Massachusetts Department Of Transportation Highway Division Proposal No. 607560-106915

DOCUMENT A00860

MASSACHUSETTS

DEPARTMENT OF ENVIRONMENTAL PROTECTION

NOTICE OF INTENT

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THIS PAGE INTENTIONALLY LEEFT BLANK

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Notice of Intent Stormwater Improvements and the I-391 Resurfacing Project

Chicopee, Massachusetts

Prepared for: Massachusetts Department of Transportation

10 Park Plaza Boston, MA 02116

Prepared by:

July 2018

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July 19, 2018

Chicopee Conservation Commission 274 Front Street Fourth Floor, City Hall Annex Chicopee, MA 01013

Subject: Notice of Intent Application Connecticut River Stormwater Improvements and the I-391 Resurfacing Project Chicopee, Massachusetts

Dear Commission members,

On behalf of the Massachusetts Department of Transportation (MassDOT) - Highway Division, AECOM respectfully submits nine copies (including one original and eight copies) of this Notice of Intent (NOI) for proposed stormwater improvements for review under the Massachusetts Wetlands Protection Act (WPA) and Implementing Regulations.

Improvements to existing stormwater management systems are proposed to be located adjacent to I-391 south on- and off-ramps at the I-391/Grattan Street (Rt. 141) Interchange (Exit 4) and at the on- and off-ramps at Exit 2 in Chicopee. The stormwater retrofits are part of the MassDOT Impaired Waters Program aimed at mitigating stormwater discharges to waterbodies through targeted upgrades to stormwater systems and installations of stormwater Best Management Practices (BMPs). The purpose of the stormwater retrofits is to improve water quality within the Connecticut River Watershed.

I-391 resurfacing work consisting of repaving and resurfacing of the roadway from Main Street in Holyoke to the I-391/Rt. 116 Interchange (Exit 2) on-ramp to I-391 north in Chicopee is also planned. This work is exempt from the WPA, as discussed in the attached narrative.

While six of the proposed stormwater BMP sites are located within the town of Chicopee, only one site (BMP #6) is located within an area subject to protection under the WPA (100-foot Buffer Zone). The construction of the proposed stormwater BMP will provide treatment of stormwater and attenuate flows prior to discharging to the Connecticut River. Project impacts have been minimized to the maximum extent practicable and no wetlands will be directly impacted from the proposed project activities.

Details of the construction activities are provided in the attached application and figures. Please advertise this matter and place it on the agenda for the August 15, 2018 Conservation Commission hearing. Enclosed with the NOI is a check made payable to the Town of Chicopee for $200.00 for the advertising fee and a check for the town share of the filing fee of $262.50. A check for the state filing fee for the amount of $237.50 has been sent to the Commonwealth of Massachusetts lockbox. We look forward to meeting with the Conservation Commission to discuss the proposed project at the hearing. If you have any questions, please do not hesitate to contact me at (978) 905-3219 or Jennifer Doyle-Breen, AECOM Associate Vice President, at (978) 905-2968.

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Sincerely,

Tom Touchet Sr. Wetland Scientist, PWS [email protected]

Enclosures cc: MA DEP – Western Region (1 copy) MA NHESP (1 copy) B. Cordeiro, Massachusetts Department of Transportation (1 copy) J. Doyle-Breen, AECOM (1 copy) File (1 copy)

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Table of Contents

• WPA Form 3 – Notice of Intent

• Project Narrative

1.0 Introduction ...... 1

2.0 Exempt Resurfacing Activities ...... 2

3.0 Existing Conditions Near the BMP Work Areas ...... 3 3.1 BMP #6 ...... 3 3.2 BMP #7 ...... 4

4.0 Proposed Stormwater Improvements within WPA Jurisdictional Areas ...... 4

5.0 Regulated Area Impacts ...... 6 5.1 100-Foot Buffer Zone ...... 6 5.2 NHESP/ Protection of Rare Species ...... 6 5.3 Compliance with Massachusetts Stormwater Policy...... 6

6.0 Mitigation ...... 7 6.1 Erosion and Sediment Controls ...... 7

7.0 Summary ...... 8

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List of Attachments

Attachment A USGS Locus Map and Environmental Constraints

Attachment B Site Photographs

Attachment C Project Plans

BMP 6 - CONSTRUCTION PLAN Sheet #9 of 32 Date: 1/8/2018 BMP 6 & BMP 7 - PROFILES AND SECTIONS Sheet #11 of 34 Date: 1/8/2018 BMP 6 - LANDSCAPE PLAN Sheet #25 of 34 Date: 1/8/2018 LANDSCAPE DETAILS I Sheet #28 of 34 Date: 1/8/2018 LANDSCAPE DETAILS II Sheet #29 of 34 Date: 1/8/2018 CONSTRUCTION DETAILS I Sheet #30 of 34 Date: 1/8/2018 CONSTRUCTION DETAILS III Sheet #32 of 34 Date: 1/8/2018 CONSTRUCTION DETAILS IV Sheet#33 of 34 Date: 1/8/2018 CONSTRUCTION DETAILS V Sheet#34 of 34 Date: 1/8/2018

Attachment D Stormwater Checklist and Report

Attachment E Wetland Data Sheets

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WPA Form 3 – Notice of Intent

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town Important: When filling out A. General Information forms on the computer, use 1. Project Location (Note: electronic filers will click on button to locate project site): only the tab key to move your Multiple (see Project Description) Chicopee 01013 cursor - do not a. Street Address b. City/Town c. Zip Code use the return key. 42.181613 N 72.606971 W Latitude and Longitude: d. Latitude e. Longitude SHLO Right of Way N/A (highway layout) f. Assessors Map/Plat Number g. Parcel /Lot Number 2. Applicant:

Susan McArthur a. First Name b. Last Name Note: Massachusetts Department of Transportation - Highway Division Before c. Organization completing this form consult 10 Park Plaza, Room 4260 your local d. Street Address Conservation Boston MA 02116 Commission e. City/Town f. State g. Zip Code regarding any municipal bylaw (857) 368-8807 (857) 368-0609 [email protected] or ordinance. h. Phone Number i. Fax Number j. Email Address 3. Property owner (required if different from applicant): Check if more than one owner

a. First Name b. Last Name Massachusetts Department of Transportation - Highway Division c. Organization 10 Park Plaza d. Street Address Boston MA 02116 e. City/Town f. State g. Zip Code (857) 368-8807 (857) 368-0609 h. Phone Number i. Fax Number j. Email address

4. Representative (if any): Tom Touchet a. First Name b. Last Name AECOM c. Company 250 Apollo Drive d. Street Address Chelmsford MA 01824 e. City/Town f. State g. Zip Code (978) 905-3219 (978) 905-2101 [email protected] h. Phone Number i. Fax Number j. Email address

5. Total WPA Fee Paid (from NOI Wetland Fee Transmittal Form):

$ 500.00 $237.50 $262.50 a. Total Fee Paid b. State Fee Paid c. City/Town Fee Paid

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town A. General Information (continued)

6. General Project Description: The proposed project consists of retrofitting an existing stormwater management system adjacent to I-391 as well as repaving and resurfacing I-391 in Chicopee. The repaving and resurfacing is an exempt activity.

7a. Project Type Checklist: (Limited Project Types see Section A. 7b.)

1. Single Family Home 2. Residential Subdivision

3. Commercial/Industrial 4. Dock/Pier

5. Utilities 6. Coastal engineering Structure

7. Agriculture (e.g., cranberries, forestry) 8. Transportation

9. Other 7b. Is any portion of the proposed activity eligible to be treated as a limited project (including Ecological

Restoration Limited Project) subject to 310 CMR 10.24 (coastal) or 310 CMR 10.53 (inland)? If yes, describe which limited project applies to this project. (See 310 CMR 1. Yes No 10.24 and 10.53 for a complete list and description of limited project types)

2. Limited Project Type

If the proposed activity is eligible to be treated as an Ecological Restoration Limited Project (310 CMR10.24(8), 310 CMR 10.53(4)), complete and attach Appendix A: Ecological Restoration Limited Project Checklist and Signed Certification.

8. Property recorded at the Registry of Deeds for: Hampden a. County b. Certificate # (if registered land) 4711 122 c. Book d. Page Number

B. Buffer Zone & Resource Area Impacts (temporary & permanent)

1. Buffer Zone Only – Check if the project is located only in the Buffer Zone of a Bordering

Vegetated Wetland, Inland Bank, or Coastal Resource Area. 2. Inland Resource Areas (see 310 CMR 10.54-10.58; if not applicable, go to Section B.3,

Coastal Resource Areas). Check all that apply below. Attach narrative and any supporting documentation describing how the project will meet all performance standards for each of the resource areas altered, including standards requiring consideration of alternative project design or location.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town

B. Buffer Zone & Resource Area Impacts (temporary & permanent) (cont’d)

Resource Area Size of Proposed Alteration Proposed Replacement (if any)

a. Bank 1. linear feet 2. linear feet For all projects affecting other b. Bordering Vegetated Resource Areas, Wetland 1. square feet 2. square feet please attach a narrative c. Land Under 1. square feet 2. square feet explaining how Waterbodies and the resource Waterways area was 3. cubic yards dredged delineated. Resource Area Size of Proposed Alteration Proposed Replacement (if any)

d. Bordering Land Subject to Flooding 1. square feet 2. square feet

3. cubic feet of flood storage lost 4. cubic feet replaced e. Isolated Land

Subject to Flooding 1. square feet

2. cubic feet of flood storage lost 3. cubic feet replaced

f. Riverfront Area 1. Name of Waterway (if available) - specify coastal or inland

2. Width of Riverfront Area (check one):

25 ft. - Designated Densely Developed Areas only

100 ft. - New agricultural projects only

200 ft. - All other projects

3. Total area of Riverfront Area on the site of the proposed project: square feet

4. Proposed alteration of the Riverfront Area:

a. total square feet b. square feet within 100 ft. c. square feet between 100 ft. and 200 ft.

5. Has an alternatives analysis been done and is it attached to this NOI? Yes No

6. Was the lot where the activity is proposed created prior to August 1, 1996? Yes No

3. Coastal Resource Areas: (See 310 CMR 10.25-10.35)

Note: for coastal riverfront areas, please complete Section B.2.f. above.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town B. Buffer Zone & Resource Area Impacts (temporary & permanent) (cont’d)

Check all that apply below. Attach narrative and supporting documentation describing how the project will meet all performance standards for each of the resource areas altered, including

standards requiring consideration of alternative project design or location.

Online Users: Include your Resource Area Size of Proposed Alteration Proposed Replacement (if any) document transaction a. Designated Port Areas Indicate size under Land Under the Ocean, below number (provided on your receipt page) b. Land Under the Ocean 1. square feet with all supplementary information you 2. cubic yards dredged submit to the Department. c. Barrier Beach Indicate size under Coastal Beaches and/or Coastal Dunes below

d. Coastal Beaches 1. square feet 2. cubic yards beach nourishment

e. Coastal Dunes 1. square feet 2. cubic yards dune nourishment

Size of Proposed Alteration Proposed Replacement (if any)

f. Coastal Banks 1. linear feet g. Rocky Intertidal

Shores 1. square feet

h. Salt Marshes 1. square feet 2. sq ft restoration, rehab., creation i. Land Under Salt

Ponds 1. square feet

2. cubic yards dredged j. Land Containing

Shellfish 1. square feet

k. Fish Runs Indicate size under Coastal Banks, inland Bank, Land Under the Ocean, and/or inland Land Under Waterbodies and Waterways, above

1. cubic yards dredged l. Land Subject to

Coastal Storm Flowage 1. square feet 4. Restoration/Enhancement

If the project is for the purpose of restoring or enhancing a wetland resource area in addition to the square footage that has been entered in Section B.2.b or B.3.h above, please enter the additional

amount here.

a. square feet of BVW b. square feet of Salt Marsh

5. Project Involves Stream Crossings

a. number of new stream crossings b. number of replacement stream crossings

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town C. Other Applicable Standards and Requirements

This is a proposal for an Ecological Restoration Limited Project. Skip Section C and complete Appendix A: Ecological Restoration Limited Project Checklists – Required Actions (310 CMR 10.11).

Streamlined Massachusetts Endangered Species Act/Wetlands Protection Act Review

1. Is any portion of the proposed project located in Estimated Habitat of Rare Wildlife as indicated on the most recent Estimated Habitat Map of State-Listed Rare Wetland Wildlife published by the

Natural Heritage and Endangered Species Program (NHESP)? To view habitat maps, see the Massachusetts Natural Heritage Atlas or go to

http://maps.massgis.state.ma.us/PRI_EST_HAB/viewer.htm. If yes, include proof of mailing or hand delivery of NOI to: a. Yes No*

Natural Heritage and Endangered Species Program Division of Fisheries and Wildlife 8/17 1 Rabbit Hill Road Westborough, MA 01581 b. Date of map

*NOTE: The subject of this NOI (BMP#6) is not located within mapped Estimated Habitat (EH). However, MassDOT is coordinating with NHESP regarding the WPA-exempt resurfacing activities in EH and they will receive a courtesy copy of this NOI. If yes, the project is also subject to Massachusetts Endangered Species Act (MESA) review (321 CMR 10.18). To qualify for a streamlined, 30-day, MESA/Wetlands Protection Act review, please complete Section C.1.c, and include requested materials with this Notice of Intent (NOI); OR complete Section C.2.f, if applicable. If MESA supplemental information is not included with the NOI, by completing Section 1 of this form, the NHESP will require a separate MESA filing which may take up to 90 days to review (unless noted exceptions in Section 2 apply, see below).

∗ c. Submit Supplemental Information for Endangered Species Review

1. Percentage/acreage of property to be altered:

(a) within wetland Resource Area percentage/acreage

(b) outside Resource Area percentage/acreage

2. Assessor’s Map or right-of-way plan of site

2. Project plans for entire project site, including wetland resource areas and areas outside of wetlands jurisdiction, showing existing and proposed conditions, existing and proposed

tree/vegetation clearing line, and clearly demarcated limits of work ∗∗

(a) Project description (including description of impacts outside of wetland resource area & buffer zone)

(b) Photographs representative of the site

∗ Some projects not in Estimated Habitat may be located in Priority Habitat, and require NHESP review (see http://www.mass.gov/eea/agencies/dfg/dfw/natural-heritage/regulatory-review/). Priority Habitat includes habitat for state-listed plants and strictly upland species not protected by the Wetlands Protection Act. ∗∗ MESA projects may not be segmented (321 CMR 10.16). The applicant must disclose full development plans even if such plans are not required as part of the Notice of Intent process.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town C. Other Applicable Standards and Requirements (cont’d)

(c) MESA filing fee (fee information available at http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/mesa/mesa_fee_schedule.htm). Make check payable to “Commonwealth of Massachusetts - NHESP” and mail to NHESP at above address

Projects altering 10 or more acres of land, also submit:

(d) Vegetation cover type map of site

(e) Project plans showing Priority & Estimated Habitat boundaries

(f) OR Check One of the Following

1. Project is exempt from MESA review. Attach applicant letter indicating which MESA exemption applies. (See 321 CMR 10.14,

http://www.mass.gov/dfwele/dfw/nhesp/regulatory_review/mesa/mesa_exemptions.htm; the NOI must still be sent to NHESP if the project is within estimated habitat pursuant to

310 CMR 10.37 and 10.59.)

2. Separate MESA review ongoing. a. NHESP Tracking # b. Date submitted to NHESP

3. Separate MESA review completed. Include copy of NHESP “no Take” determination or valid Conservation & Management

Permit with approved plan. 3. For coastal projects only, is any portion of the proposed project located below the mean high water line or in a fish run?

a. Not applicable – project is in inland resource area only b. Yes No

If yes, include proof of mailing, hand delivery, or electronic delivery of NOI to either:

South Shore - Cohasset to Rhode Island border, and North Shore - Hull to New Hampshire border: the Cape & Islands:

Division of Marine Fisheries - Division of Marine Fisheries - Southeast Marine Fisheries Station North Shore Office Attn: Environmental Reviewer Attn: Environmental Reviewer 836 South Rodney French Blvd. 30 Emerson Avenue New Bedford, MA 02744 Gloucester, MA 01930 Email: [email protected] Email: [email protected]

Also if yes, the project may require a Chapter 91 license. For coastal towns in the Northeast Region, please contact MassDEP’s Boston Office. For coastal towns in the Southeast Region, please contact MassDEP’s Southeast Regional Office.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town

C. Other Applicable Standards and Requirements (cont’d)

4. Is any portion of the proposed project within an Area of Critical Environmental Concern (ACEC)? If yes, provide name of ACEC (see instructions to WPA Form 3 or MassDEP Online Users: a. Yes No Include your Website for ACEC locations). Note: electronic filers click on Website. document transaction b. ACEC number (provided on your 5. Is any portion of the proposed project within an area designated as an Outstanding Resource Water receipt page) (ORW) as designated in the Massachusetts Surface Water Quality Standards, 314 CMR 4.00? with all supplementary a. Yes No information you submit to the 6. Is any portion of the site subject to a Wetlands Restriction Order under the Inland Wetlands Department. Restriction Act (M.G.L. c. 131, § 40A) or the Coastal Wetlands Restriction Act (M.G.L. c. 130, § 105)?

a. Yes No

7. Is this project subject to provisions of the MassDEP Stormwater Management Standards?

a. Yes. Attach a copy of the Stormwater Report as required by the Stormwater Management

Standards per 310 CMR 10.05(6)(k)-(q) and check if: 1. Applying for Low Impact Development (LID) site design credits (as described in

Stormwater Management Handbook Vol. 2, Chapter 3)

2. A portion of the site constitutes redevelopment

3. Proprietary BMPs are included in the Stormwater Management System.

b. No. Check why the project is exempt:

1. Single-family house

2. Emergency road repair

3. Small Residential Subdivision (less than or equal to 4 single-family houses or less than

or equal to 4 units in multi-family housing project) with no discharge to Critical Areas. D. Additional Information

This is a proposal for an Ecological Restoration Limited Project. Skip Section D and complete Appendix A: Ecological Restoration Notice of Intent – Minimum Required Documents (310 CMR 10.12).

Applicants must include the following with this Notice of Intent (NOI). See instructions for details. Online Users: Attach the document transaction number (provided on your receipt page) for any of

the following information you submit to the Department.

1. USGS or other map of the area (along with a narrative description, if necessary) containing sufficient information for the Conservation Commission and the Department to locate the site. (Electronic filers may omit this item.)

2. Plans identifying the location of proposed activities (including activities proposed to serve as a Bordering Vegetated Wetland [BVW] replication area or other mitigating measure) relative to the boundaries of each affected resource area.

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Massachusetts Department of Environmental Protection Provided by MassDEP:

Bureau of Resource Protection - Wetlands MassDEP File Number – Notice of Intent WPA Form 3 Document Transaction Number Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 Chicopee City/Town D. Additional Information (cont’d)

3. Identify the method for BVW and other resource area boundary delineations (MassDEP BVW Field Data Form(s), Determination of Applicability, Order of Resource Area Delineation, etc.), and attach documentation of the methodology.

4. List the titles and dates for all plans and other materials submitted with this NOI. Please see attached list of plans in the Table of Contents a. Plan Title AECOM b. Prepared By c. Signed and Stamped by Varies Varies d. Final Revision Date e. Scale

f. Additional Plan or Document Title g. Date 5. If there is more than one property owner, please attach a list of these property owners not

listed on this form.

6. Attach proof of mailing for Natural Heritage and Endangered Species Program, if needed.

7. Attach proof of mailing for Massachusetts Division of Marine Fisheries, if needed.

8. Attach NOI Wetland Fee Transmittal Form

9. Attach Stormwater Report, if needed.

E. Fees

1. Fee Exempt: No filing fee shall be assessed for projects of any city, town, county, or district of the Commonwealth, federally recognized Indian tribe housing authority, municipal housing authority, or the Massachusetts Bay Transportation Authority.

Applicants must submit the following information (in addition to pages 1 and 2 of the NOI Wetland Fee Transmittal Form) to confirm fee payment: 14484778 July 3, 2018 2. Municipal Check Number 3. Check date 14484793 July 3, 2018 4. State Check Number 5. Check date AECOM Technology Corporation 6. Payor name on check: First Name 7. Payor name on check: Last Name

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Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands NOI Wetland Fee Transmittal Form Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

Important: When A. Applicant Information filling out forms on the computer, 1. Location of Project: use only the tab key to move your Multiple locations along I-391 Chicopee cursor - do not a. Street Address b. City/Town use the return key. 14484793 $237.50 c. Check number d. Fee amount

2. Applicant Mailing Address: Susan McArthur a. First Name b. Last Name Massachusetts Department of Transportation - Highway Division

c. Organization 10 Park Plaza, Room 4260 d. Mailing Address Boston MA 02116 e. City/Town f. State g. Zip Code (857) 368-8807 (857) 368-0609 [email protected] h. Phone Number i. Fax Number j. Email Address

3. Property Owner (if different):

a. First Name b. Last Name Massachusetts Department of Transportation - Highway Division c. Organization 10 Park Plaza d. Mailing Address Boston MA 02116 e. City/Town f. State g. Zip Code (857) 368-8807 (857) 368-0609 h. Phone Number i. Fax Number j. Email Address To calculate filing fees, refer B. Fees to the category fee list and Fee should be calculated using the following process & worksheet. Please see Instructions before examples in the filling out worksheet. instructions for filling out WPA Step 1/Type of Activity: Describe each type of activity that will occur in wetland resource area and buffer zone. Form 3 (Notice of Intent). Step 2/Number of Activities: Identify the number of each type of activity.

Step 3/Individual Activity Fee: Identify each activity fee from the six project categories listed in the instructions.

Step 4/Subtotal Activity Fee: Multiply the number of activities (identified in Step 2) times the fee per category (identified in Step 3) to reach a subtotal fee amount. Note: If any of these activities are in a Riverfront Area in addition to another Resource Area or the Buffer Zone, the fee per activity should be multiplied by 1.5 and then added to the subtotal amount.

Step 5/Total Project Fee: Determine the total project fee by adding the subtotal amounts from Step 4.

Step 6/Fee Payments: To calculate the state share of the fee, divide the total fee in half and subtract $12.50. To calculate the city/town share of the fee, divide the total fee in half and add $12.50.

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Massachusetts Department of Environmental Protection Bureau of Resource Protection - Wetlands NOI Wetland Fee Transmittal Form Massachusetts Wetlands Protection Act M.G.L. c. 131, §40

B. Fees (continued) Step 1/Type of Activity Step 2/Number Step Step 4/Subtotal Activity of Activities 3/Individual Fee Activity Fee

2 j. Other 1 $500.00 $500.00

Step 5/Total Project Fee: $500.00

Step 6/Fee Payments: $500.00 Total Project Fee: a. Total Fee from Step 5 $237.50 State share of filing Fee: b. 1/2 Total Fee less $12.50 $262.50 City/Town share of filling Fee: c. 1/2 Total Fee plus $12.50 C. Submittal Requirements

a.) Complete pages 1 and 2 and send with a check or money order for the state share of the fee, payable to the Commonwealth of Massachusetts.

Department of Environmental Protection Box 4062 Boston, MA 02211

b.) To the Conservation Commission: Send the Notice of Intent or Abbreviated Notice of Intent; a copy of this form; and the city/town fee payment.

To MassDEP Regional Office (see Instructions): Send a copy of the Notice of Intent or Abbreviated Notice of Intent; a copy of this form; and a copy of the state fee payment. (E-filers of Notices of Intent may submit these electronically.)

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Project Narrative

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1.0 Introduction

On behalf of the Massachusetts Department of Transportation – Highway Division (MassDOT), AECOM is submitting this Notice of Intent application (NOI) for the Connecticut River Stormwater BMP and I-391 Resurfacing Project, pursuant to the Massachusetts Wetlands Protection Act (WPA; MGL Ch. 131 s. 40) and its implementing regulations (310 CMR 10.00). Abutter notification is not required for projects proposed by MassDOT pursuant to Chapter 472 of the Acts of 1993 as approved on January 13, 1994. The location and extent of the work areas is shown in the figures in Attachment A.

The Connecticut River BMP and I-391 Resurfacing Project is being completed to maintain the condition of the Interstate 391 roadway and improve the quality of the stormwater runoff to the Connecticut River. The roadway resurfacing work is important to maintain a safe condition for the travelers utilizing this roadway. The planned resurfacing work consists of resurfacing and repaving I-391 from the Connecticut River bridge (Holyoke/Chicopee town line at mile marker 4.5) near the project’s northern end to the I-391/Route 116 Interchange (Exit 2) in Chicopee at the project’s southern end (mile marker 0.8) for a total resurfacing/repaving distance of 3.7 miles within Chicopee. These resurfacing and repaving activities are exempt from the MA Wetlands Protection Act (WPA) as described further below.

Work within Chicopee also includes improvements to existing stormwater management systems located adjacent to I-391 south on- and off-ramps at the I-391/Grattan Street (Route 141) Interchange (Exit 4) and at the on- and off-ramps at Exit 2 in Chicopee. The stormwater retrofit work is part of the MassDOT Impaired Waters Program aimed at mitigating stormwater discharges to waterbodies through targeted upgrades to stormwater systems and installations of stormwater BMPs. The purpose of the BMP work is to improve water quality within the Connecticut River Watershed. The BMP work will include construction of vegetated water quality swales and infiltration and exfiltrating bioinfiltration basins. The construction of the proposed stormwater BMPs will provide treatment of stormwater and attenuate flows prior to discharging to the Connecticut River. The nearby river segment that this area drains to (MA34-05 of the Connecticut River) is currently impaired for Escherichia coli, PCB in fish tissue, and total suspended solids (TSS). It has been determined that direct discharge of untreated stormwater from MassDOT roadways contributes to the impairment of this river segment. The capture and treatment of this stormwater will have the same efficacy as removing a portion of the impervious surface contributing stormwater to the project area. The construction of the proposed stormwater BMPs will provide treatment of stormwater and attenuate flows prior to discharging to the Connecticut River. The proposed stormwater BMPs located within Chicopee are in the vicinity of I-391, on the east side of the Connecticut River. One BMP is located within 100 feet of a wetland. Additional BMPs and /or resurfacing are planned for Holyoke, West Springfield, and Agawam.

Project component exemptions and additional jurisdictional details are discussed further below.

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2.0 Exempt Resurfacing Activities

Resurfacing activities along I-391 are proposed to improve and maintain the condition of the roadway for driver accessibility and safety. The resurfacing work in Chicopee extends along I-391 from just south of the intersection with Route 116 to the Connecticut River Bridge that crosses to Holyoke. These activities include: full width micromill and overlay; replacing scored concrete pavement at gores with milled rumble strips and other rumble strip work; placing final pavement markings and slotted pavement markers; cleaning, replacing, and securing catch basin grids and manhole covers as needed; removing and resetting of granite edging as needed; upgrading selected existing guardrails; selected pedestrian ramp and sidewalk construction/reconstruction; replacement of traffic data collection stations; traffic management; and other incidental items. The extent of these improvements in Chicopee is shown in the locus figure and in Figures 3 through 5 in Attachment A. All of the resurfacing work will be located within existing paved roadways.

Although a portion of resurfacing activities will be located within the 100-Foot Buffer Zone, these activities solely within Buffer Zone (beyond other resource areas such as Riverfront Area) are not otherwise subject to regulation under M.G.L. c. 131, § 40 as indicated in 310 CMR 10.02(2)(b)1 provided that the work (as prescribed in 310 CMR 10.02(2)(b)2.a. through q) is performed “in a manner so as to reduce the potential for any adverse impacts to the resource area during construction, and with post-construction measures implemented to stabilize any disturbed areas”. 310 CMR 10.02(2)(b)2.p includes: “Pavement repair, resurfacing, and reclamation of existing roadways within the right-of-way configuration provided that the roadway and shoulders are not widened, no staging or stockpiling of materials, all disturbed road shoulders are stabilized within 72 hours of completion of the resurfacing or reclamation, and no work on the drainage system is performed, other than adjustments and/or repairs to respective structures within the roadway”.

A portion of resurfacing activities located in the vicinity of the Chicopee and Connecticut River bridges and a perennial stream crossing will occur within Riverfront Area. However, according to 310 CMR 10.58(6), maintenance of roads (limited to repairs, resurfacing, repaving, but not enlargement) in existence on August 7, 1996 within Riverfront Area is allowed without the filing of a Notice of Intent, but not when such work is within other resource areas or their buffer zones except as provided in 310 CMR 10.58(6)(b). 310 CMR 10.58(6)(b) includes certain minor activities as identified in 310 CMR 10.02(2)(b)1. 310 CMR 10.02(2)(b)1 references minor activities as described in 310 CMR 10.02(2)(b)2. 310 CMR 10.02(2)(b)2p includes “Pavement repair, resurfacing, and reclamation of existing roadways within the right-of-way configuration provided that the roadway and shoulders are not widened, no staging or stockpiling of materials, all disturbed road shoulders are stabilized within 72 hours of completion of the resurfacing or reclamation, and no work on the drainage system is performed, other than adjustments and/or repairs to respective structures within the roadway”. Therefore, the proposed resurfacing work within Riverfront Area is exempt from the WPA.

None of the resurfacing work is located in any other MA WPA resource areas. The resurfacing work is located in MA NHESP mapped habitat. MassDOT is currently

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separately consulting with MA NHESP regarding protected habitat, however a copy of this NOI is being provided to NHESP as a courtesy.

3.0 Existing Conditions Near the BMP Work Areas

The stormwater improvement portions of the project area contained in Chicopee are comprised of eleven proposed BMP sites (BMP #s 3, 6, 7, 10, 12, 14, 17, 18, 19, 23A, and 23B) (see Attachment A - Figure 1, Locus Map for locations). BMP #s 3, 6 and 7 are located in the vicinity of the I-391/Route 141 Interchange (Exit 4). BMP #s 10, 12 and 14 are located in the vicinity of the I-391/Route 116 Interchange (Exit 2). BMP #s 17, 18, 19, 23A, and 23B are located in the vicinity of the I-391/ I-91 interchange. BMP#s 3, 10, 12, 14, 17, 18, 19, 23A, and 23B are located outside the jurisdiction of the WPA and are not discussed further below. Wetland resource areas in the vicinity of the proposed stormwater BMP #s 6 and 7 are shown in Attachment A Figure 1.

Wetland resources were further defined via field delineation in the immediate vicinity of the proposed activities for BMP #6 and #7 because of their proximity to these resources. Bordering Vegetated Wetland (BVW) boundaries were delineated in accordance with the Massachusetts Wetlands Protection Act regulations (310 CMR 10.00) and MassDEP’s publication entitled “Delineating Bordering Vegetated Wetlands under the Massachusetts Wetlands Protection Act.”

3.1 BMP #6 BMP #6 is a proposed exfiltrating bioinfiltration basin with total limits of work of approximately 0.27 acres (11,760 SF). This BMP would be located within the area enclosed by I-391 southbound to the south and east and the I-391 on- and off-ramps to/from Route 141 to the west and north, respectively. The existing vegetation in the area proposed for BMP #6 is primarily comprised of a variety of grasses, with an existing concrete drainage swale running generally north-south through the limits of work, and a border of trees and shrubs along the western side of the limits of work. The limits of work for BMP #6 are shown in Attachment A, Figure 2.

A BVW located adjacent to the proposed BMP #6 was demarcated in the field with wetland flag series “S6-A” (Attachment A – Figure 2; Attachment C-Sheet #9). The intermittent stream and drainage that flow into this wetland supply it with water. The intermittent stream emerges from a headwall at the southeast extent of the wetland and flows to another headwall at the northwestern extent of the BVW. It is joined by two concrete swales that are connected to nearby stormwater collection systems. These swales convey runoff to the BVW. This wetland is dominated by common reed (Phragmites australis) and reed canary grass (Phalaris arundinacea) and includes some Graminae spp. (roadside fescues and other grasses) and sensitive fern (Onoclea sensibilis). Vegetation within the adjacent upland of this BVW includes assorted grasses, with trees and shrubs located just outside of the western extents of the BVW area. The 100-foot Buffer Zone extends from BVW “S6” onto the northern portion of the BMP #6 limits of work.

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3.2 BMP #7 BMP #7 is a proposed exfiltrating bioinfiltration basin with total limits of work of approximately 0.47 acres (20,470 SF). The area where BMP #7 limits of work are proposed is located within the northwestern corner of the infield area of the I-391 SB off-ramp to Route 141. This area is primarily comprised of grass, with woody shrubs and trees located in the northwestern portion of the limits of work and along the northeastern boundary. Existing concrete drainage structures direct highway stormwater runoff to a stream and associated wetland southwest of the limits of work.

A BVW associated with an intermittent stream located to the southwest of BMP #7 was demarcated in the field with wetland flag series “WL1-100 through WL1-101” and “WL1-201 through WL1-207” (Attachment A). The intermittent stream, which flows south to north through a culvert, was demarcated in the field with stream flag series “S1-100 through S1- 104”. The stream enters the wetland through a culvert near S1-100 and loses definition through the wetland. Toward the downstream end of the wetland, the stream collects in a concrete swale and exits the study area via another culvert. The wetland is dominated by common reed (Phragmites australis) and includes common jewelweed (Impatiens capensis) and sensitive fern (Onoclea sensibilis). Vegetation within the adjacent upland of this BVW includes crown vetch (Securigera varia) and American pokeweed (Phytolacca americana). The site is located outside of any areas subject to jurisdiction under the MA Wetlands Protection Act, including the 100-foot Buffer Zone (see Attachment A – Figure 2). As a result, BMP #7 is not further described below.

4.0 Proposed Stormwater Improvements within WPA Jurisdictional Areas

The only BMP located within a jurisdictional area under the WPA (and therefore the subject of this NOI) is BMP #6. The proposed BMP 6 is located within the grassy area enclosed by I-391 southbound to the south and east and the I-391 on- and off-ramps to/from Route 141 to the west and north, respectively. The proposed design for the BMP involves the removal of a portion of an existing concrete drainage swale. Stormwater runoff from the existing drainage system will then be redirected to a new sediment forebay prior to discharging to a new exfiltrating bioinfiltration basin. The purpose of this BMP system is to improve the quality of water discharged to receiving waters that ultimately drain to the Connecticut River located to the west of the project area and to control the water quality treatment volume. The exfiltrating bioinfiltration area is well suited for use at the proposed site. Overflow will be directed to an existing stormwater channel and wetland area located adjacent to BMP 6 (see Attachment C for further details).

Exfiltrating bioinfiltration cells (also called rain gardens in residential applications) are shallow depressions filled with sandy soil topped with a thick layer of mulch and planted with dense native vegetation. Stormwater runoff is directed into the cell via piped or sheet flow. The runoff percolates through the soil media that acts as a filter. Exfiltrating bioinfiltration areas can provide excellent pollutant removal for the “first flush” of

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stormwater runoff. Exfiltrating bioinfiltration areas remove pollutants through filtration, microbe activity, and uptake by plants; contact with soil and roots provides water quality treatment better than conventional infiltration structures.

Once the exfiltrating bioinfiltration basin construction has been completed, the stormwater BMP will be seeded with the sediment forebay and exfiltrating bioinfiltration basin seed mix depicted below. The planting schedule is designed to provide soil stabilization and reduce potential erosion (see landscape details in Attachment C). Areas disturbed for construction beyond the exfiltrating bioinfiltration basin will be seeded with an appropriate upland seed mix.

The BMP does not generate any new discharges to receiving waters or the Connecticut River. No new impervious surfaces are proposed and the volume of flow currently discharging to Connecticut River will not be increased.

Sediment Forebay and Exfiltrating Bioinfiltration Basin Seed Mix Percent by Weight Common/Scientific Name 25.00% Fox Sedge, PA Ecotype (Carex vulpinoidea, PA Ecotype) 25.00% Deertongue, ‘Tioga’ (Panicum clandestinum Dichanthelium c. ‘Tioga’) 20.00% Virginia Wildrye, PA Ecotype (Elymus virginicus, PA Ecotype) 20.00% Switchgrass, ‘Shawnee’ (Panicum rigatum, ‘Shawnee’) 5.00% Autumn Bentgrass, PA Ecotype (Agrostis perennans, PA Ecotype) 2.00% Ticklegrass (Rough Bentgrass), PA Ecotype (Agrostis scabra, PA Ecotype) 1.00% Soft Rush (Juncus effusus)

1.00% Path Rush, PA Ecotype (Juncus tenuis, PA Ecotype) 1.00% Green Bulrush, PA Ecotype (Scirpus atrovirens, PA Ecotype)

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5.0 Regulated Area Impacts

5.1 100-Foot Buffer Zone Construction activities at BMP #6 will result in approximately 6,960 square feet of disturbance to the 100-foot Buffer Zone (Attachment A - Figure 2). The existing impervious concrete drainage swales will be removed in the area. Two check dams will be added and the area will be regraded to create a sediment forebay and an exfiltrating bioinfiltration basin that will both serve to improve the water quality of the runoff entering into the wetland and stream. The removal of concrete and increased retention time will improve the infiltration function of the Buffer Zone.

5.2 NHESP/ Protection of Rare Species According to the MassGIS data layers, the stormwater BMPs are not within any mapped Area of Critical Environmental Concern (ACEC) and there are no Certified Vernal Pools within the project area. According to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Atlas and MassGIS datalayers (8/2017), no BMPs are proposed within Estimated or Priority Habitat.

5.3 Compliance with Massachusetts Stormwater Policy A Stormwater Report and Stormwater Checklist have been prepared and are attached to this narrative as Attachment D. The project has been designed and will be constructed and installed in accordance with the MA Stormwater Management Standards.

In addition, according to 310 CMR 10.04, the project qualifies as a “redevelopment” project. For purpose of the Stormwater Management Standards as provided in 310 CMR 10.05(6)(k) through (q), redevelopment is defined to include the following projects: (a) maintenance and improvement of existing roadways including widening less than a single lane, adding shoulders, correcting substandard intersections, improving existing drainage systems and repaving; (b) development, rehabilitation, expansion and phased projects on previously developed sites provided the redevelopment results in no net increase in impervious area; and (c) remedial projects specifically designed to provide improved stormwater management such as projects to separate storm drains and sanitary sewers and stormwater retrofit projects.

The project does not involve any new stormwater discharges to the Connecticut River or any other wetland resource area. No new impervious surfaces are proposed for the project. The volume of flow currently discharging to the Connecticut River would not be increased. In fact, the proposed BMP# 6 stormwater treatment system is designed to treat and infiltrate stormwater in place.

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6.0 Mitigation

6.1 Erosion and Sediment Controls An erosion and sedimentation control program will be implemented to minimize impacts to the adjacent BVW “S6” during the construction phase of the project. The program incorporates BMPs specified in guidelines developed by the DEP and presented in the Massachusetts Erosion and Sediment Control Guidelines for Urban and Suburban Areas: A Guide for Planners, Designers, and Municipal Officials (DEP, 1997) and U.S. Environmental Protection Agency (EPA) document, Interim Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites (Office of Water Report EPA 833-R-060-04, 2007).

Proper implementation of the erosion and sedimentation control program will:

1. Minimize exposed soil areas through sequencing and temporary stabilization; 2. Place structures to manage stormwater runoff and erosion; and 3. Establish a permanent vegetative cover for other forms of stabilization as soon as practicable.

Non-Structural Practices Non-structural practices to be used during construction include temporary stabilization, temporary seeding, permanent seeding, pavement sweeping (if necessary), and dust control. These practices will be initiated as practicable in appropriate areas at the site.

Temporary Stabilization Any areas of exposed soil or stockpiles that will remain inactive for more than 14 days will be covered with a layer of straw mulch.

Permanent Seeding Upon completion of final grading, any bare ground outside of the infiltration basins and within the limits of work will be seeded with a native upland restoration seed mix. The area within the infiltration basins will be seeded with the basin seed mix discussed above.

Pavement Sweeping

Roadways adjacent to the project site shall be swept as needed during construction. The sweeping program will remove sediment and other contaminants directly from paved surfaces before their release into stormwater runoff. Pavement sweeping has been demonstrated to be an effective initial treatment for reducing pollutant loading into stormwater (per Demonstration of Nonpoint Pollution Abatement through Improved Street Cleaning Practices, U.S. EPA, 1979).

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Structural Practices Structural erosion and sedimentation controls to be used on the site include erosion control barriers. Prior to any ground disturbance, an erosion control barrier consisting of compost filter tubes would be installed at the limit of work. As construction progresses, additional barriers would be installed around the base of stockpiles and other erosion prone areas as necessary. Limit of work erosion controls are depicted on the Project Plans in Attachment C.

If sediment has accumulated to a depth which impairs proper functioning of the barrier, it would be removed by hand or by machinery operating upslope of the barriers. This material would be either reused at the site or disposed of at a suitable offsite location. Any damaged sections of erosion control will be repaired or replaced immediately upon discovery.

7.0 Summary

The project has been designed to improve the water quality of the Connecticut River by capturing and treating adjacent roadway runoff that currently directly enters the river untreated. The project is contained entirely within the state highway layout with no direct impacts to any wetland resource areas. The only impact to an area subject to the WPA is the 100-foot Buffer Zone located within a portion of BMP #6. The BMP design minimizes the impact on the Buffer Zone while maximizing the effectiveness of the BMP within a limited project area. The project would result in an overall benefit to the area and dually improve both the stormwater quality and resource area functions.

MassDOT respectfully requests that the Chicopee Conservation Commission find these measures adequately protective of the interests identified in the WPA and issues an Order of Conditions approving the work described in this NOI and as shown on the accompanying plans.

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1.0 Introduction

On behalf of the Massachusetts Department of Transportation – Highway Division (MassDOT), AECOM is submitting this Notice of Intent application (NOI) for the Connecticut River Stormwater BMP and I-391 Resurfacing Project, pursuant to the Massachusetts Wetlands Protection Act (WPA; MGL Ch. 131 s. 40) and its implementing regulations (310 CMR 10.00). Abutter notification is not required for projects proposed by MassDOT pursuant to Chapter 472 of the Acts of 1993 as approved on January 13, 1994. The location and extent of the work areas is shown in the figures in Attachment A.

The Connecticut River BMP and I-391 Resurfacing Project is being completed to maintain the condition of the Interstate 391 roadway and improve the quality of the stormwater runoff to the Connecticut River. The roadway resurfacing work is important to maintain a safe condition for the travelers utilizing this roadway. The planned resurfacing work consists of resurfacing and repaving I-391 from the Connecticut River bridge (Holyoke/Chicopee town line at mile marker 4.5) near the project’s northern end to the I-391/Route 116 Interchange (Exit 2) in Chicopee at the project’s southern end (mile marker 0.8) for a total resurfacing/repaving distance of 3.7 miles within Chicopee. These resurfacing and repaving activities are exempt from the MA Wetlands Protection Act (WPA) as described further below.

Work within Chicopee also includes improvements to existing stormwater management systems located adjacent to I-391 south on- and off-ramps at the I-391/Grattan Street (Route 141) Interchange (Exit 4) and at the on- and off-ramps at Exit 2 in Chicopee. The stormwater retrofit work is part of the MassDOT Impaired Waters Program aimed at mitigating stormwater discharges to waterbodies through targeted upgrades to stormwater systems and installations of stormwater BMPs. The purpose of the BMP work is to improve water quality within the Connecticut River Watershed. The BMP work will include construction of vegetated water quality swales and infiltration and exfiltrating bioinfiltration basins. The construction of the proposed stormwater BMPs will provide treatment of stormwater and attenuate flows prior to discharging to the Connecticut River. The nearby river segment that this area drains to (MA34-05 of the Connecticut River) is currently impaired for Escherichia coli, PCB in fish tissue, and total suspended solids (TSS). It has been determined that direct discharge of untreated stormwater from MassDOT roadways contributes to the impairment of this river segment. The capture and treatment of this stormwater will have the same efficacy as removing a portion of the impervious surface contributing stormwater to the project area. The construction of the proposed stormwater BMPs will provide treatment of stormwater and attenuate flows prior to discharging to the Connecticut River. The proposed stormwater BMPs located within Chicopee are in the vicinity of I-391, on the east side of the Connecticut River. Additional BMPs and /or resurfacing are planned for Holyoke, West Springfield, and Agawam.

Project component exemptions and additional jurisdictional details are discussed further below.

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2.0 Exempt Resurfacing Activities

Resurfacing activities along I-391 are proposed to improve and maintain the condition of the roadway for driver accessibility and safety. The resurfacing work in Chicopee extends along I-391 from just south of the intersection with Route 116 to the Connecticut River Bridge that crosses to Holyoke. These activities include: full width micromill and overlay; replacing scored concrete pavement at gores with milled rumble strips and other rumble strip work; placing final pavement markings and slotted pavement markers; cleaning, replacing, and securing catch basin grids and manhole covers as needed; removing and resetting of granite edging as needed; upgrading selected existing guardrails; selected pedestrian ramp and sidewalk construction/reconstruction; replacement of traffic data collection stations; traffic management; and other incidental items. The extent of these improvements in Chicopee is shown in the locus figure and in Figures 3 through 5 in Attachment A. All of the resurfacing work will be located within existing paved roadways.

Although a portion of resurfacing activities will be located within the 100-Foot Buffer Zone, these activities solely within Buffer Zone (beyond other resource areas such as Riverfront Area) are not otherwise subject to regulation under M.G.L. c. 131, § 40 as indicated in 310 CMR 10.02(2)(b)1 provided that the work (as prescribed in 310 CMR 10.02(2)(b)2.a. through q) is performed “in a manner so as to reduce the potential for any adverse impacts to the resource area during construction, and with post-construction measures implemented to stabilize any disturbed areas”. 310 CMR 10.02(2)(b)2.p includes: “Pavement repair, resurfacing, and reclamation of existing roadways within the right-of-way configuration provided that the roadway and shoulders are not widened, no staging or stockpiling of materials, all disturbed road shoulders are stabilized within 72 hours of completion of the resurfacing or reclamation, and no work on the drainage system is performed, other than adjustments and/or repairs to respective structures within the roadway”.

A portion of resurfacing activities located in the vicinity of the Chicopee and Connecticut River bridges and a perennial stream crossing will occur within Riverfront Area. However, according to 310 CMR 10.58(6), maintenance of roads (limited to repairs, resurfacing, repaving, but not enlargement) in existence on August 7, 1996 within Riverfront Area is allowed without the filing of a Notice of Intent, but not when such work is within other resource areas or their buffer zones except as provided in 310 CMR 10.58(6)(b). 310 CMR 10.58(6)(b) includes certain minor activities as identified in 310 CMR 10.02(2)(b)1. 310 CMR 10.02(2)(b)1 references minor activities as described in 310 CMR 10.02(2)(b)2. 310 CMR 10.02(2)(b)2p includes “Pavement repair, resurfacing, and reclamation of existing roadways within the right-of-way configuration provided that the roadway and shoulders are not widened, no staging or stockpiling of materials, all disturbed road shoulders are stabilized within 72 hours of completion of the resurfacing or reclamation, and no work on the drainage system is performed, other than adjustments and/or repairs to respective structures within the roadway”. Therefore, the proposed resurfacing work within Riverfront Area is exempt from the WPA.

None of the resurfacing work is located in any other MA WPA resource areas. The resurfacing work is located in MA NHESP mapped habitat. MassDOT is currently

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separately consulting with MA NHESP regarding protected habitat, however a copy of this NOI is being provided to NHESP as a courtesy.

3.0 Existing Conditions Near the BMP Work Areas

The stormwater improvement portions of the project area contained in Chicopee are comprised of eleven proposed BMP sites (BMP #s 3, 6, 7, 10, 12, 14, 17, 18, 19, 23A, and 23B) (see Attachment A - Figure 1, Locus Map for locations). BMP #s 3, 6 and 7 are located in the vicinity of the I-391/Route 141 Interchange (Exit 4). BMP #s 10, 12 and 14 are located in the vicinity of the I-391/Route 116 Interchange (Exit 2). BMP #s 17, 18, 19, 23A, and 23B are located in the vicinity of the I-391/ I-91 interchange. BMP#s 3, 10, 12, 14, 17, 18, 19, 23A, and 23B are located outside the jurisdiction of the WPA and are not discussed further below. Wetland resource areas in the vicinity of the proposed stormwater BMP #s 6 and 7 are shown in Attachment A Figure 1.

Wetland resources were further defined via field delineation in the immediate vicinity of the proposed activities for BMP #6 and #7 because of their proximity to these resources. Bordering Vegetated Wetland (BVW) boundaries were delineated in accordance with the Massachusetts Wetlands Protection Act regulations (310 CMR 10.00) and MassDEP’s publication entitled “Delineating Bordering Vegetated Wetlands under the Massachusetts Wetlands Protection Act.”

3.1 BMP #6 BMP #6 is a proposed exfiltrating bioinfiltration basin with total limits of work of approximately 0.27 acres (11,760 SF). This BMP would be located within the area enclosed by I-391 southbound to the south and east and the I-391 on- and off-ramps to/from Route 141 to the west and north, respectively. The existing vegetation in the area proposed for BMP #6 is primarily comprised of a variety of grasses, with an existing concrete drainage swale running generally north-south through the limits of work, and a border of trees and shrubs along the western side of the limits of work. The limits of work for BMP #6 are shown in Attachment A, Figure 2.

A BVW located adjacent to the proposed BMP #6 was demarcated in the field with wetland flag series “S6-A” (Attachment A – Figure 2; Attachment C-Sheet #9). The intermittent stream and drainage that flow into this wetland supply it with water. The intermittent stream emerges from a headwall at the southeast extent of the wetland and flows to another headwall at the northwestern extent of the BVW. It is joined by two concrete swales that are connected to nearby stormwater collection systems. These swales convey runoff to the BVW. This wetland is dominated by common reed (Phragmites australis) and reed canary grass (Phalaris arundinacea) and includes some Graminae spp. (roadside fescues and other grasses) and sensitive fern (Onoclea sensibilis). Vegetation within the adjacent upland of this BVW includes assorted grasses, with trees and shrubs located just outside of the western extents of the BVW area. The 100-foot Buffer Zone extends from BVW “S6” onto the northern portion of the BMP #6 limits of work.

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3.2 BMP #7 BMP #7 is a proposed exfiltrating bioinfiltration basin with total limits of work of approximately 0.47 acres (20,470 SF). The area where BMP #7 limits of work are proposed is located within the northwestern corner of the infield area of the I-391 SB off-ramp to Route 141. This area is primarily comprised of grass, with woody shrubs and trees located in the northwestern portion of the limits of work and along the northeastern boundary. Existing concrete drainage structures direct highway stormwater runoff to a stream and associated wetland southwest of the limits of work.

A BVW associated with an intermittent stream located to the southwest of BMP #7 was demarcated in the field with wetland flag series “WL1-100 through WL1-101” and “WL1-201 through WL1-207” (Attachment A). The intermittent stream, which flows south to north through a culvert, was demarcated in the field with stream flag series “S1-100 through S1- 104”. The stream enters the wetland through a culvert near S1-100 and loses definition through the wetland. Toward the downstream end of the wetland, the stream collects in a concrete swale and exits the study area via another culvert. The wetland is dominated by common reed (Phragmites australis) and includes common jewelweed (Impatiens capensis) and sensitive fern (Onoclea sensibilis). Vegetation within the adjacent upland of this BVW includes crown vetch (Securigera varia) and American pokeweed (Phytolacca americana). The site is located outside of any areas subject to jurisdiction under the MA Wetlands Protection Act, including the 100-foot Buffer Zone (see Attachment A – Figure 2). As a result, BMP #7 is not further described below.

4.0 Proposed Stormwater Improvements within WPA Jurisdictional Areas

The only BMP located within a jurisdictional area under the WPA (and therefore the subject of this NOI) is BMP #6. The proposed BMP 6 is located within the grassy area enclosed by I-391 southbound to the south and east and the I-391 on- and off-ramps to/from Route 141 to the west and north, respectively. The proposed design for the BMP involves the removal of a portion of an existing concrete drainage swale. Stormwater runoff from the existing drainage system will then be redirected to a new sediment forebay prior to discharging to a new exfiltrating bioinfiltration basin. The purpose of this BMP system is to improve the quality of water discharged to receiving waters that ultimately drain to the Connecticut River located to the west of the project area and to control the water quality treatment volume. The exfiltrating bioinfiltration area is well suited for use at the proposed site. Overflow will be directed to an existing stormwater channel and wetland area located adjacent to BMP 6 (see Attachment C for further details).

Exfiltrating bioinfiltration cells (also called rain gardens in residential applications) are shallow depressions filled with sandy soil topped with a thick layer of mulch and planted with dense native vegetation. Stormwater runoff is directed into the cell via piped or sheet flow. The runoff percolates through the soil media that acts as a filter. Exfiltrating bioinfiltration areas can provide excellent pollutant removal for the “first flush” of

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stormwater runoff. Exfiltrating bioinfiltration areas remove pollutants through filtration, microbe activity, and uptake by plants; contact with soil and roots provides water quality treatment better than conventional infiltration structures.

Once the exfiltrating bioinfiltration basin construction has been completed, the stormwater BMP will be seeded with the sediment forebay and exfiltrating bioinfiltration basin seed mix depicted below. The planting schedule is designed to provide soil stabilization and reduce potential erosion (see landscape details in Attachment C). Areas disturbed for construction beyond the exfiltrating bioinfiltration basin will be seeded with an appropriate upland seed mix.

The BMP does not generate any new discharges to receiving waters or the Connecticut River. No new impervious surfaces are proposed and the volume of flow currently discharging to Connecticut River will not be increased.

Sediment Forebay and Exfiltrating Bioinfiltration Basin Seed Mix Percent by Weight Common/Scientific Name 25.00% Fox Sedge, PA Ecotype (Carex vulpinoidea, PA Ecotype) 25.00% Deertongue, ‘Tioga’ (Panicum clandestinum Dichanthelium c. ‘Tioga’) 20.00% Virginia Wildrye, PA Ecotype (Elymus virginicus, PA Ecotype) 20.00% Switchgrass, ‘Shawnee’ (Panicum rigatum, ‘Shawnee’) 5.00% Autumn Bentgrass, PA Ecotype (Agrostis perennans, PA Ecotype) 2.00% Ticklegrass (Rough Bentgrass), PA Ecotype (Agrostis scabra, PA Ecotype) 1.00% Soft Rush (Juncus effusus)

1.00% Path Rush, PA Ecotype (Juncus tenuis, PA Ecotype) 1.00% Green Bulrush, PA Ecotype (Scirpus atrovirens, PA Ecotype)

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5.0 Regulated Area Impacts

5.1 100-Foot Buffer Zone Construction activities at BMP #6 will result in approximately 6,960 square feet of disturbance to the 100-foot Buffer Zone (Attachment A - Figure 2). The existing impervious concrete drainage swales will be removed in the area. Two check dams will be added and the area will be regraded to create a sediment forebay and an exfiltrating bioinfiltration basin that will both serve to improve the water quality of the runoff entering into the wetland and stream. The removal of concrete and increased retention time will improve the infiltration function of the Buffer Zone.

5.2 NHESP/ Protection of Rare Species According to the MassGIS data layers, the stormwater BMPs are not within any mapped Area of Critical Environmental Concern (ACEC) and there are no Certified Vernal Pools within the project area. According to the Massachusetts Natural Heritage & Endangered Species Program (NHESP) Atlas and MassGIS datalayers (8/2017), no BMPs are proposed within Estimated or Priority Habitat.

5.3 Compliance with Massachusetts Stormwater Policy A Stormwater Report and Stormwater Checklist have been prepared and are attached to this narrative as Attachment D. The project has been designed and will be constructed and installed in accordance with the MA Stormwater Management Standards.

In addition, according to 310 CMR 10.04, the project qualifies as a “redevelopment” project. For purpose of the Stormwater Management Standards as provided in 310 CMR 10.05(6)(k) through (q), redevelopment is defined to include the following projects: (a) maintenance and improvement of existing roadways including widening less than a single lane, adding shoulders, correcting substandard intersections, improving existing drainage systems and repaving; (b) development, rehabilitation, expansion and phased projects on previously developed sites provided the redevelopment results in no net increase in impervious area; and (c) remedial projects specifically designed to provide improved stormwater management such as projects to separate storm drains and sanitary sewers and stormwater retrofit projects.

The project does not involve any new stormwater discharges to the Connecticut River or any other wetland resource area. No new impervious surfaces are proposed for the project. The volume of flow currently discharging to the Connecticut River would not be increased. In fact, the proposed BMP# 6 stormwater treatment system is designed to treat and infiltrate stormwater in place.

A00860 - 36 Proposal No. 607560 - 106915

6.0 Mitigation

6.1 Erosion and Sediment Controls An erosion and sedimentation control program will be implemented to minimize impacts to the adjacent BVW “S6” during the construction phase of the project. The program incorporates BMPs specified in guidelines developed by the DEP and presented in the Massachusetts Erosion and Sediment Control Guidelines for Urban and Suburban Areas: A Guide for Planners, Designers, and Municipal Officials (DEP, 1997) and U.S. Environmental Protection Agency (EPA) document, Interim Developing Your Stormwater Pollution Prevention Plan: A Guide for Construction Sites (Office of Water Report EPA 833-R-060-04, 2007).

Proper implementation of the erosion and sedimentation control program will:

1. Minimize exposed soil areas through sequencing and temporary stabilization; 2. Place structures to manage stormwater runoff and erosion; and 3. Establish a permanent vegetative cover for other forms of stabilization as soon as practicable.

Non-Structural Practices Non-structural practices to be used during construction include temporary stabilization, temporary seeding, permanent seeding, pavement sweeping (if necessary), and dust control. These practices will be initiated as practicable in appropriate areas at the site.

Temporary Stabilization Any areas of exposed soil or stockpiles that will remain inactive for more than 14 days will be covered with a layer of straw mulch.

Permanent Seeding Upon completion of final grading, any bare ground outside of the infiltration basins and within the limits of work will be seeded with a native upland restoration seed mix. The area within the infiltration basins will be seeded with the basin seed mix discussed above.

Pavement Sweeping

Roadways adjacent to the project site shall be swept as needed during construction. The sweeping program will remove sediment and other contaminants directly from paved surfaces before their release into stormwater runoff. Pavement sweeping has been demonstrated to be an effective initial treatment for reducing pollutant loading into stormwater (per Demonstration of Nonpoint Pollution Abatement through Improved Street Cleaning Practices, U.S. EPA, 1979).

A00860 - 37 Proposal No. 607560 - 106915

Structural Practices Structural erosion and sedimentation controls to be used on the site include erosion control barriers. Prior to any ground disturbance, an erosion control barrier consisting of compost filter tubes would be installed at the limit of work. As construction progresses, additional barriers would be installed around the base of stockpiles and other erosion prone areas as necessary. Limit of work erosion controls are depicted on the Project Plans in Attachment C.

If sediment has accumulated to a depth which impairs proper functioning of the barrier, it would be removed by hand or by machinery operating upslope of the barriers. This material would be either reused at the site or disposed of at a suitable offsite location. Any damaged sections of erosion control will be repaired or replaced immediately upon discovery.

7.0 Summary

The project has been designed to improve the water quality of the Connecticut River by capturing and treating adjacent roadway runoff that currently directly enters the river untreated. The project is contained entirely within the state highway layout with no direct impacts to any wetland resource areas. The only impact to an area subject to the WPA is the 100-foot Buffer Zone located within a portion of BMP #6. The BMP design minimizes the impact on the Buffer Zone while maximizing the effectiveness of the BMP within a limited project area. The project would result in an overall benefit to the area and dually improve both the stormwater quality and resource area functions.

MassDOT respectfully requests that the Chicopee Conservation Commission find these measures adequately protective of the interests identified in the WPA and issues an Order of Conditions approving the work described in this NOI and as shown on the accompanying plans.

A00860 - 38 Proposal No. 607560 - 106915

Attachment A

USGS Locus Map and Environmental Constraints

A00860 - 39 Proposal No. 607560 - 106915

BMP #7 BMP #3 HOLYOKE BMP #6

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A00860 - 41 Proposal No. 607560 - 106915

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A00860 - 42 Proposal No. 607560 - 106915

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A00860 - 43 Proposal No. 607560 - 106915

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A00860 - 44 Proposal No. 607560 - 106915

Attachment B

Site Photographs

A00860 - 45