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Forest Protection:
Pre-filed state DEP Testimony of professional wildlife consultant
January 22, 2009


In the Matter of:

Docket No. WET-2008-072
DEP File No. 106-0075
Belmont, MA


1. I have a Ph.D in Wildlife Biology/ Natural Resources Planning, which I received from the University of Massachusetts in 1974. I received a Masters Degree from the University of Toronto in 1965 and a Bachelor of Arts degree from Harvard University in 1963. I have thirty-five years of experience working in both the public and private sectors on matters pertaining to conservation, the last twenty-four primarily in New England. I have extensive experience in the study of wetlands and associated upland areas, including the evaluation of wetland functions and values as they relate to providing habitats for wildlife. I served with the U.S. Army Corps of Engineers, New England District, on contract to evaluate the mitigation of impacts on wetlands by permittees under the Clean Water Act. My findings on a wide variety of flora and fauna have appeared in numerous technical reports and professional publications.

Involvement in Belmont Uplands

2. I live just two miles from the subject site, in Watertown, which occupies a portion of the Alewife River catchment. As such a close resident, and member of the Watertown Conservation Commission, I share the concern of many other neighbors to the site, that the little remaining undeveloped open space available to the public be respected for what it is and can be if given protection from alienating commercial demands. In 2005, I was retained by the Belmont Conservation Commission, Friends of Alewife Reservation and other environmental and conservation groups in Belmont and Cambridge to conduct a review of available information and identify the ecological impacts of the high-density housing development proposed for construction on the Belmont Uplands by AP Cambridge Partners II. In February 2006 I presented my findings in a report, a copy of which is attached hereto (Appendix A). In May 2006, I presented further facts and findings to the Friends of the Alewife Reservation in an oral form. In a letter dated 15 November 2007 (also herewith attached), I submitted to the Belmont Conservation Commission a critique of the project proponent’s Wildlife Habitat Evaluation (Appendix B).

Function of the Belmont Uplands

3. The Belmont Uplands is unique in the Boston area for its combination of species composition, area size, and location. The site comprises a nearly pure stand of Silver Maple that occupies a large area of upland contiguous with floodplain, its typical habitat, where it also dominates the plant community. The wetland-upland complex encompassing the site lies within an intensely urbanized landscape of residential, commercial and industrial uses. In addition to its natural beauty, the Uplands provides many other important free public benefits, including control of both the quantity and quality of water discharged to the Little River. Stem and leaf surfaces intercept precipitation, and the permeable forest floor accepts additional precipitation as groundwater. As a result, stormwater runoff, including the relatively polluted “first flush,” dwindles and slows on its way downslope, subject to the joint forces of retention and detention. Some of the runoff is taken up by vegetation and the atmosphere, the remainder delayed in its delivery to the Little River, by which time the greatest danger of flooding has passed, and many pollutants have decomposed (e.g. nutrient overloads, hydrocarbons) or settled out in the forest (e.g. heavy metals).

4. The Uplands and the Little River and its adjoining riparian zone provide linkage between the Uplands area and downstream habitats for many aquatic and terrestrial animals. To some, the Uplands and wetland environs may be an annual endpoint (e.g. the shad and herring) or way-station (e.g. migratory birds), to others an occasional refuge (e.g. deer). The connectivity of Little River with Alewife Brook downstream facilitates access to the Alewife Reservation by mammals that otherwise might be absent from this densely populated human environment (e.g. River Otter, Mink, Beaver). Only as an intact entity can the Uplands and adjacent Alewife Reservation predictably support such species. Together, the Uplands and this protected open space have a breeding record for over 45 bird species and 20 mammals. Ten of the breeding bird species require nest cavities, which form more readily in Silver Maples than in many other trees.

Adverse Impacts of Housing Project on Nearby Residential Area

5. The high-density housing project proposed to be built on the Uplands would destroy most of the rare Silver Maple forest and severely impair the ability of the Uplands to control flooding on nearby residential neighborhoods, which are already in a state of chronic risk during storms. Furthermore, in the context of the contiguous unbuilt landscape, this project could hardly have been proposed for a location more prejudicial to open-space habitat values. Its central position in the undeveloped landscape violates standard open-space conservation guidelines and ensures the maximum adverse impacts of habitat incursion and fragmentation, including the significant loss of prime upland habitat around a potential vernal pool (Appendix A, Figures 1, 2, 3, 4). Replacement of the area’s core open space by the proposed project and its inhabitants would severely curtail or preclude the occurrence of many vertebrates as regular residents (e.g. Fisher, River Otter, Wood Thrush) or visitors (e. g. Great Blue Heron, Gray Fox) (Appendix C, page 3). These outcomes would result from (1) the change in open-space configuration and (2) the indirect impacts of intensified human activity. The area’s open space available as habitat would decline in total area by more than 5 acres, but more important, its central core of most remote habitat would diminish by over 50% (Appendix A, Figure 3). The indirect impacts include an increase in the number of domesticated animals (e.g. dogs, cats) and people pervading the environs of their new home.

Relevance of the Wetlands Protection Act (M.G.L. c. 131, Section 40)
6. The Wetlands Protection Act (WPA) defines wildlife habitat as “...those areas subject to (M.G.L. c. 131, Section 40) which due to their plant community composition and structure, hydrologic regime or other characteristics, provide important food, shelter, migratory or overwintering areas, or breeding areas for wildlife”. The Belmont Uplands site comprises state-jurisdictional wetland wildlife habitat that is important (1) in the short term (for at least the next century) because of its “plant community composition and structure”, the Silver Maple forest; and (2) in the long term (indefinitely) because of “other characteristics”, its location in the middle of a rare urban wild.
7. The WPA defines wildlife habitat as those resource areas which, due to certain physical characteristics, provide “important wildlife habitat functions” (i.e. “important food, shelter, migratory or overwintering areas, or breeding areas for wildlife”). In the words of the Massachusetts DEP Wetland Regulation Preface Appendices—May 2008, “the Legislature meant to protect wetland habitat which is important to wildlife from a regional or statewide perspective.” In the subject site’s urban landscape setting, all the above specified wildlife habitat functions gain importance that transcends the valuation they would assume in a typical, less confined and more rural wetland. This assessment is firmly grounded in standard wetland evaluation procedures, which consider not only the functions themselves but also the values of each. The landscape context is also a major explicit concern of the DEP’s Field Data Form (Wildlife Habitat Protection Guidance, Appendix B), which makes additional provision for extended discussion (thinking outside the check-list “box”) of other important habitat features of a site-specific nature.
8. More than most sites containing wetland, the Belmont Uplands indeed calls for site-specific attention. Not only is its severely confining urban location atypical, requiring a holistic consideration of all available wetland and upland resources, but so also is its wetland-upland interface, which virtually encircles the site, creating a small upland “island” in an extensive wetland complex. Impacts of the proposed development on wetland, then, radiate equally from the site in every direction. As discussed above, these impacts, both direct and indirect, must be deemed to have an adverse effect because they would suffice to substantially reduce the wetland’s capacity to provide the important wildlife habitat functions listed in the WPA that are clearly observable throughout the known wetland resource areas, including all Bordering Land Subject to Flooding up to the mapped limit of the 100-year statistical flood. The inclusion of all BLSF wetland here finds support in the Wetland Regulation Preface Appendices, viz. “Important” floodplain habitat on the upper floodplain may also be protected on a case by case basis where evidence of its existence has been demonstrated”, a condition that rests on the considerations described above: the location, size, nature and configuration of the subject site in a small but species-rich urban wetland-upland complex that would undergo serious impairment of its wildlife support function and value as a result of project implementation.

Broader Adverse Impacts of Housing Project
9. The Alewife Reservation is a public place, a rare refuge for diverse species of wildlife. Because the Alewife Reservation benefits both humans and many other animals, it deserves management to enhance its habitat values, not diminish them. That means concern for all the remaining open space in and around the Reservation: wetlands or upland, meadow, marsh, shrubland or forest, including specifically the Belmont Uplands. The development proposal considers only its own immediate project area and does not take into account its serious adverse impacts on the open space, wetlands, and wildlife habitats in the adjoining Alewife Reservation (Appendix B). Such an approach fails to recognize adequately the surrounding landscape’s ecology, as well as the many initiatives currently proposed to enhance the ecological values of the Reservation rather than further reduce and degrade this vestige of our natural heritage.

Signed under the pains and penalties of perjury, this 22nd day of January, 2009.