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FAR responds to Wetlands Protection Act
June 28, 2004
Department of Environmental Protection (DEP)
RE: Proposed changes to the Massachusetts Wetlands Protection Regulations 310 CMR 10.00, Wetlands Fees 801 CMR 4.02, Administrative Proceedings Rules 310, CMR 1.01, and Timely Action Schedule and Fee Provisions 310, CR 4.00.
Dear Sir or Madam;
The Friends of Alewife Reservation (FAR) is a multileveled stewarding and advocacy group. It protects the public Reservation land owned by the Department of Conservation and Recreation, to preserve it for wildlife and for future generations, by providing a highly accessible area in limited wilderness areas for passive recreationists. FARís board of overseers provide stewardship and advocacy for the Reservation's needs.
The Alewife Reservation contains over one hundred acres of woods, fields, swamps, and ponds with the Little River of Alewife Brook flowing through the middle of the Reservation and a wide level path from Cambridge to Belmont. One of the few natural areas left in the region, the three towns of Cambridge, Belmont, and Arlington, bound the Alewife Reservation. The Reservation is home to a couple of hundred species of animals and plants that find nesting and denning sites within. Many birds make their living there part-time, using the Reservation as a stop-off point along the Atlantic Flyway when migrating each Spring and Fall. It is a rich and varied wetland resource, with the largest extensive silver maple flood plain forest within 8 miles of the State house.
FAR has reviewed the draft Wetlands Protection Act changes, Wetlands Fees, Administrative Proceedings Rules, and Timely Action Schedule and Fee Provisions and has the following comments. FAR is supportive of the intent of the regulations, to enable DEP to provide greater resources to aid enforcement and review of projects with greater impacts. The Reservation has been undergoing illegal fill over the years and FAR is in support of increased surveillance and enforcement.
However, FAR has reviewed the "Summary Comments by the Massachusetts Association of Conservation Commissions (MACC) on proposed changes to the Massachusetts Wetlands Protection Regulations 310 CMR 10.00, Wetlands Fees 801 CMR 4.02, Administrative Proceedings Rules 310, CR 1.01, and Timely Action Schedule and Fee Provisions 310, CR 4.00" dated June 15, 2004. We think these comments are meritorious of your attention and inclusion in a revised draft for review by the public before final adoption. We are highlighting a few in our statements below.
We feel strongly that language be upheld requiring the applicant to disclose the entire project at the time of filing for a waiver. Since it is an urban wild surrounded by commercial and industrial uses, and the closest residential areas are in the floodplain, projects and their impacts are likely to be much larger than a single-family house or shed. our reservation can't take any more degradation. We want flood plain protection to remain at its highest level.
We also support the addition of language to Discretionary Fills (310 CMR 10.55(4)), requiring Conservation Commissions to apply "sequencing" standards to their review of requests for destruction of up to 5,000 square feet of wetlands. This provision would require that commissions consider the magnitude of the impacts, the significance of the wetland interests at the project site and the availability of the alternatives to avoid or minimize the proposed impacts. The commission should also consider the degree to which proposed mitigation measures will contribute to wetlands interests.
We thank you for this opportunity to comment. We ask that you consider urban areas pushed to the edge to save what little we have left as well as the suburban and rural wetland resources of the Commonwealth of Massachusetts.
FAR Steering Committee