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HomeMy WebLinkAboutCape Cod Commission 71123 669 / -e RECEIVED I � JUL 112023 BUILDING DEPARTMENT By --------- 3225 MAIN,STREET • P.O. BOX 226 BARNSTABLE, MASSACHUSETTS 02630 CAPE COD (508) 362-3828 • Fax (508) 362-3136 • www.capecodcommission.org COMMISSION CERTIFIED MAIL-RETURN RECEIPT REQUESTED 7019 0640 0001 0150 9002 July 6,2023 Robert Whritenour,Jr. Re: Yarmouth Riverwalk Park, Boardwalk and Event Town Administrator Space CCC File No:22031 Town of Yarmouth 1146 Route 28 South Yarmouth,MA 02664 Dear Mr.Whritenour, This letter serves as notice that the above-referenced project has been deemed to be a DRI under Section 2(d)(i)of Chapter A, Code of Cape Cod Commission Regulations, Enabling Regulations Governing Review of Developments of Regional Impact.The Commission received the Secretary's certification of the adequacy of the final SEIR on June 23,2023(copy attached). Under Section 6(c)(vi)of Chapter A and Section 13(b)of the Cape Cod Commission Act,the Commission is required to open the public hearing on the project within forty-five(45)days of the Secretary's certification of the adequacy of the final SEIR,which in this case means no later than August 7,2023. Once opened,the public hearing shall be closed within 90 days following its opening date,unless extended by mutual agreement with the Applicant.To allow for DRI review of the project,the Applicant shall make application with the Commission,which shall be prepared and filed in accordance with the Chapter A of the Code of Commission Regulations("Enabling Regulations"). Copies of the Commission Act, regulations,and DRI application cover sheet and guidance document,among other relevant regulatory documents,can be found on the Commission's website at www.capecodcommission.org. No municipal development permits may be issued for the project,and no development activity may be undertaken for the project, until the Commission completes its review and issues a DRI approval. Jeff Ribeiro,Regulatory Planner Ilat the Commission, is the project manager and your contact person. Please do not hesitate to contact Ms.Velozo should you have further questions. Sin erely, sa Dil n Commission Clerk Page 112 Enclosure CC via regular mail:Yarmouth CCC Representative CC via certified mail: Kathy Williams,Town Planner Mary Maslowski,Town Clerk Mark Grylls,Building Commissioner Julie Mockabee,Chair, Historical Commission Steven DeYoung,Chair,Zoning Board of Appeals Bruce Murphy,Health Director Grant Kelly, Conservation Administrator Page 212 The Commonwealth of.Massachusetts _—'� Executive Office of Energy and EnvironmentalAffairs =° !-a g 4 100 Cambridge Street, Suite 900 Boston, .MA 02114 Maura T.Healey GOVERNOR Tel:(617)626-1000 Kimberley Driscoll Fax:(617)626-1081 LIEUTENANT GOVERNOR http://www.mass.gov/eea Rebecca L.Tepper SECRETARY June 23,2023 CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE SINGLE ENVIRONMENTAL IMPACT REPORT PROJECT NAME : Yarmouth Riverwalk Park,Boardwalk and Event Space PROJECT MUNICIPALITY : Yarmouth PROJECT WATERSHED : Cape Cod EEA NUMBER : 16623 PROJECT PROPONENT : Town of Yarmouth DATE NOTICED IN MONITOR : June 10,2023 Pursuant to the Massachusetts Environmental Policy Act(MEPA; M.G.L. c. 30,ss. 61- 62L)and Section 11.08 of the MEPA regulations (301 CMR 11.00),I have reviewed the Single Environmental Impact Report(Single EIR)and hereby determine that it adequately and properly complies with MEPA and its implementing regulations. Project Description As described in the Single EIR,the project consists of the redevelopment and restoration of a site owned by the Town of Yarmouth(Town) into a park(referred to as"Riverwalk Park"), boardwalk,and event space. Riverwalk Park will include a four-acre,grassed,multi-use field area surrounded by walking paths. The field area is intended to be used periodically for outdoor events(such as concerts)and overflow parking associated with such events.As currently proposed,access to the site will be provided by a paved roadway extending in a southerly direction off of Route 28 that will border the eastern limit of the field area,adjacent to Parkers River. The access road will have two loops,one at the southern terminus and one adjacent to a 1,130 square foot(sf)park office/restroom building that is proposed just north of the field area. A total of 88 pervious parking spaces are proposed on either side of the access road between the two loops. Between the access road and the Parkers River,the project proposes to construct up to nine artist shanties(140 sf each)supported by concrete pads,as well as a nature-based play area EEA# 16623 Single EIR Certificate June 23,2023 for children. Other improvements include outdoor(dark sky)lighting, a kiosk near the kayak launch(further described below),and associated utilities. All structures are proposed to be used seasonally and therefore none will be conditioned spaces. The project proposes the construction of several walking paths and shared-use pathways. A 3-foot-wide stabilized aggregate walking path is proposed to extend from the play area to the kayak launch(traveling along the Parkers River)to serve as a nature path.An 8-foot-wide, paved, shared-use path(SUP)will extend from Route 28 along the western limit of the proposed access road,continuing around the field area and tying back to itself south of the restroom building.A 6-foot-wide stabilized aggregate walking path is proposed to extend from the northern loop within the access road to the kayak launch,traveling along the eastern limit of the site to provide access to the amenities proposed in this area.An additional 6-foot-wide stabilized aggregate walking path is proposed to extend from the SUP into the woods located south of the event space(between the field area and marsh),eventually branching into two trails that extend to meet the boardwalk proposed in the marsh area at the rear of the site. The boardwalk will generally consist of a looped, 6-foot-wide,wooden structure supported by helical piles, constructed at a variable height above the substrate to minimize shading.The looped boardwalk will total 1,300 linear feet Of)and will include a pedestrian bridge spanning a tidal creek within the marsh, four bench seating areas, and three 8-foot-wide overlook areas. Both the boardwalk and walking path located in the forested area generally follow existing, informal walking trails within the marsh/woods. As noted above,the park design also proposes a kayak launch located southeast of the field area, consisting of a pile-supported boardwalk and gangway system leading to a float for launching motorless watercraft on the Parkers River. Where the boardwalk for the kayak launch is located over Salt Marsh,the boardwalk will be 6 feet wide with 6 feet of clearance, supported by helical piles.The boardwalk will tie into a 6-foot-wide, fixed, sloped gangway connecting to a level landing platform,both of which will be supported by wooden piles. The landing platform will connect to a hinged, 5-foot-wide gangway,which will connect to an 18-foot by 18-foot floating launch that will be anchored to the underwater substrate. Separately,northeast of the field area,a 10-foot-wide stabilized aggregate access path is proposed to extend from the parking area to an existing upweller facility(a shellfish nursery). As described in the Expanded Environmental Notification Form(EENF),this driveway will improve the existing rutted and unstable condition of the current upweller driveway and will create a turnaround area with two parking spaces for operations staff at a greater distance from the Parkers River than exists today. Changes Since the EENF As described in the Single EIR,there have been several changes to the project since the filing of the EENF in response to feedback received from Agencies and Environmental Justice (EJ)communities. Specifically,the Single EIR states that in response to comments received from the EJ population located to the west of the site,the proposed elevated boardwalk has been realigned to the east to reduce outside views of the boardwalk from the nearby neighborhoods. Plantings were also added along the boardwalk to provide additional screening to the neighbors. According to the Single EIR,the new alignment represents a slight reduction in the overall length of the boardwalk,as well as impacts to Salt Marsh,from 15,300 sf(as described in the 2 EEA# 16623 Single EIR Certificate June 23,2023 EENF)to 14,277 sf.An invasive species inventory and management plan was also prepared and incorporated into the proposed project mitigation through the Yarmouth Conservation Commission review process. In response to feedback from the Massachusetts Office of Coastal Zone Management (CZM),the previously proposed use of geogrid reinforced turf along the perimeter shared-use path was eliminated, and instead replaced with a modified gravel and loam soil mixture that the Single EIR states will both support grass growth and withstand vehicle loads.As described in the Single EIR,this revision will avoid extensive areas of plastic geogrid material and eliminate the risk of the geogrid working loose in a flood event and becoming floating marine debris. Additionally,the site grading has been revised in the area east of the first cul-de-sac to provide grading to approximately elevation(el.)7.30 feet(ft)NAVD88. This change was introduced as a mitigation measure to minimize the risk of potential erosion due to increased flood velocities occurring within the Coastal AE Zone. The Single EIR states that this area will have additional boulder outcrops,plant pockets and tree and shrub plantings to slow and dissipate flood waters. Finally,the Single EIR states that the proposed grading around the event space was revised to prevent channelization of water at the southern extent of the event space as flood water recedes. Project Site The 119.78-acre project site includes a 23-acre parcel previously utilized for the Yarmouth Drive-In theater,as well as 8 acres of the Lewis Pond Marsh Conservation Area (which separately totals 170 acres). The remainder of the project site is comprised of predominantly undeveloped land. The area previously utilized for the drive-in(where the majority of the project will be located) includes a large area of cleared land(in addition to a vegetated perimeter)that has been extensively altered. Informal walking trails, litter, and debris (including glass and asphalt associated with the former use)are currently found in the area.As noted above, an existing driveway leads to the upweller facility located on the west bank of Parkers River,which is currently in operation. The project site is bounded by commercial developments associated with Route 28 to the north,residential housing to the west,the Parkers River to the east, and the remainder of the Lewis Pond Marsh Conservation Area to the south.At the entrance to the project site, abutting Route 28,a wastewater pump station is proposed to be constructed by the Town, separate from the project proposed herein. The pump station(and associated service drive,walkways, landscaping,etc.)is in the final stages of design,and will be constructed under a separate contract.' The project site contains numerous coastal and wetland resources areas, including Salt Marsh, Coastal Beach,Land Under Ocean(LUO),Land Subject to Coastal Storm Flowage (LSCSF),BVW,Riverfront Area,Fish Runs,and Land Containing Shellfish. Parkers River is listed as an impaired waterbody due to the presence and/or concentration of several different nutrients or pollutants, and has an associated Total Maximum Daily Load(TMDL)for nitrogen. 'The pump station is proposed as part of the Yarmouth Comprehensive Wastewater Management Plan(CWMP), which was first filed with the MEPA Office in 2011 and assigned EEA#14659.A Certificate was issued on September 30,2022(on the Single EIR filed for the Yarmouth CWMP)which found that the project adequately and properly complied with MEPA and its implementing regulations. 3 EEA# 16623 Single EIR Certificate June 23,2023 As further discussed below,the site contains 0.02 acres of Commonwealth tidelands.The entirety of the project site is mapped as Flood Zone AE(an area inundated during a 100-year storm),with a Base Flood Elevation(BFE) of elevation(el.)ranging from 12 to 13 ft NAVD88 as delineated on Federal Emergency Management Agency(FEMA)map 25001C0588J(effective date July 16,2014). The southern portion of the project site(within the marsh) contains Estimated and Priority Habitat of Rare Species as delineated by the Natural Heritage and Endangered Species Program(NHESP)in the 15th Edition of the Massachusetts Natural Heritage Atlas. The project site is not located in an Area of Critical Environmental Concern (ACEC)and does not contain any structures listed in the State Register of Historic Places or the Massachusetts Historical Commission's(MHC)Inventory of Historic and Archaeological Assets of the Commonwealth.The entirety of the project site is considered conservation land protected under Article 97 of the amendments to the state constitution. The project site is located within one Environmental Justice(EJ)population characterized by Income criteria and within one mile of two additional EJ populations characterized by Income criteria; additional EJ populations are located within five miles of the site. Environmental Impacts and Mitigation Environmental impacts associated with the project include the alteration of 10.06 acres of land(including 874 sf(0.02 acres) of Commonwealth tidelands),the creation of 0.67 acres of impervious surface(for a total of 1.75 acres on-site),the generation of 900 average daily trips (adt),the creation of 88 parking spaces,the generation of 900 gallons per day(gpd)of water demand and 800 gpd of wastewater(during the times of year the facility is in use),and the installation of 0.12 miles of water mains and 0.13 miles of sewer mains. The project will alter the following wetland resource areas: 6 sf of LUO; 179 sf of Coastal Beach; 14,277 sf(0.33 acres) of Salt Marsh; 14 sf of Land Containing Shellfish; 14 sf of Fish Runs; 438,245 sf(10.06 acres)of LSCSF(which overlaps with all other resource areas); 933 sf(0.02 acres)of BVW; and 134,869 sf(3.10 acres)of Riverfront Area. The impact calculations account for newly altered areas,areas to be restored, and formerly altered or degraded areas to be redeveloped. Measures to avoid,minimize, and mitigate project impacts include locating the project predominantly in previously developed/degraded areas;use of piles to minimize impacts to wetland and coastal resource areas; elevating structures located in Salt Marsh to minimize shading;restoration of 31,920 sf(0.73)of degraded LSCSF,including 29,250 sf(0.67 acres)of degraded Riverfront Area;restoration of temporarily impacted wetland and coastal resources areas;use of time-of-year(TOY)restrictions; orienting the project to reduce noise impacts (further discussed below);use of dark-sky-compliant lighting; construction of a stormwater management system utilizing best management practices(BMPs); dry-floodproofing the proposed restroom;vegetative plantings; and use of erosion and sedimentation controls during project construction. Jurisdiction and Permitting The project is undergoing MEPA review and is subject to a mandatory EIR pursuant to 301 CMR 11.03(3)(a)(l)(b) of the MEPA regulations because it requires Agency Actions and 4 EEA# 16623 Single EIR Certificate June 23, 2023 will involve the alteration of 10 or more acres of any other wetlands. The project additionally exceeds the ENF thresholds at 301 CMR 11.03(3)(b)(1)(c) and 11.03(3)(b)(1)(f)because it will result in the alteration of 1,000 or more sf of Salt Marsh and the alteration of one half or more acres of any other wetlands,respectively. The project requires the preparation of an EIR under 301 CMR 11.06(7)(b)of the MEPA regulations because it is located within one mile of one or more EJ populations(specifically,the site is within an EJ population). The project requires a Chapter 91 (c.91)License and 401 Water Quality Certification(WQC)from the Massachusetts Department of Environmental Protection(MassDEP)and a Vehicular Access Permit from the Massachusetts Department of Transportation(MassDOT). The project requires a Stormwater Management Permit and an Order of Conditions from the Yarmouth Conservation Commission among several other permits from the Town;the Single EIR indicates that Orders of Conditions were issued for the project on January 26,2023 and February 3,2023 and were not appealed, and that the Stormwater Management Permit was issued on February 22, 2023. The project requires authorization from the U.S.Army Corps of Engineers(USACE)under the General Permits for Massachusetts in accordance with Section 404 of the Federal Clean Water Act as well as a National Pollutant Discharge Elimination System(NPDES) Construction General Permit(CGP)from the United States Environmental Protection Agency(EPA). Because the project is seeking Financial Assistance through the Seaport Economic Council and the Massachusetts Department of Conservation and Recreation(DCR),MEPA jurisdiction is broad in scope and extends to all aspects of the project that are likely, directly or indirectly,to cause Damage to the Environment as defined in MEPA regulations. Review of the Single EIR The Single EIR provided a description of existing and proposed conditions;preliminary project plans; a description of coordination with CZM,MassDEP,and the Cape Cod Commission(CCC)conducted since the filing of the EENF; a floodplain analysis;additional analysis of project alternatives; additional information on potential impacts,benefits,and outreach to EJ populations; additional discussion of traffic impacts and mitigation; and an expanded analysis of impacts to wetland resource areas. Supplemental information was distributed by the Proponent on June 13,2023 that provided information regarding the project's floodplain impacts, further discussed below.For purposes of clarity,all supplemental materials provided by the Proponent are included in references to the"Single EIR,"unless otherwise indicated. Comments from Agencies do not identify any impacts that were not reviewed in the Single EIR or identify additional information that should be provided on the project. Alternatives Analysis The Scope on the EENF requested that the Single EIR provide an expanded discussion of alternative layouts for the parking lot that reduce the amount of alteration within Riverfront 5 EEA# 16623 Single EIR Certificate June 23,2023 Area.As described in the Single EIR,two additional design alternatives were evaluated that locate the parking area farther outside or entirely outside the Riverfront Area. The first alternative alignment involved locating the parking lot along the western and southern perimeter (as opposed to along the eastern perimeter);the second alternative alignment involved locating the parking lot to a central location on the site.As described in the Single EIR,the alternative alignments were dismissed as they would result in additional noise and visual impacts to EJ neighborhoods,increase pedestrian and vehicle contact points,limit the park functionality, and/or jeopardize project funding(as the accessway would fall outside the footprint of the defined area of improvements funded by the Land and Water Conservation Fund Grant). I note that at the time the EENF filed,the extent of degraded Riverfront Area within the project site was unconfirmed, and impacts associated with the parking lot were considered potentially new alteration to Riverfront Area.As further discussed below,the project will meet the performance standards for work proposed in degraded Riverfront Area; it was unclear at the time the EENF was filed whether the project could meet the performance standards associated with Riverfront Area that was not considered degraded. As described in the Single EIR,based on detailed investigations conducted at the site in December 2022, it was determined that the area where the parking lot is proposed qualifies as degraded(as defined at 310 CMR 10.58(5)), as the area lacks topsoil, does not support vegetation, and has both surficial and buried asphalt pavement as well as other debris present documented throughout the site. The Scope on the EENF also directed the Proponent to evaluate further measures to reduce impervious surface. The EENF originally described the creation of 0.60 acres of new impervious surface and 0.97 acres of existing impervious surface on-site associated with previous uses,for a total of 1.57 acres on-site following project construction.Following refinements to existing and proposed conditions calculations during the local permitting process, the Single EIR identifies the creation of 0.67 acres of impervious surface and 1.08 acres of existing impervious surface, for a total of 1.75 acres on-site following project construction. The Single EIR states that,due to site constraints and the anticipated use of the site,the proposed impervious areas have been minimized to the extent practicable,and therefore cannot be further reduced. Specifically,the Single EIR indicates that reductions in the width of the accessway would result in traffic impacts that were considered unacceptable,and further increasing the use of pervious surface(as opposed to asphalt)would result in failure of the roadway(given the expected use of commercial trucks and vehicles in the areas were asphalt is proposed)and impact the access of emergency vehicles during special events. Currently,the parking spaces and certain pedestrian pathways on-site are proposed to consist of pervious surface. Environmental Justice As noted above,the project site is located within one EJ population characterized by Income criteria and within one mile of two additional EJ populations characterized by Income criteria. The"Designated Geographic Areas"("DGA,"as defined in 301 CMR 11.02,as amended)for the project is one mile. No languages were identified as spoken by 5%or more of residents who also identify as not speaking English very well.A list of community-based organizations(CBOs)and tribes/indigenous organizations(the"EJ Reference List")provided by the MEPA Office was used to notify the listed entities of the filing of the Single EIR.The Single 6 EEA# 16623 Single EIR Certificate June 23,2023 EIR states that this notice also included a summary of project updates,and that the notice was placed in the Cape Cod Times, on various social media pages and on the front page of the Town's website,and at various public locations including bus stops and public libraries. The Single EIR indicates that,since the filing of the EENF, several public meeting and presentations have been held for the project associated with the local permitting process(in addition to the nearly 50 public meetings held on the project prior to the filing of the EENF). The Single EIR notes that these meetings have included abutter notification and legal notices placed in the Cape Cod Times,and that during these meetings,the surrounding EJ neighborhood identified concerns with the proposed boardwalk's impact on the privacy of the neighborhood. As noted above,the project design was refined in response to this feedback to move the boardwalk away from the community and to provide additional vegetative plantings/screening. The Single EIR states that,through coordination with adjacent neighborhoods,the newly proposed alignment has alleviated the neighbors' concerns. The Scope on the EENF directed the Town to confirm that traffic impacts will be sufficiently mitigated to avoid impacts to EJ populations. The Single EIR states that the Town does not anticipate creating any significant traffic impacts,other than when periodic special events are held. When special events are held,the Single EIR states that traffic will be managed through an event-specific Transportation Management Plan to avoid impacts to EJ populations. As further discussed below, comments from MassDOT note that the project is expected to have limited traffic impacts,and that the Proponent has proposed safety and multi-modal site access improvements to mitigate potential impacts.As previously discussed in the EENF,while the project may potentially increase traffic in the area associated with new visitors to the park,the site is currently located on a Cape Cod Regional Transit bus route and future work planned by MassDOT includes the creation of dedicated bike lane,shared-use-path facilities, and new crosswalks which will provide safer,multi-modal transportation options to the site. The Single EIR also discusses the potential for construction to affect the surrounding EJ populations,as requested by the Scope. As described in the Single EIR,project construction will result in a temporary increase in diesel truck routes along Route 28 (the main east-west transportation corridor)to and from the site, adjacent to EJ populations.The Single EIR states that measures to reduce impacts associated with construction include consolidating vehicle delivery trips, limiting construction activities to weekdays between 7:00 AM and 5:00 PM, implementing dust control measures,and requiring the contractor to comply with vehicle emission guidelines. Public Health The Single EIR included a separate section on"Public Health."The EENF provided a comprehensive review of publicly available data to identify existing and potential public health impacts within the applicable EJ communities. The Single EIR states that the project is not anticipated to cause negative environmental or public health impacts that would affect EJ populations.As described in the Single EIR,the project has been designed to equitably allocate environmental benefits to further environmental justice principles,and will provide an array of public health benefits associated with the creation of a public park in a previously degraded and 7 EEA# 16623 Single EIR Certificate June 23, 2023 abandoned property. The Single EIR notes that the project, located within an EJ community,will provide a nature-based playground area for children,new ADA accessible outdoor recreation opportunities, and access to both land and water recreation as well as an outdoor event space. Additionally,the Single EIR states that the proposed fill associated with the project will provide flood protection to the EJ population located west of the site during smaller,more frequent flood events(up to el. 7.5 it NAVD88),as further discussed in the Climate Change section below. Wetland and Coastal Resources The Single EIR provided the proposed elevation of the stream crossing associated with the boardwalk,the bankfull width of the tidal creek,and Mean High Water(MHW)on project design plans, as requested by the Scope. The Scope also directed the Town to address how future sea level rise has been considered and incorporated into the design of the stream crossing to maintain tidal flow over the design life of the structure. According to the Single EIR,the useful life of the proposed boardwalk and kayak launch is approximately 40 years. Based on current projections,it is estimated that as compared to water surface elevations in the early 2000's, sea levels will rise by 1.3 and 2.4 feet by 2050, and by 2.3 and 4.2 feet by 2070. Based on the"High" sea level rise projections,the MHW at the site would increase from 2.05 feet to 4.45 feet by 2050 and to 6.05 feet by 2070(NAVD88). The Single EIR states that,with this increase in MHW,the majority of the boardwalk would travel over areas that would be submerged during a typical tidal cycle in 2050 and 2070. However,while the structure would be situated over water,it is not anticipated to impact the flow of tidal waters, as water will be able to move freely under the structure during a typical tidal cycle. The Single EIR also evaluated an alternative for the boardwalk with a 1.5:1 height-to- width(H:W)ratio where it is located over Salt Marsh(including the boardwalk associated with the kayak launch).As stated in comments from the Massachusetts Department of Marine Fisheries(DMF)submitted on the EENF,a minimum 1.5:1 H:W ratio for all decking installed over Salt Marsh is recommended,based on field studies showing reductions in shading and marsh loss above this threshold. According to the Single EIR,a 1.5:1 H:W was evaluated and dismissed as it would increase negative visual impacts to abutting properties, including EJ communities that have expressed concerns about such impacts;potentially result in greater permanent impacts to Salt Marsh due to an increase in the overall number of piles/bracings required to support the additional height; greater permanent impacts in resource area buffers due to the increased length of ADA compliant ramp and landing structural systems required for the boardwalk approaches; and increased construction duration and increased public project costs. Comments from DMF acknowledge the trade-offs that exist in design considerations between indirect(shading)and direct(habitat displacement)impacts of walkways constructed over Salt Marsh,and state that the proposed design appears to balance these impacts. The Single EIR continues to propose to construct the boardwalk to provide a minimum of 1:1 H:W ratio over the ground elevation when in a north-south orientation, and a 1.25:1 H:W ratio when in an east-west orientation to minimize shading impacts on Salt Marsh. Comments from DMF state that the material provided in the Single EIR adequately addresses prior recommendations to explore alternative designs towards minimizing impact to Salt Marsh habitat. The Single EIR also commits to the time of year(TOY)restrictions recommended by DMF in comments on the EENF. 8 EEA# 16623 Single EIR Certificate June 23,2023 As noted above,the Scope on the EENF required that the Town determine the extent of the Riverfront Area within the project site that meets the definition of degraded as defined by the WPA at 310 CMR 10.58(5), as requested by MassDEP.As described in the Single EIR,on October 19,2021,a Massachusetts Registered Professional Engineer and Massachusetts Certified Soil Scientist conducted three test pits and two borings onsite within Riverfront Area. The results of the tetes pits were included in the Single EIR. In response to comments from MassDEP on the EENF,an additional 21 test pits/observations were performed on December 13, 2022 using an excavator; the test pit logs were also included in the Single EIR. The Single EIR included plans that clearly identify the area of Riverfront Area that is considered degraded,and states that the data continues to support the past characterizations of the site;notably,that the entirety of the Riverfront Area between the existing snow fence and the outer limit of the Riverfront Area is degraded per 310 CMR 10.58 (5),with specific reference to 1)the presence of existing pavement and 2)the absence of topsoil.The Single EIR also provided a discussion of the project's compliance with the Riverfront Area Performance Standards, as well as the restoration activities proposed as part of the project. Comments from MassDEP state that the Town has adequately addressed the Department's comments on the EENF. The project includes approximately 29,250 sf of Riverfront Area restoration and 31,920 sf of LSCSF restoration.All Riverfront Area restoration is proposed within existing degraded Riverfront Area in accordance with the requirements at 310 CMR 10.58(5). Restoration of these areas includes planting of native species appropriate for the ecological conditions at the Site. Comments from CZM submitted on the EENF noted that portions of the site, including the former Yarmouth Drive-In property,are modeled in the Sea Level Affecting Marshes (SLAMM)model'as potentially suitable for marsh migration.As described in the Single EIR,in 2050,under both the intermediate-low(IL)and intermediate-high(IH) sea level rise(SLR) scenarios,marsh migration is primarily anticipated to occur on the site along the Parkers River in the vegetated areas that will remain following the project's construction.Accordingly,the project is not anticipated to alter migration within that planning horizon,and Salt Marsh will be able to migrate onto the site north of the Upweller facility. In addition,the project will promote and enhance Salt Marsh migration in the area of existing Upweller driveway,which is proposed to be restored as part of the project. In 2070,the IL SLR scenario maintains generally the same marsh migration patterns seen in 2050 IH SLR scenario.The IH SLR scenario in 2070,however,shows potential brackish/transitional marsh extending both into the area of IVW south of the former drive-in and across the lower-lying portions of the former open drive-in area. Due to the proposed use of the former drive-in area at the northern limit of the site,the project will prevent Salt Marsh migration into this area. However,no action will be taken to prevent the Salt Marsh migration pathway south of the site. Finally,the Single EIR addressed measures to prevent stormwater impacts to the Parkers River,which has a TMDL for nitrogen.The Single EIR states that the project is not anticipated to increase nitrogen loading to the Parkers River as the project does not include installation of a septic system,the primary source of nitrogen to the Parkers River. In addition,the application of fertilizer onsite is not proposed by the Town, as plants included in the design are native to 2 Available at https://arcg.is/my90C0 9 EEA# 16623 Single EIR Certificate June 23,2023 Massachusetts and are adapted to thrive at the site.As described in the Single EIR,the only anticipated source of nitrogen is stormwater runoff, and while the project will increase impervious areas by 0.67 acres,the project will actually result in a decrease in stormwater runoff from the site compared to existing conditions.The proposed stormwater system will manage and treat all 1.75 acres of impervious area proposed at the site,including the 1.08 acres of existing impervious area, from which stormwater currently flows untreated to the Parkers River. Comments from the CCC submitted on the EENF identified concerns about the potential for the steel coating on the proposed boardwalk helical anchors to leach into the surrounding wetland and coastal resources.As described in the Single EIR,to significantly increase the service life of the steel helical piles,corrosion protection is required,and the most common, efficient,and economical way of providing corrosion protection of steel is to galvanize it,which is the process of placing a zinc coating over the steel.The Single EIR states that the helical piles are proposed to be galvanized,which will result in an estimated service life of approximately 70- 85 years, as opposed to the approximately 10-year service life expected for steel helical piles without any corrosion protection in temperate marine environments.According to the Single EIR,the zinc will leach slowly over the service life of the piles,but is expected to disperse as opposed to concentrate, and will also prevent steel corrosion and iron leaching.The Single EIR notes that there is no evidence that a zinc leaching containment plan has ever been executed for a boardwalk structure in a marsh land.Additionally,recent studies on various projects have shown that zinc leaching would not cause background levels of zinc to exceed the levels that would cause toxicity to aquatic organisms.As a result,a containment plan for the zinc is not proposed. I note that CCC's comments identified concerns specifically with the potential for steel leaching, as opposed to zinc. Public Benefit Determination The project proposes activities within 874 sf(0.02 acres)of tidelands subject to the provisions of An Act Relative to Licensing Requirements for Certain Tidelands(2007 Mass.Acts ch. 168),now codified at M.G.L. c. 91, § 18B,and the Public Benefit Determination(PBD) regulations(301 CMR 13.00).3 Consistent with Section 8 of the legislation,I must conduct a Public Benefit Review as part of the review of EIR projects located on tidelands that entail new use or modification of an existing use.The Single EIR described the benefits of the project as restoring degraded wetland and coastal resource areas; improving public access to the waterfront in an area that is currently primarily vegetated with invasive species and shows evidence of previous development; creating a dedicated,ADA accessible boardwalk,which will minimize erosion to Salt Marsh associated with current,unsupported public use of the space;providing public restrooms, a playground for children, shared-use paths,and crosswalks,as well as an outdoor event space. The PBD regulations, at 301 CMR 13.04(1), include a presumption that water-dependent projects provide adequate public benefit. As noted above,the project will be required to obtain a c.91 License from MassDEP. Comments from the MassDEP on the EENF included a 3 Area of Commonwealth tidelands that will be impacted by the project were described in an email sent from Laura Krause(BETA Group,Inc.)to Eva Vaughan(MEPA Office)on June 21,2023. 10 EEA# 16623 Single EIR Certificate June 23,2023 determination that the proposed activities would be classified as a water-dependent use project pursuant to the Waterways Regulations at 310 CMR 9.12.For this reason, I find that the Single EIR has demonstrated that the project will have a public benefit in accordance with M.G.L. c. 91, § 18B and 301 CMR 13.00. Thus,this Single EIR Certificate shall serve as the PBD for this project. Traffic and Transportation The Single EIR describes coordination that the Town has conducted with MassDOT since the filing of the EENF,and work that is being proposed by MassDOT proximate to the site that has been considered and incorporated into the project design.The Single EIR provided the stopping sight distance and intersection site distance available to vehicles at the site driveway, as well as the sight distance to pedestrians on the north and south sides of the proposed mid-block crossing,as requested in comments from MassDOT on the EENF. The Single EIR also provides a discussion of potential measures to reduce traffic to the site during special events that would result in above-average traffic generation, as required by the Scope.A Traffic Management Plan (TMP),developed in consultation with the Town,is required and must be provided as a condition of approval for larger events at the site. The TMP will be implemented by the Event Sponsor,in concert with the Yarmouth Police Department,who may be required to hire a police detail for events,particularly those that have a specific start and stop time. Traffic management is anticipated to be structured in a similar manner to the set-up and processes that have worked well for the town in the past. A commitment to provide additional traffic coordination during on- site events has been incorporated into the Draft Section 61 Findings, as requested by the Scope. Comments from MassDOT state that,based on the limited project impacts and proposed mitigation to improve safety and multi-modal site access,MassDOT does not recommend further environmental review of the project based on transportation issues. Climate Change Adaption and Resiliency The Single EIR addresses the project's compliance with Building Code, as requested by the Scope. The site is entirely within the 100-year FEMA floodplain,Zone AE,with a BFE of el. 13 ft NAVD88 across the majority of the site. The proposed public restroom in the center of the park is proposed to be set at el. 12 ft NAVD88,with dry flood proofing extending vertically to offer flood protection to el. 15. For the artist shanties(described as simple accessory structures), wet flood-proofing is proposed. In addition to securely anchoring the structures to concrete base slabs,floodway openings will be incorporated into all the shanties. The Single EIR indicates that the project will comply with all Building Code requirements for buildings constructed in the floodplain. Comments from CZM submitted on the EENF noted that floodwaters and waves will likely move across the site during coastal storm events,and proposed fill,retaining walls,new impervious surfaces, and amenities on the site may change the way these floodwaters move over the site. To demonstrate that the-project has been designed to avoid increasing potential impacts associated with coastal flooding,the Town conducted a pre-and post-construction flow path analysis. The flow path analysis was conducted for pre-and post-construction conditions with a floodwater elevation of 4.2, 6.2,7.2, 8.0, 8.5,and 13 ft NAVD88. These elevations were chosen 11 EEA# 16623 Single EIR Certificate June 23,2023 as they were associated with significant site conditions/elevations on-site or at adjacent properties(such as the crest of the Route 28 Bridge over the Parkers River,or the 100-year floodplain BFE). As described in the EENF, once floodwater elevations exceed el. 8.5 ft NAVD88,the existing flood limits and approach velocities over the site will match existing conditions, as at this elevation,proposed changes in grades will be overtopped.At lower elevations,the project is expected to reduce flooding impacts on the adjacent residents. Specifically,the Single EIR states that the proposed access roadway and parking area will function as a dike,which will provide the site and the residential abutters to the west of the site additional flood protection for events up to el. 7.5 ft NAVD88,which corresponds to flood levels anticipated at the peak of a Category 1 hurricane. The Single EIR states that the park improvements will also increase the vegetative buffer between the river and the proposed improvements,maintain the existing vegetation between the river and the former drive-in site,and improve the access driveway surface to the Upweller facility to reduce the potential for erosion from inundation velocities. The only change in floodwater flow identified in the Single EIR that may not result in reduced flood waters in neighboring areas is associated with an area at the entrance driveway. Below el. 8.0 ft in this area,the roadway and proposed earthen berm(which forms the outside edge of the stormwater improvements)will displace all potential flows.Under current conditions,water flows across the site to and from Route 28 through this area.With the proposed improvements, flow will be restricted through this area to a proposed swale and the existing mounded septic system associated with the abutting commercial property(the Lobster Boat Restaurant);the project will not result in channelized flows to Route 28.To mitigate a potential increase in velocities through this pathway, an earthen berm at crest el. 7.5 has been extended between the northern cul-de-sac and the Lobster Boat Restaurant.An 8-inch pipe with a check- valve will extend through the berm to allow for floodwaters to drain out of the area. The Single EIR states that the berm will prevent the passage of water around the restaurant property and compel flows to be maintained in the main channel. It will also form a ponding area between the access roadway and the adjacent commercial property,which will act as a stilling basin for flows through the entrance at Route 28; as such,the Single EIR states the diversion of floodwaters should have little impact on the abutting commercial parking lot. I refer the Town to comments from CZM state that the design plans should be revised to use salt-tolerant,erosion-control plantings to stabilize the proposed berm instead of boulders,which often scour in storms. The Single EIR also addressed the recommendations from the MA Resilience Design Tool, including whether stormwater sizing is adequate to accommodate the 2070 10-year storm recommendation(24-hour rainfall volume of 6.4 inches),and building elevations as compared to the 2070 50-year water surface elevation(14.5 ft NAVD88)and the 2050 and 2070"wave action water elevation"(16 to 18.6 ft NAVD88)provided by the Tool.The Single EIR indicates that the proposed stormwater system exceeds the recommendations of the MA Resilience Design Tool, as it has been sized to accommodate a 24-hour rainfall volume of 7.42 inches, 1.02 inches greater than that recommend by the Tool.As noted above, stormwater runoff has been minimized through the use of pervious pavement, and the project proposes to treat all runoff associated with the existing 1.08 acres of impervious surface(in addition to the impervious surface proposed to be created),which is currently completely untreated/unattenuated. 12 EEA# 16623 Single EIR Certificate June 23, 2023 The proposed restroom/office building design includes a finished floor elevation of 12 ft NAVD88,which is comparable to 2050 50-year water surface elevation(12.8 feet),but below the 2070 50-year water surface elevation;this elevation is below both the 2050 and the 2070 wave action water elevations provided by the MA Resilience Design Tool.The Single EIR states that, while the finished floor elevation is 12 ft NAVD88,the current building design includes dry flood-proofing to an elevation of 15 ft NAVD88,above the 2070 50-year water surface elevation (14.5 ft NAVD88).While still below the 2050 and 2070"wave action water elevations"(16 to 18.6 ft NAVD88,respectively),the Single EIR states that the current design of the building allows for implementation of additional measures in the future to prevent flood water from entering the windows,which would provide flood protection beyond el. 15 ft NAVD88,up to the top of the restroom/office building. Mitigation and Draft Section 61 Findings The Single EIR provides final mitigation commitments and draft Section 61 Findings for use by Agencies,which are summarized below. The Section 61 Findings should be provided to Agencies to assist in the permitting process and issuance of final Section 61 Findings. As noted in the Certificate issued on the EENF,the project qualifies for the de minimis exemption included in the May 2010 MEPA Greenhouse Gas Emission(GHG)Policy and Protocol(Policy) for projects that are expected to produce minimal GHG emissions. As stated in the EENF,GHG emissions are predominately associated with the anticipated mobile source emissions,and total GHG emissions associated with the project are de minimis. Therefore, a GHG analysis was not required for the project,and a self-certification of GHG emissions reduction measures is not required by the Proponent. Environmental Justice • Restoration of a degraded site to create an ADA accessible public recreation asset with public bathrooms, facilitating both land and water recreation activities • Implementation of traffic control measures to minimize traffic and air quality impacts • Limiting the use of use of event space perimeter lights for special events only • Installation of screening/privacy plantings for surrounding EJ populations • Requiring special event sponsors to limit sound levels to 90 dBA at 100 feet from stage area to reduce noise impacts • Reduction of flooding impacts to the EJ residences adjacent to the site Land/Stormwater • Use of a previously disturbed/currently developed site • The Stormwater design will be constructed in compliance with the Massachusetts Stormwater Standard and will include: - Subsurface infiltration - Drainage swales 13 EEA# 16623 Single EIR Certificate June 23, 2023 Infiltration basins - Porous pavement parking spaces - Infiltration trenches • The stormwater infrastructure will be constructed to accommodate the current 24-hour 100-year storm(24-hour rainfall volume of 7.42") • The stormwater system will be maintained in accordance with the Operations and Maintenance Plan Wetland and Coastal Resources • Salt Marsh restoration,including amending soils and planting native vegetation • 29,250 sf of Riverfront Area restoration and 31,920 sf of LSCSF restoration,including: - Removal of debris from the site,including debris throughout the woods - Management of invasive species - Planting native vegetation - Amending soils • Use of sedimentation and erosion controls during project construction • TOY restrictions,including: - Implementing an April 2—October 14 time of year restriction during installation of the boardwalk piles to minimize impacts to rare bird species - Implementing a February 15—June 15 time of year restriction during installation of the float to minimize impacts to anadromous fish species Traffic and Transportation • Installation of right and left-turn only lanes exiting the parking lot to decrease queues • Bicycle/Pedestrian accommodations, including the construction of an 8-foot-wide shared- use-path,installation of bicycle racks,and walking paths throughout the site. • Preparation of a Traffic Management Plan will be required for events and coordination with the Police Department during larger periodic events. Traffic management techniques typically include: - Police cruiser,Police officers at the intersection for officer traffic control, - Barrels, drums, and cones to direct and restrict traffic movements, - Use of portable,changeable message boards on Route 28 displaying event times and dates in advance of the event as well as with driving instructions the day of the event to further guide visitors, - Reversible lanes for peak entering and exiting traffic, - Designate areas to stack early-arriving vehicles before gates opened, 14 EEA# 16623 Single EIR Certificate June 23,2023 - Collect parking fees in interior areas of the Site to avoid backups to Route 28, - Use of a shuttle bus for the largest events/parades. Climate Change Adaptation and Resiliency • Inclusion of a berm along the eastern limit of the driveway a prevent flood water channelization and increases in flood water velocities • Grading the site to ensure flood flows will not increase on adjacent parcels • Maintaining areas of existing vegetation to allow marsh migration onsite. • Planting native vegetation in suitable habitat to minimize water use • Constructing the stormwater system to accommodate the current 24-hour rainfall volume for the 100-year storm(7.42"),which is greater than the 2070 10-year storm(6.4") • Dry floodproofing the proposed office/bathroom building to a minimum elevation of 15 ft NAVD88, two feet above the 100-year BFE • Enhancement of wetland areas,which provide flooding benefits Greenhouse Gas Emissions • Restricting restroom use to summer months • Orienting restroom to accommodate installation of solar panels • Use of energy-efficient design elements, including an electric tankless water heater, adjustable lights, and motion-operated lights in restroom • Installation of permanent signs limiting idling to five minutes or less Construction Period • Dust will be managed in accordance with the NPDES General Permit to minimize airborne particulate matter • Non-road diesel equipment rated 50 horsepower or greater will meet EPA's Tier 4 emission limits. If a piece of equipment is not available in the Tier 4 configuration,the Construction Manager will work with the general contractor to confirm that construction equipment will be retrofitted with appropriate emissions reduction equipment. • Implementation of a Storm Water Pollution Prevention Plan(SWPPP)which will include: - Implementation and enforcement of a Spill Contingency Plan - Storage of any chemicals or hazardous materials under cover - Installation of sediment and erosion controls including turbidity curtains,compost filter tubes, and inlet protection measures - Inspection of the Site weekly to confirm erosion controls are functioning • Construction waste and debris management, including: 15 EEA# 16623 Single EIR Certificate June 23,2023 - Reuse of crushed asphalt and concrete to the extent feasible. - Chipping and reuse of native vegetation as mulch. - Use of covered waste-storage containers • Limiting idling to five minutes or less through the installation of construction-phase signs noting that idling shall be limited,and periodic inspections to confirm contractor is complying with the requirement. Conclusion Based on a review of the Single EIR and consultation with Agencies,I find that the Single EIR adequately and properly complies with MEPA and its implementing regulations. The project may proceed to permitting.Participating Agencies should forward copies of the final Section 61 Findings to the MEPA Office for publication in accordance with 301 CMR 11.12. June 23 2023 ' Date Rebecc . Tepper Comments received: 06/09/2023 Massachusetts Department of Transportation(MassDOT) 06/09/2023 Massachusetts Division of Marine Fisheries(DMF) 06/15/2023 Massachusetts Department of Environmental Protection(MassDEP), Southeast Regional Office(SERO) 06/20/2023 Massachusetts Office of Coastal Zone Management(CZM) RLT/ELV/elv 16 I The Commonwealth of Massachusetts OR 0 Division of Marine Fisheries " (617)626-1520 I www.mass.gov/marinefisheries s� r 8J °t+ARiNE MAURA T.HEALEY KIMBERLEY DRISCOLL REBECCA L.TEPPER THOMAS K.O'SHEA DANIEL 3.MCKIERNAN Governor Lt.Governor Secretary Commissioner Director June 8,2023 Secretary Rebecca L. Tepper Executive Office of Energy and Environmental Affairs(EEA) Attn:MEPA Office Eva Vaughan,EEA No. 16623 100 Cambridge Street, Suite 900 Boston,MA 02114 Dear Secretary Tepper: The Division of Marine Fisheries(MA DMF)has reviewed the Single Environmental Impact Report(SEIR)by the Town of Yarmouth for its Yarmouth Riverwalk Park,Boardwalk and Event Space Project. The project includes the proposed construction of a public park on a vacant lot bordering the Parkers River.A 1,300 linear foot boardwalk loop is also included with a pedestrian bridge,three overlook areas and four bench areas. The boardwalk would be six feet in width and height over salt marsh would be set to a minimum 1:1 height to width(H:W)ratio for the north-south facing sections and 1.25:1 for the east-west facing sections. The preferred alternative uses three 3.5-inch diameter helical piles at each bent location for a total of 252 helical piles which would collectively impact 13 square feet of salt marsh habitat.A kayak launch is also proposed. The terminal float to the launch would be in an area of the Parkers River with at least a four foot depth at MLW and would be held in place with a helical anchor and elastomeric mooring stay system. Existing marine fisheries resources and habitat and potential project impacts to those resources are outlined in the following paragraphs. The region of the Parkers River bordering the project site includes shellfish habitat for quahog (Mercenaria mercenaria)and blue mussel(Mytilus edulis). Land containing shellfish is deemed significant to the interest of the Wetlands Protection Act(310 CMR 10.34)and the protection of marine fisheries. The region of the Parkers River bordering the project also provides passage for a variety of diadromous fish species.Alewife(Alosa pseudoharengus),American eel(Anguilla rostrata), white perch(Morone americana), and Atlantic tomcod(Microgadus tomcod)all seasonally occupy this system [1]. Much of the proposed boardwalk and a portion of the proposed kayak launch walkway directly overlie salt marsh habitat. Salt marsh provides a variety of ecosystem services, including habitat and energy sources for many fish and invertebrate species [2-4]. MA DMF offers the following comments for your consideration: • In our review of the Expanded Environmental Notification Form(EENF)for this project, we recommended that the SEIR include revisions to boardwalk height over salt marsh to SOUTH COAST FIELD STATION CAT COVE MARINE LABORATORY NORTH SHORE FIELD STATION 836 S.Rodney French Blvd 92 Fort Avenue 30 Emerson Avenue New Bedford,MA 02744 Salem,MA 01970 Gloucester,MA 01930 meet the 1.5:1 height to width(H:W)ratio currently recommended by MA DMF for all decking over salt marsh[5-7] or to provide justification for the currently proposed mix of 1:1 H:W for north-south and 1.25:1 H:W for east-west facing boardwalk segments. Discussion of this aspect of the project in Section 6.1.3 Boardwalk Alternatives of the SEIR notes that further increases to decking H:W would result in visual impacts to bordering EJ communities as well as increased direct impacts to salt marsh associated with the greater number of support piles and other infrastructure needed for a taller structure.MA DMF acknowledges the trade-offs that exist in design considerations between indirect(shading)and direct(habitat displacement)impacts of walkways constructed over salt marsh. The proposed design appears to balance these impacts by maintaining a minimum 1:1 H:W ratio and a predominant north-south orientation across the majority of the project footprint while limiting support structures to small diameter helical piles.MA DMF feels that material provided in the SEIR adequately addresses prior recommendations to explore alternative designs towards minimizing impact to salt marsh habitat. • MA DMF continues to support the proposed late fall to early winter(October 15 to April 1) construction window for work in salt marsh habitat detailed in the SEIR as this period would avoid impacts to salt marsh during the growing season. • MA DMF supports the time of year(TOY)restriction for in-water construction of February 15 to June 15 to protect the above listed diadromous fish species [1] detailed in Section 6.2 of the SEIR. Questions regarding this review may be directed to John Logan in our New Bedford office at john.logan@mass.gov. Sincerely, gc„,Jj Daniel J. McKiernan Director cc: Yarmouth Conservation Commission Laura Krause,BETA Group,Inc. Sabrina Pereira,NMFS Robert Boeri,CZM Rachel Croy,Ed Reiner,EPA Brendan Mullaney,DEP John Sheppard,Emma Gallagher,Amanda Davis,DMF References 1. Evans NT, Ford KH, Chase BC, Sheppard J. Recommended Time of Year Restrictions (TOYs)for Coastal Alteration Projects to Protect Marine Fisheries Resources in Massachusetts. Massachusetts Division of Marine Fisheries Technical Report, TR-47. 2 https://www.mass.gov/doc/time-of-year-recommendations-tr-47/download. Accessed September 29,2021. 2011. 2. Deegan LA,Hughes JE,Rountree RA. Salt marsh ecosystem support of marine transient species. In: Weinstein MP,Kreeger DA, editors. Concepts and Controversies in Tidal Marsh Ecology. Kluwer Academic Publisher,The Netherlands;2000.pp. 333-365. 3. Boesch DF,Turner RE. Dependence of fishery species on salt marshes: the role of food and refuge. Estuaries. 1984;7:460-468. 4. Deegan LA,Garritt RH. Evidence for spatial variability in estuarine food webs.Marine Ecology Progress Series. 1997;147: 31-47. 5. Logan JM, Davis A,Markos C,Ford K.H. Effects of docks on salt marsh vegetation: an evaluation of ecological impacts and the efficacy of current design standards. Estuaries and Coasts. 2018;41: 661-675. 6. Logan JM, Voss S,Davis A,Ford KH. An experimental evaluation of dock shading impacts on salt marsh vegetation in a New England estuary.Estuaries and Coasts.2018;41: 13- 24. 7. Logan JM, Boeri A, Carr J,Evans T, Feeney EM,Frew K, et al.A review of habitat impacts from residential docks and recommended Best Management Practices with an emphasis on the Northeastern United States. https://www.mass.gov/doc/dock-bmp- recommendations/download. Accessed November 18,2021.Estuaries and Coasts.2022;45: 1189-1216. DM/JL/sd 3 Maura Healey, Governor Kimberley Driscoll, Lieutenant Governor Ii7i7rS'S"4Iu ?( ) • Gina Fiandaca,Secretary&CEO Massachusetts Department of Transportation June 9,2023 Rebecca Tepper, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street,Suite 900 Boston,MA 02114-2150 RE: Yarmouth—Yarmouth Riverwalk—SEIR (EEA#16626) ATTN: MEPA Unit Eva Vaughan Dear Secretary Tepper: On behalf of the Massachusetts Department of Transportation,I am submitting comments regarding the Single Environmental Impact Report filed for the proposed Yarmouth Riverwalk in Yarmouth 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, D,,stonokAk...... David J. Mohler Executive Director Office of Transportation Planning DJM/j11 Ten Park Plaza,Suite 4160,Boston,MA 02116 Tel:857-368-4636,TTY:857-368-0655 www.mass.gov/massdot Yarmouth—Yarmouth Riverwalk Page 2 6/9/2023 cc: Jonathan Gulliver,Administrator,Highway Division Carrie Lavallee,P.E.,Chief Engineer,Highway Division Mary-Joe Perry,District 5 Highway Director James Danila, P.E., State Traffic Engineer Cape Cod Commission(CCC) Planning Board, Town of Yarmouth uMaura Healey, Governor I774. 7.S'.S'4L?() Kimberley Driscoll, Lieutenant Governor Gina Fiandaca,Secretary&CEO Massachusetts Department of Transportation MEMORANDUM TO: David J. Mohler, Executive Director Office of Transportation Planning FROM: J. Lionel Lucien, P.E.,Manager Public/Private Development Unit DATE: June 9,2023 RE: Yarmouth—Yarmouth Riverwalk—SEIR (EEA#16626) The Public/Private Development Unit(PPDU)has reviewed the Single Environmental Impact Report(SEIR)for the Yarmouth Riverwalk(the"Project")in Yarmouth as submitted by BETA Group,Inc. on behalf of Yarmouth Town Administrator Robert Whritenour Jr. (the "Proponent"). The Project site is a 119.78-acre parcel which is currently an undeveloped wetland comprising of salt marsh and coastal beach land. The Project proposes to construct a riverwalk park facility,including a walking/bicycling pathway,restroom facilities,kayak rental and launch,and associated infrastructure including impervious surface and 88 off-street parking spaces. Access to the site will be provided via a full-access driveway under STOP-sign control connecting to Main Street,with an entrance lane and dedicated right-turn and left-turn exit lanes. The Project includes a mid-block crosswalk located west of the Project driveway as well as a crosswalk across the driveway and connection to the internal bikeway/walkway. The Project previously submitted an Expanded Environmental Notification Form (EENF)which was duly noticed in the Environmental Monitor on November 9,2022. The EENF included supplemental information to support the Proponent's request for a waiver to allow the preparation of a Single Environmental Impact Report(SEIR)rather than a Draft and Final EIR. On December 16, 2023,the Secretary of Energy and Environmental Affairs(EEA) issued a Certificate finding that the Project adequately complied with the Massachusetts Environmental Protection Act(MEPA)and granting the requested waiver to allow the submittal of an SEIR. The SEIR and associated transportation analysis are responsive to MassDOT commentary submitted for the EENF. The Transportation Impact Assessment(TIA)has been updated and prepared following requirements and standards for the preparation of traffic studies as jointly issued by the Commonwealth of Massachusetts Executive Office of Energy &Environmental Affairs and the Massachusetts Department of Transportation(MassDOT). As requested,the SEIR provides the stopping sight distance and intersection site distance available to vehicles at the site driveway,as well as the sight distance to pedestrians on the Ten Park Plaza,Suite 4160,Boston,MA 02116 Tel:857-368-4636,TTY:857-368-0655 www.mass.gov/massdot Yarmouth—Yarmouth Riverwalk Page 2 6/9/2023 north and south sides of the proposed mid-block crossing.Also, a commitment to provide additional traffic coordination during on-site events in order to prevent impacts on the state highway system as well as mitigation measures are incorporated into the SEIR. The Proponent provides a summary of the transportation mitigation program that would include the following items: • Bicycle/Pedestrian accommodations are incorporated into the design, including: o Construction of an 8-foot-wide shared-use-path; and o Walking paths throughout the Site. • Installation of right and left turn only lanes exiting the parking lot to decrease queues. • For events that require preparation of a Traffic Management Plan(TMP)and coordination with the Police Department,traffic management techniques will typically include: o Police cruisers,police officers,and traffic control; o Use of portable, changeable message boards on Route 28 displaying event times and dates in advance of the event,with driving instructions the day of the event to further guide visitors; o Reversible lanes for peak entering and exiting traffic; o Designate areas to stack early arriving vehicles before gates opened; o Collect parking fees in interior areas of the Site to avoid backups to Route 28; and o Use of shuttle buses for large events. Based on the limited project impacts and proposed mitigation to improve safety and multi-modal site access,MassDOT recommends that no further environmental review be required based on transportation issues. The Proponent should continue consultation with MassDOT PPDU and the District 5 office to finalize the issuance of the Section 61 Finding for the Project. If you have any questions regarding these comments,please contact william.m.simon@dastate.ma.us. MassDEP Commonwealth of Massachusetts Executive Office of Energy&Environmental Affairs iiii.,, Department of Environmental Protection Southeast Regional Office•20 Riverside Drive, Lakeville MA 02347.508-946-2700 Maura T.Healey Rebecca L.Tepper Governor Secretary Kimberley Driscoll Bonnie Heiple Lieutenant Governor Commissioner June 14, 2023 Rebecca L. Tepper, RE: SEIR Review EOEEA#16623 Secretary of Energy and Environment YARMOUTH.Riverwalk Park,Boardwalk Executive Office of Energy& and Event Space at 669 Route 28 and a Environmental Affairs portion of the unnumbered lot to the south ATTN: MEPA Office 100 Cambridge Street, Suite 900 Boston,MA 02114 Dear Secretary Tepper, The Southeast Regional Office of the Department of Environmental Protection (MassDEP)has reviewed the Single Environmental Impact Report(SEIR)for the Riverwalk Park,Boardwalk, and Event Space at 669 Route 28 and a portion of the un- numbered lot to the south,Yarmouth,Massachusetts(EOEEA#16623). The Project Proponent provides the following information for the Project: The Town of Yarmouth(the Proponent)is proposing to redevelop the town-owned properties located at 669 Route 28 and a portion of the un-numbered lot to the south in the Town of Yarmouth,Massachusetts(Barnstable County)into a Riverwalk Park,Boardwalk,and Event Space for use by residents and visitors(the Project).The Project aims to improve the existing property through providing event space,recreation opportunities,public amenities and a restored coastline. The"Site"includes a 23-acre former Drive-In property located at 669 Route 28,and 8 acres of the Lewis Pond Marsh Conservation Area to the south.Work involves the rehabilitation of the currently vacant property and conversion into a public park,featuring a central four-acre grassed multi-use field area for periodic outdoor events,encircled with field and woodland walking paths. Near the Parkers River,a nature-based play area for children is planned with play structures and lawn games,shade sails,and artist shanties displaying work from various artists or other vendors. The park design also features a pile-supported boardwalk leading to a float for launching canoes, kayaks and paddleboards on the Parkers River. A woodland path is also proposed that will connect the park to a 1,300 linear foot 6-foot-wide boardwalk loop,including a pedestrian bridge,constructed as an elevated walkway over Salt Marsh.The boardwalk includes three overlook areas and four bench areas,offering expansive views of the sky and marsh below.Other improvements indude a porous paving parking lot with This Information Is available in alternate format.Contact Glynis Bugg at 617-348-4040. TTY#MassRelay Service 1-600-439-2370 MassDEP Website:www.mass.gov/dep Printed on Recycled Paper EEA No. 16623 December 9,2022 lighting for 88 new parking spaces,a small park office and restroom building(1,130 sf),and up to nine artist shanties(at 140 sf each),a kiosk near the kayak launch,and associated utilities.None of the proposed structures will be conditioned,as they will be seasonal. Comments//Guidance The MassDEP Southeast Regional Office has reviewed this SEIR and believes the Project Proponent has adequately addressed the Department's EENF comments.As such,the Department supports the applicants request for a Single EIR. If you have any questions regarding these comments,please contact George Zoto at George.ZotoAmass.gov or Jonathan.Hobilk mass.gov. Very truly yours, L 'nLu IAA Jonathan E. Hobill, ' Regional Engineer, Bureau of Water Resources JH/GZ Cc: DEP/SERO ATTN:Millie Garcia-Serrano,Regional Director Gerard Martin,Deputy Regional Director,BWR John Handrahan, Deputy Regional Director,BWSC Seth Pickering, Deputy Regional Director,BAW Jennifer Viveiros, Deputy Regional Director, ADMIN Maissoun Reda, Chief, Wetlands and Waterways.BWR Greg DeCesare,Wetlands,BWR Cally Harper, Wetlands,BWR Brendan Mullaney,Waterways,BWR Mark Dakers, Chief, Solid Waste,BAW Elza Bystrom, Solid Waste,BAW Angela Gallagher, Chief, Site Management,BWSC Jennifer Wharff, Site Management,BWSC THE COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS OFFICE OF COASTAL ZONE MANAGEMENT 100 Cambridge Street,Suite 900,Boston,MA 02114•(6171626-1200 MEMORANDUM TO: Rebecca L.Tepper,Secretary,EEA ATTN: Eva Vaughan,MEPA Unit FROM: Lisa Berry Engler,Director,CZM DATE: June 20,2023 RE: EEA-16623,Riverwalk Park,Boardwalk,and Event Space SEI Yarmouth 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 May 10,2023,and offers the following comments. Project Description The project involves the redevelopment of a previously altered town-owned property adjacent to Parkers River in Yarmouth.The site includes a 23-acre former drive-in property and eight acres of the Lewis Pond Marsh Conservation Area to the south. Work involves the redevelopment of the currently vacant property and conversion into a public park. Proposed features include; a central four-acre grassed multi-use field area for periodic outdoor events;multiple walking paths throughout the property; a nature-based play area for children with play structures; numerous artist shanties; a pile-supported boardwalk leading to a float for launching canoes, kayaks, and paddleboards; and a 1,300 linear foot boardwalk loop over the salt marsh. The project has received financial assistance from state agencies including a Seaport Economic Council Grant of$1,000,000 and a Department of Conservation and Recreation award of$200,000. Other funding sources include a Local Community Preservation Act award for $3,700,000; a Local Tourism Revenue Preservation Fund award for $100,000 and a Federal National Park Service award for$956,000. Project Comments Comments were submitted previously on the Expanded Environmental Notification Form in December 2022 and there was a meeting with the project proponents on April 7,2023, to review comments and to discuss flood pathway analysis, opportunities to decrease impervious areas, alternatives for the proposed reinforced turf and potential salt marsh migration pathways.The plans presented in the SEIR were modified to address these comments and mitigate potential direct and indirect environmental impacts.These changes include: • The proposed use of geogrid-reinforced turf adjacent to the perimeter shared-use path was eliminated from the plan and was replaced with a modified gravel and loam soil mixture that will both support grass growth and withstand vehicle loads.This revision will avoid extensive areas of the plastic geogrid material and eliminate the risk of the geogrid in those areas working loose in a flood event and becoming floating marine debris. MAURA T.HEALEY GOVERNOR KIMBERLEY DRISCOLL LIEUTENANT GOVERNOR REBECCA L.TEPPER SECRETARY LISA BERRY ENGLER DIRECTOR www.mass.goVczm • Revised site grading for an area east of the first cul-de-sac to create a berm to minimize the risk of potential erosion due to increased flood velocities occurring within the Coastal AE Zone.Additional plant pockets, trees,and shrubs are proposed to further slow and dissipate flood waters. • Revised site grading around the event space to reduce channelization of water at the southern extent of the event space as flood water recedes following a flood event that increases that surface water elevation above 7.5 feet (NAVD88). The plans should be revised to use salt-tolerant, erosion-control plantings to stabilize the proposed berm instead of boulders,which often scour around rocks in storms. Deep-rooted erosion control plantings will help slow flood water more effectively without causing scour. For information about plants for this application,please see the coastal bank section of StormSmart Properties Fact Sheet #3: Planting Vegetation to Reduce Erosion and Storm Damage. Federal Consistency Review The proposed project may be 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 robert.boeri(a,mass.gov,or visit the CZM website at www.mass.gov/federal-consistency-review-program. Cc: Laura Krause,Beta Groupe,Inc. Robert L Whritenour Jr.,Yarmouth Town Administrator Brittany DiRienzo,Yarmouth Conservation Administrator Kathleen Williams,Yarmouth Town Planner Steve McKenna,MACZM Rebecca Haney,MACZM Page