APPENDIX C
1997 GEIR Certificate and Response to Comments
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Tel: (617) 727-9800
Fax: (617) 727-2754
http://www.magnet.stale.ma.usJenvir
AAGEO PAUL CELLUCCI
GOVERNOR
TRUDY COXE SECRETARY September 24, 1997
CERTIFICATE OF THE SECRETARY OF ENVIRONMENTAL AFFAIRS ON THE ENVIRONMENTAL NOTIFICATION FORM PROJECT NAME
PROJECT LOCATION
EOEA NUMBER
PROJECT PROPONENT
DATE NOT I CEO IN
r~ONITOR
Snow and Ice Control Program
Statewide
11.202
Massachusetts Highway Department/
Massachusetts Turnpike Authority/
Metropolitan District Commission
June 24, 1997
Pursuant t·- :he Massachusetts Environmental Policy Act
(M.G.L. c.30, ss.61-62H) and Sections 11..04 and 11.06 of the MEPA
regulations (301 CMR 11.00), I hereby determine that this project
requires the preparation of a Generic Environmental Impact Report
(GEIR) .
The Environ~~ntal Notification Form (ENF) was filed in
accordance 'with my Certificate (dated August 31, 1995) for the
Final Generic Environmental Impact Report. The GEIR is intended
to allow state agencies and the public an opportunity to review
and comment on the methods state agency pr0grams utilize 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 GEIR
process include the Massachusetts Highway Department (MHO), the
Massachusetts Turnpike Authority (MTA) and the Metropolitan
District Commis>::10n (MOC). I expect that the t-!HD will be the
lead agency in p... ,!paring· the GEIR (a role the MHO has agreed to
RECYCLED PAPER
EOEA #11202
ENF Certificate
September 24, 1997
assume) and that it will solicit (but not necessarily wait for)
contributions from the MTA and the MOC.
A joint effort may prove difficult to complete in a timely
and effective manner because of the 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. Past experience suggests that an effort at joint
participation in completing this particular environmental review
process may be futile. However~ I expect that the GEIR (once
completed) will act as the basis for snow and ice contro~ on
state-owned roadways in,Massachusetts and I therefore encourage
the participation of the affected agencies, particularly the MOC,
which is in the Executive Office of Environmental Affairs.
I herewith formally disband the Salt Advisory Committee
(which reportedly has not met in seven years); I do not plan to
form a Citizen Advisory Committee for this GEIR. Instead, I will
ask the proponent to distribute theGEIR to interested entities
and individuals so that they have an opportunity to comment on
and/or benefit from reviewing the GEIR.
The MHD prepared a draft Scope of Work for the GEIR and
attached it to the ENF. The draft Scope was subject to public
review during a 45· day public review and comment period. A
public meeting. was held at the State Transportation Building in
Boston on July II, 1997. The final Scope that follows includes
c~anges based on the oral and written public comment received
during that period and at the hearing.
Background
The original ·draft GEIR
report was prepared in 1978.
in the Environmental Monitor
report was reviewed in 1989;
July 25, 1995, which I found
was reviewed in 1976, and a final
An ENF for an Update was published
dated November 12, 1985. The draft
the final report was submitted on
to be adequate in my Certificate
2
EOEA #11202
ENF Certificate
September 24, 1997
dated August 31, 1995. A Section 61 finding was filed on March
19, 1997. The overriding concerns during the FGEIR review as
well as this ENF review are protecting sensitive resource areas
and determining whether a proactive (rather than reactive)
approach is needed. More specifically, three questions are posed
by the mapping of known sensitive areas: l}does the nature of
these 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? or 3} can an intermediate
approach be fashioned by developing up-front knowledge of
expected impacts and designing appropriate mitigation while
remaining faithful to public safety issues?
SCOPE
General
The EIR should follow Section 11.07 of the MEPA regulations
for outline and content and address the issues described below.
The EIR must be a stand alone document and include a copy of this
Certificate and the comment letters and must address the issues
raised in those comments as they are pertinent to this review and
scope. The GEIR should be completed within 18 months of the date
of this Certificate.
The following is an annotated outline for the GEIR:
I.
SECRETARY'S CERTIFICATE ON THE ENF
II .
EXECUTIVE SUMMARY
III. INTRODUCTION
1.
2.
3.
4.
Purpose and Need of the GEIR
MEPA Review Process Past and Future
Public Input Past and Future
Summary of the Past GEIR Recommendations
3
---EOEA #11202 IV.
ENF
Certificate
september 24, 1997
EXISTING SNOW AND ICE CONTROL PROGRAM
1. Management Structure and Organization
2. Operating and Capital Costs
a. Snow and Ice Control Program Costs
b. Additional Costs of Reduced Salting
c. Impacts on Catch Basin Cleaning Frequency
3. Annual Salt Usage
1. History of Salt Use
a. By District
b. By Lane-mile
c. Quanitatively·Compare Salt Usage to Storm
Variability (i.e. meteorological conditions,
antecedent weather conditions, traffic,
time of day, etc./.
2. Basis for Statewide Application Rate Policy of
240 pounds/lane-mile
a. Application Rate versus Quantity
b. Calibration Procedures and Audits
4. Optim~zing Deicing Chemica~ Usage
a. Maintenance Manual Criteria for
Controlling De-icing Materials
Application Timing and Frequency
b. Use of the Road Surface Weather
Information System
c. Annual Training Program
d. Contractor Calibration Program and Equipment
Maintenance and Contractor Certification Process
e. Status of "Watch Dog Program"
S. Salt Contamination Complaints Program
a. Investigative Methodology
b. Results of Public Well Complaint Investigations
c. Private Well Complaint Investigation Summary
4
EOEA #11202 ENF Certificate
September 24, 1997
6. Status of Salt Storage Practices
7. Municipal Deicing Practices
a. Jurisdictional Issues
b. Technological Exchange Program (e.g., BayState Roads Program) 8. Review of MDC, MTA and other New England states Snow and Ice Control Programs V.
BEST MANAGEMENT PRACTICES
1. Reduced Salt Programs
a. Locations, Reasons and Effectiveness
b. Case Study: Cambridge Water Supply,Sodium
Contamination Study
2. Alternative Deicing Chemicals
a. Sand, Premix, Liquid Calcium Chloride
b. Results of CMA Experiments
c. Results of Calcium Chloride Experiments
3. Alternative Pavements
4. Modified Drainage System - Case Study
a. Route 25 in Bourne
5. Review of New Technological Advances For Snow and Ice'Control VI.
IMPACTS OF SNOW AND ICE CONTROLS
1. Public Water Supplies
a. History of Human Health Considerations
b. Review of Statewide Public Well Information
c. Review DEP files of Sodium Data in Municipal
Wells
d. Massachusetts Wellhead Protection Program ­
Zone II and Interim Wellhead Protection Area
5
EOEA #11202 ENF Certificate
September 24, 1997
Delineations (i.e. MHO Approach to Protection)
e. Surface Water Supply Protection
f. Assessment of Potential for Contamination Risks
g. Storm Water Quality Degradation as it Relates to the
Control of Snow and Ice (Qualitative Comparative
Analysis)
2. Other Environmental Concerns'
a. Soils
b. Roadside Vegetation
c. Agriculture
d. Surface Waters
e. Fisheries
3. Environmentally Sensitive Areas
a. Areas of Critical Environmental Concern
b. Outstanding Resource Waters
4. Infrastructure and Vehicular Corrosion
S. Improved Roadway Conditions and Other Benefits
a. Effect on Rates of Vehicular Collisions
. b. Employee Attendance and Work Force Product~vity
c. Effects on Trucking/Shipping and
Business Commerce .
VII. Conclusions
VIII. Recommendations
Appendices
i. Response to Comments
ii. Certificate on FGEIR
iii.Comments Received on FGEIR
iv. ENF Form
v. Bibliography
6
COMMONWEALTH OF MASSACHUSETIS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENVIRONMENTAL PROTECTION
ONE WINTER STREET, BOSTON, MA 02108 617-292-5500
WILLIAM F. WELD
TRUDYCOXE
Governor
Secretary
QEUE\1~U
~UG ': i lWl
ARGEO PAUL CELLUCCI
Lt. Governor
July 31, 1997
Commissioner
MEP" Trudy Coxe, Secretary
Attention: MEPA Unit
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, MA 02202
RE: DAVID B. STRUHS
EOEA #11202 (formerly #2358) Snow and Ice Control Program,
Environmental Notification Form (ENF) for a Generic EnvironmentaHmpact Report.
Dear Ms. Coxe:
The Department of Environmental Protection, Bureau of Resource Protection (BRP) offers the following
comments on the referenced ENF and the scope for the proposed Generic Environmental Impact Report
(GEIR) covering the Snow and Ice Control Program statewide.
The GEIR is currently the environmental agencies only window on the state highway practices for snow
and ice control. Winter after winter, in the many years that intervene between MEPA reviews ofthe
GEIR, snow and ice practices are carried out on our highways. What progress is being made to improve
protection for surface and groundwater supplies because of the comments on the FGEIR? Are the
reduced salt practices effective, and do they protect our most susceptible drinking water supplies? Two
years ago, the Bureau identified issues that were important to the protection of drinking water resources;
the dialogue continues herein and many of these issues are raised again.
DEP 0 \
~
The Bureau would like to expand this dialogue into a more meaningful effort that yields tangible results
in the near term. Specifically, hard evidence is requested now to show that implementation of beneficial
mitigation measures promised in previous GEIRs is making a difference in water quality impacts. The
Bureau wants assurances that our highest priority surface supplies are covered by mitigation measures
that will provide adequate protection. Where this is not happening, BRP offers to work with the
Massachusetts Highway Department to improve implementation of the mitigation plan and schedule the
most appropriate measures to address our priorities short and longer term.
General Comments
1. One purpose of a generic EIR is to "(a)ssist agencies in fulfilling their responsibilities under M.G.L./
C.30, s.61 to review periodically, evaluate, and determine the environmental impact, if any, of their I
implementation of program responsibilities." A long-standing shortcoming of the GEIR for Snow
and Ice Control has been the low level of participation by the Massachusetts Turnpike Authority, Massport, and the Metropolitan District Commission. These agencies, with state highway operation and maintenance oversight of snow and ice control, also have responsibilities under M.G.L. C.30, s;61 which should be fulfilled in the proposed GEIR.
.
'
IDEP-02. DEP on the World Wide Web: http://www.magnet.state.ma us/dep
6
Printed on Recycled Paper
Snow and Ice ENF, EOEA #11202
07/31197
Page 2
2. The DEP comment on the Final GEIR (August 24, 1995) raised significant issues regarding the
environmental impact analyses and the mitigation plan covering the Massachusetts Highway
Department's (MHD) Snow and Ice Control Program. It is requested that those comments be
incorporated fully into the scope to ensure that the issues of concern to DEP are integrated into the
GEIR document and not addressed in a response to comment section only.
-D c:p _03
L
3. The next GEIR should recognize and reflect the approach the state is taking in the Stormwater
Management Policy (November 1996) to control water quality in stormwater runoff, particularly in
critical resource areas (Outstanding Resource Waters, shellfish growing areas, swimming beaches,
cold water fisheries, and recharge areas for public water supplies).
Snow and ice management on state highways results in stormwater quality impacts, which need to be
evaluated in context with the Stormwater Policy goals and standards. For example, critical resources
receive a higher degree of protection in the Policy; more runoff from the early part of a storm event
must be subject to treatment and only certain structural stormwater controls (BMPs) can be used in
these areas. Road salt impacts are not controlled easily through the use ofBMPs, however. Sodium
is soluble in meltwater, and is transported overland and subsurface, without being attenuated by
conventional storm water BMPs. It also is persistent in the environment and will tend to accumulate
with repeated applications. Thus, the use of source controls and other nonstructural techniques will
be the most effective means for controlling road salt and its byproducts.
L
OEP-Q I
The focus of source control management should be on road salt application; the use of alternative
deicing chemicals, particularly liquid calcium chloride, which appears to have fewer environmental
impacts; and storm drain maintenance that includes rigorous catch basin cleaning and street
sweeping in early spring. New computerized monitoring equipment, combined with the Road
Surface Weather Information System, is being used in other states to control more precisely the use
of deicing chemicals in critical resource areas. The ENF indicated that some of these techniques are
being tested by MHD in pilot studies. Given the need to replace the Material Control System, which
was abandoned in the early 1990s, this research should be incorporated into standard operating
procedure, especially in reduced salt and critical resource areas where salt levels are elevated.
Expanded use of calcium chloride looks very promising. Calcium chloride has been shown to be
more effective than rock salt at low temperatures, and it is cost-effective. Furthermore, the results of
the MHD ~?~i-Icing Experiment. Liquid Calcium Chloride (1993,94,95) indicate that No Salt- Area! h~
are a posslblhty:
_
~~
"The most significant feature ofthe entire experiment is the fact that eleven miles of state
highway was maintained safely through extreme weather conditions for two years without
the use of any salt whatsoever. This last statement has a great impact on how this material
could be used in the future. In a climate of environmentally sensitive issues, the possibility
of low salt areas becoming No Salt Areas should progress on the Departments part."-===""".;_
4. The Draft GEIR (1989) included a mitigation plan that should be the basis for a revised mitigation
plan in the next report. Recent and historical data showing road salt impacts should be linked to
specific mitigation measures, to the greatest extent possible, in order to show improvements that
have been achieved through implementation of the mitigation plan. Recommendations for changes
to the plan also should be based on interpretation of the data.
Specific Comments
1. Considering that watersheds in Massachusetts are becoming the planning unit for environmental
protection, it is requested that the following information be provided on MASSGIS maps, within
their respective watersheds and subbasins: highway ramps (and other areas subject to higher than
p
;-­
Snow and Ice ENF, EOEA #11202
07/31/97
Page 3
average road salt use), salt storage areas, reduced salt areas, and critical resources (from available
datalayers) to help facilitate DEP review of the GEIR. The maps should show the relationship
between the 41 reduced salt areas and critical resource areas, such as public water supplies. It should
be clear where salt use been reduced in Zone II (or Interim Wellhead Protection Area (IWPA)) and
Zone A areas of water supplies. What plans are there to expand the reduced salt program around
drinking water supplies? Are signs posted in all reduced salt areas? The status of the reduced salt
mitigation plan in the DGEIR (1989) also should be explained.
2. Snow disposal practices (for snowbanks and snow piles that are removed and disposed) should have
been included in the Preliminary List ofDiscussion Topics, the basic scope outline, which was
appended to the ENF. The next report should explain MHD's disposal policy and show that it is
consistent with DEP's Snow Disposal Guidance, which discourages disposal of snow, which is
contaminated with sand, dirt, litter, and automotive residuals, in waterbodies and other specified
areas.
D
3, Proper snow management practices which spread snow and meltwater from paved surfaces over
vegetated pervious areas using level spreaders, plows, and berms should be explained in the next
GEIRalso,
4, The MHD's Salt Application Policy does not have a direct effect on road salt impacts, because
policy is based only on the road salt application rate, Salt use control is dependent on the standards
of maintenance, which should be addressed by policy. In consideration of this issue, the GEIR
should present a thoughtful assessment of the strengths and weaknesses of the current policy and
consider revisions that would make it possible to understand the relationship between improved road
salting policies, practices, and observed changes in salt concentrations in the environment.
"~I
5. An update of the state and municipal storage shed building program should identify (and locate on
maps) the areas where sheds have not been, or cannot be, constructed. In the last GEIR, 15 state
operated salt storage areas were without sheds. What is their status, and do any remain in protected
areas around public water supplies? What progress has been made to cover and control these salt
piles to minimize road salt runoff?
6. The GEIR should assess the success of the Salt Contamination Complaints and the Reduced Sarr-~
Area Programs. How many requests are received and approved or rejected for each program
annually? What is the public perception of these programs? How is the Complaints Program
advertised to alert the public water supplier and private well owner of the opportunity to have their
wells evaluated for road salt impacts? Has greater attention been given to notification of homes and
businesses on rural highways, where private wells tend to be near state highways (Main Streets)?
---
The GEIR should include the package of information that introduces a homeowner or public water
supplier to these programs. An explanation of the requirements for data collection and submittal,
and the highway department review and approval process should be provided. In addition, a sample
application would be useful to show the type of information needed, the analysis of data, and the
reasons for rejecting and accepting an application. A summary ofthe program for the past five years
should include annual complaint requests, locations of requests, and decisions.
7. Although the focus of the GEIR will be on source reduction management techniques for road s~
there will be situations where storm drainage systems need to be considered in order to minimize
impacts. The ENF indicates that modified drainage systems, including snow berms, have been
studied "(t)o prevent groundwater contamination." Situations where drainage systems are considered
for modification to minimize impacts should include the following.
f,) ()
Snow and Ice ENF, EOEA #11202
07/31/97
Page 4
• When data do not show reductions in sodium levels, despite implementation of a reduced salt
program, the GEIR should consider alternative mitigation, including modification to existing
drainage outlets.
• When the MHD is proposing changes to its highway drainage system that discharges into a
protected area (Zone I, II, IWPA, or Zone A) around a public drinking water supply, sodium
levels in the water supply should be checked. Where elevated, alternative drainage system
designs should be proposed to minimize the potential for sodium migration into these critical
resource areas. Emergency spill control measures in drainage system designs and signage to
protect water supplies should be considered too.
Assistant Comissioner
Bureau of Resource Protection
cc. Dave Terry, Director, DWP
H.Barbero, MHD
David Murphy, DEP
Damon Guterman, DEP, DWP
Tara Gallagher, DEP, DWP
Michael Stroman, DEP, Wetlands
Jane Downing, EPA
Jana Leung, DEP, CERO
John Felix, DEP, NERO
Sharon Stone, DEP, SERO
Elizabeth Kouloheras, SERO, DWW
Nancy CaffaIl, DEP, WERO
AODINB/nb
C:msoffice/snow-ice.scp
DE. \' COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
DEPARTMENT OF FOOD AND AGRICULTURE
LANCASTER REGIONAL FIELD OFFICE
142 OLD COMMON ROAD, LANCASTER, MA 01523 (508) 792-7711 FAX (508) 365-2131
WILLIAM F. WELD
Governor
TRUDY COXE
Secretary
ARGEO PAUL CELLUCCI
Lt. Governor MEMORANDUM
To: ...
i
MEPA Trudy Coxe, Secretary
Executiv~ Office of Environmental Affairs Attn: Doug Vigneau
From: Marcia
Re:
JUL 11 i91
JONATHAN L. HEALY
Commissioner
MEPA Unit
starkey)~S
EOEA #11202
1998 Update of the GEIR for Snow and Ice
Control Project
statewide
Date: 8 July 1997
This Environmental Notification Form presents a preliminary
list of discussion topics for the 1998 GEIR Update. Impacts
of snow and ice controls would discuss roadside vegetation,
soils, agriculture and surface waters, which should include
cranberry bog reservoirs and aquacultural areas.
VFA---Q\
-,,------------~--~.--~------
The Department request s t hat a disc ret e sect i on of the UPdate..t1
discuss MHD findings and best management practices which
Pf:A­
apply to agricultural areas, particularly with respect to
over-the-shoulder impacts under BMP c~dition~~_an~_~re}ated to
~!'b~~e.;'~_SL 0L_th~~~~Lt i ng ,!:~hi c'LE?J Recommendat ions for an
effectlveTleld edge or vegetated buffer may be helpful to
Di=
agricultural activities which are adjacent to highways, as
would other advice and contacts useful to farmers and growers
S9_~S_E:l_r:EL~jL~~:Lg~b___ !bi.sL~§UEL~J Are low sa rtzoi1es-a--reasloT
measure for lessening impacts already discernible on
farmland?
~---
-~---=-,"~~
We also request that the Update discuss the inclusion of a
section on agricultural and aquacultural areas within its
guidance documents which could reach state contractors and
local jurisdictions.
c/MHD MEPA Coordinator Massachusetts Farm Bureau Cape Cod Cranberry Growers Association THE COMMONWEALTH OF MASSAC:HUSETTS
EXECUTIVE OFFICE OF ENVIRONMENTAL AFFAIRS
RECEIVED
OFFICE OF COASTAL ZONE MANAGEMENT
100 CAMBRIDGE STREET, BOSTON,
(617) 727-9530
MA
02202
FAX, (617) 727-2754
JUL 141997
MEPA
MEMORANDUM
To:
From:
Date:
Re:
(I
V
Ira
~
Director, MEPA ~ \A ' \
Brady, Director, MCZM
>
R. J. Lyman,
Margaret M.
July 11, 1997
EOEA # 11202 1998 Update of the GEIR for the Snow and
Ice Control Project; Statewide
The Massachusetts Coastal Zone Management (MCZM) Office has
completed its review of the above-referenced Environmental
Notification Form (ENF) , noticed in the Environmental Monitor dated
June 24, 1997, and recommends the preparation of an Environmental
Impact Report.
o
MCZM supports the preliminary list of discussion topics listed by the proponent for the 1998 update of the GEIR. MCZM suggests that Massachusetts Highway Department should also investigate how snow and ice control activities can be conducted in a manner that is consistent with two recent policies issued by the Department of Environmental Protection (DEP): the Stormwater Management Policy; and the Snow Removal and Disposal Policy. mC:ZM~OI
The Stormwater Management Policy calls for the use of Best
Management Practices (BMPs) to control pollutants contained in
stormwater runoff.
Many BMPs, including several new, innovative
and alternative technologies, depend on the use of vegetated
systems for pollutant removal, and the impacts of salt loadings to
these systems should be evaluated for their potential to alter
performance.
2) disposing
The Snow
Removal and Disposal Policy includes guidance for
of snow away from roadways when the snow may contain
debris and a variety of pollutants from roadway sources.
Salt
content is one of the pollutants of concern and the impacts of snow
disposal should be evaluated for any potential impacts on potential
disposal alternatives.
The proposed project may be subject to MCZM federal consistency review.
For further information on this process, please contact Jane W. Mead, MCZM Project Review Coordinator, at 617-727-9530 x.418.
WILLIAM F. WELD, GOVERNOR; AAGEO PAUL CELLUCCI, LIEUTENANT GOVERNOR; TRUDY COXE, SECR5:TARY; MARGARET M. BRADY, DIRECTOR
2
MMB/JPS
cc: Grant Kelly, Regulatory Division,
u.s. Army Corps of Engineers
James Sprague, Section Chief,
Northeast Regional Office, Massachusetts DEP
Elizabth Koulheras, Section Chief,
Southeast Regional Office, Massachusetts DEP
Massachusetts Audubon Society
July 11, 1997
208 South Great Road
Lincoln, MassachUsetts 01773
(617) 259-9500
RECEIVED
JUL 141997
MEPA
Trudy Coxe, Secretary
Attention: MEPA Unit
Executive Office of Environmental Affairs
100 Cambridge Street, 20th Floor
Boston, MA 02116
Re: MEPA No.: 11202 - Massachusetts Highway Department
Update of Generic Environmental Impact on Snow and Ice Control
Dear Secretary Coxe:
On behalf of the Massachusetts Audubon Society, I have reviewed the above referenced
Environmental Notification Form (ENF). The Massachusetts Audubon Society is the largest
private conservation organization in Massachusetts with 54,000 household members and a wildlife
sanctuary system comprising over 27,000 acres. The Society has a mission of biological
conservation with a focus on the priorities of protecting water resources and biological diversity.
We are pleased that the Massachusetts Highway Department is embarking on the preparation of
an update to the Generic Environmental Impact Report (GEIR) on Snow and Ice Control. Snow
and ice control activities carried out by the Massachusetts Highway Department and other state and
local authorities and departments have the potential for significant impacts on the environment and
the health and safety of the public. It is important that the impacts and effectiveness of these
operations be reviewed on a regular basis and that the findings of recent scientific, economic, and
engineering investigations of snow and ice control activities be reviewed, assessed, and
incorporated into standards for snow and ice control operations.
We have reviewed the preliminary list of discussion topics for the GEIR. In general, the
preliminary list appears to include the major topics relating to the potential impacts of snow and ice
control activities. For the GEIR to be a worthwhile undertaking, the analysis of the environmental
impacts of snow and ice control activities should be detailed and specific recommendations should
be developed for addressing known problems such as the contamination of public and private
groundwater supplies. The recommendations developed to mitigate the impacts of snow and ice
fi~d~~s~f~h~r~~~os~~ufJar~6·b~-t~~t~oJa~v~r~~gr~~~gm~~n~i1i~~t~qfj1in&1~r:if~gJb\l~nw!k~ .
directors on mitigating the environmental impacts of local snow and ice control measures.
The preliminary list of discussion topics for the GEIR includes a section on environmental
concerns, including soils, roadside vegetation, and surface waters. We urge that the GEIR
specifically investigate the potential ecological impacts of snow and ice control activities. These
investigations should include an assessment of the ecologicaJ effects of increased salinity in soils
Printed on Recycled Paper
and surface waters adjacent to roadways and how such changes might impact native species.
Species, communities, and ecosystems that may be particularly vulnerable to harm from snow and
ice control activities should be identified and mitigation measures should be recommended.
----t
While we recognize and support the need to specifically address the environmental impacts of
snow and ice control activities, there are other highway maintenance and rehabilitation activities
that would also benefit from a review in a GEIR. It would be useful to expand the GEIR on snow
and ice control, or to prepare a separate GEIR on other highway maintenance and rehabilitation
activities such as stormwater management system maintenance, lane reconstruction, and minor
widening projects. The evaluation of the potential impacts of such activities, and the development
of reasonable measures to mitigate environmental impacts associated with such activities, would be
useful to the Massachusetts Highway Department, other state and local authorities responsible for
highway maintenance, state environmental agencies, and local conservation commissions. The
Massachusetts Highway Department has often noted the variability of requirements placed on
highway reconstruction projects by local authorities. A GEIR devoted to examining the
environmental impacts of such projects and identifying reasonable methods for mitigating these
environmental impacts would be useful in resolving this problem. A GEIR on highway
maintenance and rehabilitation would also be useful in identifying funding and staffing
requirements to maintain existing highway infrastructure, such as storm water management
systems, in a manner that mitigates environmental impacts.
The last update of the GEIR on Snow and Ice Control took many years to complete, WI SIX years elapsing between the draft and final reports. The currently proposed update must be sufficiently funded and supported to assure that it will be completed in a timely manner. As with previous snow and ice control GEIRs, we urge the formation for a Citizens Advisory Committee to assist in the development of a final scope and to provide guidance to the Massachusetts Highway Department and the contractor selected to prepare the GEIR. Sincerely,
d~ {/~-L---Lou Wagner
Water Resources Specialist
Henry Barbaro, Mass. Highway Department
2
m'A
y5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
July 10, 1997
Ms. Trudy Coxe, Secretary
Attention: MEP A Unit
Executive Office ofEnvironmental Affairs
100 Cambridge Street
Boston, MA 02202
Re: RECEIVED JUL 111997
MEPA E.N.F. for Massachusetts Highway Department 1998 Update of the Generic Environmental Impact Report for the Statewide Snow arid Ice Control Project (EOEA No. 2358) Dear Ms. Coxe:
The EPA-New England Regional Office appreciates the opportunity to comment on the
Massachusetts Highway Department (MHD) Generic Environmental Impact Report (GEIR) for
the Statewide Snow and Ice Control Project. Our comments focus on the management of runoff
from Massachusetts highways and its potential adverse impact on public drinking water supplies.
An important aspect of snow and ice control is safe disposal of highway runoff The
Environmental Notification Form presentation addresses most issues associated with the impact of
highway deicing salts; however, the presentation does not address issues related to other pollution EN~'\~ ~ DI
traveling with deicing chemicals and into drainage systems designed to mitigate the affects of
deicing. Contaminated roadway runoff and accidental spill runoff may adversely affect aquifers
and surface water supply sources adjacent to highways. The MHD typically works to minimize
storm water discharge to resources and to minimize the quantity of pollutants that reach important
streams and wetland water bodies. The Statewide Snow and Ice Control Project should be
expanded to include assessment of the negative impacts of polluted highway storm water and
accidental spill runoff on public water supplies. The GEIR should include assessment of the
design, operation and maintenance of all storm water and spill control structures that will be used
to mitigate the effects of deicing and to prevent highway runoff contamination of aquifers and
streams used for public water supply.
It is important to maintain the potability of ground water in local aquifers. Contro 0 azar ous
spills into highway drainage systems that discharge into or near drinking water suppliers sources
should be evaluated. Highway deicing management alternatives should consider designs that allow
control ofor don't allow infiltration of contaminants that may adversely affect a ground or surface
water resource. Drainage structures should allow speedy hazard mitigation when there are
releases. MHD "Highway Emergency Response Plans" should be presented in the GEIR and these
plans should include mechanisms to alert potentially affected drinking water supplies when an
accidental hazardous release has occurred on a Massachusetts highway. Drainage systems should 'Zi
£?\\ ~OL
conduct highway runoff away from sensitive water resources. All runoff disposal plans should be
consistent with community and state goals to preserve the integrity ofground water in underlying
down gradient aquifers and surface water that flows to drinking water supply intakes. The
considerable time necessary to flush contaminants from an aquifer and the high cost of and
technical complexity of water treatment systems make it important to prevent degradation of
sensitive water resources. Increasing community need for potable water supplies necessitate
aggressive local and state action to preserve and protect all ground and surface water resources
to prevent inadvertent loss of critical water resources.
Another issue which is a concern to water suppliers and consumers is the monitoring and
reporting of sodium loading within water supply protection areas. The GEIR should describe
actions which will be pursued by MIlD to provide early warning of salt concentrations before
sodium reaches a well as a result of salt deicing applications.
We appreciate the opportunity to comment on this project. Please contact David Delaney
(617/565-4884) if you have further questions about these comments.
Sincerely,
JJJAA f ~/ t{(/)iy fY
Jane Downing, Manager
Massachusetts Office of Ecosystem Protection
cc. MEP A Coordinator, Massachusetts Highway Department
Dave Terry, DEP DWS
Tara Gallagher, DEP DWS
Elizabeth Higgins, EPA
'Dv
MONTACHUSETT
cit- (\?-CJ d.-.
Offices: R1427 Water St., Fitchburg, Massachusetts 01420
(508) 345-7376 or 345-2216 Fax: (508) 345-9867
July 8,1997
Ms. Trudy Coxe, Secretary
Executive Office ofEnvironmental Affairs
100 Cambridge Street, 20th Floor
Boston, MA 02202
Attention: MEP A Unit
Dear Secretary Coxe:
At the Montachusett Regional Planning Commission meeting held on Tuesday, June 24, 1997 members discussed
the Environmental Notification Form submitted by the Massachusetts Highway Department for the 1998 Update
ofthe GEIR for the Snow and Ice Control Project. The Commission found the project in conformity with
regional goals, policies and objectives. The project will enhance the :MRPC goal ofenvironmental quality. By
gathering the latest information on what effect that implemented measures have had on reducing salt use and
minimizing environmental impacts and researching new advances in alternative deicing practices and findings
from other relevant studies throughout the country, adjustments can be made to further protect the environment.
Ifyou have any questions or desire further information please contact Lalla Michaud at (508) 345-7376 ext. 2245. Very truly yours,
{L"
~~
Chairman, MRPC
DJ/jh
cc: Henry Barbaro, Mass. Highway Environmental William R. Arcieri, Normandeau Associates, Inc. /
NMCOG
Northern Middlesex Council of Governments
REOUEST FOR REVIEW COMMENTS
June 17, 1997
A Multi-Purpose
TO: NMCOG; Highway Departments, Conservation Commissions, Water Departments/
Districts, NMCOG Councillors
'
Regional Planning
District Serv ing:
Billerica
Chelmsford
Dracut
Dunstable
Lowell
The Northern Middlesex Council of Governments, pursuant to M.O.L. Ch.30 S.62 has
received an Environmental Notification Form (ENF) concerning the following project: 1998
Update to the Statewide Snow and Ice Control Program.
Your opinions and comments pertaining to the extent and significance of possible ENVI­
RONMENTAL impacts which are directly attributable to this project are most welcome.
If you wish to comment, pl~e do so below. For more infonnation, please contact the
Council staff.
Pepperell
Tewksbury
Tyngsborough
Westford
COMMENTS DUE: July 15, 1997
EOEAlNMCOG REVIEW NUMBER: EOEA #2358, NMCOG ENF #485 '
APPLICANT: Massachusetts Highway Department
j
COMMENTS:
No significant environmental concerns
_ Need more information about the following environmental
aspects in order to comment. (please explain below) '.
_ Significant environmental concerns. (please explain below)
Madonna J. McKenzie
Chairman
(Attach additional sheets ifnecessary)
Robert W. Flynn
Executive Director
~
171 Ubf'l,1 t- (y
, rw DI r.,fL1O~
Date
Gallagher Terminal
Floor 3B
115 Thorndike Street
Lowell.MA
01852-3308
TEL.#(508) 454-8021
FAX #(508) 454-8023
EMail nmcog@tiac.net
The purpose ofan ENF is to present infor,nation relative to the proposed project which. along with
comments receivedfrom officials, agencies, and citizens is used by the Secretary ofEnvironmental
regarding the significance ofany potential environmental
impacts
Affairs to make a determination
.
..
I...,
concerning the project. The Massachusetts Environmental Policy Act (MEP-A) requites the
Secretary to solicit local and regional comments prior to issuing a decision ~:to w/fm measures, if
any, are appropriate in order to mitigate damage to the environ11U!nt. The Secretary may, for
example, require the preparation ofan Environmental Impact Report and ~tailol::1he scope of
such a document to specifically address certain identified concerns. Some projects pjl0matically
require the preparation ofan EIR ,and ifyou wish to comment on specific itltTnfl. that ~u feel should
be included within the scope ofan EIR or be informedofthe time andplace".fJfthe sClJ]Jing session
TF:··.~::-: ~'hl"'; _, , ,
~ ~ln"df-nhv;aJ
please indicate on thisform.
j: d
Serving Member CommunititS Since
Printed'on Recycled Paper
196{1UL 07 1997
N·M.CO.a
'~)
t-;
;
Copies of all local comments received by our office are attached. Please call if you
have any questions regarding staff comments.
Very truly yours,
cd?~Pl-~Robert W. Flynn
Executive Director
BW:cas
[cwgc-nhv.a]
Enclosures
cc: NMCOG Highway Departments
Conservation Commissions
Water Departments/Districts
NMCOG Councillors
WATER SUPPLY CITIZENS
ADVISORY COMMITTEE
to the Mass. Water Resources Authority
~\!
138 Russell St. (Rte. 9)
P.O. Box 478
Hadley, Massachusetts 01035
(413) 586-8861
FAX: (413) 585-9257
July 14, 1997
Doug Vigneau Unit, EOEA 100 Cambridge Boston 02202 MEPA
Dear Doug: Re #11202: Statewide Snow & Ic~ Control GEIR
JUL
0"
«; ""f'-cj
- ,
djJ
MEPA
WSCAC is concerned with this program because of its effect on drinking wa er
quality throughout Massachusetts. This state has a much higher use than other
states, such as Vermont; and the effect is clear, considering the rising salt
levels in local wells, as reported in MWRA Local Source studies.
wScV\c-o\
We therefore applaud MUD efforts to reduce salt levels, especially in
sensitive areas. The only additions we would make to your good proposed scope
are as follows:
--how is salt usage calculated? That is, how manr times per storm is salt
applied and why? How is U$e monitored? Are salt use reports checked against
salt purchase throughout the state?
--how much non-calibrated equipment is still in us~? Where? Why?
--how JlJany salt piles are still uncoversd? When will this work ~
--for "modified" drainage systems, how many times have impervious swales been useq? How well do they wort? How are they maintained and cleane::.d...:o:..:u:.=t~1____i --what ie the latest information on the effect of salt in drinking water on sensitive populations such as babies using bottles? --what is the latest information on roadside tree loss from salt use? ~~V5L~~'
--what are the current salt levels in small, sensitive rivers 6UCh':':"as':":"'"""tIi"'--e---lN('C.~' Charles and Ipswich
--is there any evidence that overall salt levels in the state are rising? or ~falling?
1A)~;()t',~
0
I
Sincerely,
~~~~&-WSCAC Staff
CITY OF BOSTON
THE ENVIRONMENT DEPARTMENT
Boston City Hall, Room 805 • Boston, MA 02201 • 617/635-3850 • FAX: 617/635-3435
August 11, 1997
.-~"'" ,"~n~irn
Trudy Coxe, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street, 20th Floor
Boston, MA 02202
Attention: Doug Vigneau, MEP A Unit
~~ti;J\:\" t.u
AUG 141991
MEPA
Re: 1988 Update of the Generic Environmental Impact Report (GEIR) for the Snow and Ice Control
Project - Massachusetts Highway Department
Environmental Notification Form
EOEA#11202
Dear Secretary Coxe:
The City of Boston Environment Department has reviewed the Environmental Notification Form
(ENF) referenced above and hereby submits the following comments.
The ENF under review was developed by the Massachusetts Highway Department (MHD). Previous
submissions to MEPA regarding roadway snow and ice control programs were identified under
EOEA #2358 and included the Massachusetts District Commission (MDC) and Massachusetts
----"­
Turnpike Authority (MTA) as proponents.
t:>C D~ 0 I
The August 31, 1995 Certificate of the Secretary of Environmental Affairs on the Final Generic
Environmental Impact Report (EOEA #2358) indicates that a draft GEiR was reviewed by MEPA in
1976; a final report prepared in 1978; an ENF for an update reviewed in 1985; a draft report
reviewed in 1989; and a final report submitted in July, 1995. Section 61 Findings for EOEA #2358
were issued by MHD in March, 1997. There was a tentative commitment, referenced in the
Certificate, to the filing of a new GEIR by the Fall of 1977. Responses to the numerous comments
submitted regarding EOEA #2358 were required by the Secretary as part of subsequent rev~_ie_w;"';"_ _-4
We note at the outset that the subject filing does not comply with the timelines outlined in t e
Secretary's August 31, 1995 Certificate. In addition, while the MDC and MTA were, at least
nominally, parties to the 1995 filing, they are not referenced in the current submission. Are they to
be included in this process or will each entity file a separate document?
\3
This department is in agreement with past commenters who have identified the need for sta eWl e
program of snow and ice control, to include the identification of sensitive and critical areas and for
the coordination and sharing of information and resources. The Commonwealth's Executive Office
of Transportation and Construction (EOTC) should take a leadership role in this regard .
Lorraine M. Downey, Director .. \.~ Printed on recycled paper
Thomas M. Menino, Mayor
OL\
MHD Snow & Ice Control GEIR ENF - p. 2
We do not agree with the MHD perspective that it is appropriate not to identify critical areas or ow
salt treatment. With ever-improving GIS and with coordination and information sharing among stat
and municipal environmental and transportation agencies, such identification should be fairly
efficient. We consider it a necessary part of effective mitigation.
In response to question number one in Section D of the ENF, MHD indicates that "[m]itigation
measures to alleviate salt impacts may result in minor changes in drainage patterns at particular
locations." The mitigation measures, changes in drainage patterns and the locations should be
detailed in the GEIR.
We understand from the July 11, 1997 MEPA Consultation Session that private vendors for MHD
are required to have equipment with calibrated speed control devices. Does this device allow MHD
to analyze application rates and total materials applied for the season over a specific route? If not,
how does MHD make such determinations when routes are not treated using MHD equipment?
The March, 1997 Section 61 findings suggest that MHD has not evaluated alternative deicing
compounds since the late 1980s (page 8, second full paragraph). The GEIR should confirm that this
is the case or provide detailed information on the alternatives evaluated and the results of those
evaluations. In addition, the potential environmental impacts/pollution prevention consequences of
alternatives such as Calcium Magnesium Acetate (CMA) must be outlined.
We ask that the upcoming filing contain a section devoted to a discussion of the control of snow and [\
ice program for sidewalk areas abutting state highways and bridges.
._ _ _ _,-'1
The March 1997 Section 61 Findings and the ENF indicate that sediment from snow and ice control
treatments often collect in catch basins. Impervious swales are also identified as a mechanism for
sediment collection. We request that the frequency and cost of swale and catch basin maintenance
be outlined in the next filing and that they also be included in the description of Best Management
Practices (BMPs).
The ENF and proposed Scope make no reference to the storage and disposal of snow removed from
roadways. Locations of storage areas should be identified and details provided about whether or not
the areas are enclosed, about the permeability of storage surfaces and the management of runoff fro
the sites. Any sensitive or critical areas surrounding these sites must be identified.
An issue of particular concern for the City of Boston is the quality of stormwater origina mg on s a e
roadways and then moving through the City's system. Given the increasingly stringent stormwater
quality requirements of DEP and the EPA, the City has a substantial interest in ensuring that other
governmental entities are addressing this issue. As suggested by CZM in August 21, 1995
comments, MHD and other state transportation agencies must link stormwater quality to
specifications for construction, reconstruction, repair, operations and maintenance. We also support
the recommendation that these entities develop a set of standards for managing stormwater runoff.
MHD Snow & Ice Control GEIR ENF - p. 3
We understand that there was, at one time, a Salt Advisory Committee involved in snow and ice
control issues. MHD should outline in its next filing the origin and constitution of the committee, its
past role in policy-making and plans for its future.
The representative from MHD suggested at the MEP A Consultation Session that a GEIR on snow
and ice control would be appropriate every 10 years. Given the history of environmental filings on
this issue we strongly disagree. MHD and other state transportation agencies must prove willing to
comply with mandated requirements and must show good faith in their planning and operations
before any discussion of reduced GEIR standards.
Thank you for the opportunity to offer comment.
Sincerely,
~!kiO~
Lorraine M. Downey Director ICESNOW.doc.LMD:MTZ.mtz
45 Kendal Common Road
West.on, .MA 02193
~~
Y V
)
July 14, 1997
Secret.ary Trudy Coxe
Execut.ive Office of Environment.al Affairs
MEPA Unit
100 Cambridge Street. 20th floor
Boston, MA 02202
REC£fVEO
JUL 161997
EOEA ..
formerly ..
Dear Sec. Coxe:
Thank you for the opportunit.y to comment on the ENF for the
Mass. Highway Department Snow and Ice Control Program.
The description of the project is misleading in that it de­
scribes t.he applicat.ion rate of 240 lbs/land-mile as "new".
In fact that application rate wa. initiated in the 1970".
with the intent t.o continue rate reductions absent any ad­
verse impacts. Since no adverse impActs have been
demonstrated in subsequent MEPA reviews, it i . time to
reduce the applicat.ion rate again. Without a policy change
in the current application rat. total salt us. hA. crept up
from the "low" of 200 million pounds in 1980 according to
the DEIR of March 1989.
The 50-called reduced salt zones, ostentatiously marked
along state highways, are in fact areas where t.he applica­
tion rat.es are reduced. There should be an evaluation of the
total annual salt application in these zones compared to ad·-­
jacent roadways. Since the intent of the reduced salt zones
was to minimize salting in watersheds, that purpose would
not be well served if lower application rates resulted in
more frequent applications.
------~
Please include in the GEIR updated information about t h : ] length of road miles and lane-miles under this program.
(A,~-U\Q~D3 Vehicle trip data would also be relevant. There is evidence that road salt adversely impacts some roadside vegetation. Maple trees in particular are salt averse, as documented by studies at the Uni versi ty of Massa-­
chusetts.
:J
Techniques to prevent salt contamination in surface or
groundwater must include using less salt. Mitigat.ion afterthe-fact is less cost-effective than prevention.
U\tL\'Q-DL(
U~LlQ­
Earlier attempts to assure that. spread rates were within the"
range that was allowed relied on a "materials control" pro­
n
gram. That program reveal ed a di sparate spread rate among
Ul! r- contractors. This is an opportunity to revisit that informa­
tion and set a timetable for improved calibration of sRread
rates.
+L
0
2
MMB/JPS
cc: Grant Kelly, Regulatory Division,
u.s. Army Corps of Engineers
James Sprague, Section Chief,
Northeast Regional Office, Massachusetts DEP
Elizabth Koulheras, Section Chief,
Southeast Regional Office, Massachusetts DEP
Moni toring the i rnpacts on water suppl ies should be report~d
to the publics using that water. The requirement to report
U~LIQ-O
on annual salt use by highway section should be revived even
though MGL C.85 Sec.7A is no longer operative.
1
The Snow and Ice Control Program does require the use of
more water for car washing. Even with that precaution, vast
costs absorbed by vehicle owners are associated with salt
damage to cars. There are also associated accident injuries
due to deteriorated auto parts. (I personally experienced a
"near miss" accident due to a cable failure on a two year
old car.)
----~
Salt-related bridge damage and other" infrastructure costs
must be realistically evaluated.
LU+U
IUI+).JrQ~Oq
l
~
Pr i or BE IR'" r "ported at 1"a 5 t i n par t about the MTA and Mile UrllJ Il. 10
programs as well as the DPW program. Will they be included
in the DEIR?
­
The difference in accident rates or severity within the so­
called reduced salt zones and other highways should be docu­
mented. Although the earlier Salt Advisory Committee asked
for such an analysis, no information was forthcoming.
Thank you for- considering my input.
Very truly yours,
~~~
U\-\-L( Q.- 11
R. J. Lyman, :MEPA Director
Executive Office of Environmental Affairs
100 Cambridge Street, Room 2000
Boston,~. 02202
Attention: Doug Vigneau
SUBJECT:
Generic Enyironmentallmpaet Report
EOEA #I 11202 (previously #02358) "
I am a member of the Salt Advisory Committee, which was appointed
by the'Secretary of Environmental Affairs and met actively between 1985
and 1990. The committee efforts were focused on the update of the GEm
for Snow and Ice Control, commonly known as the roadsalt GEIR. To my
knowledge, the committee has not met in about 7 years, and the only
mailings I have received are GEIR documents and announcements in the
new GEm filing of this year.
The first GEIR on roadsalt was done in 1975 and was found inadequate
by MEPA. In the period 1976-1978, Draft and Final GEIRs were prepared,
with the Draft EIR being the primary information document, while the 1978
FEm was a response document.
In November 1985, a new ENF was published in the Monitor to signal
the need for an update on the 1978 GEIR. MEPA issued the new scope in
March 1986 and also announced the formation of the Salt Advisory
Committee. In 1989 the Draft GEm was submitted and in February 1992
a 2-volume "Draft Final Generic Environmental Impact Report" was
circulated among members of the advisory committee. The actual Final
GEm was not issued until July 1995, in one volume.
I win not dwen on all the history and the numerous issues, but the
interesting questions relate to how do we develop a stable and improving
information base from which to address concerns about the environmental
and safety aspects of the use of roadsaIt.
~
Puge 2
.Jul~
9, 1997
The legal mandate for the Mass Highway Deportment and its snow and
ice control program is derived from Chapter 81, Section 19 of State laws,
authorizing and directing the DPW to keep State highways If sufficiently -­
clear of ice and snow to be reasonably safe for traveL" The resulting DPW
standard of maintenance makes no direct reference to safety: " maintain the
entire width of roadways and shoulders of all roads ....free from snow and
ice as far as conditions and a reasonable expenditure of fonds permits. "
Several questions arise :
'* What is meant by "reasonably safe"?
What is the MHD interpretation of
this goal?
'* What is meant by
11
conditions" and how does this come into play? - "
KSR -0\
'* What is a "reasonable expenditure offonds"?
Does this mean tI;le
MHD snow and ice control budget? What about expenditures by anyone
else, such as people buying bottled water, bridge repair, replacing rusted
vehicles, etc.?
The Salt Advisory Committee observed a roHer-coaster experience of different assertions about safety - as described by MHD personnel and their consultants. The original 1976 GEIR showed that for towns which .reduced usage of roadsalt in the early 1970s showed a smaH increase in total
accidents, including fender-benders, but a reduction in injury accidents. At
no point in the discussions did agency or consultant personnel demonstrate
that accident rates were reduced by the use of road salt. A different
approach, supported by the Salt Institute, sought t~ show that accidents
increased on "snow days" but did not correlate such date with the use or
non-use of salt.
Based on available studies and data, any claim that road salting
improves safety cannot be justifled. Not only does accident data not support
a safety claim, but there is evidence that the immediate ice-removing
capabilities of salt may be counterbalanced by the accident-increasing
effects of higher speeds, refreezing and slipperiness of wet pavemen"ts. "
-------'
)LSR-O-Z
Page 3
.
.July 9, 1997
The 1992 "Draft Final GEIR" actually gave the best summary of
reasonable conclusions, namely that:
" A review of the relevant literature indicates that researchers have been
unable to establish an empirical relationship between winter maintenance
and traffic safety."
"The literature suggests that accident severity is lower on snow-covered
pavement as compared with slush, wet or dry conditions."
¥£Q-Os " Attempts to relate winter maintenance to traffic accidents have resulted in
inconclusive findings."
When the actual Final GEIR was issued in July 1995, any discussion of
safety issues had been deleted. There is nothing in the new ENF filing
which indicates that the state highway department is prepared to discuss the
safety implications of the roadsalting program.
MEPA should not "defer to the expertise" (actual or alleg"ea) of the
Mass IDghway Department with respect to safety issues. The use of
roadsalt is another example where there must be an overriding public
purpose in the use of roadsalt, by which to justify the obvious environmental KSQ -0'1 damage which results. At the moment, MEPA and the GEIR process is the
only forum available to address issues of safety and environmental
tradeoffs. The new roadsalt GEIR should update any research on the effect
of roadsalt on safety, specifically relating to accident rates through the use
or non-use of roadsalt during snow and ice conditions.
/L-_s7'~ncer# .cJ)~ ,
Stephen H. Kaiser
Traffic and Transportation Engineer
cc.
~*'"D
MassDOT - Response to Comments from the 1997 ENF #11202 (formerly #2538) Snow and Ice Control Program; Generic
Environmental Impact Report
EOEA: ENF - 1997
Comment
No.
Comment
Mass DEP Comments – Arleen O’Donnell, Assist. Commissioner, July 31, 1997 letter
Category
Drinking Water
Supplies
DEP-01
What progress is being made to improve protection for surface and groundwater supplies
because of the comments on the [1995] FGEIR? Are the reduced salt practices effective, and do
they protect our most susceptible drinking water supplies? Two years ago, the Bureau identified
issues that were important to the protection of drinking water resources; the dialogue
continues herein and many of these issues are raised again. The Bureau would like to expand
the dialogue<<<;;Specifically, hard evidence is requested now to show that implementation of
the beneficial mitigation measures promised in previous GEIRs is making a difference in water
quality impacts. The Bureau wants assurances that our highest priority surface supplies are
covered by mitigation measures that will provide adequate protection. Where this is not
happening, the Bureau of Resource Protection (BRP) offers to work with MHD to improve
implementation of the mitigation plan and schedule the most appropriate measures to address
our priorities short and long term.
Agency
Coordination
DEP-02
A long standing short-coming of the previous GEIRs has been the low level of participation by
the MTA, MDC and Massport. These agencies, with state highway operation and maintenance
oversight of snow and ice control, also have responsibilities under M.G.L C.30, s.61, which
should be fulfilled in the proposed GEIR.
Env
Resources
DEP-03
Env
ResourcesReduced Salt
Zones
DEP-04
The DEP comments on the Final GEIR (Aug 24, 1995) raised significant issues regarding the
environmental impact analyses and the mitigation plan covering the MHD’s S&I ontrol
program. It is requested that those comments be incorporated fully into the scope to ensure
that the issues of concern to DEP are integrated into the GEIR document and not addressed in a
response to comment section only.
The next GEIR should recognize and reflect the approach the state is taking in the Stormwater
Mgt Policy (Nov. 1996) to control water quality in stormwater runoff, particularly in critical
resource areas (ORW’s, shellfish growing areas, swimming beaches, cold water fisheries, and
recharge areas for public water supplies). Snow and Ice mgt on state highways results in
stormwater quality impacts, which need to be evaluated in the context with the Stormwater
Management Policy goals and standards. For example, critical resources receive a higher
degree of protection in the Policy; more runoff from the early part of a storm event must be
subject to treatment and only certain structural stormwater controls (BMPs) can be used in
these areas; < Since road salt impacts are not controlled easily through the use of MPs< the
focus of source control management should be on road salt applications; alternative deicing
chemicals, particularly liquid calcium chloride, which appears to have fewer environmental
impacts. New computerized monitoring equipment, combined with RWIS, is being used in other
states to control the use of deicing chemicals in critical resource areas. The ENF indicated that
some of these technologies are being tested by MHD in pilot studies. Given the need to replace
the Material ontrol System, which was abandoned in the early 1990’s, this research should be
incorporated into the standard operating procedure, especially in reduced salt and critical
resource areas where salt levels are elevated.
ENF 1997 - Summary of Comments Responses-Final.doc
1
MassDOT Response
As discussed in the ESPR. MassDOT has incorporated many innovations over the last five
years that have resulted in reduced overall salt usage statewide. The statewide salt usage in
the winter of 2010/11was approximately 23 percent lower than that used in previous years
with similar or slightly less winter severity. This represents significant progress and this trend
is anticipated to continue with even greater implementation of these measures. With
respect to reduced salt zones, MassDOT seeks to reduce its use of sand as an alternative to
road salt as sand provides little benefit for snow and ice control and presents an even greater
issues with respect to phosphorus and sediment loading to surface waters. MassDOT
coordinates with public water suppliers on an as needed basis to maintain existing reduced
salt zones (RSZs). MassDOT has recently met with the Cambridge Water District to discuss
the need for any additional measures to improve protection. MassDOT is receptive to
meeting with resource agencies in the future, if deemed necessary, to discuss the latest
activities and information concerning the Snow and Ice Control Program.
MassDOT contacted each of these agencies as part of the 1995 GEIR preparation. However,
their response and level of participation was limited. MassDOT has no jurisdiction or authority
to require their participation or cooperation. This regulatory authority can only come directly
from the EOEA .The Turnpike Authority has since been merged with MassDOT and Massport
conducts its own reporting to EOEEA.
So noted. The 2012 ESPR provides a detailed description of the various activities and
measures that MassDOT has implemented in the last few years to increase its material usage
efficiency. Recommendations for further improvements are also provided.
MassDOT has adopted and implemented many related measures with respect to MassDOT
Stormwater Mgt Policy including the development of their 2004 Stormwater Handbook and
updates to their Facilities Maintenance Manual. MassDOT has continually updated and
implemented source control measures including adding more RWIS stations, purchasing new
computerized spreader equipment, as well as requiring hired contractors to equip their
spreader trucks with pre-wetting equipment. In many respects, MassDOT has made greater
progress in achieving statewide implementation of many these innovations relative to other
New England states. See Response to DEP-01 above.
2/27/2012
OperationsAlternative
Deicers
DEP-05
Env
Resources
DEP-06
Env Resources
GIS Mapping
DEP-07
Operations
Snow Disposal
Practices
DEP-08
Operations
Snow Disposal
Practices
DEP-09
Salt Application
Rate Policy
DEP-10
Expanded use of calcium chloride looks very promising. Calcium chloride has been shown to be
more effective than rock salt at low temperatures, and it is cost-effective. Furthermore, the
results of the MHD Anti-Icing Experiment Liquid Calcium Chloride (1993, 94 and 95) indicated
that No Salt Areas are a possibility: The report states: “The most significant feature of the
entire experiment is the fact that eleven miles of the state highway was maintained safely
through extreme weather conditions for two years without the use of any salt whatsoever. The
last statement has a great impact on how this material could be used in the future. In a climate
of environmentally sensitive areas, the possibility of low salt areas becoming No Salt Areas
should progress on the Departments part;”
The Draft GEIR (1989) included a mitigation plan that should be the basis for a revised
mitigation plan in the next report. Recent and historical data showing road salt impacts should
be linked to specific mitigation measures to show improvements through implementation of the
mitigation plan. Recommendations for changes to the plan also should be based on
interpretation of the data.
Considering that watersheds are becoming the planning unit for environmental protection, it is
requested that the following information be provided on MassGIS maps, within their respective
watersheds and sub-basins: highway ramps (and other areas subject to higher than average
road salt use), salt storage areas, reduced salt areas, and critical resources, (from available data
layers) to facilitate DEP review of the GEIR. These maps should show the relationship between
the 41 reduced salt areas and the critical resource areas, such as public water supplies. It should
be clear where salt use has been reduced in Zone II areas or Zone A areas for drinking water
supplies. What plans are there to expand the reduced salt program around drinking water
supplies? Are signs posted in all reduced salt areas? The status of the reduced salt mitigation
plan in the DGEIR (1989) should also be explained.
Snow disposal practices (for snowbanks and snow piles that are removed and disposed) should
have been included in the Preliminary List of Discussion Topics, the basic scope outline, which
was appended to the ENF; The next report should explain MHD’s disposal policy and show that
it is consistent with DEP’s Snow Disposal Guidance, which discourages disposal of snow, which is
contaminated with sand, dirt, litter, and automotive residuals, in water bodies and other
specified areas.
Proper snow management practices which spread snow and melt water from paved surfaces
over vegetated pervious areas using level spreaders, plows, and berms should be explained in
the next GEIR also.
The MHD’s Salt !pplication Policy does not have a direct effect on road salt impacts, because
the policy is based only on the road salt application rate. Salt use control is dependent on the
standards of maintenance, which should be addressed by policy. In consideration of this issue,
the GEIR should present a thoughtful assessment of the strengths and weaknesses of the
current policy and consider revisions that would make it possible to understand the relationship
between improved road salting policies, practices, and observed changes in salt concentrations
in the environment.
ENF 1997 - Summary of Comments Responses-Final.doc
2
MassDOT has greatly increased its use of liquid calcium chloride (CaCL2) and liquid
magnesium chloride (MgCL2) as part of its anti-icing approach adopted over the last 5 years.
The liquid brine solutions are used to supplement and improve the efficiency of regular road
salt during low temperature conditions when sodium chloride is less effective. In fact,
MassDOT as a result of this improved efficiency the overall road salt usage has been reduced
as noted in the winter of 2010/11 results compared to previous years. (See Response to
Comment DEP-01 above) It should be noted, however, the phrase “No-Salt !rea” as used in
this comment appears to pertain to “No Sodium” use since both the CaCL2 and MgCL2 are still
salt compounds and contain chloride components similar to regular road salt.
See Responses to Comments above and especially Comment DEP-01.
MassDOT has included a statewide GIS map of the reduced salt zones and salt shed locations
in the 2012 ESPR. MassDOT’s roadway network is included as a data layer in the MassGIS
system, which would allow comparison to Zone II areas. Adjustments or expansions of RSZs
are done on an as needed basis based on complaints received with regard to increasing
sodium levels. The complaints are investigated to determine if MassDOT’s salt use is a
primary source to elevated sodium levels in the drinking water supply based on field
investigations. In many locations, the elevated sodium levels are due to a variety of sources
within the local area of which MassDOT has no control. Any changes or expansions to RSZs
are anticipated to be reported in the proposed future annual reports. The status of existing
or new mitigation measures will also be provided.
MassDOT does not engage in snow removal and disposal practices. The only time snow
would be removed is under emergency conditions. If snow is removed, due to an emergency,
the snow disposal would be consistent with MassDEP policies.
Most of the MassDOT roadways have grass swales and grassed embankments along the
shoulder and within the right of way. As noted above, MassDOT does not generally engage in
snow removal activities where snow would be stockpiled and concentrated areas of melt
water are created.
MassDOT has reduced its application rate from 350 lbs/lane-mile used in the 1970’s to 300
lbs/lane-mile in the 1980’s and then to 240 lbs/lane-mile in the 1990’s; These reductions
have resulted mostly from improved spreader equipment. However, as noted above, there is
a limit to how much the application rate can be reduced before it becomes ineffective and a
waste of material. MassDOT considers the current 240 lbs/ln-mile rate to be at the minimal
threshold needed to be effective under most conditions and is consistent with the rates used
by other New England states. MassDOT continues to make progress in reducing its overall
seasonal usage as noted in Response to Comment DEP-01 above.
2/27/2012
State Agencies (cont.)
Comment
No.
Comment
Mass DEP Comments – Arleen O’Donnell, Assist. Commissioner, July 31, 1997 letter
Category
Salt Storage
Sheds
DEP-11
Remediation
Program
DEP-12
RSZ Data
Requirements
DEP-13
Drainage
System
Modifications
DEP-14
MassDOT Response
An update of the state and municipal storage shed building program should identify (and locate
on maps) the areas where sheds have not been, or cannot be constructed. In the last GEIR, 15
state-operated salt storage areas were without sheds. What is their status, and do any remain
in protected areas around public water supplies? What progress has been made to cover and
control these salt piles to minimize road salt runoff.
The GEIR should assess the success of the Salt Remediation Program and the Reduced Salt Area
Programs. How many requests are received and approved or rejected for each programs
annually? What is the public perception of these programs? How is the Complaints Program
advertised to alert the public water supplier and private well owner of the opportunity to have
their wells evaluated for road salt impacts? Has greater attention been given to notification of
homes and businesses on rural highways, where private wells tends to be near state highways
The GEIR should include the package of information that introduces a homeowner or public
water supplier to these programs. An explanation of the requirements for data collection and
submittal and the highway department review and approval process should be provided. In
addition, a sample application would be useful to show the type of information needed, the
analysis of data, and the reasons for rejecting and accepting an application. A summary of the
program for the past five years should include annual complaint requests, locations of requests,
and decisions.
Although the focus of the GEIR will be on source reduction management techniques for road
salt, there will be situations where storm drainage systems need to be considered to minimize
impacts. The ENF indicates that modified drainage systems, including snow berms, have been
studied “to prevent groundwater contamination;” Situations where drainage systems are
considered for modification to minimize impacts should include the following.
 When data do not show reductions in sodium levels, despite implementation of a reduced
salt program, the GEIR should consider alternative mitigation, including modification to
existing drainage outlets.
When MHD is proposing changes to its highway drainage system that discharges into a
protected area (Zone I, II, IWPA, or Zone A) around a public drinking water supply, sodium
levels in the water supply should be checked. Where elevated, alternative drainage system
designs should be proposed to minimize the potential for sodium migration into these
critical resource areas. Emergency spill control measures in drainage system designs and
signage to protect water supplies should be considered too.
ENF 1997 - Summary of Comments Responses-Final.doc
3
MassDOT stores all salt and sand mixed salt under cover and has constructed several new
storage sheds in various locations and has modified other existing sheds to provide roof
extensions over the loading areas. These shed improvements and upgrades are described in
the 2012 ESPR.
Chapter 2 of the 2012 ESPR provides a summary of the number and locations of complaints
received over the last five years and a discussion of how successful the remediation
measures have been in reducing sodium levels as part of the Salt Remediation and Reduced
Salt Zone Program. MassDOT will continue to update this information in the proposed
annual reports that would be prepared in the future. In addition, the Salt Remediation
Program information materials and forms have been posted on the MassDOT web site.
See Response to Comment above.
MassDOT believes that improving material efficiency through newer innovations and
technologies is the most cost-effective approach to reducing salt usage. MassDOT will
continue to work with and coordinate with drinking water suppliers on as needed basis to
identify effective solutions. If the use of a RSZ is having little impact on sodium levels, it is
quite possible that other sources in the Zone II area are having a greater impact on these
levels. Due to the much higher capital costs, implementing major drainage modifications are
considered only as a last resort and only if MassDOT has been confirmed to be a major
contributor to the elevated sodium levels. Restricting infiltration and redirecting stormwater
runoff to other receiving waters may also run contrary to the goals of the state’s stormwater
and watershed programs.
2/27/2012
State Agencies (cont.)
Category
Comment
No.
Comment
EOEA– Department of Food and Agriculture Comments fromMarcia Starkey, Lancaster Regional Field Office, dated July 8,1997
Roadside
Vegetation
DFA-01
Impacts of snow and ice controls would discuss roadside vegetation, soils, agriculture and
surface waters, which should include cranberry bog reservoirs and aquacultural areas.
Agriculture
DFA-02
The Department requests that a discrete section of the Update discuss MHD findings and best
management practices which apply to agricultural areas, particularly with respect to over-theshoulder impacts under BMP conditions and related to the speed of the salting vehicle (i.e
Overspray).
Agriculture
BMPs
DFA-03
Recommendations for an effective field edge or vegetated buffer to agricultural activities which
are adjacent to highways, as would other advice and contacts useful to farmers and growers
concerned with this issue.
Agriculture
BMPs
DFA-04
Are low salt zones a feasible measure for lessening impacts already discernable on farmland?
Agriculture
BMPs
DFA-05
We also request the Update discuss the inclusion of s section on agricultural and aquacultural
areas within its guidance documents which could reach state contractors and local jurisdictions.
MassDOT Response
The 2012 ESPR provides an update on these environmental issues, with the exception of
aquaculture. MassDOT is not aware of any aquaculture operations that might be affected by
its Snow and Ice Control Program.
The 2012 ESPR provides a discussion of various innovative measures used by MassDOT to
reduce its salt usage and minimize the potential salt related impacts to the environment. .
Along MassDOT roadways in more rural areas where farmlands exist there is generally a 50
to 100 foot wide right-of-way area that provides a buffer from the treated roadway surface
and any adjacent farmland. Much of the research, as summarized in the 2012 ESPR, have
reported that the bulk of the discernable impacts on roadside vegetation occurs within 30 to
100 feet of the roadway, depending on the roadway size. Refer to Chapter 2 for a more
detailed discussion.
In preparing the 2006 GEIR. MassDOT consulted with the UMass Cooperative Extension
Service to identify any known issues with respect to agriculture. The Extension Service did
not know of any specific situations where agricultural production was being directly affected
by road salt use. If impacts were detected, the Coop Ext Service would be the best source for
guidance, particularly since many farmers have a relationship with their local extension
service specialist.
See Response to Comments above. .
Massachusetts Office of Coastal Zone Management (MCZM), from Margaret M. Brady, Director, dated July 11, 1997
Stormwater
MCZM-01
MCZM supports the preliminary list of discussion topics listed for the 1998 update of the GEIR.
MCZM suggests MHD also investigate how snow and ice control activities can be conducted in a
manner that is consistent with the following:
1) The Stormwater Management Policy;< calls for the use of BMPs to control pollutants
contained in stormwater runoff. Many BMPs depend on vegetated systems for pollutant
removal, and the impacts of salt loadings to these systems should be evaluated for their
potential to alter performance of these vegetated systems.
2) The Snow Removal and Disposal Policy; This policy includes guidance for disposing of snow
away from roadways when snow may contain debris and a variety of pollutants from roadway
sources. Salt content is one of the pollutants of concern and the impacts of snow disposal
should be evaluated for any potential impacts on potential disposal alternatives.
ENF 1997 - Summary of Comments Responses-Final.doc
4
1) MassDOT has not found or is aware of any research that suggests that the use of road salt
reduces the pollutant removal effectiveness in vegetated BMPs.
2) As noted above, MassDOT, as a general practice, does not engage in snow removal and
disposal practices. If snow needs to be removed under rare emergency conditions for
safety or heavy load concerns, it will be done consistent with MassDEP policies.
2/27/2012
State Agencies (cont.)
Comment
Category
No.
Comment
Massachusetts Audubon Society fromLou Wagner, Water Resources Specialist, dated July 11, 1997.
BMPs
Schedule and
Budget Info
MAS-01
Municipal
Coordination
MAS-02
Env- Impacts
MAS-03
Stormwater
MAS-04
GEIR
Preparation
Schedule
MAS-05
We have reviewed the preliminary list of discussion topics for the GEIR. In general, the
preliminary list appears to include the major topics relating to the potential impacts of
S&I control activities. For the GEIR to be a worthwhile undertaking, the analysis of the
environmental impacts of S&I control activities should be detailed and specific
recommendations should be developed to address known problems such as
contamination of public and private groundwater wells. The recommendations for
mitigating impacts should be accompanied by a schedule and budget for implementation.
The findings of the GEIR should also be used to develop recommendations to municipal
public works directors on mitigating environmental impacts of local snow and ice control
measures.
The preliminary list of discussion topics for the GEIR includes a section on environmental
concerns, including soils, roadside vegetation and surface waters. We urge that the GEIR
specifically investigate the potential ecological impacts of S & I control activities. These
investigations should include an assessment of the ecological effects of increased salinity
in soils and surface waters adjacent to roadways and how such changes might impact
native species. Species, communities and ecosystems that may be particularly vulnerable
to harm from S & I Control activities should be identified and mitigation measures
recommended.
It would be useful to expand the GEIR, or to prepare a separate GEIR on highway
maintenance and rehabilitation activities such as stormwater management system
maintenance, lane construction and minor widening projects. The evaluation of the
potential impacts of such activities, and the development of reasonable measures to
mitigate environmental impacts<; would be useful to MHD and other state and local
authorities responsible for highway maintenance. A GEIR devoted to highway
maintenance and rehabilitation activities might help to resolve this problem <;; and be
useful in identifying funding and staffing needs to carry out such activities.
The last update of the GEIR <; Took many years to complete, with six years elapsing
between the draft and final reports. The currently proposed update must be sufficiently
funded and supported to assure that it will be completed in a timely manner. As with
previous Snow and Ice GEIRs, we urge the formation for a Citizens Advisory Committee to
assist in the development of a final scope and to provide guidance to MHD and the
contractor to prepare the GEIR.
ENF 1997 - Summary of Comments Responses-Final.doc
5
MassDOT Responses
The 2012 ESPR contains a list of recommendations for future measures and actions steps to
investigate and/or minimize any potential environmental impacts associate with its Snow and
Ice Control Program. MassDOT has proposed to prepare brief annual reports in the future to
increase the frequency of information exchange and provides updates on progress in
implementing or expanding the use of new measures in the future.
MassDOT shares technical information to municipalities through the Baystate Training Program
or specific training workshops held by MassDOT, but has no jurisdiction or authority to require
municipal DPW’s to adopt any specific recommendations or measures.
Chapter 2 of the 2012 ESPR provides a detailed discussion on these concerns and this
information will be discussed in future annual agency meetings and report updates. .
Since the completion of the1995 GEIR, MassDOT has updated its Facility Environmental
Handbook as part of the 2003 Environmental Management Systems (EMS) Manual and
developed a Stormwater Handbook in 2004, which provides design guidelines and standards of
practice for stormwater BMP design and maintenance activities as well as the handling and
storage of materials.
The current ESPR is targeted for completion by the end of June 2012, which will complete a 5year cycle since the 2006 GEIR and then will be updated every 5 years. As suggested in several
other comments, MassDOT has proposed providing brief Annual Reports in the future to
provide updates on material usage and any progress made on various initiatives to increase the
efficiency of salt usage.
2/27/2012
Federal Agencies
Comment
Category
No.
Comment
EPA – Office of Ecosystem Protection, signed by Jane Downing, Manager and July 10, 1997
EPA-01
EPA-02
EPA-03
Our comments focus on the management of runoff from Massachusetts highways and its
potential adverse impact on public drinking water supplies. An important aspect of snow
and ice control is safe disposal of highway runoff. The ENF presentation addresses most
issues associated with the impact of highway deicing salts; however, the presentation
does not address issues related to other pollution traveling with deicing chemicals and
into drainage systems<<; The Snow and Ice GEIR should be expanded to include
assessment of the negative impacts of polluted highway storm water and accidental spill
runoff on public water supplies. The GEIR should also include assessment of the design,
operation and maintenance of all storm water and spill control structures that will be
used to mitigate the effects of deicing and to prevent highway runoff contamination of
aquifers and streams used for public drinking water supplies.
It is important to maintain the potability of ground water in local aquifers. Control of
hazardous spills into highway drainage systems that discharge into or near drinking water
supplies. Highway deicing management alternatives should also consider designs that
allow control of or don’t allow infiltration of contaminants that may adversely affect
ground water. Drainage structures should allow speedy hazard mitigation when there
are releases; MHD’s “Highway Emergency Response Plans” should be presented in the
GEIR and plans should include mechanisms to alert potentially affected drinking water
supplies of an accidental hazardous release. Drainage systems should also direct highway
runoff away from sensitive resources.
Another issue which is a concern to water suppliers and consumers is the monitoring and
reporting of sodium loading within water supply protection areas. The GEIR should
describe actions which will be pursued by MHD to provide early warning of salt
concentrations before sodium reaches a well as a result of salt deicing applications.
ENF 1997 - Summary of Comments Responses-Final.doc
6
MassDOT Response
The design, operation and maintenance of stormwater drainage systems are addressed in
both the 2004 Stormwater Handbook and as part of MassDOT’s MS4 Stormwater
Management Plan. MassDOT has also initiated an Impaired Waters Program as part of the
MS4 Program, which evaluates and identifies opportunities to implement cost-effective,
stormwater retrofits to enhance treatment of roadway runoff in watersheds of impaired
water bodies. This effort is ongoing and will continue for the foreseeable future.
MassDOT initially participated and assisted in the preparation of the Emergency Response
Plans the Cambridge Water District’s Hobbs rook and Stony rook reservoirs; The updates
and maintenance of these Emergency Response Plans are now administered by the
Cambridge Water Department. These plans, as well as any other compendium of highway
drainage features, are kept on file with the “first responders” of a drinking water supply;
MassDOT will continue to work with PWS’ who have reported elevated sodium levels. It is
most effective for the PWS to conduct their own sampling and analyses since they are most
familiar with their source contribution areas, groundwater or surface flow directions and
have direct access to their well network. It would be an enormous undertaking for
MassDOT to install a statewide network of wells to monitor groundwater quality under a
variety of site specific conditions. As discussed in the ESPR, the sodium data collected from
hundreds of community PWS that are located within 0.5 mile of MHD-roadway, indicated
that less than 10% of these wells had reported sodium levels above 60 mg/l, which is the US
EPA recommended health guidance upper limit for people on sodium restricted diets.
Given the relatively low occurrence of sodium levels being above EP!’s health guidance and
the fact that PWS’ are already required to test and report sodium levels above 20 mg/L, it
would seem that a statewide network of monitoring wells would not be cost-effective or
warranted. It seems much more effective to work with the few PWS’s who are reporting
elevated levels, on a case by case basis, to address the specific issues of each situation.
2/27/2012
Regional Agencies
Category
Comment
No.
Comment
Montachusett Regional Planning Commission; submitted by David Jarvenpaa, Chairman, July 8, 1997
Municipal
MRPC-01 At the Montachusett RPC meeting held on June 24, 1997, members discussed the ENF
submitted by MHD for the 1998 GEIR Update. The Commission found the project in
Coordination
conformity with regional goals, policies and objectives. The project will enhance the MRPC
goal of environmental quality. By gathering the latest information on what effect the
implemented measures have had on reducing salt use and minimizing environmental impacts
and researching new advances in alternative deicing practices and findings form other
relevant studies throughout the country, adjustments can be made to further protect the
environment.
MassDOT Response
MassDOT agrees with the general premise of this comment. See Response to Comment DEP01 above regarding MassDOT’s progress in becoming more efficient and reducing its use of
road salt compared to previous years. . The ESPR presents information with regard to the
effectiveness of newer technologies and innovations which can assist local communities,
private contractors and other agencies in determining what measures could be adopted to
increase their own salt use efficiency.
Northern Middlesex Council of Governments, Robert W. Flynn, Exec Director, July 16, 1997
NMCOG The information produced through this update will be useful to local officials and highway
departments throughout the Commonwealth in assessing the impacts of deicing to surface
-01
and groundwater within their communities and in evaluating their own snow and ice
programs. The proposed document outline contained in the ENF appears to be thorough and
comprehensive. Copies of all local comments received by our office are attached.
(Completed response forms were received from the DPW Directors in Billerica and
Tewksbury indicating they had no significant environmental concerns)
So noted.
Water Supply Citizens Advisory Committee, submitted by Alexandra Dawson, July 14, 1997
WSCAC-01 WSCAC is concerned with this program because of its effect on drinking water quality
WSCAC-02
WSCAC-03
throughout Massachusetts. This state has much higher use than other states, such as
Vermont; and the effect is clear, considering the rising salt levels in local wells, as reported in
MWRA Local Source Studies. We therefore applaud MHD efforts to reduce salt levels,
especially in sensitive areas. The only additions, we would make to your good proposed
scope as follows:
How is salt calculated? That is, how many times per storm is salt applied and why? How is
use monitored? Are salt use reports checked against salt purchases throughout the state?
How much non-calibrated equipment is still in use? Where? Why?
ENF 1997 - Summary of Comments Responses-Final.doc
7
So noted; see responses to the specific comments below.
MassDOT personnel from each depot report salt usage at the end of each storm as part of a
new computerized Snow and Ice Management System to track salt usage by district
throughout the state. The actual number of applications per storm depends on a wide variety
of weather related and non-weather related factors as described in the 2012 ESPR. MassDOT
has evaluated its annual salt use against a Weather Severity Index (WSI), which accounts for a
number of weather variables and has shown that the annual salt use over the last ten years,
going back to 2001, is highly correlated to the WSI and explains approximately 95 percent of
the variability in year to year usage. See Response to Comment DEP-01 above.
MassDOT has adopted strict polices to require all MassDOT spreaders and contractor
spreaders to be submit a calibration certificate prior to use during the season. MassDOT also
has calibration inspection teams to periodically check MassDOT and contractor equipment
through the winter to ensure the equipment settings and calibration documentation are
consistent the MassDOT policies.
2/27/2012
Comment
Category
No.
Comment
Water Supply Citizens Advisory Committee, submitted by Alexandra Dawson, July 14, 1997 (cont.)
WSCAC-04 How many salt piles are still uncovered? When will this work be completed?
WSCAC-05 For “modified” drainage systems, how many times have impervious swales been used? How
WSCAC-07
well do they work? How are they maintained and cleaned out?
What is the latest information on the effect of salt in drinking water on sensitive populations
such as baby bottles?
What is the latest information on roadside tree loss from salt use?
WSCAC-08
What are the current salt levels in small, sensitive rivers such as the Charles and Ipswich?
WSCAC-09
Is there any evidence that overall salt levels in the state are rising or falling?
WSCAC-06
ENF 1997 - Summary of Comments Responses-Final.doc
8
MassDOT Response
All of MassDOT’s salt piles are covered.
Modified drainage systems have been used in southeastern Mass to protect areas near
cranberry bogs. MassDOT has ongoing studies to assess the effectiveness of these systems.
See Response to Comment EPA-03 above.
Chapter 2 of the2012 ESPR provides a discussion on various research concerning impacts to
roadside vegetation. MassDOT is not aware of any roadside inventory of affected trees but
the general consensus appears to be that the extent of the impacts are highly localized based
on anecdotal data.
MassDOT has commissioned a study with the US Geological Survey to analyze highway runoff
quality from its roadways, which contains some data on sodium and chloride level in runoff
but has limited data with respect to concentrations in streams and rivers statewide. Baseline
sampling conducted in several streams along the I-93 corridor in the Tewksbury-Andover
area during the winter of 2010/11 in conjunction with US EPA efforts indicated elevated
levels in certain streams both upstream and downstream of the highway, which suggests
multiple sources are likely to be contributing to these elevated levels. MassDOT has
continued to work with EPA in evaluating the implications of the observed levels for the
Town of Wilmington’s water supply; MassDOT has also been working with the ambridge
Water District to assist in the monitoring sodium and chloride levels within their reservoir
system along the Route 128/95 corridor.
See Response to Comment DEP-03 above
2/27/2012
Local Agencies
Comment
Category
No.
Comment
City of Boston Environmental Department, submitted Lorraine M. Downey, Director – Letter dated August 11, 1997
BED-01
BED-02
BED-03
BED-04
BED-05
BED-06
The ENF under review was developed by the Massachusetts Highway Department. Previous
submissions to MEPA regarding roadway snow and ice control programs were identified under
EOEA #2358 and included the Massachusetts District Commission (MDC) and Massachusetts
Turnpike Authority (MTA) as proponents.
The August 31,1995 Certificate of the Secretary of Environmental Affairs on the Final Generic
Environmental Impact Report (EOEA #2358) indicates that a draft GEIR was reviewed by MEPA
in 1976; a final report prepared in 1978; and ENF for an update reviewed in 1985; a draft
report reviewed in 1989; and a final report submitted in July 1995. Section 61 Findings for
EOEA #2358 were issued by MHD in March, 1997. There was a tentative Commitment,
referenced in the Certificate, to the filing of a new GEIR by the fall of 1977. Responses to the
numerous comments submitted regarding EOEA #2358 were required by the Secretary as part
of subsequent review.
We note that the subject filing does not comply with the timelines outlined in the Secretary’s
August 31, 1995 Certificate. While the MDC and MTA were, partied to the 1995 filing, they are
not referenced in the current submission. Are they to be included in this process or will each
entity file a separate document?
This department is in agreement with past commenters who have identified the need for
statewide program of snow and ice control, to include the identification of sensitive and critical
areas and for the coordination and sharing of information and resources. The Mass Executive
Office of Transportation and Construction (EOTC) should take a leadership role in this regard..
We do not agree with the MHD perspective that it is appropriate not to identify critical areas
for low salt treatment. With ever-improving GIS and coordination and information sharing
among state and municipal environmental and transportation agencies, such identification
should be fairly efficient. We consider it a necessary part of effective mitigation.
In response to question number one in Section D of the ENF, MHD indicates that “*m+itigation
measures to alleviate salt impacts may result in minor changes in drainage patterns at
particular locations;” The mitigation measures, changes in drainage patterns and the location
should be detailed in the GEIR.
We understand from the July 11, 1997 MEPA Consultation Session that private vendors for
MHD are required to have equipment with calibrated speed control devices. Does this device
allow MHD to analyze application rates and total materials applied for the season over a
specific route? If not, how does MHD make such determinations when routes are not treated
using MHD equipment?
ENF 1997 - Summary of Comments Responses-Final.doc
9
MassDOT Response
The Turnpike Authority is now integrated into MassDOT Highway and MassDOT conducts
snow and ice operations on approximately 60 percent of DCR’s (formerly MDC) urban
parkways as described in the current ESPR.
So noted. Responses to the Previous Comments are included in Appendix of the current
2012 ESPR.
See Response to Comment CBED-01 above.
MassDOT continues to work with water suppliers and agencies throughout the state and
has established approximately fifty-three (53) reduced salt zones throughout the state. The
establishment of reduced salt zones is serious matter and cannot be taken lightly as added
substantial costs and public safety related issues must be weighed against the potential
benefits. Detailed field investigations are important part of the process to confirm that
MassDOT’s snow and ice operations are a primary source of the impacts to the affected
source
So noted. See Response to Comment EPA-03 above and Chapter 3 of the ESPR for a detailed
description of the ESPR.
Newer closed loop controllers, introduced in the last 2 to 3 years have data logging
capabilities to record salt usage. About 50% of the hired equipment used last year had
these controllers. The older ground speed control devices do not have recording
capabilities but were designed to adjust and maintain a more uniform application of
material based on truck speed. Material usage is currently recorded by route coordinators
and time keepers who manually track equipment during the storm and supply this data to
depot foreman after each event.
2/27/2012
Local Agencies (cont.)
Category
Comment
No.
Comment
MassDOT Response
BED-07
The March1997 Section 61 findings suggest that MHD has not evaluated alternative deicing
compounds since the late 1980’s (page 8, 2nd full paragraph); The GEIR should confirm that
this is the case or provide detailed information on the alternatives evaluated and the results of
those evaluations. In addition, the potential environmental impacts/pollution prevention
consequences of alternatives such as Calcium Magnesium Acetate (CMA) must be outlined.
BED-08
We ask that the upcoming filing contain a section devoted to a discussion of the control of
snow and ice program for sidewalk areas abutting state highways and bridges.
BED-09
MassDOT has expanded its use of liquid calcium chloride and magnesium chloride to
enhance the effectiveness and efficiency of regular road salt. See Response to Comment
EPA-01. The 2012 ESPR discusses the various alternative deicers, especially non-chloride
deicers, which can be effective in addressing sodium and chloride issues but can pose other
environmental risks such as dissolved oxygen depletion and increased nutrient loading.
Their effectiveness in terms of melting capacity pound for pound appears to be less than
that of chloride based deicers. The biggest challenge to using these materials is the overall
cost, as the unit cost for non-chloride deicers is generally 15 to 20 times greater than that of
road salt. With roughly 16,000 lane-miles of roadway to maintain, using non-chloride
deicers would increase MassDOT’s Snow& Ice Budget by well over $100 million.
MassDOT’s responsibility for snow and ice control is within the travel way from the curb line
to curb line and does not maintain responsibility for sidewalk clearing. Sidewalk clearing is
the responsibility of the municipality.
The March 1997 Section 61 Findings and the ENF indicates that sediment from snow and ice
control treatments often collect in catch basins. Impervious swales are also identified as a
mechanism for sediment collection. We request that the frequency and cost of swale and
catch basin maintenance be outlined in the next filing and that they also be included in the
description of Best Management Practices (BMPs).
The ENF and proposed Scope make no reference to the storage and disposal of snow removal
from roadways. Locations of storage areas should be identified and details provided about
whether or not the areas are enclosed, about the permeability of storage surfaces and the
management of runoff from the sites. Any sensitive or critical areas surrounding these sites
must be identified.
A particular concern for the City of Boston is the quality of stormwater originating on state
roadways and then moving through the ity’s system; Given the increasingly stringent
stormwater quality requirements of DEP and the EPA, the City has a substantial interest in
ensuring that other governmental entities are addressing this issue. As suggested by CZM in
08/21/95 comments, MHD and other state transportation agencies must link stormwater
quality to specifications for construction, reconstruction, repair, operations and maintenance.
We support the recommendations for entities to develop standards for managing stormwater.
We understand that there was, at one time, a Salt Advisory Committee involved in snow and
ice control issues. MHD should outline in its next filing the origin and constitution of the
committee, its past role in policy-making and plans for its future.
City of Boston Environmental Department, submitted Lorraine M. Downey, Director – Letter dated August 11, 1997 (cont.)
CBED-10
BED-11
BED-12
BED-13
The representative from MHD suggested at the MEPA Consultation Session that a GEIR on
snow and ice control would be appropriate every 10 years. Given the history of environmental
filings on this issue we strongly disagree. MHD and other state transportation agencies must
prove willing to comply with mandated requirements and must show good faith in their
planning and operations before any discussion of reduced GEIR standards.
ENF 1997 - Summary of Comments Responses-Final.doc
10
MassDOT is using much less sand as part of its snow and ice operations, which greatly
reduces the need for swale and drainage system maintenance. Sand has shown to have
limited effectiveness for improving road way traction and is expensive to clean up.
MassDOT does not typically engage in snow removal and storage activities. The only time
snow might be removed is in an emergency situation when there are safety or excessive
loading concerns.
Stormwater quality issues are addressed as part of MassDOT’s MS4 Stormwater General
Permit, Stormwater Management Plan and related annual reports. As part of this overall
effort, MassDOT has initiated an Impaired Waters Program in the last two years that
focuses on identifying locations for appropriate stormwater BMP retrofits that will help to
reduce MassDOT’s potential contributions to impaired waters associated with highway
runoff. The lower Charles River Basin is one of the high priority areas of this program.
!dditional information on this program can be found on the MassDOT’s web site; ;
The 1997 EOEA Certificate agreed to disband and dismiss the Committee for future filings.
The 2006 EOEA Certificate (Dec, 1, 2006), also established a Special Reporting Procedure
with increased reporting frequency and timing such that the role of a Citizen Advisory
Committee was considered to no longer be needed.
Consistent with the Special Reporting Procedure outlined in the 2006 Certificate, MassDOT
has agreed to prepare Snow and Ice Control ESPR’s every five years with the current ESPR to
be completed in 2012.
2/27/2012
Public at Large
Comment
Category
No.
Comment
Ingeborg Uhlir, Weston, MA dated July 14, 1997, member of the former Salt Advisory Committee
UHLIR-01
The description of the project is misleading in that it describes the application rate of 240
lbs/lane-mile as “new”; In fact, that application rate was initiated in the 1970’s with the
intent to continue rate reductions absent any adverse impacts. Since no adverse impacts
have been demonstrated in subsequent MEPA reviews, it is time to reduce the application
rate again. Without a policy change in the current application rate, total salt use has crept
up from the ”low” of 200 million pounds in 1980 according to the DEIR of March 1989.
UHLIR-02
The so-called reduced salt zones, ostensibly marked along state highways, are in fact areas
where the application rates are reduced. There should be an evaluation of the total annual
salt application in these zones compared to adjacent roadways. Since the intent of the
reduced salt zones was to minimize salting in watersheds, that purpose would not be well
served if lower application rates resulted in more frequent applications.
UHLIR-03
Please include in the GEIR updated information about the length of road miles and lane-miles
under this Program. Vehicle trip data would also be relevant.
There is evidence that road salt adversely impacts some roadside vegetation. Maple tress in
particular are salt averse, as documented by studies at the University of Massachusetts.
Techniques to prevent salt contamination in surface or groundwater must include using less
salt. Mitigation after-the-fact is less cost effective than prevention.
Earlier attempts to assure that spread rates were within the range that was allowed relied on
a “materials control” program; That program revealed a disparate spread rate among
contractors. This is an opportunity to revisit that information and set a timetable for
improved calibration of spread rates.
Monitoring the impacts on water supplies should be reported to the public using that water.
The requirement to report on annual salt use by highway section should be revived even
though MGL C.85 Sec. 7A is no longer available.
UHLIR-04
UHLIR-05
UHLIR-06
UHLIR-07
UHLIR-08
UHLIR-09
UHLIR-10
UHLIR-11
The Snow and Ice Control Program requires the use of more water for car washing. Even with
that precaution, vast cost absorbed by vehicle owners are associated with salt damage to
cars. There are also associated accident injuries due to deteriorated auto parts.
Salt related bridge damage and other infrastructure costs must be realistically evaluated.
Prior GEIR’s reported at least in part about the MT! and MD Programs as well as the DPW
Program. Will they be included in the DEIR?
The difference in accident rates or severity within the so-called reduced salt zones and other
highways should be documented. Although the earlier Salt Advisory committee asked for
such an analysis, no information was forthcoming.
ENF 1997 - Summary of Comments Responses-Final.doc
11
MassDOT Response
As discussed in the 2012 ESPR, the 240 lbs per lane-mile application rate is consistent with
what other New England states are using is considered to be the minimum of material
needed to effectively prevent snow and ice from bonding to the pavement under most
winter storm conditions. Reducing the application rate below a certain amount could result
in the material being ineffective or in other words wasted. MassDOT has been able to
increase the efficiency and effectiveness of the applied material to reduce its overall use for
a given season. As discussed in the Response to Comment DEP-01, MassDOT recently
reported a 23 percent reduction in its overall salt usage for the winter of 2010/11,
compared to previous years of similar winter severity. This is even more notable given that
MassDOT road network has increased by 20 % since the 2006 GEIR. The 2010/11 winter
was also one of the most severe winters in the last ten or more years.
In reduced salt zones, the same application rate of 240 lbs per ln-mile is still utilized but
much of the sodium chloride material is replaced by either Pre-mix (i.e., mix of CaCl2 and
NaCl) or sand. Thus, the amount of sodium that would otherwise be applied is reduced but
essentially the same amount of material is applied. In locations where sand is used to
replace salt, the effectiveness of the applied material is often greatly reduced especially at
cold temperatures.
So noted. This information is provided in the 2012 ESPR.
Chapter 2 of the 2012 ESPR provides a discussion of the potential road salt impacts on
roadside vegetation.
So noted. See Responses to Comments DEP-01 and UHLIR-01 above.
Since the late 1990s, MassDOT has required that all contractors submit a calibration
certificate prior to the season. See also Response to Comment WSCAC-03 on page 8 above.
PWS are required to report sodium levels once every 3 years to MaDEP and notify the local
Board of Health if levels exceed 20mg/l. MassDOT generally works with PWS’, such as the
Cambridge Water District, who have ongoing issues with elevated sodium levels to report
salt usage. .
So noted. These added costs of vehicle washing and corrosion must be weighed against the
potential added costs of increased accidents and injuries if roadways were not maintained
to be reasonably safe conditions.
Chapter 4 of the 2012 ESPR provides an evaluation of the potential costs due to bridge and
other infrastructure corrosion.
See Response to Comment DEP-02 above
Chapter 5 of the 2012 ESPR discusses vehicle accident rates during winter months based on
Mass RMV data, however, accident rate data in specific reduced salt zones is not readily
available and would require additional funding and studies to obtain such data. .
2/27/2012
Public at Large (cont.)
Comment
Category
No.
Comment
Stephen H. Kaiser, PhD, member of Road Salt Task Force, 1985-1996, submitted July 09, 1997
1) What is meant by “reasonably safe”? What is MHD’s interpretation of this goal?
KSR-01
2) What is meant by “conditions” and how does this come into play?
3) What is “reasonable expenditure funds”? Does this mean the MHD snow and ice control
budget? What about expenditure by anyone else such as people buying bottled water,
bridge repair, replacing rusted vehicles etc.
KSR-02
Based on available studies and data, any claim that road salting improves safety cannot be
justified. Not only does accident data not support a safety claim but there is evidence that
the immediate ice-removing capabilities of salt may be counterbalanced by the accidentincreasing effects of higher speeds, refreezing and slipperiness of wet pavements
KSR-03
The 1992 “Draft Final GEIR” actually gave the best summary of reasonable conclusions
namely that: “! review of the relevant literature indicates that researchers have been unable
to establish an empirical relationship between winter maintenance and traffic safety;”The
literature suggests that accident severity is lower on snow covered pavement as compared
with slush, wet or dry conditions. Attempts to relate winter maintenance to traffic accidents
have resulted in inconclusive findings;”
When the actual Final GEIR was issued in July 1995 any discussion of safety issues had been
deleted. There is nothing in the new ENF filing which indicates that the state highway
department is prepared to discuss the safety implications of the road salting program.
MEP! should not “defer to the expertise” (actual or alleged) of the Mass Highway
Department with respect to safety issues. The use of road salt is another example where
there must be an overriding public purpose in which to justify the obvious environmental
damage which results. At the moment, MEPA and the GEIR process is the only forum
available to address issues of safety and environmental tradeoffs. The new road salt GEIR
should update any research on the effect of road salt on safety, specifically relating to
accident rates through the use of non-use road salt during snow and ice conditions.
KSR-04
ENF 1997 - Summary of Comments Responses-Final.doc
12
MassDOT Response
1) The term “reasonably safe” involves personal judgment on the part of the vehicle
operator and therefore is subject to broad interpretation but it is intended to mean
providing road conditions that allow motorists to maintain vehicle mobility and control
at speeds well below posted speed limits while using safe driving techniques.
2) Weather and road conditions are ever changing during winter storms particularly
during heavy snowfalls and high winds. Motorists need to adjust their speed and driving
habits while snow and ice personnel may adjust their application timing and frequency.
3) The reference to “reasonable expenditure funds” pertained to MassDOT’ Snow and Ice
Budget. As discussed in Response to Comment CBED-07, there are alternative deicers
that could be used but the cost differential in using these materials would be huge.
The 2012 ESPR provides an analysis of accident rates during the winter months vs. nonwinter months as well as days with snow and without snow based on reported accident
data in Massachusetts. The data shows considerably higher accident rates during
winter months and on snow days. This would indicate that winter clearly has an effect
on accident rates and to the extent that snow and ice operations can make roads safer,
this would seem to be an important socio-economic and public safety benefit.
See the Response to Comment above regarding vehicle accident data.
See Response to Comment above and Chapter 5 of the 2012 ESPR for a more detailed
discussion on vehicle accident data.
2/27/2012