To: Rachel Freed, Acting Deputy Regional Director, Bureau of Resource Protection, Northeast Regional Office, Mass. Department of Environmental Protection (Mass DEP)
Re: DEP File #106-0075

Ms. Freed,

I am writing to notify you of dramatically changed precipitation conditions on the Belmont Uplands site, and to request that the DEP amend the Superseding Order of Conditions (SO/C) under DEP File #106-0075 to require that the proposed project safely handle stormwater from current estimates of a 24-hour 100-year flood, and not estimates based on precipitation data collected only through 1958. This amendment is required in order to protect the water quality of Little Pond and Little River, the wildlife habitat on the Alewife Reservation, and the health and safety of my Precinct 8 constituents and other residents in low-lying areas of Belmont, Cambridge, and Arlington.

The changed condition on this site since the 2008 SO/C (and since the subsequent 2010 Notice of Project Change) is that extreme precipitation events are now known to have dramatically changed for the worse. In particular, the 24-hour 100-year storm event on this site is now known to be over two inches more severe than was assumed prior to a significant report issued by the Northeast Regional Climate Center (NRCC) in 2011. The 24-hour 100-year storm is now estimated at 8.8. inches instead of the 6.5 inches estimated in 1961. The design of the proposed project was made to accommodate 6.5 inches of rain, an event which is now known to occur every 30 years instead of every 100 years.

As I'm sure you're aware, Technical Paper 40 (TP-40), the document used as a standard at the time of the 2008 SO/C, was published in 1961. In 2011, the Northeast Regional Climate Center (NRCC) and the Natural Resources Conservation Service (NRCS) published updated models of extreme precipitation which take into account precipitation data collected through 2008. More information about NRCC, NRCS, and these results can be found at precip.eas.cornell.edu.

I respectfully request that the DEP respond as to whether it considers significant the fact that it is now known that additional cubic feet of rain will fall on the impervious surface of the proposed project during a 24-hour 100-year storm. I further request that the DEP amend the SO/C under DEP File #106-0075 to require that the proposed project handle extreme precipitation estimates that include 50 years of precipitation data missing from TP-40, on which the proposed design is based. I recognize that the funding and coordination of government studies and regulations related to climate change represent daunting complexity, and that individual cases cannot be re-opened frequently without impacting the certainty required for a robust economy. The 2011 NRCC report indicates the simple fact that, for this site, it is now known that there is a lot more rain during a 24-hour 100-year storm. More robust stormwater management is required to ensure the type of safe housing on which a robust economy depends.

The fact that current regulatory standards ignore 50 years of precipitation data is putting the health of our waterways and of our citizens at risk. The Wetlands Program Policy 85-4 (Amended Orders) may provide an avenue for addressing the specific risks at this location. The NRCC report provides authoritative, unambiguous, and simple data about rainfall at this site. Regardless of how it is accomplished, I urge you and the leaders at DEP to find a better way to protect my constituents and our waterways during this time of climate change. The urgency of taking adequate steps to mitigate the type of damage witnessed during Hurricane Sandy in New York and New Jersey is great.

Respectfully,

Anne-Marie Lambert

Belmont Town Meeting Member, Precinct 8
Founder, Belmont Stormwater Working Group

• Heidi Davis, Acting Section Chief, Wetlands Program Bureau of Resource Protection, MassDEP NERO
• Andy Rojas, Chair, Belmont Board of Selectmen
• Mark Paolillo, Belmont Board of Selectmen
• Glenn Clancy, Belmont Building Inspector, and Director, Belmont Community Development Department
• David Kale, Belmont Town Administrator
• David Webster, Belmont Conservation Commissioner, and Belmont Town Meeting Member
• Mary Trudeau, Belmont Conservation Agent
• Dan Driscoll, Director, Recreational Facilities Planning, Mass. Department of Conservation and Recreation (MassDCR)
• Kathryn Baskin, Water Policy Director, Executive Office of Energy and Environmental Affairs, and Belmont Town Meeting Member, Precinct 8
• Mark Smith, Director, The Nature Conservancy, and Belmont Town Meeting Member, Precinct 8
• Idith Haber, President, Coalition to Preserve the Belmont Uplands, and Belmont Town Meeting Member, Precinct 8
• Fred Paulsen, Founder, Belmont Stormwater Working Group, and Belmont Town Meeting Member, Precinct 3
• Michael Baram, Belmont Town Meeting Member