006 GEl R comments, the monitoring of criteria air pollutants to
establish compliance with National Ambient Air Quality Standards (NAAQS) does not provide
sufficient data upon which to reach conclusions about acceptable air quality; the NAAQS and the
State Implementation Plan (SIP) are not intended to reflect localized impacts. We note that the
majority of cites in the Air Quality section of 4.2, Environmental Concerns of Sand, date from the
early- to mid-1990s and we question if there is more recent data. Is there an established protocol
for determining the level of particulate matter in areas along MHO roadways where abrasives are
routinely applied and as the result of clean-up? Are ultrafine particles a potential concern with
abrasives used in this context? Have these questions been addressed in other jurisdictions and,
if so, with what results? If abrasives will continue to be a significant part of the MHO snow and
ice management program, air quality issues and mitigation should receive greater attention.
It has been 21 years since alternative paving materials were evaluated by MHO and section 3.1.5
does not include significant recent data from other jurisdictions. We suggest that MHO research
current options and engage in a multi-product testing program.
There is a brief discussion in this GEIR about an 11-year old survey of regional state agencies on
data program costs related to the percentage of private contractors used in the program.
Although data such as "lane miles" is not similarly defined amongst agencies, MHO concluded
that the use of private contractors was cost-effective in the long- term. In an updated 2001
questionnaire, information was sought about deicing agents, alternative technologies, annual salt
use, average traffic volumes and the extent of private contractor use. MHO concluded that it
operates a program similar in cost, predominant deicers, equipment and evaluation of other
technologies to those used by other transportation agencies in New England. An updated
analysis should be part of the ESPR.
BED comments - MHO Snow and Ice Control Program, Final Work Plan for the Future ESPR
EEA #11202
Page 3
More than 90 percent of diesel engine particulate emissions are highly respirable and carry toxins
deep into the lung, exacerbating human respiratory ailments. The U. S. Environmental Protection
Agency (EPA) has proposed classification of diesel exhaust as "highly likely to be carcinogenic in
humans." It estimates that diesel engines currently on the road can run for 1,000,000 miles and
remain in operation for as long as 20 to 30 years. Oxidation catalysts and catalyzed particulate
filters reduce toxic emissions of formaldehyde, benzene, acrolein and 1-3 butadiene by as much
as 70 percent. This amounts to 160 to 240 tons of pollution over the life of each engine. The
ESPR should indicate if on- or off-road diesel vehicles owned, operated or controlled by MHO or
contractors are used and, if so, the number should be identified. Measures to minimize air quality
impacts should be detailed.
Fuel prices are expected to continue increasing which will strain already tight public budgets. We
ask that the ESPR identify any conservation steps MHO has taken.
The cleaning of stormwater infrastructure is labor-intensive and costly. We ask that MHO discuss
in the ESPR the ways in which these structures are protected and maintained. If sweepers are
used to remove sand from roadways, we ask that MHO evaluate the use of regenerative type.
Thank you for the opportunity to offer comment. We look forward to the ESPR.
Sincerely,
Bryan Glascock
Director
MHD Snow.lce ControI60Bdoc.DBG:MTZ.mtz
COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
NORTHEAST REGIONAL OFFICE
205B Lowell Street, Wilmington, MA 01887. (978) 694-3200
DEVAL L. PATRICK
Governor
IAN A BOWLES
Secretary
TIMOTHY P MURRAY
Lieutenant Governor
LAURIE BURT
Commissioner
([CrlvEt
JUN 20_
Ian A. Bowles, Secretary
Executive Office of
Environmental Affairs
100 Cambridge Street
Boston MA, 02114
MEPA
June 6, 2008
RE: Statewide
Massachusetts Highway Department
Snow & Ice Generic Environmental Impact Report EEA #11202 Attn: MEP A Unit Dear Secretary Bowles:
The Department of Environmental Protection (MassDEP) has reviewed the Final Work
Plan for the Future Environmental Status and Planning Report to be prepared by Massachusetts
Highway Department (MHD) in lieu of the Snow & Ice Generic Environmental Impact Report
(GEIR), which provided an overview of the snow and ice control programs on Massachusetts
state highways (EEA #11202, formerly 2358). MassDEP provides the following comm~nts.
General Comment
The change from a generic environmental impact report to an environmental status and
planning report (ESPR) is viewed by MassDEP-NERO as an opportunity for MHD to be
responsive and proactive with respect to addressing agencies' and communities road salt
concerns. Modeled after an effective MEPA review process established for Massport, the ESPR
for Logan Airport is submitted in five-year intervals, and supplemented annually in the
intervening years between ESPR submissions with data reports that are subject to a 30-day
public review. As now envisioned by MHD, the Snow & Ice ESPR will not be submitted sooner
than December 2011 as a draft, to be followed six months later as a final report. MassDEP
respectfully requests that the review process and filing scheduled be redirected to mimic
Massport's program, which has been demonstrated to be effective.
In reviewing the future ESPR Work Plan, there appears to be information in each of the
five sections of the ESPR that could be provided sooner than December 2011. All accessible
information, for example, could be submitted as an Environmental Data Report (EDR) within six
months of the date of the Secretary's Certificate, and no later than December 2008, allowing
submittal of a meaningful report within a year of the Special Review Procedure established in the
Secretary's Certificate on December 1, 2006, requiring submittal of the Work Plan. Only by
This infor'mation is available in altemate format. Call Donald M. Gomes, ADA Coordinator at 617 -556-1057. TDD# 866-539-7622 or 617-574-6868.
http//www.mass gov/dep • Fax (978) 694-3499
o
Printed on Recycled Paper
Massachusetts Highway Department Snow & Ice Generic Environmental Impact Report EEA # 11202
expediting the Snow & Ice reporting process and providing more frequent dialogue and
exchange of current information on highway deicing practices will MHD and EEA be able to
establish a useful MEP A program that yields results and builds public confidence in the snow &
ice, state highway management practices.
Environmental Data Report (EDR)
An EDR would provide an opportunity to refine the Work Plan for the ESPR, and provide
the following information.
• Details, such as model inputs, weather and road condition data, study locations, and
modeling information for the longer-range study on salt use efficiency and salt use trend
analysis based on operation and equipment factors;
• Responses to comments on this Work Plan and make revisions, as appropriate, to the plan;
• Responses to comments on the 2006 GEIR that have not been addressed individually,
showing where they have either resulted in mitigation and/or inclusion in the ESPR;
• A proposal on the approach planned to show correlations between sodium data and road
salt management;
• Information that would be used to, "Coordinate with the Cambridge Water Department on
an annual basis ... "
Section 2.3 Summary of Public Water Supply Sodium Data The MassDEP-NERO Drinking
Water Program (NERO-DWP) has compiled several Excel graphs of sodium levels vs. time,
which were included in the NERO-DWP comments on the 2006 GEIR, but were not included in
MassDEP's final comments to MEPA. The graphs were for water supplies that are believed to be
receiving sodium inputs from adjacent state roads or state salt storage facilities. Some of these
are regularly updated; for example, North Chelmsford Water District (NCWD) collects quarterly
sodium samples from its four wells, and NERO-DWP has been keeping a graph of this data for
the last decade. Several of the graphs have been provided to David White of MassHighway's
Environmental Services Section in years past. NERO-DWP can readily provide updated graphs
of this sodium data to MassHighway.
If elevated and increased sodium levels are found in public water supplies, then item #4
for the "Future ESPR Work" also should include an evaluation of whether changes in MHD
practices are systematically resulting in increased sodium inputs to the environment. These
changes in practices would include, for example, the replacement of sand/salt applications with
applications of salt alone, and the increase in applications by private contractors.
Miscellaneous Comments
Although the Work Plan references contractor incentives for using improved spreader
equipment, the effectiveness of incentives should be demonstrated. Assuming that incentives are
demonstrated to be effective in the EDA and/or ESPR, MassDEP would recommend expansion
of the incentive program to road salt management training to contractors, and that the most
highly trained contractors and state employees be used for critical areas, such as public drinking
water supplies, Outstanding Resource Waters, and Areas of Critical Environmental Concern.
Establishing requirements for continuing education units (CEUs) could be linked to incentives,
2
Massachusetts Highway Department Snow & Ice Generic Environmental Impact Report EEA #11202
giving MHD greater oversight of highway maintenance practices and ensuring that progressive
road management techniques and advanced technologies be utilized to the greatest extent.
The Work Plan proposes to investigate the range of Level of Service standards, polices,
procedures, new technologies, and average annual deicing chemical usage rates for comparable
states in the Northeast region (Work Plan, Section 1.1). It is not clear why MHD is limiting the
study to the Northeast, since it would appear to be appropriate to look to all states with
comparable climate and highway systems, for a broader perspective on highway deicing
management practices. Information on minimum and maximum deicing chemical use rates, in
context with the circumstances associated with those application rates, also might shed light on
practical ways to refine deicing practices without compromising road safety objectives.
The Department recommends that the salt storage reporting be prospective, as well as
retrospective by providing information on planned improvements, including stormwater
management controls, and funding availability. What opportunities does MHD pursue for federal
funding or other funding sources for salt storage improvements?
In reporting on the coordination with the Cambridge Water Department, MassDEP
requests that the ESPR report on the status of the stormwater mitigation projects identified in the
environmental impact report MHD prepared for Hobbs Brook Reservoir.
With respect to salt storage facilities, it is requested that the Work Plan identify all salt
storage facilities that need improvements, including stormwater management controls that would
bring facilities into compliance with the Massachusetts Stormwater Management regulations and
associated performance standards.
The proposed work in Section 1.6 appears to be duplicative of the activities identified in
Section 1.1. It also appears that there is duplication in work plan activities proposed under item
5, Section 2.4 and item 1, in Section 3.2. If these work plan activities are different, the work
plan should be rewritten for clarity of purpose.
The Department requests that the water supplies identified in previous GEIR comments be
included among the water supplies for which sodium data will be reviewed for changes in
contamination levels and trends (Section 2.3).
An assessment of the reduced salt locations (Section 2.1) should identify any and all
former reduced salt zones that no longer have that status, with an explanation for the change in
status.
The salt complaints and remediation program should be described in sufficient detail to
understand how salt complaints are processed, the timeframe for processing and mitigation
implementation, the decision-making process that determines an appropriate response, and the
criteria used to accept and deny remediation.
The Department requests, as the agency did in its comment on the 2006 GEIR, that the
ESPR work plan evaluate the potential to expand R WIS stations, where data appear to show that
3
Massachusetts Highway Department Snow & lee Generic Environmental Impact Report EEA #11202
contamination levels are high and/or increasing, in areas near sensitive receptors, such as public
water supplies and critical areas.
The four wells in North Chelmsford affected by high sodium from the Drum Hill storage
facility are part of the NCWD, not the Chelmsford Water District. This was a typographic error
in the comments MassDEP provided to MEPA on the 2006 GEIR (Section 1.4).
The MassDEP appreciates the opportunity to comment on this proposed project. Please
contact Jim Persky at (978) 694-3227 for further information on the water supply issues in the
Northeast Region. If you have any general questions regarding the NERO comments, please contact
Nancy Baker, MEPA Review Coordinator at (978) 694-3338.
Sincerely, ~
J~a
Deputy Regional Director
cc: Brona Simon, Massachusetts Historical Commission
Phil Weinberg, Kathy Romero, Suzanne Robert, Derek Standish, Tom Maguire, MassDEP­
Boston
Jim Persky, Nancy Baker, Pam Merrill, MassDEP-NERO
Dennis Dunn, Warren Kimball, Elizabeth Kotowski, Mark Mattson, Stella Tamul,
MassDEP-CERO
Sharon Stone, MassDEP-SERO
Craig Givens, MassDEP-WERO
4