The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114

% The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, 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 : Plymouth Rubber Redevelopment PROJECT MUNICIPALITY : Canton PROJECT WATERSHED : Boston Harbor EEA NUMBER : 16335 PROJECT PROPONENT : Canton Copperworks, LLC 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 involves the phased construction of an approximately 650,480 square foot (sf) mixed-use development on a former industrial site. The project includes approximately 588,000 total sf of residential space (272 units) comprised of townhomes and six multifamily residential buildings; approximately 22,500 total sf of commercial space consisting of retail, office, restaurant, function, and exhibit space; and up to 40,000 total sf of light industrial uses. The project also includes the construction of a bridge over the Neponset River Diversion Channel to connect Revolution Way with Neponset Street. This connection to Neponset Street was incorporated into the project in response to a request from the Town of Canton (Town) in order to improve fire safety response times to northern points within the Town. The project also includes remediation of contaminated soil and groundwater associated with past industrial uses; establishment of a 9-acre park (Paul Revere Heritage Park) along the Neponset River Diversion Channel; installation of a stormwater management system; and additional transportation, pedestrian and utility improvements as described further below.

EEA# 16335 ENF Certificate March 26, 2021

A Special Permit/Site Plan Approval was issued by the Town for the site in 2016. Construction was proposed in four phases. The first three phases are complete or are currently under construction. Therefore, the ENF submission is an after-the-fact filing for most of the project. The final phase includes the development of two residential buildings (Building 5 and 6) and a 40,000-sf light industrial building on Lots 8 and 9.

Project Site

As described in the ENF, the development area includes an approximately 41.9-acre project site bounded by the Neponset River Diversion Channel (Diversion Channel) and the Neponset Street residential neighborhood to the south and west, MBTA commuter rail line to the west and north, and Revere Street to the east. The Diversion Channel is a manmade flood control channel which was constructed by the Army Corp of Engineers in 1963 to reduce flooding associated with the Neponset River. The project site includes the following wetland resource areas: Bordering Land Subject to Flooding (BLSF), Riverfront Area, Land Under Water (LUW), Bank, and Bordering Vegetated Wetlands (BVW). Portions of the project site (approximately 9 acres) are within the 100-year floodplain (Zone AE) with varying Base Flood Elevations (BFE) based on the effective Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map (FIRM-panel 250235 0001 effective June 4, 1987). The effective BFEs on/adjacent to the site range from 65.19 to 76.19 ft elevation (el.) NAVD88. As indicated in supplemental information provided by the Proponent, new flood mapping for the project area will likely be approved later this year.1

The project site includes structures listed in the State Register of Historic Places or the Inventory of Historic and Archaeological Assets of the Commonwealth, including the Paul Revere and Son Copper Rolling Mill (CAN.126) and Draft Horse Stable (CAN.127).

Environmental Impacts and Mitigation

Potential environmental impacts associated with the project include the new alteration of 5.4 acres of land; alteration of 32,500 sf (0.75 acres) of BLSF, 10,050 sf (0.23 acres) of Riverfront Area, 145 linear feet (lf) of Bank, and 5,725 sf of LUW; generation of 2,252 new average daily trips (adt), construction of 700 new parking spaces, generation of 76,240 gallons per day of water demand and generation of 69,310 gpd of wastewater generation. The project includes construction of 0.61 miles of water main and 0.42 miles of sewer main.

Measures to avoid, minimize, and mitigate environmental impacts identified in the ENF include the provision of a 9.1-acre park, reduction of on-site impervious area by 3.5 acres; installation of stormwater management systems consistent with MassDEP’s Stormwater Management Standards; remediation of contaminated soils; provision of compensatory flood storage at 1.2:1 ratio; restoration of in situ impacts to bank and LUW, and pedestrian and transportation improvements.

Jurisdiction and Permitting

1 Floodplain information was provided to the MEPA Office by the Proponent on March 23, 2021. 2

EEA# 16335 ENF Certificate March 26, 2021

This project is subject to MEPA review and preparation of an ENF pursuant to 301 CMR 11.03(3)(b)(1)(f), 11.03(6)(b)(13), and 11.03(6)(b)(15) because the project requires a State Agency Action and involves alteration of one half or more acres of any other wetlands; generation of 2,000 or more new adt on roadways providing access to a single location; and construction of 300 or more new parking spaces at single location, respectively. The project received an 8(m) permit from the Massachusetts Water Resource Authority (MWRA) and a Chapter 91 License from the Massachusetts Department of Environmental Protection (MassDEP). As noted below, the project also received a Superseding Order of Conditions from MassDEP. The project may require one or more license agreements from the Massachusetts Bay Transportation Authority (MBTA).

The project received multiple Orders of Conditions (DEP File Nos. 124-1169, 124-1183,124- 1245, 124-1266) from the Canton Conservation Commission and a Superseding Order of Conditions (SOC) from MassDEP (124-1182)). The project required a National Pollutant Discharge Elimination System (NPDES) Construction General Permit from the U.S. Environmental Protection Agency. The project required review by the Massachusetts Historical Commission (MHC) acting as the State Historic Preservation Officer (SHPO) pursuant to Section 106 of the National Historic Preservation Act of 1966, as amended (36 CFR 800).

The project is not receiving Financial Assistance from the Commonwealth. Therefore, MEPA jurisdiction for any future review would be 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, and identified measures to avoid, minimize and mitigate environmental impacts. Because the project is under construction, no alternatives analysis was provided. Comments from State Agencies do not request additional analysis in the form of an EIR. The Town of Canton submitted a letter of support for the project indicating the numerous opportunities for public and municipal input during the design of the project as well as the public benefits the project provides, including remediation of a heavily contaminated site; establishment of cultural and recreational amenities for residents; and the provision of affordable housing.

One comment letter from a resident expressed concerns regarding the clearing of undeveloped land for the construction of Building 5 and 6 which were originally sited in previously disturbed area (Lot 8). As discussed in the remote meeting held on March 4, 2021 and reiterated in correspondence received by the MEPA office on March 23, 2021, the siting of Building 5 and 6 was revised based on more extensive soil testing of Lots 8 and 9. This testing indicated that contaminated soil was present in Lot 8 and a very small portion of Lot 9 but was deeper than originally thought. Town officials expressed a very strong desire to see underground parking as part of the residential development plan in order to reduce impervious cover near the wetlands system. However, as described in the ENF, the quantities of contaminated soil that would have to be hauled off-site to allow for underground parking on Lot 8 would be cost prohibitive and placing the residential use on Lot 8 would also require an Activity Use Limitation (AUL) and potentially result in exposure to future residents. For these reasons,

EEA# 16335 ENF Certificate March 26, 2021

the Proponent determined that the siting of residential Buildings 5 and 6 on the undeveloped portion of Lot 9 and within the MBTA ZOI was necessary.

Land Alteration and Stormwater

As discussed above, the majority of the project site was previously disturbed due to industrial uses on site; however, the project will result in the new alteration (i.e. clearing) of 5.4 acres of undeveloped land for the development of Building 5 and 6. The project will result in the net reduction of impervious area by 3.5 acres. The project also includes a 9-acre public park located along the banks of the Diversion Channel.

As described in the ENF, the project’s stormwater management system is comprised of a combination of impervious area reduction, surface/subsurface infiltration basins, sand filters, detention and constructed stormwater wetlands to promote recharge, enhance water quality and mitigate peak rates of runoff. The system has been designed in accordance with MassDEP’s Stormwater Management Standards. The Project required Orders of Conditions (OOC) from the Canton Conservation Commission. As noted in the ENF, as part of that permitting process the stormwater design underwent a rigorous review by the Town’s peer review consultants.

Wetlands

As noted above, the project has resulted in impacts to previously disturbed BLSF, Riverfront Area, Bank, LUW, and buffer zone associated with the Neponset River and diversion channel. The Bridge crossing the diversion channel was redesigned to include a wildlife shelf for wildlife passage under the superstructure. The project included 51,730 CF (1.2:1) of compensatory flood storage to mitigate impacts to BLSF.

As indicated in the ENF, MassDEP issued Chapter 91 License No. 14823 on December 19, 2018 for the construction of the vehicular bridge. As noted above, the Canton Conservation Commission and MassDEP reviewed the project’s impacts to wetland resource areas for consistency with the Wetlands Protection Act (WPA) and implementing regulations (310 CMR 14.00) and issued multiple OOCs and one SOC for the project.

Traffic and Transportation

The project exceeds ENF thresholds for trip generation and parking supply and may require one or more License Agreements from the MBTA due to the project site’s proximity to the MBTA’s Zone of Influence (ZOI) and pedestrian connection to the Canton Junction Commuter Rail Station. As noted above, a previous version of the project that was originally approved by the Town did not include construction within the MBTA ZOI. The relocation of Building 5 and 6 now requires construction in the ZOI due to the presence of extensive soil contamination on Lot 8 and 9, as described above. The project also requires a new license agreement with the MBTA for the construction of a lighted multi-modal pathway connecting Canton Center and adjacent neighborhoods to the Canton Junction Commuter Rail Station along an existing rail spur. This license was previously obtained but expired before work on the project began.

EEA# 16335 ENF Certificate March 26, 2021

The full-build project will include 667 parking spaces (consisting of 341 surface parking spaces and 326 spaces will be within garages and or below grade) and is expected to generate 2,252 vehicle trips per day. Access is provided via Revolution Way, which connects to Neponset Street via a new bridge in the southwest, and Revere Street in the northeast. Access to other sections of the project is provided via driveways along Revere Street. The project does not impact any MassDOT jurisdictional roadways. A Transportation Impact and Access Study (TIAS) was prepared to facilitate local permitting in 2015 and again in 2020 for additional residential units proposed as part of Phase 4 of the project. To mitigate traffic impacts associated with the project, the Proponent and Town agreed on multiple transportation improvements which included the complete reconstruction of Revere Street, sidewalk improvements, and improved bike accommodations (sharrows); bridge construction over the Diversion Channel to connect Revolution Way with Neponset Street; and intersection improvements and signalization at Neponset Street/Norfolk Street/Revolution Way. Additionally, as noted above, the project includes a pedestrian/bicycle connection to the Canton Junction Commuter Rail Station.

As described in the ENF, the project will include implementation of a Transportation Demand Management (TDM) plan primarily oriented towards the limited number of employees for the proposed commercial uses, but which will also include measures targeted towards reducing single-occupant automobile travel for the primary residential component of the site. The TDM plan may include measures to promote bicycle and pedestrian travel, connections to nearby public transportation (bus and train), and other multimodal transportation options. The Proponent should consider incorporating the following measures into the TDM program:

• Designate a transportation coordinator for the project to coordinate the elements of the TDM program; • Post information regarding public transportation services, maps, schedules, and fare information in a central location and/or otherwise made available to residents; • Provide a “welcome packet” to residents detailing available public transportation services, bicycle and walking alternatives, and commuter options available; • Provide work-at-home workspaces to support telecommuting by residents; • Provide a mail drop in a central location; and • Provide secure bicycle parking within the project site consisting of both exterior and interior (covered) bicycle parking.

Hazardous Waste

In August 2017, a combined Permanent and Temporary Solution Statement was filed for the former Plymouth Rubber project with MassDEP for the site-wide Release Tracking Number (RTN) 4- 3011520. The Solution Statement report established Permanent Solutions for five release areas that were remediated between 2015 and 2017 on the main mill complex area of the property (former mill complex including the park, Rolling Mill, and residential condominiums). The Permanent Solution supports residential reuse without an AUL for this area. Temporary Solutions were attained for contaminated sediment/soil at Factory Pond and for the Light Industrial use. Every five years, the status of sediment of Factory Pond will be re-evaluated, and once natural attention has improved sediment conditions supportive of a favorable ecological risk assessment, a Permanent Solution will be filed for Factory Pond. Current conditions at Lot 8 require filing a Permanent Solution with an AUL that would limit reuse of Lot 8 to commercial only uses (or residential reuse with establishment of a cover/cap of 3 feet

EEA# 16335 ENF Certificate March 26, 2021

of soil); however, due to the lack of a defined redevelopment plan for this portion of the property in 2017, a Temporary Solution was put in place. The Temporary Solution filed for the Lot 8 established that the use of Lot 8 is to remain “commercial” and passive in nature until such time that redevelopment plans become available at which time a Permanent Solution with appropriate AUL would then be filed.

Comments from MassDEP indicate that because the proposed location of the commercial structure is located within the boundaries of the 2017 Temporary Solution Statement, a revised Phase IV Remedial Action Plan (Phase IV) or Release Abatement Measure (RAM) must be submitted to MassDEP prior to the initiation of construction activities. Although the proposed locations of the additional residential structures (Building 5 and Building 6) are not within the boundaries of the Temporary Solution Statement, past site investigative activities conducted in this area identified limited impact to soils. Therefore, MassDEP recommends that prior to beginning the construction activities of Building 5 and Building 6, a RAM Plan should be filed to memorialize Soil Management Procedures should impacted soil be encountered during the construction activities.

Cultural and Historical Resources

A Massachusetts Historical Commission (MHC) Project Notification Form (PNF) was submitted for the Project on March 16, 2018 because it included the rehabilitation of the Paul Revere and Son Copper Rolling Mill (CAN.126) and Draft Horse Stable (CAN.127). The project included comprehensive reconstruction of Improvements to the Paul Revere Barn and Rolling Mill buildings used by the Revere family as part of their copper rolling business in conjunction with the development of a dedicated community park on-site (now known as the Revere Heritage Park). Reconstruction and rehabilitation work to historical resources has been completed and no further work is proposed at this time.

Water and Wastewater

The project does not exceed water or wastewater review thresholds but is anticipated to generate 76,240 gpd of new water demand and result in 69,310 gpd of new wastewater generation. Water will be supplied by the Town of Canton. The project included water system improvements in the vicinity of the site including water main upgrades in Revere Street and a new connection to Neponset Street providing a looped water system from Neponset Street to Revere Street. As indicated in MWRA’s comment letter, the project site is served by the Town of Canton’s sanitary sewer system which conveys flows to MWRA’s New Neponset Valley Sewer (NNVS), which in turn delivers flows to MWRA’s High Level Sewer (HLS), the Nut Island Headworks in Quincy, and ultimately to the Deer Island wastewater treatment plant. Due to high levels of infiltration (groundwater) and inflow (rain related flow) (together, “I/I”) into the sewer systems of communities’ tributaries to the NNVS and the HLS, flows can exceed system capacities in large storms and contribute to system surcharging and overflows. To ensure that the Project’s new wastewater flow does not increase surcharging or overflows in large storms, the Proponent should fully offset the project’s new wastewater flow with I/I removal in compliance with MassDEP regulations and in accordance with Town of Canton I/I mitigation policy.

As described in the ENF, the sewer system associated with the previous industrial site use consisted of clay pipes and masonry sewer structures which likely contributed I/I into the municipal system. As part of the project, the previously existing sewer system was removed and an entirely new

EEA# 16335 ENF Certificate March 26, 2021 system was constructed using plastic piping and waterproof manholes to significantly reduce I/I potential. In addition, two illicit connections to the drainage system were identified and removed. The project also includes low flow fixtures in all new buildings to conserve water.

Comments from MWRA indicate that the discharge of groundwater and stormwater into the sanitary sewer system is prohibited, pursuant to 360 C.M.R. 10.023(1) except in a combined sewer area when permitted by the MWRA and Town. The project site has access to a storm drain and is not located in a combined sewer area. Therefore, the discharge of groundwater or stormwater to the sanitary sewer system associated with the project is prohibited. A Sewer Use Discharge Permit is required prior to discharging industrial wastewater or photo processing wastewater from industrial space associated with the Project into the MWRA sanitary sewer system.

Section 8(m) of Chapter 372 of the Acts of 1984, MWRA’s Enabling Legislation, enables the MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA, with the goal of protecting Authority-owned infrastructure. An 8(m) permit was required for work associated with the construction of the diversion channel bridge.

Climate Change

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

Adaptation and Resiliency

The region’s climate is expected to experience higher temperatures and more frequent and intense storms. 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. I encourage the Proponent to consult the data available on the resilientMA.org website to develop climate change scenarios for the site and identify potential adaptation measures. For instance, stormwater sizing and choices about building elevation in the flood plain should take into account anticipated precipitation volumes under future climate conditions. Even if the proposed stormwater design shows improvements over existing conditions, it may not improve conditions as measured against future scenarios that consider the effects of climate change. These effects should be quantified and evaluated in light of the useful life of the project, so design choices can appropriately consider likely future conditions.

EEA# 16335 ENF Certificate March 26, 2021

The Town 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 Town can take to reduce risk and build resilience. The Town of Canton published their MVP Plan in February 2019. The plan is focused on the vulnerability of the Town’s infrastructure to current and future natural hazards. Town officials indicated that they believe the Town’s localized flood challenges are due to lack of adequate drainage infrastructure. As described by the Proponent, the project addresses the Town’s priorities for improving resilience by reducing impervious area, improving stormwater management, improving pedestrian access and mobility, creating open space, and mitigating site contamination. Building 2 is located within the preliminary floodplain.2 The building design has taken this into account and will have a first floor elevation a minimum of 4 ft above the effective flood maps and 2 ft above the proposed 100-year flood elevations anticipated to be published next year.

Greenhouse Gas (GHG) Emissions and Sustainable Design

While the project does not exceed the thresholds for application of MEPA’s GHG Policy and Protocol, it does involve the development of new residential homes that will add to GHG emissions from the building sector. I encourage the Proponent to voluntarily undertake additional measures to minimize GHG emissions from the project by incorporating energy conservation measures into uses not yet constructed. Measures that may be suitable include:

• Passivehouse building standards for residential uses; • Efficient Electrification of space and water heating; • Maintaining envelope integrity with framed, insulated walls with continuous insulation; • Reducing air leakage; • Avoiding glass curtain wall assemblies and excessive windows; • Mitigation of solar heat gains; • Energy recovery; and • Rooftop solar PV.

In addition, significant incentives may be available including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) credits. I encourage the Proponent to consult with the Department of Energy Resources (DOER) on how to incorporate energy efficiency measures into the project.

Construction Period

As described in the ENF, demolition debris waste associated with the demolition of previous industrial uses on the site was separated and legally disposed of in regional landfills. Material that could not be separated and recycled (structural steel, electrical, metal plumbing) was sorted and recycled. During construction, wood, metals, gypsum, cardboard and plastic were segregated and sent to recycling facilities. Overall, the project diverted approximately 75% of construction debris from landfills. The

2 As described by the Proponent, the most recent FEMA maps available for the project site date back to 1987. New FEMA maps will establish a more up to date floodplain and are referenced as the “preliminary floodplain.” 8

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Project will continue to enforce anti-idling measures consistent with MGL Chapter 90 Section 16A. In addition, all diesel construction machinery will be fitted with oxidation catalysts to reduce emissions.

All remaining construction and demolition 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). The Proponent must perform asbestos surveys of these buildings prior to disturbance of the buildings. If asbestos is found, MassDEP must be notified prior to its handling or removal in accordance with the Asbestos regulations (310 CMR 7.15). All construction activities should be undertaken in compliance with the conditions of all State and local permits. I encourage the Proponent to reuse or recycle construction and demolition (C&D) debris to the maximum extent.

Conclusion

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

March 26, 2021 ______Date Kathleen A. Theoharides

Comments received:

03/03/2021 Town of Canton 03/16/2021 Massachusetts Water Resources Authority (MWRA) 03/16/2021 Ann McGovern MacAdam 03/17/2021 Massachusetts Department of Environmental Protection (MassDEP) Southeast Regional Office (SERO) 03/23/2021 Massachusetts Department of Transportation (MassDOT)

KAT/EFF/eff

EEA# 16335 ENF Certificate March 26, 2021

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SELECT ~OAF2D POLICE COMMISSIONERS UPPER MEMORIAL HALL BOARD OF PUBLIC WORKS 801 WASHINGTON STREET LICENSING BOARD CANTON, MA 02021 TEL: (78 7) 821 -5000 FAX: (781) 821-2935 TOWN ADMINISTRATOR Ema~~: caspinwallQa town.canton.ma.us March 3, 2021 CHARLES J. ASPINWALL

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

Re: Plymouth Rubber Redevelopment Project, Canton, MA Environmental Notification Form (ENF), EEA No. 16335

Dear Secretary Theoharides:

The Select Board of Canton understands that Canton Holdings, LLC and Canton Copperworks, LLC (an affiliated Thorndike Development Corporation company), the developer who will construct 84 residential units along the MBTA rail in Phase 4 of the Plymouth Rubber Redevelopment Project have filed an ENF and the MEPA Unit will conduct a remote consultation session on March 4, 2021. We offer our support for this nearly completed landmark Brownfield mixed-use redevelopment Project.

This Project is a significant achievement and benefit to the Town of Canton and the Metro Region. It is transforming a contaminated and vacant industrial property into a Commw~ity Preservation Act success story. It meets Canton's Master Plan 2035 goals and the MAPC MetroFuture goals. Since 2014, Canton has worked closely with the master developer, Canton Holdings, LLC and Thorndike Development to make our shared vision a reality. The planning and permitting processes provided numerous opportunities for public and municipal input in the design and construction reviews. The Project is an excellent example of what the public and private sectors can accomplish working collaboratively toward a common goal.

Renamed the Paul Revere Heritage Site, this Project has allowed Canton to reclaim an important part of its history and see a heavily contaminated site in the center of Canton now remediated. It has also resulted in the establishment of cultural and recreational opportunities that will provide benefits for generations to come. The Project provides the Town of Canton with additional affordable housing and market rate housing opportunities to residents who wish to live close to transit and to Canton's main shopping district. The Project includes important infrastructure improvements, including construction of an essential bridge over a diversionary channel of the Neponset River that has improved response times for Canton Fire and Safety Departments to entire neighborhoods in Canton and provides public access to Heritage Park, and construction of significant intersection improvements and signalization, sidewalks and pathways.

~oaaz9~z8 -88a~~,6} Kathleen Theoharides, Secretary March 3, 2021 Page 2

The Project is largely complete at this time including 72 units (five affordable) already constructed and conveyed and an additional 54 units (two affordable) under construction and to be conveyed later this year. The final phase of residential units is scheduled to begin this Spring. Canton is very proud of this redevelopment project and is eager to see it completed without further delay. Thank you for considering our comments. We are available to answer any questions you might have.

Sincerely,

John J. o oll , air

1~6h~ Michael C. Loughran, Vice-Chair

Mark J. Porter ler

Ch ' opher on ly; Member

t Lisa R. Lopez, Memb

cc: Lloyd Geisinger, Canton Copperworks, LLC and Thorndike Development Corporation Bernie Plante, Canton Holdings Erin Flaherty, MEPA Analyst

{00029728 -8801/16)

March 16, 2021

Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge St, Suite 900 Attn: MEPA Office, Erin Flaherty Boston, MA 02114

Subject: EOEEA #16335 Environmental Notification Form Plymouth Rubber Redevelopment, Canton, MA

Dear Secretary Theoharides,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Environmental Notification Form (ENF) submitted by Canton Copperworks, LLC (the “Proponent”) for Plymouth Rubber Redevelopment (the “Project”) in Canton, Massachusetts. The 41.9- acre Project site is located on Revere Street and is bounded by the Army Corps of Engineers’ Neponset River Right Bank Flood Damage Reduction System, the Neponset Street residential neighborhood to the south and west, MBTA rail line to the west and north, and Revere Street to the east. Construction of the Project is underway for a mixed-use development and 9-acre park. Three of the four Project phases are complete or under construction. Prior to redevelopment, the site consisted of a series of buildings and structures associated with the Revere Copper Company Works and its predecessor, the Plymouth Rubber Company.

MWRA comments on the ENF relate to wastewater issues and the need for Infiltration/Inflow (I/I) Removal, Toxic Reduction and Control (TRAC) discharge permitting and MWRA Enabling Statute Section 8(m) permitting.

Wastewater

The ENF reports that the Project will generate approximately 69,310 gallons per day (gpd) of new wastewater flow. The Project site is served by a sanitary sewer system owned and operated by the Town of Canton that conveys flows to MWRA’s New Neponset Valley Sewer (NNVS), which delivers the flows to MWRA’s High Level Sewer (HLS), the Nut Island Headworks in Quincy and ultimately to the Deer Island wastewater treatment plant. Due to high levels of infiltration (groundwater) and inflow (rain related flow) (together, “I/I”) into the sewer systems of communities tributary to the NNVS and the HLS, flows can exceed system capacities in large storms and contribute to system surcharging and overflows.

To ensure that the Project’s new wastewater flow does not increase surcharging or overflows in large storms, the Proponent should fully offset the Project’s new wastewater flow with I/I removal in compliance with Massachusetts Department of Environmental Protection regulations and in accordance with Town of Canton I/I mitigation policy. The ENF reports that the previously existing sewer system at the former Plymouth Rubber factory was developed over the past two centuries and was expanded as the industrial site expanded. Much of the system consisted of clay pipes and masonry sewer structures which likely contributed I/I into the municipal system. As part of the Project, the previously existing sewer system was removed and an entirely new system was constructed using water-tight plastic pipe and manholes to significantly reduce I/I potential. In addition, two illicit connections to the drainage system were identified and removed. The Project also uses low flow fixtures in all new buildings to conserve water.

TRAC Discharge Permitting

MWRA prohibits the discharge of groundwater and stormwater into the sanitary sewer system, pursuant to 360 C.M.R. 10.023(1) except in a combined sewer area when permitted by the Authority and the local community. The Project site has access to a storm drain and is not located in a combined sewer area. Therefore, the discharge of groundwater or stormwater to the sanitary sewer system associated with this Project is prohibited.

A Sewer Use Discharge Permit is required prior to discharging industrial wastewater or photoprocessing wastewater from industrial space associated with the Project into the MWRA sanitary sewer system. For assistance in obtaining this permit, representatives of the proposed industrial or commercial space should contact Stephen Buczko, Industrial Coordinator, in the TRAC Department at (617) 305-5619.

Section 8(m) Permitting

Section 8(m) of Chapter 372 of the Acts of 1984, MWRA’s Enabling Legislation, enables the MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA, with the goal of protecting Authority-owned infrastructure. An 8(m) permit may be required due to the proximity of MWRA wastewater infrastructure to the Project site. The Proponent should contact Kevin McKenna in the Wastewater Operations Permitting Group at (617) 305-5956 for assistance related to this matter.

On behalf of the MWRA, thank you for the opportunity to provide comments on this Project. Please do not hesitate to contact me at 1 (617) 788-4958 with any questions or concerns.

Sincerely,

Beth Card Director Environmental and Regulatory Affairs cc: George Zoto, MassDEP March 16, 2021

Secretary Kathleen Theoharides Executive Office of Energy and Environmental Affairs Attn: MEPA Office 100 Cambridge Street, Suite 900 Boston, MA 02114

Re: Environmental Notification Form, Plymouth Rubber Redevelopment, Canton, MA

Dear Secretary Theoharides:

Mass. Executive Office of Energy and Environmental Affairs MEPA should require an Environmental Impact Report for this project for the following reasons:

The proposed project changes impact the adjacent ACEC of Fowl Meadow and Ponkaboag Bog. The existing woodlands a performing a valuable ecological service to purifying water flowing through the site and into the ACEC.

The amount of undeveloped land being used for this project is excessive. The original project was approved for utilizing the developed areas of the former Plymouth Rubber site. Town approval at Town Meeting was never granted for the massive clearcutting of existing woodlands and replacing them with buildings and pavement for parking. Consideration for the loss of carbon uptake and storage by the several acres of trees proposed for removal must be accounted for, as well as the loss of habitat adjacent to an ACEC. Canton has given up too much undeveloped land for this project already, rather than focusing on the previously developed land. If the contamination at the original location for these buildings is too excessive, the proponent should clean up the contamination as originally approved for this project, rather than clear cutting 5+ acres of trees and destroying existing woodlands just to save money for the project proponent.

The project claims to take a “complete streets” approach that is supposed to enable pedestrian and bicycle use of the new roadways. However, the construction of the new intersection at Neponset and Norfolk Streets has eliminated the breakdown lane altogether where the bridge roadway meets Neponset Street, effectively blocking the lane that was previously used by bicyclists on this roadway. This newly designed intersection, which was not built according to what was shown and approved at Town Meeting, has resulted in the effect that Neponset Street can no longer be used by bicyclists on the stretch of Neponset Street between downtown and Canton Junction, due to the narrowing of the roadway to a single lane bordered by granite curbing that excludes passage by bicycles, negating the supposed “complete streets” approach touted in this proposal.

The fecal coliform impairment of the East Branch of the Neponset River Diversion Channel is a new development and must be addressed as a result of the current development. This water body flows directly to Fowl Meadow and is part of the Neponset River aquifer. Failure of the project’s wastewater or stormwater systems should be identified before this project is allowed to expand.

The encroachment of the proposed project into the MBTA’s Zone of Influence should be studied further, due to the unique nature of the Canton Viaduct, and future plans for the railway. It doesn’t make sense to build so close to the ZOI when the originally approved plan would not have done so. The cost to clean up the contaminated area to enable use of that land is not the concern of MEPA, whereas protection of the environment for the benefit of all is.

Sincerely,

Ann McGovern MacAdam 18 Lexington St. Canton, MA 02021

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

March 16, 2021

Kathleen A. Theoharides RE: ENF Review. EOEEA 16335 Secretary of Environment and Energy CANTON. Plymouth Rubber Executive Office of Energy and Redevelopment at Revere Street Environmental Affairs 100 Cambridge Street, Suite 900 ATTN: MEPA Office Boston, MA 02114

Dear Secretary Theoharides,

The Southeast Regional Office of the Department of Environmental Protection (MassDEP) has reviewed the Environmental Notification Form (ENF) for the Plymouth Rubber Redevelopment at Revere Street, Canton, Massachusetts (EOEEA #16335). The Project Proponent provides the following information for the Project:

A development agreement was executed in April 2015 between the Town of Canton Board of Selectmen and the Master Developer after a lengthy master planning effort which ultimately resulted in an overlay zoning approved by two-thirds of Town Meeting members and broad support across multiple Town interest groups. Permitting for site enabling work for the Plymouth Rubber Redevelopment Project (the “Project”) began in May 2015, and environmental remediation work began later that year. In October 2016, a Special Permit/Site Plan Approval was issued. Today this project stands as a model of what public/private partnership can accomplish utilizing the tools available to municipalities in the Commonwealth. The Project has allowed Canton to reclaim an important part of its history by memorializing the role Paul Revere and his heirs played in town and revitalizing a dilapidated and contaminated industrial site immediately adjacent to downtown Canton. It is now the home of the Copperworks Condominiums and the Paul Revere Heritage Site. All structures contemplated in the Project are either under construction (Building #1, Building #2 and Buildings #7-15 Townhomes), completed (Community Building/Revere Barn), or occupied (Buildings #3-4 and the Rolling Mill Building), with the exception of the final two residential buildings (5 and 6), which are anticipated to be completed by mid to late 2022. To date, the following Project components have been completed:

 The 9-acre Paul Revere Heritage Park (to be dedicated in 2021);  72 residential units in Building #3 and #4 (occupied);  Bridge construction in improve Town fire access; and  Historic Copper Rolling Mill building restored, occupied by Northern Spy restaurant

This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper

EEA No. 16335 March 16, 2021 The following is anticipated to occur in 2021:

 Paul Revere Heritage Commission will establish a museum/cultural center in the historic Draft Horse Stable;  116 residential units in Buildings #1 and #2 (under construction) and the townhomes, Buildings #7-#15 (under construction) will be occupied; and  The community building amenity will open. Bureau of Water Resources Comments Wetlands. The Wetlands Program has reviewed the ENF for the proposed Plymouth Rubber Redevelopment Project and offers the following comments. The Project Proponent has applied for and obtained the necessary approvals under the Wetlands Protection Act as outlined in the ENF. MassDEP's SERO Wetlands Program issued a Superseding Order of Conditions for the construction of the bridge over the Neponsett River Diversion Channel. At the time of the issuance of the SOC, the Project did not exceed any Wetlands Review thresholds found in 301 CMR 11.03(7).

The Wetlands Program does not believe that any further review under MEPA would provide additional environmental benefits or reduce impacts to wetland resource areas.

Waterways. As indicated in the ENF, MassDEP issued Chapter 91 License No. 14823 on December 19, 2018 for the construction of the vehicular bridge. All other components of the Project as described in the ENF that are existing, currently under construction or potential future Projects do not require additional licensing under Chapter 91.

Water Management Act. According to the ENF, it is anticipated that the water use for the Plymouth Rubber Redevelopment in Canton will be 76,240 gallons per day and will be provided by the Town of Canton. Canton Water Department is partially supplied water by the MWRA and has the capacity to provide the requested volume for this Project based on its recent water use. MassDEP suggests the Proponent evaluate and implement conservation efforts that incorporate Best Management Practices (BMPs) at the Project site. MassDEP also encourage Project Proponents that add additional demand to the public water system (PWS) to work with the PWS to mitigate the additional demands proposed by the Project.

Stormwater Management/National Pollutants Discharge Elimination System (NPDES) Permit. The Project construction activities are scheduled to disturb more than an acre of land and therefore may require a NPDES Stormwater Permit for Construction Activities. The Proponent can access information regarding the NPDES Stormwater requirements and an application for the Construction General Permit at the EPA website: https://www.epa.gov/sites/production/files/2017- 07/documents/cgp_flow_chart_do_i_need_a_permit2.pdf

The Proponent is advised to consult with David Gray at [email protected], 617-918-1577 for any of its questions regarding EPA’s NPDES stormwater permitting requirements.

Bureau of Waste Site Cleanup Comments Based upon the information provided, the Bureau of Waste Site Cleanup (BWSC) searched its databases for disposal sites and release notifications that have occurred at or might impact the proposed Project area. A disposal site is a location where there has been a release to the environment of oil and/or hazardous material that is regulated under M.G.L. c. 21E, and the Massachusetts Contingency Plan [MCP – 310 CMR 40.0000].

EEA No. 16335 March 16, 2021

The former Plymouth Rubber property is a Disposal Site as defined in M.G.L. Chapter 21E and the Massachusetts Contingency Plan (MCP – 310 CMR 40.0000). Release Tracking Number 4- 3011520 was issued for the Site. A Temporary Solution Statement/Partial Permanent Solution Statement was submitted to MassDEP on August 25, 2017. The 33-acre Site operated as a manufacturer of brass and copper products as well as rubber and vinyl products on the property. Site operations involved a variety of chemicals. Historic site use has resulted in releases of chemicals included phthalates, polyaromatic hydrocarbons, volatile organic compounds, chromium, copper, lead, mercury and zinc.

The Project Description on the ENF proposes the construction of additional structures at the Property. Specifically, the construction of a commercial structure is proposed in the portion of the disposal Site known as the Vacant Land and construction of two additional residential structures (Building 5 and Building 6) in an undeveloped portion of the property, located to the north of the Vacant Land.

The proposed location of the commercial structure is located within the boundaries of the 2017 Temporary Solution Statement, therefore, a revised Phase IV Remedial Action Plan (Phase IV) or Release Abatement Measure (RAM) must be submitted to MassDEP prior to the initiation of construction activities. Although the proposed locations of the additional residential structures (Building 5 and Building 6) are not within the boundaries of the Temporary Solution Statement, past site investigative activities conducted in this area identified limited impact to soils. Therefore, it is recommended that prior to beginning the construction activities of Building 5 and Building 6, a RAM Plan should be filed to memorialize Soil Management Procedures should soil impact be encountered during the construction activities.

There are no other listed MCP disposal sites located at or in the vicinity of the site that would appear to impact the proposed Project area. Interested parties may view a map showing the location of BWSC disposal sites using the MassGIS data viewer (Oliver) at: http://maps.massgis.state.ma.us/map_ol/oliver.php Under “Available Data Layers” select “Regulated Areas”, and then “DEP Tier Classified 21E Sites”. MCP reports and the compliance status of specific disposal sites may be viewed using the BWSC Waste Sites/Reportable Release Lookup at: https://eeaonline.eea.state.ma.us/portal#!/search/wastesite

The Project Proponent is advised that if oil and/or hazardous material are identified during the implementation of this Project, notification pursuant to the Massachusetts Contingency Plan (310 CMR 40.0000) must be made to MassDEP, if necessary. A Licensed Site Professional (LSP) should be retained to determine if notification is required and, if need be, to render appropriate opinions. The LSP may evaluate whether risk reduction measures are necessary if contamination is present. The BWSC may be contacted for guidance if questions arise regarding cleanup.

Bureau of Air and Waste (BAW) Comments Air Quality. Construction and operation activities shall not cause or contribute to a condition of air pollution due to dust, odor or noise. To determine the appropriate requirements please refer to: 310 CMR 7.09 Dust, Odor, Construction, and Demolition 310 CMR 7.10 Noise

Construction-Related Measures MassDEP requests that all non-road diesel equipment rated 50 horsepower or greater meet EPA’s Tier 4 emission limits, which are the most stringent emission standards currently available for off-

EEA No. 16335 March 16, 2021 road engines. If a piece of equipment is not available in the Tier 4 configuration, then the Proponent should use construction equipment that has been retrofitted with appropriate emissions reduction equipment. Emission reduction equipment includes EPA-verified, CARB-verified, or MassDEP- approved diesel oxidation catalysts (DOCs) or Diesel Particulate Filters (DPFs). The Proponent should maintain a list of the engines, their emission tiers, and, if applicable, the best available control technology installed on each piece of equipment on file for Departmental review.

Massachusetts Idling Regulation As reported by the Proponent, “The Project will continue to enforce anti-idling measures consistent with MGL Chapter 90 Section 16A. In addition, all diesel construction machinery will be fitted with oxidation catalysts to reduce emissions.”

MassDEP reminds the Proponent that unnecessary idling (i.e., in excess of five minutes), with limited exception, is not permitted during the construction and operations phase of the Project (Section 7.11 of 310 CMR 7.00). With regard to construction period activity, typical methods of reducing idling include driver training, periodic inspections by site supervisors, and posting signage. In addition, to ensure compliance with this regulation once the Project is underway, MassDEP recommends that the Proponent install signs limiting idling to five minutes or less on- site.

Spills Prevention. A spills contingency plan addressing prevention and management of potential releases of oil and/or hazardous materials from pre- and post-construction activities should be presented to workers at the site and enforced. The plan should include but not be limited to, refueling of machinery, storage of fuels, and potential on-site activity releases.

Hazardous Waste Management. If any occupant of the Project generates hazardous waste and/or waste oil, that entity must be properly registered with the MassDEP in accordance with 310 CMR 30.000 for legally generating and managing regulated waste. The Proponent is advised to consult at this MassDEP website https://www.mass.gov/guides/hazardous-waste-generation-generators to determine if the Proponent qualifies as a generator of hazardous waste and/or waste oil.

Solid Waste Management. The ENF indicates that the Project will generate demolition or construction debris and that the Project will disturb asbestos containing materials.

Solid Waste/Asbestos Comments 1. Compliance with Waste Ban Regulations: Waste materials discovered during construction that are determined to be solid waste (e.g., construction and demolition waste) and/or recyclable material (e.g., metal, asphalt, brick, and concrete) shall be disposed, recycled, and/or otherwise handled in accordance with the Solid Waste Regulations including 310 CMR 19.017: Waste Bans. Waste Ban regulations prohibit the disposal, transfer for disposal, or contracting for disposal of certain hazardous, recyclable, or compostable items at solid waste facilities in Massachusetts, including, but not limited to, metal, wood, asphalt pavement, brick, concrete, and clean gypsum wallboard. The goals of the waste bans are to: promote reuse, waste reduction, or recycling; reduce the adverse impacts of solid waste management on the environment; conserve capacity at existing solid waste disposal facilities; minimize the need for construction of new solid waste disposal facilities; and support the recycling industry by ensuring that large volumes of material are available on a consistent basis. Further guidance can be found at: https://www.mass.gov/guides/massdep-waste-disposal-bans.

EEA No. 16335 March 16, 2021 MassDEP recommends the Proponent consider source separation or separating different recyclable materials at the job site. Source separation may lead to higher recycling rates and lower recycling costs. Further guidance can be found at: https://recyclingworksma.com/construction-demolition- materials-guidance/

For more information on how to prevent banned materials from entering the waste stream the Proponent should contact the RecyclingWorks in Massachusetts program at (888) 254-5525 or via email at [email protected]. RecyclingWorks in Massachusetts also provides a website that includes a searchable database of recycling service providers, available at http://www.recyclingworksma.com.

2. Building Demolition and Asbestos Containing Waste Material: The Project Proponent is advised that demolition activity must comply with both Solid Waste and Air Quality Control regulations. Please note that MassDEP promulgated revised Asbestos Regulations (310 CMR 7.15) that became effective on June 20, 2014. The new regulations contain requirements to conduct a pre- demolition/renovation asbestos survey by a licensed asbestos inspector and post abatement visual inspections by a licensed asbestos Project monitor. The Massachusetts Department of Labor and Work Force Development, Division of Labor Standards (DLS) is the agency responsible for licensing and regulating all asbestos abatement contractors, designers, Project monitors, inspectors, and analytical laboratories in the state of Massachusetts.

3. In accordance with the revised Asbestos Regulations at 310 CMR 7.15(4), any owner or operator of a facility or facility component that contains suspect asbestos containing material (ACM) shall, prior to conducting any demolition or renovation, employ a DLS licensed asbestos inspector to thoroughly inspect the facility or facility component, to identify the presence, location and quantity of any ACM or suspect ACM and to prepare a written asbestos survey report. As part of the asbestos survey, samples must be taken of all suspect asbestos containing building materials and sent to a DLS certified laboratory for analysis, using USEPA approved analytical methods.

4. If ACM is identified in the asbestos survey, the Proponent must hire a DLS licensed asbestos abatement contractor to remove and dispose of any asbestos containing material(s) from the facility or facility component in accordance with 310 CMR 7.15, prior to conducting any demolition or renovation activities. The removal and handling of asbestos from the facility or facility components must adhere to the Specific Asbestos Abatement Work Practice Standards required at 310 CMR 7.15(7). The Proponent and asbestos contractor will be responsible for submitting an Asbestos Notification FormANF-001 to MassDEP at least ten (10) working days prior to beginning any removal of the asbestos containing materials as specified at 310 CMR 7.15(6).

5. The Proponent shall ensure that all asbestos containing waste material from any asbestos abatement activity is properly stored and disposed of at a landfill approved to accept such material in accordance with 310 CMR 7.15 (17). The Solid Waste Regulations at 310 CMR 19.061(3) list the requirements for any solid waste facility handling or disposing of asbestos waste. Pursuant to 310 CMR 19.061(3) (b) 1, no asbestos containing material; including VAT, asphaltic-asbestos felts, or shingles; may be disposed at a solid waste combustion facility.

6. In accordance with the Air Quality Regulations at 310 CMR 7.09(2), the Proponent must submit a BWP AQ 06 Notification Prior to Construction or Demolition form to MassDEP for any construction or demolition of an industrial, commercial, or institutional building or residential building with 20 or more dwelling units at least ten (10) working days prior to initiation of said

EEA No. 16335 March 16, 2021 construction or demolition Project. The Proponent should propose measures to prevent or alleviate dust, noise, and odor nuisance conditions, which may occur during the demolition.

7. Asphalt, brick, and concrete (ABC) rubble, such as the rubble generated by the demolition of buildings must be handled in accordance with Massachusetts solid waste regulations. These regulations allow, and MassDEP encourages, the recycling/reuse of ABC rubble. The Proponent should refer to MassDEP's Information Sheet, entitled "Using or Processing Asphalt Pavement, Brick and Concrete Rubble, revised February 27, 2017", that answers commonly asked questions about ABC rubble and identifies the provisions of the solid waste regulations that pertain to recycling/reusing ABC rubble. This policy can be found on-line at the MassDEP website: https://www.mass.gov/files/documents/2018/03/19/abc-rubble.pdf

If you have any questions regarding the Solid Waste Management Program comments above, please contact Mark Dakers at (508) 946-2847 or Cynthia Baran at (508) 946-2887.

Proposed s.61 Findings The “Certificate of the Secretary of Energy and Environmental Affairs on the Environmental Notification Form” may indicate that this Project requires further MEPA review and the preparation of an Environmental Impact Report. Pursuant to MEPA Regulations 301 CMR 11.12(5)(d), the Proponent will prepare Proposed Section 61 Findings to be included in the EIR in a separate chapter updating and summarizing proposed mitigation measures. In accordance with 301 CMR 11.07(6)(k), this chapter should also include separate updated draft Section 61 Findings for each State agency that will issue permits for the Project. The draft Section 61 Findings should contain clear commitments to implement mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation, and contain a schedule for implementation.

Other Comments/Guidance The MassDEP Southeast Regional Office appreciates the opportunity to comment on this ENF. If you have any questions regarding these comments, please contact George Zoto at (508) 946-2820.

Very truly yours,

Jonathan E. Hobill, Regional Engineer, Bureau of Water Resources JH/GZ

Cc: DEP/SERO

ATTN: Millie Garcia-Serrano, Regional Director David Johnston, Deputy Regional Director, BWR Gerard Martin, Deputy Regional Director, BWSC Seth Pickering, Deputy Regional Director, BAW Jennifer Viveiros, Deputy Regional Director, ADMIN Dan Gilmore, Chief, Wetlands and Waterways, BWR

EEA No. 16335 March 16, 2021 David Hill, Wetlands and Waterways, BWR Duane LeVangie, Chief, Water Management Act, BWR/Boston Shi Chen, Water Management Act, BWR/Boston Dan DiSalvio, Chief, Compliance and Enforcement, BAW Cynthia Baran, Chief, Asbestos, BAW Mark Dakers, Chief, Solid Waste, BAW Alison Cochrane, Solid Waste, BAW Elza Bystrom, Solid Waste, BAW Kathryn Carvalho, Site Management, BWSC Allen Hemberger, Site Management, BWSC

March 22, 2021

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

RE: Canton: Plymouth Rubber Redevelopment – ENF (EEA #16335)

ATTN: MEPA Unit Erin Flaherty

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Environmental Notification Form for the Plymouth Rubber Redevelopment project in Canton, 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

Plymouth Rubber Redevelopment Page 2 3/22/2021 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division John McInerney, P.E., District 6 Highway Director Neil Boudreau, Assistant Administrator of Traffic and Safety Engineering Planning Board, Town of Canton Metropolitan Area Planning Council Massachusetts Bay Transportation Authority Neponset Valley Transportation Management Association

MEMORANDUM

TO: David Mohler, Executive Director Office of Transportation Planning

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

DATE: March 22, 2021

RE: Plymouth Rubber Redevelopment – ENF (EEA #16335)

The Public/Private Development Unit (PPDU) has reviewed the Environmental Notification Form (ENF) for the proposed Plymouth Rubber Redevelopment project in Canton. The project site consists of approximately 41.9 acres of land bounded by Revere Street to the northeast, the Diversion Channel to the south, the Diversion Channel and the MBTA rail line to the west, and the MBTA rail line to the north. Before redevelopment began, the site was vacant and contaminated by former industrial uses associated with the Revere Copper Company Works and the Plymouth Rubber Company. The site contained structures constructed between 1945 and 1970.

The full build project consists of 272 residential units; 5,650 square feet (sf) of restaurant space; 5,650 sf of office/function/exhibit space; 1,600 sf of exhibit space; 1,600 sf of function space; 8,000 sf of commercial space, and up to 40,000 sf of light industrial space. A local Special Permit/Site Plan Approval was issued for the site in 2016. The project will be constructed in four phases. The first three phases are complete or are currently under construction. The final phase includes two residential buildings.

The full-build project will include 700 parking spaces and is expected to generate 2,252 vehicle trips per day. Access is provided via Revolution Way, which connects to Neponset Street via a new bridge in the southwest, and Revere Street in the northeast. Access to other sections of the project is provided via driveways along Revere Street. The project parking provision and trip generation exceed the Massachusetts Environmental Policy Act (MEPA) ENF transportation thresholds.

A building that is part of the fourth phase is proximate to the MBTA rail right-of-way, therefore the project may require a license from the MBTA for work within the MBTA Zone of Influence. Final determination regarding the need for this license will be determined after initial design review. As noted in the ENF the project, as originally approved by the Town, did not include construction within the MBTA Zone of Influence and the Zone of Influence was not formally established at that time. In addition, the Proponent will require an MBTA

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

Plymouth Rubber Redevelopment Page 2 3/22/2021

License for Entry Upon MBTA Property to construct a sidewalk extension within the MBTA parcel adjacent to the project site. This license was previously obtained but expired before work on the project began.

The project includes a new roadway bridge over the Diversion Channel extending Revolution Way to Neponset Street, which has been constructed. Construction of this bridge required agency action; however, this project was requested by the Town to meet their needs, separate from impacts created by the development of the project.

The ENF adequately discusses the transportation impacts of the project.

Multimodal Access and Improvements

The project is located within 0.4 miles of two MBTA Commuter Rail stations, the Canton Junction Station and the Canton Center Station, served by the Providence/Stoughton rail line. The Proponent has committed to constructing a lighted multi-use path connecting Canton Center and nearby neighborhoods with the Canton Junction Commuter Rail Station, using an existing rail spur. MassDOT asks that the Proponent ensure that the project contains safe and clear pedestrian pathways between this path as well as other entrances to the project, and the building entrances.

The Proponent has committed to reconstructing Revere Street, including sidewalk improvements and improved bike accommodations. This reconstruction is in progress. As mentioned above, the Proponent constructed a bridge over the Diversion Channel to connect Revolution Way with Neponset Street. This improvement was requested by the Town to improve fire safety response times. In conjunction with the new bridge, the Proponent completed intersection improvements and signalization at the intersection of Neponset Street at Norfolk Street/Revolution Way.

Transportation Demand Management (TDM)

The ENF states that a TDM plan will be developed as part of the project. The TDM plan will be targeted primarily at the employees of the site, but it will also include measures oriented toward the residents of the site. The ENF states that the Proponent will consult with the Neponset Valley Transportation Management Association (TMA) to determine if membership in the TMA would be appropriate given the primarily residential nature of the project. Discussions with the TMA will include strategies directed at both employees and residents.

MassDOT recommends that no further environmental review be required based on transportation-related issues. The Proponent should continue consultation with the Town of Canton and appropriate MassDOT units, including PPDU and the District 6 Office. If you have any questions regarding these comments, please contact me or Catrina Meyer at [email protected].