The Commonwealth of Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 , MA 02114 Charles D. Baker GOVERNOR Tel: (617) 626-1000 Karyn E. Polito Fax: (617) 626-1081 LIEUTENANT GOVERNOR http://www.mass.gov/eea Kathleen A.Theoharides SECRETARY

March 26, 2021

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE ENVIRONMENTAL NOTIFICATION FORM

PROJECT NAME : Woburn Fire Headquarters PROJECT MUNICIPALITY : Woburn PROJECT WATERSHED : Aberjona River EEA NUMBER : 16333 PROJECT PROPONENT : Mayor Scott Galvin, City of Woburn DATE NOTICED IN MONITOR : February 24, 2021

Pursuant to the Massachusetts Environmental Policy Act (MEPA; M.G. L. c. 30, ss. 61-62I) and Section 11.06 of the MEPA regulations (301 CMR 11.00), I hereby determine that this project does not require an Environmental Impact Report (EIR).

Project Description

As described in the Environmental Notification Form (ENF), the project proposes the construction of a new Fire Department Headquarters (Headquarters) for the City of Woburn (the City) in Forest Park, which is land that is subject to protection pursuant to Article 97 of the Amendments to the Constitution of the Commonwealth (Article 97). The City proposes to construct two buildings: a 27,000 gross square foot (sf) two-story building that will act as the Headquarters, and a 6,800-sf single-story building that will serve as a maintenance building for repair of the firefighting vehicles and equipment. The Headquarters will be constructed at 731 Main Street and consist of apparatus bays with support spaces, central administration offices for the fire department, a meeting room that will be available to the public, and second floor dormitory facilities for the firefighters assigned to this station. The project will include the construction of a new surface parking lot with 47 spaces, three access drives off of Maine

EEA# 16333 ENF Certificate March 26, 2021

Street, a new communications tower, and improvement of an existing trailhead that will be accessible from the new parking lot. The project also includes the construction of a new stormwater management system.

Following the construction of the new Headquarters, three of the five existing fire stations within the City (Station 1, 4, and 5) covering the west, east, and southern portions of the City will be renovated. The two remaining stations (Station 2 and 4) will be decommissioned, resulting in four total fire stations (including the new Headquarters). According to the ENF, once decommissioned, the two existing stations will have the potential to offer additional public benefits, although specific uses have not been identified. The project also includes the transfer of the care, custody, management, and control of a 3.183-acre parcel of land located near the Hurld-Wyman School to the Woburn Recreation Commission to address the no-net loss provision of Article 97 Policy and to mitigate the loss of 3.16-acres of Article 97 Land within Forest Park.

Project Site

As described in the ENF, the 3.16-acre project site is part of Forest Park, a 35.14-acre, City- owned site that includes walking trails and recreational fields. All of Forest Park, including the proposed site, is Article 97 Land. The project site is currently undeveloped and moderately forested. The site is bound to the north by Fisher Terrace and associated residences, to the west by the remainder of Forest Park, to the south by Intervale Street and associated residences, and to the west by Main Street (Route 38). As noted in the ENF, the site is immediately adjacent to the Massachusetts Route 38 at Massachusetts Route 128/ . The project site does not contain Estimated and Priority Habitat of Rare Species as delineated by the Natural Heritage and Endangered Species Program (NHESP) in the 14th Edition of the Massachusetts Natural Heritage Atlas, nor is it located in an Area of Critical Environmental Concern (ACEC). The site does not contain any structures listed in the State Register of Historic Places or the Massachusetts Historical Commission’s (MHC) Inventory of Historic and Archaeological Assets of the Commonwealth.

Environmental Impacts and Mitigation

Potential environmental impacts associated with the project include the alteration and clearing of 3.16 acres of forested land, the creation of 1.56 aces (67,660 sf) of impervious surface, the generation of 122 additional vehicles trips per day (adt), and the construction of 47 new parking spaces. The project will require the release of 3.162 acres of Article 97 Land. The project will generate 1,000 gallons per day (gpd) of wastewater and 1,000 gpd of water demand.

Measures to avoid, minimize, and mitigate, environmental impacts include: the transfer of 3.183 acres of land to the City’s Recreation Commission, the construction of a stormwater management system to capture and treat runoff, tree and shrub plantings, use of sediment and erosion controls during construction, and use of a planned construction vehicle route to minimize traffic impacts during construction.

Jurisdiction and Permitting

This project is subject to MEPA review and preparation of an ENF pursuant to 301 CMR

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11.03(1)(b)(3) because it requires a State Agency Action and involves the conversion of land held for natural resources purposes in accordance with Article 97 of the Amendments to the Constitution of the Commonwealth to any purposes not in accordance with Article 97. The project requires a Vehicular Access Permit from the Massachusetts Department of Transportation (MassDOT).

The project submitted a request for a Determination of Applicability from the Woburn Conservation Commission and received a Negative Determination on June 14, 2019. The project requires a Site Plan Approval from the Woburn Planning Board which it has received; a Special Permit was issued on February 27, 2020. The project requires a National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) from the United States Environmental Protection Agency (EPA).1

The project is not receiving Financial Assistance from the Commonwealth. Therefore, MEPA jurisdiction is limited to those aspects of the project that are within the subject matter of any required or potentially required Agency Actions and that may cause Damage to the Environment, as defined in the MEPA regulations.

Review of the ENF

The ENF provided a description of existing and proposed conditions, preliminary project plans, geotechnical report, details on fire department facilities upgrades, an alternatives analysis, stormwater management report, construction period impacts, Woburn Recreation Commission and Committee on Finance hearing minutes, correspondence with EEA, Chapter 95 of the Acts of 2020: “An Act Authorizing the City of Woburn to Use Certain Land for Fire Station Purposes” (the Legislation), and the Negative Determination of Applicability from the Woburn Conservation Commission. The ENF also identified measures to avoid, minimize and mitigate environmental impacts. Additional information regarding Article 97 impacts, the stormwater management system design, and proposed tree and shrub plantings was provided to the MEPA Office to assist in review.2 For the purposes of this Certificate, this supplemental information in combination with the original filing materials is referred to as the ENF.

Comments from MassDOT do not identify any impacts that were not reviewed in the ENF, nor do they note deficiencies in the alternatives analysis or recommend additional alternatives for further review. Comments from the Mystic River Watershed Association (MyRWA) express concern with the proposed stormwater management system and tree clearing associated with the project, which are discussed further below.

Alternatives Analysis

The ENF describes the project goals as constructing a new Fire Department Headquarters to improve the emergency response coverage and capabilities of the Woburn Fire Department while minimizing environmental impacts at the preferred project site. The City is currently served by five (5) fire stations ranging in age from 40 to 120 years old. A feasibility study was performed to evaluate the

1 The necessity of a NPDES CDP was not identified in the ENF but was confirmed in an email from Janet Bernardo (Horsley Witten Group) to Eva Murray (MEPA Office) on March 24, 2021. 2 Supplemental information provided in an email from Janet Bernardo (Horsley Witten Group) to Eva Murray (MEPA Office) on March 17, 2021. 3

EEA# 16333 ENF Certificate March 26, 2021 existing stations’ physical condition and their ability to be successfully renovated and/or expanded to suit current firefighting needs. The feasibility study also evaluated five different sites as potential locations for a new Headquarters building and new or renovated substations. Based on the results of the feasibility study, which evaluated 4-minute emergency coverage for six different combinations of existing and new infrastructure, the ENF includes three different alternatives that were selected for evaluation (Alternative 1, Alternative 2 and Alternative 3 (Preferred Alternative)), in addition to a No- Build Alternative.

The No-Build Alternative would avoid impacts to undeveloped Article 97 Lands. According to the ENF, even with renovations or expansions of the existing fire stations, all of the existing station sites are too small to provide necessary storage space, and most lack sufficient area to provide adequate fire vehicle driveways. As described in the ENF, the No-Build Alternative was dismissed as it would not satisfy the project purpose of improving emergency response capabilities in Woburn. Alternative 1 would involve the construction of the new Headquarters at the Forest Park site, a new substation at the Joyce Middle School site, and the demolition of the existing Station 4 to build a new state-of-the-art substation at the Station 4 site. The remaining existing fire stations (Station 1, 2, 3, and 5) would be decommissioned following construction. According to the ENF, this Alternative would worsen the 4- minute emergency response coverage, would still require the disposition of 3.16 acres of Article 97 Land, would increase the impervious surface at the Joyce School site and Station 4 site, and would result in impacts to areas designated for water supply protection. For these reasons, Alternative 1 was dismissed.

Alternative 2 would involve constructing the new Fire Department Headquarters at the Senior Center site within the City, which would avoid impacts to Article 97 Land. According to the ENF, while the Senior Center site has adequate space to construct the new Headquarters, it does not, however, provide for 4-minute emergency response coverage, and was therefore dismissed. Alternative 3, the Preferred Alternative (described herein), improves upon the existing 4-minute emergency response coverage of households, nonstructural fires, emergency medical services, and other incidents. As described in the ENF, the location of the Headquarters will also provide quick access to MassDOT Route 128/ Interstate 95. The Preferred Alternative will require the disposition of 3.16 acres of Article 97 land and will increase the impervious surface at the Forest Park site by approximately 67,660 sf. The Preferred Alternative will not result in impacts to wetland areas or within wetland buffer zones and will not impact land designated for water supply protection. According to the ENF, the Preferred Alternative was selected because it achieves the primary project purpose of improving emergency response coverage and upgrades municipal emergency infrastructure while minimizing environmental impacts.

Article 97

Prior to submitting the ENF, the Town consulted with staff from EEA to address the project’s compliance with the EEA Article 97 Land Disposition Policy (Article 97 Policy). Any disposition affecting land held for Article 97 purposes must be carefully considered to protect these lands from development pressures and to preserve the Commonwealth’s legacy of open space conversation and protection. Land protected by Article 97 may not be disposed of without authorization from the legislature. The ENF included a copy of the Article 97 Legislation which authorized the City to use approximately 3.162 acres of land within Forest Park for the construction of the new Headquarters. Forest Park was acquired by the City on October 4, 1980 for the purpose of park land and includes

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EEA# 16333 ENF Certificate March 26, 2021 walking trails and recreational fields. As stated in the Article 97 Legislation, the City will transfer the care, custody, management and control of approximately 3.183 acres of land currently held for general municipal purposes to the Woburn Recreation Commission to be used solely for active or passive park and recreational uses in order to comply with the Article 97 Policy. According to the ENF, this parcel of land (referred to as the Spence Farm site) is more centrally located within Woburn and is adjacent to an elementary school, offering more value as an open space amenity due to its increased accessibility.

As part of the construction of the new Headquarters, the trailhead of an existing walking trail within the park will be retained and regraded for ease of access. The parking lot constructed as part of the Headquarters will also serve as public parking for those seeking to use the walking trail, for which a parking lot does not currently exist. Comments from the MyRWA express concern with the proposed tree clearing within Forest Park and note that the Spence Farm site is not forested. MyRWA comments state that the tree clearing in Forest Park represents an unmitigated environmental impact due to the loss of forested canopy and associated environmental benefits. The original ENF filing did not include a tree planting plan, however additional information provided to the MEPA Office on March 17, 2021 included a tree and shrub planting plan that proposes a significant number of deciduous, flowering, and evergreen trees; deciduous and evergreen shrubs; and additional grasses and groundcover within the Fire Department Headquarters site.

Stormwater

The project will create 1.56 acres of impervious area within the project site. A stormwater management system is proposed to mitigate stormwater runoff generated from the impervious surface. As described in the ENF, the stormwater system will convey runoff from the rooftops, parking areas, and walkways through a series of trench drains, catch basins, and manholes located throughout the site. All runoff will ultimately be captured by one of two underground infiltration systems. According to the ENF, the proposed drainage system has the capacity to capture, store, and recharge up to and including a 25-year 24-hour storm event, and will result in minimal discharge to the municipal system during a 100- year storm event. The ENF states the proposed stormwater management system was designed in accordance with the Massachusetts Stormwater Management Standards. Comments from the MyRWA note concern with the data used to establish the design standards for the stormwater management system, and request that the City reference the U.S. National Oceanic and Atmospheric Administration (NOAA) Atlas 14 precipitation projections to size the stormwater management system. As described in the ENF, the stormwater analysis was conducted using the Extreme Precipitation Tables from the Northeast Regional Climate Center (NRCC). I note that the Massachusetts Department of Environmental Protection (MassDEP) is currently in the process of updating the Massachusetts Stormwater Handbook and the Massachusetts Wetlands Protection Act (WPA) stormwater regulations (310 CMR 10.05(6)), including, at a minimum, adopting the NOAA Atlas 14 precipitation projections for stormwater management.3 According to the ENF, the NRCC precipitation projections were chosen because they include higher volumes for the 100-year storm event as compared to the NOAA Atlas 14.

Climate Change Adaptation and Resiliency

Governor Baker’s Executive Order 569: Establishing an Integrated Climate Change Strategy for

3 More information on the Massachusetts Stormwater Management updates can be found at: https://www.mass.gov/info- details/massachusetts-stormwater-management-updates-advisory-committee 5

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the Commonwealth (EO 569; the Order) was issued on September 16, 2016. The Order recognizes the serious threat presented by climate change and direct Executive Branch agencies to develop and implement an integrated strategy that leverages state resources to combat climate change and prepare for its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state government and cities and towns for the impacts of climate change. I note that the MEPA statute directs all State Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other administrative approvals and decisions. M.G.L. c. 30, § 61.

The Northeast Climate Science Center at the University of Massachusetts at Amherst has developed projections of changes in temperature, precipitation, and sea level rise for Massachusetts. This data is available through the Climate Change Clearinghouse for the Commonwealth at www.resilientma.org. By the end of the century, the average annual temperature in the Boston Harbor Drainage Basin is projected to rise by 4.85 to 9.33 degrees Fahrenheit (°F), including an increase in the number of days each year with temperatures over 90 °F from a minimum of an additional 20.61 days to a maximum of an additional 53.83 days compared to the 1971-2000 baseline period. During the same time span, the average annual precipitation is projected to increase by a minimum of 4.42 to a maximum of 4.95 inches, which may be associated with more frequent and intense storm events. The Massachusetts State Hazard Mitigation & Climate Adaptation Plan (2018) may provide additional data and resources applicable to the project site.

The City is a participant in the Commonwealth’s Municipal Vulnerability Preparedness (MVP) program. The MVP program is a community-driven process to define natural and climate-related hazards, identify existing and future vulnerabilities and strengths of infrastructure, environmental resources, and vulnerable populations, and develop, prioritize and implement specific actions the City can take to reduce risk and build resilience. Through the MVP program, the City received funding to conduct a planning process for climate change resiliency and implementing priority projects. The results of the initial community-driven process were presented in the “City of Woburn Community Resilience Building Workshop - Summary of Findings” (the Report), dated April 2019.4 The Report identified flooding, high winds, snow and ice, and extreme heat and drought as top climate hazards in Woburn. The Report notes that between 1961 and 2015, the 24-hour, 100-year rain event in Woburn increased from 6.5 inches to 8.4 inches and that extreme precipitation events are causing severe local riverine and stormwater flooding in the City. As noted above, comments from the MyRWA express concern with the sizing of the proposed stormwater management system. I encourage the City to consider future climate change conditions as the design of the project is finalized and proceeds to permitting.

Greenhouse Gas (GHG) Emissions

While the project does not exceed the thresholds for application of MEPA’s GHG Policy and Protocol, it does involve the development of presently forested, undeveloped land that will add to GHG emissions from the building sector. The ENF states the proposed Headquarters will be built to limit energy demand and mitigate its carbon footprint. According to the ENF, the proposed building will meet or exceed energy code requirements. The building will be “solar ready,” and a building mounted solar study is currently underway. EV charging stations will be provided onsite to enable and encourage

4 The Report can be accessed at: https://www.mass.gov/doc/woburn-report/download 6

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electric vehicle usage. I encourage the City to continue to investigate and implement energy efficiency measures as the project design is finalized.

Traffic

The project will result in the generation of 122 vehicles trips per day and the construction of 47 parking spaces within the project site. Comments from MassDOT state that, while not described in the ENF, the Proponent confirmed the trip generation is based on anticipated employee shift timing and employment levels provided by the Fire Department. The project proposes the addition of two traffic poles and one red light traffic signal along Main Street (Route 28) to ensure safe entrance and exit from the site by fire vehicles. The ENF states the project will have minimum impacts on post-construction traffic. Comments from MassDOT state the ENF adequately discusses the transportation impacts from the project, and does not request further environmental review based on transportation-related issues.

Construction

According to the ENF, site preparation work for the project will take approximately four months and building construction approximately 14 months. According to the ENF, a construction vehicle route has been proposed to mitigate traffic impacts during construction. The route requires incoming and outgoing vehicles to approach the site via MassDOT Route 128 / Interstate 95, limiting overall traffic impacts to the City of Woburn. The project will be phased such that the proposed Headquarters will be constructed first followed by the sequential upgrading of the existing substations (Stations 1, 4, and then 5) to avoid loss of emergency response capabilities. Once upgrades are complete, Stations 2 and 3 will be decommissioned.

All construction activities should be managed in accordance with applicable MassDEP’s regulations regarding Air Pollution Control (310 CMR 7.01, 7.09-7.10), and Solid Waste Facilities (310 CMR 16.00 and 310 CMR 19.00, including the waste ban provision at 310 CMR 19.017). The project should include measures to reduce construction period impacts (e.g., noise, dust, odor, solid waste management) and emissions of air pollutants from equipment, including anti-idling measures in accordance with the Air Quality regulations (310 CMR 7.11). I encourage the Proponent to require that its contractors use construction equipment with engines manufactured to Tier 4 federal emission standards, or select project contractors that have installed retrofit emissions control devices or vehicles that use alternative fuels to reduce emissions of volatile organic compounds (VOCs), carbon monoxide (CO) and particulate matter (PM) from diesel-powered equipment. Off-road vehicles are required to use ultra-low sulfur diesel fuel (ULSD). If oil and/or hazardous materials are found during construction, the Proponent should notify MassDEP in accordance with the Massachusetts Contingency Plan (310 CMR 40.00). All construction activities should be undertaken in compliance with the conditions of all State and local permits.

Conclusion

The ENF has adequately described and analyzed the project and its alternatives, and assessed its potential environmental impacts and mitigation measures. Based on review of the ENF and comments received on it, and in consultation with MassDOT, I have determined that an EIR is not required.

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March 26, 2021 ______Date Kathleen A. Theoharides

Comments received:

03/16/2021 Massachusetts Department of Transportation (MassDOT) 03/16/2021 Mystic River Watershed Association (MyRWA)

KAT/ELM/elm

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March 16, 2021

Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114-2150

RE: Woburn: Woburn Fire Station Headquarters – ENF (EEA #16333)

ATTN: MEPA Unit Eva Murray

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Environmental Notification Form for the Woburn Fire Station Headquarters project in Woburn, as prepared by the Office of Transportation Planning. If you have any questions regarding these comments, please contact J. Lionel Lucien, P.E., Manager of the Public/Private Development Unit, at (857) 368-8862.

Sincerely,

David J. Mohler Executive Director Office of Transportation Planning

DJM/jll

Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot

Woburn Fire Station Headquarters Page 2 3/16/2021 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division Paul Stedman, District 4 Highway Director Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Planning Board, City of Woburn Metropolitan Area Planning Council

MEMORANDUM

TO: David Mohler, Executive Director Office of Transportation Planning

FROM: J. Lionel Lucien, P.E, Manager Public/Private Development Unit

DATE: March 16, 2021

RE: Woburn Fire Station Headquarters – ENF (EEA #16333)

The Public/Private Development Unit (PPDU) has reviewed the Environmental Notification Form (ENF) for the proposed Woburn Fire Station Headquarters project in Woburn. The project site consists of approximately 3.16 acres within the City-owned Forest Park. The project is located at 731 Main Street and is bounded by residential development along Fisher Terrace to the north, the remainder of Forest Park to the east, residential development to the south, and Main Street (Route 38) to the west. The site is currently undeveloped and used as a park. There is a gated emergency access point to the park and a trail head located on the project site.

The project consists of constructing a 27,000-square foot (sf) Fire Station Headquarters and a 6,800-sf maintenance building for repair of firefighting vehicles and equipment, for a total of 33,800 sf of development. The project will include 47 parking spaces and is expected to generate 122 vehicle trips per day. Although it is not described in the ENF, the Proponent confirmed that the trip generation is based on anticipated employee shifts and employment levels provided by the Fire Department. Access will be provided via three driveways that connect to Route 38.

The project land conversion exceeds the Massachusetts Environmental Policy Act (MEPA) ENF land threshold. The project requires a Vehicular Access Permit from MassDOT because it abuts and would be accessed from Route 38, which is a State Highway. The ENF does not include a Transportation Impact Assessment (TIA), but the ENF adequately discusses the transportation impacts of the project. MassDOT notes that the Transportation Section (page 22) of the ENF incorrectly indicates that the project does not require an Access Permit; however, as is clearly stated in other sections of the ENF, the project requires an Access Permit.

Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot

Woburn Fire Station Headquarters Page 2 3/16/2021

Multimodal Access and Improvements

The project trip generation will not significantly impact the surrounding transportation network. Two traffic poles and one red light traffic signal are proposed to be added along Route 38, at the signalized with Middlesex Canal Road, to ensure safe entrance and exit from the site by fire vehicles. The existing trail head to walking trails within Forest Park will be retained and improved. The trail will be accessed from the rear of the Fire Station parking lot, where trail users may park, or via a walkway between the sidewalk along Route 38 and the trail head. MassDOT asks that on the east side of Route 38, along the project frontage, the Proponent reconstruct the sidewalk according to the most current MassDOT standards. The parking lot will also include electric vehicle charging stations.

MassDOT recommends that no further environmental review be required based on transportation-related issues. The Proponent should continue consultation with the City of Woburn and appropriate MassDOT units, including PPDU and the District 4 Office. If you have any questions regarding these comments, please contact me or Catrina Meyer at [email protected].

March 16, 2021

Eva Murray Environmental Analyst, MEPA Office Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 [email protected]

Re: Woburn Fire Headquarters, EEA #16333

Dear Ms. Murray,

The Mystic River Watershed Association (MyRWA) appreciates the opportunity to submit comments on the Woburn Fire Headquarters planned to be constructed from land in Forest Park in Woburn.

MyRWA was founded in 1972 to protect and restore the Mystic River, its tributaries and watershed lands for the benefit of present and future generations and to celebrate the value, importance, and great beauty of these natural resources. As part of this work, our organization has a powerful focus on climate resiliency and the acute risks of increased flooding and other impacts as climate disruption manifests in our communities.

While we very much appreciate the need for Woburn to continue to improve the infrastructure needed for public safety in Woburn, we have concerns about the plans for the site and the design standards for stormwater management.

Our first concern is that the plans for the site involve the deforestation of almost 3 acres of forested lands. Forested canopy is in rare supply in Woburn and plays an important role in regulating temperature in a future climate. In addition, naturally vegetated land has great capacity to sequester carbon from the atmosphere into biomass and then into soils, and thus reduce the impact of climate change. Forests and wetlands are particularly significant in this regard. When naturally vegetated land is disturbed or converted to developed use, significant amounts of carbon are released from living biomass and from soils, thus exacerbating and accelerating the warming of our climate. In addition to this loss of stored carbon (often referred to as carbon stocks), conversion of naturally vegetated land to developed land can greatly reduce or eliminate the future capacity of the land to sequester carbon. The land swap that occurred under Ch. 97 is for a parcel of open space that does not have trees, and as such is not an equivalent exchange of an environmental resource. We feel that deforesting this site causes a significant environmental impact that is not offset by the land swap and as such should be mitigated. We request that the Secretary apply conditions that appropriately mitigate the loss of this important natural resource.

MysticRiver.org | 20 Academy Street, Suite 306 | Arlington, MA 02476-6401 | (781) 316-3438

Our second concern is the data used to establish the design standards for the stormwater management system. We request that the City of Woburn reference the rainfall depth, duration, and frequency from the U.S. National Oceanic and Atmospheric Administration (NOAA) Atlas 14 to properly size the stormwater management on the site.

Thank you again for the opportunity to comment on this important infrastructure project.

Sincerely,

Patrick Herron Executive Director, Mystic River Watershed Association

MysticRiver.org | 20 Academy Street, Suite 306 Arlington, MA 02476-6401 | (781) 316-3438