Corey Schutzman Environmental Permitting New England Environmental Department January 4, 2021 Lowell Conservation Commission Attention: Louisa Varnum, Chair Lowell City Hall 375 Merrimack Street Lowell, MA 01852 RE: Boston Gas Company - Lowell Area Gas Modernization Project DEP File Number 206-0804 Members of the Conservation Commission: This letter responds to requests for information made by the Conservation Commission at its December 9, 2020 hearing regarding Boston Gas Company’s (“BGC”) Notice of Intent (“NOI”) concerning the Lowell Area Gas Modernization Project (the “Project”). In advance of the Commission’s upcoming January 13, 2021 meeting, BGC responds to questions on the following five topics: 1. Written responses to questions from the Lowell Sustainability Council; 2. Further explanation of potential wetlands impacts compared to the Project’s safety and reliability benefits; 3. Further description of BGC’s efforts to avoid and minimize wetlands impacts, specifically regarding the Project’s necessary 75 foot temporary work space width; 4. Potential modifications to the preferred alternative to minimize wetlands impacts; and 5. Engineering Plans. As described in BGC’s NOI and at the Commission’s December 9th hearing, the Project is the product of several years of extensive study, engineering and regulatory review. The Order of Conditions is the last permit required for the Project and the Commission’s jurisdiction is limited by the Wetlands Protection Act, the Department of Environmental Protection’s implementing regulations (the “DEP Regulations”) and the jurisdiction of other agencies, including the Massachusetts Energy Facilities Siting Board (EFSB or “Siting Board”). The Project’s purpose, need, route and potential impacts have been thoroughly reviewed, certified and approved by the Executive Office of Energy and Environmental Affairs under Massachusetts Environmental Policy Act (MEPA) and by the EFSB. The Siting Board’s certification of the Project under G.L. c. 164, § 69J was issued on September 26, 2019 (“Final Decision”). That decision included a finding that the Project is needed to facilitate enhanced inspection of the natural gas system in this area and that such improved inspection will increase the reliability and safety of the system. The Siting Board has also reviewed and approved BGC’s route selection process to ensure the proposed Project appropriately minimizes costs and environmental impacts. Because the Siting Board has previously considered route alternatives for this public utility Limited Project, the DEP Regulations at 310 CMR 10.53(3)(d)(1) expressly prohibit the selection of alternative routes in order to prevent an outcome that is inconsistent with the 40 Sylvan Rd, Waltham, MA 02451 T: (508) 330-9578 ◼ [email protected] ◼ www.nationalgrid.com EFSB’s review and approval of the route. MEPA approval, which culminated with the issuance of the Certificate of the Secretary of Energy and Environmental Affairs on the Final Environmental Impact Report on June 14, 2019 (“FEIR Certificate”), also required an alternatives analysis of comparative Project routes and related environmental impacts, including wetlands impacts, and the proposed Project. The City of Lowell submitted comments during the MEPA permitting processes, and BGC provided responses to those comments as part of review. Many of the questions that the Commission raised at its December 9th hearing, or that the Lowell Sustainability Council has raised are similar to questions raised and responded to during previous permitting. While the substance of many questions lie outside of the Commission’s wetlands jurisdiction, BGC understands the local interest in the Project and the desire of the Commission and the public to generally understand the Project. To aid in that general understanding of the Project, the responses in this letter and the attachment provide concise answers to all of the Commission’s questions and where appropriate, direct the Commission to the analyses, responses to comments, information requests, and other documents that provide detailed information about BGC’s determination of the need for the Project and the selection of the project route. To the extent that a question and BGC’s answer fall outside the jurisdiction of the Commission, the responses provided in this letter are for informational purposes only and the Commission must base its substantive review of the NOI on the requirements of the Wetlands Protection Act, the DEP’s Regulations and the City of Lowell Wetlands Ordinance. 1. Responses to Comments from the Lowell Sustainability Council The Lowell Sustainability Council has submitted comments to BGC concerning the Project. Most of the Council’s questions concern topics outside the scope of the Wetlands Protection Act and the City of Lowell Wetlands Ordinance. To aid the Conservation Commission in its consideration of those sections of the Project that are within wetlands jurisdiction, BGC provides below its responses to the Sustainability Council’s questions that relate to wetlands. The remainder of the questions from the Sustainability Council are answered in Attachment A. 10. Has NGrid developed a plan for remediation of site area disturbance related to the construction? Yes. The primary source of temporary construction disturbance is associated with excavating the trench to replace the pipeline. Disturbance also is associated with construction matting in wetlands. Construction matting is a best management practice (BMP) that avoids significant rutting and disturbance to wetlands associated with heavy vehicle operation. Following construction, BGC will restore disturbed surfaces and re-seed excavated areas per our Environmental Guidance document (See Attachment G of the NOI for EG303NE). Standards and BMPs contained in this document include provisions for re- grading surfaces, re-seeding with an appropriate seed mix, and stabilizing soils with mulch to reduce erosion and promote seed germination (See Section 5 page 44 of the NOI). These restoration methods have been and will be conditions of environmental permits. 40 Sylvan Rd, Waltham, MA 02451 T: (508) 330-9578 ◼ [email protected] ◼ www.nationalgrid.com 34. The ENF states 'hydrostatic testing'- apparently this uses lots of water and 1) where does the water come from? 2) what happens to the discharged water? It is an environmental hazard and contains contaminants that are/may be harmful. The discharge of hydrostatic testing water is an activity that is subject to regulation by MassDEP. Hydrostatic testing water will be obtained from a pool water supplier. Water will be pressurized in the new sections of the installed pipeline, which will not have been pressurized with product. Hydrostatic water will be discharged to containers to be processed off site at a licensed receiving facility. 33. The ENF states the project will cross the Middlesex Canal 4X. This is a nationally registered property. Who permits these crossings, the Lowell CC? The Project crosses the Middlesex Canal in three locations in areas of commercial development and through a transportation corridor. The remaining area is within a marsh to the west of West Forest Street. With respect to historic properties, work in this area is subject to review by the Massachusetts Historical Commission through the federal Section 106 consultation process associated with the federal Clean Water Act permit issued by the United States Army Corps of Engineers. 42. What environmental concerns are there for abandoning the existing sections of pipe in place? There are no environmental concerns associated with abandoning the existing sections of pipe in place. The Company will remove all measurable traces of natural gas from the existing pipeline by pressurizing the pipeline with an inert gas, such as nitrogen. This inert gas will be released slowly as the pipeline degrades over time. In addition, per regulator request the pipeline will be capped with grout. 45. Were the alternative proposals identified by Colonial Gas viable and reasonably considered? Are there others we should consider? The Project has been through rigorous alternatives analyses through several permitting processes. Alternatives have been described in the NOI for the Project and include Project Alternatives, Route Alternatives, and Construction Methodology Alternatives. The Project as proposed has been approved by the EFSB (Final Decision issued September 26, 2019 ) and MEPA (FEIR Certificate issued June 14, 2019) . In order to secure EFSB approval, the Company was required to present alternatives to the proposed facility and to demonstrate that, on balance, the Project is superior to alternative approaches in terms of reliability, cost, environmental impact and ability to meet the identified need. The EFSB also required the Company to demonstrate that it considered a reasonable range of practical siting/routing alternatives and that the proposed facility is sited/routed in locations that minimize costs and environmental impacts while ensuring supply reliability. Similarly, the MEPA review process required the Company to identify and thoroughly analyze all feasible alternatives to the Project at every stage of the review, including the Environmental Notification Form, 40 Sylvan Rd, Waltham, MA 02451 T: (508) 330-9578 ◼ [email protected] ◼ www.nationalgrid.com Draft Environmental Impact Report and Final Environmental Impact Report. As a result, all reasonable and feasible alternatives have been thoroughly