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

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 April 16, 2021

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE SINGLE ENVIRONMENTAL IMPACT REPORT

PROJECT NAME : Great Marsh Integrated Restoration Project1 PROJECT MUNICIPALITY : Ipswich, Essex, and Newbury PROJECT WATERSHED : Parker River EEA NUMBER : 16033/16210 PROJECT PROPONENT : The Trustees of Reservations DATE NOTICED IN MONITOR : March 10, 2021

Pursuant to the Massachusetts Environmental Policy Act (MEPA; M.G.L. c. 30, ss. 61-62I) and Section 11.08 of the MEPA regulations (301 CMR 11.00), I have reviewed the Single Environmental Impact Report (SEIR) and hereby determine that it adequately and properly complies with MEPA and its implementing regulations.

The expanded pilot project will consist of two components. The Proponent submitted an Expanded Notice of Project Change (ExNPC) for the Old Town Salt Marsh Restoration for the first component (EEA#16033) and an Expanded Environmental Notification Form (EENF) for the Great Marsh Restoration Phase II for the second component (EEA#16210) in May 2020. These components, as described in the two separate filings, were submitted concurrently and reviewed in the combined Certificate on the ExNPC and EENF, which was issued on July 17, 2020. The Certificate required the Proponent to file a SEIR that addresses both components of the expanded pilot project in accordance with the Scope outlined therein.

As noted above, this nature-based restoration initiative expands upon the previous pilot project at the Old Town Hill Reservation in Newbury (EEA# 16033), which is intended to restore the vital functions of salt marshes in providing habitat, recreation, and coastal resiliency benefits. I appreciate the participation of the many agencies and project partners in this pilot project, including the Massachusetts Division of Ecological Restoration (DER), U.S. Fish and Wildlife Service, and Massachusetts Bays

1 Project names were previously noted as the Old Town Hill Salt Marsh Restoration and Great Marsh Restoration Phase II. EEA# 16033/16210 SEIR Certificate April 16, 2021

National Estuary (MassBays) Program, for applying their collective experience and expertise to maximize the environmental benefits of the project.

By conducting proposed ditch remediation at a larger scale than previous efforts, and with the addition of the micro-runneling technique, the goal of the pilot project is to demonstrate the efficacy of this integrated approach as a restoration strategy at the landscape level. The Proponent anticipates that, as monitoring information from the expanded sites is made available on the success of these restoration techniques in the coming years, generalizations can be made as to its applicability under differing site conditions for additional projects. As requested by the Scope, the SEIR provides an understanding of where and when this approach may be transferable to other locations and how it should be applied in order for the project to successfully serve as a pilot for other salt marsh restoration projects.

Procedural History

The Proponent filed an EENF in May 2019 for the original pilot project that proposed restoration of approximately 85 acres of salt marsh within the Old Town Hill Reservation (EEA#16033). The original pilot project was intended to address the impacts of historic agricultural and mosquito control ditches that have interfered with natural tidal drainage and resulted in water logging of the peat substrate, subsidence of the marsh, and loss of vegetation. The restoration approach will encourage revegetation by creating conditions that would allow natural processes to restore elevation of the salt marsh and vegetation over time without ongoing intervention. Specifically, the Proponent would hand- mow, collect, loosely braid, and secure bundles of salt marsh hay to the bottom of pre-selected ditches in the marsh (ditch remediation technique). This technique slows tidal flow, encourages the deposition of sediment from the water column, and facilitates accelerated peat development and revegetation by native salt marsh species, particularly Spartina alterniflora. Upon completion of the project, tidal flow would be directed to the untreated ditches, identified as primary channels. The increased rate of flow in the primary channels would bring the site closer to the single-channel hydrology of a healthy and resilient salt marsh. The original pilot project also included the hand removal of small clogs within identified primary channels (up to four feet in length), which are caused by slumping peat, to minimize the potential that flow will be diverted around the blockages, causing unnecessary erosion of the marsh plain. The original project proposed treating 138 auxiliary ditches (once a year for three years) and reopening nine small blockages to encourage flow. Proposed post-restoration monitoring included an evaluation of vegetative cover using one square meter plots in transects along a select sampling of both treated and untreated ditches. Success of the ditch remediation restoration technique would be measured by the establishment of native salt marsh vegetation on the ditch bottoms.

The EENF for Old Town Hill Reservation (EEA#16033) included a request for a full waiver of the mandatory EIR. The Certificate on the EENF was issued on June 28, 2019 and a Final Record of Decision (FROD) was issued on July 26, 2019 that granted a waiver from the requirement to prepare a mandatory EIR for the original pilot project. The original pilot project obtained all permits and approvals at the end of 2019. Initial restoration efforts involving ditch remediation treatments with harvested saltmarsh hay at this site were completed during the summer and fall of 2020; refinement and efficiencies of technique will be developed which will be used to inform implementation at the other sites. Post-treatment vegetation and elevation monitoring data collection will not start until the six-week tidal cycle in spring/summer of 2021 and this data is expected to be available summer of 2021.

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Expansion of Pilot Project

The ExNPC (EEA#16033) and EENF (EEA#16210) reviewed in the July 17, 2020 Certificate2 described the Proponent’s intention to expand the previously permitted pilot project to include additional areas in Newbury, Essex and Ipswich. The continued goal for the expanded pilot project is to reverse the trend of salt marsh subsidence, reestablish and maintain high marsh habitat, support native obligate marsh species such as the at-risk salt marsh sparrow, and to improve coastal resiliency to Sea Level Rise (SLR). If successful, this pilot project may restore up to an additional 273 acres of salt marsh in the Great Marsh Area of Critical Environmental Concern (ACEC) for a total of up to 358 acres.3 In addition to the techniques used in the original pilot project, the expanded pilot project proposes a supplemental restoration technique called micro-runneling, which involves the construction of swales/ditches to direct surface tidal water to the new ditches in order to encourage peat formation and eventual revegetation of the ditch with salt marsh grasses. The ExNPC proposed activities to restore salt marsh within 30 additional acres3 in the adjacent William T. Forward Wildlife Management Area (WMA) in Newbury, which is owned and managed by the Massachusetts Division of Fisheries and Wildlife (DFW). The EENF proposed restoration of 243 acres of salt marsh within the Great Marsh ACEC, including 132 acres at the Crane Reservation in Ipswich and 111 acres in the Crane Wildlife Reservation and adjoining Stavros Reservation in Essex, which are both owned and managed by the Proponent.

The projects in Ipswich, Essex, and the expanded area in Newbury are considered an expansion of the initial pilot in Newbury that will test the ditch remediation technique over a broader range of tidal conditions in different areas of the Great Marsh. The hydro-period for each project area differs based on slope, elevation, and proximity to the ocean. In addition, the expanded areas provide an opportunity to introduce a secondary restoration technique to the pilot program of overall adaptive ditch management strategy, specifically the use of micro-runnels and the formation of bird islands from the resulting marsh sod. Micro‐runneling is proposed to address targeted areas where more advanced subsidence has occurred. This process consists of creating shallow linear swales to restore drainage in areas that once contained natural channels that were eliminated as part of past agricultural practices or are unrecoverable due to subsidence. According to the SEIR, this technique is proposed to expedite a natural process to break down mega-pools created by historic agricultural and mosquito control uses by encouraging tidal flows, drainage, peat formation, and eventual revegetation of the ditch with salt marsh grasses. The project also proposes to enhance wildlife habitat by reusing the excavated marsh sod collected during runnel construction to create small nesting areas of high marsh to benefit saltmarsh sparrow (Ammodramus caudacutus), a state-listed rare species. The SEIR indicates that the project design for these areas has been developed with careful attention to site specific conditions, and that other combinations of restoration techniques may be more applicable in other locations.

Project Site

The original 85-acre pilot project site is located within the Old Town Hill Reservation in Newbury. The expanded 30‐acre project area in Newbury is located at the William T. Forward WMA. It extends around Kent’s Island from the upland edge to the banks of the Little River along the south and eastern portion of the site and to the north and west. The Little River, tributary to the Parker River, winds through the site as it does within the original project area. Previous salt marsh restoration efforts

2 In addition to supplemental information provided to the MEPA Office on June 15, 2020. 3 The Certificate on the ExNPC and EENF noted the total salt marsh restoration as 378 acres; however, the reduction of the expansion at the Newbury site from 50 acres to 30 acres as described in the SEIR, reduced this total amount to 358 acres.

3 EEA# 16033/16210 SEIR Certificate April 16, 2021

have been conducted at the project site, including the completion of the new Kent’s Island bridge which eliminated a tidal obstruction and severe erosion at the site of the old culvert, enabling restoration of 47 acres of salt marsh. Despite these improvements, changes to the drainage of large sections have led to changes in the extent and type of vegetation within the marsh, created large areas of mud flats and interconnected pools, and converted areas from high marsh (i.e. Spartina patens) to low marsh (i.e. Spartina alterniflora). Within the expanded project area in Newbury, there are the remnants of a total of 161 historic agricultural embankments and 102 ditches, which are in addition to the 51 agricultural embankments and 219 ditches in the original project.

The expanded 243-acre project area includes two separate locations at Crane Reservation in Ipswich and the Crane Wildlife Reservation in Essex. The 132-acre Ipswich site includes salt marsh to the east and west side of Argilla Road at the approach to the Crane Beach parking area. This site contains 150 historic agricultural embankments and 229 ditches associated with former agricultural and mosquito control activities. Both the western and eastern marsh sections have experienced excessive historic ditching, and vegetation loss is readily observable especially in the western section near Argilla Road. The unmaintained historic ditches have changed the extent and type of vegetation within the marsh, created large areas of mud flats and interconnected pools, and converted areas from high marsh (i.e. Spartina patens) to low marsh (i.e. Spartina alterniflora). The Proponent, with funding from the Massachusetts Office of Coastal Zone Management (CZM), is currently in the design phase of a project (EEA#16227) to elevate Argilla Road and potentially address tidal restrictions in the area. The proposed ditch remediation work is expected to compliment, rather than interfere with, planned resiliency measures for the roadway.

The 111-acre Essex site is located approximately one mile south of the Ipswich site and is located within the Crane Wildlife Refuge with a small portion in the southwest within the Stavros Reservation. This site contains 110 historic agricultural embankments, 85 naturalized tidal channels and 310 ditches. There are few roads or culverts in this area to interfere with tidal exchange. However, the ditch network is complicated and excessive ditching is believed to have contributed to subsidence at this location. The site was selected due to its inclusion in CZM’s Tidal Marsh Sentinel Site Program, which was developed to collect and analyze data to inform management of sensitive coastal locations. The site also represents a good example of a platform marsh, or a marsh that is located a significant distance from shore, and provides an opportunity for restoration to protect the John Wise Avenue causeway, which is the only means of accessing Lowe Island.

Wetland resource areas within the project areas include Salt Marsh, Riverfront Area (RFA), and Land Subject to Coastal Storm Flowage (LSCSF). The site is located within the designated Great Marsh ACEC, which is also an Outstanding Resource Water (ORW). The project site is located in Priority and Estimated Habitat as mapped by DFW’s Natural Heritage and Endangered Species Program (NHESP). According to the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM), the project site is located within the designated 100-year floodplain (Zone AE).

Environmental Impacts and Mitigation

Potential environmental impacts are associated with the alteration of wetland resources, a necessary component of a salt marsh restoration project. The entire project site is within the Great Marsh ACEC. The restoration projects collectively will alter the hydrology of up to 358 acres of Salt Marsh. The original project in Newbury would directly impact 14.2 acres of salt marsh and LSCSF, and 8.57 acres of RFA, and alter the hydrology of 85 acres of salt marsh. Tables 6 and 7 of the SEIR summarize

4 EEA# 16033/16210 SEIR Certificate April 16, 2021 impacts associated with ditch remediation, mowing, clog removal, construction of micro-runnels and creation of nesting islands as part of the expanded pilot project within Salt Marsh, LSCSF, RFA, and ACEC.

Measures to minimize construction period impacts include the following: conducting restoration work during neap tide cycles; adhering to all time-of-year (TOY) restrictions; minimizing introduction of invasive species; restoring unintended impacts to wetland resource areas; selecting a restoration method that does not require use of heavy equipment and is reversible in the event of unforeseen outcomes; and providing a performance bond to ensure that any reasonably anticipated adaptive management measures following project implementation can be addressed (amount will be equal to the total construction cost of the project). A comprehensive monitoring program will be developed to build on data collected in prior pilot projects and in this salt marsh system to gauge the efficacy of restoration efforts. The provision of adaptive management and specific benchmarks for success or intervention are crucial aspects of the project design as they will allow early indications as to the success of the project, as well as the identification of any unexpected changes, which can be immediately avoided or mitigated.

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Jurisdiction and Permitting

The project is subject to MEPA review and preparation of a mandatory EIR pursuant to 301 CMR 11.03(3)(a)(1)(a) and 301 CMR 11.03(3)(a)(1)(b) because it requires State Agency Actions and involves alteration of one or more acres of Salt Marsh and alteration of ten or more acres of any other wetlands (LSCSF and RFA). It also exceeds the ENF threshold at 301 CMR 11.03(11)(b) as it involves a project within a designated ACEC. The project will require a Chapter 91 (c. 91) License and 401 Water Quality Certification (WQC) from the Massachusetts Department of Environmental Protection (MassDEP) and review by NHESP. The project is subject to review under the May 2010 MEPA Greenhouse Gas (GHG) Emissions Policy and Protocol (“the Policy”).4

The project requires an Ecological Restoration Order of Conditions from the Conservation Commissions for Newbury, Ipswich and Essex (or in the case of an appeal, a Superseding Order of Conditions from MassDEP), submittal of a Pre-Construction Notification (PCN) to the U.S. Army Corps of Engineers (ACOE), and Federal Consistency Review from CZM.

Funding and technical assistance will be provided from DER and DFW. Because the project is receiving State Financial Assistance, MEPA jurisdiction is broad in scope and extends to all aspects of the project that may cause Damage to the Environment, as defined in the MEPA regulations.

Review of the SEIR

According to the SEIR, the overall project purpose is to restore vegetated salt marsh using integrated strategies to address landscape-level changes that appear to be occurring as a result of past human alterations, by restoring natural marsh hydrology to improve marsh resilience and its ability to respond to SLR. An understanding of the results of this pilot project on a landscape level is critical to evaluate the effectiveness of this innovative restoration technique and to assess potential unintended impacts to the marsh and identify any adjustments to the approach which may be needed as part of adaptive management. The SEIR describes the project, proposed monitoring, criteria that will be used to gauge project success, and triggers for implementation of adaptation actions to minimize the possibility of adverse impacts on the marsh as a result of the project.

CZM and MassDEP comments indicate their support for the Proponent’s research goals and work associated with understanding how to protect the long-term health of the Great Marsh and facilitate its ability to respond to climate change impacts, including SLR. CZM has worked with the Proponent towards these goals and continues to support opportunities to develop best management practices (BMPs) based on robust research. Prior to filing the SEIR, the Proponent extensively consulted with state agencies, including CZM and MassDEP to ensure that the SEIR was responsive to their comments provided on the prior MEPA documents and to the Scope. According to MassDEP comments, the Proponent has addressed all of the comments and recommendations outlined in their prior comment letters on the ExNPC and EENF. CZM and MassDEP will continue to work with the Proponent as the pilot project develops.

The expanded pilot project proposes ditch remediation, a less impactful technique for salt marsh restoration based on hand mowing and subsequent placement of salt marsh hay into treated ditches by

4 The Certificate issued on July 17, 2021 indicated that the project falls under the GHG Policy’s de minimis exemption and the Proponent was not required to prepare a GHG analysis.

6 EEA# 16033/16210 SEIR Certificate April 16, 2021 hand or blower to depths of eight to nine inches. This restoration strategy is proposed for 138 ditches as part of the original pilot project, and 62 ditches in the expanded Newbury site, 218 ditches in Ipswich, and 225 ditches in Essex. Within as early as one growing season, some ditch bottoms are expected to become fully vegetated as salt marsh grass becomes established and serves to bind new peat layers to the surrounding marsh. In addition, the SEIR identifies 47 discrete locations where small blockages or clogs in untreated primary channels will be opened (up to four feet) using hand tools to encourage flow. Sediment would not be removed or relocated from these channels. Proposed micro-runneling will involve excavation of shallow linear swales (four to six inches deep by 1.5-2.5 feet wide) using a low ground pressure (2.3 pounds per square inch (psi)) track loader to connect the swales to adjacent primary ditch channels (seven micro-runnel locations at the expanded Newbury site (1,916 linear feet (lf)), two in Ipswich (250 lf), and two in Essex (271 lf)). Excavated material will include primarily marsh sod, which will be transplanted to the nearby high marsh platform to create small nesting islands as habitat for saltmarsh sparrow.

Alternatives Analysis

In addition to the Preferred Alternative (as described herein), the SEIR includes an evaluation of the following alternatives: No Action; No Runnel; Revised Runnel; and several Nest Island alternatives. The No Action Alternative was dismissed as it would continue the pattern of vegetation loss and marsh subsidence, which will negatively impact the natural functions of the Great Marsh including its ability to provide resiliency from coastal storms and rising sea level. The SEIR emphasizes the need to address the loss of salt marsh associated with agricultural legacies and accelerated SLR and implement measures to stem these losses. The SEIR maintains that the resiliency of salt marshes can be improved through the use of evidence-based approaches to restore appropriate hydrology.

The Scope required that the SEIR consider an alternative project design which does not involve the use of micro-runnels. The SEIR argues that elimination of micro-runneling from the proposed suite of restoration measures would significantly reduce the ability of the project to address subsidence due to excess inundation (waterlogged subsidence). According to the SEIR, proposed construction of micro- runnels would result in a total of 0.46 acres of temporary alteration of marsh surface at all three sites, but it has the potential to directly enhance and restore a total of 11.73 acres, which represents the total area of the subsidence basins associated with each runnel. In addition, in some areas, ditches proposed for remediation would require adjustment to avoid potential additional waterlogging and subsidence. According to the SEIR, this alternative would also eliminate the opportunity to support and enhance rare species habitat through the construction of nest islands for a population experiencing decline.

The SEIR indicates that some form of runnels to address waterlogged subsidence has been used by others in previous projects in various marshes throughout New England. The technique proposed in this pilot project attempts to build upon the successes of these earlier projects, including adjustments to cross-sectional dimensions in response to observations of small clogs forming in narrow runnels constructed by others which required adaptive interventions. Table 5 (Runnel Comparisons) in the SEIR provides a list of runnel techniques and purposes and clarifies the standards for runnels proposed to be employed for this project. Runnels that are constructed by hand, called compression runnels, were not proposed due to the length of the runnels required to address the subsidence and the potential that runnels constructed in this manner would not result in establishment of adequate hydrologic exchange.

The SEIR indicates that alternatives to nesting islands include import of material which has the potential to introduce unwanted seed stock and may present permitting challenges, or no nest island

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alternative which would require the removal of material excavated during runnel construction. The no nest island alternative would eliminate any habitat enhancement and result in loss of vegetated material and sediment from the system when sediment and vegetation is critically needed to support a subsiding marsh. As described in the SEIR, the alternative of constructing nesting islands in upland locations adjacent to the marsh does not meet the habitat requirements for the salt marsh sparrow.

Wetlands, Waterways, Water Quality

While the project is proposed to improve the overall ecosystem functions of portions of the Great Marsh ACEC on a long-term basis, it will result in unavoidable impacts to wetland resource areas (Salt Marsh, RFA, and LSCSF). The project is proposed as an Ecological Restoration Project (ERP) pursuant to 310 CMR 10.13. The Newbury, Ipswich and Essex Conservation Commissions will review the project to determine its consistency with the Wetlands Protection Act (WPA), the Wetlands Regulations (310 CMR 10.00), and associated performance standards. The SEIR includes a description of the project’s consistency with applicable WPA performance standards and eligibility criteria for a Restoration Order of Conditions. MassDEP will review the project to determine its consistency with the Waterways Regulations (310 CMR 9.00) and the 401 WQC regulations (314 CMR 9.00). MassDEP comments indicate that the project qualifies as an Ecological Restoration limited project under the WPA Regulations and that a Variance should not be required. The project is subject to federal consistency review from CZM. The SEIR identifies how the project will be designed to be consistent with CZM's enforceable program policies.

Project goals include restoration of salt marsh degraded by anthropogenic influences through reestablishment of natural flow, sedimentation and revegetation processes, and management of declining salt marsh sparrow habitat. MassDEP comments indicate that although the ditch remediation technique is relatively new, it is an innovative approach that has been found to be successful at smaller scales in other locations, with no adverse impacts to marsh vegetation or function. The original pilot project was supported by MassDEP as it met the criteria of an Ecological Restoration Limited Project under the WPA. The expanded pilot project is proposed to demonstrate the efficacy of the overall adaptive management approach (ditch remediation at a larger scale than previous efforts and the addition of micro-runneling and bird islands) as a restoration strategy at the landscape level.

CZM comments note that because this pilot project is proposed to test the effectiveness of these management techniques to improve the resiliency of salt marshes not only within the proposed sites, but potentially regionally and at a landscape scale, documenting baseline conditions and conducting and documenting comprehensive monitoring and reporting throughout the course of this multi-year project are critical aspects. Monitoring for expected or unexpected changes, and implementing adaptive management as needed to avoid or mitigate impacts is necessary and important as marsh response to the proposed treatment methods is expected to be incremental over time, with hydrologic responses experienced first followed by vegetative changes. Table 10 in the SEIR provides a summary of the expected responses and adaptation actions for each proposed management technique, with specific benchmarks to indicate success or the need for intervention to avoid impacts at specific points in the project. These benchmarks will be important indicators of the preliminary success of the project as it moves forward. The Proponent should provide periodic reports as these benchmarks are reached to demonstrate ongoing success of the project and/or to highlight any adaptive management that is determined to be necessary. Comments from the Massachusetts Division of Marine Fisheries (DMF) request the Proponent provide project updates once restoration activities have commenced.

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The SEIR provides additional information to demonstrate that runneling will not produce unintended consequences. The SEIR provides an updated impact analysis that summarizes direct impacts for each project site and includes a breakdown of impacts in a narrative and tabular format associated with treatment of ditches through placement of the mowed hay, clearing of identified clogs, mowing of vegetation, excavation of micro-runnels, and creation of nesting islands. It also includes a detailed breakdown of temporary impacts to wetland areas in a narrative and tabular format. Impact analyses are provided in Tables 6 and 7 of the SEIR.

The SEIR states that determining the primary ditches and auxiliary ditch hierarchy is often complicated by unique ditching patterns, land use history, soil drainage conditions, upland influences and other factors and requires extensive empirical knowledge of salt marsh hydrology in general and site-specific conditions in particular as tidal flow may not follow a regular pattern. Because of these challenges, the SEIR recommends that this determination should not be attempted by unqualified individuals as restoration actions attempted with incorrect hydrology will lead to poor restoration results. CZM comments emphasize that the specific steps of the methodology for determining the correct hydrology that was used to design this project must be more specifically described during permitting if this restoration technique is to be replicated for other restoration projects in the future. As requested by CZM, the Proponent should develop and provide a detailed methodology describing the specific information and steps necessary to determine the primary and auxiliary ditch hierarchy so that this restoration technique can be replicated correctly in other locations as appropriate.

The Proponent completed a study of aquatic vegetation, with special attention to Ruppia maritima, within all three sites during the summer and fall of 2020. The SEIR indicates that while Ruppia occurs within a few pools within the project area, the project is not expected to result in significant loss of aquatic vegetation, and the conversion of the margins of these pools to marsh plain species is an indicator of successful restoration of more natural hydrology. The SEIR addresses monitoring and maintenance of new opened areas, where clogs within the channels are removed to avoid impacts from this activity. The Proponent should provide standard operating procedures during permitting which outline practices to avoid the transfer of invasive species on equipment, machinery, and hay from outside sources.

As previously indicated, portions of the Crane Marsh site in Ipswich are directly adjacent to the ongoing Argilla Road project (EEA#16227), which will elevate the road and have direct impacts on this portion of the salt marsh. The Proponent has consulted with the engineer of the Argilla Road project, to evaluate the relationship and interaction between the two projects to provide a better understanding of how the Argilla Road project may affect or intersect with the expanded pilot project. The SEIR indicates that hydrologic impacts to the salt marsh area subject to restoration are not anticipated because the major hydrologic changes caused by the roadway project will be upstream of the salt marsh. Potential long- term benefit to the salt marsh may occur through the introduction of a 3:1 side slope along the road, which will provide an opportunity for marsh migration as sea-level rises. Coordination will be required to address construction sequencing and managing construction traffic, parking, and staging. The Proponent will ensure that erosion and sedimentation is managed from the roadway project to avoid erosion within the marsh or sediment accumulation which could adversely alter the marsh plain or create opportunity for introduction by invasive species. The Proponent will review recent plans to install a new box culvert at Fox Creek at the Castle Hill entrance to determine any potential impact to the project.

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Rare Species

The project site is mapped as Priority and Estimated Habitat for the Eastern Whip-poor-will (Antrostomus vociferus), the Common Tern (Sterna hirundo) and Least Tern (Sterna antillarum) according to the Massachusetts Natural Heritage Atlas (14th Edition). These species and their habitat are protected pursuant to the Massachusetts Endangered Species Act (MESA; MGL c.131A) and its implementing regulations (321 CMR 10.00). NHESP comments indicate that it anticipates that the project will likely qualify for the habitat management exemption from the MESA review process pursuant to 321 CMR 10.14(15) as “the active management of State-listed species habitat…for the purpose of maintaining or enhancing the habitat for the benefit of rare species” carried out in accordance with an approved habitat management plan. The Proponent has submitted a preliminary habitat management plan to NHESP for review and approval prior to initiating work. This plan will include a timing restriction on work between May 15 and August 31 on the Ipswich and Essex sites to avoid disruption to foraging/nesting activities of state-listed terns. The SEIR provides an update on consultations with NHESP and indicates that work will comply with all TOY restrictions required for the protection of rare species and their habitat.

Climate Change and Resiliency

The protection and restoration of wetlands plays an increasingly important role in promoting ecosystem resiliency and mitigating climate change impacts. Revegetating these ditches is proposed to reverse the trend of salt marsh subsidence and enhance its ability to reduce wave energy and absorb storm surge in the face of SLR. Through the Commonwealth’s Municipal Vulnerability Preparedness (MVP) program, the Towns received funding to conduct a planning process for climate change resiliency and implementing priority projects; separate municipal reports indicated that restoration of the Great Marsh was identified as a high priority action to improve resiliency. Through the MVP Program, the Towns will have access to technical support and funding for project implementation.

The SEIR provides a discussion regarding the effects of climate change and SLR on the Great Marsh and describes how the project will further improve resiliency. The Proponent and the Woods Hole Group, Inc. recently prepared a North Shore State of the Coast report which used results from the Massachusetts Coast Flood Risk Model (MC-FRM)5 to determine future projected chronic and storm- based flooding. Table 2 in the SEIR presents elevations using this method for the three towns within the project area.

Based on the data, the SEIR indicates that the project area is experiencing a higher rate of SLR than current global projections of 3.3 millimeters per year (mm/yr) (0.13 inches). To adapt to SLR, the marsh must gain elevation (accrete) at a rate equal to or greater than SLR to prevent drowning and

5 MC-FRM includes SLR associated with the “high” projections, which assumes that global GHG emissions continue in a similar manner as today.

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conversion to mudflats. Salt marshes may withstand changes to SLR based on their ability to expand to upland areas. The SEIR asserts that the potential for any significant migration or expansion of the Great Marsh to accommodate this increasing volume is generally limited because of development along much of the coast and typically steep upland topography. Table 3 in the SEIR depicts current estimated Great Marsh accretion rates.6 Based on these projections, the total area of high marsh loss estimated by 2050 is 108 acres in Newbury, 322 acres in Ipswich and 263 in Essex.

The Great Marsh is a system which contains both low suspended sediment concentrations, which can only withstand fairly low rates of relative SLR and steep inland topography. The marsh slope is very low and mostly uniform and contains a high tidal range (meso to macrotidal). Within a portion of the Great Marsh (Plum Island Sound), accretion rates were estimated to be 2.85 mm/yr on high marsh which is below that needed to keep up with SLR. The SEIR summarizes modeling results on the effects of SLR on the Great Marsh based on varying estimates of SLR. In year 2020, the marsh is estimated to contain 76 percent high marsh and 24 low marsh. High marsh is projected to convert to low marsh almost immediately with rapid acceleration around 2040 until all high marsh is replaced by low marsh by 2055- 2065. The SEIR attributes the marsh’s persistence for several decades to the mesotidal range of this area despite the limitations of sediment availability. Conversion to low marsh was also projected to increase the tidal prism, altering the marsh’s hydrodynamics, and leading to other negative feedbacks for the variety of wildlife that depend on high marsh. This study indicates the vulnerability of the Great Marsh and others with low sediment supply and/or steep inland topography.

The SEIR indicates that scientific evidence is steadily accruing that neither tidal sediment deposition nor biomass accumulation is occurring at a rate sufficient to keep up with SLR within the Great Marsh and that restoration strategies are needed to maintain marsh viability into the future. The project’s proposed restoration strategies are intended to address this point by correcting tidal hydrology altered by past practices which are hindering marsh building and to further encourage plant productivity.

Construction Period

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

6 Estimate based on applying the Marsh Equilibrium Model.

11 EEA# 16033/16210 SEIR Certificate April 16, 2021

Mitigation and Draft Section 61 Findings

The SEIR contains a separate chapter on mitigation measures and draft Section 61 Findings. It describes mitigation measures and contains clear commitments to mitigation. The draft Section 61 Findings will serve as the primary template for State Agency Permit conditions. Minor temporary and unavoidable impacts to wetland resource areas will be mitigated through pre-construction, construction and post-construction BMPs (Section 7 of the SEIR), including careful timing of construction, use of appropriate equipment, measures to minimize introduction of invasive species, proper implementation, monitoring and compliance with local state and federal permits and approvals. Extensive pre- and post- restoration monitoring (Section 9 of the SEIR) will allow the tracking of multiple success criteria, and the early identification of any inadvertent or unforeseen circumstances. Potential adaptive management measures to address unanticipated conditions have been considered and identified based on similar project types and past contractor experience (Section 9.8 and Table 10 of the SEIR). The monitoring effort proposed will add to the scientific understanding of salt marsh function which will be useful in the design and management of potential future salt marsh restoration projects. The Proponent has made a long-term commitment to the successful completion of this project, including securing a performance bond to ensure funding is available for unforeseen adaptive management measures. The project will advance the resiliency of the salt marsh to adapt to climate change and specifically SLR.

The project will require final Ecological Restoration Order of Conditions for each of the three sites in Newbury, Ipswich and Essex pursuant to 310 CMR 10.00 (these Orders will also serve to meet the requirements of a WQC under 314 CMR 9.03; c. 91 Waterways License (water-dependent) for placement of material (hay) below mean high water within existing tidal ditches pursuant to 310 CMR 9.00; and CZM Federal Consistency Review.

Conclusion

Based on a review of the SEIR and consultation with State Agencies, I find that it adequately and properly complies with MEPA and its implementing regulations. The project may proceed to permitting. State Agencies should forward copies of the final Section 61 Findings to the MEPA Office for publication in accordance with 301 CMR 11.12.

April 16, 2021 ______Date Kathleen A. Theoharides

Comments received:

03/31/2021 Massachusetts Natural Heritage and Endangered Species Program (NHESP) 04/02/2021 Massachusetts Division of Marine Fisheries (DMF) 04/08/2021 Massachusetts Office of Coastal Zone Management (CZM) 04/09/2021 Massachusetts Department of Environmental Protection (MassDEP) – Northeast Regional Office (NERO)

KAT/PPP/ppp

March 31, 2021

Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs Attention: MEPA Office Purvi Patel, EEA No. 16210 and 16033 100 Cambridge St. Boston, Massachusetts 02114

Project Name: Great Marsh Integrated Restoration Project Proponent: The Trustees of Reservations Location: Ipswich, Essex, Newbury Document Reviewed: Single Environmental Impact Report EEA No.: 16210, 16033 NHESP No.: 20-39324, 08-25343

Dear Secretary Theoharides:

The Natural Heritage & Endangered Species Program of the Massachusetts Division of Fisheries & Wildlife (the “Division”) has received and reviewed the Single Environmental Impact Report (SEIR) for the proposed GREAT MARSH INTEGRATED RESTORATION PROJECT (the Project) and would like to offer the following comments regarding state-listed species and their habitats.

The Project site is mapped as Priority Habitat and Estimated Habitat for the Common Tern (Sterna hirundo), Least Tern (Sterna antillarum), and Eastern Whip-poor-will (Antrostomus vociferus) according to the Massachusetts Natural Heritage Atlas (14th Edition). All three species are state-listed as Special Concern. These species and their habitats are protected pursuant to the Massachusetts Endangered Species Act (MGL c.131A) and its implementing regulations (MESA; 321 CMR 10.00). Fact Sheets for these species can be found on our website, www.mass.gov/nhesp.

As proposed, the Project will occur in Essex, Ipswich, and Newbury. In Essex, management will occur on 111 acres at the Crane Wildlife Refuge and Stavros Reservation. In Ipswich, management will occur on 132 acres within the Crane Reservation and in Newbury, management will occur on 85 acres of the Old Town Hill Reservation. The management proposed at each location focuses on salt marsh restoration through remnant agricultural ditch remediation, removing blockages to facilitate tidal flow in existing ditches, and restoration of select historic creek channels through runneling.

All projects proposed within Priority Habitat, which are not otherwise exempt from review pursuant to 321 CMR 10.14, will require review through a direct filing with the Division pursuant to the Massachusetts Endangered Species Act (M.G.L. c. 131A) and its implementing regulations (MESA; 321 CMR 10.00). The MESA is administered by the Division and prohibits the Take of state-listed species, which is defined as “in reference to animals…harm…kill…disrupt the nesting, breeding, feeding or migratory activity…and in

EIR, Essex, Ipswich, Newbury, EEA 16210 and 16033, page 2 of 2 reference to plants…collect, pick, kill, transplant, cut or process…Disruption of nesting, breeding, feeding, or migratory activity may result from, but is not limited to, the modification, degradation, or destruction of Habitat” of state-listed species (321 CMR 10.02).

Although the Division has not yet received a direct filing pursuant to the MESA for the proposed salt marsh restoration activities, the Division notes that the proposed project may qualify pursuant to 321 CMR 10.14 (15), which states that “[t]he following Projects and Activities shall be exempt from the requirements of 321 CMR 10.18 through 10.23…”

[15] the active management of State-listed Species habitat, including but not limited to mowing, cutting, burning, or pruning of vegetation, or removing exotic or invasive species, for the purpose of maintaining or enhancing the habitat for the benefit of rare species, provided that the management is carried out in accordance with a habitat management plan approved in writing by the Division and;

The Division anticipates that any state-listed species concerns can be addressed during the MESA review process. As our MESA review of the project is not complete, no alteration to the soil, surface, or vegetation and no work associated with the proposed project shall occur on the property until the Division has made a final determination.

If you have any questions about this letter, please contact Rebekah Zimmerer, Endangered Species Review Biologist, at (508) 389-6354 or [email protected]. We appreciate the opportunity to comment on this project.

Sincerely,

Everose Schlüter, Ph.D. Assistant Director cc: Town of Ipswich Select Board Town of Ipswich Planning Board Town of Ipswich Conservation Commission Town of Essex Select Board Town of Essex Planning Board Town of Essex Conservation Commission Town of Newbury Select Board Town of Newbury Planning Board Town of Newbury Conservation Commission Mary Rimmer, Rimmer Environmental Consulting

From: Frew, Katelyn (FWE) To: Patel, Purvi (EEA) Subject: EEA#16033 and #16210 Salt marsh restoration Date: Friday, April 2, 2021 11:26:06 AM

Hi Purvi, MA DMF has been reviewing this project since 2019. We have no resource concerns or comments at this time, we’ve just requested to different permitting agencies over that past 2 years that DMF receive a copy of the post-treatment monitoring report being conducted by the UNH Marine Lab. Thanks Kate

Kate Frew Environmental Analyst MA Division of Marine Fisheries 30 Emerson Avenue Gloucester, MA 01930 phone: 978-282-0308 x157

MEMORANDUM

TO: Kathleen A. Theoharides, Secretary, EEA ATTN: Purvi Patel, MEPA Office FROM: Lisa Berry Engler, Director, CZM DATE: April 8, 2021 RE: EEA-16033/16210, Great Marsh Restoration Phase II; Newbury, Essex, and Ipswich

The Massachusetts Office of Coastal Zone Management (CZM) has completed its review of the above-referenced Single Environmental Impact Report (SEIR), noticed in the Environmental Monitor dated March 10, 2021. The activities are proposed to meet the stated goals of the project including restoring the salt marsh through re-establishment of natural flow, sedimentation and revegetation processes and the management of declining salt marsh sparrow (Ammodramus caudacutus). Because the proposed techniques have not been tested in Massachusetts or have previously only been employed at small-scale research sites, data to be developed from this pilot project may inform the design and implementation of similar projects throughout the coastal zone. We look forward to working with the project proponents as the pilot project develops and offer the following comments.

Project Description The SEIR proposes restoration activities affecting up to 132 acres at the Crane Reservation in Ipswich and 111 acres within the Crane Wildlife Refuge and adjoining Stavros Reservation in Essex, which are both owned and managed by The Trustees of Reservations (Trustees). This project was initially filed with MEPA as an Environmental Notification Form (EEA#16210). The SEIR states that the goal for these areas is to reverse the trend of salt marsh subsidence, re-establish and maintain high marsh habitat, support native obligate marsh species such as the at-risk salt marsh sparrow, and to improve coastal resiliency in the face of sea level rise. These sites were selected to expand a previously permitted pilot project begun within 85 acres of salt marsh at the Old Town Hill Reservation in Newbury, which is currently underway. The Newbury project is proposed to expand the original area by approximately 50 acres within the adjacent William T. Ford Wildlife Management Area, under a Notice of Project Change (#16033). These two projects have been combined into this SEIR. The SEIR states that the project is proposed to restore salt marsh by encouraging re-vegetation of the historic ditch network within the project sites, thereby restoring more natural drainage characteristics to the affected areas of marsh. The ditch remediation technique involves harvesting marsh hay by hand-mowing swaths of marsh parallel to the ditches to be treated. The mown hay is loosely braided and placed to depths of 8-9 inches within the pre-selected ditches, then secured with twine and wood stakes to the ditch bottom. The stated goal of this technique is to slow tidal flow within the ditches to allow sediment to settle out of the water column and create a substrate for the establishment of native salt marsh vegetation, particularly Spartina alterniflora. In addition to ditch remediation, a supplemental restoration technique identified as “micro‐runneling” is proposed at the expanded Newbury location, as well as in Ipswich and Essex, to address targeted areas where more advanced subsidence has occurred. This process involves forming shallow 4- to 6-inch-deep linear swales approximately 1.5-2.5 feet wide to restore drainage in areas that once contained natural channels. These runnels are to be constructed using a low ground pressure (2.3 psi) track loader. Material excavated will include primarily marsh sod, which is then proposed to be transplanted to the

nearby high marsh platform to create small nesting islands as habitat for saltmarsh sparrow. In addition, identified primary channels contain small blockages approximately 4-feet in length which are caused by slumping peat. Part of the restoration effort will involve re‐opening these blockages using hand tools to encourage flow without removing or relocating sediment. Although the increased tidal flow expected within these primary channels following treatment of the auxiliary ditches may eventually release the blockages naturally, addressing them during the treatment phase is proposed to minimize the potential that flow will be diverted around the blockages, causing unnecessary erosion of the marsh plain. According to the SEIR, the overall project goal is an increase in vegetated salt marsh using integrated strategies that can address landscape-level changes that appear to be occurring as a result of past human alterations, with the goal to restore natural marsh hydrology to improve marsh resilience and its ability to keep up with sea level rise.

Project Comments CZM supports the project team’s research goals and the important work of understanding how to protect the long-term health of the Great Marsh and facilitate its ability to respond to climate change impacts, including sea level rise. CZM has worked with the project partners toward these goals and continues to support opportunities to develop best management practices based on robust research. Since the filing of the ENF and NPC, the project team has worked closely with CZM to ensure that the SEIR describes the proposed project details, necessary monitoring, project success criteria, and adaptation actions to minimize the possibility of adverse impacts on the marsh as a result of these activities.

If successful, this pilot project may restore up to 273 acres of salt marsh in the Great Marsh Area of Critical Environmental Concern (ACEC). Success of this large-scale pilot restoration technique may have implications for other restoration efforts within the Great Marsh and areas with similar conditions, particularly where remnants of agricultural manipulations are present and impacting hydrology. As clarified during the review of the ENF and NPC for these projects, broadening the scope of the Newbury Old Town Hill Reservation restoration project and including the Ipswich and Essex projects as part of the initial pilot is intended to test these restoration techniques over a broader range of tidal conditions in different areas of the Great Marsh. In particular, the hydro-period for each project area differs due to slope, elevation, and proximity to the ocean. The expanded scope and geographic area also provide an opportunity to introduce the use of micro-runnels and the formation of bird islands from the marsh sod generated by the micro-runnels to the original pilot program of overall adaptive ditch management. Because this pilot project is proposed to test the effectiveness of these management techniques to improve the resiliency of salt marshes not only within the proposed sites, but potentially regionally and at a landscape scale, documenting baseline conditions and conducting and documenting comprehensive monitoring throughout the course of this multi-year project is critical. As marsh response to the proposed treatment methods is expected to be incremental over time, with hydrologic responses experienced first followed by vegetative changes, monitoring for expected or unexpected changes, and implementing adaptive management as needed to avoid or mitigate impacts is necessary and important. Table 10 in the SEIR provides a helpful summary of the expected responses for each proposed management technique, with specific benchmarks to indicate success or the need for intervention to avoid impacts at specific points in the project. These benchmarks will be important indicators of the preliminary success of the project as it moves forward. The proponent should provide periodic reports as these benchmarks are reached to demonstrate ongoing success of the project and/or to highlight any adaptive management that is determined to be necessary.

The SEIR states that determining the primary ditches and auxiliary ditch hierarchy is often complicated by unique ditching patterns, land use history, soil drainage conditions, upland influences and other factors and requires extensive empirical knowledge of salt marsh hydrology in general and site-specific conditions in particular as tidal flow may not follow a regular pattern. Because of these challenges, the SEIR recommends that this determination should not be attempted by unqualified individuals as restoration actions attempted with incorrect hydrology will lead to poor restoration results. The specific steps of the methodology for determining the correct hydrology that was used to design this project must be more specifically described if this restoration technique is to be replicated for other restoration projects in the future. The proponent should develop and provide a detailed methodology describing the specific information and steps necessary to determine the primary and auxiliary ditch hierarchy so that this restoration technique can be replicated correctly in other locations as appropriate.

As is recommended for any restoration project, standard operating procedures should be provided during permitting which outline practices to avoid the transfer of invasive species on equipment, machinery, and hay from outside sources.

The Essex project site is also one of three state-wide sentinel sites monitored by CZM as part of the Tidal Marsh Sentinel Site Program, which was developed to collect and analyze data for the purpose of informing management of sensitive coastal locations. The Trustees chose this location because it offers an opportunity to coordinate with existing agency monitoring work and expand on the existing monitoring efforts, which include both water level and vegetation monitoring. As discussed on April 9, 2021, the proponent should coordinate closely with CZM on the proposed timing of restoration activities near the monitoring area for the sentinel site so that both projects can proceed successfully.

Federal Consistency Review The proposed project is subject to CZM federal consistency review and if so must be found to be consistent with CZM's enforceable program policies. For further information on this process, please contact Robert Boeri, Project Review Coordinator, at [email protected], or visit the CZM web site at https://www.mass.gov/federal-consistency-review-program. cc: Kathryn Glenn, CZM Rachel Freed, DEP NERO Chrissy Hopps, DEP Waterways William Holt, Newbury Conservation Agent Ken Whittaker, Essex Conservation Agent Brendan Lynch, Ipswich Conservation Agent

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

April 9, 2021

Kathleen A. Theoharides, Secretary Executive Office of RE: Essex, Ipswich, Newbury Energy & Environmental Affairs Great Marsh Integrated Restoration Project 100 Cambridge Street EEA # 16033/16210 Boston MA, 02114

Attn: MEPA Unit

Dear Secretary Theoharides:

The Massachusetts Department of Environmental Protection Northeast Regional Office (MassDEP-NERO) has reviewed the Environmental Impact Report (EIR) for the proposed Great Marsh Integrated Restoration Project in Essex, Ipswich and Newbury. MassDEP provides the following comments.

Wetlands

MassDEP-NERO has completed its review of the Single EIR for the Great Marsh Restoration Project, Phase II in Essex, Ipswich and Newbury. The Project’s goals are to reverse salt marsh subsidence, re-establish and maintain high marsh habitat, support native obligate species such as the salt marsh sparrow (Ammodramus caudacutus), and improve coastal resiliency to sea level rise. The project proposes restoration activities in up to 132 acres at the Crane Reservation in Ipswich and 111 acres within the Crane Wildlife Refuge and adjacent Stavros Reservation in Essex. The sites were selected to expand a previously proposed pilot project in 85 acres of salt marsh at the Old Town Hill Reservation in Newbury, which is currently underway. The Old Town Hill Marsh project is undergoing MEPA review for an expansion of approximately 50 acres within the adjacent William T. Ford Wildlife Management Area under a Notice of Project Change (EEA 16033).

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

The ditch remediation project is intended to restore salt marsh by using hand-mowed and braided salt marsh hay placed by hand in selected ditches within the marsh. This method is intended to encourage the revegetation of the ditches by slowing tidal flow and allowing sediment to settle out to create a substrate for new salt marsh growth. Although the technique is relatively new, it is an innovative approach that has been found to be successful at smaller scales in other locations, with no adverse impacts to marsh vegetation or functions. The original pilot project (Newbury) proposed restoration of approximately 85 acres of salt marsh and was supported by MassDEP as it appears to meet the criteria of an Ecological Restoration Limited Project under the Wetlands Protection Act.

The SEIR proposes to apply the original technique for ditch remediation, and to add an additional restoration method, known as "micro- runneling," to target areas where marsh subsidence has been identified. This technique will be applied in the expanded Newbury location as well as in Ipswich and Essex. The method entails forming shallow (4-6 inch deep) linear swales approximately 1.5 - 2.5 feet wide to restore drainage in areas that contained natural channels in the past, but were eliminated as a result of agricultural activities or are unrecoverable due to subsidence. Runnels would be constructed using a low ground pressure (2.3 psi) track loader and would involve excavating marsh sod, which would be transplanted to the high marsh platform to create small nesting islands for salt marsh sparrow. In addition, primary channels that contain small blockages caused by slumping peat that are approximately 4 feet in length will be re-opened using hand tools to encourage flow. Sediment will not be removed or relocated from these channels.

The SEIR describes the overall project purpose as increasing vegetated salt marsh using integrated strategies to address landscape-level changes that appear to be occurring as a result of past human alterations. If successful, the project may result in the restoration of approximately 273 acres of salt marsh in the Great Marsh ACEC. As noted in CZM’s comments, with which MassDEP fully concurs, the pilot project will test the effectivness of techniques to improve the resiliency of salt marshes both locally and regionally. The proposed documentation of baseline conditions, monitoring and reporting are critical aspects of the project. The provision of adaptive management and specific benchmarks for success or intervention are crucial aspects of the project design as they will allow early indications as to the success of the project, as well as the identification of any unexpected changes, which can be immediately avoided or mitigated.

MassDEP supports the research goals of this project and has met several times with the project proponents, as well as consulting with CZM. The applicant has incorporated all of MassDEP’s and CZM’s comments and recommendations, particularly with regard to monitoring, success criteria and actions to minimize the possibility of adverse impacts to the marsh as a result of the project. Based on the information contained in the SEIR, it is MassDEP’s opinion that the project qualifies as an Ecological Restoration limited project under the Wetlands Protection Act Regulations, and that a Wetlands Variance should not be required.

The MassDEP appreciates the opportunity to comment on this proposed project. Please contact [email protected] at (978) 694-3258 for further information on wetlands issues. If you have any general questions regarding these comments, please contact me at [email protected] or at (978) 694-3304.

Sincerely,

John D. Viola Deputy Regional Director

cc: Brona Simon, Massachusetts Historical Commission Eric Worrall, Rachel Freed, MassDEP-NERO