Final Environmental Impact Report for:

Waltham High School

554 Lexington Street
Waltham, Massachusetts
August 17, 2020
Final Environmental Impact Report

Waltham High School

Waltham, MA

Prepared by Table of Contents

SMMA
1. Summary
Distribution List
ENF Certificate
DEIR/Notice of Project Change Certificate
1.1 Project Description
1.2 Changes to the Project Since Filing the DEIR
1.3 Summary of Potential Environmental Impacts Since
Filing the DEIR
1.4 Status of Project Permitting
1.5 List of Mitigation Measures
1.5.1 Wastewater
1.5.2 Water
Tables
1.1 Statutory and Regulatory Requirements

2. Project Description
2.1 Project Overview
2.1.1 Comprehensive High School
2.1.2 Education Plan
2.2 Physical Characteristics
2.2.1 Locus Map
2.2.2 Site Plan
2.3 Project Schedule and Cost
2.4 Emergency Access
2.5 Bicycle and Pedestrian Access
2.6 Traffic Intersection Update
2.7 Natural Turf Field
2.8 Water and Wastewater Flow
2.9 Alternatives Analysis
Attachments
2.2 NPC/DEIR Figures
2.4a Lincoln Street easement taking order
2.4b Emergency access City Law Department letter
2.4c Lincoln Street 1959 Plan
Tables
2.1 Potential Project Sites Studied
Figures
2.1 Fencing at Lexington Street
2.2 Existing Topography
2.3 Proposed Topography
2.4 Emergency Access Plan Enlargement
2.5 Emergency Access Plan Enlargement with Existing
Aerial
2.6 Existing Conditions – Lexington Street

TOC | p. 1 Waltham High School | Draft Environmental Impact Report

 2.7 Proposed Conditions – Lexington Street
2.8 Waltham Transportation Master Plan – Lexington
Street Corridor Improvements
2.9 Existing Photographs of Lexington Street
2.10 On-Site Circulation Patterns
2.11 Natural Turf Field

3. Land Alteration/Drainage
3.1 City’s Open Space and Recreation Plan
3.2 Stormwater Management
3.2.1 Stormwater Drainage
3.2.2 Hydrologic Modeling
3.2.3 Flooding and Groundwater
3.3 Synthetic Turf Field
Attachments
3.1 City Open Space Letter
3.2 NPC/DEIR Figures
Tables
3.1 Pre- and Post-Development Peak Discharge Rate
Summary

4. Climate Change
4.1 Stationary Use – GHG Emissions Reduction Analysis
4.2 Life Cycle Cost Analysis
4.3 Solar PV Study
4.4 Mobile Sources
Tables
4.1 GHG Emissions Analysis Summary: Stationary and
Mobile Sources
4.2 GHG Emissions Analysis: Whole Building
4.3 GHG Emissions Analysis: Reductions by End Uses
4.4 Life Cycle Cost Analysis: HVAC Systems and Building
Enclosure
4.5 Preliminary Project Incremental Costs and Payback
Analysis
4.6 Preliminary Project Annual Energy Consumption Costs
4.7 Energy Analysis Criteria (Energy Modeling Inputs)
4.8 Solar PV Systems List Cycle Cost Analysis (40% PV
Readiness)
4.9 Solar Photovoltaic (PV) Estimated GHG Emissions
Reduction
4.10 Predicted Motor Vehicle CO2 Emissions Burden
Figures
4.1 Solar PV Readiness Area

5. Adaptation and Resiliency

5.1 Regulatory Basis of Design
5.2 Climate Change and Stormwater Management
5.3 Resiliency in Design

Waltham High School | Final Environmental Impact Report TOC | p. 2

 6. Construction Period
6.1 Construction Period and Hours
6.2 Dust and Noise Mitigation
6.3 Pre-Blast Condition Survey
6.4 Massachusetts Idling Policy
Attachments
6.2 Regulation 9 Dust and Odor
6.2 OSHA silica exposure control
Figures
6.1 Draft 500-foot Blast Radius

7. Mitigation and Draft Section 61

Findings
7.1 Mitigation Measures
7.1.1 Wetlands
7.1.2 Construction Traffic and Truck Routes
7.1.3 Traffic
7.1.4 Stormwater
7.1.5 Wastewater
7.1.6 Water
7.1.7 Noise Quality
7.1.8 Air Quality
7.1.9 Demolition and Hazardous Materials
7.1.10 Historical and Archaeological Resources
7.1.11 Greenhouse Gas Emissions
7.1.12 Adaptation and Resiliency
7.1.13 General Construction Measures
7.2 Draft Section 61 Findings
7.2.1 Contents of Section 61 Findings
7.2.2 Section 61 Findings and Agency Action
Tables
7.1 Summary of Mitigation Measures, Responsible Party
and Cost
Figures
7.1 Construction Vehicle Traffic Plan

8. Response to Comments
8.1 Secretary’s Certificate
8.2 Massachusetts Water Resources Authority (MWRA)
8.3 Charles River Watershed Association (CRWA)
8.4 Massachusetts Department of Environmental
Protection (MassDEP)
8.5 Massachusetts Historical Commission (MHC)
8.6 Department of Energy Resources (DOER)
8.7 Other Comment Letters
8.7.a City of Waltham universal response to Article 97 and
Open Space comments by MEPA and numerous
abutters
8.7.b City of Waltham response to Robert Coleman
comment letter

Waltham High School | Final Environmental Impact Report TOC | p. 3

 9. Appendices
4.1 Stationary Source GHG Calculations
4.2 LCCA Calculations
4.3 Mobile Source GHG Calculations
6.2 Acentech Community Noise Report
9.1 Site Plans
C-101 Existing Conditions Plan I
C-102 Existing Conditions Plan II
C-111 Site Preparation Plan I
C-112 Site Preparation Plan II
C-121 Layout and Materials Plan I
C-122 Layout and Materials Plan II
C-131 Grading and Utilities Plan I
C-132 Grading and Utilities Plan II
C-141 Planting Plan I
C-142 Planting Plan II
C-161 Schematic Traffic Signal Plan
C-501 Details I
C-502 Details II
C-503 Details III
C-504 Details IV
C-505 Details V

Waltham High School | Final Environmental Impact Report TOC | p. 4

Summary 1
Summary
Distribution List
ENF Certificate
DEIR/Notice of Project Change Certificate
1.1 Project Description
1.2 Changes to the Project Since the Filing of the DEIR
1.3 Status of Project Permitting
1.4 Summary of Potential Environmental Impacts Since Filing
the DEIR
1.5 List of Mitigation Measures
Tables
1.1 Statutory and Regulatory Requirements
Summary
1.1 Project Description
The City of Waltham filed an Environmental Notification Form (ENF) on September 16, 2019 for the
Waltham High School project (Project) and a Draft Environmental Impact Report (DEIR) and Notice of
Project Change (NPC) on May 15, 2020. The NPC/DEIR Certificate issued by the Secretary on June 26,
2020 noted the NPC/DEIR adequately and properly complies with MEPA and its implementing
regulations. This Final Environmental Impact Report (FEIR) addresses additional analysis and information
requested by the Secretary.

The new Waltham High School will be constructed at 554 Lexington Street in Waltham, MA,
approximately 760 feet south of Jack’s Way which serves as the existing high school driveway.

The new school building, totaling approximately 414,850 gross square feet, will house approximately
1,830 students in grades 9 - 12. The proposed site work includes new vehicular and pedestrian
circulation from Lexington Street, a synthetic turf athletic field above a parking garage and limited at-
grade parking.

Site work will consist of the demolition of all existing structures, paved surfaces, and existing site
improvements. Significant earthwork will be required to achieve final design grades of the Project
including significant bedrock blasting.

1.2 Changes to the Project Since the Filing of DEIR

The list below identifies the changes to the Project since the issuance of the NPC/DEIR Certificate:
1. Hired the Construction Manager – Consigli Construction Company.
2. Issued the Abatement and Demolition package for bid on July 20, 2020.
3. Received approval of the traffic signal concept -Two signals versus one signal from the Waltham
Traffic Commission. The project will now commence design of the signal and will be submitting the
design to the Traffic Commission at a later date for approval.

1.3 Summary of Potential Environmental Impacts Since Filing

the DEIR
There have been no changes since the NPC/DEIR that have any environmental impacts.

1 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 1: Summary

1.4 Status of Project Permitting

The project is subject to statutory and regulatory requirements as identified in the attached table.
Changes since the NPC/DEIR are noted in red.

Table 1.1 Statutory and Regulatory Requirements

Agency Approval or Permit Status

State
Massachusetts School Feasibility Study Agreement (FSA) FSA Complete
Building Authority Project Scope and Budget Agreement (PSBA) PSBA Complete
Project Funding Agreement (PFA) PFA execution in progress
Department of Elementary and Special Education Program Approval SPED Approved at Schematic Design - Feb 2020
Secondary Education Chapter 74 Program Certification Chapter 74 Program Certification at Substantial
Completion - Summer 2024
Executive Office of Energy and Massachusetts Environmental Policy Act Review
Environmental Affairs ENF ENF Certificate Received - December 6, 2019
DEIR DEIR Certificate Received – June 26, 2020
FEIR FEIR - Filed on August 17, 2020
Massachusetts Historical State Register Review (via MSBA Process) No further review required per letter dated
Commission February 19, 2019
Department of Environmental Issuance of SORAD SORAD - pending completion of MEPA process
Protection Notice of Abatement of Hazardous Material AQ-04 AQ-04 - Anticipated filing in Late Summer 2020
Notice of Demolition AQ-06 AQ-06 - Demolition anticipated filing in Late
Summer 2020
Notice of Construction AQ-06 AQ-06 - Anticipated filing in Spring 2021
Stormwater UIC Well Registration UIC - Anticipated filing in Summer 2024
Federal
Environmental Protection NPDES Construction General permit Anticipated filing in Fall 2020
Agency
Waltham
Conservation Commission Order of Resource Area Delineation (ORAD) ORAD issued August 13, 2019 (See DEP above)
Order of Conditions O of C - Anticipated filing NOI Late Summer 2020
Zoning Board of Appeals Variance Variance - Anticipated filing Late Summer 2020
Board of Survey and Planning Special Permit SP - Anticipated filing Fall 2020
Historic Commission Demolition Delay Demolition delay placed on April 8, 2019, expired
on April 8, 2020.
Building Department Demolition Permit Demo - Demolition permit anticipated filing in
Summer 2020
Construction Permit Construction - Anticipated filing in Spring 2021
Fire Department Blasting Permit Blasting -anticipated filing in Fall 2020
Consolidated Public Works Application for curb cut Anticipated filing Fall 2020
Application for street opening Anticipated filing Fall 2020

Waltham High School | Final Environmental Impact Report 1 | p. 2

 Section 1: Summary

1.5 List of Mitigation Measures

The project will provide mitigation measures as detailed in Section 12 of the NPC/DEIR. The FEIR
clarifies scope to wastewater and water and accordingly offers mitigation as outlined below and
detailed in Section 7 of the FEIR.

1.5.1 Wastewater
The project will result in a net increase of 39,594 gallons per day (gpd) in wastewater generation
and reflects both the proposed high school and the future development at 617 Lexington Street.
The required I&I inflow mitigation is 4:1 or 158,376 gallons and will be deducted from the City’s
sewer bank. The project will also include replacement of approximatley 375 linear feet of sewer
within Stanley Road.

1.5.2 Water
The project will result in a net increase of 43,560 gallons per day (gpd) in water use when using the
City Ordinance in calculating the flows. The increase in water supply reflects both the proposed
high school and the future development at 617 Lexington Street, has been reviewed with the City’s
Engineering Department and it has been confirmed there is adequacy in the existing inrastructure.
The project will also include replacement of approximatley 4,900 linear feet of water main within
Lexington Street.

Waltham High School | Final Environmental Impact Report 1 | p. 3

Distribution List
Massachusetts Environmental Policy Act Office
100 Cambridge Street
Boston, MA 02114
Email: MEPA@mass.gov

Department of Environmental Protection, Boston Office

Commissioner’s Office
One Winter Street
Boston, MA 02108
Email: helena.boccadoro@mass.gov

Department of Environmental Protection, Appropriate Regional Office

DEP/Northeast Regional Office
Attn: MEPA Coordinator
205B Lowell Street
Wilmington, MA 01887
Email: john.d.viola@mass.gov

Massachusetts Department of Transportation

Public/Private Development Unit
10 Park Plaza, Suite 4150
Boston, MA 02116
Email: lionel.lucien@dot.state.ma.us

Applicable Massachusetts DOT District Office

District #4
Attn: MEPA Coordinator
519 Appleton Street
Arlington, MA 02476
Email: connie.raphael@dot.state.ma.us

Massachusetts Historical Commission

The MA Archives Building
220 Morrissey Boulevard
Boston, MA 02125
Email: mhc@sec.state.ma.us
Email: brona.simon@state.ma.us

Department of Energy Resources

Attn: MEPA Coordinator
100 Cambridge Street, 10th Floor
Boston, MA 02114
Email: paul.ormond@mass.gov
Email: brendan.place@mass.gov

Applicable Regional Planning Agency

Metropolitan Area Planning Council
60 Temple Place/6th Floor
Boston, MA 02111
Email: mdraisen@mapc.org

1 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 1: Distribution List

Municipal Agency
Waltham City Council Historical Commission
City of Waltham City of Waltham
610 Main Street 610 Main Street
Waltham, MA 02452 Waltham, MA 02052
Email: rwaddick@city.waltham.ma.us Email: WHC@city.waltham.ma.us

Board of Survey and Planning Conservation Commission

City of Waltham City of Waltham
165 Lexington Street 610 Main Street
Waltham, MA 02452 Waltham, MA 02452
Email: mchiasson@city.waltham.ma.us Email: mrichard@city.waltham.ma.us

Zoning Board of Appeals Board of Health

City of Waltham City of Waltham
119 School Street 610 Main Street
Waltham, MA 02451 Waltham, MA 02452
Email: pdoucette@city.waltham.ma.us Email: mfeeley@city.waltham.ma.us

Massachusetts Water Resources Authority (MWRA)

Massachusetts Water Resource Authority
Attn: MEPA Coordinator
100 First Avenue
Charlestown Navy Yard
Boston, MA 02129
Email: katherine.ronan@mwra.com

Massachusetts School Building Authority (MSBA)

Massachusetts School Building Authority
Attn: Mary Pichetti
40 Broad Street, Suite 500
Boston, MA 02109
Email: Mary.Pichetti@MassSchoolBuildings.org

Department of Elementary and Secondary Education (DESE)

Department of Elementary and Secondary Education
Attn: Matthew Deninger
75 Pleasant Street
Malden, MA 02148-4906
Email: matthew.j.deninger@mass.gov

ENF & DEIR Commenters

Deb Abberton Carol Baclawski
debabberton@gmail.com carolannbaclawski@gmail.com
Melissa Abell-Bardsley Shelli Barry
lookout_maa@yahoo.com Shelli.barry@gmail.com

John Allen Angie Benoit

jsallen@bikexprt.com aneville9@yahoo.com
Ron Ayers Zac Borrelli
ronayers@gmail.com email

Waltham High School | Final Environmental Impact Report 1 | p. 2

 Section 1: Distribution List

Isabel Brassil Maureen Bagge Fowler

Isabel.brassil@gmail.com mbaggefowler@yahoo.com

Amy Brown Superintendent George Frost

abrown@watchcitymanagement.com georgefrost@walthampublicschools.org

Michelle Campbell Rachel Gagne

mtsoup01@hotmail.com Vdub.rachel@gmail.com

Colette Casey-Brenner Alison Guzman

ccaseybrenner@gmail.com alyvons@stanfordalumni.org

Laura Cannon Jose Guzman

laura@fosterandcannon.com Jrman75@hotmail.com

Mike Chen Tom Haley

Mchen222@gmail.com tomhaley73@gmail.com

Philip Chorman Robert Hanley

bigdeliciousband@yahoo.com hanleybnl@icloud.com

Robert Coleman William Hanley

rcolema1@ix.netcom.com whanley1@gmail.com
Amy Corbett Robert Hargrove
amyc913@gmail.com Roberthargrove611@gmail.com

Lynelle Cortellini-Devine Karina Hines

Lynelle_c@hotmail.com hineskarina@gmail.com

Rebecca Cyr Elizabeth Homan

rebeccaacyr@comcast.net elizabethhoman@walthampublicschools.org

Jaclyn Davidson Paula Hughes

jdavidson@local22.net hughespaula@comcast.net

Michele DesAutels Paul Hughes

micheledesautels@gmail.com hughespaula@comcast.net

James Devin Alicia Hutton

Jdevin501@verizon.net Aliciageorge623@hotmail.com

Reva Dolobowsky Tammy Donroe Inman

revad@comcast.net tdonroe@gmail.com

Carol Dunbar Jeannie Joe

carol_12343@hotmail.com jeanniejoe@gmail.com

City Councilor Sean Durkee Heather Johnson

sdurkee@city.waltham.ma.us heatherj1964@gmail.com

Jeffrey Esposito JP Jones

jeffreyesposito@hotmail.com roscojjj@gmail.com

Donna Fils-Aime Jacob Katz

dcesary@yahoo.com jacobkatz@walthampublicschools.org

Kit Fintzel Paul Katz

kitfintz@gmail.com 89pkatz@gmail.com

Bill Fowler Sharon Katz

bfowlerma@yahoo.com sharon.katz@comcast.net

Waltham High School | Final Environmental Impact Report 1 | p. 3

 Section 1: Distribution List

Michelle Kern Kristen Mullin

mckern4527@gmail.com Kristen858@gmail.com

David King Geri Nederhoff

daking350@verizon.net gerinederhoff@gmail.com

Tom King Elsie Ordlie

Tkkk2008@comcast.net e.ordile8@gmail.com

Ben Kuchler Luisa Pandolfi

benkuchler@gmail.com luisa.pandolfi@yahoo.com

Erika Kuno Alysia Parkes

ekuno@outlook.com alysiaparkes@gmail.com

Carolina Lara Susan Parrella

carolara@hotmail.com sueparr39@gmail.com

Elizabeth Lear Christin Piccirilli

eliz.lear@gmail.com christinpic@gmail.com

Megan Letendre Brandice Proskoczilo

megletendre@gmail.com brandice_hermann@hotmail.com
Karen Pruy
Donald Lucente kleepruy@gmail.com
donlucente@yahoo.com
Evelyn Reily
C. David Luther evreilly2468@gmail.com
cannon781@aol.com
Sarah Remage-Healey
Carolina Lara sarah.remage-healey@brighthorizons.com
carolina.lara@NEMoves.com
Christine Reynolds
Ruby Flores Lopez
rdandm@comcast.net
rubyelizabethlopez@live.com
Doug MacDonald Patricia Roche and David Brountas
doug.macdonald@ymail.com Patricia.roche133@verizon.net

Thomas Maclellan Patrick Rooney

thom.maclellan@hotmail.com patrickrooney996@gmail.com

Pradip Mallik Jennifer Rose

pradipm@busitants.com jennifer@downtown-diva.com

Kathi Martuza and Kester Cotton

kathimartuza@gmail.com Tammy Rose
cristinaroseup@gmail.com
Christopher Matteodo
cmatteod@gmail.com Jennifer Roy
Jennr5000@yahoo.com
Mayor Jeannette McCarthy
mayor@city.waltham.ma.us Margaret Schadelbauer
divapegret@yahoo.com
Paula McNiece
gjgpjm24@gmail.com Jude Seminara c/o Caren Dunn, Councillor-
elect
Orlando Medeiros caren_dunn@yahoo.com
medeiom@outlook.com
Pat Seminara
Hector R. Montesino jpnmom@aol.com
bostonhector@aol.com

Waltham High School | Final Environmental Impact Report 1 | p. 4

 Section 1: Distribution List

Valerie Sharpe Charles River Watershed Association (CRWA)

vcsharpe129@gmail.com Heather Miller
hmiller@crwa.org
James Simeone
jimsimeone37@gmail.com Department of Energy Resources (DOER)
Paul Ormond and Brendan Place
Nadene Stein
nadenestein@walthampublicschools.org MassBike
galen@massbike.org
Kathleen Simpson
kathleensimpson14@gmail.com MassBike
jsallen@bikexprt.com
State Rep. Thomas M. Stanley
State Rep. John J. Lawn MassDEP
Senator Michael J. Barrett john.d.viola@mass.gov;
john.d.viola@state.ma.us (duplicate)
George Sumner
lsumner660@gmail.com Massachusetts Water Resources Authority
(MWRA)
Larry Sumner Bethany Card
Lsumner660@gmail.com
Massachusetts Water Resources Authority
Kristen Thibodeau (MWRA)
kris071254@gmail.com Katherine.ronan@mwra.com (duplicate)

Kaj Telenar WalkBoston and MassBike

kaj.telenar@gmail.com Brendan Kearney and Galen Mook
bkearney@walkboston.org
Alex Urquhart
alexurquhart@comcast.net Waltham Citizens for Education
celeste@bewellwithin.com
Laura Urquhart
lauraurquhart@comcast.net Waltham Historical Commission
Mort Isaacson
David Westner whc@city.waltham.ma.us
davidwestner@gmail.com
Waltham Land Trust
Rachel Weinstein Anna Richardson
rachel_weinstein@hotmail.com arichardson@walthamlandtrust.org
Donna Weitz Waltham Land Trust
donna_ayres5@hotmail.com swadman@walthamlandtrust.org
Emily Wiseheart Waltham Land Trust
wisehearte@gmail.com mrudnick@walthamlandtrust.org
Steve Wolff Christina McCalla
steve@profwolff.org mccallac@gmail.com

Celeste Woodside Christy Kahana

celeste@bewellwithin.com christy@ckhrconsulting.com

Waltham High School | Final Environmental Impact Report 1 | p. 5

Other Interested Parties
robert.boeri@state.ma.us
jsaxeman@gmail.com
nathaniel.tipton@state.ma.us
mmd@juno.com
mmd65@juno.com
gary.moran@state.ma.us
pawprints227@yahoo.com
pbrasco@brascofuneralhome.com
paul.stedman@state.ma.us
pke041@aol.com
kyle.lally@state.ma.us
Rwrubel@massaudubon.org
melany.cheeseman@state.ma.us
schleelein@gmail.com
mpillsbury@mapc.org
wdoyle@city.waltham.ma.us
serafina.t.zeringo@state.ma.us
Howejeff@comcast.net
marianparrella@walthampublicschools.org
mrimmer@rimmerenv.com

1 | p. 6 Waltham High School | Final Environmental Impact Report

ENF Certificate
DEIR/Notice of Project Change Certificate
 The Commonwealth of Massachusetts
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Charles D. Baker
GOVERNOR
Tel: (617) 626-1000
Karyn E. Polito
LIEUTENANT GOVERNOR
Fax: (617) 626-1081
http://www.mass.gov/eea
Kathleen A. Theoharides
SECRETARY

June 26, 2020

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS

ON THE
NOTICE OF PROJECT CHANGE / DRAFT ENVIRONMENTAL IMPACT REPORT

PROJECT NAME : Waltham High School

PROJECT MUNICIPALITY : Waltham
PROJECT WATERSHED : Charles
EEA NUMBER : 16097
PROJECT PROPONENT : City of Waltham
DATE NOTICED IN MONITOR : May 20, 2020

Pursuant to the Massachusetts Environmental Policy Act (M.G.L. c. 30, ss. 61-62I) and Section
11.08 of the MEPA Regulations (301 CMR 11.00), I have reviewed the combined Notice of Project
Change (NPC)/Draft Environmental Impact Report (DEIR) and hereby determine that it adequately and
properly complies with MEPA and its implementing regulations.

The NPC/DEIR described changes to the project, most notably the incorporation of an adjacent
6-acre parcel, referred to as Jericho Hill Parcel II, into the project site. As described below in greater
detail, the addition of this parcel enabled the reconfiguration of the proposed layout, resulting in a new
Preferred Alternative that eliminates direct impacts to wetland resource areas and reduces the amount of
land alteration and impervious area. The NPC/DEIR indicated that these revisions were in made in
response to the Scope issued in the Certificate on the Environmental Notification Form (ENF), which
requested continued evaluation of alternatives that avoid significant impacts to wetland resource areas.
Comments from the Massachusetts Department of Environmental Protection (MassDEP), interim
Waltham Public Schools Superintendent George Frost, and the Waltham legislative delegation (State
Representative Thomas M. Stanley, State Representative John J. Lawn, Jr., and State Senator Michael J.
EEA# 16097 NPC/DEIR Certificate June 26, 2020

Barrett) express support for the revised layout and associated reduction in impacts. Comments from
residents also support the new Preferred Alternative, highlight the urgent need for a new facility, and
indicate the new school will provide educational equality. Comments from the Waltham Land Trust and
other residents identify concerns with the addition of the Jericho Hill II Parcel, currently serving as open
space, into the project site without mitigating measures such as permanent protection of other land
through a recorded conservation restriction or similar means. Comments from residents and abutters also
continue to identify concerns with impacts to groundwater, loss of wildlife habitat, and traffic and
congestion.

The MEPA process has provided, and will continue to provide, a valuable forum for the
collection of all relevant points of view, but reconciling all of the identified (and sometimes competing)
concerns is beyond the scope of the MEPA. The primary purpose of the MEPA process is to provide
meaningful opportunities for public review of the potential environmental impacts of the Project and to
refine the project in the subsequent DEIR and Final Environmental Impact Report (FEIR) process as
design progresses. The MEPA process requires public disclosure of a project’s environmental impacts as
well as the measures that the Proponent will undertake to mitigate these impacts. MEPA review occurs
before state agencies act to issue Permits or Financial Assistance for a proposed project to ensure that
they are fully cognizant of the environmental consequences of their actions. MEPA review is not a
permitting process, nor does it serve as an appeal for local decisions. It is not a zoning process, and it
does not proscribe to a Proponent what, where, or how a project should be designed or built. While I
expect that the FEIR will serve to provide further transparency and explanations of environmental
impacts and mitigation, the many concerns about the design of the project will continue to be reviewed
as the final design of the project proceeds to permitting before the City. This certificate is not intended
to prejudge the outcome of those subsequent permitting procedures.

Project Description

As described in the ENF, the project includes the demolition of existing structures (a retreat
house and conference center) and construction of a new high school building (414,850 gross square feet
(sf); 484,240 gross sf including the parking structure) with associated site work, utilities, above- and
below-ground parking, on-site access roadways, stormwater infrastructure, and two athletic fields (an
existing natural field and a new synthetic turf field). The project is proposed to meet the full
programmatic requirements for a 1,830-student, 9th-through-12th-grade high school. The project
includes significant earthwork to achieve final design grades of the project, including significant
bedrock excavation using a combination of hoe ramming and controlled blasting techniques. An early
site preparation phase will include clearing, earthwork, blasting, grading, and preparation for the
building construction followed by construction of the building. The existing high school building will be
repurposed for other uses at a later time, no earlier than 2024.

As previously described in the ENF, the existing 388,000-sf Waltham High School was
constructed in 1968 and does not meet current building, accessibility, and safety standards, nor does it
accommodate educational programming needs and increases in student population. The ENF indicated
that the existing high school will risk losing its accreditation in 2027 without significant investment in
the building or the construction of a new high school. The NPC/DEIR noted the City’s future needs
related to the growing student population. The City is in need of additional space for either a
Kindergarten (K) through 8th grade school or a middle school to relieve overcrowded conditions.

2
EEA# 16097 NPC/DEIR Certificate June 26, 2020

Following construction of the new high school, the City will repurpose the existing high school to meet
these needs. For the purpose of evaluating environmental impacts, the DEIR assumed that the McDevitt
Middle School (grades 6-8) and the Dual Language School at the Waltham Community and Cultural
Center (formerly South School) (K-5) would be relocated to the existing high school building. It also
assumed the existing high school building would house the District’s Central Office and Parent
Information Center (PIC). Renovation of the existing high school for these uses is not anticipated to
commence until 2024 at the earliest.

Project Changes Since the ENF

Project changes include the incorporation of an adjacent 6-acre parcel (Jericho Hill II) into the
project site and reconfiguration of the project layout. The addition of this parcel enabled relocating the
athletic field and parking from the northcentral portion of the site to behind the building and shifting the
building west by approximately 90-ft. The NPC/DEIR indicated the reconfiguration was in response to
the Secretary’s Scope which requested further evaluation of alternatives that avoid significant impacts to
wetland resource areas. The revised layout locates all the significant programmatic elements on one side
of the intermittent stream, avoids impacts to wetland resource areas, and retains an existing natural turf
field located on the eastern portion of the site. As described below in greater detail, the NPC/DEIR also
presented a revised plan to provide secondary emergency access to the site.

Project Site

The approximately 52.5-acre project site is comprised of three parcels located at 554 Lexington
Street (46.5 acres) and one adjacent parcel known as Jericho Hill II located at 131R Lincoln Street (6
acres) in Waltham. The site is generally bounded by undeveloped land to the west (known as Sanderson
Heights), residential areas to the north and south, and Lexington Street and residences to the east. The
site was previously owned by the Stigmatine Fathers Inc. Trust and contains buildings associated with
the Espousal Retreat House and Conference Center which will be demolished as part of the project.
Existing development is located on the southern portion of the site. The remainder of the site is
undeveloped and contains areas of relatively steep slopes. Topography ranges from an elevation of 106
ft at Lexington Street to 286 ft at the highest portion of the site near the northern property line. Site
access is provided via a single driveway from Lexington Street.

An intermittent stream runs north to south through the center of the site and has associated areas
of Bordering Vegetated Wetlands (BVW). The stream extends from a high point in the north central
portion of the site to a point in the middle of the site where the stream enters underground piping that
extends off the site and under Lexington Street to Chester Brook. The project site is not located in
Priority and/or Estimated Habitat as mapped by the Division of Fisheries and Wildlife’s (DFW) Natural
Heritage and Endangered Species Program (NHESP) or an Area of Critical Environmental Concern
(ACEC). The project site contains one building that is listed in the Massachusetts Historical
Commission’s (MHC) Inventory of Historic and Archaeological Assets of the Commonwealth and is
identified as MHC ID# WLT.138. The ENF contained correspondence from MHC dated February 19,
2019 which acknowledged the building would be demolished and indicated that no further MHC review
is required for the project.

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Environmental Impacts and Mitigation

As summarized in the table below, the revised project layout has eliminated impacts to wetland
resource areas and reduced other environmental impacts.

Environmental Impact ENF NPC/DEIR Net Change

Total Site Area (acres) 46.5 52.5 6
Land Alteration (acres) 12.95 10.2 -2.75
New Impervious Area (sf) 9.72 9.54 -0.18
Bordering Vegetated Wetlands (sf) 4,760 0 -4,760
Inland Bank (lf) 1,680 0 -1,680
New Trip Generation (average daily vehicle trips; adt) 1,491 1,851 360 1
Parking Spaces 554 454 -100
Water Use (gallons per day; gpd) 30,550 6,380 -24,170
Wastewater Generation (gdp) 26,568 4,575 -21,993

Measures to avoid, minimize, and mitigate environmental impacts include: an upgraded

stormwater management system, redesigning the project to eliminate wetland impacts, traffic
signalization and roadway improvements, implementation of energy efficient building systems and
features, and implementation of a construction management plan.

Jurisdiction and Permitting

The project is undergoing MEPA review and requires preparation of an ENF pursuant to
Sections 11.03(1)(b)(2), 1.03(6)(b)(14), and 11.03(6)(b)(15) of the MEPA regulations because it
requires a State Agency Action and will result in the following: creation of five or more acres of
impervious area; generation of 1,000 or more New adt on roadways providing access to a single location
and construction of 150 or more New parking spaces at a single location; and construction of 300 or
more New parking spaces at a single location (respectively). 2 The project will receive Financial
Assistance from the Massachusetts School Building Authority (MSBA).

The project requires an Order of Conditions from the Waltham Conservation Commission (or in
the case of an appeal, a Superseding Order of Conditions from the Massachusetts Department of
Environmental Protection (MassDEP)). 3 The project is subject to review by and requires permits from

1 The trip generation has been revised since the ENF was filed to account for the trips associated with future reuse of the
existing high school (360 adt).
2 The ENF indicated the project also exceeded the threshold at 301 CMR 11.03(3)(b)(1)(b) – Alteration of 500 or more linear

feet of bank along an inland bank. The project has been redesigned and no longer exceeds this threshold.
3 The project also requires a Superseding Order of Resource Area Delineation (ORAD) from MassDEP. This is not

considered an Agency Action as defined at 301 CMR 11.02.

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several City of Waltham agencies, including: a Variance from the Zoning Board of Appeals (ZBA),
Special Permit from the Board of Survey and Planning, Demolition and Construction Permits from the
Building Department, Blasting Permit from the Fire Department, and approval for curb cuts and street
opening from the Consolidated Public Works Department. It also requires a National Pollutant
Discharge Elimination System (NPDES) Construction General Permit from the U.S. Environmental
Protection Agency (EPA).

Because the project will receive Financial Assistance, MEPA jurisdiction for this project is broad
and extends to all aspects of the project that are likely, directly or indirectly, to cause Damage to the
Environment as defined in the MEPA regulations.

Review of the NPC/DEIR

The NPC/DEIR was responsive to the Scope and identified changes to the project to minimize
environmental impacts as compared to the ENF. The NPC/DEIR described the proposed project and
changes since the filing of the ENF. The NPC/DEIR identified existing conditions, described potential
environmental impacts and mitigation measures, and provided a discussion of alternatives. It included
updated site plans for existing and proposed conditions, a brief description of applicable statutory and
regulatory standards and requirements, and an explanation of how the project will meet the standards. It
included a list of required State Permits, Financial Assistance, or other State approvals and provided an
update on the status of each of these pending actions. It provided figures depicting secondary emergency
access and conceptual site plans for proposed off-site improvements. The NPC/DEIR provided
clarification regarding the school district’s Master Educational Plan and athletic field requirements. The
list of priorities for athletic fields (sometimes referred to as the Athletic Field Master Plan; provided as
Appendix 2.2) was created for planning purposes as a guide to evaluate alternatives and to identify
locations which could accommodate additional athletic programs. The NPC/DEIR clarified it was not
the intent to provide fields for all athletic programs on a single site.

The NPC/DEIR presented a revised plan to provide a secondary emergency access site which is
not required by Code but was requested by the City’s Police Chief and Fire Chief. The ENF previously
indicated that the only viable alternative for providing secondary access without acquisition of
additional land was a route through two abutting parcels owned by the City (Jericho Hill II and
Sanderson Heights). The NPC/DEIR indicated that Sanderson Heights was eliminated from
consideration because the property is not controlled by the Waltham School Department. The
NPC/DEIR indicated that secondary emergency access will be provided via an existing easement as the
City does not want to acquire additional land. The City has a water, sewer, and drain easement that
extends from the end of Lincoln Street to the 554 Lexington Street property line, referred to as Lincoln
Street Extension. The project will construct a 20-ft wide paved drive on the project site for use by
emergency vehicles. The 20-ft paved drive which will connect the on-site internal roadway network to
the edge of the 554 Lexington Street property line where it will connect to the abutting easement. The
NPC/DEIR indicated the easement provides the City with maintenance rights and that the City may pave
Lincoln Street Extension. Access to this emergency road will be gated at the property line abutting the
easement and at the high school internal roadway. A six-foot high chain link fence will be installed
along the southern boundary line to prevent students from walking through private properties.

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Alternatives Analysis

The Scope required the City to reconsider the alternative site layouts presented in the ENF
(Alternatives 1-5) in light of MassDEP’s comments on the ENF, which noted that alternatives that avoid
significant impacts to Bank or BVW should continue to be explored even if they result in increased
impacts to upland areas or require increased blasting. Alternatives 1-5 were alternative site layouts
specifically focused on reducing impacts to the intermittent stream and BVW. The Scope also required
the City to evaluate alternatives to mitigate the loss of Bank and BVW. As noted above, the project has
been revised to eliminate all impacts to wetland resource areas. The DEIR did not present any new
alternatives, other than the revised Preferred Alternative. As summarized below, the NPC/DEIR
compared the environmental impacts of the revised Preferred Alternative to the Alternatives described in
the ENF, including Alternatives Option A-B and Alternatives 1-5.

Altered Altered New Land New Estimated Length of

Alternative
Alternative Bank BVW Alteration Impervious Rock Rock
Description
(lf) (sf) (ac) Area (ac) Removal (cy) Walls (lf)
1
No Build 0 0 0 0 0 0
2 ENF Preferred
1,680 4,670 12.95 9.72 780,000 2,215
Alternative
Replication
3 Similar to
1,200 4,670 12.60 9.72 780,000 2,215
Schematic
Design
Intermittent
Stream
Replication
4
Between 1,040 4,670 14.80 9.99 985,000 3,460
Separated
Development
Areas
Existing
Intermittent
Stream to
5
remain Between 0 0 14.75 13.8 930,000 3,430
Separated
Development
Areas
Located school
near Lexington
Option A Street within 1,700 4,670 12.90 10.25 930,000 2,250
developed
portion of site.
Located school
Option B further into 1,300 4,670 13.8 11.25 950,000 2,620
project site.
NPC/DEIR
Preferred Revised
0 0 10.89 9.54 747,000 1,920
Alternative Preferred
Alternative

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The NPC/DEIR identified the pros and cons of each of the alternatives. The NPC/DEIR
indicated that the Preferred Alternative was selected based on the following criteria: fulfills the goals of
the project to meet the educational needs for the children of Waltham; avoids impacts to wetland
resource areas and will restore previously filled Bank and BVW; provides integrated design among the
building, athletic field, and parking area; and allows for maintenance of the existing natural field area
near Lexington Street, on the other side of the intermittent stream from the proposed school.
Additionally, it will result in less land alteration, impervious area, earthwork/blasting, and removal of
blast material compared to the other alternatives. Comments from MassDEP support the Preferred
Alternative as it avoids impacts to wetland resource areas. The NPC/DEIR indicated the Preferred
Alternative will increase the buffer to residential areas on the east side of the project (Lexington Street)
but reduce the buffer to residential areas on the south side (Lincoln Street, Lincoln Terrace, and Glen
Circle). Comments from abutters identify concerns regarding noise and light from the proximate athletic
fields during sporting events. Comments also request additional analysis of alternative locations for the
project, including 617 Lexington Street (adjacent to the existing high school) and 200 Trapelo Road
(former Fernald Hospital). I note that these alternative locations were previously evaluated in the ENF
and the Scope for the NPC/DEIR did not require further analysis.

Land

The project will alter 10.2 acres of land and will create 9.54 acres of new impervious area. The
NPC/DEIR indicated that relocating the athletic field allows the existing natural field and north-central
portion of the site to remain as undisturbed wooded area. It also reduced impervious area through
elimination of previously proposed on-site access roads. I encourage the City to consider placing a
conservation restriction on these portions of the site that will remain as undeveloped open space to
ensure their permanent protection. The ENF previously proposed the use of porous pavers 4 in a
pedestrian plaza area located adjacent to the athletic field. The NPC/DEIR asserts that porous pavers are
no longer needed as the area of the pedestrian plaza and overall impervious area have been reduced. The
NPC/DEIR included a new commitment to construct green vegetated roofs on the third floor of the
building (approximately 3% of the overall roof area).

The NPC/DEIR included a copy of the updated geotechnical report (Appendix 3.1) which
described additional geotechnical work that has occurred to evaluate subsurface conditions. The site
contains steep topography and will require a significant amount of grading and controlled blasting,
creation of a 1,920 lf rock wall cut face, and removal of 747,000 cubic yards (cy) of material from the
site. The NPC/DEIR included figures that conceptually identified the proposed areas of cut and fill,
areas that will require blasting, and approximate elevation changes necessary to achieve proposed grade
given exiting topography. The majority of the cut material will be comprised of rock which will be
crushed, processed, and re-used on-site. Limited fill material will be imported to the site. The
NPC/DEIR confirmed that project specifications will prohibit the use of perchlorates in blasting
materials to avoid impacts to water quality and wetlands.

As requested by the Scope, the NPC/DEIR provided information to address whether the project
parcels are protected in accordance with Article 97 of the Amendments to the Constitution of the
Commonwealth (Article 97) (Appendices 3.2 – 3.4 of the NPC/DEIR). This information included

4Porous pavers are a cellular grid system filled with gravel or soil and grass that provide ground stabilization while reducing
compaction of the soil to maintain permeability and improve stormwater quality through infiltration.

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written opinions from the City’s Law Department which state that the parcels at 554 Lexington Street
and 131R Lincoln Street (Jericho Hill II) are not subject to the protections of Article 97. According to
information provided with the NPC/DEIR, the City took the 554 Lexington Street parcels by eminent
domain in 2018 for the purpose of educational use, open space, or combination thereof. In 2019, the City
Council transferred the care, custody, and control of the parcels to the Waltham School Committee and
the Waltham School Department for educational use and the purposes associated with educational use.
In 2001, the City obtained the 131R Lincoln Street parcel (Jericho Hill II) through a friendly
taking/purchase for municipal purposes. According to the NPC/DEIR, on March 9, 2020, the Waltham
City Council transferred the care, custody, and control of the Jericho Hill II parcel to the Waltham
School Committee and Waltham School Department for educational use and purposes associated with
educational use. Comments received from residents identify concerns that this parcel was transferred
without an opportunity for public input. Comments also identify concerns about development of the
school building on a location that provided public open space and request that the City place a
conservation restriction (CR) on the northerly portion of the project site to permanently protect it as
publicly accessible open space.

Wetlands/Stormwater

The addition of the Jericho Hill II Parcel allowed the vast majority of the project to be sited on
one side of the intermittent stream, eliminating all wetland impacts, including the need to fill and reroute
the stream. The project will impact 1.44 acres of buffer zone. Work within the buffer zone includes
removal of fill, construction of roadways and sidewalks, and earthwork required to achieve design
grades. Comments from MassDEP are supportive of the revised project design which avoids impacts to
wetland resource areas. The project also includes removal of historic fill to restore approximately 550 sf
of BVW and 270 lf of bank associated with an intermittent stream. As noted during review of the ENF,
these resource areas were identified through proceedings related to a Superseding Order of Resource
Area Delineation (ORAD) for 554 Lexington Street. The NPC/DEIR noted that MassDEP is still
processing the Superseding ORAD, which will determine the resource area boundaries on the site.
Project plans provided with the NPC/DEIR depicted resource areas consistent with MassDEP’s findings
at the site investigations for the Superseding ORAD. Comments from MassDEP indicate the
Superseding ORAD will be issued upon issuance of the MEPA Certificate. I note that a Superseding
ORAD is not considered an Agency Action as defined at 301 CMR 11.03, and as such, may be issued
prior to the completion of the MEPA review process.

The project will create 9.54 acres of impervious area (14.16 total acres). The NPC/DEIR
indicated the stormwater model was updated to account for the project changes, including the addition of
Jericho Hill II and the revised project layout. The stormwater management system will incorporate the
following Best Management Practices (BMPs): bioretention swales, subsurface detention basins, hooded
deep sump catch basins, and structural water quality units. The NPC/DEIR indicated the project will be
considered a redevelopment per the MassDEP SMS and acknowledged that the site access road is
considered a Land Use with Higher Potential Pollutant Loads (LUHPPL) for the purposes of applying
the SMS. As such, the stormwater management system has been designed with suitable BMPs to treat
the one inch water volume and provide adequate treatment prior to infiltration. The NPC/DEIR indicated
the project will improve drainage conditions on abutting properties through installation of a drainage
swale along the eastern side of the property line and site grading along the southern edge of the property
which will intercept stormwater runoff from the site and direct it to the on-site drainage system.

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The project is required to comply with the Total Maximum Daily Load (TMDL) for nutrients in
the Upper/Middle Charles River, which requires no additional inputs of phosphorous to the river and a
significant reduction from existing development. The NPC/DEIR provided phosphorus load calculations
which indicate that the project will result in a post-development export of approximately 16 lbs/year of
phosphorous. I refer the City to comments from the Charles River Watershed Association (CRWA)
which encourage additional use of surface biofiltration strategies to ensure compliance with the TMDL.
The NPC/DEIR indicated that site constraints (such as large amounts of cut land, proximity to
groundwater and wetland resources, steep slopes, and compact site design footprint) limit opportunities
to incorporate bioretention and water quality swales to further reduce nutrient loads.

Currently, all stormwater that leaves the site eventually discharges to Chester Brook. The on-site
intermittent stream is a tributary that also discharges to Chester Brook. The project includes earthwork
and 280 lf of bedrock cuts (i.e. rock walls) located parallel to and approximately 50-ft south of the
intermittent stream. The NPC/DEIR indicated that this work is not anticipated to impact surficial flow
within the stream channel due to the 50-ft setback distance and the lower bedrock wall heights in this
area (ranging from 0 to 40-ft high). Earthwork and the rock wall will cut off flows from a 0.4 acre
portion of the intermittent stream’s contributing watershed (20.39 total acres). The flows from this area
will combine with the rest of the site’s runoff and will ultimately still discharge to Chester Brook. The
NPC/DEIR indicated that this reduction is insignificant (2% of the existing intermittent stream
watershed) and that the loss of tributary area is not anticipated to adversely affect the wetland system.
The NPC/DEIR noted that potential impacts from existing fractures and/or joints within the bedrock will
be further evaluated relative to possible impacts to surficial flow within the stream channel as project
design progress.

Depths to groundwater across the site vary from between 1- to 12.5-feet in test pits and 8.2- to
12.5-feet in best borings. Portions of the rock wall, building, and below-grade parking structure will be
below groundwater elevations. The project includes a permanent, below-slab and perimeter foundation
system and a piped drainage system along the base of the rock wall to collect groundwater and
incorporate it into the stormwater management system. The NPC/DEIR indicated that a series of test
borings with observation wells and groundwater pump tests will be conducted to further understand
hydrogeologic conditions in the bedrock and groundwater flow rates and to further evaluate groundwater
flow and direction.

Traffic/Transportation

The NPC/DEIR indicated that trip generation and the number of parking spaces were revised to
account for 360 additional trips and the elimination of 100 parking spaces associated with repurposing
the existing high school. The NPC/DEIR confirmed that the Traffic Impact Analysis (TIA) previously
included the future reuse of the existing high school as part of the future build conditions. The project
will result in 1,851 new adt and 454 new parking spaces (650 total parking spaces). Approximately 450
of the 650 total parking spaces will be provided in a subsurface parking garage below the artificial turf
field. Many comment letters on the ENF identified concerns with increased congestion on Lexington
Street and referenced a report to the Waltham Traffic Commission which indicated the project will
significantly increase traffic on Lexington Street to a point where it may exceed the street’s capacity.
The NPC/DEIR provided a response to the analysis performed by the City Traffic Commission.

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As noted in the ENF, the project will signalize the site driveway’s intersection with Lexington
Street and installation of turning lanes on Lexington Street to mitigate the project’s transportation
impacts. The City proposes to increase the design speed on Lexington Street and to eliminate existing
bike lanes on Lexington Street to accommodate the addition of turning lanes. A shared bike lane will be
incorporated into the northern lane to offset the elimination of the dedicated bike lane. The NPC/DEIR
indicated this portion of Lexington Street cannot accommodate both an exclusive bike lane and the
proposed turning lanes without private land takings (presumably to widen the right of way). The
NPC/DEIR did not provide figures or additional documentation to support this. I refer the City to joint
comments from MassBike/WalkBoston and others which identify concerns that vehicle accommodations
are being provided at the expense of the safety of bicyclists and pedestrians, especially given the
increase in design speed along Lexington Street. I expect the City will continue to evaluate and will
commit to measures that will improve safety for bicyclists and pedestrians along this corridor. These
measures should be specifically identified in the FEIR and incorporated into the draft Section 61
Findings.

The NPC/DEIR indicated the City will investigate implementing adaptive signal control
technologies at the signalized intersections along the Lexington Street corridor. I encourage the City to
implement this measure which may reduce congestion and improve traffic operations in the area. The
NPC/DEIR did not clarify whether the other measures identified in the TIA to improve operations on the
Woodcliff Drive and Forest Street approaches, and at the Lexington Street/Lake Street/Bishops Forest
Drive and Lexington Street/Existing School Exit Only Driveway intersections will be implemented as
part of this project. This should be clarified in the FEIR and these measures should be incorporated into
the draft Section 61 Findings.

Climate Change

The NPC/DEIR provided an analysis of stationary- and mobile-source GHG emissions and
identified measures to mitigate the project’s GHG impacts. As described below, it also included a
general discussion of vulnerabilities of the site to the potential effects of climate change.

Greenhouse Gas Emissions

The NPC/DEIR included an updated GHG analysis based on the MEPA Greenhouse Gas Policy
and Protocol (the Policy). The GHG Policy requires projects to quantify carbon dioxide (CO2) emissions
and identify measures to avoid, minimize or mitigate such emissions. The analysis quantified the direct
and indirect CO2 emissions associated with the project's energy use (stationary sources) and
transportation-related emissions (mobile sources). The DEIR outlined and committed to mitigation
measures to reduce GHG emissions. The stationary source GHG analysis evaluated CO2 emissions for
two alternatives as required by the Policy; the Base Case and the Design Case. The Base Case was
designed to meet the minimum energy requirements of the 9th Edition of the Massachusetts Building
Code, which references the American Society of Heating, Refrigerating and Air-Conditioning Engineers
(ASHRAE) 90.1-2013. The Design Case included additional energy-efficiency measures proposed in the
Preferred Alternative. The City of Waltham has adopted the Massachusetts Stretch Energy Code (SC).
Therefore, the project will be required to meet the applicable version of the SC in effect at the time of
construction. The SC requires at least a 10-percent reduction in energy use compared to the base

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Building Code requirements. According to the NPC/DEIR, the Town intends to design the project to
exceed the energy efficiency requirements of the Building Code by at least 20%, which will make it
eligible for an additional reimbursement from the MSBA. I refer the City to comments from DOER
which indicate that the SC will include several new amendments that will become effective in August of
this year. The NPC/DEIR indicated that an updated energy modelling analysis based on the new
Building Code will be conducted during the design development phase.

The GHG analysis used eQuest modeling software to quantify stationary source emissions from
the project. The NPC/DEIR included a summary of modeling inputs (e.g., R-values, U-values,
efficiencies, lighting power density, etc.) for both the Base Case and Preferred Alternative. The
NPC/DEIR identified those energy efficiency measures that will be incorporated into the project and
were modeled in the GHG analysis, measures that were dismissed as infeasible or inappropriate (solar
hot water, solar PV, ground source heat pumps, cogeneration, fuel cells), and measures that will be
studied further during the advanced design stages. As presented in the NPC/DEIR, key building related
energy efficiency measures proposed for the buildings include:
 High-performing building envelope insulated beyond Code (wall assembly U-factor=0.0357;
roof assembly U-factor=0.0208);
 High-performing lighting systems and controls beyond Code, including reduced Lighting Power
Densities (LPD) (0.5 watts/square foot), daylight and vacancy controls, and advanced digital
lighting controls;
 Solar-ready rooftop and electrical system;
 Electric-Vehicle (EV) charging stations for 2% of parking spaces;
 A high efficiency mechanical HVAC system including:
o Direct Outside Air Ventilation System (DOAS) with heat recovery (design effectiveness
of 70% or better);
o High efficiency air cooled chiller;
o Demand control ventilation for all occupied spaces;
o Temperate setback during unoccupied hours;
o VFDs on pumps;
o High performance condensing natural gas boilers (95% efficiency); and
o High performance natural gas hot water boiler.

The NPC/DEIR included a commitment to design the rooftop and electrical system to be solar
ready. It did not include a commitment to install or reserve rooftop space for a solar PV system. The
NPC/DEIR noted that solar PV is not considered for the project as the City of Waltham cannot commit
to rooftop PV at this time. It did not provide a feasibility analysis or financial assessment to support its
dismissal. Additional analysis of solar PV is required in the FEIR. The NPC/DEIR indicated that
repurposing the existing high school facility will not occur until 2023 at the earliest. The City will
maintain and upgrade the building systems as needed until substantial retrofits are proposed as part of
the building’s reuse. The NPC/DEIR identified energy conservation measures that will be considered as
part of future upgrades and retrofits.

The NPC/DEIR indicated the City will encourage and promote a Transportation Demand
Management (TDM) program to reduce mobile source GHG emissions. The TDM program may include
the following measures:
 Encouraging and incentivizing the use of buses;

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 Limiting bus and vehicle idling at the school;

 Providing improved site circulation and intersection design to reduce idling times for vehicles;
 Encouraging the use of bicycles and pedestrian traffic to the school and providing numerous
secure bike racks/storage;
 Providing vehicle charging stations for electrical vehicles;
 Offering preferred parking for carpool and low emission vehicles; and
 Providing assigned parking spaces to minimize travel time on-site.

The TDM plan was not included as a mitigation commitment nor incorporated in the draft
Section 61 Findings. The City’s commitment to implement the above TDM programs should be clarified
in the FEIR.

Mobile GHG emissions were estimated using the standard methodology in the
EEA/MassDOT Guidelines for EIR/EIS Traffic Impact Assessments and MOVES CO2 emission factors.
Mobile source GHG emissions were calculated for the 2024 No Build Condition, 2024 Build without
TDMs Condition, and 2024 Build with TDMs Condition. There are discrepancies in the analysis as the
NCP/DEIR states that the 2024 Build Case includes roadway mitigation measures but not TDMs. This
discrepancy should be clarified in the FEIR. Additionally, the NPC/DEIR indicated that the 2024 No
Build and 2024 Build cases both include emissions associated with new project-generated trips in
addition to existing background traffic. It is unclear why project-generated emissions are included in the
2024 No Build scenario. Mobile source GHG emissions were calculated by subtracting the 2024 No
Build values from those for the 2024 Build Cases. To accurately understand the mobile source GHG
emissions associated with the project, the FEIR should exclude project-generated trips from the 2024 No
Build Condition and should compare the GHG emissions associated with the 2024 Build Condition
(with no roadway improvements or TDM measures) to the 2024 Build with Mitigation Condition (i.e.
with roadway improvements and TDM measures), and propose additional mitigation measures, if
necessary.

The GHG analysis indicates that the project will generate approximately 2,283 tons per year
(tpy) of stationary source Base Case emissions. The Preferred Alternative, developed to demonstrate
consistency with the Policy and the SC, will reduce stationary source emissions by 755 tpy, an
approximate 33% reduction. Mobile source GHG emissions should be reevaluated in in the FEIR.

The NPC/DEIR modeled and conducted a 50-year life cycle cost analysis (LCCA) for an
alternative that incorporated triple glazed window systems and two alternative HVAC systems: System
2: DOAS/variable air volume (VAV) and 4-pipe fan coil unit (FCU) with high efficiency natural gas
condensing boilers, and System 3: DOAS/heat recovery and VRF (air source heat pump; ASHP) for
heating and cooling (all electric). System 3 generally replaces proposed fossil fuel equipment with
efficient electrification. Comments from DOER also note that maximizing electrification of space and
water heating can significantly reduce the project’s energy use and GHG emissions over time. The triple
glazed window system alternative would contribute to a 19 tpy (1%) reduction in GHG emissions. The
City has included triple glazing to be priced as an alternate due to the high first costs and payback period
which extends beyond the 50-year life cycle. The alternative HVAC System 2 would contribute to an
additional 118 tpy reduction in GHG emissions (5.2%) and System 3 would contribute to an additional
444 tpy reduction in GHG emissions (19.5%). The NPC/DEIR indicated the City dismissed these
alternatives based on their facility management preferences on maintenance and experience with natural

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gas heating over the all-electric ASHP heating system. Comments from DOER request evaluation of a
scenario that examines electrification of space heating in conjunction with a more improved building
envelope. Additional analysis of this scenario is required in the FEIR.

Adaptation and Resiliency

The City of Waltham is a participant in the Commonwealth’s Municipal Vulnerability

Preparedness (MVP) program. The MVP program is a community-driven process to define natural and
climate-related hazards, identify existing and future vulnerabilities and strengths of infrastructure,
environmental resources and vulnerable populations, and develop, prioritize and implement specific
actions the municipality can take to reduce risk and build resilience. The NPC/DEIR indicated the City
is currently developing a Hazard Mitigation Plan and a Municipal Vulnerability Plan (MVP). The
NPC/DEIR indicated the site is vulnerable to the following climate change related events: winter storms,
high winds, flooding, heat waves, droughts, and brush fire. The project has incorporated the following
elements to minimize impacts from these vulnerabilities: light colored roof, vegetated green roof (3% of
total roof area), covered parking area, native and drought resistant plantings, solar-ready rooftop, electric
vehicle (EV) charging for 2% of parking spaces, emergency generator, and limited irrigation to reduce
outdoor water use. The NPC/DEIR did not include a discussion of future climate conditions nor evaluate
or specify whether the stormwater management system was designed to account for the potential
impacts of increased precipitation frequency and volume due to climate change. This should be provided
in the FEIR.

According to the NPC/DEIR, the new high school building will be designed to be certifiable at
the silver level by the LEED (version 4; v4) rating system. The NPC/DEIR included a copy of the
preliminary LEED scorecard (Appendix 9.3) that identified the project design criteria and associated
credits under consideration for the project. I note the NPC/DEIR indicated the construction of on-site
sidewalks and bikeway that connect to a public way and the provision of bike racks for 5% of the
building occupants as design criteria incorporated to achieve Sustainable Sites / Location and
Transportation LEED credits. These provisions appear to be inconsistent with plans disclosed in the
NPC/DEIR to eliminate exclusive bike lanes along Lexington Street. This should be addressed in the
FEIR, along with any additional mitigation measures that may be warranted to encourage non-vehicular
(bicycle) travel to and from the site as part of TDM measures to offset transportation impacts.

Water Supply/Wastewater

The FEIR described the off-site improvements to the City’s water and wastewater infrastructure
and provided conceptual figures and plans for these improvements, including replacement of the 4,900
linear foot (lf) water main in Lexington Street and reconstruction of 375 lf of sewer main in Stanley
Road. As previously described in the ENF, the City’s sewer system eventually conveys flows to the
Massachusetts Water Resources Authority’s (MWRA) Deer Island Treatment Plant.

The DEIR stated that the total wastewater generation at the new high school (554 Lexington
Street) has not changed since the ENF was filed (41,460 gpd). The DEIR included a memo from the City
Engineer (Appendix 7.1) which stated that existing wastewater flow at the site is 1,866 gpd (based on
review of water meter data). However, the DEIR stated that existing wastewater flow at the site is
14,945 gpd. The project will increase wastewater generation at this location by 26,515 gpd to 39,594

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

gpd, depending upon which number is used to for existing flow. The DEIR indicated that the future
reuse of the existing high school (617 Lexington Street) will decrease wastewater generation at that
location by 21,940 gpd. The DEIR indicated that total and net new wastewater demand at the new high
school (554 Lexington Street) will remain unchanged from the ENF (47,000 gpd and 30,550 gpd,
respectively). The DEIR did not provide updated calculations based on actual water meter data, which
would result in an increased water demand for this location. The DEIR indicated that the future reuse of
the existing high school (617 Lexington Street) will decrease water demand at that location by 24,170
gpd.

The memo from the City’s Engineer and comments from MWRA state that approximately
158,376 gpd of infiltration and inflow (I/I) will need to be removed (calculated based on an increase in
wastewater flows of 39,594 gpd) in order to achieve the 4:1 I/I removal rate required by MassDEP
regulations and City. The memo from the City’s Engineer stated that that the City has accumulated a bank of
sewer gallons through private I/I mitigation projects that can be applied to City projects like this one.
According to the memo, the sewer bank has adequate gallons to accommodate the Project and a withdrawal
of 158,376 gallons will be credited to the City.

Construction Period

According to the NPC/DEIR, the project will be constructed in multiple phases over the course
of four years, as follows: Phase 1: June 2020 – October 2020: Abatement and demolition of existing
buildings; Phase 2: October 2020 – October 2021: Site clearing, tree and rock removal (blasting), site
benching, potential traffic controls; Phase 3: August 2021 – June 2024: Construction of new high
school, parking area, and athletic fields; and Phase 4: September 2024 – Open new high school to
students. The NPC/DEIR included a draft construction management plan (Section 10) that outlined
mitigation measures that will be implemented during the project to avoid or minimize impacts associated
with construction traffic, noise and vibration, stormwater, air quality, rodent control, and other impacts.
Mitigation measures identified in the NPC/DEIR include: erosion and sedimentation control measures,
designated truck routes, scheduling deliveries during non-peak hours, noise and vibration control
measures, dust control measures, prohibition of excessive idling of construction equipment,
development of a rodent control program, and a commitment to reuse or recycle a minimum of 75-
percent of construction debris. Groundwater encountered during construction will be pumped out of the
excavations to a recharge pit where it will be recharged into the ground. In the event the groundwater is
not absorbed, the contractor will pump the groundwater to a sedimentation tank, filter it through silt
sacks, and discharge it to the City’s sewer system.

The project will require the removal of 747,000 cy of material from the site. The NPC/DEIR
indicated that blasting operations and onsite crushing/processing of material will continue for
approximately twelve months. According to the NPC/DEIR, forty to seventy truckloads of material will
be exported from the site each day during this time. The anticipated truck route is Lexington Street to
Totten Pond Road to Interstate-95 (I-95). The ENF previously indicated that the construction period
traffic will not have a significant impact on traffic flow or operations. All construction traffic will be
coordinated to avoid peak commuter rush hours and adjacent school drop off and pick up times to the
greatest extent practicable.

The NPC/DEIR noted that compliance with the Construction Monitoring Plan will be monitored
through field inspection, meeting minutes, and periodic updates. Many comments request that I mandate

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monitoring of construction period impacts by independent third parties or that I appoint a community
liaison. While I strongly encourage the City to closely monitor construction period impacts and
communicate with abutters and residents, this is an issue that is more appropriately addressed during
review of the project at the local level. I also expect full compliance with MassDEP regulations
governing noise, idling, air quality and other impacts. Comments from residents continue to identify
concerns regarding the potential impacts of blasting. As noted in the NPC/DEIR, the project must
comply with the blasting regulations pursuant to 527 CMR 1.00 which identify requirements for a blast
analysis, blast design plan, pre-blast inspection surveys, allowable limits of effects of blasting, and
blasting regulatory review. The NPC/DEIR indicated the City has voluntarily expanded the radius of the
pre-blast inspection survey from 250-ft to 500-ft. The City does not restrict the noise from blasting or
crushing operations. The NPC/DEIR indicated the project team is analyzing preferred locations for this
equipment to minimize impacts on all abutters and to identify potential sound proofing or sound
mitigation measures such as constructing sound barriers around the equipment. Additional information
on these noise mitigation measures is required in the FEIR.

Conclusion

The MEPA regulations indicate that, upon review of a draft EIR, I may determine that the DEIR
is adequate, even if certain aspects of the Project or issues require additional description or analysis in a
final EIR, provided that I find the DEIR is generally responsive to the requirements of 301 CMR 11.07
and the Scope. Certain aspects of the Project or issues require additional description or analysis and will
be addressed in the FEIR. Based on a review of the NPC/DEIR, the Scope for the DEIR, consultation
with State Agencies, and review of comment letters, I have determined that the NPC/DEIR adequately
and properly complies with MEPA and its implementing regulations. The Scope below identifies
additional analysis and information that should be provided in the FEIR.

SCOPE

General

The FEIR should follow Section 11.07 of the MEPA regulations for outline and content, as
modified by this Scope. The FEIR should clearly demonstrate that the City has sought to avoid,
minimize and mitigate Damage to the Environment to the maximum extent feasible. I expect the FEIR
will provide a comprehensive response to comments on the NPC/DEIR that specifically address each
issue raised in the comment letter; references to a chapter or sections of the FEIR alone are not adequate
and should only be used, with reference to specific page numbers or subsections, to support a direct
response. The FEIR should identify measures the City will adopt to further reduce the impacts of the
project since the filing of the NPC/DEIR, or, if certain measures are infeasible, the FEIR should discuss
why these measures will not be adopted.

The information and analyses identified in this Scope should be addressed within the main body
of the FEIR and not in appendices. In general, appendices should be used only to provide raw data, such
as drainage calculations, traffic counts, capacity analyses and energy modelling, that is otherwise
adequately summarized with text, tables and figures within the main body of the FEIR. Information
provided in appendices should be indexed with page numbers and separated by tabs, or, if provided in

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

electronic format, include links to individual sections. Any references in the FEIR to materials provided
in an appendix should include specific page numbers to facilitate review.

Project Description and Permitting

The FEIR should include an updated description of the proposed project and describe any
changes to the project since the filing of the NPC/DEIR. The FEIR should identify, describe, and assess
the environmental impacts of any changes in the project that have occurred between the preparation of
the NPC/DEIR and FEIR. The FEIR should include updated site plans for existing and post-
development conditions at a legible scale. The FEIR should provide a brief description and analysis of
applicable statutory and regulatory standards and requirements, and describe how the project will meet
those standards. It should include a list of required State Permits, Financial Assistance, or other State
approvals and provide an update on the status of each of these pending actions. The FEIR should include
an update on local, regional or federal permitting as applicable. The FEIR should clarify the projected
net net increase in water demand and wastewater flow. It should clarify whether the natural field will be
used for overflow parking, and if so, the anticipated frequency with which this will occur.

The NPC/DEIR described the following access points to the site: two separate primary access
driveways on Lexington Street (separated entrance and exit driveways), a secondary 40-ft wide exit to
Lexington Street, and 20-ft wide secondary emergency access drive connecting the site to an adjacent
off-site 20-ft wide easement. The FEIR should clarify whether the 40-ft wide access road to Lexington
Street (located north of the main entrance to the site) will be gated and used only for emergency access
or whether it will serve as a secondary access point. This access road should be depicted on project plans
and figures. I note that I received many comments that identify concerns with the City’s proposal to use
a 20-ft wide water, sewer, and drain easement (Lincoln Street Extension) as a secondary emergency
access drive. The FEIR should include specific references to the deed language that supports using the
infrastructure easement as an emergency access roadway. It should clarify whether additional clearing or
road widening is necessary to enable access by fire trucks. It should also clarify whether the City will
need to acquire additional rights to use the easement as an emergency access road either through
purchase or an eminent domain taking. The project plans depict steep topography on the project site near
this easement. The FEIR should clarify how stormwater from the site will be collected to avoid
exacerbating flooding on adjacent off-site properties.

The NPC/DEIR indicated Lexington Street cannot accommodate both an exclusive bike lane and
the proposed turning lanes without private land takings (presumably to widen the right of way). The
FEIR should identify the width of the right of way and the proposed roadway cross section along this
location. The FEIR should identify alternative means to encourage bicycle travel to align with the
City’s commitment to installing bicycle racks on site.

Alternatives Analysis

The ENF and NPC/DEIR indicated that proposed alternatives were evaluated against criteria
established by the School Building Committee, including the site’s ability to allow adequate space to
provide for the master plan which includes the school, 650 parking spots, and room for future expansion
and relocation of as many off-site athletic fields to the site as possible/practical. The project site was
selected in part because it met these criteria. The FEIR should clarify whether this is still applicable

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given that the Jericho Hill II Parcel was incorporated into the site to enable revisions that would
eliminate development from the northeastern portion of the site. To the extent the potential for future
expansion is no longer a project goal, the City should address how this would impact the prior analysis
of other locations considered for the site which would not require the use of designated public open
space.

Land Alteration/Drainage

As noted above, the revised layout allows the existing natural field and north-central portion of
the site to remain as undisturbed wooded area. Many comment letters identify concerns about
development of open space which provides valuable natural resources and note that the project site (554
Lexington Street) was identified in the City’s Open Space and Recreation Plan as a priority area for
protection. The City should address in the FEIR whether it will consider placing a conservation
restriction on the portion of the site which will remain undeveloped, or at an alternative off-site location,
to permanently protect such land as publicly accessible open space.

The FEIR should include a more detailed narrative discussion of the stormwater management
system and stormwater conveyance from the project site to Chester Brook. This should address how and
where flows from the 0.4 acre portion of the stream’s watershed combine with the rest of the site’s
runoff prior to discharge to Chester Brook. The FEIR should clarify the source data for the design
storms used to design the stormwater management system. As discussed below, the City should evaluate
sizing the stormwater management system to account for the potential impacts of increased precipitation
frequency and volume due to climate change. I received comments from abutters that identify concerns
the project will exacerbate flooding conditions. The NPC/DEIR indicated the project team will continue
to investigate sources of [flood] water and will implement additional mitigation strategies where feasible
so that the project improves conditions to the abutting properties. The FEIR should provide an update on
this investigation and should identify any additional mitigation measures that were incorporated into the
project. The NPC/DEIR noted that potential impacts from fractures and/or joints within the bedrock will
be further evaluated to determine potential impacts to surficial flow within the stream channel. The
FEIR should provide an update on this evaluation and identify a timeline for its completion.

Comment letters identify concerns regarding the presence of Per- and polyfluoroalkyl substances
(PFAS) in the synthetic turf field. The NPC/DEIR indicated that the turf field will be in accordance
with MassDEP regulations for PFAS but did not identify the applicable regulations or explain how the
project would comply. This should be addressed in the FEIR.

Climate Change

Governor Baker’s Executive Order 569: Establishing an Integrated Climate Change Strategy for
the Commonwealth (EO 569; the Order) was issued on September 16, 2016. The Order recognizes the
serious threat presented by climate change and direct Executive Branch agencies to develop and
implement an integrated strategy that leverages state resources to combat climate change and prepare for
its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits
established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state
government and cities and towns for the impacts of climate change. The MEPA statute directs all State
Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse

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gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other
administrative approvals and decisions. M.G.L. c. 30, § 61.

The GHG Policy and requirements to analyze the effects of climate change through EIR
review play an important role in this statewide strategy. These analyses advance proponents’
understanding of a project’s contribution and vulnerability to climate change.

Greenhouse Gas Emissions

The FEIR should include a revised GHG analysis which reflect any changes to the project since
the NPC/DEIR. New construction offers many opportunities for building shell and mechanical system
improvements and I expect the City will reconsider these measures to maximize the potential benefits of
this new $122 million dollar construction. The project will be required to meet the version of the
Building Code in effect at the time of construction. As noted in the NPC/FEIR and confirmed by
DOER, an update to the Stretch Code (SC) will become effective in August 2020. The underlying code
provisions will not change. The SC to take effect in August is based on ASHRAE 90.1-2013-Appendix
G. However, there will be several new, or changed, Massachusetts amendments. I encourage the City
to utilize the updated SC as it updates its GHG emissions calculations to accurately evaluate the GHG
reduction benefits provided by proposed mitigation measures.

As requested by DOER, the FEIR should evaluate a scenario which includes electrification of
space heating with an improved envelope. This scenario should evaluate whether additional
improvements to the envelope could potentially eliminate or downsize HVAC systems. The FEIR
should include a LCCA for this scenario and the scenario where the currently proposed building will be
retrofitted to electric heating in the future. I refer the City to comments from DOER for additional
guidance on this issue.

The City has committed to construct the building with solar-ready construction. The FEIR should
provide a solar PV feasibility analysis that addresses the following:
 Include an estimate of available roof area for development of solar PV;
 Include a cost analysis to determine the overall financial feasibility of installation of solar,
including potential payback periods;
 Propose an installation that can be supported by the maximum available roof area (excluding
areas dedicated for mechanical equipment);
 State the assumed panel efficiency;
 Estimate electrical or thermal output of the potential system; and
 Estimate annual GHG reductions of renewable energy versus electricity or natural gas.

The analysis should provide conceptual roof plans that identify the “usable areas” for potential
solar PV systems, rooftop HVAC equipment, and other appurtenances. The plans and an accompanying
table should identify the extent of the roof that is required to be “solar ready” in order to comply with
Building Code requirements after August 2020 (as applicable), the total rooftop area, and the maximum
usable roof area for a solar installation. The analysis should include a narrative and data to support the
adoption or dismissal of solar PV as a feasible measure to avoid, minimize or mitigate project-related
GHG emissions and Damage to the Environment.

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The FEIR should include a revised mobile source GHG analysis incorporates any changes to the
TDM program and/or traffic mitigation measures. The FEIR should identify the specific roadway
mitigation measures and TDM measures that are reflected in the analysis and these mitigation measures
should be incorporated into the draft Section 61 Findings. The TDM program provided in the
NPC/DEIR noted the City will encourage the use of bicycles and pedestrian traffic to the school and
provide numerous secure bike racks/storage. It also stated that the Massachusetts Safe Routes to School
(SRTS) Program will be included as part of the sustainability measures that will be implemented for the
project. 5 The FEIR should clarify this commitment. The FEIR should expand upon the information
presented in the NPC/DEIR to demonstrate a clear commitment to promoting safe and accessible
pedestrian and bicycle access for students to and throughout the project site. It should include graphics
(and supporting narrative) depicting internal circulation patterns (vehicles, pedestrian, and bicycles) and
connection points to adjacent land uses and access roadways. Measures to promote safe and accessible
pedestrian and bicycle access (including participation in the SRTS Program) should be incorporated into
the draft Section 61 Findings.

Adaptation and Resiliency

The Northeast Climate Science Center at the University of Massachusetts at Amherst has
developed projections of changes in temperature, precipitation and sea level rise for Massachusetts. The
FEIR should identify the projected changes in temperature and precipitation for the Charles River Basin
using this data which is available through the Climate Change Clearinghouse for the Commonwealth
at www.resilientMA.org. I expect that the City will consider recent data identifying increases in climate
change-induced storm intensity and precipitation volumes to design an appropriately-sized stormwater
system to convey each design storm event. The stormwater management system will also be used to
convey groundwater flow from the below-slab and perimeter foundation system and drainage system
along the base of the rock wall. The FEIR should address how the projected change in precipitation may
impact groundwater levels, flow rates, direction, and flooding. The FEIR should include a narrative
discussion about how existing and future groundwater flow volumes above the invert elevations were
accounted for and incorporated into the design of the stormwater management system. This evaluation
should consider the future effects of climate change. The FEIR should also provide an update on the
results of any additional test borings and groundwater pump tests that have been performed since the
NPC/DEIR was submitted and a timeline for conducting any additional tests to better understand
hydrogeologic conditions in the bedrock and groundwater flow rates and direction.

Construction Period

I received numerous comment letters that express concerns regarding noise, vibration, and traffic
impacts associated with earthwork, blasting, and rock crushing during construction. According to the
NPC/DEIR, construction activity will occur between 7:00 AM and 5:00 PM weekdays and 8:00 AM to
4:00 PM on Saturdays. Blasting will occur between 8:00 AM to 4:00 PM on weekdays for a continuous
twelve month period. No blasting will occur on Saturdays, Sundays, or holidays. The FEIR should
clarify whether noise or dust from construction activities will create a nuisance condition by interfering
with enjoyment of property. I strongly encourage the City to consider reduced construction hours to
minimize construction-related impacts to nearby residences. The FEIR should continue to analyze

5The SRTS Program is a federally funded initiative of the Massachusetts Department of Transportation (MassDOT) that
encourages elementary and middle school students to safely walk and bike to/from school.

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

potential noise and vibration impacts associated with blasting and crushing operations, and propose
appropriate mitigation measures. The NPC/DEIR indicated that the project team is modeling the noise
generating equipment and is analyzing preferred locations for equipment to minimize impacts on
abutters and to identify potential sound proofing measures such as sound barriers around equipment.
The FEIR should provide an update on this analysis and should identify specific mitigation measures
that will be implemented to address these impacts.

The FEIR should provide a figure identifying the approximately 500-ft pre-blast inspection
survey radius or identify when this information will become available and how it may be viewed by
stakeholders. The FEIR should describe the blasting notification procedure for abutters to be used by the
contractor. It should identify an approximate timeframe for completing the pre-blast surveys. The FEIR
should provide details of how the survey will be conducted and clarify whether property owners will be
provided with copies of the completed survey. It should also identify a process for addressing noise,
vibration, or dust complaints from abutters during the construction phase of the project.

The FEIR should address how the project will ensure compliance with the Massachusetts Idling
regulation at 310 CMR 7.11. Because this project will occur in close proximity to residential areas, I
urge the City to minimize potential noise and air quality impacts by requiring that construction vehicles
limit engine idling, use ultra-low sulfur diesel fuel, and be retrofit with emissions control equipment,
including emission control equipment identified in the Commonwealth’s Clean Air Construction
Initiative.

Mitigation and Draft Section 61 Findings

The FEIR should include a section that summarizes all proposed mitigation measures and
provides draft Section 61 Findings for each State Agency Action. It should contain clear commitments
to implement these mitigation measures, estimate the individual costs of each proposed measure,
identify the parties responsible for implementation, and contain a schedule for implementation.

In order to ensure that all GHG emissions reduction measures adopted by the Proponent as the
Preferred Alternative are actually constructed or performed by the Proponent, the Secretary requires
proponents to provide a self-certification to the MEPA Office indicating that all of the required
mitigation measures, or their equivalent, have been completed. The commitment to provide this self-
certification in the manner outlined above should be incorporated into the draft Section 61 Findings
included in the FEIR.

Response to Comments

The FEIR should contain a copy of this Certificate and a copy of each comment letter received.
In order to ensure that the issues raised by commenters are addressed, the FEIR should include direct
responses to comments to the extent that they are within MEPA jurisdiction. This directive is not
intended, and shall not be construed, to enlarge the scope of the FEIR beyond what has been expressly
identified in this certificate.

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Circulation

The Proponent should circulate the FEIR to those parties who commented on the ENF or
NPC/DEIR, to any State and municipal agencies from which the City will seek permits or approvals, and
to any parties specified in section 11.16 of the MEPA regulations. Per 301 CMR 11.16(5), the City may
circulate copies of the FEIR to commenters in CD-ROM format or by directing commenters to a project
website address. However, the City must make a reasonable number of hard copies available to
accommodate those without convenient access to a computer and distribute these upon request on a first-
come, first-served basis. The City should send correspondence accompanying the CD-ROM or website
address indicating that hard copies are available upon request, noting relevant comment deadlines, and
appropriate addresses for submission of comments. The FEIR submitted to the MEPA office should
include a digital copy of the complete document. A copy of the FEIR should be made available for
review at the Waltham Public Library. 6

June 26, 2020 ________________________

Date Kathleen A. Theoharides

Comments received:

5/27/2020 Anonymous 6/1/2020 Nadene Stein

6/1/2020 Alicia Hutton 6/1/2020 Rebecca Cyr
6/1/2020 Alison Guzman 6/1/2020 Ron Ayers
6/1/2020 Angie Benoit 6/1/2020 Sarah Remage-Healey
6/1/2020 Anonymous 6/1/2020 Tom King
6/1/2020 Brandice Proskoczilo 6/1/2020 Valerie Sharp
6/1/2020 Carol Baclawski 6/2/2020 Amy Corbett
6/1/2020 Celeste Woodside 6/2/2020 David Westner (1 of 2)
6/1/2020 Christin Piccirilli 6/2/2020 Jaclyn Davidson
6/1/2020 Christina McCalla 6/2/2020 Kathleen Simpson
6/1/2020 Christy Kahana 6/2/2020 Robert Hanley
6/1/2020 Donald Lucente 6/3/2020 Elizabeth Homan
6/1/2020 Donna Fils-Aime 6/3/2020 Elizabeth Lear
6/1/2020 Donna Weitz 6/3/2020 Jennifer Roy
6/1/2020 Jeffrey Esposito 6/4/2020 Heather Johnson
6/1/2020 Jose Guzman 6/4/2020 Interim Superintendent George
6/1/2020 Kathi Martuza and Kester Cotton Frost
6/1/2020 Kit Fintzel 6/4/2020 Michelle Kern
6/1/2020 Kristen Mullin 6/4/2020 Rachel Weinstein (1 of 4)
6/1/2020 Lynelle Cortellini-Devine 6/4/2020 Rachel Weinstein (2 of 4)
6/1/2020 Melissa Abell-Bardsley 6/5/2020 Ben Kuchler
6/1/2020 Michelle Campbell 6/6/2020 Megan Letendre

6
Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 response.
Please consult the MEPA website for further details on interim procedures during this emergency period:
https://www.mass.gov/orgs/massachusetts-environmental-policy-act-office.

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

6/8/2020 Amy Brown (1 of 3) 6/19/2020 Massachusetts Water Resources

6/8/2020 Amy Brown (2 of 3) Authority (MWRA)
6/8/2020 Amy Brown (3 of 3) 6/19/2020 Alysia Parkes
6/8/2020 Mayor Jeannette McCarthy 6/19/2020 Charles River Watershed
6/8/2020 State Rep. Thomas M. Stanley, Association (CRWA)
State Rep. John J. Lawn, State 6/19/2020 Erika Kuno
Senator Michael J. Barrett 6/19/2020 Isabel Brassil
6/10/2020 City Councilor Sean Durkee 6/19/2020 Jeannie Joe
6/10/2020 Laura Cannon 6/19/2020 Jennifer Rose
6/11/2020 Michele DesAutels 6/19/2020 Pat Seminara
6/12/2020 Orlando Medeiros 6/19/2020 Karen Pruy
6/12/2020 Waltham Historical Commission 6/19/2020 Karina Hines
6/15/2020 Christopher Matteodo 6/19/2020 Karina Hines
6/15/2020 Luisa Pandolfi 6/19/2020 Kristen Thibodeau
6/15/2020 Orlando Medeiros 6/19/2020 Margaret Schadelbauer
6/15/2020 Steve Wolff 6/19/2020 Massachusetts Department of
6/16/2020 Rachel Weinstein (3 of 4) Environmental Protection
6/17/2020 Bill Fowler (MassDEP)
6/17/2020 David King 6/19/2020 Massachusetts Historical
6/17/2020 Maureen Bagge Fowler Commission (MHC)
6/17/2020 Orlando Medeiros 6/19/2020 Mike Chen
6/17/2020 Paul Hughes 6/19/2020 Patricia Roche and David
6/17/2020 Philip Chorman Brountas
6/17/2020 Rachel Weinstein (4 of 4) 6/19/2020 Paul Katz
6/17/2020 Robert Hargrove 6/19/2020 Pradip Mallik
6/17/2020 Waltham Land Trust 6/19/2020 Rachel Gagne
6/18/2020 Alex Urquhart 6/19/2020 Robert Coleman
6/18/2020 Carolina Lara 6/19/2020 Shelli Barry
6/18/2020 Christine Reynolds 6/19/2020 Tammy Rose
6/18/2020 David Westner (2 of 2) 6/19/2020 Thomas Maclellan
6/18/2020 Doug MacDonald 6/19/2020 Larry Sumner
6/18/2020 Jacob Katz 6/19/2020 Carol Dunbar
6/18/2020 James Devin 6/19/2020 WalkBoston and MassBike
6/18/2020 Laura Urquhart 6/19/2020 Patrick Rooney
6/18/2020 Paula McNiece 6/19/2020 Zac Borrelli
6/18/2020 Reva Dolobowsky 6/19/2020 JP Jones
6/18/2020 Sharon Katz 6/19/2020 Kaj Telenar
6/18/2020 Susan Parrella 6/26/2020 Department of Energy Resources
6/18/2020 Tammy Inman (DOER)
6/18/2020 Tom Haley

KAT/PRC/prc

22
Project Description 2
2.1 Project Overview
2.1.1 Comprehensive High School
2.1.2 Education Plan
2.2 Physical Characteristics
2.2.1 Locus Map
2.2.2 Site Plan
2.3 Project Schedule and Cost
2.4 Emergency Access
2.5 Bicycle and Pedestrian Access
2.6 Traffic Intersection Update
2.7 Natural Turf Field
2.8 Water and Wastewater Flow
2.9 Alternatives Analysis
Attachments
2.2 NPC/DEIR Figures
2.4a Lincoln Street easement taking order
2.4b Emergency access City Law Dept Letter
2.4c Lincoln Street 1959 Plan

Tables
2.1 Potential Project Sites Studied
Figures
2.1 Fencing at Lexington Street
2.2 Existing Topography
2.3 Proposed Topography
2.4 Emergency Access Plan Enlargement
2.5 Emergency Access Plan Enlargement with Existing Aerial
2.6 Existing Conditions – Lexington Street
2.7 Proposed Conditions – Lexington Street
2.8 Waltham Transportation Master Plan – Lexington Street
Corridor Improvements
2.9 Existing Photographs of Lexington Street
2.10 On-Site Circulation Patterns
2.11 Natural Turf Field
Project Description
2.1 Project Overview
2.1.1 Comprehensive High School
The new Waltham High School will be constructed at 554 Lexington Street in Waltham, MA,
approximately 760 feet south of Jack’s Way which serves as the existing high school driveway. The
project site includes developed land and a portion of the Jericho Hill Parcel II which was transferred to
the care, custody and control of the Waltham School Department on March 9, 2020. Information about
this transfer and addition to the Project site is included in the Notice of Project Change (NPC) filed with
MEPA on May 15, 2020.

The new school building, totaling approximately 414,850 gross square feet, will house approximately
1830 students in grades 9-12. The massing of the building embodies a four-cluster approach to match
the Educational Program. It features a four-story academic building element fronting the main entrance
drive, and a series of two-to-three story volumes fanning out towards the north. A multi-story Dining
Commons hall connects the new Media Center to the Auditorium and Gymnasium while lending a
vibrant sense of community and visibility to the overall school environment.

The proposed site work includes new vehicular and pedestrian circulation from Lexington Street, up and
around the new school building, a synthetic turf athletic field above a parking garage and limited at-
grade parking. The project proposes 650 parking spaces, the majority of which are provided in a garage
structure below the artificial turf athletic field. The remaining spaces are provided in at-grade spaces off
the main access driveway. Outdoor gathering/classroom spaces are proposed at the main entrance, at
the rear secondary entrance and within the southern recess of the building. Emergency vehicular access
will be provided by the 360-degree main driveway and supplemented via an emergency-only access
drive off Lincoln Street gated at the property line and at the school access drive.

Site work will consist of the demolition of all existing structures, paved surfaces, existing site
improvements, and above and below ground utilities. Significant earthwork will be required to achieve
final design grades of the Project including significant bedrock blasting. Early abatement and demolition
work as well as early site preparation work will include clearing, earthwork, and preparation for the
building construction.

Landscaping will be added where feasible to enhance the design of the building and site. New site
lighting is proposed to meet current standards. Utility services will be upgraded or replaced. A new
stormwater management system will be designed to capture and regulate the runoff from the developed
portion of the site. The stormwater management system will be designed to meet or exceed the current
Massachusetts DEP Stormwater Policy and Standards.

2.1.2 Education Plan

The Massachusetts School Building Authority (MSBA) approved the Waltham Education Plan in
February 2020.

Waltham’s educational plan is for a comprehensive high school for 1,830 students with fourteen
career, technical and vocational programs. In essence, Waltham is building two schools into one
with four academic clusters: STEM (Science Technology, Engineering, and Mathematics); Fine and
Performing Arts; Health, Wellness and Athletics; and Humanities.

2 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 2: Project Description

2.2 Physical Characteristics

The new Waltham High School project is proposed at 554 Lexington Street. As described in Section 3.7 of
the NPC/DEIR, the transfer of Jericho Hill Parcel II use to the School Department allowed the design team
to review siting of the major elements of the project in attempts to further minimize environmental impacts,
with the ultimate goal of avoiding impacts to the existing wetland resources as much as possible. There
have been no changes to the site since the NPC/DEIR.

2.2.1 Locus Map

There have been no changes to the site locus since filing the NPC/DEIR. Refer to NPC/DEIR Figure
1.1 which is attached for reference.

2.2.2 Site Plan

There have been no changes to the site plan since filing the BPC/DEIR. Refer to NPC/DEIR Figure
2.2 which is attached for reference.

2.3 Project Schedule and Cost

The project remains on schedule for a 2024 school year occupancy with the following milestones, changes since
the NPC/DEIR shown in red:
• August 2020 – CM establishes project boundary, staging areas and installs construction trailers
• September 2020 - Abatement and demolition of the existing buildings commence
• November 2020 - Site clearing and rock removal commence
• August 2021 - Construction of the new school, parking, playing field and associated sitework
• September 2024 – New Waltham High School Opens to students

The project budget remains unchanged.

2.4 Emergency Access

The existing 40-foot wide portion of the Project site that connects to Lexington Street will remain part of the
overall property. There are no plans to use this connection for access to the project site. A portion of the
City’s eastern property line will have fencing behind the Lexington Street abutters. This will include a 6-foot
high chain link fence and a 6-foot high chain link gate at this leg of the property. This gate will only be used
in the case of an emergency, see Figure 2.1 below.

Figure 2.1 Fencing at Lexington Street

Waltham High School | Final Environmental Impact Report 2 | p. 2

 Section 2: Project Description

The existing 20-foot wide right-of-way to the south of the property (referred to as Lincoln Street
“extension”) will be used as the secondary emergency access for Police and Fire only as indicated in the
NPC/DEIR. This easement was taken by eminent domain by the Waltham City Council in 1984. The taking
order is included by attachment at the end of this section.

The taking order language reads “That an easement for water, sewer and drain services together with the
right to enter and dig up the earth therein, and to remove rock and stones to such depths and widths as
may be proper and necessary for the convenient laying, replacing, repairing and maintaining the said
services, be and hereby is taken by right of eminent domain under General Laws, Chapter 43 and Chapter
79 and every power thereto enabling in the following described parcel of land.”

Further, under the Federal Constitution and Massachusetts statutes and case law, the Fire Department and
Police Department have the right to use this right-of-way under exigent public safety or emergency
situations involving potential risks to public safety. Under such situations, the government’s good faith
interest in protecting public safety outweighs an individual’s private property rights. See Memo of Law from
the City of Waltham Law Department, July 27, 2020, by attachment at the end of this section.

The existing Lincoln Street “extension” is sufficient in width to serve as an emergency access. This is
further confirmed by the attached September 1959 Plan endorsed by the City of Waltham Board of
Planning and Survey as “Approval Not Required”. Such a plan is intended to signify that a road shown thereon
is either a public way or an approved subdivision road (private way). That means that, at the time the Approval
Not Required (ANR) endorsement was given, it was deemed of suitable width for emergency use for the
properties having rights over it. This Plan is included by attachment at the end of this section. The project will
not widen Lincoln Street “extension” and no eminent domain taking is required. Limited tree clearing will be
required within the easement to extend the pavement and water line in Lincoln Street “extension” to the
new high school fire hydrant planned at the property line. The City is reviewing options with the abutters to
re-surface the street if they desire.

Tree clearing will also occur on the new high school site to connect Lincoln Street “extension” to the
secondary emergency access drive on the school site. The existing topography in this area slopes down
towards Lincoln Street as shown below in Figures 2.2 and 2.3.

Figure 2.2 Existing Topography Figure 2.3 Proposed Topography

Waltham High School | Final Environmental Impact Report 2 | p. 3

 Section 2: Project Description

Much of the existing topography will not change in this area. The hydrology analysis indicates a reduction
in stormwater discharge to the south, refer to Design Point 1 in Table 3.1 in Section 3.2.1. The Project team
is working with the City to confirm if there are opportunities to collect runoff from the emergency roadway
and discharge to existing drainage within the street. If feasible, it will be incorporated into the Project.

Figure 2.4 Emergency Access Plan Enlargement

Waltham High School | Final Environmental Impact Report 2 | p. 4

 Section 2: Project Description

Figure 2.5 Emergency Access Plan Enlargement with Existing Aerial

2.5 Bicycle and Pedestrian Access

The existing Lexington Street corridor is 40-foot wide curb to curb, and the existing right-of-way is 60-ft.
which includes the granite curb, a grass edge separation between the road and the public sidewalk.
Included below are images of the existing and proposed alignment of Lexington Street, see Figure 2.6 and
Figure 2.9 for existing conditions and 2.7 for proposed conditions.

Waltham High School | Final Environmental Impact Report 2 | p. 5

 Section 2: Project Description

Figure 2.6 Existing Conditions – Lexington Street

Figure 2.7 Proposed Conditions – Lexington Street

Lexington Street between Totten Pond Road and Lincoln Street includes shared bike lanes, although there
are no pavement markings, i.e., “sharrows” or signage in this stretch of roadway. Bike lanes begin just to
the north of the Lincoln Street intersection. The project is proposing to increase the shared section at the
new high school site to accommodate the left turning lane needed to access the site resulting in the
elimination of approximately 800 feet of dedicated bike lane. Bike lanes are currently also eliminated at
other intersections within the corridor to accommodate turn lanes.

Waltham High School | Final Environmental Impact Report 2 | p. 6

 Section 2: Project Description

The project team believes this is the safest option for bicyclists as it continues a method currently in
practice on this corridor. Additionally, the project will install bicycle detection, including pavement markings
and signage at the High School traffic signals to aid bicyclists in activating the lights, and also install
sharrows and signage for the shared bike lanes on Lexington Street. See Figure 2.8 below from the City of
Waltham Traffic Master Plan, identifying the current extents of the Lexington Street bike corridor. The new
high school is located with a red star.

Figure 2.8 Waltham Transportation Master Plan – Lexington Street Corridor Improvements

Waltham High School | Final Environmental Impact Report 2 | p. 7

 Section 2: Project Description

Figure 2.9 Existing Photographs of Lexington Street

Looking Northbound Looking Southbound End of Bike Lane at Curve Street

Currently approximately 5-8 students bike to the existing High School on Lexington Street although the
bike lane is available. While the Safe Routes to School (SRTS) program is for elementary and Middle school
students there are aspects of the program that can be applicable to the High School Students – specifically
the Six E’s. Working with the administration during design, specific locations for 30 bike racks were
discussed for safety and accessibility. With the addition of the new signal and crosswalks, better signage
for the bike path and bike boxes addressing the Engineering component, the administration is committed
to Educating, Encouraging, Evaluating and Enforcing bike use and safety.

Waltham High School | Final Environmental Impact Report 2 | p. 8

 Section 2: Project Description

Figure 2.10 On-Site Circulation Patterns

Figure 2.10 identifies the internal circulation patterns and connection points to adjacent land uses and
access roadways. Blue indicates bicycle circulation on a shared vehicular roadway. Orange indicates
pedestrian access into and through the project site. The sidewalks along the entry road are 6’ wide and
include an accessible route to the main entrance at the front of the building. Sidewalks at loading zones
and plazas have been highlighted in this diagram and vary in width dependent on location, however all
gathering spaces maintain accessible routes to and from the building.

Waltham High School | Final Environmental Impact Report 2 | p. 9

 Section 2: Project Description

2.6 Traffic Intersection Update

The project team continues to work with the City traffic engineer to develop the concept for the signal
design on Lexington Street. The project has proposed a two-signal design and the City engineer requested
a one signal design for review with the Traffic Commission.

At the Traffic Commission meeting on Tuesday August 4, 2020, the Traffic Commission approved the two-
signal design with the following modifications:
• Exit lane shall include one right turn lane only (previously two). This will allow for “right turn on red”.

2.7 Natural Turf Field

The existing natural turf field (Figure 2.11 below) will remain as part of the Project. This area will be used for
lay-down space during construction and restored to a natural turf field at the completion of the project. As
with any school project, the parking designed and constructed meets the day-to-day needs for school
operations; however, it is insufficient to meet the needs of special occasions such as school wide
performances, major athletic events or graduation.

The project team reviewed options for overflow parking with the School Building Committee at their June
08, 2020 meeting so the parking for these events can be planned accordingly. Options include maximizing
the proposed 650 spaces at 554 Lexington Street, using the natural turf field for overflow parking and using
the existing parking lots at 617 Lexington Street. As discussed at that meeting, the field parking is not
recommended except during the winter-time when the ground is frozen to avoid damage to the field. No
formal decision was made at that meeting, but in the event the natural turf field is used, it will not be a
frequent occurrence, as there are approximately 15 High School events a year that require overflow
parking.

Figure 2.11 Natural Turf Field

Waltham High School | Final Environmental Impact Report 2 | p. 10

 Section 2: Project Description

2.8 Water and Wastewater Flow

Within the ENF and the NPC/DEIR the water use and wastewater flows were calculated based on Title 5
rates for both existing and proposed. The Title 5 rates are the industry standard in Massachusetts and are
generally conservative, being higher than the actual flows. The NPC/DEIR noted the increases were 6,380
gpd for water and 4,575 gpd for wastewater over the existing site uses based on Title 5.

The City Engineer noted in his memorandum dated May 12, 2020 that the existing wastewater flow should
be based on the actual existing average daily flow over the last 5 years per City Ordinances. This results in
a net increase of 39,594 gpd. With a 4:1 mitigation ratio (I & I), the I & I mitigation will be 158,376 gpd. The
City intends to satisfy the requirement by deducting 158,376 gallons from the City Sewer Bank for this
project.

Therefore, the projected increases for the new project at 554 Lexington Street are 39,594 gpd for
wastewater and approximately 43,560 gpd in water use, adding 10% for uses not discharged through the
sewer.

The 617 Lexington Street property will have a net decrease in water and wastewater flow as it will be
changed from a 1,710 student High School to a 650-student middle school.

2.9 Alternatives Analysis

The NPC/DEIR indicated that proposed alternatives were evaluated against criteria established by the
School Building Committee, including the site’s ability to allow adequate space to provide for the Education
Master Plan which includes the school, 650 parking spots, and room for future expansion and relocation of
as many off-site athletic fields to the site as possible/practical.

As described in the table below (which was included in the ENF), sites were eliminated for a variety of
reasons based upon the challenges the sites presented, but never specifically because of the lack of ability
to allow relocation of fields in the future. As discussed in the NPC/DEIR, the Project budget would not
account for relocation of the athletic fields and the City has invested millions of dollars in offsite locations
which they have no intention of abandoning. Therefore, the elimination of this criteria would not change any
previous determination on preferred sites, the prior analysis remains valid and the reasons for the selection
of 554 Lexington Street as the preferred site stands.

For clarification, the Jericho Hill Parcel II was incorporated into the project to enable the project to eliminate
impacts on wetland resource areas including the intermittent stream. The Jericho Hill Parcel II is not
designated as Open Space as noted in the NPC/DEIR Certificate. The following table is from Section 2 of
the ENF.

Waltham High School | Final Environmental Impact Report 2 | p. 11

 Section 2: Project Description

Table 2.1 Potential Project Sites Studied (from ENF)

Waltham High School | Final Environmental Impact Report 2 | p. 12

NPC/DEIR Figures
 JerichoParcel
Jericho ParcelIIII

554Lexington
554 LexingtonStreet
Street

NPC / DEIR Figure 1.1 - USGS

Waltham High School, Waltham, MA
 Synthetic Field and
Garage Structure
Secondary
Emergency
Access Drive

Proposed Building

Natural Field

NPC / DEIR Figure 2.2 - Project Rendering

Waltham High School, Waltham, MA
Lincoln Street Easement
Taking Order
Waltham City Council 1984
Emergency Access
Memo of Law
City of Waltham Law Department
July 27, 2020
September 1959 Plan
Lincoln Street
endorsed by the City of Waltham Board of
Planning and Survey
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Land Alteration/Drainage 3
3.1 City's Open Space and Recreation Plan
3.2 Stormwater Management
3.3 Synthetic Turf Field
Attachments
3.1 City Open Space Letter
3.2 NPC/DEIR Figures
Tables
3.1 Pre- and Post-Development Peak Discharge Rate
Summary
Land Alteration/Drainage
3.1 City's Open Space and Recreation Plan
The NPA/DEIR Certificate requested the City address whether it will consider placing a conservation restriction
on the portion of the site which will remain undeveloped, or at an alternative off-site location, to permanently
protect such land as publicly accessible open space

See attached City of Waltham Law Department Letter dated August 12, 2020 addressed to Honorable Jeannette
A. McCarthy.

The above was catalyzed because MassDEP stated that its first priority was protecting the intermittent stream
and its bordering vegetated wetlands (BVW) in the northeast corner of 554 Lexington Street from any significant
impacts of accessory improvements to the new high school construction. So, the City and its architects shifted
the entire new high school building and its accessory improvements and relocated the project from that area and
moved the project to the south and west. The DEP has accepted/approved this shift in its official response to the
City’s NPC/DEIR. In following Mass DEP’s recommendations to avoid the intermittent stream and BVW, the City
and its design team needed to add about six (6) acres of contiguous land to the west of 554 Lexington Street
known as Jericho Hill Parcel II/131R Lincoln Street, that was already in the City’s unrestricted General Inventory,
by previous eminent domain Taking “…for all public and municipal purposes…”

The City has previously transferred care, custody and control of 554 Lexington Street to the School
Committee/School Department for educational purposes, and also transferred Jericho Hill/131R Lincoln Street to
the School Department as part of the new high school project – thus clearly demonstrating its dedication to
education use (i.e. not Article 97).

In light of the above, the Mayor is willing to recommend to the City Council that a conservation restriction be
placed on an alternative off-site location nearby that is currently held in the City’s General Inventory and is
currently undeveloped.

The alternative location, located adjacent to the current high school property, is a portion of the City-owned land
known as 0 Chesterbrook Road (aka 605R Lexington Street) and that restriction would be placed on 5.97 acres
of that site (see plan attached). A conservation restriction on this 5.97-acre area would not only preserve existing
undeveloped open space, but would also protect wetlands and other environmental concerns.

3.2 Stormwater Management

3.2.1 Stormwater Drainage
As shown in Figures 5.1 and 5.2 of the NPC/DEIR, which are below for reference, there are three major Design
Points to which stormwater flows under existing conditions. Design Point 1 (DP-1) includes stormwater
discharging to the south of the property. DP-2 includes stormwater discharging to the Chester Brook via the
drainage structures in Lexington Street. DP-3 includes overland flow which runs off the site to the east. These
same three Design Points are used in the proposed conditions model to design the system so that post-
construction peak flows are not increased. Table 5.1 below summarizes pre- and post-development peak
discharge rates as calculated in NPC/DEIR Section 5.1.2.

3 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 3: Land Alteration/Drainage

Table 3.1 Pre- and Post-Development Peak Discharge Rate Summary

2-year (cfs) 10-year (cfs) 100-year (cfs)

Existing Proposed Existing Proposed Existing Proposed
Design Point 1: 10.25 4.27 25.53 10.71 53.11 22.31
South Lexington system
Design Point 2: 32.49 30.18 75.63 70.82 151.53 147.59
Lexington Street system
(Chester Brook)
Design Point 3: 3.25 3.25 8.91 8.91 19.47 19.47
North Lexington system

As calculated in Section 5.1.2 of the NPC/DEIR, the existing watershed for DP-1 is significantly reduced in the
proposed conditions from 511,352 square feet to 229,397 square feet. Existing Subcatchment 1.1 consists of
buildings and pavement and wooded areas of the site. Proposed Subcatchment 1.1 consists of landscaped and
non-disturbed wooded areas adjacent to the southern loop roadway/parking lot and a small portion of woods
above the rock wall to the west of the garage/field. The peak flows leaving the site via DP-1 are reduced in the
proposed conditions; please refer to NPC/DEIR Appendix 5.1 for calculations.

DP-2 includes runoff from existing Subcatchments 2.1, 2.2, and 2.3 and represents the majority of the existing
development including buildings, pavement, and landscaped areas, along with a large portion of wooded area
within the site. The Project is represented in proposed Subcatchments 2.1 through 2.11 and includes building
and garage/field structures, at-grade parking and roadways, landscaped improvements, along with the majority
of the remaining wooded area of the site. The Project’s Best Management Practices (BMPs) are designed to
treat and mitigate runoff from this area of the site and include subsurface chambers, at-grade bioretention, and
trenches. The peak flows leaving the site via DP-2 are reduced in the proposed conditions. Please refer to
NPC/DEIR Appendix 5.1 for calculations.

The contributing area draining to DP-3 is not changed from existing to proposed condition and is an area of
woods in the northeast corner of the property. Please refer to NPC/DEIR Appendix 5.1 for calculations.

At a high level, the proposed stormwater management system consists of BMPs which are designed to collect,
treat, and mitigate runoff as stated above. The stormwater management system also keeps separate “clean”
water from the stormwater which must be treated. That is, MassDEP’s regulations consider stormwater runoff
from the athletic field and building roof “clean” so this runoff does not need to be treated prior to discharge.
Runoff from the wooded areas above the rock wall and groundwater collected in foundation drains are also
considered “clean” and these sources will be collected and managed separately from the stormwater which
requires treatment.

The athletic field drainage (Subcatchment 2.1) will be infiltrated to the maximum extent practicable in a
subsurface chamber system below the south parking lot, an area of fill. The building runoff (Subcatchment 2.5)
will be stored in a subsurface chamber system under the main entrance parking. Runoff from the wooded areas
which flows over the rock wall (Subcatchments 2.7 and 2.9) will be captured in a stone trench with perforated
pipe at the base of the wall. The trench will also collect runoff from the landscape area adjacent to north loop
roadway (Subcatchment 2.6). Discharges from these “clean” systems will be combined with the drainage from
the intermittent stream and discharged from the site via DP-2.

The rest of the contributary area of DP-2 requires treatment prior to discharge, and this will be accomplished
through a combination of Low Impact Development (LID) and structural BMPs. Bioretention gardens are
proposed to treat stormwater from the south parking lot (Subcatchment 2.3), the front plaza and parking area

Waltham High School | Final Environmental Impact Report 3 | p. 2

 Section 3: Land Alteration/Drainage

(Subcatchment 2.4), and the northern entrance road (Subcatchment 2.8). The front lawn also includes a water
quality swale (trench), which is designed to slow and treat stormwater prior to the bioretention garden near
Lexington Street. The gardens are located in areas of fill where possible and downgradient of the contributary
areas they serve. They are also located in areas of high visibility, which will facilitate educational and interactive
opportunities for students and public visiting the school.

The remainder of the roadways, walkways, plazas, and parking areas will be drained to a closed drainage
system and treated via structural BMPs such as water quality units. Proposed Subcatchment 2.11 consists of
woods and landscape area which drains overland toward the neighboring parcels to the east. In addition, a
swale and level spreader system are proposed to further protect the neighboring properties from overland flow.

Section 4.2 of the NPC/DEIR described the site being tributary to Chester Brook. All stormwater from the site
discharges to the brook, whether as overland runoff or stormwater captured by the existing underground
drainage system. The Project will not change the tributary area that drains to Chester Brook. The on-site
unnamed intermittent stream’s watershed is approximately 20.39 acres and includes all land upgradient of the
resource. As described in Section 4.2 of the NPC/DEIR, the Project will alter 0.4 acres of the tributary watershed
to the intermittent stream which is approximately 2%. Instead of contributing overland flow to the intermittent
stream, the runoff from the 0.4-acre portion will be collected in either the trench at the base of the rock wall or
within the catch basins within the school’s internal roadway and will combine flows from the Project before
discharging to Chester Brook. The 0.4-acre portion is represented in Subcatchments 2.6 and 2.9.

3.2.2 Hydrologic Modeling

The hydrologic models presented in the DEIR were developed using HydroCAD 10.00 using the SCS unit
hydrograph procedure, also known as the TR-20 runoff method. Type III 24-hr storms were modeled using
rainfall events downloaded from the NOAA Atlas 14 Precipitation Frequency Data Server in April, 2020.

3.2.3 Flooding and Groundwater

As discussed in Section 2.4 of the NPC/DEIR, the downgradient abutters to the east and south currently
experience flooding caused by stormwater or groundwater from the site. The Project has incorporated a swale
along the eastern edge of the property to protect those abutters from stormwater running directly from the site
into their properties. Refer to sheet C-132 included in Appendix 9.1. Abutters to the south will be protected
because although Project’s development (roadways and parking) extends further towards the southern
properties, it is graded to direct runoff to the stormwater management features which eventually discharge from
the site to Chester Brook via the Lexington Street drainage.

A supplemental subsurface exploration program to aid in the bedrock cut design is currently underway. The
program is comprised of test borings, geophysical testing, laboratory testing, down-the-hole packer testing, and
aquifer pumping tests. Rock core samples collected from test borings and geophysical testing are used to
identify bedrock fracture and joint location and orientation. Down-the-hole packer testing is performed to
evaluate the response of the fractures to injection of water under pressure. That information is used to better
understand the permeability of the rock under a variety of pressures, and evaluate the ability to inject fluids into
the rock fractures. The aquifer pumping tests will allow a better understanding of anticipated groundwater inflow
rates to the underdrain system, and expected volume of water exiting the rock face. Down-the-hole packer
testing and pump testing will be performed after the test borings are drilled and the boreholes are flushed. The
test borings are anticipated to be completed by the end of August 2020, and the down-the-hole packer and
pump testing program to be complete by mid-September 2020.

Based on visual observations of the rock core samples and the groundwater elevation data collected to date, it
is anticipated that the stream channel flow will not be impacted, however evaluations will continue as additional
aquifer data becomes available.

Waltham High School | Final Environmental Impact Report 3 | p. 3

 Section 3: Land Alteration/Drainage

Proposed finished grade elevations are lower than the observed groundwater level and in some cases are equal
to approximately 100 ft below the groundwater level. Groundwater will be controlled at the base of the rock cut
through a network of piping established at the base of the rock wall. Groundwater at the school and parking
garage will be managed and collected as a part of the underslab drainage system below the school and the site
drainage system.

Groundwater flow rates across the site will be estimated based on the results of the aquifer testing program
planned as a part of the ongoing supplemental subsurface exploration program described above. Once
available, aquifer testing results can be used to estimate time required for groundwater stabilization.

3.3 Synthetic Turf Field

As of the date of this document, Massachusetts does not have required test methods and specifications for
testing and regulating solid materials, such as synthetic turf. MassDEP has water quality regulations for six Per-
and Polyfluoroalkyl Substances (PFAS). In the past year, the synthetic turf industry has been utilizing various test
methods with varying degrees of effectiveness in determining concentrations of these compounds. The
subcommittee ASTM F08.65 is currently working on the development of a test method and specification to
address this variation in the industry and ASTM will continue to coordinate with the synthetic turf industry in the
development of this standard through a consensus based process. In the absence of published regulations, the
project will utilize EPA 533, which was recently approved by the EPA, for water quality as the basis of testing. To
address the solids aspect of turf material, the project will utilize Isotope Dilution techniques by Liquid
Chromatography Tandem Mass Spectrometry as 537.1 M. Reporting limits shall not exceed 0.5 µg/kg (µg:
microgram) as required by New York Department of Conservation part 375 (NYDEC part 375), with a reporting
criteria less than or equal to 1.0 µg/kg (NYDEC part 375). If any one of the six PFAS is detected in any sample at
or above 1 μg/kg, then synthetic turf should be tested by EPA 1312 SPLP and the leachate analyzed for total
PFAS below 70 ppt (parts per trillion), which is the current threshold for the six regulated PFAS under MADEP
water quality regulations.

Waltham High School | Final Environmental Impact Report 3 | p. 4

City Open Space Response
NPC/DEIR Figures
 2.2

2.2

2.3

LEGEND

DESIGN POINT 2.3

DP-3
#.# SUBCATCHMENT

LEGEND

Tc FLOW PATH
DESIGN POINT
SUBCATCHMENT LIMIT

PROPERTY LINE DP-3

#.# SUBCATCHMENT
WETLAND BOUNDARY LEXINGTON STREET
EXISTING 10' CONTOUR

Tc FLOW PATH
SUBCATCHMENT LIMIT

PROPERTY LINE

WETLAND BOUNDARY LEXINGTON STREET

EXISTING 10' CONTOUR

NPC / DEIR Figure 5.1 - Existing Drainage Area Map

Waltham High School, Waltham, MA
 2.10

2.10
2.11

2.11
2.3

2.3
LEGEND

DESIGN POINT

LEGEND

#.# SUBCATCHMENT
DESIGN POINT

DP-3
Tc FLOW PATH
#.# SUBCATCHMENT
SUBCATCHMENT LIMIT

PROPERTY LINE DP-3

Tc FLOW PATH
WETLAND BOUNDARY
SUBCATCHMENT LIMIT
EXISTING 10' CONTOUR
PROPERTY
PROPOSED 10' CONTOURLINE
WETLAND BOUNDARY
EXISTING 10' CONTOUR
PROPOSED 10' CONTOUR

NPC / DEIR Figure 5.2 - Proposed Drainage Area

Waltham High School, Waltham, MA
Climate Change 4
4.1 Stationary Use - GHG Emissions Reduction Analysis
4.2 Life Cycle Cost Analysis
4.3 Solar PV Study
4.4 Mobile Sources
Tables
4.1 GHG Emissions Analysis Summary: Stationary and Mobile
Sources
4.2 GHG Emissions Analysis: Whole Building
4.3 GHG Emissions Analysis: Reductions by End Uses
4.4 Life Cycle Cost Analysis: HVAC Systems and Building
Enclosure
4.5 Preliminary Project Incremental Costs and Payback
Analysis
4.6 Preliminary Project Annual Energy Consumption Costs
4.7 Energy Analysis Criteria (Energy Modeling Inputs)
4.8 Solar PV Systems List Cycle Cost Analysis (40% PV
Readiness)
4.9 Solar Photovoltaic (PV) Estimated GHG Emissions
Reduction
4.10 Predicted Motor Vehicle CO2 Emissions Burden
Figures
4.1 Solar PV Readiness Area
Greenhouse Gas Analysis and Sustainability
The GHG emission reduction analysis was updated per the NPC/DEIR Certificate, DOER Comment
letter dated June 26,, 2020 and subsequent conference call with MEPA and DOER on July 8, 2020.

The City of Waltham is designated as a MA DOER Green Community, based on its commitment to
environmental leadership as a community. Sustainability has been integrated into Waltham’s core
policies and objectives. Waltham has adopted the MA Stretch Energy Code and continues to develop
multiple energy efficiency and renewable policies that contribute to a strong community commitment to,
and expectation of, sustainable design in municipal building projects.

Stationary Sources
This FEIR updates the new Waltham High School GHG emission analysis to the new Massachusetts
Energy Code IECC 2018 (with MA Amendments). The energy modeling analysis follows the C401.2b
ASHRAE 90.1-2013 Appendix G, as modified by Massachusetts amended Sections C401.2,
C402.1.5, C402.3, 405.3, 405.4, 405.9 and C406, with three C406 options:
1. C406.3-light power density reduction,
2. C402.4 advanced digital lighting controls, and
3. C402.9-air infiltration reduction.

The FEIR includes an updated energy modeling analysis conducted during design development
based on the new preferred design alternative presented in this filing. In addition, the FEIR includes
a comparison of the proposed design and all-electric HVAC system scenarios requested under the
NPC/DEIR review to the new MA Stretch Code.

Section 4.1 describes the GHG emission reduction analysis comparing (4) alternative energy
efficiency scenarios to the Massachusetts Energy Code baseline, to be in effect as of August 7,
2020.
Baseline: Massachusetts Energy Code IECC 2018 (with MA Amendments)
1. Scenario 1: Massachusetts Stretch Code (as approved on February 7, 2020)
2. Scenario 2: Proposed Design
3. Scenario 3: All-electric heating and cooling system with proposed design building enclosure
4. Scenario 4: All-electric heating and cooling system with improved building enclosure (NZER)

Life Cycle Cost Analysis (LCCA) is described in section 4.2. The LCCA compares Scenarios 2, 3
and 4 to Scenario 1– Stretch Code. It inlcudes a detailed energy systems criteria and energy
modeling inputs for each scenario. The LCCA scenarios and results were presented to the Waltham
Sustainability Focus Group on July 23, 2020 and to the Waltham School Building Committee on
July 27, 2020. The School Building Committee elected to pursue the project design with Scenario 2
as the project energy systems of choice. The Life Cycle Cost Analysis (LCCA) analysis
demonstrated that Scenarios 3 and 4 financial outcomes are not beneficial to the Project, as they
result in a predicted annual energy costs increase. Scenarios 3 and 4 Life Cycle Cost Analysis
(LCCA) demonstrate the financial challenges and reduced returns to the City that would be
associated with implementing these measures as part of the Project.

Solar PV readiness is described in Section 4.3, the project includes 40% of the qualifying roof area
as required by the Massachusetts Energy Code IECC 2018 Appendix CA C103.3, MA Amendments
C103.2 and C403.2. Section 4.3 also includes a preliminary assessment for a future Solar

4 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 4: Greenhouse Gas Analysis and Sustainability

Photovoltaic (PV) system installation on the Project’s designated PV ready roof area, as well as a
GHG emission reduction analysis of the impact of a future installation.

The NPC/DEIR included the schematic design energy modeling that was completed in July 2019,
prior to the issuance of the new MA Energy Code (IECC 2018). It included the IECC 2015 with MA
Amendments as the baseline for the new Waltham High School’s NPC/DEIR GHG analysis. With a
more stringent baseline under the new MA Energy Code (IECC 2018), the resulting design development
GHG emissions reduction and energy savings has resulted in lower savings than the ones presented in
the NPC/DEIR.

Mobile Sources Summary

The FEIR updated the mobile sources GHG analysis’ transportation study with the following three traffic
analysis scenarios:
• 2024 No-Build
• 2024 Build without roadway improvements and TDMs
• 2024 Build with TDMs

Since the NPC/DEIR, the mobile source study area was expanded from 4 major roadway segments to
the 17 roadway segments, as well as included signalization of the Proposed High School Driveway
Intersection.

Section 4.4 describes the mobile sources GHG emission analysis.

GHG Emissions Summary

Table 4.1 shows the new Waltham High School GHG Emissions Analysis Summary for Stationary
and Mobile Sources

The stationary sources GHG emissions reduction resulted in a 22.4% reduction for the Scenario 2-
proposed design, when compared to the baseline (Massachusetts Code (IECC 2018 with MA
Amendments)) and 14.3% when compared to Scenario1-Stretch Code.

The Mobile Sources GHG emissions reduction analysis resulted in a 14.6% increase for the traffic
scenario without Transportation Demand Management (TDMs) and a 13.7% increase for the traffic
scenario with TDMs and signalization of the proposed driveway intersection when compared to the
Baseline-2024 No Build.

The overall site GHG emissions analysis resulted in an average of 4.3% emissions reduction when
accounting for both the stationary source GHG emission reduction and the mobile sources
TDMs/signalization scenario GHG emission increase.

Refer to Section 4.1 for the stationary GHG emission analysis & section 4.2 for the stationary
sources LCCA analysis comparing the four (4) building design scenarios. Refer to Section 4.4 for
the mobile sources GHG emissions analysis.

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 Section 4: Greenhouse Gas Analysis and Sustainability

Table 4.1 GHG Emissions Analysis Summary: Stationary and Mobile Sources
GHG
Baseline Proposed Difference
GHG Emissions Reduction/Increase
(tons/year) (tons/year) (%)
(tons/year)
MA Code
Stationary Sources 1,745 1,354 -22.4% -391
2024-No Build
Mobile Sources (Without TDMs) 6,257 7,114 14.6% 916
Mobile Sources (With TDMs and
Proposed High School Driveway 6,257 7,173 13.7% 858
Intersection Signalization

GHG
Stretch Code Proposed Difference
GHG Emissions Reduction/Increase
(tons/year) (tons/year) (%)
(tons/year)
Stationary Sources 1,580 1,354 14.3% -226

1 2019 ISO New England Electric Generator Air Emissions Report: 682 lb/MWh
2 EIA Fuel Emissions Factors, Carbon Dioxide Emissions Coefficients by Fuel, 2019, 117 lb/MMBtu

The City is committed to energy performance in compliance with the MSBA requirements and the City’s
own goal to outperform the new Stretch Code as stated above. Furthermore, the following will contribute
to the project’s measured energy performance and GHG reduction goals:
• MSBA’s recent initiative to pursue on-going commissioning and energy performance measurements
on new school projects
• The utility incentive program post installation verification
• The whole building air infiltration testing included as part of the project scope
• SMMA post-occupancy evaluation analysis

4.1 Stationary Use – GHG Emissions Reduction Analysis

The FEIR updated GHG emission reduction analysis to the new Massachusetts Energy Code IECC
2018 (with MA Amendments), Waltham is a Stretch Code Community. Energy modeling was
conducted using the latest version of eQuest, a widely recognized and accepted building energy
modeling program, and followed the protocol of C401.2 b-ASHRAE 90.1-2013 Appendix G, as
modified by Massachusetts amended Sections C401.2, C402.1.5, C402.3, 405.3, 405.4, 405.9 and
C406, including (3) C406 options:
1. C406.3-light power density reduction,
2. C406.4-enhanced digital lighting controls and
3. C406.9-reduced air infiltration.

This FEIR includes an updated energy modeling analysis conducted during design development
and based on the new preferred facility design alternative described in the NPC/DEIR. The FEIR
GHG emission reduction analysis compares the following scenarios to the MA Energy Code
baseline:
• Scenario 1-Stretch Code
• Scenario 2-Proposed Design
• Scenario 3-Proposed Design with VRF All-electric heating and cooling
• Scenatio 4-Improved Enclosure with VRF All-elelctric heating and cooling

Waltham High School | Final Environmental Impact Report 4 | p. 3

 Section 4: Greenhouse Gas Analysis and Sustainability

The following provides a brief description of each scenario. Refer to Table 4.2 for detailed energy
systems criteria input used as part of the energy modeling analysis.

Baseline - Massachusetts Energy Code IECC 2018 (with MA Amendments)

The baseline MA Code includes the following building energy systems:
• Natural gas boilers for the heating system.
• DOAS (Direct Outside Air System) ventilation with heat recovery as required by code (50%).
• Air based chiller cooling system.
• Code-compliant building enclosure thermal performance criteria.
• Code-compliant Lighting systems.
• The lighting systems and enclosure criteria comply with (3) C406 options: C406.3-light power
density reduction, C406.4-enhanced digital lighting controls and C406.9-reduced air infiltration.

Scenario 1 - Massachusetts Stretch Code (as approved on February, 7 2020)

Scenario 1 - Stretch Code includes energy systems that exceed the MA base code. It demonstrates
how the project attains 10% beyond the Base Code.
• Condensing natural gas boilers for the heating system.
• DOAS (Direct Outside Air System) ventilation with heat recovery as required by code (50%).
• Air based chiller cooling system with performance exceeding base code requirements.
• Building enclosure thermal performance criteria exceeding the base code requirements.
• Lighting systems efficiency exceeding C406.3-light power density requirements.
• The lighting systems and enclosure criteria comply with (3) C406 options: C406.3-light power
density reduction, C406.4-enhanced digital lighting controls and C406.9-reduced air infiltration.

Scenario 2 - Proposed Design

Scenario 2 – Proposed Design includes energy systems that exceed the MA Energy Code and
Stretch Code, comprehensively resulting in energy reduction better than the MA Stretch Code:
• High efficiency gas condensing natural gas boilers for the heating system.
• DOAS (Direct Outside Air System) ventilation with heat recovery performance outperforming the
base code requirements.
• Air based chiller cooling system with performance exceeding base code requirements.
• Building enclosure criteria exceeding the base code and Stretch Code requirements.
• Lighting Systems efficiency exceeding Stretch Code.
• The lighting systems and enclosure criteria comply and outperform the (3) C406 options:
C406.3-light power density reduction, C406.4-enhanced digital lighting controls and C406.9-
reduced air infiltration.
• The project includes a whole building air infiltration test, in addition to the design criteria
measures to achieve air infiltration reduction.

Scenario 3 - All-electric heating and cooling system with proposed design building enclosure
Scenario 3 includes an all-electric heating and cooling system with Scenario 2-proposed design
building enclosure.
• Commercial VRF/ASHP (air source heat pump) heating and cooling system.

Waltham High School | Final Environmental Impact Report 4 | p. 4

 Section 4: Greenhouse Gas Analysis and Sustainability

• DOAS (Direct Outside Air System) ventilation with heat recovery performance outperforming the
base code requirements.
• Building enclosure criteria exceeding the base code and Stretch Code requirements.
• Lighting Systems efficiency exceeding Stretch Code.
• The lighting systems and enclosure criteria comply and outperform the (3) C406 options:
C406.3-light power density reduction, C406.4-enhanced digital lighting controls and C406.9-
reduced air infiltration.

Scenario 4 - All-electric heating and cooling system with improved building enclosure (NZER)
Scenario 4 includes an all-electric heating and cooling system with an improved building enclosure
(NZER).
• Commercial VRF/ASHP (air source heat pump) heating and cooling system.
• DOAS (Direct Outside Air System) ventilation with heat recovery performance outperforming the
code requirements.
• Building enclosure criteria equivalent to Net Zero Energy Ready thermal exceeding the base
code and Stretch Code requirements:
o R-40 walls and R-60 roof
o Triple glazing system with a U-value assembly 0.22 per available 3 equal manufacturers)
o Reduced air infiltration measures for a goal of 0.10 CFM/SF @ 75 PA .
• The lighting systems and enclosure criteria comply and outperform the (3) C406 options:
C406.3-light power density reduction, C406.4 -enhanced digital lighting controls and C406.9-
reduced air infiltration.

GHG Emissions Reduction Analysis

When compared to a Massachusetts code-compliant high school facility, the Scenario 2-Proposed
Design is expected to decrease GHG emissions by approximately 22.4% percent, or approximately 391
tons/year, and 14.3% when compared to the Massachusetts Stretch Code or approximately 226 tons/
year. The Baseline Code totals 1,745 tons/yr, and the Scenario 1-Stretch Code totals 1,580 tons/yr,
while the proposed design totals 1,354 tons/yr.

The City of Waltham is a Stretch Code Community. The design development energy analysis estimates
25.6% energy savings over the MA Code baseline (IECC 2018), which comply and outperform with the
Massachusetts Stretch Code and the 10% energy performance required under the MSBA High
Efficiency Green School Program relative to the MA IECC 2018 Code (ASHRAE 90.1-2013) as modified
by Massachusetts amended Sections C401.2, C402.1.5, C402.3, 405.3, 405.4, 405.9 and C406.
Energy costs savings were analyzed and described under Section 4.2 – Life Cycle Cost Analysis (LCCA).

Scenarios 3 and 4 show a close result of 27.4% and 28.1% GHG reduction, respectively. It represents
an additional 5-5.7% GHG reduction when compared to the proposed design. It also demonstrates the
beneficial impact of the already proposed design improved enclosure thermal performance and air
tightness over Base Code and Stretch Code. The analysis and resulting pEUI for Scenarios 3 and 4
show a diminishing return when considering further improving the enclosure to a NZER level with the
predicted EUI (Energy Use Intensity) for both scenarios, at 30.3 and 30, respectively. The pEUI reduction
from an improved enclosure is in part limited by the overall plug load end use, which includes a large
comprehensive Program (Culinary, automotive and carpentry). Scenarios 3 and 4 Life Cycle Cost
Analysis (LCCA) demonstrate the financial challenges and reduced returns to the City that would be
associated with implementing these measures as part of the Project.

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 Section 4: Greenhouse Gas Analysis and Sustainability

However, the Life Cycle Cost Analysis (LCCA) demonstrated Scenarios 3 and 4 financial outcomes are
not beneficial to the Project, due to the annual predicted energy costs increase (vs. energy costs savings
for Scenario 2). Refer to Section 4.2 for the detailed LCCA.

Table 4.2 summarizes the GHG emissions reduction and the Design Development predicted energy
savings for the whole building design scenarios relative to the MA energy code (IECC 2018) baseline and
Scenario 1-Stretch Code.

Table 4.2 GHG Emissions Analysis: Whole Building

Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4
GHG Emissions MA Energy MA Stretch Proposed Proposed Electric
Code (IECC Code Design Design + Heating +
2018) (Natural Gas Electric NZER
Heating) Heating enclosure
Tons/yr. Tons/yr. Tons/yr. Tons/yr. Tons/yr.
756 675 483 0 0
Direct Natural Gas
Indirect Electricity 989 905 871 1,268 1255
Total 1,745 1,580 1,354 1,268 1,255
Diff. from Baseline (tons/yr) -165
-391 -478 -491
Diff. (%) 9.5%
22.4% 27.4% 28.1%

Diff. from Stretch

-226 -313 -325
Diff. %
14.3% 19.8% 20.6%
Predicted Energy Savings and pEUI
pEUI (kBtu/SF/yr.) 54.6 49.3 40.6 30.3 30
Energy Savings -Base Code (%) 10.0% 25.6% 44.4% 45.0%
Energy Savings- Stretch Code (%) 17.6% 38.4% 39.0%

Notes CO2 Emissions Factors

1 2019 ISO New England Electric Generator Air Emissions Report: 682 lb/MWh
2 EIA Fuel Emissions Factors, Carbon Dioxide Emissions Coefficients by Fuel, 2019, 117 lb/MMBtu
3 Using EIA 2020 energy costs, based on $0.1648/kWh and $1.26/therm
4 Energy Use Intensity (EUI) is a measure of annual building energy use per square foot of conditioned space

Table 4.3 demonstrates the project’s GHG emissions reduction calculations by end uses relative to the
MA energy Code (IECC 2015) baseline.

Notable is the fact that Scenario 3 and 4 EUI are close, which indicates the proposed design building
enclosure (beyond Stretch) has as beneficial impact in reducing the overall building load to the resulting
pEUI 30.3. However, the facility’s comprehensive program’s process load (plug load) remains a
challenge. The comprehensive educational programs include a culinary, automotive, carpentry and
daycare programs. These programs’ spaces add considerable amount of equipment load and ventilation
load when compared to a typical high school without such programs.
• The comprehensive programs’ process load ventilation system, such as the air filtration system
for carpentry and automotive, are in addition to the main building ASHRAE 62.1 ventilation
system. They run close to a 24/7 schedule during occupied months.

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 Section 4: Greenhouse Gas Analysis and Sustainability

• The culinary program adds a second commercial kitchen to the facility. Half of the culinary
program will be dedicated to teaching cooking on commercial electric kitchen equipment, the
other half on commercial natural gas kitchen equipment.
• The automotive and carpentry programs present both additional electric and electronic
equipment (vs. typical high schools), as well as additional ventilation system.
• The automotive program is planning for electric vehicle automotive curriculum as part of their
program.
• The equipment for the culinary and daycare programs add domestic hot water use loads
beyond a typical high school.
• The comprehensive program equipment is limited in energy efficiency and controls. Automotive
equipment such as auto-lifts and electronic software-based tools do not have efficiency
measures options. Despite the limitations, the project equipment planning is striving to include
as much efficiency measures as possible.
o All culinary kitchen and daycare equipment will optimize Energy Star rating for energy efficiency
and Water Sense for water efficiency. In addition, equipment specified have improved refrigerant
options that meet the Montreal Protocol.
o The air compressors system is centralized for all shops. It includes VFDs which may qualify for
utility incentives.
o The carpentry dust collection system may be optimized with VFDs, pending on type of filters
required. Unfortunately, this option may not be available from a minimum of three equal
manufacturers, which may deem it not applicable to this project.
o Equipment may not be switched off through programmable controls for safety and operational
reasons. Each piece of equipment is shut off individually. Only the emergency shut off is used to
turn off equipment at once.

The resulting impact is reflected below in the kitchen, miscellaneous loads end use. The plug
load/process load, common to all scenarios, impacts the overall energy profile of the facility. It
represents 45% of the overall electric load for the MA Code baseline, 49% for the Stretch Code, 51% for
Scenario 2, 35% for Scenario 3 and 35% for Scenario 4. The equipment plug load/process load
represents 10.6 kBtu/SF/yr of the pEUI, across all scenarios, which is 26.4% of the proposed design
pEUI, 35% of the Scenario 3’s 30.3 pEUI and 35.5% of Scenario 4’s 30 pEUI.

As mentioned above, the comprehensive program spaces offer limited energy efficiency and GHG
emissions mitigation measures. However, the design team continues to research and consider
opportunities for energy efficiency within the MSBA requirement of three equals on all products and
equipment.

Table 4.3 GHG Emissions Analysis: Reduction by End Uses

End use Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4

Proposed Proposed Electric
MA Energy
MA Stretch Design Design + heating +
Code (IECC
Code (Nat. Gas Electric NZER
2018)
Heating) Heating enclosure
Direct (Natural Gas) MMBtu/yr. MMBtu/yr. MMbtu/yr MMBtu/yr. MMBtu/yr.
Space Heating 10 9 6 0 0
Domestic Hot Water 3 3 2 0 0
Total 13 12 8 0 0

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 Section 4: Greenhouse Gas Analysis and Sustainability

End use Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4

Proposed Proposed Electric
MA Energy
MA Stretch Design Design + heating +
Code (IECC
Code (Nat. Gas Electric NZER
2018)
Heating) Heating enclosure
Indirect (Electricity MWh/yr. MWh/yr. MWh/yr. MWh/yr. MWh/yr.
Space Heating 0 6 798 710
Space Cooling 252 220 125 252 275
Domestic Hot Water 671 671
Ventilation Fans 760 578 769 275 307
Pumps and Aux. 153 151 9 77 71
Heat Rejection
Lighting 390 360 300 300 300
Kitchen Equipment 131 131 131 131 131
Misc. Equipment 1,173 1173 1,173 1,173 1,173
Ext. usage 42 42 42 42 42
Total 2,901 2,655 2,555 3,718 3,680
Predicted Energy Use Intensity (pEUI)
kBtu/SF/yr kBtu/SF/yr kBtu/SF/yr kBtu/SF/yr kBtu/SF/yr
pEUI 54.6 49.3 40.6 30.3 30.0

Project SF (modeled) 418,000

Project SF (designed) 418,000
Factor 1
Notes:

1 CO2 Emissions Factors:

a. 2019 ISO New England Electric Generator Air Emissions Report: 682 lb/MWh
b. EIA Fuel Emissions Factors, Carbon Dioxide Emissions Coefficients by Fuel, 2019, 117 lb/MMBtu
2 Process loads: Kitchen equipment includes the 2 commercial level kitchens (cafeteria and culinary teaching
program) equipment process load. The Misc. Equipment includes all comprehensive program equipment loads
for automotive, culinary, carpentry, daycare, etc., as well as the refrigeration loads for the culinary.

GHG Emissions Reduction Mitigation Measures Summary

The following GHG emissions reduction measures are included in the project, as provided in the
NPC/DEIR.
• High Performance Building Enclosure:
o R-50 Roof
o R-28.5 Walls
o U-0.32 Glazing System (SHGC 0.27)
o Triple Glazing Systems (Add Alternative)
o Window to Wall Ratio- 25-30% goal
o Exterior Shading Devices
o Light colored Reflective Roof
o Solar PV readiness (40% min, compliant with the MA Energy Code)
• Whole Building Air Infiltration Testing included in the project scope and budget.
• High efficiency Lighting Systems:
o Light Power Density Reduction (LPD)
o Vacancy and Daylight controls
o Advanced Digital network Controls
o All LED Exterior Lighting

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 Section 4: Greenhouse Gas Analysis and Sustainability

• High Efficiency transformers.

• Energy Star rated Appliances and Equipment.
• High Efficiency Mechanical Systems (HVAC):
o Condensing Natural Gas boilers
o Variable frequency Drives (VFDs) on pumps
o DOAS ventilation with Heat Recovery
o High-Performance air-cooled chiller
o Demand Control Ventilation
o Energy Management System (EMS) and Controls
o High Efficiency Domestic Hot Water (DHW)
o Kitchen Hood Controls
• Enhanced Commissioning for Mechanical, Electrical, Plumbing and Building Enclosure systems.
• High performance Elevators.
• Green vegetated Roof.
• Optimized Daylighting and access to views.

Note: The City of Waltham is undergoing negotiation for a City-wide Green Power Purchase Agreement
Contract.

4.2 Life Cycle Cost Analysis

A life cycle cost analysis (LCCA) was conducted comparing Scenarios 2, 3 and 4 to Scenario 1–
Stretch Code. It includes a 30 year Present Value analysis (up to year 2050) for the energy costs
(annual utility costs for electricity and natural gas), initial project costs, maintenance costs and
replacement costs.

Table 4.4 provides for the LCCA summary results. The plug load/process load, common to all scenarios,
reduces the impact of the improved enclosure and HVAC systems on each scenario's pEUIs and overall
energy costs. It compounds on the cost of heating with electricity, which is currently more costly than
natural gas. It outweighs the HVAC load reduction, system sizing (peak load reduction based) and
system costs, resulting in a higher annual energy cost. It impacts the feasibility of a cost neutral NZER
scenario and a beneficial payback. Both Scenario 3 and Scenario 4 demonstrate a pEUI in the 30’s,
however the annual energy costs resulted in an increase when compared to Scenario 1-Stretch Code
and Scenario 2-proposed design. Please note that Scenario 4-Electric heating/cooling with NZER
enclosure also includes a larger and more costly emergency generator.

Based on a 30-year life cycle costs (up to year 2050), the cost of energy represents between 65% and
70% of the overall project systems costs. Scenario 4 represents only 1% energy costs savings over 30
years.

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 Section 4: Greenhouse Gas Analysis and Sustainability

Table 4.4 Life Cycle Cost Analysis: HVAC Systems and Building Enclosure

System Costs as Present Value

System Options
Installation Replacement Maintenance Energy 30-Year Life
Natural Gas
Boilers +
Scenario Stretch DOAS + Air
$17,026,689 $9,108,543 $1,790,000 $63,083,000 $91,008,000
1 Code Cooled Chiller
(Stretch
Code)

Natural Gas
Scenario Proposed Boilers +
$17,576,528 $10,145,649 $1,789,909 $57,413,000 $86,925,000
2 Design DOAS + Air
Cooled Chiller

Proposed VRF + DOAS

Scenario Design w/ + Proposed
$17,522,000 $12,346,236 $1,952,000 $69,675,000 $101,495,000
3 Electric Design
Heating Enclosure

Electric
VRF + DOAS
Scenario Heating
+ NZER $19,923,000 $15,418,000 $1,952,000 $68,973,000 $106,266,000
4 w/ NZER
Enclosure
Enclosure

Notes:

1. Installation costs are based on Schematic Design project cost estimate.

2. Replacement costs are specific to each system, based on ASHRAE useful life data and using unit costs brought
forward as Present Value costs.
3. Maintenance costs are estimated to include third-party service to systems, but in-house routine maintenance.
4. Energy costs are based on energy modeling analysis and current energy costs based on EIA 2020.
5. Total Cost is the sum of Installation, Replacement, Maintenance and Energy costs.
6. Present Value modeled on a 30-year lifecycle cost, 3% depreciation.
7. Refer to the Appendix for Installation, Replacement and Maintenance Costs details.

Table 4.5 demonstrates the preliminary incremental costs and payback for each scenario, when
compared to Stretch Code.

Scenarios 3 and 4 resulted in an additional $57,080 and $51,004 additional annual energy costs,
respectively, when compared to the Stretch Code, while the proposed design brings $49,099 energy
costs savings. When comparing the proposed designs, Scenarios 3 and 4 represent over $100,000 in
additional energy costs annually. Current available incentives and energy costs unfortunately are not
outweighing the additional annual energy costs.

An energy "cost neutral" equivalent scenario to Stretch Code would require the all-electric Scenario 3
and 4 to have an EUI of 25 kBtu/SF/yr, with an annual energy cost savings of $48,179. The Waltham
High School comprehensive program process load (plug load) presents a major challenge in attaining
pEUI 25 for this facility. The project miscellaneous equipment and refrigeration loads are equivalent to a
pEUI of 10.6, a third of Scenario 3 and 4’s total pEUI. As mentioned in Section 4.1, Plug load and
ventilation controls are not applicable in the same manner as on a typical classroom.

The incremental costs of Scenario 4 when compared to Scenario 2: Scenario 4 represents $2,896,406
over Scenario 1 -Stretch Code and $2,346,567 over Scenario 2-Proposed Design. The additional cost is
not financially feasible for the City as part of this project.

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 Section 4: Greenhouse Gas Analysis and Sustainability

Scenario 3 offers a slight cost reduction over the Scenario 2-proposed design, when comparing
incremental costs, totaling $55,000. The Scenario 3 and 4 incremental costs include the HVAC sizing
reduction and system cost reduction totaling a $305,000 cost over base code and $175,000 over Stretch
Code. However, all electric heating requires the emergency generator to be designed to support the
heating loads during a winter power out event. This adds significant load to the emergency generator
and doubles its costs from the proposed design system. It outweighs the costs benefits of the HVAC
sizing reduction and system cost reduction. The resulting narrow margin cost benefits are not enough to
neutralize the low cost of natural gas as a heating fuel, 4 to 5 time less than the cost of electricity.

Please note that the current MA CEC website states that the VRF incentives program is closed: “Due to
funding constraints, MassCEC is no longer accepting applications for the VRF program.” For that reason,
the project may not justify accounting for incentives that are no longer provided. [Original MA CEC
incentive program for VRF systems would be capped at $150,000/project.]

[Source: https://www.masscec.com/air-source-heat-pumps and https://files-cdn.masscec.com/get-clean-

energy/business/clean-heating-cooling/VRF_Program_Manual_EFFECTIVE_FEB_2019.pdf]

Table 4.5 Preliminary Project Incremental Costs and Payback Analysis

System Options System Installation Incremental Annual Energy Payback Estimated Payback
Description Costs costs Costs Savings Incentives⁴ with
$ $ % $ Yrs. $ Incentives
Natural Gas
Boilers +
Scenario Stretch DOAS + Air
$17,026,689 $0
1 Code Cooled Chiller
(Stretch
Code)
Natural Gas
Scenario Proposed Boilers +
$17,576,528 $549,839 0.3% $49,099 11.2 $209,000 2.1
2 Design DOAS + Air
Cooled Chiller

Proposed VRF + DOAS

Scenario Design w/ + Proposed
$17,521,528 $494,839 0.2% ($57,080) 0.0 $184,394 N/A
3 Electric Design
Heating Enclosure

Electric
VRF + DOAS
Scenario Heating w/
+ NZER $19,923,096 $2,896,406 1.5% ($51,004) 0.0 $377,552 N/A
4 NZER
Enclosure
Enclosure

Notes:

1. Utility Incentives are based on the current MassSave PA comprehensive Integrated Design incentives program,
under which the project is already registered for: $0.30/kWh and $1.70/Therm. The estimated utility MassSave
incentives are not confirmed or approved by the utility. Preliminary AEC incentives based on DOER’s AEC
incentives calculator: $2/AEC [$1,519 for Scenario 3 and $1,352 for Scenario 4]. The estimated AEC incentives
are subject to change based on the RECs market at the time of project construction completion. All incentives
are included in the payback calculations for the sole purpose of the FEIR, as required in the NPC/DEIR comment
letter.
2. All cost estimates are sourced from recent project costs estimates and bids (SMMA Schools).
3. Incremental Costs percentage (%) is compared to the estimated building construction costs and budget:
$199,511,592 (Schematic Design Estimate).

Waltham High School | Final Environmental Impact Report 4 | p. 11

 Section 4: Greenhouse Gas Analysis and Sustainability

Table 4.6 provides for the preliminary project annual energy consumption costs.

Table 4.6 Preliminary Project Annual Energy Consumption Costs

Present
Total Annual Energy Use
Value
Annual Annual
System Options Natural
Electricity Energy Energy 2050 (30
Gas
(kWh)* Costs Costs yrs.)
(therm)
($) savings ($)
NATURAL GAS
Scenario BOILERS + DOAS +
Stretch Code 2,655,014 115,368 $546,278 $63,083,106
1 AIR COOLED CHILLER
(Stretch Code)

NATURAL GAS
Scenario Proposed
BOILERS + DOAS + 2,565,943 80,831 $497,285 $48,993 $57,425,466
2 Design
AIR COOLED CHILLER

Proposed
VRF + DOAS +
Scenario Design w/
PROPOSED DESIGN 3,755,442 0 $609,508 ($63,230) $70,384,805
3 Electric
ENCLOSURE
Heating
Electric
Scenario Heating w/ VRF + DOAS + NZER
3,691,811 0 $599,181 ($52,903) $69,192,228
4 NZER ENCLOSURE
Enclosure
Note

1. Using EIA 2020 energy costs, based on $0.1648/kWh and $1.26/therm

Table 4.7 shows the project energy modeling analysis inputs for the Massachusetts Energy Code
baseline and the proposed design.

Table 4.7 Energy Analysis Criteria (Energy Modeling Inputs)

Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4 (3) C406
amendments:
MA Energy Code Stretch Code Proposed Proposed Design Electric Heating + - C406.3: Reduced
Design + Electric NZER Enclosure lighting power
Heating - C406.4: Enhanced
Natural Gas Boilers Natural Gas Natural Gas VRF + DOAS + VRF + DOAS + digital lighting
+ DOAS + Air Boilers + Boilers + DOAS Proposed Design NZER Enclosure controls
Cooled Chiller DOAS + Air + Air Cooled Enclosure - C406.9: Reduced
Cooled Chiller Chiller air infiltration
Comments
Building Enclosure
U = 0.032 U = 0.028 U = 0.020 U = 0.020 U = 0.016
Roof (R-30ci) (R-35ci) (R-50ci) (R-50ci) (R-60ci)
U = 0.052 U = 0.047 U = 0.035 U = 0.035 U = 0.025
Walls (R-19.2) (R-21.2) (R-28.5) (R-28.5) (R-40ci)

Reflectivity 0.5 0.5 0.5 0.5 0.5

U = 0.033 (R-30) U = 0.033 (R- U = 0.033 (R-30) U = 0.033 (R-30) U = 0.033 (R-30)
Floor
30)
U = 0.100 (R-10) U = 0.100 (R- U = 0.060 U = 0.060 U = 0.060
Slab
10) (R-16.6) (R-16.6) (R-16.6)

Waltham High School | Final Environmental Impact Report 4 | p. 12

 Section 4: Greenhouse Gas Analysis and Sustainability

Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4 (3) C406

amendments:
MA Energy Code Stretch Code Proposed Proposed Design Electric Heating + - C406.3: Reduced
Design + Electric NZER Enclosure lighting power
Heating - C406.4: Enhanced
Natural Gas Boilers Natural Gas Natural Gas VRF + DOAS + VRF + DOAS + digital lighting
+ DOAS + Air Boilers + Boilers + DOAS Proposed Design NZER Enclosure controls
Cooled Chiller DOAS + Air + Air Cooled Enclosure - C406.9: Reduced
Cooled Chiller Chiller air infiltration

Air Infiltration 0.25 cfm/sf @ 75 0.25 cfm/sf @ 0.25 cfm/sf @ 75 0.25 cfm/sf @ 75 0.15 cfm/sf @ 75
Pa 75 Pa Pa Pa Pa C406.9

U = 0.38 U = 0.36 U = 0.32 U = 0.32 U = 0.22

Windows
(Assembly) (Assembly) (Assembly) (Assembly) (Assembly)
SHGC 0.40 SHGC 0.40 SHGC 0.29 SHGC 0.29 SHGC 0.29

Entrance doors U = 0.77; SHGC U = 0.77; U = 0.77; SHGC U = 0.77; SHGC U = 0.77; SHGC
0.40 SHGC 0.40 0.40 0.40 0.40

Skylights U = 0.50; SHGC U = 0.50; U = 0.50; SHGC U = 0.50; SHGC U = 0.50; SHGC
0.40 SHGC 0.40 0.40 0.40 0.40
Window-to- 22% Vertical 22% Vertical ~25% Vertical ~25% Vertical ~25% Vertical
wall ratio fenestration fenestration fenestration fenestration fenestration
U-value =
Opaque Doors U-value = 0.38; 0.38; SHGC - U-value = 0.38; U-value = 0.38; U-value = 0.38;
SHGC - 0.50 0.50 SHGC - 0.50 SHGC - 0.50 SHGC - 0.50
Lighting and Equipment Power Density

Lighting (LPD) 0.648 w/sqft 0.6 w/sqft 0.5 w/sqft 0.5 w/sqft 0.5 w/sqft C406.3 + C406.4
Exterior lighting 12 kW 12 kW 12 kW 12 kW 12 kW
Plug loads
(process Incl. Comprehensive
energy) 1.00 w/sqft 1.00 w/sqft 1.00 w/sqft 1.00 w/sqft 1.00 w/sqft Programs
Misc. Loads
Elevator
Two (2)
22.38 kW (30 22.38 kW (30
elevators; 15 22.38 kW (30 HP) 22.38 kW (30 HP) 22.38 kW (30 HP)
HP) HP)
HP ea.
(assumption)
Plumbing

Peak flow 5 gallons per 5 gallons per 5 gallons per 5 gallons per 5 gallons per
(gpm) minute (gpm) minute (gpm) minute (gpm) minute (gpm) minute (gpm)

100% thermal 100% thermal

Water heating 80% thermal 88% thermal 95% thermal efficiency (electr. efficiency (electr.
efficiency efficiency efficiency efficiency tank) tank)
Kitchen loads
Kitchen equip.
consumption 200 kW 200 kW 200 kW 200 kW 200 kW Incl. both kitchens**
Refrigeration
Walk-in Code per Code per In addition to
kWh/day/volume Code per volume Code per volume
refrigerator and volume volume kitchen loads
freezer
(5000 CFM (5000 CFM (5000 CFM
(5000 CFM (5000 CFM makeup air) makeup air) makeup air)
Kitchen Hood
makeup air) makeup air) Incl. Exhaust Incl. Exhaust Incl. Exhaust
Controls Controls Controls

Waltham High School | Final Environmental Impact Report 4 | p. 13

 Section 4: Greenhouse Gas Analysis and Sustainability

Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4 (3) C406

amendments:
MA Energy Code Stretch Code Proposed Proposed Design Electric Heating + - C406.3: Reduced
Design + Electric NZER Enclosure lighting power
Heating - C406.4: Enhanced
Natural Gas Boilers Natural Gas Natural Gas VRF + DOAS + VRF + DOAS + digital lighting
+ DOAS + Air Boilers + Boilers + DOAS Proposed Design NZER Enclosure controls
Cooled Chiller DOAS + Air + Air Cooled Enclosure - C406.9: Reduced
Cooled Chiller Chiller air infiltration
HVAC
Cooling
40 units w/ Heat
(2) air cooled (2) air cooled 40 units w/ Heat
5 air cooled Recovery +
Unit(s) chillers per chillers per Recovery + Branch
chillers Branch Circuit
IECC/App G IECC/App G Circuit Controllers
Controllers
Operating 75⁰ cooling 75⁰ cooling 75⁰ cooling 75⁰ cooling 75⁰ cooling
temperature temperature temperature temperature temperature temperature
Load Sizing (Auto-sized) (Auto-sized) (Auto-sized) (Auto-sized) (Auto-sized)
10.1 EER (0.842 11 EER (0.917 11.9 EER (0.992
Efficiency 12 EER 12 EER
kW/ton) kW/ton) kW/ton)
Heating
40 units w/ Heat
(2) 40 units w/ Heat
(2) Atmospheric 4 Condensing Recovery +
Unit(s) Atmospheric Recovery + Branch
HW boilers HW Boilers Branch Circuit
HW boilers Circuit Controllers
Controllers
Operating 70⁰ heating 70⁰ heating 70⁰ heating 70⁰ heating 70⁰ heating
temperature temperature temperature temperature temperature temperature
Boiler
80% 88% 95%
Efficiency %
VRF (ASHP) 3.51 COP 3.51 COP
Fans
Standard efficiency Standard High efficiency High efficiency
Efficiency High efficiency fans
fans efficiency fans fans fans
Mech eff. 0.6 0.6 0.7 0.7 0.7
Ventilation
ASHRAE 62.1 ASHRAE 62.1
ASHRAE 62.1 ASHRAE 62.1 ASHRAE 62.1
assumptions assumptions for
assumptions for assumptions for assumptions for
for occupant occupant
occupant density, occupant density, occupant density,
Design criteria density, OA density, OA CFM
OA CFM from OA CFM from OA CFM from
CFM from from HVAC
HVAC design HVAC design HVAC design
HVAC design design
assumptions assumptions assumptions
assumptions assumptions

DOAS/ERUs - DOAS/ERUs - DOAS/ERUs -

Coupled w/ VAV Coupled w/ Decoupled Decoupled Decoupled
Ventilation
supply air VAV supply air ventilation ventilation supply ventilation supply
supply air air air
Enthalpy Enthalpy Wheel - Enthalpy Wheel -
Heat/Energy Enthalpy Wheel - Enthalpy Wheel -
Wheel - 50% 70% 70%
Recovery 50% effectiveness 70% effectiveness
effectiveness effectiveness effectiveness
DCV where
DCV where required by DCV beyond DCV beyond code DCV beyond code
required by code code (area code (all (all (all
Controls
(area >500sqft w/ >500sqft w/ educational/occ educational/occu educational/occupi
25ppl/1,000sqft) 25ppl/1,000sq upied spaces) pied spaces) ed spaces)
ft)

Waltham High School | Final Environmental Impact Report 4 | p. 14

 Section 4: Greenhouse Gas Analysis and Sustainability

Baseline Scenario 1 Scenario 2 Scenario 3 Scenario 4 (3) C406

amendments:
MA Energy Code Stretch Code Proposed Proposed Design Electric Heating + - C406.3: Reduced
Design + Electric NZER Enclosure lighting power
Heating - C406.4: Enhanced
Natural Gas Boilers Natural Gas Natural Gas VRF + DOAS + VRF + DOAS + digital lighting
+ DOAS + Air Boilers + Boilers + DOAS Proposed Design NZER Enclosure controls
Cooled Chiller DOAS + Air + Air Cooled Enclosure - C406.9: Reduced
Cooled Chiller Chiller air infiltration
Thermal 75⁰ cooling, 70⁰ 75⁰ cooling, 75⁰ cooling, 70⁰ 75⁰ cooling, 70⁰ 75⁰ cooling, 70⁰
comfort heating 70⁰ heating heating heating heating
Building Occupancy Schedule
Weekdays,
School day A. ASHRAE
A. ASHRAE 90.1 A. ASHRAE 90.1 A. ASHRAE 90.1 A. ASHRAE 90.1
classes, 90.1 User's
User's manual User's manual User's manual User's manual
Evenings manual
Weekends

4.3 Solar Photovoltaic (PV) Feasibility Analysis

A preliminary Solar Photovoltaic (PV) feasibility analysis was conducted for the potential to reduce GHG
emissions by installing a Solar PV system in the allocated 40% PV readiness area of the roof. The City of
Waltham does not intend to install a Solar PV system as part of the new school project due to budgetary
constraints. The following analysis is intended to solely respond to the NPC/DEIR comments.

Figure 1 demonstrates the available flat roof PV area, based on Add code section /language. Please note
that the HVAC equipment takes a considerable portion of the roof area and consolidation is not always
feasible. In addition, roof screens are required to shield HVAC equipment for aesthetic and acoustical
purposes in addressing adjacent neighborhoods. Many projects seeking to achieve higher % of roof
mounted PV, such as Net Zero Energy project, often recourse to locate equipment on the ground level
and/or Solar PV Canopies over equipment. The City of Waltham, alongside other MA school districts
prefer for all HVAC equipment to be located on the roof for safety reasons. Solar PV Canopies mounted
above HVAC equipment have proven to be challenging in New England due to winter conditions creating
drainage and icy conditions below the canopies, resulting in higher costs to manage the drainage from
the canopies and roof maintenance.

Figure 4.1 Solar PV Readiness Area (40% per MA energy code IECC 2018)

Waltham High School | Final Environmental Impact Report 4 | p. 15

 Section 4: Greenhouse Gas Analysis and Sustainability

Table 4.8 provides for the Solar PV system costs, estimated energy harvesting and payback.

Table 4.8 Solar PV System Life Cycle Cost Analysis (40% PV Readiness)

Total Available Roof area (SF)¹ 128253

PV readiness area (40%) 52,858

Total Estimated PV System Costs ($) $2,220,036

School Roof Array ($3.50/w²)
Size (kW) 634 Assuming 12 w/SF³
Estimated Cost ($) $2,220,036
Estimated Payback
Predicted PV Electrical Harvest (kWh) 634,296
Predicted PV Electrical energy costs savings ($)⁴ $104,532
Payback (yrs.) 21
Energy Usage
Predicted EUI (kBtu/SF/yr) 40.6
Predicted Annual Energy Use (kBtu) 16,970,800
Predicted Annual Energy Electric. Use (kWh equiv.) 4,972,400
Estimated % of total building predicted energy use 12.8%
Notes:

1. Per IECC 2018 MA Amendments C103.2 and C403.2 and IECC 2018 Appendix CA C103.3
2. All estimated costs based on current PV market rates, based on recent public project bids (Source: Solar Design
Associates and SMMA recent projects – low roof PV system bids varied between $3.50-$3.94 w/SF). All costs
are subject to change.
3. Panel efficiency may vary between 10-14 w/SF. The higher end panels often result in a higher $/w or $/Kwh,
pending on a “turn-key” District ownership or PPA contract.
4. Based on EIA 2020 $0.1648/kWh. It does not include peak rate savings, as the rates would likely be negotiated
with the utility at the time of the installation. In addition, it is likely that the totality of the PV could still be solely
consume by the facility in the less occupied hours and summer months, as it represents only 12.8 % of the
overall building energy load.

Table 4.9 provides for the estimated GHG emission reduction associated with installing a Solar
Photovoltaic system.

Table 4.9 Solar Photovoltaic (PV) Estimated GHG Emission Reduction

Baseline Scenario 1 Solar PV impact
MA Energy Code
GHG Emissions MA Stretch Code 40% roof area
(IECC 2018)
tons/yr
Direct Natural Gas 756 675
Indirect Electricity 989 905 -236
Total 1,745 1,580 -236
Diff. from Baseline (tons/yr) -236
Diff. (%) 13.5%
Diff. from Stretch -236
Diff. % 14.92%
Notes:

1 2019 ISO New England Electric Generator Air Emissions Report: 682 lb/MWh
2 EIA Fuel Emissions Factors, Carbon Dioxide Emissions Coefficients by Fuel, 2016, 117 lb/MMBtu

Waltham High School | Final Environmental Impact Report 4 | p. 16

 Section 4: Greenhouse Gas Analysis and Sustainability

4.4 Mobile Sources – Transportation

Transportation-related emissions for the Base Case are modeled for the “build without mitigation”
condition. The analysis is based on a study year of 2024. The transportation analysis for the proposed
case includes the effects of any roadway improvements, Transportation Demand Management (TDM)
program proposed by the City of Waltham, and signalization of the Proposed High School Driveway
Intersection.

The transportation portion of the GHG analysis calculated emissions of CO2 for the traffic study area for
three traffic analysis scenarios:
• 2024 No-Build
• 2024 Build without roadway improvements and TDMs
• 2024 Build with TDMs

Since the NPC/DEIR, the mobile source study area was expanded from 4 major roadway segments to
the following 17 roadway segments:
• Lexington Street South of Totten Pond Road
• Bacon Street
• Totten Pond Road
• Lexington Street North of Totten Pond Road
• Stanley Road
• Espousal Center Driveway
• Lexington Street North of Stanley Road
• Jack's Way West of Existing Middle School
• Lexington Street North of Jack's Way
• Woodcliff Drive
• Forest Street South of Woodcliff Drive
• Forest Street North of Woodcliff Drive
• Exit Only Driveway
• Lexington Street North of Exit Only Driveway
• Bishops Forest Drive
• Lake Street
• Lexington Street North of Lake Street

The vehicle miles traveled (VMT) for the 17 roadway segments in the traffic study area were calculated
by multiplying the length of each road segment by the average daily traffic (ADT) volume on the
segment. The CO2 emissions for each roadway segment were calculated with the latest version of the
EPA MOVES model (MOVES2014b). Average daily traffic volumes were provided by Bryant Associates.
Tables 1 and 2 in Appendix 4.4 presents the VMT and emission calculations.

Idling emissions were calculated using predicted vehicle traffic volumes and delay times for each traffic
movement for the signalization of the Lexington Street, Stanley Road, and the Espousal Center driveway
(Proposed High School driveway) intersection and for the other intersection/roadway improvements
described in Section 8 of the NPC/DEIR. The afternoon peak-hour period was analyzed for each model
year scenario. Factors were provided by Bryant Associates, to convert the calculated peak hour idling
emissions to daily values. Table 3 in Appendix 4.4 shows the idling emissions calculations. Table 4.10
summarizes the idling vehicle CO2 emissions for each case.

Transportation Demand Management

The City of Waltham will encourage and promote sustainable measures of transportation that will help to
reduce the emission of greenhouse gases. These measures may include:
• Encouraging and incentivizing the use of buses (High occupancy vehicles).

Waltham High School | Final Environmental Impact Report 4 | p. 17

 Section 4: Greenhouse Gas Analysis and Sustainability

• Limiting bus and vehicle idling at the school.

• Providing improved site circulation and intersection design to reduce idling times for vehicles.
• Encouraging the use of bicycles and pedestrian traffic to the school and providing numerous secure
bike racks/storage.
• Providing vehicle charging stations for electrical vehicles.
• Offering preferred parking for carpool and low emission vehicles.
• Providing assigned parking spaces to minimize travel time on-site.
It is anticipated the proposed TDM measures will decrease trips to the site 1, which in aggregate it is
estimated will reduce CO2 transportation emissions by 2%.
Intersection Improvements
Section 8 of the NPC/DEIR presented a detailed discussion of the signalization of the Lexington Street,
Stanley Road, and the Espousal Center driveway (Proposed High School driveway) intersection, a traffic
signal is proposed and signalized capacity analysis was undertaken for future build conditions during the
school A.M. and school P.M. peak hours. The 2024 Build with TDMs and Proposed High School
Driveway Intersection Signalization scenario, which also includes the other intersection/roadway
improvements, will reduce vehicle idling conditions and as a result decrease CO2 idling emissions for all
vehicles by 2.5% compared to the 2024 Build without TDMs scenario.
Transportation CO2 emissions are summarized in Table 4.10. The emissions listed for the 2024 No-Build
case include existing volumes on the roadway network plus background growth rate of 0.5% per year.
The 2024 Build without TDMs case includes the 2024 No-Build volumes plus the new project-generated
trips, but not roadway improvements and TDMs. The 2024 Build with TDMs and Proposed High School
Driveway Intersection Signalization case includes the 2024 No-Build volumes, new project-generated
trips, roadway mitigation measures, proposed TDMs, and improved vehicle idling conditions due the
signalization of the High School Driveway intersection.

The Project’s transportation emissions are calculated by subtracting the 2024 No-Build values from
those for the 2024 Build cases. Table 4.10 reveals the 2024 Build with TDMs and Proposed High School
Driveway Intersection Signalization CO2 emissions (857.6 tons/year) will be 6% less than those for the
2024 Build without TDMs case (916.6 tons/year).

Table 4.10 Predicted Motor Vehicle CO2 Emissions Burden

2024 Build with TDMs and

2024 Build without
Traffic Operation 2024 No-Build Proposed High School Driveway
TDMs
Intersection Signalization*
Moving 11,589.9 kg/day 13,325.5 kg/day 13,290.8 kg/day
Idling 3,974.8 kg/day 4,519.2 kg/day 4,407.2 kg/day
Total 15,564.7 kg/day 17,844.7 kg/day 17,698.0 kg/day
Total Project -- 2,280.0 kg/day 2,133.3 kg/day
Moving 4,658.9 tons/year 5,356.6 tons/year 5,342.7 tons/year
Idling 1,597.8 tons/year 1,816.6 tons/year 1,771.6 tons/year
Total 6,256.7 tons/year 7,173.2 tons/year 7,114.3 tons/year
Total Project -- 916.6 tons/year 857.6 tons/year
*This scenario also includes other intersection/roadway improvements.

1
Ewing, R. “TDM, Growth Management, and the Other Four Out of Five Trips,” Transportation Quarterly, Vol. 47, No. 3, 1993, pp.
343-366.

Waltham High School | Final Environmental Impact Report 4 | p. 18

Adaptation and 5
Resiliency
5.1 Regulatory Basis of Design
5.2 Climate Change and Stormwater Management
5.3 Resiliency in Design
Adaptation and Resiliency
5.1 Regulatory Basis of Design
The Project is designed to comply with the Massachusetts Department of Environmental Protection Stormwater
regulations, which are the governing regulations for stormwater management design. The Stormwater Handbook
integrates hydrologic data into its standards through treatment, infiltration, scour protection, and storage
requirements. For example, treatment Best Management Practice (BMP) are generally required to be sized to
treat a water quality volume of 1" over the contributing impervious area directed toward that BMP. The
stormwater management design will use criteria such as these to size BMPs, and because these criteria are
based on historical rainfall data and conservative storm events, the system will be resilient to minor increases or
decreases in temperature or precipitation over its operational lifetime.

5.2 Climate Changes and Stormwater Management

For Massachusetts-specific climate change data, the Massachusetts Climate Change Clearinghouse (Resilient
MA) developed by the Northeast Climate Adaptation Science Center (NECASC) is referenced herein. Resilient
MA provides climate change projections based on fourteen models from the Coupled Model Intercomparison
Project Phase 5 (CIMP5) and use two future greenhouse gas emissions pathways: RCP4.5 and RCP8.5 (the
medium and high emissions scenarios, respectively). The median values presented here are therefore a center
point of some of the best publicly available models but are not intended to be forecasts.

Resilient MA models for the Charles River Basin predict a median increase of 3.8" in total annual precipitation by
the end of the 21st century above the 30-year mean of approximately 48" in 2000. The models also predict a
median increase of 1.4 days with at least 1" of precipitation over the same time period above the 30-year mean
of 8 days. This means there may be one or two more rainfall events per year which meet or exceed the 1” water
quality treatment volume for which some BMPs are sized according to the Handbook (and the remaining
precipitation events will be smaller storms). Additionally, winter precipitation is expected to be the largest
contributor to the annual increase in precipitation. Due to increases in temperature, more of the winter
precipitation is expected to be rain or freezing rain rather than snow. There is no discernable change in
consecutive dry days seasonally or annually, so the Handbook regulation requiring drawdown of infiltration
basins within 72 hours is likely to still be effective. The most significant change predicted by the models appears
to be the increases in temperature; annual average temperatures statewide are expected to increase between 4-
11°F. While this will have serious implications for agriculture, there are no current stormwater regulations which
would be made outdated as a result of the changes.

5.3 Resiliency in Design

Stormwater management systems can be made more resilient by disconnecting impervious areas, incorporating
Low Impact Design (“LID”) BMPs, and providing redundant treatment trains where rational. The Project includes
several LID BMPs which are designed to slow, settle, treat, and store stormwater, often treating in excess of the
required water quality volume. Several LID BMPs are linked sequentially, increasing the residence time of
stormwater, and providing redundant methods of treatment and maximum peak flow attenuation.

The design also separates groundwater and “clean” runoff (i.e. roof, field, or woodland runoff) from stormwater
which requires treatment. This reduces the size of the BMPs required and reduces the likelihood of the treatment
BMPs to be operating past capacity. Separating stormwater flows also helps with peak flow attenuation; sending
clean runoff off the site before the treated stormwater is discharged reduces the peak flowrate exiting the site.

5 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 5: Adaptation and Resilience

The closed drainage system is designed to convey the 25-year storm (i.e. a storm that has a 4% chance of
occurring any given year). This is the City of Waltham regulation and an industry standard; oversizing the pipe
system beyond this point is considered unnecessary and costly. Basins are designed to safely discharge the
100-year storm event through either broad berms or piped culverts.

Storm events such as a 100-year storm are infrequent, unlikely (1% chance of occurring in any year), and
resistant to change. That is, changes in annual precipitation are not the same as changes to a 100-year storm
event. It will take consistent increased annual precipitation for an extended period of time to change the 100-
year storm event – and even then, it may not be a statistically significant change within the hydrologic model.
The most appropriate approach at this time is to design the stormwater management system to meet or exceed
MA Stormwater regulations, disconnect as much impervious area as practical, maximize the use of LID BMPs,
and design basins to safely handle and discharge a 100-year storm event.

The proposed groundwater management system will be designed to account for the future change in
precipitation by accounting for a possible rise in groundwater elevation and increase in surface water and
groundwater flow rates. The system will be designed based on a groundwater elevation two feet higher than the
current estimated seasonal high groundwater elevation. In addition, once the groundwater flow rate across the
site has been evaluated, the design of groundwater management system components including piping, pumps,
etc. will be evaluated to for feasibility to increase flow based on the anticipated increase in precipitation. Based
on the design considerations above, it is expected that the additional rainfall would continue to be captured and
conveyed in the drainage system as intended.

Waltham High School | Final Environmental Impact Report 5 | p. 2

Construction Period 6
6.1 Construction Period and Hours
6.2 Dust and Noise Mitigation
6.3 Pre-Blast Condition Survey
6.3 Massachusetts Idling Policy
Attachments
6.1 Regulation 9 Dust and Odor
6.2 OSHA Silica Exposure Control
Figures
6.1 Draft 500-foot Blast Radius
Construction Period
6.1 Construction Period and Hours
As noted in section 10.1.1 of the NPC/DEIR, the construction period for the Project is approximately 4
years and is broken into various sequences of work based upon design documentation schedule, permits
and approvals.

Construction activity will occur between 7:00 AM and 5:00 PM weekdays and 8:00 AM to 4:00 PM on
Saturdays, consistent with the City’s noise ordinance. Extended work hours, Sundays and Holidays are not
permitted without prior approval of the City of Waltham.
• Blasting will occur between 8:00 AM to 4:00PM weekdays. No blasting will occur on Saturdays,
Sundays or Holidays.

The duration of the blasting operations were noted in the NPC/DEIR as approximately 12 months, but it did
not say or mean that blasting would be continuous for 12 months as mentioned in the DEIR Certificate. It is
expected that on average there will be one to three blasting events per day, followed by rock removal.
• Depending on the site construction progress and excavation sequencing, between one (1) and three (3)
blasts may be conducted per day on days when blasting is performed. Note: No explosives will remain
on site overnight.

If the daily hours of construction were to be reduced, it would result in the overall schedule extending, over
more days, longer durations for blasting activities, longer durations for construction activities and traffic,
additional costs to the Project but most importantly, it would delay the proposed start time for the 1,830
students of Waltham planning to attend in 2024.

6.2 Dust and Noise Mitigation

As described in sections 10.1.4 and 10.1.5 of the NPC/DEIR, noise and dust activities will be monitored
regularly. The Project involves construction of a new high school and, in general, construction occurs
between 7:00 AM and 5:00 PM weekdays and 8:00 AM to 4:00 PM on Saturdays.

Consigli as the Construction Manager (CM) will comply with and require all subcontractors to comply with
Regulations for the Control of Air Pollution: Regulation 9 Dust and Odor issued by the Department of Public
Health, Division of Environmental Health Bureau of Air Quality Control.

The CM plans to use water misters, water trucks, and automatic wheel wash stations to minimize dust.
Methods for controlling silica dust exposure will be in compliance with OSHA Section 1926.1153 Table 1
(attached). The CM’s Site Specific Safety Plan includes that any activity which can produce silica dust will
use engineering controls to keep dust to a minimum. There will be no dry cutting of any masonry material
allowed; if water cannot be used then a dustless vacuum system consisting of a HEPA dustless vacuum
system shall be used.

Finally, the CM plans to use sound blankets at the perimeter fence strategically placed to mitigate noise to
the adjacent neighbors.

Blasting Noise: The actual noise from blasting is during shot hole drilling which is similar to typical
construction site noise, with occasional louder but very short duration peaks at the immediate moment of

6 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 6: Construction Period

blast shot ignition. Technical provisions for Controlled Blasting will require the Contractor to comply with
the rules and regulations of the Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire
Prevention Regulations for Explosives and City of Waltham Fire Department (WFD) Regulations. On site
rock crushing will be mitigated with earth berms or other sound barriers. Per City of Waltham, double
matting will be utilized during all blasting operations to mitigate debris, dust and noise.

The anticipated bedrock conditions are such that a portion of the upper “fractured” surface of the bedrock
can likely be excavated with conventional excavation equipment rather than controlled blasting. However,
the majority of the bedrock excavation for the project is anticipated to require controlled blasting in
benches or lifts to achieve design subgrades. Perimeter control blasting methods at the limit of excavation
and limited hoe ramming may be required to achieve subgrade level.

A proactive approach by the Project will be implemented to ensure that rock blasting is conducted safely
to minimize harm and injury to persons and that damage to surrounding property does not result from blast
vibrations, air blast overpressures, or flyrock. Rock blasting controls will include:
• Pre-Blast Condition Surveys - Pre-Blast surveys will be offered for each of the residential buildings
within 500 feet of blast locations.
• Blasting Plan Review - Blasting subcontractor’s blasting plan will be reviewed by Haley & Aldrich, and
will list and describe specific technical measures and approaches to control damage and minimize
adverse effects including ground vibrations, air blast overpressures and flyrock.
• Test Blast Program - A test blast program will be conducted to assess the Site geology and
surrounding building responses to the Test Blast, and to develop Site Propagation Data (i.e., scaled
distance relationship) from which the Project can extrapolate and predict with reasonable certainty
vibration levels generated by the blasting at and surrounding the Site.
• Blasting Limit Criteria - Following successful completion of the Test Blast, production blasting shall be
designed and conducted so that the effects of ground vibrations do not exceed the U.S. Bureau of
Mines allowable vibration limits as specified in 527 CMR 13.09(1)(l)(9)(b)(Option2, Figure a) and air
overblast pressures do not exceed the limits of 527 CMR 13.09(1)(l)(9)(b).
• Flyrock Control - To mitigate the potential for flyrock, two layers of blasting mats (“double matting”) will
be required for all blasts detonated at the Site.
• Perimeter Control Drilling - Line drilling, presplitting and/or cushion blasting will be required at rock
slope limits of excavations to reduce overbreak of the rock to remain and to reduce vibrations.
• Vibration and Air Blast Monitoring - Ground vibrations and air blast overpressure measurements will be
monitored at several points surrounding the blast area, including the closest buildings, using portable
engineering seismographs, during periods when hoe ramming and blasting activities are planned.
These data are reviewed daily following individual blast events, and adjustments or modifications to
improve successive blasts are incorporated, as warranted.

Building Noise: The project team has continued to advance the design of the building and the noise
generating equipment on the building. The project acoustician, Acentech, has reviewed the equipment
selections and worked with the project team. Their progress report is attached in Appendix 6.2 of the FEIR.
Sound levels are based upon three periods with a 24-hour day in coordination with the Director of Facilities
and how the building roof top equipment would be operated.
1. Daytime - 6.00am to 6.00pm
2. Evening – 6.00pm to midnight
3. Nighttime – midnight to 6.00am

Waltham High School | Final Environmental Impact Report 6 | p. 2

 Section 6: Construction Period

Using these timeframes and measuring against the background noise measurements conducted in July
2019, Acentech is recommending additional noise mitigation be incorporated on a number of rooftop units
to achieve compliance with the Waltham Noise Ordinance and Massachusetts DEP. These additional
measures will be incorporated into the project scope.

Complaints for dust and noise should be addressed to the Police Department.

6.3 Pre-Blast Condition Survey

The project team is still evaluating the extent of the proposed blasting on the site and has not finalized the
500-foot blast radius map at this time. Figure 6.1 below drafted by Haley & Aldridge geotechnical
engineers is being refined. This draft was presented at the SBC Meeting on August 10, 2020. Once
finalized it will be posted on the project website, reviewed publicly at the SBC meeting and shared with
those within the 500-foot radius via mail.

Figure 6.1 Draft 500-foot Blast Radius

Waltham High School | Final Environmental Impact Report 6 | p. 3

 Section 6: Construction Period

As noted in section 10.1.5 of the NPC/DEIR, blasting notification will occur in accordance with 527 CMR
13.09, with pre-blast condition surveys intended to commence by the beginning of November 2020 or
sooner and be completed within a 4 to 6 week timeframe.

The intent of a pre-blast survey is to provide documentation of the existing physical condition of buildings
and structures within the blasting area with the dimensions of each observed defect clearly documented.
When blasting within 500 feet of a structure, as measured from the closest borehole to the structure, or
structures not owned or controlled by the Project, a pre-blast condition survey will be offered free of
charge to the structures’ owner. The Construction Manager is hiring a third-party company to conduct the
pre-blast condition surveys. This initial contact is typically performed via conventional mail and if contact
is unsuccessful, certified mail will be utilized.
1. The pre-blast survey will document the existing visual conditions of the interior and exterior of the
structure including improvements to the property and other physical factors that could reasonably be
affected by the blasting. Structures such as pipelines, cables, transmission lines, cisterns, wells, and
other water systems warrant special attention; however, the assessment of these structures may be
limited to observations of readily visible surface conditions and other readily available data.
2. The survey will accurately record existing deficiencies, crack, or flaws by means of written notes,
sketches, photographs, video, taped narrative or any other format or combination that sufficiently
depicts the pre-existing conditions prior to the blasting.
3. If a property owner refuses the pre-blast survey, the inspector will request that he or she sign a waiver.
A pre-blast survey waiver will be made on a form approved by the Fire Marshal. If the owner or
occupant refuses to sign a waiver, the inspector will sign the waiver attesting to the refusal. The receipt
of said waiver is subsequently recorded by an authorized representative from the City of Waltham Fire
Department.
4. Three attempts will be made to contact the owner to offer the survey. If no response is made after the
second attempt, or the owner refuses to sign a survey waiver, a notice offering the survey will be sent
via any carrier capable of providing a receipt of delivery. A receipt of delivery shall satisfy this
requirement.
(a) Surveys will be conducted by technicians familiar with construction methods and materials, familiar
with blasting procedures, and 527 CMR 13.00.
(b) Surveys in excess of the above may be conducted at the discretion of the City. If the owner or
occupant request surveys in excess of 527 CMR 13.09(10), the cost of the survey(s) will be paid by
the owner or occupant of the structure.
(c) Requirements for pre blast survey may be suspended if the blaster adheres to 527 CMR
13.09(9)(b), Option 1. The Project is not waiving the requirements for the survey.
(d) When a blast inspection is made, the results of that inspection may only be made available to the
head of the local fire department, the Marshal, or their designees upon request with the written
consent of the occupant of the structure. The blast inspection will be made available to the owner
of the inspected property within a reasonable time after request is made in writing.

Copies of the survey will be provided to property owners as requested. Complaints about vibration should
be addressed to the local Fire department.

Waltham High School | Final Environmental Impact Report 6 | p. 4

 Section 6: Construction Period

6.4 Massachusetts Idling Policy

As noted in Section 10.1.1 of the NPC/DEIR, state truck idling restrictions will be specified in all
subcontracts. The CM will provide, reconfigure, and maintain all traffic control signage, either directly, or
through subcontractor throughout the various phases of work.

This will be enforced on site via signage and construction management personnel and subcontractor
contractual language. Verbal warnings will be issued followed by written warnings and fines per incident.

As noted in Section 10.1.4 of the NPC/DEIR, methods that shall be used by the CM to control nuisance
odors associated with diesel emissions from construction equipment will include:
• Turning off construction equipment not in active use for 5 minutes or more.
• Locating combustion engines away from abutters; to the greatest extent possible.
• Using appropriate emissions control equipment on all equipment and on-going maintenance of
exhausts.

The CM will include the requirement for ultra-low sulfur diesel fuel and equipment retrofitted with
emissions control equipment, including emission control equipment identified in the Commonwealth’s
Clean Air Construction initiative for all subcontractors.

Waltham High School | Final Environmental Impact Report 6 | p. 5

Dust and Odor
 THE COMMONWEALTH OF MASSACHUSETTS

DEPARTMENT OF PUBLIC HEALTH

DIVISION OF ENVIRONMENTAL HEALTH

BUREAU OF AIR QUALITY CONTROL

REGULATIONS FOR THE CONTROL OF AIR POLLUTION

REGULATION 9 . DUST AND ODOR

REGULATION 9. Dust and Odor

9.1 No person having control of any dust or odor generating operations such as, but not
limited to asphalt batching plants, asphalt roofing materials manufacturing plants,
asphalt blowing plants, foundries, chemical products manufacturing plants,
incinerators, fuel utilization facilities, petroleum products manufacturing plants,
aggregate manufacturing plants, food preparation or processing facilities, wood
products plants, dry cleaning establishments, paint and varnish manufacturing plants,
paper manufacturing plants, leather manufacturing plants, concrete batching plants,
metal coating and treating plants, land clearing operations, construction work, dump
operations, building demolition and agricultural operations shall permit emissions
therefrom which cause or contribute to a condition of air pollution.

9.2 No person shall cause, suffer, allow, or permit the handling or transportation or
storage of any material in a manner that results or may result in emissions therefrom
which cause or contribute to a condition of air pollution.

9.3 No person shall cause, suffer, allow, or permit a building, road, driveway, or open
area to be constructed, used, repaired, or demolished without applying such
reasonable measures as may be necessary to prevent particulate matter from becoming
air-borne that may cause or contribute to a condition of air pollution.

9.4 U No person shall cause, suffer, allow, or permit the operation of mechanized street
sweeping equipment that is not equipped with a suitable dust collection or dust
suppression system which is maintained in good operating condition and is
operated continuously while the street sweeping equipment is in use to prevent
conditions of air pollution.

9.5 U Regulation 9.1, 9.2, 9.3, and 9.4 are subject to the enforcement provisions
specified in Regulation 52.1.

Control of Air Pollution Regulation 9. Page - 1

OSHA Silica Exposure Control
Table
 §1926.1153 Respirable crystalline silica.

(c) Specified exposure control methods. (1) For each employee engaged in a task identified on Table 1, the employer shall fully and properly implement
the engineering controls, work practices, and respiratory protection specified for the task on Table 1, unless the employer assesses and limits the exposure
of the employee to respirable crystalline silica in accordance with paragraph (d) of this section.

Table 1: Specified Exposure Control Methods When Working With Materials Containing Crystalline Silica

Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(i) Stationary masonry Use saw equipped with integrated water delivery system that None None
saws continuously feeds water to the blade.

Operate and maintain tool in accordance with manufacturer’s

instructions to minimize dust emissions.
(ii) Handheld power Use saw equipped with integrated water delivery system that
saws (any blade continuously feeds water to the blade.
diameter)
Operate and maintain tool in accordance with manufacturer’s
instructions to minimize dust emissions.

− When used outdoors. None APF 10

− When used indoors or in an enclosed area. APF 10 APF 10

 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(iii) Handheld power For tasks performed outdoors only:
saws for cutting fiber-
cement board (with Use saw equipped with commercially available dust None None
blade diameter of 8 collection system.
inches or less)
Operate and maintain tool in accordance with manufacturer's
instructions to minimize dust emissions.

Dust collector must provide the air flow recommended by the

tool manufacturer, or greater, and have a filter with 99% or
greater efficiency.
(iv) Walk-behind saws Use saw equipped with integrated water delivery system that
continuously feeds water to the blade.

Operate and maintain tool in accordance with manufacturer's

instructions to minimize dust emissions.

− When used outdoors. None None

− When used indoors or in an enclosed area. APF 10 APF 10

(v) Drivable saws For tasks performed outdoors only:

Use saw equipped with integrated water delivery system that None None
continuously feeds water to the blade.

Operate and maintain tool in accordance with manufacturer's

instructions to minimize dust emissions.
 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(vi) Rig-mounted core Use tool equipped with integrated water delivery system that None None
saws or drills supplies water to cutting surface.

Operate and maintain tool in accordance with manufacturer's

instructions to minimize dust emissions.
(vii) Handheld and Use drill equipped with commercially available shroud or None None
stand-mounted drills cowling with dust collection system.
(including impact and
rotary hammer drills) Operate and maintain tool in accordance with manufacturer's
instructions to minimize dust emissions.

Dust collector must provide the air flow recommended by the

tool manufacturer, or greater, and have a filter with 99% or
greater efficiency and a filter-cleaning mechanism.

Use a HEPA-filtered vacuum when cleaning holes.

(viii) Dowel drilling For tasks performed outdoors only:
rigs for concrete
Use shroud around drill bit with a dust collection system. Dust APF 10 APF 10
collector must have a filter with 99% or greater efficiency and a
filter-cleaning mechanism.

Use a HEPA-filtered vacuum when cleaning holes.

(ix) Vehicle-mounted Use dust collection system with close capture hood or shroud None None
drilling rigs for rock around drill bit with a low-flow water spray to wet the dust at the
and concrete discharge point from the dust collector.

OR

Operate from within an enclosed cab and use water for dust None None
suppression on drill bit.
 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(x) Jackhammers and Use tool with water delivery system that supplies a continuous
handheld powered stream or spray of water at the point of impact.
chipping tools
− When used outdoors. None APF 10

− When used indoors or in an enclosed area. APF 10 APF 10

OR

Use tool equipped with commercially available shroud and dust

collection system.

Operate and maintain tool in accordance with manufacturer's

instructions to minimize dust emissions.

Dust collector must provide the air flow recommended by the

tool manufacturer, or greater, and have a filter with 99% or
greater efficiency and a filter-cleaning mechanism.

− When used outdoors. None APF 10

APF 10 APF 10
− When used indoors or in an enclosed area.
(xi) Handheld grinders Use grinder equipped with commercially available shroud and dust APF 10 APF 25
for mortar removal (i.e., collection system.
tuckpointing)
Operate and maintain tool in accordance with manufacturer's
instructions to minimize dust emissions.

Dust collector must provide 25 cubic feet per minute (cfm) or

greater of airflow per inch of wheel diameter and have a filter
with 99% or greater efficiency and a cyclonic pre-separator or
filter-cleaning mechanism.
 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(xii) Handheld grinders For tasks performed outdoors only:
for uses other than
mortar removal Use grinder equipped with integrated water delivery system that None None
continuously feeds water to the grinding surface.

Operate and maintain tool in accordance with manufacturer’s

instructions to minimize dust emissions.

OR

Use grinder equipped with commercially available shroud and

dust collection system.

Operate and maintain tool in accordance with manufacturer’s

instructions to minimize dust emissions.

Dust collector must provide 25 cubic feet per minute (cfm) or

greater of airflow per inch of wheel diameter and have a filter
with 99% or greater efficiency and a cyclonic pre-separator or
filter-cleaning mechanism.

− When used outdoors. None None

− When used indoors or in an enclosed area. None APF 10

 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(xiii) Walk-behind Use machine equipped with integrated water delivery system None None
milling machines and that continuously feeds water to the cutting surface.
floor grinders
Operate and maintain tool in accordance with manufacturer's
instructions to minimize dust emissions.

OR

Use machine equipped with dust collection system recommended None None
by the manufacturer.

Operate and maintain tool in accordance with manufacturer's

instructions to minimize dust emissions.

Dust collector must provide the air flow recommended by the

manufacturer, or greater, and have a filter with 99% or greater
efficiency and a filter-cleaning mechanism.

When used indoors or in an enclosed area, use a HEPA-filtered

vacuum to remove loose dust in between passes.

(xiv) Small drivable Use a machine equipped with supplemental water sprays designed None None
milling machines (less to suppress dust.
than half-lane) Water must be combined with a surfactant.

Operate and maintain machine to minimize dust emissions.

 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(xv) Large drivable For cuts of any depth on asphalt only:
milling machines
(half-lane and larger) Use machine equipped with exhaust ventilation on drum None None
enclosure and supplemental water sprays designed to
suppress dust.

Operate and maintain machine to minimize dust emissions.

For cuts of four inches in depth or less on any substrate:

Use machine equipped with exhaust ventilation on drum None None

enclosure and supplemental water sprays designed to
suppress dust.

Operate and maintain machine to minimize dust emissions.

OR

Use a machine equipped with supplemental water spray designed None None
to suppress dust.
Water must be combined with a surfactant.

Operate and maintain machine to minimize dust emissions.

(xvi) Crushing Use equipment designed to deliver water spray or mist for dust None None
machines suppression at crusher and other points where dust is generated
(e.g., hoppers, conveyers, sieves/sizing or vibrating components,
and discharge points).

Operate and maintain machine in accordance with manufacturer’s

instructions to minimize dust emissions.

Use a ventilated booth that provides fresh, climate-controlled air

to the operator, or a remote control station.
 Equipment / Task Engineering and Work Practice Control Methods Required Respiratory Protection and
Minimum Assigned Protection Factor (APF)
≤ 4 hours /shift > 4 hours /shift
(xvii) Heavy Operate equipment from within an enclosed cab. None None
equipment and utility
vehicles used to abrade When employees outside of the cab are engaged in the task, apply None None
or fracture silica- water and/or dust suppressants as necessary to minimize dust
containing materials emissions.
(e.g., hoe-ramming,
rock ripping) or used
during demolition
activities involving
silica-containing
materials
(xviii) Heavy equipment Apply water and/or dust suppressants as necessary to None None
and utility vehicles for minimize dust emissions.
tasks such as grading
and excavating but not OR
including: demolishing,
abrading, or fracturing When the equipment operator is the only employee engaged in None None
silica- containing the task, operate equipment from within an enclosed cab.
materials

(2) When implementing the control measures specified in Table 1, each employer shall:
(i) For tasks performed indoors or in enclosed areas, provide a means of exhaust as needed to minimize the accumulation of visible airborne dust;
(ii) For tasks performed using wet methods, apply water at flow rates sufficient to minimize release of visible dust;
(iii) For measures implemented that include an enclosed cab or booth, ensure that the enclosed cab or booth:
(A) Is maintained as free as practicable from settled dust;
(B) Has door seals and closing mechanisms that work properly;
(C) Has gaskets and seals that are in good condition and working properly;
(D) Is under positive pressure maintained through continuous delivery of fresh air;
(E) Has intake air that is filtered through a filter that is 95% efficient in the 0.3-10.0 μm range (e.g., MERV-16 or better); and
(F) Has heating and cooling capabilities.
(3) Where an employee performs more than one task on Table 1 during the course of a shift, and the total duration of all tasks combined is more than
four hours, the required respiratory protection for each task is the respiratory protection specified for more than four hours per shift. If the total
duration of all tasks on Table 1 combined is less than four hours, the required respiratory protection for each task is the respiratory protection
specified for less than four hours per shift.
Mitigation and Draft 7
Section 61 Findings
7.1 Mitigation Measures
7.1.1 Wetlands
7.1.2 Construction Traffic and Truck Routes
7.1.3 Traffic
7.1.4 Stormwater
7.1.5 Wastewater
7.1.6 Water
7.1.7 Noise Quality
7.1.8 Air Quality
7.1.9 Demolition and Hazardous Materials
7.1.10 Historical and Archaeological Resources
7.1.11 Greenhouse Gas Emissions
7.1.12 Adaptation and Resiliency
7.1.13 General Construction Measures
7.2 Draft Section 61 Findings
7.2.1 Contents of Section 61 Findings
7.2.2 Section 61 Findings and Agency Action
Tables
7.1 Summary of Mitigation Measures, Responsible Party and
Cost
Figures
7.1 Construction Vehicle Traffic Plan
Mitigation and Draft Section 61 Findings
7.1 Mitigation Measures
7.1.1 Wetlands
As described in Section 12.1.1 of the NPC/DEIR, the Project has no direct impact on Bordering Vegetated
Wetland (“BVW”) or other wetland Resource Areas and does not require stream relocation. The Project will
restore the approximately 0.4 acres of previously damaged bank and BVW and includes minor work within the
Buffer Zone. All work proposed within the Buffer Zone of the resource areas will be included in the future Notice
of Intent filing and will be reviewed in accordance with the Massachusetts Wetlands Protection Act.

The Project will be filing a Stormwater Pollution Prevention Plan (SWPPP) in accordance with the permitting
requirements of the U. S. Environmental Protection Agency (U.S. EPA) for the National Pollutants Discharge
Elimination System (NPDES). Development, implementation, and maintenance of the SWPPP will provide the
Contractor with the framework for reducing soil erosion and minimizing pollutants in storm water during
construction.

7.1.2 Construction Traffic and Truck Routes

As described in Section 12.1.2 of the NPC/DEIR, truck traffic will vary throughout the construction period
depending on the various phases of construction.

The project commits to truck access to and from the project site and will be generally limited to Lexington Street
via Totten Pond Road from Route 95 so as to avoid smaller roads. This commitment will be implemented by
including the truck route in all contracts and subcontracts. To the greatest extent possible, all construction traffic
and deliveries will be coordinated to avoid peak commuter rush hours and adjacent school drop off and pick up
times.

Figure 7.1 Construction Vehicle Traffic Plan

6 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 7: Mitigation and Draft Section 61 Findings

7.1.3 Traffic
As described in Section 12.1.3 of the NPC/DEIR, the design includes a new signal in Lexington Street which
includes adaptive signal control technology which will be implemented and sequenced with previous and
subsequent traffic lights along Lexington Street.

A new designated left turn lane will be striped within the existing public street and a shared bike lane will be
incorporated into the northern lane to mitigate the elimination of the dedicated bike lane.

New Crosswalks will be provided for pedestrian safety at the new signals.

7.1.4 Stormwater
As described in Section 12.1.4 of the NPC/DEIR, the Project will comply with the Massachusetts Stormwater
Management Standards 1, 2, 4, 5, 8, 9 and 10 fully, and Standards 3 and 7 to the maximum extent practicable;
Standard 6 does not apply. The site is designed to maximize groundwater recharge to the extent possible.
Stormwater will be collected and treated using a combination of LID and proprietary treatment BMPs.

Refer to Section 5 of the NPC/DEIR and 3.2 of the FEIR for more detailed discussion on stormwater
management.

7.1.5 Wastewater
The Project will result in a net increase of 39,594 gallons per day (gpd) in wastewater generation and
reflects both the proposed high school and the future development at 617 Lexington Street. The required
I&I inflow mitigation is 4:1 or 158,376 gallons and will be deducted from the City’s sewer bank. The project
will also include replacement of approximatley 375 linear feet of sewer within Stanley Road.

7.1.6 Water
The Project will result in a net increase of 43,560 gallons per day (gpd) in water use when using the City
Ordinance in calculating the flows. The increase in water supply reflects both the proposed high school and
the future development at 617 Lexington Street. The City’s Engineering Department has reviewed this
increase and confirmed there is adequate capacity in the existing infrastructure. The Project also includes
replacement of approximatley 4,900 linear feet of water main within Lexington Street.

7.1.7 Noise Quality

As described in Section 12.1.7 of the NPC/DEIR, an acoustician is reviewing the project and will recommend
appropriate acoustical mitigation measures for both construction noise and for the final project noise generating
equipment. The project will meet the Commonwealth of Massachusetts Department of Environmental Protection
(DEP) Noise Control Regulation 310 CMR 7.10. as well as the City of Waltham’s Noise Ordinance.

The Construction Manager (CM) will use sound blankets at the perimeter fence strategically placed to mitigate
noise to the adjacent neighbors. The actual noise from the blasting during shot hole drilling is similar to typical
construction site noise, with occasional louder but very short duration peaks at the immediate moment of blast
shot ignition. Technical provisions for Controlled Blasting will require the Contractor to comply with the rules and
regulations of the Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for
Explosives and City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with
earth berms or other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to
mitigate debris, dust and noise. Finally, Consigli plans to use sound blankets at the perimeter fence strategically
placed to mitigate noise to the adjacent neighbors.

Waltham High School | Final Environmental Impact Report 7 | p. 2

 Section 7: Mitigation and Draft Section 61 Findings

The Project’s commitment to sound mitigation program includes building design, equipment controls and
orientation, ductwork design and configuration, roof top mounted equipment and attenuation. The design team
commits to continue to work closely with the acoustician as the design progresses to further mitigate noise
impacts. Refer to Section 10 of the NPC/DEIR for more detailed discussion on noise mitigation and measures.

7.1.8 Air Quality

As described in Section 12.1.8 of the NPC/DEIR, construction activities will potentially generate fugitive dust,
which could result in localized increase in airborne particulate levels. Fugitive emissions from construction
activities will depend upon a multitude of factors such as ambient humidity, recent weather patterns, and phase
of construction. The Project will endeavor to maintain as much of the existing paved areas as long as possible to
facilitate managing dust, erosion, and stormwater runoff through existing protected structures.
• Dust will be mitigated though a variety of mechanisms such as wetting agents, gravel tracking pads, wheel
cleaning, street cleaning, dumpster control and soil stabilization.
• Asbestos fibers will be mitigated through the use of negative air machines, HEPA filters and containments
and other measures so as to comply with DEP’s Asbestos regulations. Clean air test will be performed and
confirmed by an independent Industrial Hygienist before containments can be removed.
• Odors will be mitigated by covering stockpiles (beyond short time storage), maintaining a trash free site,
turning off construction equipment not in active use for 5 minutes or more.
• The CM will include the requirement for ultra-low sulfur diesel fuel and equipment retrofitted with emissions
control equipment, including emission control equipment identified in the Commonwealth’s Clean Air
Construction initiative for all subcontractors.
These measures are further defined within Section 10 of the NPC/DEIR.

7.1.9 Demolition and Hazardous Materials

As described in Section 12.1.9 of the NPC/DEIR, the Project includes the abatement of hazardous materials from
the existing buildings prior to demolition. Air monitoring during hazardous materials abatement will be conducted
in accordance with OSHA requirements and removal and disposal of hazardous materials will be managed in
accordance with DEP regulations.

7.1.10 Historical and Archaeological Resources

As described in Section 12.1.10 of the NPC/DEIR, the Project has been cleared of historic preservation review
locally and with the Massachusetts Historical Commission (MHC). MHC referenced in their NPC/DEIR comment
letter a Waltham Historic Commission concern regarding removal of stone walls within the Jericho Hill Parcel II.
There are no stone walls within the 6–acre parcel. Refer to the existing conditions plan C101. Stone walls for the
boundary (property line) between Jericho Hill Parcel II and Sanderson Heights will remain.

7.1.11 Greenhouse Gas Emissions

As described in Section 12.1.11 of the NPC/DEIR and Section 4 of the FEIR, the proposed design and energy
performance measures and their impact on reducing predicted GHG emissions in accordance with the MEPA
GHG Policy are detailed in Section 4 of the NPC/DEIR. The GHG Policy requires a GHG emissions analysis to
demonstrate the Project’s strategies to avoid, minimize, or mitigate such emissions for projects undergoing an
EIR MEPA review. The New Waltham High School GHG emissions analysis quantifies the proposed energy
performance strategies in terms of energy savings and GHG emissions reductions.

The Project has committed to exceed energy efficiency requirements of the Building Code by at least 20% rather
than the 10% required by the MSBA and Stretch Energy Code. The Project is pursuing LEED Silver Certification,
specific features included in the Project are high-efficiency air cooled chiller, high-efficiency condensing boiler,
high-efficiency domestic water heaters, high performance building envelope with increased wall and roof

Waltham High School | Final Environmental Impact Report 7 | p. 3

 Section 7: Mitigation and Draft Section 61 Findings

insulation and improved glazing, energy efficiency interior and exterior lighting and a solar photovoltaic (PV)
ready roof and PV canopy ready parking area.

The Project will provide a self-certification to the MEPA Office indicating that all the required mitigation
measures, or their equivalent have been completed.

The following GHG emissions reduction measures are included in the project, as provided in the NPC/DEIR. No
additional mitigation where added for the FEIR.
• High Performance Building Enclosure:
o R-50 Roof
o R-28.5 Walls
o U-0.32 Glazing System (SHGC 0.27)
o Triple Glazing Systems (Add Alternative)
o Window to Wall Ratio- 25-30% goal
o Exterior Shading Devices
o Light colored Reflective Roof
o Solar PV readiness (40% min, compliant with the MA Energy Code)
• Whole Building Air Infiltration Testing included in the project scope and budget.
• High efficiency Lighting Systems:
o Light Power Density Reduction (LPD)
o Vacancy and Daylight controls
o Advanced Digital network Controls
o All LED Exterior Lighting
• High Efficiency transformers.
• Energy Star rated Appliances and Equipment.
• High Efficiency Mechanical Systems (HVAC):
o Condensing Natural Gas boilers
o Variable frequency Drives (VFDs) on pumps
o DOAS ventilation with Heat Recovery
o High-Performance air-cooled chiller
o Demand Control Ventilation
o Energy Management System (EMS) and Controls
o High Efficiency Domestic Hot Water (DHW)
o Kitchen Hood Controls
• Enhanced Commissioning for Mechanical, Electrical, Plumbing and Building Enclosure systems.
• High performance Elevators.
• Green vegetated Roof.
• Optimized Daylighting and access to views.

Waltham High School | Final Environmental Impact Report 7 | p. 4

 Section 7: Mitigation and Draft Section 61 Findings

7.1.12 Adaptation and Resiliency

As described in Section 12.1.12 of the NPC/DEIR, the City of Waltham is a participant in the Commonwealth’s
Municipal Vulnerability (MVP) program.

The Project includes strategies that will support climate change adaptiveness and resiliency such as reduced
heat island effect, stormwater management strategies, high performance building systems, PV and EV
readiness, inclusion of an emergency generator. These measures are further defined within Section 9 of the
NPC/DEIR.

7.1.13 General Construction Measures

As described in Section 12.1.13 of the NPC/DEIR, the Construction Manager will be responsible for traffic
management, dust control, noise control, erosion and sedimentation control, vibration monitoring, site safety
and security as described in Section 10 of the NPC/DEIR.

7.2 Draft Section 61 Findings

7.2.1 Contents of Section 61 Findings
In all cases, each Agency shall base its Section 61 Findings on the EIR and shall specify in detail: all feasible
measures to be taken by the Proponent or any other Agency or Person to avoid Damage to the Environment or,
to the extent Damage to the Environment cannot be avoided, to minimize and mitigate Damage to the
Environment to the maximum extent practicable; an Agency or Person responsible for funding and implementing
mitigation measures, if not the Proponent; and the anticipated implementation schedule that will ensure that
mitigation measures shall be implemented prior to or when appropriate in relation to environmental impacts.

7.2.2 Section 61 Findings and Agency Action

Provided that mitigation measures are specified as conditions to or restrictions on the Agency Action, the
Agency shall:
1. Make its Section 61 Findings part of the Permit, contract or other document allowing or approving the
Agency Action, which may include additional conditions to or restrictions on the Project in accordance with
other applicable statutes and regulations.
or
2. Refer in its Section 61 Findings to applicable sections of the relevant Permit, contract or other document
approving or allowing the Agency Action.

State Agencies that will be required to make Section 61 Findings prior to issuing permits for the Project are the
DEP and the MSBA.

Table 7.1 has been prepared for the consideration of those agencies in issuing their Section 61 Findings.

Waltham High School | Final Environmental Impact Report 7 | p. 5

 Section 7: Mitigation and Draft Section 61 Findings

Proposed Section 61 Findings

Finding Pursuant to
M.G.L. Chapter 30, Section 61

Project Name: Waltham High School

Project Location: 554 Lexington Street, Waltham, MA 02451

Project Proponent: City of Waltham

EoEA Number: 16097

Date DEIR Noticed in Monitor May 20, 2020

Date FEIR Noticed in Monitor

Permit:

The potential environmental impacts of the Project have been characterized and quantified in the ENF and EIR,
which are incorporated by reference into this Section 61 Finding. Throughout the planning and environmental
review process, the Proponent, The City of Waltham has been working to develop measures to mitigate
significant impacts of the Project. With the mitigation proposed and carried out in cooperation with state
agencies, the [Agency] finds that there are no significant unmitigated impacts.

The Proponent recognizes that the identification of effective mitigation, and implementation of that mitigation
throughout the life of the project, is central to its responsibilities under the Massachusetts Environmental Policy
Act (MEPA). The Proponent has accordingly prepared the annexed Table of Mitigation that specifies, for each
potential state permit category, the mitigation that the Proponent will provide.

Now, therefore, [Agency], having reviewed the MEPA filings for the City of Waltham, the mitigation measures
already implemented, and those further mitigation measures set forth on the annexed Table of Mitigation
Measures, finds pursuant to M.G.L. c. 30, § 61 that with the implementation of the aforesaid measures, all
practicable and feasible means and measures will have been taken to avoid or minimize potential damage from
the project to the environment.

_____________________________________

[AGENCY]

_____________________________________

By

_____________________________________

[Date]

Waltham High School | Final Environmental Impact Report 7 | p. 6

Draft Section 61 Findings
 Table 7.1
Summary of Mitigation Measures, Responsible Party and Cost
Subject Matter Impact Mitigation Responsible Party Mitigation Timing and Cost
1 Wetlands No direct impact to wetland Resource Areas. The previous site Restoration of approx. 0.4 acres of the intermittent stream filled City of Waltham - School Building The estimated cost of the wetland replication is approx.
owner's allowed fill to be placed over the presumed intermittent by the previous site Owners. Project (The "Project") $500,000 and the work will be done during construction
stream. The existing intermittent stream is interrupted by the fill Work within approx. 0.4 acres of the buffer as a result of following site preparation and blasting, in accordance with
pile, approximately 0.4 acres in size. demolition. Waltham Conservation Commission.

The existing shed and storage, and previously abandoned pool Work within approx. 0.6 acres of the buffer as a result of new
area to the east of the stream will be demolished, this work construction.
occurs within the buffer zone of the on-site wetlands.
An NOI will be filed with Waltham Conservation Commission to
A portion of the new wall and roadway will be within the buffer delineate the scope and areas, including sedimentation and
zone of the on-site wetlands. erosion control measures.

Construction SWPPP (see Stormwater) will protect against

construction impacts to water quality.

2 Construction Traffic and Truck Routes Up to 250 vehicles per day (construction workers) during peak Parking for construction workers will be on-site in temporary City of Waltham - School Building Construction traffic mitigation will be implemented at
construction period. parking lots. Project (The "Project") commencement of construction and continue through Project
Construction Manager completion. The permanent light will be installed prior to
Construction workforce will arrive in advance of the morning commencement of use of the High School building at the
Truck Routes through the City commute and depart between School end and evening latest.
commute periods.
If the permanent light is not installed prior to site clearing, a
All trucks/construction vehicles will be restricted to the temporary light or Police detail will be provided. The cost
designated truck routes with the exception of workers living in estimate for the permanent light is $350K. The cost estimate
the local area. The designated Truck route for the project is for the temporary light is $75K and the estimate for a police
Lexington Street to Totten Pond Road to Interstate 95. In the detail is $500.00 per day.
event Piety Corner reconstruction starts, the designated truck
route will be reevaluated.
Delivery rates to and from the site will vary depending on the
construction activities. During rock removal, truck trips could A temporary traffic light on Lexington Street will be installed if
include between 40-70 trips per day on average, with an needed before the permanent light is installed, or a Police detail
estimate peak over 100. to assist with traffic entering and existing the site. During
construction, all deliveries will be restricted to non-peak traffic
hours on Lexington Street as defined in Section 10 of the
NPC/DEIR.

3 Traffic Additional daily trips of approximately 1,491 after the new school Design includes a new signal in Lexington Street which includes City of Waltham - School Building The cost of the new traffic light and street markings are
is occupied. adaptive signal control technology which will be implemented Project (The "Project") included within the project construction costs. The cost of the
and sequenced with previous and subsequent traffic lights Construction Manager new light is approx. $350K.
along Lexington Street.
A new designated left turn lane will be striped within the The permanent light will be installed prior to commencement
existing public street. of use of the High School building at the latest. The left turn
A shared bike lane will be striped and incorporated into the lane and bike lane will be striped no later than May 1, 2024.
northern lane to mitigate the elimination of the dedicated bike
lane.
30 bicycle racks will be incoporated into the design.
The City of Waltham has committed to utilizing adaptive signal
control on existing signals within the Lexington Street corriror.
The City will incorporate the TMD plan as discussed in Section
4 to encourage and promote sustainable measures of
transportation.

Page 1 of 3
 Table 7.1
Summary of Mitigation Measures, Responsible Party and Cost
Subject Matter Impact Mitigation Responsible Party Mitigation Timing and Cost
4 Stormwater Existing developed area at the project site exports Design will meet DEP Stormwater Management Policy and City of Waltham - School Building Implementation of sediment and erosion control measures
approximately 13 lb./yr. of phosphorus. Wetlands Protection Act regulations and will maximize on-site Project (The "Project") during construction; and proper maintenance of stormwater
recharge to groundwater to the extent practical. The system will management facilities including periodic inspections and
be in place for construction and operation. cleaning as specified in the stormwater operations and
maintenance plan.
Biofiltration and subsurface infiltration are included in the
Project. Including these BMPs at 80% removal rates, the A general allowance of $200K has been included in the
proposed project includes approximately 15 lb./yr. of budget for erosion control and $60K for dust management
phosphorus reduction, or approximately 48% of the untreated during construction. Regular inspections and maintenance will
load. This results in a post-development export of be performed by the School Facilities Department.
approximately 16 lb./yr. of phosphorus.
The estimated costs of the stormwater management
measures are approx. $3M

5 Wastewater A projected net increase of 39,594 GPD when accounting for the Project will support removal of I/I in accordance with DEP and City of Waltham - Engineering The cost of low flow fixtures are included within the project
future use of 617 Lexington Street City policies, etc. Department construction costs. These fixtures are standard to the industry
and therefore no additional costs are defined.
Low flow fixtures are designed into the Project and have been
accounted for within the wastewater calculations. 158,367 gallons of I/I will be taken from the City's bank.

The City of Waltham has confirmed that there is adequate Cost for replacing 375 linear feet of sewer line is approx.
capacity in their Sewer Bank to account for the additional sewer $320K and will be done prior to project completion.
discharge.

City will replace 375 linear feet of sewer line in Stanley Road.

6 Water A projected net increase of 43,560 GPD when accounting for the City of Waltham current utility infrastructure supports the City of Waltham - Engineering The estimated costs of installing a new waterline from Lake
future use at 617 Lexington Street. increased usage. City will replace 4,900 linear feet of water Department Street to Totten Pond Road as requested by City Engineering
main in Lexington Street. is approx. $1.2M, and will be completed Spring through
Summer 2021.
7 Noise The Project will have roof top mechanical equipment as well as Sound attenuators will be installed for HVAC and other rooftop City of Waltham - School Building The cost for sound attenuators for the roof top mechanical
other noise generating equipment. mechanical equipment. Sound barriers will be installed around Project (The "Project") equipment and other exterior noise generating equipment
rock crushing equipment. Mechanical equipment to operate the Construction Manager (other than those exempt) is included within the project
The project will create noise during construction including rock Project will meet DEP Noise Control Regulation 310 CMR 7.10. construction costs. It is estimated at approx. 600K.
blasting and crushing.
Construction noise will comply with City of Waltham, Noise The cost for implementing construction noise mitigation
Ordinance as well as the Construction Management Plan.Noise measures in the Construction Management Plan as well as
blanketing will be used at strategic site perimeter locations. cost for sound barriers around rock crushing equipment is
included within the project construction costs.

8 Air Quality The project includes the removal of earthwork and rock by Dust control measures will minimize air borne debris and dust City of Waltham - School Building The costs associated with construction dust control are
excavation and blasting respectively. resulting from construction activities including earthwork Project (The "Project") included in the project construction costs. They are estimated
removal. Construction Manager at approx. $60K.

The project includes the removal of asbestos containing Rock removal will be in accordance with 527 CMR specifically The cost for removal of ACM is included in the project
materials (ACM). section 13. construction costs.

Containments will be establishes in accordance with OSHA and

DEP requirements to mitigate airborne fibers.

Page 2 of 3
 Table 7.1
Summary of Mitigation Measures, Responsible Party and Cost
Subject Matter Impact Mitigation Responsible Party Mitigation Timing and Cost
9 Demolition & Hazardous Materials The project includes the abatement of hazardous materials from Air monitoring during hazardous materials abatement will be City of Waltham - School Building The costs associated with containment and air monitoring
the existing buildings prior to demolition. conducted in accordance with OSHA requirements and removal Project (The "Project") during abatement are included in the project construction
and disposal in accordance with DEP requirements. Construction Manager costs. They are estimated at approx. $100K
Hazardous materials include asbestos containing materials
(ACM), Lead based paint, PCB's, Mercury containing devices,
Devices containing lithium ion batteries, Oil-containing tanks,
freon-containing appliances, fire extinguishers.

10 Historic and archaeological resources Demolition of Bertoni Hall (aka Clark House) Project filed a demolition delay permit with Waltham Historic City of Waltham - School Building The costs associated with the demolition of existing
Commission which included a one year delay which ended on Project (The "Project") structures are included in the project construction costs. They
April 8, 2020. are estimated at approx. $300K

The project received a response from Massachusetts Historic

Commission of no further MHC review required.

11 Greenhouse Gas emissions Avoid, minimize or mitigate Greenhouse gas emissions Provide a self-certification to the MEPA Office indicating that all City of Waltham - School Building The costs associated with the high performance and high
of the required GHG mitigation measures, or their equivalent, Project (The "Project") efficiency features are included in the project construction
have been completed. costs. These costs are not identified as a budget or extras
within the project budget as they are inherent within the
The project has committed to exceed energy efficiency design.
requirements of the Building Code by at least 20% rather than
the 10% required by the MSBA and Stretch Energy Code. The Self-certification to the MEPA Office that all of the required
project is pursuing LEED Silver Certification, specific features GHG mitigation measures, or their equivalent, have been
included in the project are high-efficiency air cooled chiller, high- completed will be submitted after completion of construction.
efficiency condensing boiler, high-efficiency domestic water
heaters, high performance building envelope with increased
wall and roof insulation and improved glazing, energy efficiency
interior and exterior lighting and a solar photovoltaic (PV) ready
roof.
The City will incorporate the TMD plan as discussed in Section
4 to encourage and promote sustainable measures of
transportation.

12 Adaptation and Resiliency Climate change risks can include extreme and more frequent Waltham is a participant in the Commonwealth’s Municipal City of Waltham - School Building The costs associated with the adaptation and resiliency
intense precipitation event, extreme heat waves, winter storms Vulnerability (MVP) program. Project (The "Project") measures are included in the project construction costs.
and high winds that may result in flooding, drought and/or These costs are not identified as a budget or extras within the
extended power outages. The Project includes strategies that will support climate change project budget as they are inherent within the design.
These events affect the natural and built environment that we adaptiveness and resiliency such as reduced heat island effect,
rely on for our safety, security, and well-being. stormwater management strategies to accommodate increased
storm intensity and precipitation volumes, high energy-
efficiency building systems, PV and EV readiness, inclusion of
an emergency generator.

13 General Construction Measures Site boundary is not currently fenced and is contiguous with During construction, the site shall be secured to prevent City of Waltham - School Building The estimate cost of fencing, signage, construction barriers
adjacent City property and residential properties unauthorized entry to the construction site, and to protect Project (The "Project") etc. is $530K.
existing and adjacent facilities and properties. Supplemental Construction Manager
lighting, signs, railings, and construction barriers shall be used Fencing and signage will be one of the first activities before
as necessary to provide safety to employees, construction earthwork commences.
workers, visitors and the general public during the construction
process in accordance with Occupational Safety and Health
Administration (OSHA) and other applicable regulations.

Page 3 of 3
Response to Comments 8
8.1 Secretary's Certificate
8.2 Massachusetts Water Resources Authority (MWRA)
8.3 Charles River Watershed Association (CRWA)
8.4 Massachusetts Department of Environmental Protection
(MassDEP)
8.5 Massachusetts Historical Commission (MHC)
8.6 Department of Energy Resources (DOER)
8.7 Other Comment Letters
Response to Comments
8.1 Secretary's Certificate (MEPA) Page 2

8.2 Massachusetts Water Resources Authority (MWRA) Page 16

8.3 Charles River Watershed Association (CRWA) Page 17

8.4 Massachusetts Department of Environmental Protection Page 18

(MassDEP)

8.5 Massachusetts Historical Commission (MHC) Page 19

8.6 Department of Energy Resources (DOER) Page 20

8.7 Other Comment Letters TOC Page 23

8.7.a City of Waltham universal response to Article 97 and Open Space Page 28
comments by MEPA and numerous abutters
8.7.b City of Waltham response to Robert Coleman comment letter Page 29

8 | p. 1 Waltham High School | Final Environmental Impact Report

 Section 8: Responses to Comments

8.1 Secretary's Certificate (MEPA)

MEPA 1

I expect the City will continue to evaluate and will commit to measures that will improve safety for bicyclists and
pedestrians along this corridor. These measures should be specifically identified in the FEIR and incorporated
into the draft Section 61 Findings.

The City and Traffic Engineer believe the shared bike lane is the safest approach for bicyclists along this
corridor. A portion of the route is currently shared, so it is extending a current practice. Bicycle detection will be
added to the traffic signal design to aid in activating the lights and additional signage for the bike lane will be
added along the corridor. The project is installing new crosswalks on Lexington Street at the site which will aid
pedestrian safety. The section 61 findings incorporate this scope.

MEPA 2

The NPC/DEIR did not clarify whether the other measures identified in the TIA to improve operations on the
Woodcliff Drive and Forest Street approaches, and at the Lexington Street/Lake Street/Bishops Forest Drive and
Lexington Street/Existing School Exit Only Driveway intersections will be implemented as part of this project. This
should be clarified in the FEIR and these measures should be incorporated into the draft Section 61 Findings.

Off Site improvements at subsequent intersections will not be implemented as part of this project. However, in
coordination with the City Traffic Engineer, the City will update these signals to provide for adaptive
programming as the signals get updated. The new intersection design at Totten Pond Road will include the
adaptive capability.

MEPA 3

I refer the City to comments from DOER which indicate that the SC will include several new amendments that will
become effective in August of this year.

After the NPC/DEIR Certificate issuance, a conference call was held between SMMA, DOER and MEPA, many
items within the DOER letter were clarified during that call, including but not limited to the referenced
amendments. SMMA is designing the Project to the current Building Code and Massachusetts Amendments.

MEPA 4

It did not provide a feasibility analysis or financial assessment to support its dismissal. Additional analysis of solar
PV is required in the FEIR.

The Project is being designed to meet the code requirement of 40% rooftop PV ready. Additional documentation
on the areas designated for PV and a feasibility analysis is included within Section 4.3 of the FEIR.

Waltham High School | Final Environmental Impact Report 5 | p. 2

 Section 8: Responses to Comments

MEPA 5

The City’s commitment to implement the above TDM programs should be clarified in the FEIR.

The TDM plan is presented in the Section 61 Findings (Section 7) in the FEIR.

MEPA 6

There are discrepancies in the analysis as the NPC/DEIR states that the 2024 Build Case includes roadway
mitigation measures but not TDMs. This discrepancy should be clarified in the FEIR.

A full discussion of the 2024 No-Build and 2024 Build traffic volumes and assumptions are presented in
Section 4.

MEPA 7

To accurately understand the mobile source GHG emissions associated with the project, the FEIR should exclude
project-generated trips from the 2024 No Build Condition and should compare the GHG emissions associated
with the 2024 Build Condition (with no roadway improvements or TDM measures) to the 2024 Build with
Mitigation Condition (i.e. with roadway improvements and TDM measures), and propose additional mitigation
measures, if necessary.

A full discussion of the 2024 No-Build and 2024 Build traffic volumes and assumptions are presented in Section
4.

MEPA 8

The Preferred Alternative, developed to demonstrate consistency with the Policy and the SC, will reduce
stationary source emissions by 755 tpy, an approximate 33% reduction. Mobile source GHG emissions should be
reevaluated in in the FEIR.

A full re-evaluation of the mobile source GHG emissions are presented in Section 4.

MEPA 9

Comments from DOER request evaluation of a scenario that examines electrification of space heating in
conjunction with a more improved building envelope. Additional analysis of this scenario is required in the FEIR.

Scenario 4, which includes an all-electric heating and cooling system with improved building enclosure (NZER),
is evaluated in section 4.2 of the FEIR.

MEPA 10

The NPC/DEIR did not include a discussion of future climate conditions nor evaluate or specify whether the
stormwater management system was designed to account for the potential impacts of increased precipitation
frequency and volume due to climate change. This should be provided in the FEIR.

Climate change is addressed in section 5, and specifically includes discussion of how the proposed stormwater
management features will handle anticipated increases in precipitation in section 5.3.

Waltham High School | Final Environmental Impact Report 5 | p. 3

 Section 8: Responses to Comments

MEPA 11

These provisions appear to be inconsistent with plans disclosed in the NPC/DEIR to eliminate exclusive bike
lanes along Lexington Street. This should be addressed in the FEIR, along with any additional mitigation
measures that may be warranted to encourage non-vehicular (bicycle) travel to and from the site as part of TDM
measures to offset transportation impacts.

The City and Traffic Engineer believe the shared bike lane is the safest approach for bicyclists along this
corridor. A portion of the route is currently shared so it is extending a current practice. Bicycle detection will be
added to the traffic signal design to aid in activating the lights and additional signage for the bike lane will be
added along the corridor.

MEPA 12

Additional information on these noise mitigation measures [noise from blasting] is required in the FEIR.

The actual noise from the blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD , double matting will be utilized during all blasting operations to mitigate
debris, dust and noise. Finally, Consigli plans to use sound blankets at the perimeter fence strategically placed
to mitigate noise to the adjacent neighbors.

MEPA 13

The FEIR should clearly demonstrate that the City has sought to avoid, minimize and mitigate Damage to the
Environment to the maximum extent feasible.

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to avoid any relocation of the intermittent stream and wetland resources. This FEIR clearly
demonstrates that the City has sought to avoid, minimize, and mitigate Damage to the Environment to the
maximum extent feasible.

MEPA 14

I expect the FEIR will provide a comprehensive response to comments on the NPC/DEIR that specifically address
each issue raised in the comment letter; references to a chapter or sections of the FEIR alone are not adequate
and should only be used, with reference to specific page numbers or subsections, to support a direct response.

All comment letters have been included in section 8 of the FEIR and responses provided to the extent that they
are within MEPA jurisdiction.

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 Section 8: Responses to Comments

MEPA 15

The FEIR should identify measures the City will adopt to further reduce the impacts of the project since the filing
of the NPC/DEIR, or, if certain measures are infeasible, the FEIR should discuss why these measures will not be
adopted.

Section 7 of the FEIR identifies the measures the City will adopt to mitigate impacts.
Section 1.2 identifies the changes to the Project since the issuance of the NPC/DEIR Certificate:
1. Hired the Construction Manager – Consigli Construction Company.
2. Issued the Abatement and Demolition package for bid on July 20, 2020.
3. Received approval of the traffic signal concept -Two signals versus one signal from the Waltham Traffic
Commission. The project will now commence design of the signal and will be submitting the design to the
Traffic Commission at a later date for approval.

Section 5.3 of the FEIR included discussion of how stormwater management features are sized, including BMPs
and the piped drainage network, to accommodate anticipated change in precipitation. It would be possible to
over-size features, for example make subsurface storage chambers larger or increase pipe sizes, to
accommodate larger storms, but it is unnecessary and costly. The system complies with current state and city
regulations and will not be upsizing the stormwater management system.
The Project includes construction of 650 parking spaces, of which 450 spaces are proposed below the synthetic
turf field and 200 spaces at-grade. The project could theoretically reduce the quantity of parking which in turn
would likely reduce impervious area and disturbed area, but this is not feasible. In developing the proposed
parking program for the new school, School Building Committee considered that many students have after-
school commitments, such as jobs or athletic obligations, which require students to leave school either before or
after school buses depart for the day. Additionally, this could result in increased ADT as parents would
potentially need to drop off and pick up.
A requirement that all students utilize bussing to get to and from school would likely positively impact mobile
source green house gas analysis, presented in section 4.4 of the FEIR. But as described above, student parking
is provided in part to allow students with afterschool commitments to leave either before or after the school
buses depart for the day.
The project is complying with the City of Waltham construction hours. The project could theoretically limit the
construction hours however this would result in a longer duration of the overall project thereby having the
neighbors endure prolonged construction and add unnecessary cost to the project.
The project is proposing to conduct the rock crushing operation on site. The size of the rock will dictate the
length of time required to crush the rock. The project team is reviewing options to optimize the size, however
removing the rock from the site without any crushing would result in significantly more trucking as the volumes
of rock would be reduced due to the larger sizes and voids created. Off sourcing the crushing operation is not
financially feasible for the project and some of the material is planned for reuse on site to save the project
importing new materials (hence more trucks).
The project is proposing a PV ready roof. The project is not purchasing the photovoltaic panels at this time as
the initial capital cost is not within the project budget.
MEPA 16

The information and analyses identified in this Scope should be addressed within the main body of the FEIR and
not in appendices.

The information and analyses are contained within the body of the FEIR or attached directly as figures. The
Appendix contains backup calculations only.

Waltham High School | Final Environmental Impact Report 5 | p. 5

 Section 8: Responses to Comments

MEPA 17

Any references in the FEIR to materials provided in an appendix should include specific page numbers to
facilitate review.

Acknowledged and incorporated into the FEIR.

MEPA 18

The FEIR should identify, describe, and assess the environmental impacts of any changes in the project that have
occurred between the preparation of the NPC/DEIR and FEIR.

There have been no notable changes to the project since the NPC/DEIR submission. The changes which are
limited to hiring the CM, issuing a demolition package to bid and the approval of the traffic signal design are
included within section 1.2 of the FEIR.

MEPA 19

The FEIR should include updated site plans for existing and post-development conditions at a legible scale.

Updated site plans are included within section 9.1 of the FEIR.

MEPA 20

It should include a list of required State Permits, Financial Assistance, or other State approvals and provide an
update on the status of each of these pending actions.

List of required permits are included within section 1.4 of the FEIR.

MEPA 21

The FEIR should include an update on local, regional or federal permitting as applicable.

List of required permits are included within section 1.4 of the FEIR.

MEPA 22

The FEIR should clarify the projected net increase in water demand and wastewater flow.

The project will result in a net increase of 43,560 gallons per day (gpd) in water use when using the City
Ordinance in calculating the flows. The increase in water supply reflects both the proposed high school and the
future development at 617 Lexington Street, has been reviewed with the City’s Engineering Department and has
confirmed there is adequacy in the existing infrastructure.

The project will result in a net increase of 39,594 gallons per day (gpd) in wastewater generation and reflects
both the proposed high school and the future development at 617 Lexington Street. The required I&I inflow
mitigation is 4:1 or 158,376 gallons and will be deducted from the City’s sewer bank.

The net increase on water and wastewater demand is clarified in section 1.5.2 of the FEIR.

MEPA 23

It should clarify whether the natural field will be used for overflow parking, and if so, the anticipated frequency
with which this will occur.

Waltham High School | Final Environmental Impact Report 5 | p. 6

 Section 8: Responses to Comments

Although no formal vote was taken by the School Building Committee, the natural turf field can be used for
overflow parking. Historically there are approximately 15 high school events a year that require overflow parking.
The natural turf field is clarified in section 2.7 of the FEIR.

MEPA 24

The FEIR should clarify whether the 40-ft wide access road to Lexington Street (located north of the main
entrance to the site) will be gated and used only for emergency access or whether it will serve as a secondary
access point.

The existing 40-foot wide connection to Lexington Street will remain on the property. There are no plans to use
this for access to the project site. A portion of the western property line behind the Lexington Street abutters will
include a 6-foot high chain link fence, and a 6-foot high chain link gate will be provided at this leg of the
property. This gate will only be used in the case of an emergency. The emergency access road is clarified in
section 2.4 of the FEIR.

MEPA 25

The FEIR should include specific references to the deed language [20-ft wide water, sewer and drain easement]
that supports using the infrastructure easement as an emergency access roadway.

Under the Federal Constitution and Massachusetts statutes and case law, the Fire Department and Police
department have the right to use this right-of-way under exigent public safety or emergency situations involving
potential risks to public safety. Under such situations, the government’s good faith interest in protecting public
safety outweighs an individual’s private property rights. The emergency access road is further clarified in section
2.4 of the FEIR.

MEPA 26

The FEIR should clarify how stormwater from the site will be collected to avoid exacerbating flooding on adjacent
off-site properties.

At a high level, the proposed stormwater management system consists of BMPs which are designed to collect,
treat, and mitigate runoff. The stormwater management system also keeps separate “clean” water from the
stormwater which must be treated. That is, MassDEP’s regulations consider stormwater runoff from the athletic
field and building roof “clean” so this runoff does not need to be treated prior discharge. Runoff from the
wooded areas above the rock wall and groundwater collected in foundation drains are also considered “clean”
and these sources will be collected and managed separately from the stormwater which requires treatment.

The stormwater is clarified in section 3.2 of the FEIR.

MEPA 27

The NPC/DEIR indicated Lexington Street cannot accommodate both an exclusive bike lane and the proposed
turning lanes without private land takings (presumably to widen the right of way). The FEIR should identify the
width of the right of way and the proposed roadway cross section along this location. The FEIR should identify
alternative means to encourage bicycle travel to align with the City’s commitment to installing bicycle racks on
site.

The existing width of Lexington Street curb to curb is 40ft and 60ft for the right-of-way. The right-of-way
includes the granite curbing, a grass edge separation between the road and the public sidewalk. The project is
not proposing to widen the road, there is no intent to take any property to widen the right of way. Therefore, the
bicycle lane must be eliminated for a portion of the road to accommodate the left turn lane for the High School.

Waltham High School | Final Environmental Impact Report 5 | p. 7

 Section 8: Responses to Comments

The project will install additional signage at the bike lane and install bicycle detection at the signals. Currently
approximately 5-8 students’ bike to the existing High School on Lexington Street although the bike lane is
available. The school is providing 30 bicycle parking spaces at the new high school.

MEPA 28

The FEIR should clarify whether this is still applicable given that the Jericho Hill II Parcel was incorporated into
the site to enable revisions that would eliminate development from the northeastern portion of the site. To the
extent the potential for future expansion is no longer a project goal, the City should address how this would
impact the prior analysis of other locations considered for the site which would not require the use of designated
public open space.

The selection of this site is still valid and applicable, as discussed in the NPC/DEIR, the Project budget would
not account for relocation of the athletic fields and the City has invested millions of dollars in offsite locations
which they have no intention of abandoning. Therefore, the prior analysis remains valid and the reasons for the
selection of 554 Lexington Street as the preferred site stands. It should also be clarified that both 554 Lexington
Street and the Jericho Hill II Parcel has been transferred to the School Committee/School Department
exclusively for educational use, and neither is designated for public open space. is designated public open
space. The evaluation is clarified in section 2.10 of the FEIR.

MEPA 29

The City should address in the FEIR whether it will consider placing a conservation restriction on the portion of
the site which will remain undeveloped, or at an alternative off-site location, to permanently protect such land as
publicly accessible open space.

See attached City of Waltham Law Department Letter dated August 12, 2020 addressed to Honorable Jeannette
A. McCarthy in Section 3.1 of the FEIR.

In summary: The City has previously transferred care, custody and control of 554 Lexington Street to the School
Committee/School Department for educational purpose, and also transferred Jericho Hill/131R Lincoln Street to
the School Department as part of the new high school project – thus clearly demonstrating its dedication to
education use (i.e. not Article 97).

In light of the above, the Mayor is willing to recommend to the City Council that a conservation restriction be
placed on an alterative off-site location nearby that is currently held in the City’s General Inventory and is
currently undeveloped.

The alternative location, located adjacent to the current high school property, is a portion of the City-owned land
known as 0 Chesterbrook Road (aka 605R Lexington Street) and that restriction would be placed on 5.97 acres
of that site (see plan attached). A conservation restriction on this 5.97-acre area would not only preserve existing
undeveloped open space, but would also protect wetlands and other environmental concerns.

Waltham High School | Final Environmental Impact Report 5 | p. 8

 Section 8: Responses to Comments

MEPA 30

The FEIR should include a more detailed narrative discussion of the stormwater management system and
stormwater conveyance from the project site to Chester Brook. This should address how and where flows from
the 0.4 acre portion of the stream’s watershed combine with the rest of the site’s runoff prior to discharge to
Chester Brook. The FEIR should clarify the source data for the design storms used to design the stormwater
management system. As discussed below, the City should evaluate sizing the stormwater management system to
account for the potential impacts of increased precipitation frequency and volume due to climate change.

As discussed in section 3.2.1 of the FEIR, Section 4.2 of the NPC/DEIR described the site being tributary to
Chester Brook. All stormwater from the site discharges to the brook, whether as overland runoff or stormwater
captured by the existing underground drainage system. The Project will not change the tributary area that drains
to Chester Brook. The on-site unnamed intermittent stream’s watershed is approximately 20.39 acres and
includes all land upgradient of the resource. As described in Section 4.2 of the NPC/DEIR, the Project will alter
0.4 acres of the tributary watershed to the intermittent stream which is approximately 2%. Instead of
contributing overland flow to the intermittent stream, the runoff from the 0.4-acre portion will be collected in
either the trench at the base of the rock wall or within the catch basins within the school’s internal roadway and
will combine flows from the Project before discharging to Chester Brook. The 0.4-acre portion is represented in
Subcatchments 2.6 and 2.9.

MEPA 31
The NPC/DEIR indicated the project team will continue to investigate sources of [flood] water and will implement
additional mitigation strategies where feasible so that the project improves conditions to the abutting properties.
The FEIR should provide an update on this investigation and should identify any additional mitigation measures
that were incorporated into the project.

As discussed in section 3.2.3 of the FEIR, the downgradient abutters to the east and south currently experience
flooding caused by stormwater or groundwater from the site. The Project has incorporated a swale along the
eastern edge of the property to protect those abutters from stormwater running directly from the site into their
properties. Refer to sheet C-132 included in Appendix 9.1. Abutters to the south will be protected because
although Project’s development (roadways and parking) extends further towards the southern properties, it is
graded to direct runoff to the stormwater management features which eventually discharge from the site to
Chester Brook via the Lexington Street drainage.

A supplemental subsurface exploration program to aid in the bedrock cut design is currently underway. The
program is comprised of test borings, geophysical testing, laboratory testing, down-the-hole packer testing, and
aquifer pumping tests. Rock core samples collected from test borings and geophysical testing are used to
identify bedrock fracture and joint location and orientation. Down-the-hole packer testing is performed to
evaluate the response of the fractures to injection of water under pressure. That information is used to better
understand the permeability of the rock under a variety of pressures, and evaluate the ability to inject fluids into
the rock fractures. The aquifer pumping tests will allow a better understanding of anticipated groundwater inflow
rates to the underdrain system, and expected volume of water exiting the rock face. Down-the-hole packer
testing and pump testing will be performed after the test borings are drilled and the boreholes are flushed. The
test borings are anticipated to be completed by the end of August 2020, and the down-the-hole packer and
pump testing program to be complete by mid-September 2020.

MEPA 32

The NPC/DEIR noted that potential impacts from fractures and/or joints within the bedrock will be further
evaluated to determine potential impacts to surficial flow within the stream channel. The FEIR should provide an
update on this evaluation and identify a timeline for its completion.

Waltham High School | Final Environmental Impact Report 5 | p. 9

 Section 8: Responses to Comments

Based on visual observations of the rock core samples and the groundwater elevation data collected to date, it
is anticipated that the stream channel flow will not be impacted, however evaluations will continue as additional
aquifer data becomes available.

MEPA 33

The NPC/DEIR indicated that the turf field will be in accordance with MassDEP regulations for PFAS but did not
identify the applicable regulations or explain how the project would comply. This should be addressed in the
FEIR.

As of the date of this document, Massachusetts does not have required test methods and specifications for
testing and regulating solid materials, such as synthetic turf. The Project has committed to meeting other
available standards. Refer to section 3.3 of the FEIR for further information on testing and regulations.

MEPA 34

New construction offers many opportunities for building shell and mechanical system improvements and I expect
the City will reconsider these measures to maximize the potential benefits of this new $122 million dollar
construction.

The project is being designed to meet current Energy Code, Stretch Code (BBRS- February 7th 2020), with a goal
to outperform the Stretch Code by 10%. It includes enhanced exterior enclosures, increased lighting systems
efficiency, whole building air infiltration testing and high-performance mechanical systems to maximize energy
savings to the extent possible within the overall budget.

MEPA 35

I encourage the City to utilize the updated Stretch Code as it updates its GHG emissions calculations to
accurately evaluate the GHG reduction benefits provided by proposed mitigation measures.

The project is being designed to meet the current Stretch Code (per BBRS - February 7th 2020), with a goal to
outperform the Stretch Code by 10%

MEPA 36

As requested by DOER, the FEIR should evaluate a scenario which includes electrification of space heating with
an improved envelope. This scenario should evaluate whether additional improvements to the envelope could
potentially eliminate or downsize HVAC systems. The FEIR should include a LCCA for this scenario and the
scenario where the currently proposed building will be retrofitted to electric heating in the future. I refer the City
to comments from DOER for additional guidance on this issue.

Scenario 4, which includes an all-electric heating and cooling system with improved building enclosure (NZER),
is evaluated in section 4.1 and 4.2 of the FEIR.

MEPA 37

The FEIR should provide a solar PV feasibility analysis.

A preliminary Solar Photovoltaic (PV) feasibility analysis was conducted for the potential to reduce GHG
emissions by installing a Solar PV system in the allocated Code required 40% PV readiness area of the roof. The
City of Waltham does not intend to install a Solar PV system as part of the new school project due to budgetary
constraints. The analysis is provided in section 4.3 of the FEIR

Waltham High School | Final Environmental Impact Report 5 | p. 10

 Section 8: Responses to Comments

MEPA 38

The plans and an accompanying table should identify the extent of the roof that is required to be “solar ready” in
order to comply with Building Code requirements after August 2020 (as applicable), the total rooftop area, and
the maximum usable roof area for a solar installation.

Following the DEIR Certificate issuance, a conference call was held between SMMA, DOER and MEPA. Many
items within the DOER letter were clarified during that call, including but not limited to the referenced
amendments. SMMA is designing the project to the current Massachusetts Energy Code and Amendments (as
approved by BBRS on February 7th 2020). A roof plan depicted the PV ready areas is included in section 4.3 of
the FEIR.

MEPA 39

The FEIR should include a revised mobile source GHG analysis incorporates any changes to the TDM program
and/or traffic mitigation measures. The FEIR should identify the specific roadway mitigation measures and TDM
measures that are reflected in the analysis and these mitigation measures should be incorporated into the draft
Section 61 Findings.

A listing of TDMs and traffic mitigations measures included as part of the mobile source GHG emissions are
presented in Section 4.

MEPA 40

It also stated that the Massachusetts Safe Routes to School (SRTS) Program will be included as part of the
sustainability measures that will be implemented for the project. The FEIR should clarify this commitment.

While the Safe Routes to School (SRTS) program is for Elementary and Middle school students there are aspects
of the program that can be applicable to the High School Students – specifically the Six E’s. Working with the
administration during design, specific locations for 30 bike racks were discussed for safety, accessibility, and
Equity. With the addition of the new signal and crosswalks, better signage for the bike path and bike boxes
address the Engineering component, the administration is committed to Educating, Encouraging, Evaluating and
Enforcing bike use and safety.

MEPA 41

The FEIR should expand upon the information presented in the NPC/DEIR to demonstrate a clear commitment to
promoting safe and accessible pedestrian and bicycle access for students to and throughout the project site.

The on-site circulation pattern has been designed and reviewed to provide safe access for all students, staff and
visitors to the site. Sidewalks along the entry road are six feet wide. Refer to section 2.5 for a discussion on
bicycle and pedestrian access.

MEPA 42

The FEIR should address how the projected change in precipitation may impact groundwater levels, flow rates,
direction, and flooding.

It is anticipated that the projected change in precipitation will not impact the function of proposed stormwater
management system. The Project has incorporated resilient design strategies in the stormwater management
system including disconnecting impervious surfaces, incorporating LID BMPs, and providing redundant
treatment trains where rational. The groundwater is currently being studied but the management system will be

Waltham High School | Final Environmental Impact Report 5 | p. 11

 Section 8: Responses to Comments

designed to account for a raise in groundwater elevation. Refer to section 5.3 for a discussion on design
resiliency.

MEPA 43

The FEIR should include a narrative discussion about how existing and future groundwater flow volumes above
the invert elevations were accounted for and incorporated into the design of the stormwater management
system. This evaluation should consider the future effects of climate change.

The Project has incorporated resilient design strategies in the stormwater management system including
disconnecting impervious surfaces, incorporating LID BMPs, and providing redundant treatment trains where
rational. The groundwater is currently being studied but the management system will be designed to account for
a raise in groundwater elevation. Refer to section 5.3 for a discussion on design resiliency.

MEPA 44

The FEIR should also provide an update on the results of any additional test borings and groundwater pump tests
that have been performed since the NPC/DEIR was submitted and a timeline for conducting any additional tests
to better understand hydrogeologic conditions in the bedrock and groundwater flow rates and direction.

A supplemental subsurface exploration program to aid in the bedrock cut design is currently underway. The
program is comprised of test borings, geophysical testing, laboratory testing, down-the-hole packer testing, and
aquifer pumping tests. Rock core samples collected from test borings and geophysical testing are used to
identify bedrock fracture and joint location and orientation. Down-the-hole packer testing is performed to
evaluate the response of the fractures to injection of water under pressure. That information is used to better
understand the permeability of the rock under a variety of pressures, and evaluate the ability to inject fluids into
the rock fractures. The aquifer pumping tests will allow a better understanding of anticipated groundwater inflow
rates to the underdrain system, and expected volume of water exiting the rock face. Down-the-hole packer
testing and pump testing will be performed after the test borings are drilled and the boreholes are flushed. The
test borings are anticipated to be completed by the end of August 2020, and the down-the-hole packer and
pump testing program to be complete by mid-September 2020. Refer to section 3.2.3 in the FEIR for a
discussion on flooding and groundwater.

MEPA 45

The FEIR should clarify whether noise or dust from construction activities will create a nuisance condition by
interfering with enjoyment of property.

The FEIR should continue to analyze potential noise and vibration impacts associated with blasting and crushing
operations, and propose appropriate mitigation measures.

The actual noise from blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to mitigate
debris, dust and noise.

The CM plans to use water misters, water trucks, and automatic wheel wash stations to minimize dust. Methods
for controlling silica dust exposure will be in compliance with OSHA section 1926.1153 Table 1. The CM’s Site
Specific Safety Plan includes that any activity which can produce silica dust will use engineering controls to keep

Waltham High School | Final Environmental Impact Report 5 | p. 12

 Section 8: Responses to Comments

dust to a minimum. There will be no dry cutting of any masonry material allowed; if water cannot be used then a
dustless vacuum system consisting of a HEPA dustless vacuum system shall be used.

Finally, the CM plans to use sound blankets at the perimeter fence strategically placed to mitigate noise to the
adjacent neighbors.

Waltham High School | Final Environmental Impact Report 5 | p. 13

 Section 8: Responses to Comments

MEPA 46

The NPC/DEIR indicated that the project team is modeling the noise generating equipment and is analyzing
preferred locations for equipment to minimize impacts on abutters and to identify potential sound proofing
measures such as sound barriers around equipment. The FEIR should provide an update on this analysis and
should identify specific mitigation measures that will be implemented to address these impacts.

The project team has continued to advance the design of the building and the noise generating equipment on
the building. The project acoustician, Acentech, has reviewed the equipment selections and worked with the
project team. Their progress report is attached in Appendix 6.2 of the FEIR.

Sound levels are based upon three periods with a 24-hour day in coordination with the Director of Facilities and
how the building roof top equipment would be operated.

1. Daytime - 6.00am to 6.00pm

2. Evening – 6.00pm to midnight
3. Nighttime – midnight to 6.00am

Using these timeframes and measuring against the background noise measurements conducted in July 2019,
Acentech is recommending additional noise mitigation be incorporated on a number of rooftop units to achieve
compliance with the Waltham Noise Ordinance and Massachusetts DEP. These additional measures will be
incorporated into the project scope.

MEPA 47

The FEIR should provide a figure identifying the approximately 500-ft pre-blast inspection survey radius or
identify when this information will become available and how it may be viewed by stakeholders.

The project team is still evaluating the extent of the blasting on the site and has not finalized the 500-foot blast
radius map at this time. The map drafted by Haley & Aldridge geotechnical engineers is being refined. This draft
was presented at the SBC Meeting on August 10, 2020. Once finalized it will be posted on the project website,
reviewed publicly at the SBC meeting and shared with those within the 500-foot radius via mail. The map is
included in Section 6.3 of the FEIR.

MEPA 48

The FEIR should describe the blasting notification procedure for abutters to be used by the contractor. It should
identify an approximate timeframe for completing the pre-blast surveys.

The blasting notification procedures were described in Section 10.1.5 of the NPC/DEIR and clarified in Section
6.3 of the FEIR. The initial contact is typically performed via conventional mail and if contact is unsuccessful;
certified mail will be utilized. Pre-blast condition surveys intended to commence by the beginning of November
or sooner and be completed within a 4-6 week timeframe.

MEPA 49

The FEIR should provide details of how the survey will be conducted and clarify whether property owners will be
provided with copies of the completed survey.

The survey will be conducted in accordance with 527 CMR section 13.09. The details of the survey are outlines
in Section 10.1.5 of the NPC/DEIR and reiterated in Section 6.3 of the FEIR. Copies of the survey will be
provided to property owners as requested.

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 Section 8: Responses to Comments

MEPA 50

The FEIR should address how the project will ensure compliance with the Massachusetts Idling regulation at 310
CMR 7.11. Because this project will occur in close proximity to residential areas, I urge the City to minimize
potential noise and air quality impacts by requiring that construction vehicles limit engine idling, use ultra-low
sulfur diesel fuel, and be retrofit with emissions control equipment, including emission control equipment
identified in the Commonwealth’s Clean Air Construction Initiative.

The no idling policy will be enforced on site via signage and construction management personnel and
subcontractor contractual language. Verbal warnings will be issued followed by written warnings and fines per
incident.

The CM will include the requirement for ultra-low sulfur diesel fuel and equipment retrofitted with emissions
control equipment, including emission control equipment identified in the Commonwealth’s Clean Air
Construction initiative for all subcontractors.

MEPA 51

The FEIR should include a section that summarizes all proposed mitigation measures and provides draft Section
61 Findings for each State Agency Action. It should contain clear commitments to implement these mitigation
measures, estimate the individual costs of each proposed measure, identify the parties responsible for
implementation, and contain a schedule for implementation.

Section 7 of the FEIR summarizes all proposed mitigation and provides costs, commitments, and schedule for
implementation.

MEPA 52

The commitment to provide this self-certification in the manner outlined above should be incorporated into the
draft Section 61 Findings included in the FEIR.

Section 7 of the FEIR includes the table of mitigation which notes that Self-certification to the MEPA Office that
all of the required GHG mitigation measures, or their equivalent, have been completed will be submitted after
completion of construction.

MEPA 53

The FEIR should contain a copy of this Certificate and a copy of each comment letter received.

Included.

MEPA 54

In order to ensure that the issues raised by commenters are addressed, the FEIR should include direct responses
to comments to the extent that they are within MEPA jurisdiction. This directive is not intended, and shall not be
construed, to enlarge the scope of the FEIR beyond what has been expressly identified in this certificate.

Acknowledged.

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 Section 8: Responses to Comments

MEPA 55

The Proponent should circulate the FEIR to those parties who commented on the ENF or NPC/DEIR, to any State
and municipal agencies from which the City will seek permits or approvals, and to any parties specified in section
11.16 of the MEPA regulations.

Acknowledged.

MEPA 56

The FEIR submitted to the MEPA office should include a digital copy of the complete document.

Acknowledged.

MEPA 57

A copy of the FEIR should be made available for review at the Waltham Public Library.

The Waltham Public Library is closed at this time due to COVID-19. A copy of this FEIR will be posted on the
High School Project website.

Waltham High School | Final Environmental Impact Report 5 | p. 16

 The Commonwealth of Massachusetts
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Charles D. Baker
GOVERNOR
Tel: (617) 626-1000
Karyn E. Polito
LIEUTENANT GOVERNOR
Fax: (617) 626-1081
http://www.mass.gov/eea
Kathleen A. Theoharides
SECRETARY

June 26, 2020

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS

ON THE
NOTICE OF PROJECT CHANGE / DRAFT ENVIRONMENTAL IMPACT REPORT

PROJECT NAME : Waltham High School

PROJECT MUNICIPALITY : Waltham
PROJECT WATERSHED : Charles
EEA NUMBER : 16097
PROJECT PROPONENT : City of Waltham
DATE NOTICED IN MONITOR : May 20, 2020

Pursuant to the Massachusetts Environmental Policy Act (M.G.L. c. 30, ss. 61-62I) and Section
11.08 of the MEPA Regulations (301 CMR 11.00), I have reviewed the combined Notice of Project
Change (NPC)/Draft Environmental Impact Report (DEIR) and hereby determine that it adequately and
properly complies with MEPA and its implementing regulations.

The NPC/DEIR described changes to the project, most notably the incorporation of an adjacent
6-acre parcel, referred to as Jericho Hill Parcel II, into the project site. As described below in greater
detail, the addition of this parcel enabled the reconfiguration of the proposed layout, resulting in a new
Preferred Alternative that eliminates direct impacts to wetland resource areas and reduces the amount of
land alteration and impervious area. The NPC/DEIR indicated that these revisions were in made in
response to the Scope issued in the Certificate on the Environmental Notification Form (ENF), which
requested continued evaluation of alternatives that avoid significant impacts to wetland resource areas.
Comments from the Massachusetts Department of Environmental Protection (MassDEP), interim
Waltham Public Schools Superintendent George Frost, and the Waltham legislative delegation (State
Representative Thomas M. Stanley, State Representative John J. Lawn, Jr., and State Senator Michael J.
EEA# 16097 NPC/DEIR Certificate June 26, 2020

Barrett) express support for the revised layout and associated reduction in impacts. Comments from
residents also support the new Preferred Alternative, highlight the urgent need for a new facility, and
indicate the new school will provide educational equality. Comments from the Waltham Land Trust and
other residents identify concerns with the addition of the Jericho Hill II Parcel, currently serving as open
space, into the project site without mitigating measures such as permanent protection of other land
through a recorded conservation restriction or similar means. Comments from residents and abutters also
continue to identify concerns with impacts to groundwater, loss of wildlife habitat, and traffic and
congestion.

The MEPA process has provided, and will continue to provide, a valuable forum for the
collection of all relevant points of view, but reconciling all of the identified (and sometimes competing)
concerns is beyond the scope of the MEPA. The primary purpose of the MEPA process is to provide
meaningful opportunities for public review of the potential environmental impacts of the Project and to
refine the project in the subsequent DEIR and Final Environmental Impact Report (FEIR) process as
design progresses. The MEPA process requires public disclosure of a project’s environmental impacts as
well as the measures that the Proponent will undertake to mitigate these impacts. MEPA review occurs
before state agencies act to issue Permits or Financial Assistance for a proposed project to ensure that
they are fully cognizant of the environmental consequences of their actions. MEPA review is not a
permitting process, nor does it serve as an appeal for local decisions. It is not a zoning process, and it
does not proscribe to a Proponent what, where, or how a project should be designed or built. While I
expect that the FEIR will serve to provide further transparency and explanations of environmental
impacts and mitigation, the many concerns about the design of the project will continue to be reviewed
as the final design of the project proceeds to permitting before the City. This certificate is not intended
to prejudge the outcome of those subsequent permitting procedures.

Project Description

As described in the ENF, the project includes the demolition of existing structures (a retreat
house and conference center) and construction of a new high school building (414,850 gross square feet
(sf); 484,240 gross sf including the parking structure) with associated site work, utilities, above- and
below-ground parking, on-site access roadways, stormwater infrastructure, and two athletic fields (an
existing natural field and a new synthetic turf field). The project is proposed to meet the full
programmatic requirements for a 1,830-student, 9th-through-12th-grade high school. The project
includes significant earthwork to achieve final design grades of the project, including significant
bedrock excavation using a combination of hoe ramming and controlled blasting techniques. An early
site preparation phase will include clearing, earthwork, blasting, grading, and preparation for the
building construction followed by construction of the building. The existing high school building will be
repurposed for other uses at a later time, no earlier than 2024.

As previously described in the ENF, the existing 388,000-sf Waltham High School was
constructed in 1968 and does not meet current building, accessibility, and safety standards, nor does it
accommodate educational programming needs and increases in student population. The ENF indicated
that the existing high school will risk losing its accreditation in 2027 without significant investment in
the building or the construction of a new high school. The NPC/DEIR noted the City’s future needs
related to the growing student population. The City is in need of additional space for either a
Kindergarten (K) through 8th grade school or a middle school to relieve overcrowded conditions.

2
EEA# 16097 NPC/DEIR Certificate June 26, 2020

Following construction of the new high school, the City will repurpose the existing high school to meet
these needs. For the purpose of evaluating environmental impacts, the DEIR assumed that the McDevitt
Middle School (grades 6-8) and the Dual Language School at the Waltham Community and Cultural
Center (formerly South School) (K-5) would be relocated to the existing high school building. It also
assumed the existing high school building would house the District’s Central Office and Parent
Information Center (PIC). Renovation of the existing high school for these uses is not anticipated to
commence until 2024 at the earliest.

Project Changes Since the ENF

Project changes include the incorporation of an adjacent 6-acre parcel (Jericho Hill II) into the
project site and reconfiguration of the project layout. The addition of this parcel enabled relocating the
athletic field and parking from the northcentral portion of the site to behind the building and shifting the
building west by approximately 90-ft. The NPC/DEIR indicated the reconfiguration was in response to
the Secretary’s Scope which requested further evaluation of alternatives that avoid significant impacts to
wetland resource areas. The revised layout locates all the significant programmatic elements on one side
of the intermittent stream, avoids impacts to wetland resource areas, and retains an existing natural turf
field located on the eastern portion of the site. As described below in greater detail, the NPC/DEIR also
presented a revised plan to provide secondary emergency access to the site.

Project Site

The approximately 52.5-acre project site is comprised of three parcels located at 554 Lexington
Street (46.5 acres) and one adjacent parcel known as Jericho Hill II located at 131R Lincoln Street (6
acres) in Waltham. The site is generally bounded by undeveloped land to the west (known as Sanderson
Heights), residential areas to the north and south, and Lexington Street and residences to the east. The
site was previously owned by the Stigmatine Fathers Inc. Trust and contains buildings associated with
the Espousal Retreat House and Conference Center which will be demolished as part of the project.
Existing development is located on the southern portion of the site. The remainder of the site is
undeveloped and contains areas of relatively steep slopes. Topography ranges from an elevation of 106
ft at Lexington Street to 286 ft at the highest portion of the site near the northern property line. Site
access is provided via a single driveway from Lexington Street.

An intermittent stream runs north to south through the center of the site and has associated areas
of Bordering Vegetated Wetlands (BVW). The stream extends from a high point in the north central
portion of the site to a point in the middle of the site where the stream enters underground piping that
extends off the site and under Lexington Street to Chester Brook. The project site is not located in
Priority and/or Estimated Habitat as mapped by the Division of Fisheries and Wildlife’s (DFW) Natural
Heritage and Endangered Species Program (NHESP) or an Area of Critical Environmental Concern
(ACEC). The project site contains one building that is listed in the Massachusetts Historical
Commission’s (MHC) Inventory of Historic and Archaeological Assets of the Commonwealth and is
identified as MHC ID# WLT.138. The ENF contained correspondence from MHC dated February 19,
2019 which acknowledged the building would be demolished and indicated that no further MHC review
is required for the project.

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Environmental Impacts and Mitigation

As summarized in the table below, the revised project layout has eliminated impacts to wetland
resource areas and reduced other environmental impacts.

Environmental Impact ENF NPC/DEIR Net Change

Total Site Area (acres) 46.5 52.5 6
Land Alteration (acres) 12.95 10.2 -2.75
New Impervious Area (sf) 9.72 9.54 -0.18
Bordering Vegetated Wetlands (sf) 4,760 0 -4,760
Inland Bank (lf) 1,680 0 -1,680
New Trip Generation (average daily vehicle trips; adt) 1,491 1,851 360 1
Parking Spaces 554 454 -100
Water Use (gallons per day; gpd) 30,550 6,380 -24,170
Wastewater Generation (gdp) 26,568 4,575 -21,993

Measures to avoid, minimize, and mitigate environmental impacts include: an upgraded

stormwater management system, redesigning the project to eliminate wetland impacts, traffic
signalization and roadway improvements, implementation of energy efficient building systems and
features, and implementation of a construction management plan.

Jurisdiction and Permitting

The project is undergoing MEPA review and requires preparation of an ENF pursuant to
Sections 11.03(1)(b)(2), 1.03(6)(b)(14), and 11.03(6)(b)(15) of the MEPA regulations because it
requires a State Agency Action and will result in the following: creation of five or more acres of
impervious area; generation of 1,000 or more New adt on roadways providing access to a single location
and construction of 150 or more New parking spaces at a single location; and construction of 300 or
more New parking spaces at a single location (respectively). 2 The project will receive Financial
Assistance from the Massachusetts School Building Authority (MSBA).

The project requires an Order of Conditions from the Waltham Conservation Commission (or in
the case of an appeal, a Superseding Order of Conditions from the Massachusetts Department of
Environmental Protection (MassDEP)). 3 The project is subject to review by and requires permits from

1 The trip generation has been revised since the ENF was filed to account for the trips associated with future reuse of the
existing high school (360 adt).
2 The ENF indicated the project also exceeded the threshold at 301 CMR 11.03(3)(b)(1)(b) – Alteration of 500 or more linear

feet of bank along an inland bank. The project has been redesigned and no longer exceeds this threshold.
3 The project also requires a Superseding Order of Resource Area Delineation (ORAD) from MassDEP. This is not

considered an Agency Action as defined at 301 CMR 11.02.

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several City of Waltham agencies, including: a Variance from the Zoning Board of Appeals (ZBA),
Special Permit from the Board of Survey and Planning, Demolition and Construction Permits from the
Building Department, Blasting Permit from the Fire Department, and approval for curb cuts and street
opening from the Consolidated Public Works Department. It also requires a National Pollutant
Discharge Elimination System (NPDES) Construction General Permit from the U.S. Environmental
Protection Agency (EPA).

Because the project will receive Financial Assistance, MEPA jurisdiction for this project is broad
and extends to all aspects of the project that are likely, directly or indirectly, to cause Damage to the
Environment as defined in the MEPA regulations.

Review of the NPC/DEIR

The NPC/DEIR was responsive to the Scope and identified changes to the project to minimize
environmental impacts as compared to the ENF. The NPC/DEIR described the proposed project and
changes since the filing of the ENF. The NPC/DEIR identified existing conditions, described potential
environmental impacts and mitigation measures, and provided a discussion of alternatives. It included
updated site plans for existing and proposed conditions, a brief description of applicable statutory and
regulatory standards and requirements, and an explanation of how the project will meet the standards. It
included a list of required State Permits, Financial Assistance, or other State approvals and provided an
update on the status of each of these pending actions. It provided figures depicting secondary emergency
access and conceptual site plans for proposed off-site improvements. The NPC/DEIR provided
clarification regarding the school district’s Master Educational Plan and athletic field requirements. The
list of priorities for athletic fields (sometimes referred to as the Athletic Field Master Plan; provided as
Appendix 2.2) was created for planning purposes as a guide to evaluate alternatives and to identify
locations which could accommodate additional athletic programs. The NPC/DEIR clarified it was not
the intent to provide fields for all athletic programs on a single site.

The NPC/DEIR presented a revised plan to provide a secondary emergency access site which is
not required by Code but was requested by the City’s Police Chief and Fire Chief. The ENF previously
indicated that the only viable alternative for providing secondary access without acquisition of
additional land was a route through two abutting parcels owned by the City (Jericho Hill II and
Sanderson Heights). The NPC/DEIR indicated that Sanderson Heights was eliminated from
consideration because the property is not controlled by the Waltham School Department. The
NPC/DEIR indicated that secondary emergency access will be provided via an existing easement as the
City does not want to acquire additional land. The City has a water, sewer, and drain easement that
extends from the end of Lincoln Street to the 554 Lexington Street property line, referred to as Lincoln
Street Extension. The project will construct a 20-ft wide paved drive on the project site for use by
emergency vehicles. The 20-ft paved drive which will connect the on-site internal roadway network to
the edge of the 554 Lexington Street property line where it will connect to the abutting easement. The
NPC/DEIR indicated the easement provides the City with maintenance rights and that the City may pave
Lincoln Street Extension. Access to this emergency road will be gated at the property line abutting the
easement and at the high school internal roadway. A six-foot high chain link fence will be installed
along the southern boundary line to prevent students from walking through private properties.

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Alternatives Analysis

The Scope required the City to reconsider the alternative site layouts presented in the ENF
(Alternatives 1-5) in light of MassDEP’s comments on the ENF, which noted that alternatives that avoid
significant impacts to Bank or BVW should continue to be explored even if they result in increased
impacts to upland areas or require increased blasting. Alternatives 1-5 were alternative site layouts
specifically focused on reducing impacts to the intermittent stream and BVW. The Scope also required
the City to evaluate alternatives to mitigate the loss of Bank and BVW. As noted above, the project has
been revised to eliminate all impacts to wetland resource areas. The DEIR did not present any new
alternatives, other than the revised Preferred Alternative. As summarized below, the NPC/DEIR
compared the environmental impacts of the revised Preferred Alternative to the Alternatives described in
the ENF, including Alternatives Option A-B and Alternatives 1-5.

Altered Altered New Land New Estimated Length of

Alternative
Alternative Bank BVW Alteration Impervious Rock Rock
Description
(lf) (sf) (ac) Area (ac) Removal (cy) Walls (lf)
1
No Build 0 0 0 0 0 0
2 ENF Preferred
1,680 4,670 12.95 9.72 780,000 2,215
Alternative
Replication
3 Similar to
1,200 4,670 12.60 9.72 780,000 2,215
Schematic
Design
Intermittent
Stream
Replication
4
Between 1,040 4,670 14.80 9.99 985,000 3,460
Separated
Development
Areas
Existing
Intermittent
Stream to
5
remain Between 0 0 14.75 13.8 930,000 3,430
Separated
Development
Areas
Located school
near Lexington
Option A Street within 1,700 4,670 12.90 10.25 930,000 2,250
developed
portion of site.
Located school
Option B further into 1,300 4,670 13.8 11.25 950,000 2,620
project site.
NPC/DEIR
Preferred Revised
0 0 10.89 9.54 747,000 1,920
Alternative Preferred
Alternative

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The NPC/DEIR identified the pros and cons of each of the alternatives. The NPC/DEIR
indicated that the Preferred Alternative was selected based on the following criteria: fulfills the goals of
the project to meet the educational needs for the children of Waltham; avoids impacts to wetland
resource areas and will restore previously filled Bank and BVW; provides integrated design among the
building, athletic field, and parking area; and allows for maintenance of the existing natural field area
near Lexington Street, on the other side of the intermittent stream from the proposed school.
Additionally, it will result in less land alteration, impervious area, earthwork/blasting, and removal of
blast material compared to the other alternatives. Comments from MassDEP support the Preferred
Alternative as it avoids impacts to wetland resource areas. The NPC/DEIR indicated the Preferred
Alternative will increase the buffer to residential areas on the east side of the project (Lexington Street)
but reduce the buffer to residential areas on the south side (Lincoln Street, Lincoln Terrace, and Glen
Circle). Comments from abutters identify concerns regarding noise and light from the proximate athletic
fields during sporting events. Comments also request additional analysis of alternative locations for the
project, including 617 Lexington Street (adjacent to the existing high school) and 200 Trapelo Road
(former Fernald Hospital). I note that these alternative locations were previously evaluated in the ENF
and the Scope for the NPC/DEIR did not require further analysis.

Land

The project will alter 10.2 acres of land and will create 9.54 acres of new impervious area. The
NPC/DEIR indicated that relocating the athletic field allows the existing natural field and north-central
portion of the site to remain as undisturbed wooded area. It also reduced impervious area through
elimination of previously proposed on-site access roads. I encourage the City to consider placing a
conservation restriction on these portions of the site that will remain as undeveloped open space to
ensure their permanent protection. The ENF previously proposed the use of porous pavers 4 in a
pedestrian plaza area located adjacent to the athletic field. The NPC/DEIR asserts that porous pavers are
no longer needed as the area of the pedestrian plaza and overall impervious area have been reduced. The
NPC/DEIR included a new commitment to construct green vegetated roofs on the third floor of the
building (approximately 3% of the overall roof area).

The NPC/DEIR included a copy of the updated geotechnical report (Appendix 3.1) which
described additional geotechnical work that has occurred to evaluate subsurface conditions. The site
contains steep topography and will require a significant amount of grading and controlled blasting,
creation of a 1,920 lf rock wall cut face, and removal of 747,000 cubic yards (cy) of material from the
site. The NPC/DEIR included figures that conceptually identified the proposed areas of cut and fill,
areas that will require blasting, and approximate elevation changes necessary to achieve proposed grade
given exiting topography. The majority of the cut material will be comprised of rock which will be
crushed, processed, and re-used on-site. Limited fill material will be imported to the site. The
NPC/DEIR confirmed that project specifications will prohibit the use of perchlorates in blasting
materials to avoid impacts to water quality and wetlands.

As requested by the Scope, the NPC/DEIR provided information to address whether the project
parcels are protected in accordance with Article 97 of the Amendments to the Constitution of the
Commonwealth (Article 97) (Appendices 3.2 – 3.4 of the NPC/DEIR). This information included

4Porous pavers are a cellular grid system filled with gravel or soil and grass that provide ground stabilization while reducing
compaction of the soil to maintain permeability and improve stormwater quality through infiltration.

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written opinions from the City’s Law Department which state that the parcels at 554 Lexington Street
and 131R Lincoln Street (Jericho Hill II) are not subject to the protections of Article 97. According to
information provided with the NPC/DEIR, the City took the 554 Lexington Street parcels by eminent
domain in 2018 for the purpose of educational use, open space, or combination thereof. In 2019, the City
Council transferred the care, custody, and control of the parcels to the Waltham School Committee and
the Waltham School Department for educational use and the purposes associated with educational use.
In 2001, the City obtained the 131R Lincoln Street parcel (Jericho Hill II) through a friendly
taking/purchase for municipal purposes. According to the NPC/DEIR, on March 9, 2020, the Waltham
City Council transferred the care, custody, and control of the Jericho Hill II parcel to the Waltham
School Committee and Waltham School Department for educational use and purposes associated with
educational use. Comments received from residents identify concerns that this parcel was transferred
without an opportunity for public input. Comments also identify concerns about development of the
school building on a location that provided public open space and request that the City place a
conservation restriction (CR) on the northerly portion of the project site to permanently protect it as
publicly accessible open space.

Wetlands/Stormwater

The addition of the Jericho Hill II Parcel allowed the vast majority of the project to be sited on
one side of the intermittent stream, eliminating all wetland impacts, including the need to fill and reroute
the stream. The project will impact 1.44 acres of buffer zone. Work within the buffer zone includes
removal of fill, construction of roadways and sidewalks, and earthwork required to achieve design
grades. Comments from MassDEP are supportive of the revised project design which avoids impacts to
wetland resource areas. The project also includes removal of historic fill to restore approximately 550 sf
of BVW and 270 lf of bank associated with an intermittent stream. As noted during review of the ENF,
these resource areas were identified through proceedings related to a Superseding Order of Resource
Area Delineation (ORAD) for 554 Lexington Street. The NPC/DEIR noted that MassDEP is still
processing the Superseding ORAD, which will determine the resource area boundaries on the site.
Project plans provided with the NPC/DEIR depicted resource areas consistent with MassDEP’s findings
at the site investigations for the Superseding ORAD. Comments from MassDEP indicate the
Superseding ORAD will be issued upon issuance of the MEPA Certificate. I note that a Superseding
ORAD is not considered an Agency Action as defined at 301 CMR 11.03, and as such, may be issued
prior to the completion of the MEPA review process.

The project will create 9.54 acres of impervious area (14.16 total acres). The NPC/DEIR
indicated the stormwater model was updated to account for the project changes, including the addition of
Jericho Hill II and the revised project layout. The stormwater management system will incorporate the
following Best Management Practices (BMPs): bioretention swales, subsurface detention basins, hooded
deep sump catch basins, and structural water quality units. The NPC/DEIR indicated the project will be
considered a redevelopment per the MassDEP SMS and acknowledged that the site access road is
considered a Land Use with Higher Potential Pollutant Loads (LUHPPL) for the purposes of applying
the SMS. As such, the stormwater management system has been designed with suitable BMPs to treat
the one inch water volume and provide adequate treatment prior to infiltration. The NPC/DEIR indicated
the project will improve drainage conditions on abutting properties through installation of a drainage
swale along the eastern side of the property line and site grading along the southern edge of the property
which will intercept stormwater runoff from the site and direct it to the on-site drainage system.

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The project is required to comply with the Total Maximum Daily Load (TMDL) for nutrients in
the Upper/Middle Charles River, which requires no additional inputs of phosphorous to the river and a
significant reduction from existing development. The NPC/DEIR provided phosphorus load calculations
which indicate that the project will result in a post-development export of approximately 16 lbs/year of
phosphorous. I refer the City to comments from the Charles River Watershed Association (CRWA)
which encourage additional use of surface biofiltration strategies to ensure compliance with the TMDL.
The NPC/DEIR indicated that site constraints (such as large amounts of cut land, proximity to
groundwater and wetland resources, steep slopes, and compact site design footprint) limit opportunities
to incorporate bioretention and water quality swales to further reduce nutrient loads.

Currently, all stormwater that leaves the site eventually discharges to Chester Brook. The on-site
intermittent stream is a tributary that also discharges to Chester Brook. The project includes earthwork
and 280 lf of bedrock cuts (i.e. rock walls) located parallel to and approximately 50-ft south of the
intermittent stream. The NPC/DEIR indicated that this work is not anticipated to impact surficial flow
within the stream channel due to the 50-ft setback distance and the lower bedrock wall heights in this
area (ranging from 0 to 40-ft high). Earthwork and the rock wall will cut off flows from a 0.4 acre
portion of the intermittent stream’s contributing watershed (20.39 total acres). The flows from this area
will combine with the rest of the site’s runoff and will ultimately still discharge to Chester Brook. The
NPC/DEIR indicated that this reduction is insignificant (2% of the existing intermittent stream
watershed) and that the loss of tributary area is not anticipated to adversely affect the wetland system.
The NPC/DEIR noted that potential impacts from existing fractures and/or joints within the bedrock will
be further evaluated relative to possible impacts to surficial flow within the stream channel as project
design progress.

Depths to groundwater across the site vary from between 1- to 12.5-feet in test pits and 8.2- to
12.5-feet in best borings. Portions of the rock wall, building, and below-grade parking structure will be
below groundwater elevations. The project includes a permanent, below-slab and perimeter foundation
system and a piped drainage system along the base of the rock wall to collect groundwater and
incorporate it into the stormwater management system. The NPC/DEIR indicated that a series of test
borings with observation wells and groundwater pump tests will be conducted to further understand
hydrogeologic conditions in the bedrock and groundwater flow rates and to further evaluate groundwater
flow and direction.

Traffic/Transportation

The NPC/DEIR indicated that trip generation and the number of parking spaces were revised to
account for 360 additional trips and the elimination of 100 parking spaces associated with repurposing
the existing high school. The NPC/DEIR confirmed that the Traffic Impact Analysis (TIA) previously
included the future reuse of the existing high school as part of the future build conditions. The project
will result in 1,851 new adt and 454 new parking spaces (650 total parking spaces). Approximately 450
of the 650 total parking spaces will be provided in a subsurface parking garage below the artificial turf
field. Many comment letters on the ENF identified concerns with increased congestion on Lexington
Street and referenced a report to the Waltham Traffic Commission which indicated the project will
significantly increase traffic on Lexington Street to a point where it may exceed the street’s capacity.
The NPC/DEIR provided a response to the analysis performed by the City Traffic Commission.

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As noted in the ENF, the project will signalize the site driveway’s intersection with Lexington
Street and installation of turning lanes on Lexington Street to mitigate the project’s transportation
impacts. The City proposes to increase the design speed on Lexington Street and to eliminate existing
bike lanes on Lexington Street to accommodate the addition of turning lanes. A shared bike lane will be
incorporated into the northern lane to offset the elimination of the dedicated bike lane. The NPC/DEIR
indicated this portion of Lexington Street cannot accommodate both an exclusive bike lane and the
proposed turning lanes without private land takings (presumably to widen the right of way). The
NPC/DEIR did not provide figures or additional documentation to support this. I refer the City to joint
comments from MassBike/WalkBoston and others which identify concerns that vehicle accommodations
are being provided at the expense of the safety of bicyclists and pedestrians, especially given the
increase in design speed along Lexington Street. I expect the City will continue to evaluate and will MEPA 1
commit to measures that will improve safety for bicyclists and pedestrians along this corridor. These
measures should be specifically identified in the FEIR and incorporated into the draft Section 61
Findings.

The NPC/DEIR indicated the City will investigate implementing adaptive signal control
technologies at the signalized intersections along the Lexington Street corridor. I encourage the City to
implement this measure which may reduce congestion and improve traffic operations in the area. The
NPC/DEIR did not clarify whether the other measures identified in the TIA to improve operations on the
Woodcliff Drive and Forest Street approaches, and at the Lexington Street/Lake Street/Bishops Forest
Drive and Lexington Street/Existing School Exit Only Driveway intersections will be implemented as
part of this project. This should be clarified in the FEIR and these measures should be incorporated into MEPA 2
the draft Section 61 Findings.

Climate Change

The NPC/DEIR provided an analysis of stationary- and mobile-source GHG emissions and
identified measures to mitigate the project’s GHG impacts. As described below, it also included a
general discussion of vulnerabilities of the site to the potential effects of climate change.

Greenhouse Gas Emissions

The NPC/DEIR included an updated GHG analysis based on the MEPA Greenhouse Gas Policy
and Protocol (the Policy). The GHG Policy requires projects to quantify carbon dioxide (CO2) emissions
and identify measures to avoid, minimize or mitigate such emissions. The analysis quantified the direct
and indirect CO2 emissions associated with the project's energy use (stationary sources) and
transportation-related emissions (mobile sources). The DEIR outlined and committed to mitigation
measures to reduce GHG emissions. The stationary source GHG analysis evaluated CO2 emissions for
two alternatives as required by the Policy; the Base Case and the Design Case. The Base Case was
designed to meet the minimum energy requirements of the 9th Edition of the Massachusetts Building
Code, which references the American Society of Heating, Refrigerating and Air-Conditioning Engineers
(ASHRAE) 90.1-2013. The Design Case included additional energy-efficiency measures proposed in the
Preferred Alternative. The City of Waltham has adopted the Massachusetts Stretch Energy Code (SC).
Therefore, the project will be required to meet the applicable version of the SC in effect at the time of
construction. The SC requires at least a 10-percent reduction in energy use compared to the base

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Building Code requirements. According to the NPC/DEIR, the Town intends to design the project to
exceed the energy efficiency requirements of the Building Code by at least 20%, which will make it
eligible for an additional reimbursement from the MSBA. I refer the City to comments from DOER MEPA 3
which indicate that the SC will include several new amendments that will become effective in August of
this year. The NPC/DEIR indicated that an updated energy modelling analysis based on the new
Building Code will be conducted during the design development phase.

The GHG analysis used eQuest modeling software to quantify stationary source emissions from
the project. The NPC/DEIR included a summary of modeling inputs (e.g., R-values, U-values,
efficiencies, lighting power density, etc.) for both the Base Case and Preferred Alternative. The
NPC/DEIR identified those energy efficiency measures that will be incorporated into the project and
were modeled in the GHG analysis, measures that were dismissed as infeasible or inappropriate (solar
hot water, solar PV, ground source heat pumps, cogeneration, fuel cells), and measures that will be
studied further during the advanced design stages. As presented in the NPC/DEIR, key building related
energy efficiency measures proposed for the buildings include:
 High-performing building envelope insulated beyond Code (wall assembly U-factor=0.0357;
roof assembly U-factor=0.0208);
 High-performing lighting systems and controls beyond Code, including reduced Lighting Power
Densities (LPD) (0.5 watts/square foot), daylight and vacancy controls, and advanced digital
lighting controls;
 Solar-ready rooftop and electrical system;
 Electric-Vehicle (EV) charging stations for 2% of parking spaces;
 A high efficiency mechanical HVAC system including:
o Direct Outside Air Ventilation System (DOAS) with heat recovery (design effectiveness
of 70% or better);
o High efficiency air cooled chiller;
o Demand control ventilation for all occupied spaces;
o Temperate setback during unoccupied hours;
o VFDs on pumps;
o High performance condensing natural gas boilers (95% efficiency); and
o High performance natural gas hot water boiler.

The NPC/DEIR included a commitment to design the rooftop and electrical system to be solar
ready. It did not include a commitment to install or reserve rooftop space for a solar PV system. The
NPC/DEIR noted that solar PV is not considered for the project as the City of Waltham cannot commit
to rooftop PV at this time. It did not provide a feasibility analysis or financial assessment to support its
dismissal. Additional analysis of solar PV is required in the FEIR. The NPC/DEIR indicated that MEPA 4
repurposing the existing high school facility will not occur until 2023 at the earliest. The City will
maintain and upgrade the building systems as needed until substantial retrofits are proposed as part of
the building’s reuse. The NPC/DEIR identified energy conservation measures that will be considered as
part of future upgrades and retrofits.

The NPC/DEIR indicated the City will encourage and promote a Transportation Demand
Management (TDM) program to reduce mobile source GHG emissions. The TDM program may include
the following measures:
 Encouraging and incentivizing the use of buses;

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 Limiting bus and vehicle idling at the school;

 Providing improved site circulation and intersection design to reduce idling times for vehicles;
 Encouraging the use of bicycles and pedestrian traffic to the school and providing numerous
secure bike racks/storage;
 Providing vehicle charging stations for electrical vehicles;
 Offering preferred parking for carpool and low emission vehicles; and
 Providing assigned parking spaces to minimize travel time on-site.

The TDM plan was not included as a mitigation commitment nor incorporated in the draft
Section 61 Findings. The City’s commitment to implement the above TDM programs should be clarified MEPA 5
in the FEIR.

Mobile GHG emissions were estimated using the standard methodology in the
EEA/MassDOT Guidelines for EIR/EIS Traffic Impact Assessments and MOVES CO2 emission factors.
Mobile source GHG emissions were calculated for the 2024 No Build Condition, 2024 Build without
TDMs Condition, and 2024 Build with TDMs Condition. There are discrepancies in the analysis as the
NCP/DEIR states that the 2024 Build Case includes roadway mitigation measures but not TDMs. This MEPA 6
discrepancy should be clarified in the FEIR. Additionally, the NPC/DEIR indicated that the 2024 No
Build and 2024 Build cases both include emissions associated with new project-generated trips in
addition to existing background traffic. It is unclear why project-generated emissions are included in the
2024 No Build scenario. Mobile source GHG emissions were calculated by subtracting the 2024 No
Build values from those for the 2024 Build Cases. To accurately understand the mobile source GHG MEPA 7
emissions associated with the project, the FEIR should exclude project-generated trips from the 2024 No
Build Condition and should compare the GHG emissions associated with the 2024 Build Condition
(with no roadway improvements or TDM measures) to the 2024 Build with Mitigation Condition (i.e.
with roadway improvements and TDM measures), and propose additional mitigation measures, if
necessary.

The GHG analysis indicates that the project will generate approximately 2,283 tons per year
(tpy) of stationary source Base Case emissions. The Preferred Alternative, developed to demonstrate
consistency with the Policy and the SC, will reduce stationary source emissions by 755 tpy, an
approximate 33% reduction. Mobile source GHG emissions should be reevaluated in in the FEIR. MEPA 8

The NPC/DEIR modeled and conducted a 50-year life cycle cost analysis (LCCA) for an
alternative that incorporated triple glazed window systems and two alternative HVAC systems: System
2: DOAS/variable air volume (VAV) and 4-pipe fan coil unit (FCU) with high efficiency natural gas
condensing boilers, and System 3: DOAS/heat recovery and VRF (air source heat pump; ASHP) for
heating and cooling (all electric). System 3 generally replaces proposed fossil fuel equipment with
efficient electrification. Comments from DOER also note that maximizing electrification of space and
water heating can significantly reduce the project’s energy use and GHG emissions over time. The triple
glazed window system alternative would contribute to a 19 tpy (1%) reduction in GHG emissions. The
City has included triple glazing to be priced as an alternate due to the high first costs and payback period
which extends beyond the 50-year life cycle. The alternative HVAC System 2 would contribute to an
additional 118 tpy reduction in GHG emissions (5.2%) and System 3 would contribute to an additional
444 tpy reduction in GHG emissions (19.5%). The NPC/DEIR indicated the City dismissed these
alternatives based on their facility management preferences on maintenance and experience with natural

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gas heating over the all-electric ASHP heating system. Comments from DOER request evaluation of a
scenario that examines electrification of space heating in conjunction with a more improved building
envelope. Additional analysis of this scenario is required in the FEIR. MEPA 9

Adaptation and Resiliency

The City of Waltham is a participant in the Commonwealth’s Municipal Vulnerability

Preparedness (MVP) program. The MVP program is a community-driven process to define natural and
climate-related hazards, identify existing and future vulnerabilities and strengths of infrastructure,
environmental resources and vulnerable populations, and develop, prioritize and implement specific
actions the municipality can take to reduce risk and build resilience. The NPC/DEIR indicated the City
is currently developing a Hazard Mitigation Plan and a Municipal Vulnerability Plan (MVP). The
NPC/DEIR indicated the site is vulnerable to the following climate change related events: winter storms,
high winds, flooding, heat waves, droughts, and brush fire. The project has incorporated the following
elements to minimize impacts from these vulnerabilities: light colored roof, vegetated green roof (3% of
total roof area), covered parking area, native and drought resistant plantings, solar-ready rooftop, electric
vehicle (EV) charging for 2% of parking spaces, emergency generator, and limited irrigation to reduce
outdoor water use. The NPC/DEIR did not include a discussion of future climate conditions nor evaluate
or specify whether the stormwater management system was designed to account for the potential
impacts of increased precipitation frequency and volume due to climate change. This should be provided MEPA 10
in the FEIR.

According to the NPC/DEIR, the new high school building will be designed to be certifiable at
the silver level by the LEED (version 4; v4) rating system. The NPC/DEIR included a copy of the
preliminary LEED scorecard (Appendix 9.3) that identified the project design criteria and associated
credits under consideration for the project. I note the NPC/DEIR indicated the construction of on-site
sidewalks and bikeway that connect to a public way and the provision of bike racks for 5% of the
building occupants as design criteria incorporated to achieve Sustainable Sites / Location and
Transportation LEED credits. These provisions appear to be inconsistent with plans disclosed in the
NPC/DEIR to eliminate exclusive bike lanes along Lexington Street. This should be addressed in the MEPA 11
FEIR, along with any additional mitigation measures that may be warranted to encourage non-vehicular
(bicycle) travel to and from the site as part of TDM measures to offset transportation impacts.

Water Supply/Wastewater

The FEIR described the off-site improvements to the City’s water and wastewater infrastructure
and provided conceptual figures and plans for these improvements, including replacement of the 4,900
linear foot (lf) water main in Lexington Street and reconstruction of 375 lf of sewer main in Stanley
Road. As previously described in the ENF, the City’s sewer system eventually conveys flows to the
Massachusetts Water Resources Authority’s (MWRA) Deer Island Treatment Plant.

The DEIR stated that the total wastewater generation at the new high school (554 Lexington
Street) has not changed since the ENF was filed (41,460 gpd). The DEIR included a memo from the City
Engineer (Appendix 7.1) which stated that existing wastewater flow at the site is 1,866 gpd (based on
review of water meter data). However, the DEIR stated that existing wastewater flow at the site is
14,945 gpd. The project will increase wastewater generation at this location by 26,515 gpd to 39,594

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

gpd, depending upon which number is used to for existing flow. The DEIR indicated that the future
reuse of the existing high school (617 Lexington Street) will decrease wastewater generation at that
location by 21,940 gpd. The DEIR indicated that total and net new wastewater demand at the new high
school (554 Lexington Street) will remain unchanged from the ENF (47,000 gpd and 30,550 gpd,
respectively). The DEIR did not provide updated calculations based on actual water meter data, which
would result in an increased water demand for this location. The DEIR indicated that the future reuse of
the existing high school (617 Lexington Street) will decrease water demand at that location by 24,170
gpd.

The memo from the City’s Engineer and comments from MWRA state that approximately
158,376 gpd of infiltration and inflow (I/I) will need to be removed (calculated based on an increase in
wastewater flows of 39,594 gpd) in order to achieve the 4:1 I/I removal rate required by MassDEP
regulations and City. The memo from the City’s Engineer stated that that the City has accumulated a bank of
sewer gallons through private I/I mitigation projects that can be applied to City projects like this one.
According to the memo, the sewer bank has adequate gallons to accommodate the Project and a withdrawal
of 158,376 gallons will be credited to the City.

Construction Period

According to the NPC/DEIR, the project will be constructed in multiple phases over the course
of four years, as follows: Phase 1: June 2020 – October 2020: Abatement and demolition of existing
buildings; Phase 2: October 2020 – October 2021: Site clearing, tree and rock removal (blasting), site
benching, potential traffic controls; Phase 3: August 2021 – June 2024: Construction of new high
school, parking area, and athletic fields; and Phase 4: September 2024 – Open new high school to
students. The NPC/DEIR included a draft construction management plan (Section 10) that outlined
mitigation measures that will be implemented during the project to avoid or minimize impacts associated
with construction traffic, noise and vibration, stormwater, air quality, rodent control, and other impacts.
Mitigation measures identified in the NPC/DEIR include: erosion and sedimentation control measures,
designated truck routes, scheduling deliveries during non-peak hours, noise and vibration control
measures, dust control measures, prohibition of excessive idling of construction equipment,
development of a rodent control program, and a commitment to reuse or recycle a minimum of 75-
percent of construction debris. Groundwater encountered during construction will be pumped out of the
excavations to a recharge pit where it will be recharged into the ground. In the event the groundwater is
not absorbed, the contractor will pump the groundwater to a sedimentation tank, filter it through silt
sacks, and discharge it to the City’s sewer system.

The project will require the removal of 747,000 cy of material from the site. The NPC/DEIR
indicated that blasting operations and onsite crushing/processing of material will continue for
approximately twelve months. According to the NPC/DEIR, forty to seventy truckloads of material will
be exported from the site each day during this time. The anticipated truck route is Lexington Street to
Totten Pond Road to Interstate-95 (I-95). The ENF previously indicated that the construction period
traffic will not have a significant impact on traffic flow or operations. All construction traffic will be
coordinated to avoid peak commuter rush hours and adjacent school drop off and pick up times to the
greatest extent practicable.

The NPC/DEIR noted that compliance with the Construction Monitoring Plan will be monitored
through field inspection, meeting minutes, and periodic updates. Many comments request that I mandate

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

monitoring of construction period impacts by independent third parties or that I appoint a community
liaison. While I strongly encourage the City to closely monitor construction period impacts and
communicate with abutters and residents, this is an issue that is more appropriately addressed during
review of the project at the local level. I also expect full compliance with MassDEP regulations
governing noise, idling, air quality and other impacts. Comments from residents continue to identify
concerns regarding the potential impacts of blasting. As noted in the NPC/DEIR, the project must
comply with the blasting regulations pursuant to 527 CMR 1.00 which identify requirements for a blast
analysis, blast design plan, pre-blast inspection surveys, allowable limits of effects of blasting, and
blasting regulatory review. The NPC/DEIR indicated the City has voluntarily expanded the radius of the
pre-blast inspection survey from 250-ft to 500-ft. The City does not restrict the noise from blasting or
crushing operations. The NPC/DEIR indicated the project team is analyzing preferred locations for this
equipment to minimize impacts on all abutters and to identify potential sound proofing or sound
mitigation measures such as constructing sound barriers around the equipment. Additional information MEPA 12
on these noise mitigation measures is required in the FEIR.

Conclusion

The MEPA regulations indicate that, upon review of a draft EIR, I may determine that the DEIR
is adequate, even if certain aspects of the Project or issues require additional description or analysis in a
final EIR, provided that I find the DEIR is generally responsive to the requirements of 301 CMR 11.07
and the Scope. Certain aspects of the Project or issues require additional description or analysis and will
be addressed in the FEIR. Based on a review of the NPC/DEIR, the Scope for the DEIR, consultation
with State Agencies, and review of comment letters, I have determined that the NPC/DEIR adequately
and properly complies with MEPA and its implementing regulations. The Scope below identifies
additional analysis and information that should be provided in the FEIR.

SCOPE

General

The FEIR should follow Section 11.07 of the MEPA regulations for outline and content, as
modified by this Scope. The FEIR should clearly demonstrate that the City has sought to avoid, MEPA 13
minimize and mitigate Damage to the Environment to the maximum extent feasible. I expect the FEIR MEPA 14
will provide a comprehensive response to comments on the NPC/DEIR that specifically address each
issue raised in the comment letter; references to a chapter or sections of the FEIR alone are not adequate
and should only be used, with reference to specific page numbers or subsections, to support a direct
response. The FEIR should identify measures the City will adopt to further reduce the impacts of the
project since the filing of the NPC/DEIR, or, if certain measures are infeasible, the FEIR should discuss MEPA 15
why these measures will not be adopted.

The information and analyses identified in this Scope should be addressed within the main body MEPA 16
of the FEIR and not in appendices. In general, appendices should be used only to provide raw data, such
as drainage calculations, traffic counts, capacity analyses and energy modelling, that is otherwise
adequately summarized with text, tables and figures within the main body of the FEIR. Information
provided in appendices should be indexed with page numbers and separated by tabs, or, if provided in

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

electronic format, include links to individual sections. Any references in the FEIR to materials provided MEPA 17
in an appendix should include specific page numbers to facilitate review.

Project Description and Permitting

The FEIR should include an updated description of the proposed project and describe any
changes to the project since the filing of the NPC/DEIR. The FEIR should identify, describe, and assess MEPA 18
the environmental impacts of any changes in the project that have occurred between the preparation of
the NPC/DEIR and FEIR. The FEIR should include updated site plans for existing and post- MEPA 19
development conditions at a legible scale. The FEIR should provide a brief description and analysis of
applicable statutory and regulatory standards and requirements, and describe how the project will meet
those standards. It should include a list of required State Permits, Financial Assistance, or other State MEPA 20
approvals and provide an update on the status of each of these pending actions. The FEIR should include MEPA 21
an update on local, regional or federal permitting as applicable. The FEIR should clarify the projected MEPA 22
net net increase in water demand and wastewater flow. It should clarify whether the natural field will be MEPA 23
used for overflow parking, and if so, the anticipated frequency with which this will occur.

The NPC/DEIR described the following access points to the site: two separate primary access
driveways on Lexington Street (separated entrance and exit driveways), a secondary 40-ft wide exit to
Lexington Street, and 20-ft wide secondary emergency access drive connecting the site to an adjacent
off-site 20-ft wide easement. The FEIR should clarify whether the 40-ft wide access road to Lexington MEPA 24
Street (located north of the main entrance to the site) will be gated and used only for emergency access
or whether it will serve as a secondary access point. This access road should be depicted on project plans
and figures. I note that I received many comments that identify concerns with the City’s proposal to use
a 20-ft wide water, sewer, and drain easement (Lincoln Street Extension) as a secondary emergency
access drive. The FEIR should include specific references to the deed language that supports using the MEPA 25
infrastructure easement as an emergency access roadway. It should clarify whether additional clearing or
road widening is necessary to enable access by fire trucks. It should also clarify whether the City will
need to acquire additional rights to use the easement as an emergency access road either through
purchase or an eminent domain taking. The project plans depict steep topography on the project site near
this easement. The FEIR should clarify how stormwater from the site will be collected to avoid MEPA 26
exacerbating flooding on adjacent off-site properties.

The NPC/DEIR indicated Lexington Street cannot accommodate both an exclusive bike lane and
the proposed turning lanes without private land takings (presumably to widen the right of way). The MEPA 27
FEIR should identify the width of the right of way and the proposed roadway cross section along this
location. The FEIR should identify alternative means to encourage bicycle travel to align with the
City’s commitment to installing bicycle racks on site.

Alternatives Analysis

The ENF and NPC/DEIR indicated that proposed alternatives were evaluated against criteria
established by the School Building Committee, including the site’s ability to allow adequate space to
provide for the master plan which includes the school, 650 parking spots, and room for future expansion
and relocation of as many off-site athletic fields to the site as possible/practical. The project site was
selected in part because it met these criteria. The FEIR should clarify whether this is still applicable

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

given that the Jericho Hill II Parcel was incorporated into the site to enable revisions that would
eliminate development from the northeastern portion of the site. To the extent the potential for future MEPA 28
expansion is no longer a project goal, the City should address how this would impact the prior analysis
of other locations considered for the site which would not require the use of designated public open
space.

Land Alteration/Drainage

As noted above, the revised layout allows the existing natural field and north-central portion of
the site to remain as undisturbed wooded area. Many comment letters identify concerns about
development of open space which provides valuable natural resources and note that the project site (554
Lexington Street) was identified in the City’s Open Space and Recreation Plan as a priority area for
protection. The City should address in the FEIR whether it will consider placing a conservation MEPA 29
restriction on the portion of the site which will remain undeveloped, or at an alternative off-site location,
to permanently protect such land as publicly accessible open space.

The FEIR should include a more detailed narrative discussion of the stormwater management MEPA 30
system and stormwater conveyance from the project site to Chester Brook. This should address how and
where flows from the 0.4 acre portion of the stream’s watershed combine with the rest of the site’s
runoff prior to discharge to Chester Brook. The FEIR should clarify the source data for the design
storms used to design the stormwater management system. As discussed below, the City should evaluate
sizing the stormwater management system to account for the potential impacts of increased precipitation
frequency and volume due to climate change. I received comments from abutters that identify concerns
the project will exacerbate flooding conditions. The NPC/DEIR indicated the project team will continue
to investigate sources of [flood] water and will implement additional mitigation strategies where feasible
so that the project improves conditions to the abutting properties. The FEIR should provide an update on MEPA 31
this investigation and should identify any additional mitigation measures that were incorporated into the
project. The NPC/DEIR noted that potential impacts from fractures and/or joints within the bedrock will
be further evaluated to determine potential impacts to surficial flow within the stream channel. The MEPA 32
FEIR should provide an update on this evaluation and identify a timeline for its completion.

Comment letters identify concerns regarding the presence of Per- and polyfluoroalkyl substances
(PFAS) in the synthetic turf field. The NPC/DEIR indicated that the turf field will be in accordance MEPA 33
with MassDEP regulations for PFAS but did not identify the applicable regulations or explain how the
project would comply. This should be addressed in the FEIR.

Climate Change

Governor Baker’s Executive Order 569: Establishing an Integrated Climate Change Strategy for
the Commonwealth (EO 569; the Order) was issued on September 16, 2016. The Order recognizes the
serious threat presented by climate change and direct Executive Branch agencies to develop and
implement an integrated strategy that leverages state resources to combat climate change and prepare for
its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits
established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state
government and cities and towns for the impacts of climate change. The MEPA statute directs all State
Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other
administrative approvals and decisions. M.G.L. c. 30, § 61.

The GHG Policy and requirements to analyze the effects of climate change through EIR
review play an important role in this statewide strategy. These analyses advance proponents’
understanding of a project’s contribution and vulnerability to climate change.

Greenhouse Gas Emissions

The FEIR should include a revised GHG analysis which reflect any changes to the project since
the NPC/DEIR. New construction offers many opportunities for building shell and mechanical system
improvements and I expect the City will reconsider these measures to maximize the potential benefits of MEPA 34
this new $122 million dollar construction. The project will be required to meet the version of the
Building Code in effect at the time of construction. As noted in the NPC/FEIR and confirmed by
DOER, an update to the Stretch Code (SC) will become effective in August 2020. The underlying code
provisions will not change. The SC to take effect in August is based on ASHRAE 90.1-2013-Appendix
G. However, there will be several new, or changed, Massachusetts amendments. I encourage the City MEPA 35
to utilize the updated SC as it updates its GHG emissions calculations to accurately evaluate the GHG
reduction benefits provided by proposed mitigation measures.

As requested by DOER, the FEIR should evaluate a scenario which includes electrification of MEPA 36
space heating with an improved envelope. This scenario should evaluate whether additional
improvements to the envelope could potentially eliminate or downsize HVAC systems. The FEIR MEPA 36
should include a LCCA for this scenario and the scenario where the currently proposed building will be
retrofitted to electric heating in the future. I refer the City to comments from DOER for additional
guidance on this issue.

The City has committed to construct the building with solar-ready construction. The FEIR should MEPA 37
provide a solar PV feasibility analysis that addresses the following:
 Include an estimate of available roof area for development of solar PV;
 Include a cost analysis to determine the overall financial feasibility of installation of solar,
including potential payback periods;
 Propose an installation that can be supported by the maximum available roof area (excluding
areas dedicated for mechanical equipment);
 State the assumed panel efficiency;
 Estimate electrical or thermal output of the potential system; and
 Estimate annual GHG reductions of renewable energy versus electricity or natural gas.

The analysis should provide conceptual roof plans that identify the “usable areas” for potential
solar PV systems, rooftop HVAC equipment, and other appurtenances. The plans and an accompanying MEPA 38
table should identify the extent of the roof that is required to be “solar ready” in order to comply with
Building Code requirements after August 2020 (as applicable), the total rooftop area, and the maximum
usable roof area for a solar installation. The analysis should include a narrative and data to support the
adoption or dismissal of solar PV as a feasible measure to avoid, minimize or mitigate project-related
GHG emissions and Damage to the Environment.

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

The FEIR should include a revised mobile source GHG analysis incorporates any changes to the MEPA 39
TDM program and/or traffic mitigation measures. The FEIR should identify the specific roadway
mitigation measures and TDM measures that are reflected in the analysis and these mitigation measures
should be incorporated into the draft Section 61 Findings. The TDM program provided in the
NPC/DEIR noted the City will encourage the use of bicycles and pedestrian traffic to the school and
provide numerous secure bike racks/storage. It also stated that the Massachusetts Safe Routes to School
(SRTS) Program will be included as part of the sustainability measures that will be implemented for the
project. 5 The FEIR should clarify this commitment. The FEIR should expand upon the information MEPA 40
presented in the NPC/DEIR to demonstrate a clear commitment to promoting safe and accessible MEPA 41
pedestrian and bicycle access for students to and throughout the project site. It should include graphics
(and supporting narrative) depicting internal circulation patterns (vehicles, pedestrian, and bicycles) and
connection points to adjacent land uses and access roadways. Measures to promote safe and accessible
pedestrian and bicycle access (including participation in the SRTS Program) should be incorporated into
the draft Section 61 Findings.

Adaptation and Resiliency

The Northeast Climate Science Center at the University of Massachusetts at Amherst has
developed projections of changes in temperature, precipitation and sea level rise for Massachusetts. The
FEIR should identify the projected changes in temperature and precipitation for the Charles River Basin
using this data which is available through the Climate Change Clearinghouse for the Commonwealth
at www.resilientMA.org. I expect that the City will consider recent data identifying increases in climate
change-induced storm intensity and precipitation volumes to design an appropriately-sized stormwater
system to convey each design storm event. The stormwater management system will also be used to
convey groundwater flow from the below-slab and perimeter foundation system and drainage system
along the base of the rock wall. The FEIR should address how the projected change in precipitation may MEPA 42
impact groundwater levels, flow rates, direction, and flooding. The FEIR should include a narrative MEPA 43
discussion about how existing and future groundwater flow volumes above the invert elevations were
accounted for and incorporated into the design of the stormwater management system. This evaluation
should consider the future effects of climate change. The FEIR should also provide an update on the MEPA 44
results of any additional test borings and groundwater pump tests that have been performed since the
NPC/DEIR was submitted and a timeline for conducting any additional tests to better understand
hydrogeologic conditions in the bedrock and groundwater flow rates and direction.

Construction Period

I received numerous comment letters that express concerns regarding noise, vibration, and traffic
impacts associated with earthwork, blasting, and rock crushing during construction. According to the
NPC/DEIR, construction activity will occur between 7:00 AM and 5:00 PM weekdays and 8:00 AM to
4:00 PM on Saturdays. Blasting will occur between 8:00 AM to 4:00 PM on weekdays for a continuous
twelve month period. No blasting will occur on Saturdays, Sundays, or holidays. The FEIR should MEPA 45
clarify whether noise or dust from construction activities will create a nuisance condition by interfering
with enjoyment of property. I strongly encourage the City to consider reduced construction hours to
minimize construction-related impacts to nearby residences. The FEIR should continue to analyze MEPA 45

5The SRTS Program is a federally funded initiative of the Massachusetts Department of Transportation (MassDOT) that
encourages elementary and middle school students to safely walk and bike to/from school.

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

potential noise and vibration impacts associated with blasting and crushing operations, and propose
appropriate mitigation measures. The NPC/DEIR indicated that the project team is modeling the noise
generating equipment and is analyzing preferred locations for equipment to minimize impacts on
abutters and to identify potential sound proofing measures such as sound barriers around equipment.
The FEIR should provide an update on this analysis and should identify specific mitigation measures MEPA 46
that will be implemented to address these impacts.

The FEIR should provide a figure identifying the approximately 500-ft pre-blast inspection MEPA 47
survey radius or identify when this information will become available and how it may be viewed by
stakeholders. The FEIR should describe the blasting notification procedure for abutters to be used by the MEPA 48
contractor. It should identify an approximate timeframe for completing the pre-blast surveys. The FEIR MEPA 49
should provide details of how the survey will be conducted and clarify whether property owners will be
provided with copies of the completed survey. It should also identify a process for addressing noise,
vibration, or dust complaints from abutters during the construction phase of the project.

The FEIR should address how the project will ensure compliance with the Massachusetts Idling MEPA 50
regulation at 310 CMR 7.11. Because this project will occur in close proximity to residential areas, I
urge the City to minimize potential noise and air quality impacts by requiring that construction vehicles
limit engine idling, use ultra-low sulfur diesel fuel, and be retrofit with emissions control equipment,
including emission control equipment identified in the Commonwealth’s Clean Air Construction
Initiative.

Mitigation and Draft Section 61 Findings

The FEIR should include a section that summarizes all proposed mitigation measures and MEPA 51
provides draft Section 61 Findings for each State Agency Action. It should contain clear commitments
to implement these mitigation measures, estimate the individual costs of each proposed measure,
identify the parties responsible for implementation, and contain a schedule for implementation.

In order to ensure that all GHG emissions reduction measures adopted by the Proponent as the
Preferred Alternative are actually constructed or performed by the Proponent, the Secretary requires
proponents to provide a self-certification to the MEPA Office indicating that all of the required
mitigation measures, or their equivalent, have been completed. The commitment to provide this self- MEPA 52
certification in the manner outlined above should be incorporated into the draft Section 61 Findings
included in the FEIR.

Response to Comments

The FEIR should contain a copy of this Certificate and a copy of each comment letter received. MEPA 53
In order to ensure that the issues raised by commenters are addressed, the FEIR should include direct
responses to comments to the extent that they are within MEPA jurisdiction. This directive is not
intended, and shall not be construed, to enlarge the scope of the FEIR beyond what has been expressly
identified in this certificate.

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

Circulation

The Proponent should circulate the FEIR to those parties who commented on the ENF or
NPC/DEIR, to any State and municipal agencies from which the City will seek permits or approvals, and
to any parties specified in section 11.16 of the MEPA regulations. Per 301 CMR 11.16(5), the City may
circulate copies of the FEIR to commenters in CD-ROM format or by directing commenters to a project
website address. However, the City must make a reasonable number of hard copies available to
accommodate those without convenient access to a computer and distribute these upon request on a first-
come, first-served basis. The City should send correspondence accompanying the CD-ROM or website
address indicating that hard copies are available upon request, noting relevant comment deadlines, and
appropriate addresses for submission of comments. The FEIR submitted to the MEPA office should
include a digital copy of the complete document. A copy of the FEIR should be made available for
review at the Waltham Public Library. 6

June 26, 2020 ________________________

Date Kathleen A. Theoharides

Comments received:

5/27/2020 Anonymous 6/1/2020 Nadene Stein

6/1/2020 Alicia Hutton 6/1/2020 Rebecca Cyr
6/1/2020 Alison Guzman 6/1/2020 Ron Ayers
6/1/2020 Angie Benoit 6/1/2020 Sarah Remage-Healey
6/1/2020 Anonymous 6/1/2020 Tom King
6/1/2020 Brandice Proskoczilo 6/1/2020 Valerie Sharp
6/1/2020 Carol Baclawski 6/2/2020 Amy Corbett
6/1/2020 Celeste Woodside 6/2/2020 David Westner (1 of 2)
6/1/2020 Christin Piccirilli 6/2/2020 Jaclyn Davidson
6/1/2020 Christina McCalla 6/2/2020 Kathleen Simpson
6/1/2020 Christy Kahana 6/2/2020 Robert Hanley
6/1/2020 Donald Lucente 6/3/2020 Elizabeth Homan
6/1/2020 Donna Fils-Aime 6/3/2020 Elizabeth Lear
6/1/2020 Donna Weitz 6/3/2020 Jennifer Roy
6/1/2020 Jeffrey Esposito 6/4/2020 Heather Johnson
6/1/2020 Jose Guzman 6/4/2020 Interim Superintendent George
6/1/2020 Kathi Martuza and Kester Cotton Frost
6/1/2020 Kit Fintzel 6/4/2020 Michelle Kern
6/1/2020 Kristen Mullin 6/4/2020 Rachel Weinstein (1 of 4)
6/1/2020 Lynelle Cortellini-Devine 6/4/2020 Rachel Weinstein (2 of 4)
6/1/2020 Melissa Abell-Bardsley 6/5/2020 Ben Kuchler
6/1/2020 Michelle Campbell 6/6/2020 Megan Letendre

6
Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 response.
Please consult the MEPA website for further details on interim procedures during this emergency period:
https://www.mass.gov/orgs/massachusetts-environmental-policy-act-office.

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EEA# 16097 NPC/DEIR Certificate June 26, 2020

6/8/2020 Amy Brown (1 of 3) 6/19/2020 Massachusetts Water Resources

6/8/2020 Amy Brown (2 of 3) Authority (MWRA)
6/8/2020 Amy Brown (3 of 3) 6/19/2020 Alysia Parkes
6/8/2020 Mayor Jeannette McCarthy 6/19/2020 Charles River Watershed
6/8/2020 State Rep. Thomas M. Stanley, Association (CRWA)
State Rep. John J. Lawn, State 6/19/2020 Erika Kuno
Senator Michael J. Barrett 6/19/2020 Isabel Brassil
6/10/2020 City Councilor Sean Durkee 6/19/2020 Jeannie Joe
6/10/2020 Laura Cannon 6/19/2020 Jennifer Rose
6/11/2020 Michele DesAutels 6/19/2020 Pat Seminara
6/12/2020 Orlando Medeiros 6/19/2020 Karen Pruy
6/12/2020 Waltham Historical Commission 6/19/2020 Karina Hines
6/15/2020 Christopher Matteodo 6/19/2020 Karina Hines
6/15/2020 Luisa Pandolfi 6/19/2020 Kristen Thibodeau
6/15/2020 Orlando Medeiros 6/19/2020 Margaret Schadelbauer
6/15/2020 Steve Wolff 6/19/2020 Massachusetts Department of
6/16/2020 Rachel Weinstein (3 of 4) Environmental Protection
6/17/2020 Bill Fowler (MassDEP)
6/17/2020 David King 6/19/2020 Massachusetts Historical
6/17/2020 Maureen Bagge Fowler Commission (MHC)
6/17/2020 Orlando Medeiros 6/19/2020 Mike Chen
6/17/2020 Paul Hughes 6/19/2020 Patricia Roche and David
6/17/2020 Philip Chorman Brountas
6/17/2020 Rachel Weinstein (4 of 4) 6/19/2020 Paul Katz
6/17/2020 Robert Hargrove 6/19/2020 Pradip Mallik
6/17/2020 Waltham Land Trust 6/19/2020 Rachel Gagne
6/18/2020 Alex Urquhart 6/19/2020 Robert Coleman
6/18/2020 Carolina Lara 6/19/2020 Shelli Barry
6/18/2020 Christine Reynolds 6/19/2020 Tammy Rose
6/18/2020 David Westner (2 of 2) 6/19/2020 Thomas Maclellan
6/18/2020 Doug MacDonald 6/19/2020 Larry Sumner
6/18/2020 Jacob Katz 6/19/2020 Carol Dunbar
6/18/2020 James Devin 6/19/2020 WalkBoston and MassBike
6/18/2020 Laura Urquhart 6/19/2020 Patrick Rooney
6/18/2020 Paula McNiece 6/19/2020 Zac Borrelli
6/18/2020 Reva Dolobowsky 6/19/2020 JP Jones
6/18/2020 Sharon Katz 6/19/2020 Kaj Telenar
6/18/2020 Susan Parrella 6/26/2020 Department of Energy Resources
6/18/2020 Tammy Inman (DOER)
6/18/2020 Tom Haley

KAT/PRC/prc

22
 Section 8: Responses to Comments

8.2 Massachusetts Water Resources Authority (MWRA)

MWRA 1

To ensure that the Project’s new wastewater flow does not increase surcharging and overflows in large storms,
the Proponent should fully offset the Project’s wastewater flows with I&I removal at the rate of four gallons
removed for every gallon of new wastewater flow, in compliance with MassDEP regulation at 314 CMR
12.04(2)(d) and in accordance with Town of Waltham’s I&I Mitigation City Ordinance.

Therefore, to achieve the 4:1 removal rate required by MassDEP and the City Ordinance, removal of 158,376
gpd of I&I from the wastewater system will be required.

Acknowledged

MWRA 2

Therefore, the discharge of groundwater and stormwater to the sanitary sewer system associated with this
Project is prohibited.

Acknowledged

MWRA 3

Any gas/oil separators in parking garages associated with the Project must comply with 360 C.M.R. 10.016 and
State Plumbing Code.

Acknowledged

Waltham High School | Final Environmental Impact Report 5 | p. 17

 June 19, 2020

Kathleen A. Theoharides, Secretary

Executive Office of Energy and Environmental Affairs
100 Cambridge St, Suite 900
Attn: MEPA Office, Page Czepiga
Boston, MA 02114

Subject: EOEEA #16097 – Draft Environmental Impact Report and

Notice of Project Change
Waltham High School, Waltham, MA

Dear Secretary Theoharides,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to

comment on the Draft Environmental Impact Report (DEIR) submitted by the City of Waltham
(the “Proponent”) for Waltham High School (the “Project”) in Waltham, Massachusetts. The
Project consists of the construction of a new High School to be located at 554 Lexington Street.
Since review of the Environmental Notification Form (ENF), an additional 6-acre parcel has
been added to the Project site to adjust the location of the building and athletic field in an effort
to avoid impacts to wetlands resource areas. Due to this addition, a Notice of Project Change
(NPC) is included with the DEIR. Additionally, the proposed future use of the existing Waltham
High School site at 617 Lexington Street has been included in the DEIR.

MWRA’s comments continue to related wastewater issues emphasizing the need for
Infiltration/Inflow (I/I) Removal and Discharge Permitting from the Toxic Reduction and
Control (TRAC) Department.

Wastewater

As previously noted, the Project site is served by a sanitary sewer system owned and
operated by the City of Waltham that conveys flows to MWRA’s South Charles Relief Sewer. In
large storms, infiltration and inflow (I/I) in Waltham and in downstream communities, including
communities with combined sewer systems, can contribute to sewage backups and overflows as
well as combined sewer overflow (CSO) discharges to the Charles River Basin. To ensure that
the Project’s new wastewater flow does not increase surcharging and overflows in large storms,
the Proponent should fully offset the Project’s wastewater flows with I/I removal at the rate of MWRA 1
four gallons removed for every gallon of new wastewater flow, in compliance with MassDEP
regulation at 314 CMR 12.04(2)(d) and in accordance with Town of Waltham’s I/I Mitigation
City Ordinance.

The DEIR reports that the Project will generate a total of 41,460 gallons per day (gpd) of
wastewater. The ENF previously stated the existing flow from the site was 14,892 gpd and that
the Project would increase flow by 26,568 gpd. However, as noted in a letter from the City
Engineer included in the DEIR, analysis of water meter data on the site indicates that existing
wastewater flow is actually 1,866 gpd and that the Project will increase flow by 39,594 gpd.
Therefore, to achieve the 4:1 removal rate required by MassDEP and the City Ordinance, MWRA 1
removal of 158,376 gpd of I/I from the wastewater system will be required. The letter states that
the City has accumulated a bank of sewer gallons through private I/I mitigation projects to be
applied to City projects like this one. The sewer bank has adequate gallons to accommodate the
Project and a withdrawal of 158,376 gallons will be credited to the City.

TRAC Discharge Permitting

MWRA prohibits the discharge of groundwater and stormwater to the sanitary sewer
system, pursuant to 360 C.M.R. 10.023(1) except in a combined sewer area when permitted by
the Authority and the local community. The Project site has access to a storm drain system and is
not located in a combined sewer area. Therefore, the discharge of groundwater and stormwater to MWRA 2
the sanitary sewer system associated with this Project is prohibited.

Any gas/oil separators in parking garages associated with the Project must comply with MWRA 3
360 C.M.R. 10.016 and State Plumbing Code. The installation of the proposed gas/oil separators
may not be back filled until inspected and approved by the MWRA and the Local Plumbing
Inspector. For assistance in obtaining an inspection the Proponent should contact John Feeney,
Source Coordinator in the TRAC Department at 1 (617) 305-5631.

On behalf of the MWRA, thank you for the opportunity to provide comments on this
Project. Please do not hesitate to contact me at 1 (617) 788-4958 with any questions or concerns.

Sincerely,

Bethany Card
Director
Environmental and Regulatory Affairs

cc: Gary Moran, DEP

John Viola, DEP
 Section 8: Responses to Comments

8.3 Charles River Watershed Association (CRWA)

CRWA 1

As CRWA previously commented, the City should avoid cutting down as many trees (especially mature trees) as
possible.

The Project will only remove what is needed for construction, safety, and/or tree health.

CRWA 2

The City should consider whether more can be done to reduce the amount of surface parking, roads, and other
impervious surfaces, while incorporating green infrastructure into parking lot design to treat excess stormwater
generated by the impervious surface.

The parking program is set at 650 spaces. This is based upon the needs at the current High School and
accounting for student population increase and staff level increases. Local zoning requires 868 spaces; however
the Project is seeking relief through a variance to the Zoning Board of Appeals to provide the lesser amount. The
parking garage has aided in reducing impervious surfaces as the footprint of the parking is covered with the
field.

CRWA 3

Given that infiltration opportunities on the site are limited, we urge the City to maximize the use of surface
biofiltration strategies to ensure compliance with the TMDL.

These BMPs should be implemented wherever feasible to manage runoff and protect water quality.

Biofiltration has been incorporated where feasible, that is in areas of fill and downgradient of the contributary
areas they serve. Biofiltration is located in areas of high visibility which will facilitate educational and interactive
opportunities for students and public visiting the school.

CRWA 4

The DEIR does not indicate whether PFAS chemicals may be present in the turf and if so, what the impacts
would be.

MassDEP has water quality regulations for six Per- and Polyfluoroalkyl Substances (PFAS). In the absence of
published regulations, the project will utilize EPA 533, which was recently approved by the EPA, for water quality
as the basis of testing, which the New York Department of Conservation requires. Refer to Section 3.3 of the
FEIR for a detailed discussion on testing, ASTM standard and protocols.

Waltham High School | Final Environmental Impact Report 5 | p. 18

June 19, 2020

Via Email

Page Czepiga
Assistant Director, MEPA Office
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
page.czepiga@state.ma.us

Re: Comments on Waltham High School DEIR, 554 Lexington Street, Waltham

Dear Page:

Charles River Watershed Association (“CRWA”) submits the following comments on the
Draft Environmental Impact Report (“DEIR”) for the Waltham High School project in Waltham,
Massachusetts filed with the MEPA Office on May 15, 2020. The City of Waltham’s proposed
development includes a new school building, athletic field, garage, parking lots, roadways, and
pedestrian paths. Given the magnitude of this project and its proposed environmental impacts,
we appreciate the Secretary’s decision to require an EIR to fully analyze the project’s impacts
and allow the public to meaningfully participate in the project’s development.

CRWA’s previous comments on the Environmental Notification Form (“ENF”) for this
project raised concerns about the proposed impacts to wetlands, destruction of an entire section
of stream, clearing of trees, and creation of significant new impervious surface on the site. We
explained that these alterations to the natural environment would result in impacts including
increases in stormwater runoff and corresponding decreases in groundwater recharge,
exacerbation of heat effects, loss of wildlife habitat and natural flood storage, and alteration of
natural hydrology, and that these impacts would be further exacerbated as climate change
brings increased heavy rainfalls, more drought, and hotter temperatures. At the same time, we
explained that by minimizing impervious surfaces, maximizing the functioning of natural
ecosystems, and employing green infrastructure, the City could mitigate the effects of climate
change and create a healthier environment for students and the community.

We applaud the City for going back to the drawing board and redesigning the project to
reduce its overall impact on the environment. Avoiding direct impacts to the stream and
wetlands and reducing the total amount of land to be cleared and impervious surface to be
created are all positive changes to the project.

We also urge the City to consider additional measures to promote a healthy environment
for both students and the surrounding community. The project still proposes to create nearly 10

Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 www.charlesriver.org
new acres of impervious surface, which will increase stormwater runoff, decrease groundwater
recharge, and exacerbate heat effects. Clearing trees and vegetation, especially mature trees,
will affect air and water quality and reduce cooling benefits. As CRWA noted in its ENF
comments, by preserving as much wooded area and the ecosystem processes it provides as
possible, the City would improve its climate resilience and be better able to handle drought.
Given that this property is located within an environmental justice community and a green space
desert, protecting the natural resources on site provides critical environmental benefits in an
area where they are particularly needed.

Land Alteration and Tree Preservation

We appreciate that the total amount of proposed land alternation has been reduced as
compared to what was originally anticipated in the ENF. Trees and other vegetation protect air
and water quality, help to control stormwater runoff and flooding, and provide natural cooling.
The DEIR indicates that 10 acres will be cleared for development but says the exact number of
trees that will be cut down is unknown. It also does not evaluate the impacts of clearing trees
and vegetation on the site.

As CRWA previously commented, the City should avoid cutting down as many trees CRWA 1
(especially mature trees) as possible. Mitigation of tree removal should be required onsite and
there should be no net loss of trees from the site – any trees removed should be replaced with
trees along proposed roadways and in proposed landscaped areas to help mitigate temperature
impacts. Mature trees should be replaced on a 2 to 1 basis. While the benefits of new young
trees will not be the same as the mature trees removed, it will be a start.

Impervious Surface and Stormwater Management

As CRWA noted in its ENF comments, creation of new impervious area should be avoided
wherever possible. The City is now proposing to add 9.54 acres for a total of 14.16 acres on the
site. The City should consider whether more can be done to reduce the amount of surface CRWA 2
parking, roads, and other impervious surfaces, while incorporating green infrastructure into
parking lot design to treat excess stormwater generated by the impervious surface. The DEIR
indicates that the use of pervious pavers is no longer planned, but we urge the City to consider
use of alternatives to impervious surface wherever possible. Alternatives such as porous
pavement for walkways or use of green roofs or cisterns would help reduce the volume of runoff
generated by the project.

Since this project will be required to comply with the Total Maximum Daily Load
(“TMDL”) for Nutrients in the Upper/Middle Charles River, which requires no additional inputs of
phosphorus to the river and a significant reduction from existing development, we are glad that
the phosphorus load calculations have been provided in the DEIR. Given that infiltration
opportunities on the site are limited, we urge the City to maximize the use of surface CRWA 3
biofiltration strategies to ensure compliance with the TMDL.

2
 Additionally, we are glad to see that the project will incorporate Low Impact
Development (“LID”) techniques such as disconnecting impervious area, treating stormwater as
close to the source as possible, and employing best management practices (“BMPs”) like water
quality swales and bioretention areas. These BMPs should be implemented wherever feasible to CRWA 3
manage runoff and protect water quality. Designing these BMPs to be visible and interactive for
students and the public, as is proposed in the DEIR, will create important educational
opportunities and serve as examples of how such measures can be implemented elsewhere.

We appreciate the DEIR’s discussion of the project’s vulnerabilities to climate change and
measures that will be taken to promote climate resilience. We urge the City to continue
analyzing impacts under future climate conditions. According to the National Climate
Assessment, the amount of precipitation falling in very heavy events increased by 71% in New
England from 1958 to 2012. Stormwater management measures must be designed to handle
current and predicted future rainfall amounts using the best available science.

Runoff from the turf field remains particularly concerning because toxic PFAS chemicals
have been found in artificial turf. The DEIR states that “[t]urf fields will be in accordance with
DEP regulations for PFAS,” but DEP has only started to regulate PFAS and is currently only
regulating these chemicals in drinking water supplies and on clean-up sites. The DEIR does not CRWA 4
indicate whether PFAS chemicals may be present in the turf and if so, what the impacts would
be. PFAS chemicals are known to cause serious health problems, including cancer. If PFAS
chemicals are present in the turf, students using the field will be exposed, and if PFAS chemicals
enter stormwater runoff from the field, downstream communities and waters will also be at risk.

Thank you for considering these comments, and please do not hesitate to reach out with
any questions.

Sincerely,

Heather Miller, Esq.

General Counsel & Policy Director
hmiller@crwa.org
781-788-0007 x 234

3
 Section 8: Responses to Comments

8.4 Massachusetts Department of Environmental Protection

(MassDEP)

MassDEP 1

Work within the 100-foot Buffer Zone and work to restore the previously altered BVW and Intermittent Stream
will require a Notice of Intent and a stormwater management plan in accordance with Regulations.

Acknowledged, a Notice of Intent will be filed with Waltham Conservation Commission.

Waltham High School | Final Environmental Impact Report 5 | p. 19

Charles D. Baker Kathleen A. Theoharides
Governor Secretary

Karyn E. Polito Martin Suuberg

Lieutenant Governor Commissioner

June 19, 2020

Kathleen A. Theoharides, Secretary RE: Waltham

Executive Office of Waltham High School
Energy & Environmental Affairs EEA # 16097
100 Cambridge Street
Boston MA, 02114

Attn: MEPA Unit

Dear Secretary Theoharides:

The Massachusetts Department of Environmental Protection Northeast Regional Office

(MassDEP-NERO) has reviewed the Draft Environmental Impact Report (DEIR) for the proposed
Waltham High School in Waltham. MassDEP provides the following comments.

Wetlands

According to page one of the Draft Environmental Impact Report, the Waltham School
Department has acquired a parcel of land adjacent to the original project site described in the
Environmental Notification Form. The additional parcel, called the Jericho Hill Parcel II, is an
approximately 6-acre site which is located immediately westerly of 554 Lexington Street.
The acquisition of the Jericho Hill Parcel II provides an alternative site which accommodates the
project goals while reducing or avoiding wetland impacts and addresses many of the
concerns discussed in MassDEP's comments on the ENF. The new site layout allows all the
significant programmatic elements to reside on one side of the intermittent stream and will limit
impacts to the 100-foot Buffer Zone. Work within the Buffer Zone includes removing the fill
previous placed over the Intermittent stream and BVW; construction of pavement, structures, a
small portion of new roadway and sidewalks, and associated earthwork required to achieve design
grades. MassDEP supports this alternative as described in the DEIR.

This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751.
TTY# MassRelay Service 1-800-439-2370
MassDEP Website: www.mass.gov/dep
Printed on Recycled Paper
 MassDEP is reviewing a Superseding Order of Resource Area Delineation (SORAD) for
554 Lexington Street which will determine the resource area boundaries on the site. The SORAD
will be issued upon the issuance of the final MEPA Certificate. Work within the 100-foot Buffer
Zone and work to restore the previously altered BVW and Intermittent Stream will require a Notice MassDEP 1
of Intent and a stormwater management plan in accordance with Regulations.

The MassDEP appreciates the opportunity to comment on this proposed project. Please
contact Rachel.Freed@mass.gov at (978) 694-3258 for further information on wetlands issues. If
you have any general questions regarding these comments, please contact me at
John.D.Viola@state.ma.us or at (978) 694-3304.

Sincerely,

John D. Viola
Deputy Regional Director

cc: Brona Simon, Massachusetts Historical Commission

Eric Worrall, Rachel Freed, Kyle Lally, MassDEP-NERO

2
 Section 8: Responses to Comments

8.5 Massachusetts Historical Commission (MHC)

Reference the Waltham Historical Commission for concerns about the proposed project’s impacts to exiting
stone walls within the 6-acre parcel.

There are no stone walls within the 6 – acre parcel. Refer to the existing conditions plan C101. Stone walls for
the boundary (property line) between Jericho Hill Parcel II and Sanderson Heights will remain.

Waltham High School | Final Environmental Impact Report 5 | p. 20

 Section 8: Responses to Comments

8.6 Department of Energy Resources (DOER)

DOER 1

Examine heating load and compare to DOE prototype. Compare and contrast inputs/outputs.

As discussed on July 8, 2020 with MEPA and DOER representatives, this requirement was not required for the
FEIR.

DOER 2

Develop a new scenario (“Scenario 4”) which further improves envelope (both UA and air infiltration) such that
HVAC systems can be downsized, simplified, and eliminated. For example, improve vertical performance such
that perimeter heating could be eliminated.

A new scenario 4 has been included in the FEIR. As discussed on July 8, 2020, refer to Section 4.1 and 4.2 of
FEIR, table 4.5 - page 9 & 10, as well as table 4.7- energy modeling inputs.

The Scenario 3 and 4 incremental costs include the HVAC sizing reduction and system cost reduction totaling a
$305,000 cost over base code and $175,000 over Stretch Code. However, the all-electric heating requires the
emergency generator to be designed to support the heating loads during a winter power out event. This adds
significant load to the emergency generator and double its costs from the proposed design system. It outweighs
the costs benefits of the HVAC sizing reduction and system cost reduction. Please refer to the Appendix for the
detailed installation costs for each scenario.

DOER 3

3. Provide detailed LCCA results for:

a. Proposed scenario (gas heating + proposed envelope).
b. Proposed scenario (gas heating + proposed envelope) with retrofit in future to efficient electric space
heating in the future. This LCCA should include premium costs for retrofitting an existing, in-service
building.
c. Scenario 3 (efficient electric heating + proposed envelope).
d. Scenario 4 (efficient electric heating + further improved envelope). This scenario should improve the
envelope such that HVAC systems can be downsized and simplified (for example: size reduction of all
equipment due to smaller peak loads; reduction and/or elimination of perimeter space heating systems;
simplified controls, etc).
e. Scenario 4 (gas heating + further improved envelope) with retrofit to efficient electric space heating in the
future. This LCCA should include premium costs for retrofitting an existing, in-service building.

As discussed on July 8, 2020 with MEPA and DOER representatives, the following Scenarios were agreed to be
analyzed relative to the MA Energy Code baseline for GHG emissions reduction and LCCA:
• Scenario 1-Stretch Code - demonstrating the criteria & strategies to attain the 10% threshold beyond
MA Energy Code
• Scenario 2-Proposed Design -demonstrating the criteria and strategies to outperform the Stretch Code
• Scenario 3-Proposed Design with VRF All-electric heating and cooling
• Scenario 4-Improved Enclosure with VRF All-electric heating and cooling
Refer to Section 4.1 and 4.2 of FEIR for the detailed GHG emissions reduction and LCCA analysis results.

Waltham High School | Final Environmental Impact Report 5 | p. 21

 Section 8: Responses to Comments

DOER 4

Provide full model inputs and outputs for all analyzed scenarios.

Baseline, Stretch Code (Scenario1), Proposed Design (Scenario 2), Scenario 3 & 4 energy model inputs are
provided in Table 4.7 in FEIR. Refer to the Appendix for all energy model output (annual end use and total
energy use by fuel).

DOER 5

For all scenarios, provide the aggregate U-value (also called “UA”) for the wall assembly.

As discussed on July 8, 2020 with MEPA and DOER representative, this requirement was not required for the
FEIR.

DOER 6

Meet with MassSave® and confirm level of incentive for scenarios being analyzed. These inputs should go into
the LCCAs.

As discussed on July 8, 2020:

• A meeting with the MassSave PA Utilities was held during Schematic Design and the project will be
analyzed under the Eversource (Electric PA) and National Grid (natural gas PA) Comprehensive
Integrated Design incentives program.
• The first MassSave Technical Assistance (TA) Study analysis will be conducted following the issuance of
the project Design Development package.
• The FEIR includes Utility Incentives based on the current MassSave (PA) incentives program, under
which the project is already registered for: $0.30/kWh and $1.70/Therm.
• The estimated incentives are not confirmed or approved by the utility. They are included in the payback
calculations for the sole purpose of the FEIR, as required in the NPC/DEIR comment letter.

Refer to Table 4.5 of FEIR.

DOER 7

Estimate Alternative Energy Credits (AECs) under electrification scenario. These estimates should go into the
LCCAs.

As discussed on July 8, 2020, FEIR includes preliminary AEC incentives based on DOER’s AEC incentives
calculator: $2/AEC [$1,519 for Scenario 3 and $1,352 for Scenario 4]

The estimated incentives are subject to change based on the RECs market at the time of project construction
completion. They are included in the payback calculations for the sole purpose of the FEIR, as required in the
NPC/DEIR comment letter.

Refer to Table 4.5 of FEIR.

Waltham High School | Final Environmental Impact Report 5 | p. 22

 Section 8: Responses to Comments

DOER 8

Provide detailed roof plans to demonstrate 50% and 80% PV set aside.

Refer to Section 4.3 of FEIR for the Solar PV Readiness and GHG emission reduction analysis of a future Solar
PV installation. As discussed on July 8, 2020, it was agreed that the analysis would demonstrate Code required
PV readiness only. The project is meeting the code required 40% area for PV readiness, per IECC 2018 MA
Amendments C103.2 and C403.2 and IECC 2018 Appendix CA C103.3. Figure 4.1 (page 15) shows the
available total PV readiness roof area at 41.2%, when accounting for HVAC equipment, roof perimeter and
required safety/access clearances, as well as roof acoustical and visual screens’ associated shading impact.

Waltham High School | Final Environmental Impact Report 5 | p. 23

 COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE OFFICE OF
ENERGY AND ENVIRONMENTAL AFFAIRS
DEPARTMENT OF ENERGY RESOURCES
100 CAMBRIDGE ST., SUITE 1020
BOSTON, MA 02114
Telephone: 617-626-7300
Facsimile: 617-727-0030

Charles D. Baker Kathleen A. Theoharides

Governor Secretary

Karyn E. Polito Patrick Woodcock

Lt. Governor Commissioner

26 June 2020

Kathleen Theoharides, Secretary

Executive Office of Energy & Environmental Affairs
100 Cambridge Street
Boston, Massachusetts 02114
Attn: MEPA Unit

RE: Waltham High School, Waltham, MA, EEA #16097

Cc: Maggie McCarey, Director of Energy Efficiency, Department of Energy Resources

Patrick Woodcock, Commissioner, Department of Energy Resources

Dear Secretary Theoharides:

We’ve reviewed the Draft Environmental Impact Review (DEIR) for the above project. The
proposed project consists of a 4-story high school with traditional classrooms and technical
training space with a total of approximately 414,000-sf.

Executive Summary

A key mitigation measure for Massachusetts projects is replacing fossil fuel heating with efficient
electric heating. Currently, efficient electric heating has approximately 45% lower emissions
than even best-in-class (95%) condensing natural gas heating. Because Massachusetts will
continue to add renewables to the electric grid, efficient electric heating is expected to have
approximately 85% lower emissions than condensing natural gas heating by 2050.

Accordingly, evaluating replacing fossil fuel heating with efficient electric heating should be
thoroughly evaluated in the FEIR.

Our detailed comments follow.

Waltham High School, EEA #16097
Waltham, Massachusetts

Pathway to 51% Mitigation Level

Using the model output reported in the DEIR, Mitigation Level1 would be about 24%. Mitigation
Level could be improved by more than 2, as follows:

• Electrification of space heating would improve ML to 36%.

• PV installed on 50% of the roof improves ML to 45%;
• PV installed on 80% of the roof improves ML to 51%.

Efficient Electrification

Electrification of space and service water heating is an effective strategy for GHG mitigation with
both short and long term benefits. Electrification entails swapping from gas-fueled equipment to
ground source or air source heat pumps and/or VRF systems.

The DEIR included a “Scenario 3” which generally replaces the proposed fossil fuel equipment
with efficient electrification. This scenario was not adopted, however. We note the following
regarding this scenario:

• Scenario 3 has more emissions than the currently proposed scenario. This unusual result
should be checked. Because space heating with efficient electric equipment has 45% lower

1
Mitigation Level is the percent GHG reduction beyond the reduction that would occur as a result of following
state and local building codes. A Mitigation Level of 0% means that no mitigation is proposed.

Page 2 of 7
Waltham High School, EEA #16097
Waltham, Massachusetts

emissions than even 95% efficient condensing equipment, one would expect emissions for
this scenario to go down, not up.

• The DEIR explains that decisions were made to stay with natural gas based on a life cycle
cost analysis (LCCA). However, details of the LCCA were not included in the submission.

To fully evaluate efficient electrification, we recommend the following:

• An additional, new scenario (“Scenario 4”) should be developed which examines

electrification of space heating in tandem with an even further improved envelope. This
scenario should improve the envelope such that HVAC systems can be downsized and
simplified (for example: size reduction of all equipment due to smaller peak loads;
reduction and/or elimination of perimeter space heating systems; simplified controls, etc).

Two LCCAs can be derived from the above, as follows:

o Scenario 4a: this is an LCCA using the improved envelope and efficiently
electrified space heating.

o Scenario 4b: this is an LCCA using the improved envelope and using gas space
heating, then retrofitting to efficient electric at the end of the gas equipment’s life.
The LCCA should include premium costs to retrofit an existing, in-service building.

The submission also makes reference to the possibility of building as proposed, then swapping to
electrified heating in the future. We recommend an LCCA be developed for this scenario, as well.
The LCCA should include premium costs to retrofit an existing, in-service building. Note that this
scenario will not benefit from reduced/eliminated equipment like would be the case for Scenario
4.

The electrified heating scenarios described above could still have gas-heated hot water.
Accordingly, the building will still be serviced with gas and can still include gas stoves for the
cooking program.

Space Heating – Comparison to Prototype

Another potential issue which should be examined in the FIER is the size of the heating end use
itself. The “baseline” scenario (which should correspond to a Code building) has more than x3
more space heating than the DOE prototype building for our climate. (See illustration.)

Page 3 of 7
Waltham High School, EEA #16097
Waltham, Massachusetts

The proponent should examine the DOE prototype and evaluate the differences in inputs/outputs.
The FEIR should provide some discussion to explain the differences.

Building Envelope Mitigation

High-performing envelope is essential to successful GHG mitigation. Key strategies for

maintaining integrity of envelope are:

• Continuous insulation;
• Reducing air infiltration;
• Reducing thermal bridges;
• Limiting or eliminating use of glass “curtain wall” and spandrel assemblies;
• Maximizing framed, insulated walls sections;
• Maintaining window at code levels.

Beginning in August 2020, Massachusetts energy code amendments require conformance with
2018 IECC Section C402.1.5 which mandates that the aggregate performance of all above-grade
surfaces conform to the wall performance factors in IECC Table C402.1.4 and C402.4 and
fenestration values in C402.4.1 and C402.4.3.

It is unclear from the submission whether the project meets this requirement. In the future
submission the proponent should include a UA analysis separately identifying the % of wall, U-
value, and insulation commitment (R-xx+R-xxc.i. or window U-value) for the wall, curtain wall,
and window and calculating the aggregate UA.

Page 4 of 7
Waltham High School, EEA #16097
Waltham, Massachusetts

Codes and Baseline

Massachusetts Stretch Code applies to this project. Stretch Code requires a 10% energy
performance improvement over ASHRAE 90.1-2013-Appendix G plus Massachusetts
amendments. Accordingly, the baseline for this project should be based on ASHRAE 90.1-2013
plus Massachusetts amendments. The project is using this baseline.

In August 2020, an update to the Massachusetts Stretch Code is planned to take effect. The Stretch
Code planned to take effect in August also uses ASHRAE 90.1-2013-Appendix G and the 10%
improvement remains unchanged. However, there will be several new, or changed, Massachusetts
amendments including: C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV
charging), and C406 (additional efficiency measures). In addition, the additional C406 measures
are increased from 2 to 3 while the list of additional measures to choose from are expanded.

To accurately estimate Mitigation Level for this project, we recommend that the baseline for this
project be set at the Stretch Code provisions planned to take effect in August 2020 as this will
likely be the code that will be used for building construction. The DEIR submission states that
these updates will be included in the FEIR.

Financial Incentives

High performance and electrified buildings can receive significant incentives from MassSave®
under their performance-based programs.

Efficient electric space heating could also potentially qualify for Alternative Energy Credits which
may be able to provide an income stream for the buildings.

Rooftop Solar PV

Rooftop PV can provide significant GHG benefits as well as significant financial benefits. The
proponent committed to make the roof solar ready, however it is unclear what portion of the roof
will be set aside for on-site PV. Additionally, beginning August 2020, buildings 4 stories and under
are required to set aside 50% of their rooftop for PV.

The project should submit detailed roof plans showing how they will meet the base requirements
of 50%. Additionally, the project should examine the opportunity to set aside 80% of the roof for
PV.

Recommendations

We recommend the following:

1. Examine heating load and compare to DOE prototype. Compare and contrast DOER 1
inputs/outputs.

Page 5 of 7
Waltham High School, EEA #16097
Waltham, Massachusetts

2. Develop a new scenario (“Scenario 4”) which further improves envelope (both UA and air DOER 2
infiltration) such that HVAC systems can be downsized, simplified, and eliminated. For
example, improve vertical performance such that perimeter heating could be eliminated.

3. Provide detailed LCCA results for: DOER 3

a. Proposed scenario (gas heating + proposed envelope).

b. Proposed scenario (gas heating + proposed envelope) with retrofit in future to

efficient electric space heating in the future. This LCCA should include premium
costs for retrofitting an existing, in-service building.

c. Scenario 3 (efficient electric heating + proposed envelope).

d. Scenario 4 (efficient electric heating + further improved envelope). This scenario

should improve the envelope such that HVAC systems can be downsized and
simplified (for example: size reduction of all equipment due to smaller peak loads;
reduction and/or elimination of perimeter space heating systems; simplified
controls, etc).

e. Scenario 4 (gas heating + further improved envelope) with retrofit to efficient

electric space heating in the future. This LCCA should include premium costs for
retrofitting an existing, in-service building.

4. Provide full model inputs and outputs for all analyzed scenarios. DOER 4

5. For all scenarios, provide the aggregate U-value (also called “UA”) for the wall assembly. DOER 5
The UA should be presented in the table below.

Appendix G Reference Mitigated Building Mitigated Building

Building Minimum
(ASHRAE 90.1 2013, Requirement
Table 5.5-5 and (2018 IECC Tables C-
Appendix G 402.1.3, 402.1.4, 402.4)
fenestration limits)
Percent Percent
Percent
Vertical of of
U value U value Vertical U Value
Envelope Vertical Vertical
Area
Area Area
Framed,
insulated % value % value % value
Wall
Opaque
glass,
curtain
% value % value % value
wall,
shadowbox,
spandrel

Page 6 of 7
Waltham High School, EEA #16097
Waltham, Massachusetts

Vision
% value % value % value
glass

Aggregate Aggregate Aggregate

100% 100% 100%
U U U
Aggregate Aggregate Aggregate
R R R

6. Meet with MassSave® and confirm level of incentive for scenarios being analyzed. These DOER 6
inputs should go into the LCCAs.

7. Estimate Alternative Energy Credits (AECs) under electrification scenario. These DOER 7
estimates should go into the LCCAs.

8. Provide detailed roof plans to demonstrate 50% and 80% PV set aside. DOER 8

Sincerely,

Paul F. Ormond, P.E.

Energy Efficiency Engineer
Massachusetts Department of Energy Resources

Brendan Place
Clean Energy Engineer
Massachusetts Department of Energy Resources

Page 7 of 7
 Section 8: Responses to Comments

8.7 Other Comment Letters

Responses included on pages 28 to 145, individual comment letters attached behind each response
letter, electronically bookmarked.

8.7.a City of Waltham universal response to Article 97 and Open Space comments by MEPA Page 28
and numerous abutters MassDEP 1

Refer to 43-page attachment

8.7.b City of Waltham response to Robert Coleman comment letter Page 29

Refer to 26-page attachment. Additional comments are provided specifically in 8.7.16

8.7.01 Abell – Bardsley, Melissa Page 30

8.7.02 Anonymous 5/27/2020 Page 31

8.7.03 Anonymous 6/1/2020 Page 32

8.7.04 Ayers, Ron Page 33

8.7.05 Baclawski, Carol Page 34

8.7.06 Bagge Fowler, Maureen Page 35

8.7.07 Barry, Shelli Page 37

8.7.08 Benoit, Angie Page 38

8.7.09 Borrelli, Zac Page 39

8.7.10 Brassil, Isabel Page 40

8.7.11 Brown, Amy (2 of 2) Page 41

8.7.12 Campbell, Michelle Page 42

8.7.13 Cannon, Laura Page 43

8.7.14 Chen, Mike Page 44

8.7.15 Chorman, Philip Page 45

8.7.16 Coleman, Robert L. Page 46

8.7.17 Corbett, Amy Page 51

8.7.18 Cortellini – Devine, Lynelle Page 52

8.7.19 Cyr, Rebecca Page 53

8.7.20 Davidson, Jaclyn Page 54

Waltham High School | Final Environmental Impact Report 5 | p. 24

 Section 8: Responses to Comments

8.7.21 DesAutels, Michele Page 55

8.7.22 Devin, James E. Jr. Page 56

8.7.23 Dolobowsky, Reva Page 57

8.7.24 Dunbar, Carol Page 58

8.7.25 Durkee, Sean - Councilor Page 59

8.7.26 Eposito, Jeffrey Page 60

8.7.27 Fils – Aime, Donna Page 61

8.7.28 Fintzel, Kit Page 62

8.7.29 NOT USED Page 63

8.7.30 Fowler, Bill Page 64

8.7.31 Frost, George - Interim Superintendent Page 65

8.7.32 Gagne, Rachel Page 66

8.7.33 Guzman, Alison Page 67

8.7.34 Guzman, Jose R. Page 68

8.7.35 Haley, Tom Page 69

8.7.36 Hanley, Robert Page 70

8.7.37 Hargrove, Robert Page 71

8.7.38 Hines, Karina (2 of 2) Page 72

8.7.39 Homan, Elizabeth Page 75

8.7.40 Hughes, Paula Page 77

8.7.41 Hutton, Alicia Page 78

8.7.42 Inman Donroe, Tammy Page 79

8.7.43 Joe, Jeannie (2 of 2) Page 80

8.7.44 Johnson, Heather Page 81

8.7.45 Jones, JP Page 82

8.7.46 Kahana, Christy Page 83

8.7.47 Katz, Jacob Page 84

8.7.48 Katz, Paul Page 85

Waltham High School | Final Environmental Impact Report 5 | p. 25

 Section 8: Responses to Comments

8.7.49 Katz, Sharon Page 86

8.7.50 Kern, Michelle Page 87

8.7.51 King, David Page 88

8.7.52 King, Tim Page 89

8.7.53 Kuchler, Ben Page 90

8.7.54 Kuno, Erika Page 91

8.7.55 Lara, Carolina Page 92

8.7.56 Lear, Elizabeth Page 93

8.7.57 Letendre, Megan Page 94

8.7.58 Lucente, Donald Page 95

8.7.59 MacDonald, Doug Page 96

8.7.60 MacLellan, Thomas Page 97

8.7.61 Mallik, Pradip Page 98

8.7.62 Martuza, Kathi and Cotton, Kester Page 99

8.7.63 Matteodo, Christopher Page 100

8.7.64 McCalla, Christina Page 101

8.7.65 McCarthy, Jeannette – Mayor Page 102

8.7.66 McNiece, Paula Page 103

8.7.67 Medeiros, Orlando (3 of 3) Page 104

8.7.68 Mullin, Kristen Page 106

8.7.69 Pandolfi, Luisa Page 107

8.7.70 Parkes, Alysia Page 109

8.7.71 Parrella, Susan Page 110

8.7.72 Piccirilli, Christin Page 111

8.7.73 Proskoczilo, Brandice Page 112

8.7.74 Pruy, Karen Page 113

8.7.75 Remage – Healey, Sarah Page 114

8.7.76 Reynolds, Christine Page 115

Waltham High School | Final Environmental Impact Report 5 | p. 26

 Section 8: Responses to Comments

8.7.77 Roche, Patricia and Brountas, David Page 117

8.7.78 Rooney, Patrick Page 118

8.7.79 Rose, Jennifer Page 120

8.7.80 Rose, Tammy Page 121

8.7.81 Roy, Jennifer Page 122

8.7.82 Schadelbauer, Margaret Page 123

8.7.83 Seminara, Pat Page 124

8.7.84 Sharpe, Valerie Page 125

8.7.85 Simpson, Kathleen Page 126

8.7.86 Stein, Nadene Page 127

8.7.87 Sumner, Larry Page 128

8.7.88 Telenar, Kaj Page 130

8.7.89 Thibodeau, Kristen Page 131

8.7.90 Urquhart, Alex Page 132

8.7.91 Urquhart, Laura Page 133

8.7.92 WalkBoston MassBike Page 134

8.7.93 Waltham Delegation Page 135

8.7.94 Waltham Historical Commission Page 136

8.7.95 Waltham Land Trust Page 137

8.7.96 Weinstein, Rachel (4 of 4) Page 138

8.7.97 Weitz, Donna Page 142

8.7.98 Westner, David (2 of 2) Page 143

8.7.99 Wolff, Steven Page 144

8.7.100 Woodside, Celeste Page 145

Waltham High School | Final Environmental Impact Report 5 | p. 27

 Section 8: Responses to Comments

8.7.a City of Waltham universal response to Article 97 and Open Space comments by MEPA
and numerous abutters MassDEP 1

Refer to 43-page attachment

Waltham High School | Final Environmental Impact Report 5 | p. 28

 Section 8: Responses to Comments

8.7.b City of Waltham response to Robert Coleman comment letter

Refer to 26-page attachment. Additional comments are provided specifically in 8.7.16

Waltham High School | Final Environmental Impact Report 5 | p. 29

 Section 8: Responses to Comments

8.7.01 Abell – Bardsley, Melissa

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 30

 Section 8: Responses to Comments

8.7.02 Anonymous 5/27/2020

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 31

 Section 8: Responses to Comments

8.7.03 Anonymous 6/1/2020

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 32

 Section 8: Responses to Comments

8.7.04 Ayers, Ron

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 33

 Section 8: Responses to Comments

8.7.05 Baclawski, Carol

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 34

 Section 8: Responses to Comments

8.7.06 Bagge Fowler, Maureen

MBF 1

Why was only the sixth alternative ever even discussed in early 2020? What criteria was used to decide that was the best?
With this alternative, why does the entire project have to shift to the south/west?

This alternative was introduced to avoid impacts on the intermittent stream and wetland resources areas.

MBF 2

Why was that original plan for the fields behind the building (not using Jericho Hill) not discussed in 2020?

The option with the fields behind the building without using Jericho Hill required relocation of part of the
intermittent stream and alteration to wetland resource areas.

MBF 3

So, where will educational expansion take place?

The expansion is on the third-floor roof at the roof deck.

MBF 4

Can you provide details of how you propose that students will walk to the high school from the north, south, east and west
sides?

Students will walk along Lexington Street to the entrance using existing sidewalks.

MBF 5

Can you please provide additional playing field lighting details?

Additionally, please provide lighting details about the school building.

This is under development and will be reviewed at an SBC meeting, this is not within MEPA jurisdiction.

MBF 6

How does a city owned sewer, water, drain easement translate to emergency egress from a high school?

Under the Federal Constitution and Massachusetts statutes and case law, the Fire Department and Police
department have the right to use this right-of-way under exigent public safety or emergency situations involving
potential risks to public safety. Under such situations, the government’s good faith interest in protecting public
safety outweighs an individual’s private property rights. The emergency access road is clarified in section 2.4 of
the FEIR.

MBF 7

When will the Lexington Street roadway work be performed? How will residents from Lincoln or Curve Street be able to
take a left onto Lexington Street during these peak times?

Waltham High School | Final Environmental Impact Report 5 | p. 35

 Section 8: Responses to Comments

The schedule for the waterline replacement has not been determined at this time. It is being coordinated with
other work to minimize the impact on traffic on Lexington Street. Lincoln street and curve street will remin
unchanged.

MBF 8

So, who will be approving any changes to the construction schedule? To change the times of work, it is stated that the
change must be approved by the City of Waltham. Who will that be?

The Inspector of Buildings approves any changes to the construction hours.

Waltham High School | Final Environmental Impact Report 5 | p. 36

From: Maureen Bagge Fowler
To: Czepiga, Page (EEA)
Subject: EEA 16097 Waltham High School
Date: Wednesday, June 17, 2020 9:25:14 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
To whom it may concern:

EEA: 16097

I trusted the Mayor, the Waltham School Committee (SC), the Waltham School Building Committee
(SBC), and the SMMA design team of architects, wetland specialists, construction management
consultants and lawyers to make the best choices for the Waltham High School project. I have only
recently gotten involved when the project expanded onto the Jericho Hill parcel in February 2020.  A few
years ago, the SBC decided that the best parcel of land in Waltham for the high school was the 46.5
acres at 554 Lexington Street. The SBC declared that this parcel would provide more than enough space
for the educational plans, parking, fields and also provided room for expansion.  In 2020, the Mayor
decided that this type of school could not be built on the 46.5 acres, and the playing field/parking lot had
to expand onto an adjacent parcel, known as Jericho Hill.   In the EIR, Section 2.2.3, the building shifts
west 90 feet to “maintain preferred adjacencies and greatly reduce the environmental impact”. 

Of course, reducing the environmental impact is of great importance, but so is providing a quality
education for now and the future and also not completely changing the neighborhood in the rear of 554
Lexington Street.  There have been many neighborhood meetings (some are listed as Table 2.2 of EIR).
But, NO meetings have been held in 2020, and not a single member of the design team, SBC, SC or
Mayor will even respond to any public input during the meetings, or via email.  If public meetings were
held in 2020, members of the public, neighbors like me, were not invited or included.

There were 5 alternatives for building siting listed in the DEIR, and a sixth one (including Jericho Hill) was
added in February. Why was only the sixth alternative ever even discussed in early 2020? What criteria MBF 1
was used to decide that was the best?  With this alternative, why does the entire project have to shift to
the south/west?  This makes the “121 parking spaces” closer to the abutters on the south than in any
other plan.  Additionally, during the SBC meeting I attended on March 6, 2020, a person giving
community input commented that locating the playing fields behind the school building had previously
been discussed, but withdrawn from consideration.  Why was that original plan for the fields behind the MBF 2
building (not using Jericho Hill) not discussed in 2020? I have asked this question to the Committees at
least 4 times, and no one has ever responded. I assume this is the option described as ENF-7, but I can’t
be sure, because no one ever responds to comments. And, if that plan was ENF-7, can’t that be re-
explored with moving the field and parking around and not keeping in the exact location? The DEIR
proposed plan has a “pro” listed as increasing buffer to one neighborhood, and a “con” as reducing buffer
to another neighborhood. Again, this seems unfair since the reduced buffer neighborhood has not been
allowed to participate in any dialogue.

I am personally interested in the exploration of alternative number 5.  And, it appears that MaDEP was
also interested in the exploration of Alternative 5.  To quote the MaDEP from 11-26-19, “Other
alternatives have been described in the ENF which decrease wetland impacts. While these alternatives
may have larger alterations to upland areas and require increased blasting and site work, they should still
be considered if they avoid significant impacts to Bank and BVW.   For example, Alternative 5, which has
no direct impact to Bank or BVW, should be further explored…” The Mayor’s comments to City Council on
2-24-20 to recommend transfer of control of Jericho Hill to the Waltham schools seems to be in response
to this same MaDEP comment. So, why was Alternative 5 never further explored, but adding Jericho Hill
use was explored? Why not have the designers be creative and consider adding a usable floor of the
school, and shrinking the entire footprint of the building? This could result in less alteration of the entire
site.
The joint committee decided that the best place for a 400+ parking garage and associated elevated
playing field was on the Jericho Hill parcel without any neighborhood input meeting or discussion. This
decision just pits one neighborhood on the northeast side of the property against the neighborhood on the
southwest side. And, the neighborhood on the northeast side wins dramatically. This just does not seem
fair to me.  

Before February 2020, there were no plans for lit playing field/parking lot anywhere near Glen Circle. The
uncovered 120+ parking area was farther away from Lincoln Street, and now the design has it on a rocky
ledge on the southwest corner of the now expanded 52.5 acres, using a shared driveway on Lincoln
Street as the secondary emergency access, and questions from abutters and concerned neighbors go
unanswered. The Waltham City Council voted against having a public meeting in February.

Section 2.8.1, Master Plan of the DEIR explains that Waltham wants room for expansion and adding
more playing fields.  This final design plan does not do that.  The front cover of the DEIR shows a 52.5
acre site and only the south side is being used.  In Section 3.1, the land alteration is discussed. Based on
the last few months of discussions, the “natural turf” field at the entrance could be used for school activity
and also for overflow event parking. So, where will educational expansion take place? Since the
MBF 3
wetlands, and a potential lawsuit regarding the wetlands, seem to be the deciding factor in the final
placement of the high school, will the City consider placing a formal Conservation Restriction on the
remaining undeveloped 20+ acres, including the wetland areas? This will eliminate having this same
discussion in a few years. If the SBC has decided that this is the only alternative for the fields, the
parking, and the high school, they really do not need the other 20 acres for expansion. For future
expansion, maybe they can think about increasing the number of floors of the building. If they want more
playing fields, they should figure out the design now, and discuss that in the neighborhood process.

Pedestrian safety: Can you provide details of how you propose that students will walk to the high school MBF4
from the north, south, east and west sides?  The DEIR says the city is encouraging walkers. But, Lincoln
Street, Curve Street, and College Farm Road, for example, have no sidewalks. The only crosswalk
across Lincoln Street is at Lexington Street. Students from near Bigelow or Winter Street will definitely
NOT walk to Lexington Street to safely cross Lincoln Street. I do not think any students coming from the
north will walk to the end of the end of the property line to go in the main entrance. The plans also call for
bike racks, but the re-design of Lexington Street calls for removal of the bike lanes. How do you explain
that?

Playing Fields: Can you please provide additional playing field lighting details? Before February 2020, the MBF 5
main athletic field and parking lot was located near Lexington Streets which allowed easy visible access
from Lexington Street. Now, the parking lot and fields are planned to be on elevated rocky cliff hovering
above the neighborhood.  Will the police patrol this parking lot over night disrupting the neighbors with the
patrol car headlights?  It does not make a lot of sense to me to put the main parking lot behind the
building and playing fields completely out of the public view.  If this is the final plan, please consider the
option of no lights after 9:00 pm in fairness to the neighbors.  Additionally, please provide lighting details MBF 5
about the school building. I don’t think the neighborhood needs to see the hallway and classroom lighting
and exit lights of a school building all night long, every night of the year.

Sewer, water, drain, easement at 79-85 Lincoln Street:  How does a city owned sewer, water, drain MBF 6
easement translate to emergency egress from a high school? A fire truck is not even able to make the
turn from Lincoln Street onto this shared driveway.

Traffic:  When will the Lexington Street roadway work be performed?  How will residents from Lincoln or MBF 7
Curve Street be able to take a left onto Lexington Street during these peak times? I am very concerned
about increased traffic on Lexington Street near the intersection of Totten Pond/Lexington/Bacon Streets. 
And, will the needed construction of sidewalks and bike lanes be performed at the same time?

DEIR 10.1, Construction Management: As you can tell from the tone of this letter, I have lost confidence
in the public officials managing this project. So, who will be approving any changes to the construction MBF 8
schedule?  To change the times of work, it is stated that the change must be approved by the City of
Waltham.  Who will that be?
 

In closing, I have, and continue to want a new high school in Waltham, and the costs associated with it
have never been a concern to me. However, the lack of public dialogue about changes to the project and
pitting one side of abutters against the others does not seem fair. This is not a NIMBY (not in my back
yard) complaint  - this is a public dialogue complaint.

I am certainly appreciative that the changes to the siting reduced some environmental impacts.  I want the
Stormwater system to be better in all of Waltham, and I understand the need for wetlands and buffer
zones. Since, writing this letter to the MA Secretary of Environmental Affairs is the only method of
communication available to the public at this time, because no one (except the recently appointed
neighborhood liaison) responds to anything, I am raising my lighting, traffic, child safety, traffic and
construction management in this same letter.  I hope you can encourage more open communication with
the neighborhood and encourage the city to not be afraid of some potential litigation, but rather strive for
the best high school in the city. In good faith, maybe the Secretary of Environmental Affairs could
condition a legal permanent Conservation Restriction on the unused 20+ acres on approval of the
project? 

Sincerely,

Maureen Bagge Fowler

54 Lincoln Street

Waltham, MA  02451

781-248-4101

mbaggefowler@yahoo.com
 Section 8: Responses to Comments

8.7.07 Barry, Shelli

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 37

 Section 8: Responses to Comments

8.7.08 Benoit, Angie

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 38

 Section 8: Responses to Comments

8.7.09 Borrelli, Zac

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 39

To Whom It May Concern,

I am an environmental engineer currently living at 536 Lexington Street, directly adjacent to the subject
property. I was surprised and disappointed to hear that the new high school would be built on the hill
next to my residence, where the shallow bedrock protrudes upwards on that beautiful piece of land.
After doing some more research, it became apparent to me that this location is far from ideal, especially
considering there are much better options nearby that will not involve blasting huge quantities of
bedrock. In addition to the cost implications, there are also many foreseeable environmental and public
safety issues, including but not limited to:

1. Construction considerations
a. Traffic disruption on a main road
b. Noise pollution
c. Air quality from blasting
d. Duration – years of managing public relations and complaints
2. Water management with potential flooding from blasting
3. Rodent displacement and infestation to local residences
4. Ecological concerns on an relatively untouched piece of land

I am no expert, but I am educated enough to know that there wasn’t enough thought and planning put
into choosing this piece of land to build the new school. It seems clear to me that there better
alternatives that can save a lot of time and money. I sincerely hope this decision will be reconsidered.

Zachary Borrelli

M.S. Geology
Environmental Engineering Consultant
Resident of 536 Lexington Street
 Section 8: Responses to Comments

8.7.10 Brassil, Isabel

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 40

From: Isabel Brassil
To: Czepiga, Page (EEA)
Subject: EEA#16097 - Waltham High School EIR
Date: Friday, June 19, 2020 9:52:42 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Dear Ms. Czepiga, 

My name is Isabel Brassil and I am entering 6th grade at McDevitt Middle School in
Waltham.  I am really excited about a new high school.  Right now, I will only get to go to the
high school for 3 years.  All because a few people are complaining.  

I do not think it is fair that adults get to decide our whole future while we just have to sit and
watch.  That's why I'm writing this letter.  

I know the decision to move forward with the project is up to you but I would love to be able
to go to a new high school.  

Your decision decides my future and my education.  I hope you move forward with the
project.  We have already gotten so far. 

Thank you.

Isabel Brassil
Age 11, rising 6th grader
Waltham, Massachusetts
 Section 8: Responses to Comments

8.7.11 Brown, Amy (2 of 2)

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 41

 Section 8: Responses to Comments

8.7.12 Campbell, Michelle

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 42

 Section 8: Responses to Comments

8.7.13 Cannon, Laura

LC 1

I would strongly urge the City to place permanent Conservation Restrictions on the natural field and adjacent forested area,
intermittent stream and buffer zone to ensure that this plan is forever protected.

The City is reviewing options for Conservation restrictions.

LC 2

As previously stated the City can raise the grade of the driveway and raise the grade of the entrance door to the building in
order to reduce the impact of blasting.

The site needs to be accessible to all from the street to the front door, the design team has analyzed the grades
and the current design represented the optimal elevation that allows access for all and is in complaince with the
American with Disabilities Act.

Waltham High School | Final Environmental Impact Report 5 | p. 43

LC 1
LC 1
LC 2
 Section 8: Responses to Comments

8.7.14 Chen, Mike

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 44

 Section 8: Responses to Comments

8.7.15 Chorman, Philip

PC 1

I am respectfully asking that a report on noise, vibration and air pollution mitigation be required of the City of Waltham by
the Secretary for the proposed subject Waltham High School project.

The actual noise from blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to mitigate
debris, dust and noise. Consigli also plans to use water misters, water trucks, and automatic wheel wash
stations to minimize dust. Finally, Consigli plans to use sound blankets at the perimeter fence strategically
placed to mitigate noise to the adjacent neighbors.

PC 2

The noise and dust pollution caused by this project will have a huge detrimental impact on the lives, wellbeing and
properties of the neighbors and the abutters for years, and yet there is no mention in the recently submitted Draft
Environmental Impact Report by the City of Waltham as to how they plan to monitor and mitigate the Problems.

The project will be monitoring noise with noise meters for adherence to the City of Waltham Noise Ordinance.
The Construction Manager will be responsible for mitigating dust on site and plans to use water misters, water
trucks, and automatic wheel wash stations to minimize dust.

PC 3

Will the rock blasting project even be paused?

The blasting schedule will be published to the Project website and provided to abutters once it is determined.

PC 4

When ground water run-off floods the low areas around the site, will the city install storm drains or allow all of the affected
basements to be flooded?

The Project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment
and includes not exceeding pre-development discharge rates for the design storms. During the construction
period, a Storm Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout
construction to monitor and modify temporary control measures as required. The stormwater is clarified in
section 3.2 of the FEIR.

Waltham High School | Final Environmental Impact Report 5 | p. 45

From: Philip Chorman
To: Czepiga, Page (EEA)
Subject: Waltham High School - EEA#: 16097
Date: Wednesday, June 17, 2020 6:37:04 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Page Czepiga

Assistant Director, MEPA Office

Executive Office of Energy and Environmental Affairs

Re: Waltham High School EEA#: 16097

Draft Environmental Report and Notice of Project Change submitted by SMMA

Dear Ms. Czepiga,

I am writing to respectfully ask that a report on noise, vibration and air pollution PC 1
mitigation be required of the City of Waltham by the Secretary for the proposed
subject Waltham High School project.

Given the property’s elevation (with 330 ft high point and 104 ft low point) and the
severe topographic grades, the project would require a massive quarry-size operation
with dramatic alteration of more than 50 acres of land. The proposed project destroys
long-preserved greenspace.  Why squeeze a poorly designed 4 story, 418,000 sq. ft.
school and a 182,000 sq. ft. garage into the southwesterly corner of the 52.5 acre
site?

An estimated 747,000 cubic yards of ledge, trees, soil and vegetation would need to
be blasted, drilled, excavated, cut and removed, requiring uncountable truck loads of
removed earth and material for more than a year around a strictly residential
neighborhood.  A blasted rock wall of 100 ft height and 1,920 ft length is planned that
will truly create a safety hazard like no other in Waltham.

There are private homes just 50 feet away from areas to be blasted and excavated.
The total construction project is expected to take over 4 years. The height of the
ground level of the proposed structures is well above the height of the residences on
the southerly side of the site, not including the 4+ story penthouse structures on top
that will bring the elevation to well over 60 ft.

The noise and dust pollution caused by this project will have a huge detrimental PC 2
impact on the lives, wellbeing and properties of the neighbors and the abutters for
years, and yet there is no mention in the recently submitted Draft Environmental
Impact Report by the City of Waltham as to how they plan to monitor and mitigate the
problems. More importantly, what will they do and what recourse exists for neighbors
when the damage occurs to the adjacent properties occur?  Will the rock blasting PC 3
project even be paused?  When ground water run-off floods the low areas around the PC 4
site, will the city install storm drains or allow all of the affected basements to be
flooded?

Below is a link to the Massachusetts Department of Environmental Protection Noise

Pollution Policy
Interpretation:https://www.mass.gov/files/documents/2018/01/31/noise-
interpretation.pdf

It states “This policy has been designed to protect affected residents and other
sensitive occupants of nearby property, but not necessarily uninhabited areas in and
around the source's property. Sources of noise may need to implement mitigation if
residences or buildings occupied by sensitive receptors are developed where they
may be affected by the source's noise”.

My home is a few hundred yards from the proposed project. I am concerned for the
health and safety of my household, specifically how the dust, radon, vibration, noise,
water run-off and stress of living next to a quarry and rock crushing operation will
affect our lives.  

An emergency access road is now planned to be perched on the southerly side of a

steep portion of the site leaving abutters to wonder about the disruption of their lives
and property. It is proposed to connect with a 20 ft wide private way to Lincoln Street
over which the City has no rights to pass and repass to provide access to a 52.5 acre
site that will be occupied by 1,380 students and 250+ administrative personnel. The
City has no legitimate way to claim legal access over this private way, and the utility
easement does not entitle them to repurpose this private way.  What is currently a
cul-de-sac and essentially a shared, privately owned driveway for multiple driveway
will become a heavily foot-trafficked path to and from the school, whether or not it is
intended only for emergency use.  

I kindly request that the City of Waltham be asked to submit a proper report on their
plans to mitigate these community-wide concerns to your agency for review.  Thank
you for your kind attention and consideration.

Philip Chorman
26 Lincoln Terrace
Waltham MA 02451
 Section 8: Responses to Comments

8.7.16 Coleman, Robert L.

RC 1

…asked for written assurances from the proponent that no additional playing fields, parking lots or expanded facilities will
be added to the project at some later date, those written assurances have not been forthcoming

Any significant changes or projects such as additional playing field, parking lots or expanded facilities at a later
date would need to go through their own approval process.

RC 2

Where is the real master plan for the proposed new high school dealing with each and every aspect of school facility needs
along with the proposed solution? What about the athletic fields’ master plan and the details of how current and future
athletic field requirements will be met?

The selection of this site is still valid and applicable, as discussed in the NPC/DEIR. The Project budget would
not account for relocation of the athletic fields and the City has invested millions of dollars in offsite locations
which they have no intention of abandoning. Therefore, the prior analysis remains valid and the reasons for the
selection of 554 Lexington Street as the preferred site stands. The evaluation is clarified in section 2.10 of the
FEIR.

In the interest of fairness, the lower lying neighbors deserve to be informed about the impact that water flow will have on
their property. Failure to complete such a study in advance of any blasting or construction leaves the neighbors at grave
risk. Even after such a study, continued testing and monitoring will likely be required to protect the neighbors.

As has been reported at the Waltham Conservation Commission meetings by the lower lying neighbors, they
have experienced overland flow for years. Although, no formal complaints were raised prior to this project, this
Project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment and
includes not exceeding pre-development discharge rates for the design storms. During the construction period,
a Storm Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout construction
to monitor and modify temporary control measures as required. The stormwater is clarified in section 3.2 of the
FEIR.

RC 3

All manner of testing, monitoring, and reporting on the impact of the blasting should take place to protect the community.

Testing, monitoring and reporting will occur as required and applicable.

RC 4

Why is it unreasonable for the neighbors to be concerned and to ask questions about this whole blasting process? Why
won’t the proponent explain to the neighbors what the process will be before blasting, during blasting, and after blasting if
they experience any kind of a problem or damage resulting from the blasting? Who bears the responsibility for any damage
to persons or property, is it the City, the blasting contractor, the construction manager, the architect, or all of them? When
will the City explain exactly what the neighbors need to do to file a claim against any responsible party? Will the City
establish a fund that will assist the neighbors in filing a claim against any precipitating party? Will the City ever respond to
the numerous questions and inquiries made by the abutters, the neighbors and community members about all aspects of
this project?

Waltham High School | Final Environmental Impact Report 5 | p. 46

 Section 8: Responses to Comments

The blasting notification procedures were described in Section 10.1.5 of the NPC/DEIR and clarified in Section
6.3 of the FEIR. The initial contact is typically performed via conventional mail and if contact is unsuccessful;
certified mail will be utilized. Pre-blast condition surveys intended to commence by the beginning of November
or sooner and be completed within a 4-6 week timeframe.

The Design Team provided an update on blasting to the SBC at the their regular meeting on 8/10/2020.

RC 5

Will the proponent’s proposals fully recharge the ground water on the subject property as required by statute, ordinance
and regulations? Will the groundwater drainage structures result in all stormwater staying on the property? What are the
neighbors to do if stormwater and groundwater negatively impact their property?

Runoff volumes from both sources should be fully analyzed and evaluated so that regulatory standards are not exceeded.

The project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment
and will not exceed pre-development discharge rates for the design storms. During the construction period, a
Storm Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout construction to
monitor and modify temporary control measures as required. The stormwater is clarified in section 3.2 of the
FEIR.

At a high level, the proposed stormwater management system consists of Best Management Practices (BMPs)
which are designed to collect, treat, and mitigate runoff as stated above. The stormwater management system
also keeps separate “clean” water from the stormwater which must be treated. That is, MassDEP’s regulations
consider stormwater runoff from the athletic field and building roof “clean” so this runoff will not be treated prior
discharge. Runoff from the wooded areas above the rock wall and groundwater collected in foundation drains
are also considered “clean” and these sources will be collected and managed separately from the stormwater
which requires treatment.

The stormwater is clarified in section 3.2 of the FEIR.

RC 6

Why hasn’t a subsurface exploration program been conducted before the design of the bedrock cuts and blasting for the
rock wall?

A preliminary subsurface exploration was undertaken during Schematic Design and additional testing has been
occurring during the month of July 2020, of which the abutters were notified.

RC 7

A full accounting for all discharges in the sewer system should be fully documented and presented so that it can be
determined if the City is meeting its required inflow and infiltration requirements of removing four gallons of infiltration
inflow for each additional gallon of wastewater that will be discharged into the sewer system.

The project will result in a net increase of 43,560 gallons per day (gpd) in water use when using the City
Ordinance in calculating the flows. The increase in water supply reflects both the proposed high school and the
future development at 617 Lexington Street, has been reviewed with the City’s Engineering Department and has
confirmed there is adequacy in the existing infrastructure.

Waltham High School | Final Environmental Impact Report 5 | p. 47

 Section 8: Responses to Comments

The project will result in a net increase of 39,594 gallons per day (gpd) in wastewater generation and reflects
both the proposed high school and the future development at 617 Lexington Street. The required I&I inflow
mitigation is 4:1 or 158,376 gallons and will be deducted from the City’s sewer bank.

The net increase on water and wastewater demand is clarified in section 1.5.2 of the FEIR.

RC 8

First, where is the plan and list showing the location of all the houses that will be entitled to a pre-blast/pre-demolition
survey in connection with the project. What are the details of how the pre-blast/pre-demolition survey will be conducted?
Will the property owners be provided with copies of the plans, the photos, the videos, and the written survey? What will
the pre-blast/pre/demolition survey consist of, who will complete it and when will it be done?

The project team is still evaluating the extent of the blasting on the site and has not finalized the 500-foot blast
radius map at this time. The map below drafted by Haley & Aldridge geotechnical engineers is being refined. This
draft was presented at the SBC Meeting on August 10, 2020. Once finalized it will be posted on the project
website, reviewed publicly at the SBC meeting and shared with those within the 500-foot radius via mail. The
map is included in Section 6.3 of the FEIR.

The blasting notification procedures were described in Section 10.1.5 of the NPC/DEIR and clarified in Section
6.3 of the FEIR. The initial contact is typically performed via conventional mail and if contact is unsuccessful;
certified mail will be utilized. Pre-blast condition surveys intended to commence by the beginning of November
or sooner and be completed within a 4-6 week timeframe.

RC 9

Next the CMP is silent on what testing, monitoring, reporting, analysis and mitigation will be done during demolition,
construction, and blasting of vibration (seismograph), dust and air quality, wind direction, wind speed, and noise?

Testing, monitoring and reporting will be conducted as applicable to the construction activity occurring and in
conformance with local regulations and state laws. The project is under design and many of these items are still
being developed.

The actual noise from during shot hole drilling is similar to typical construction site noise, with occasional louder
but very short duration peaks at the immediate moment of blast shot ignition. Technical provisions for Controlled
Blasting will require the Contractor to comply with the rules and regulations of the Commonwealth of
Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and City of Waltham Fire
Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or other sound barriers.
Per the WFD, double matting will be utilized during all blasting operations to mitigate debris, dust and noise.
Consigli also plans to use water misters, water trucks, and automatic wheel wash stations to minimize dust.
Finally, Consigli plans to use sound blankets at the perimeter fence strategically placed to mitigate noise to the
adjacent neighbors.

MEPA 46

RC 10

The Mayor has promised repeatedly that sound barriers and sound mitigation will be available to the neighbors. Please tell
us how that will be accomplished and when?

Waltham High School | Final Environmental Impact Report 5 | p. 48

 Section 8: Responses to Comments

Consigli plans to use sound blankets at the perimeter fence strategically placed to mitigate noise to the adjacent
neighbors. These should be erected in September, 2020 at the commencement of the demolition activities.
Sound barriers for rock crushing are being evaluated and may include earth berms or other manufacturers
barriers, these will be installed prior to blasting.

The project team has continued to advance the design of the building and the noise generating equipment on
the building. The project acoustician, Acentech, has reviewed the equipment selections and worked with the
project team. Their progress report is attached in Appendix 6.2 of the FEIR.

Sound levels are based upon three periods with a 24-hour day in coordination with the Director of Facilities and
how the building roof top equipment would be operated.

1. Daytime - 6.00am to 6.00pm

2. Evening – 6.00pm to midnight
3. Nighttime – midnight to 6.00am

Using these timeframes and measuring against the background noise measurements conducted in July 2019,
Acentech is recommending additional noise mitigation be incorporated on a number of rooftop units to achieve
compliance with the Waltham Noise Ordinance and Massachusetts DEP. These additional measures will be
incorporated into the project scope.

RC 11

What monitoring of volume and quality of storm water, rainfall, snow fall, ground water, storm surges, test well monitoring,
and quality testing will occur? Erosion control, dewatering and groundwater management are extremely important to the
downhill neighbors. Please provide the details of when testing will occur, how, who will do the testing and how will it be
made publicly available?

The Project will file a National Pollutant Discharge Elimination System (NPDES) permit with the Environmental
Protection Agency (EPA) for construction-related stormwater discharge. The NPDES permit requires a
Stormwater Pollution Prevention Plan (SWPPP) to be developed and implemented to:

• Define the characteristics of the site and the type of construction which will be occurring;

• Describe the site plan for the development to be constructed and discuss the proposed construction
sequence;

• Describe the practices that will be implemented to control erosion and the release of pollutants into
storm water;

• Create an implementation schedule to ensure that the practices described in this SWPPP are
implemented and to evaluate the plan's effectiveness in reducing erosion, sediment, and pollutant levels
in storm water discharged from the site;

• Describe the final stabilization/termination design to minimize erosion and prevent storm water impacts
after construction is complete.

• Identify the SWPPP coordinator’s duties;

Waltham High School | Final Environmental Impact Report 5 | p. 49

 Section 8: Responses to Comments

• Describes the existing site conditions including existing land use for the site, soil types at the site, as
well as the location of surface waters which are located on or next to the site (wetlands, streams, rivers,
lakes, ponds, etc.);

• Identify the body of water(s) which will receive runoff from the construction site, and depicts all waters
within one mile downstream of the site’s discharge point;

• Identify the drainage areas and potential storm water contaminants;

• Describe the project's monitoring plan and how controls will be coordinated with construction activities;
and

• Describe the implementation schedule and provisions for amendment of the plan.

Who will be the person responsible for handling complaints, and how are they to be contacted?

Responsible parties for receipt of complaint will vary depending upon the complaint:

Blasting Complaints – Fire Department

Noise complaints – Police Department

Blasting damage complaints – Consigli (CM) will provide a Point of Contact

All other complaints – Inspector of Buildings

RC 13

What part will Leftfield/Jacobs play in the construction monitoring process and in the interest of complete transparency
how will they communicate with the abutters, the neighbors and the community daily about the project and the problems
being experienced at the job site?

The Owner’s Project Manager (Leftfield) provides in the field representatives to oversee and monitor the progress
of the work. Once construction commences, they will be issuing a weekly report on activities.

RC 14

Rodent control is another major concern and there is virtually no information available? How will that issue be handled and
by who?

The CM will hire a pest management company who will bait the project site and building, weekly inspections will
occur.

RC 15

I also urge any and all from Massachusetts of Office of Energy and Environmental Affairs involved in the decision making on
this project to take the time for a complete site inspection especially because of the Notice of Project Change filed with this
DEIR .

The MEPA office has indicated that additional site walks are not required.

Waltham High School | Final Environmental Impact Report 5 | p. 50

June 19, 2020

Via Email: page.czepiga@mass.gov

Kathleen A. Theoharides
The Secretary of Energy and Environmental Affairs
Commonwealth of Massachusetts
100 Cambridge Street, Suite 900
Boston, MA 02114
Attention: Page Czepiga, MEPA Office

Re: EEA #16097 Waltham High Project

Location: 554 Lexington Street, Waltham MA

Dear Secretary Theoharides:

As a resident and citizen of North Waltham, Massachusetts for many years, I am writing
to express my continuing dire concern about the proposed new Waltham High School
(WHS) at 554 Lexington Street and 131R Lincoln Street in Waltham and to request that
you carefully review, analyze, vet and consider the Draft Environmental Impact Report
(DEIR) submitted by SMMA/City of Waltham in connection with this project, which fails
to accurately, adequately and appropriately respond to the Certificate of Secretary of
Energy and Environmental Affairs on the Environmental Notification Form, promulgated
on December 6, 2019. In my opinion this DEIR is a distortion of reality in many ways.

Since the original ENF filing and Secretary of EEA’s certificate of decision, the
proponent has attempted to fashion the DEIR into an acceptable response by adding an
additional 6+ acres of existing abutting open space to the existing 46.5+ acre parcel
totaling 52.5+ acres and re-orienting the location of the school building and parking
garage with multipurpose field on, top to the southwesterly corner of the new expanded
site. The MEPA process requires full public disclosure of a project's environmental
impacts as well as the measures that the Proponent will undertake to mitigate these
impacts. The process requires additional information and analysis to evaluate less
impactful alternatives; assess potential, environmental impacts; and identify potential
mitigation measures to ensure that the project is designed to avoid, minimize, and
mitigate Damage to the Environment to the maximum extent feasible.
Kathleen A. Theoharides
June 19, 2020
Page 2

Project Narrative

According to the information submitted, the proponent’s program of development of the

WHS project includes a 414,854 sq. ft. school building and a garage building of
185,150± sq. ft. with multipurpose synthetic turf field on top, totaling 600,000± sq. ft. in a
Single Family Residence A-2 Zoning district. The project includes significant and
dramatic earthwork with a 1,920 lineal foot rock wall to achieve final design grades of
the project, including significant bedrock blasting, excavation and onsite rock crushing
and trucking 70 truckloads of ledge daily for over a year. An early site preparation phase
will include clear cutting all trees and vegetation, grubbing stumps, earthwork, drilling,
blasting, grading, excavation, rock crushing, loading and trucking up to 747,000± cu.
yds of ledge and preparation for the building construction followed by construction of the
building. This quarry operation on 6+acres of what was public open space is an
unacceptable use of a residential neighborhood where the new proposed structures are
reportedly within 40 feet of several residential properties.

To hoodwink the public and you into thinking that the revised preferred alternative is
acceptable for the site of the new Waltham High School, the proponent has attempted
to shoehorn 600,000± sq. ft. of structures at an elevation of 4 stories or 60+ft. with
mechanical penthouses on top, into a constrained area with a stream, bordering
vegetated wetland, bank, buffer zone and watershed to the north, a 105+ft high blast
wall to the west abutting a public open space, and a precipice looming over residential
homes below to the south. The proponent has failed to fully explicate the need for an
ungodly oversized X shaped structure with 4 acre parking garage, located in the
southwest corner of the property as far from Lexington Street as possible, will meet the
educational needs of the students of Waltham especially since it doesn’t meet the
needs of the full Master Plan with expansion area, which was one of the prime reasons
for selecting the site originally. The siting process has completely ignored the
consequences of the 225 ft. elevation difference between the high and low points of the
property, the massive amounts of ledge, the impact that the project will have on the
groundwater hydrology, the impact that the project will have on the watershed, the
impact the project will have on the woodland and the resulting traffic nightmare that will
threaten, students, pedestrians, bicyclists, and motorists on Lexington Street. The truth
of the matter is that the size, location, and dimensions of the building could indeed be
further adjusted to eliminate the environmental damage that will be done to the wetland
and hillside. The school building could be moved easterly and the garage could be
accommodated on the original 47 acres without the use of Jericho Hill with some
competent architectural assistance. The cost of blasting and using Jericho Hill is an
unnecessary burden on the project.

Article 97

In reviewing the responses and documentation contained in the DEIR it seems that the
proponent, its law department and SMMA are playing to the audience with their
comments about open space, and its importance to the Citizens of Waltham, and the
Kathleen A. Theoharides
June 19, 2020
Page 3

City’s needs. Three important open space properties in a residential area are impacted
by this major development project, which is the largest since the development of 1265
Main Street and they are 554 Lexington Street (Stigmatines), 131 R Lincoln Street
(Jericho Hill) and Before 167 Lincoln Street (Sanderson Heights).

The reason that we know that they are open space properties is because the law
department cited them as such to the Defendant and the Court in their brief in the
matter of COMMONWEALTH OF MASSACHUSETTS, MIDDLESEX, SS SUPERIOR
COURT DEPT., CIVIL ACTION NO. 1881CV02385, CITY OF WALTHAM, Plaintiff, v.
THE TRUSTEES OF THE STIGMATINE FATHERS, INC., Defendant, CITY OF
WALTHAM'S MEMORANDUM IN SUPPORT OF ITS MOTION FOR SUMMARY
JUDGMENT ON COUNT I , Dated 5/1/2019 it cites the following on pages 5 and 6:

“The City had studied its open space needs and 554 Lexington St. had been
considered for acquisition for such open space since 1994 and consistently through
the date of the taking order. In 1994 the parcel was included in the City's Open Space
and Recreation Plan in the section titled "Inventory of Lands of Conservation and
Recreation Interest" and provided: "[a]ugment open space at Stigmatine Fathers" in
section titled "Areas for Open Space Protection." Next, the City's Community
Development Plan, submitted to the City Council in 2004 and adopted by the City
Council on June 11,2007, also identifies "the Stigmatine ... " property as a parcel to
be added to the City's inventory for open space by acquiring "Jericho Hill, Stigmatine
Center and Sanderson Woods properties to create a contiguous open space. Indeed,
it provides in a section titled "Open Space Connections" that the City should "[ e ]xplore
creating a series of attractive corridors/trails/paths linking parks, open space ... This
can be started by acquiring or securing permanent public access to several key open
space parcels, including the Lincoln Woods property, the Stigmatine Espousal
Center ... amongst others." In fact, these two parcels in the general vicinity of 554
Lexington Street, were acquired for open space use. On September 25,2007, the City
voted to take by eminent domain a 26.339 acre parcel identified as "Bef. 167 Lincoln
Street, Waltham" (also known as "Sanderson Heights") for open space purposes;
indeed, the City paid $5 million for acquisition of said land by eminent domain. On
December 21,2001, the City voted to take by eminent domain a 6 acre parcel and a
21,815 square foot parcel known as "Lot 2 at end of Larchmont Avenue, Waltham,
MA" and "R-131 Lincoln Street, Waltham, MA" both for "municipal purposes" and the
City paid $750,000 dollars for acquisition of said land by eminent domain. Said land is
contiguous to 554 Lexington Street and the land has remained undeveloped to
date.”

And further in the footnote cited on page 6 of the brief it states the following:

“Updates to said Plan continued to include 554 Lexington Street as an area of interest
for future acquisition for open space: (1) in 2000, parcel listed in same section and also
includes parcel in section titled "Areas for Acquisition": "augment open space at
Kathleen A. Theoharides
June 19, 2020
Page 4

Stigmatine Fathers;" (2) in 2006, parcel listed in same section and included as "action"
item to "acquire Stigmatine property and Sanderson Woods to create contiguous
open space;" (3) in 2010 5-Y ear Action Plan, the Stigmatine parcel is again included
in chart detailing City's objectives and action plan to address Waltham's "open space &
recreational needs": "[a]quire Stigmatine property to create contiguous open space";
and (4) in 2015, the update states that the "Stigmatine property [has] been identified
as a priority area[ ] for protection.”

Then again on pages 15 and 16 of the same brief the following is found:

“The City's prior and continued interest in the taken land and surrounding parcels for
open space eliminates any inference of bad faith in the taking for open space. There is
ample evidence in the record to support this: City had studied its open space needs and
554 Lexington St. had been considered for acquisition for such open space. In 1994
the parcel was included in the City's Open Space and Recreation Plan in the section
titled "Inventory of Lands of Conservation and Recreation Interest" and reads
"[a]ugment open space at Stigmatine Fathers" in the section titled "Areas for Open
Space Protection." Updates to the City's Open Space and Recreation Plan continued to
include 554 Lexington Street as an area of interest for future acquisition for open
space in 2000, 2006, 2010, and 2015. In addition, the City's Community Development
Plan, adopted by the City Council on June 11, 2007, also identifies "the Stigmatine ... "
property as a parcel to be added to the City's inventory for open space by
acquiring "Jericho Hill, Stigmatine Center and Sanderson Woods properties to
create a contiguous open space." Here, the City has shown prior interest in the
neighboring land of the taken property for the public purpose of open space
given it took those two contiguous parcels for said purpose, and paid a
significant amount of money for said acquisitions.”

For the second time on September 19, 2019 in the same litigation, CIVIL ACTION NO.
1881CV02385, in the City’s brief filed as part of CITY OF WALTHAM'S
MEMORANDUM OF LAW IN SUPPORT OF ITS MOTION FOR SUMMARY
JUDGMENT the city filed the following on pages 18 and 19 of the brief:

“Here, the City expressed its prior and continued interest in the taken land for
open space (since 1994 through the date of the taking in various official
publications); plus, the City had previously acquired two contiguous parcels for
open space purposes (in 2001 and 2007). Similarly, the City's prior and continued
interest in the taken land for school purposes since January 2016 eliminates any
inference of bad faith in the taking for school purposes in 2018. Although the City had
long been interested in the taken land for open space, in January 2016 the City
realized the parcel could potentially be used as the site for the City's new high school
when it learned that the Defendant was exploring selling the property (note: at this time
the search for the new high school site was occurring). During negotiations to purchase
the parcel, the Mayor told Defendant that the uses for which the City sought to acquire
554 Lexington St. included school use and open space use.
Kathleen A. Theoharides
June 19, 2020
Page 5

And further in the footnote 25 cited on page 18 of the brief it states the following:

The City had studied its open space needs and 554 Lexington St. had been
considered for acquisition for such open space. In 1994, the parcel was included in
the City's Open Space and Recreation Plan in the section titled "Inventory of Lands of
Conservation and Recreation Interest" and reads "[a]ugment open space at
Stigmatine Fathers" in the section titled "Areas for Open Space Protection."
Updates to said Plan continued to include the parcel as an area of interest for future
acquisition for open space in 2000, 2006, 2010, and 2015. In addition, the City's
Community Development Plan, adopted by the City Council on June 11,2007, also
identifies "the Stigmatine ... " property as a parcel to be added to the City's
inventory for open space by acquiring "Jericho Hill, Stigmatine Center and
Sanderson Woods properties to create a contiguous open space." Two
contiguous parcels were acquired for open space use in 2001 and 2007.

These statements are admissions against interest by the law department of the City of
Waltham about the open space nature of the three properties, Stigmatines, Jericho Hill
and Sanderson Heights. The defendant, the court and the Citizens of Waltham had the
right to rely upon the representations made by the City attorneys about the open space
nature of these three properties.

Even the Environmental Notification Form filed previously in this matter by SMMA
contains the following:

Project Narrative
Existing Conditions

The project site is located at 554 Lexington Street in Waltham, MA. It is comprised of
three properties that are a total of approximately 46.5 acres. The parcels are identified
by Waltham assessors as R33-2-19, 19A, and 19B. The current zoning for these
properties is Residence A-2 (RA-2). The site was previously owned by the Stigmatine
Fathers Inc. Trust and is now owned by the City of Waltham. The site is bordered by
Lexington Street and residential properties to the east, conservation land to the west,
and residential properties to the north and south……

The building is proposed to be sited in the southwestern quadrant of the property,

adjacent to the Jericho Hill conservation land, such that the footprint of development
Kathleen A. Theoharides
June 19, 2020
Page 6

may be optimized, and open space preserved near the Lexington Street corridor. The
siting also does not require extension of developed land beyond the previous
development in the vicinity of the neighbors along Lexington Street, Lincoln Terrace and
Glen Circle.

Excerpt from Alternatives Analysis section of SMMA Environmental Notification Form

2 | p. 1 Waltham High School | Environmental Notification Form

Then again it the ENF contains this:

Alternatives #5 through #8 – 554 Lexington Street

Existing Site Description

The 554 Lexington St. site is comprised of three properties that are a total of
approximately 46.5 acres. The parcels are zoned as Residence A-2 (RA-2). The site
was previously owned by the Stigmatine Fathers Inc. Trust and is now owned by the
City of Waltham though an eminent domain taking in July 2018. The site is bordered by
Lexington Street and residential properties to the east, conservation land to the west,
and residential properties to the north and south.

Waltham High School | Environmental Notification Form 11 | p. 10

The third inclusion that is called to your attention on the subject is the following:
More recently we’ve learned that the Stigmatine Espousal Center could be
the location of our new high school. The Waltham Land Trust has
advocated for municipal acquisition of this 40-acre campus since our
inception in 2000. Combined with the City’s abutting 26-acre Sanderson Heights
and 6-acre Jericho Hill Summit parcels, these properties comprise one of the
largest unprotected open space resources in the City and form the connection
between the Western Greenway and Prospect Hill Park.

Excerpt from 12/6/2016 Statement of the Waltham Land Trust contained in

Waltham High School | Environmental Notification Form (Pg. 823 of pdf)

The final item in the ENF called to your attention is the following:

3. Set aside a location for public trail access into the woods above and
Kathleen A. Theoharides
June 19, 2020
Page 7

behind the school, so that future trail builders can connect the existing trail
network at Jericho Hill and Sanderson Heights to the Western Greenway
Trail at Chesterbrook Woods.
Excerpt from Letter of Waltham Land Trust to the Waltham School Building Committee
contained in
Waltham High School | Environmental Notification Form (Pg. 825 of pdf)

Further review of the Order of Taking of the Stigmatines’ property at 554 Lexington
Street reads as follows:

The purpose of the taking is spelled out as “for the purpose of educational use, open
space, or combination thereof.” If a significant portion of the 46+acre parcel taken
can not be utilized to build a school or any other supporting use, why is 100% of every
square foot of the property being devoted to educational use when it can not be used for
that purpose. Not one square foot is set aside for open space despite the repeated
Kathleen A. Theoharides
June 19, 2020
Page 8

acknowledgement by the City that that use is appropriate for all or at least part of the
property. A more informed, prudent and reasoned approach to the use of the parcel
would be to use that portion that is capable of supporting school use for that purpose
and using the portion that is not capable for school use for open space, the use that has
been indicated for the Stigmatine property since 1994 by the various studies previously
recited. The City Council who voted to take this property recognized this reality by
including the specific “purpose language” acknowledging both open space and a
combination of open space and educational use in the order of taking. The City’s own
studies and documents included in the DEIR indicate that such an approach would be
reasoned and prudent. Would a court, if fully informed of all of the facts and the amount
of land that cannot be used for educational purposes, for a variety of reasons many of
them regulatory prohibitions, and physical impossibilities, not at least consider an open
space use like that contemplated under Article 97 to be a valid use of the property
worthy of open space protections. A review of the proponent’s documents indicates that
at least 20 of the 46+ acres are likely unusable in connection with improvements for
educational use.
Similarly, as to the 6 acres at Jericho Hill, a review of the proponent’s documents
indicates that 100% of every square foot of the property is to be devoted to educational
use. In reality, according to the proposed plans, there is only about half of the property
anticipated to be used for educational purposes on the southerly side of the property
and the balance on the northerly side is not contemplated for use. Many of the reasons
which make use of the northerly portion unusable relate to physical impossibility without
substantial, even extraordinary, expenditures of funds to make the property useable.
Again, would a court, if fully informed of all the facts and the amount of land that cannot
be used for educational purposes, not at least consider an open space use like that
contemplated under Article 97 to be a valid use of the property worthy of open space
protections especially given the previous history that was recited about use of the
property for open space?
These are but a few examples of the double speak that exists about this subject from
representatives of the proponent. Article 97 of the Declaration of Rights, GL c. 30 § 61
and the requirements of the EEA Article 97 Land Disposition Policy all indicate that
Citizens of the Commonwealth are entitled to the quality of life that clean water and
open space provide. Use of all practicable means and measures to minimize damage to
the environment in projects such as this one that encompasses such a broad range of
environmental issues is extraordinarily important to the preservation of such a valuable
environmental resource. Every documented pronunciation by the City of Waltham about
Sanderson Heights, Jericho Hill, and 554 Lexington Street available indicates that these
are three extraordinary natural assets worthy of preservation as open space.
There is nothing in any City documentation, that calls for the one of the largest most
massive structures with extraordinary breadth height and size in all the City of Waltham,
Kathleen A. Theoharides
June 19, 2020
Page 9

to be built on any portion of these three parcels. And yet, as a result of the December
7th, 2017 vote of the School Committee, after significant arm twisting and without the
benefit of any engineering data or any feasibility study, with a litany of questionable
representations, a vote overriding the November 17, 2017 vote of the School Building
Committee to locate the new high school at 617 Lexington Street occurred. Not one
word of acknowledgement of the years of environmental review and analysis about the
Stigmatine property was ever presented or discussed. Not one word was uttered by the
pro development-oriented school committee with visions of a monument to their egos,
about the preservation of even one square foot of 554 Lexington Street for open space
or conservation use. .
Reasonable minds would have at least entertained some discussion of the possibility of
preservation of the stream, the bank ,the bordering vegetated wetland, the watershed,
the woodlands, the vistas, the natural elevations of the property, the woodlands, the
flora, the fauna, the ledge and soil conditions, the wildlife on the property, and the
pristine nature of the property. And no discussion occurred about preserving any of it
and instead avarice and greed took over as the School Committee and Mayor sought to
confiscate the property to create an engineering nightmare. And now here we are on a
day of reckoning relative to the use of the property. What would a court say after
reviewing Smith V. City of Westfield, 478 Mass 49, relevant statutes and regulations
and the other case law and president on the subject. Maybe a court would side with the
proponent, but maybe the court might not. What about a split decision and the time it
might take for the matter to wend its way through the legal system? To ignore the issues
around Article 97 protection for all 3 properties is likely folly on the proponent’s part.

But more important is the question of why the proponent wont even acknowledge that a
significant portion of the property is worth protecting as open space. Why hasn’t the
proponent come forward and offered to make at least 20 acres on the northerly side of
the 554 Lexington Street and 3 acres, if not all, of Jericho Hill as deed restricted open
space for use by the Citizens of Waltham for at least 50 years. Doing so would at least
be an acknowledgement to the community of the importance of these valuable natural
resources which have long been recognized as important open space. To fail to do so
would clearly show the bad faith and unfair dealing of the School Department and the
Mayor relative to these properties.

Emergency Access

A continuing issue related to the project is the issue of an Emergency Access way to the
campus as recommended by the Police Chief and the Fire Chief as a matter of public
safety. In order to deal with this issue, the proponent has devised a scheme to provide
access from Lincoln Street through a 20 foot private way sometimes called Lincoln
Street, Extension which provides access to three residences on the way numbered 75,
79. 81 and 85 Lincoln Street. This private way essentially ends at the southerly
boundary of the Stigmatine property which it once served as a point of access. That
Kathleen A. Theoharides
June 19, 2020
Page 10

access was essentially terminated by the Stigmatines several years ago and the only
property rights remaining to pass and repass are to the properties abutting the way
including 75, 79, 81 and 85 Lincoln Street. Currently there is a narrow-paved surface
approximately 20 feet wide on this way. In addition, there are utility easements for the
benefit of the City which allow the City of Waltham to construct and maintain water,
sewer, and drainage lines on the way. The City of Waltham does not have the right to
pass and repass from Lincoln Street to 554 Lexington Street. To legally acquire the
rights to pass and repass to the property, the City would either acquire these rights from
each of the abutters through out right purchase or by making an eminent domain taking.
Each of the abutters would have to agree to sell these rights to the City. It is anticipated
that between issues of severance damage and direct damage the value of the
easements is significant because of the public project for which the acquisitions would
be made as well as the sale of the rights themselves.

Another factor to be considered is the history of the acquisition of the rights to the
emergency access road at the current Waltham High School which leads out Woodcliff
Drive to Forest Street. That emergency road was constructed for the purpose of
providing emergency access only to the high school. After several years of traffic
problems at 617 Lexington Street the City recognized that an additional means of
access was necessary to mitigate the traffic problems. The City then decided to open
the access road gate from 6 am to 3:30 pm daily allowing anyone to travel from Forest
Street to Lexington Street or the reverse from Lexington Street to Forest Street daily
from 6 am to 3:30 pm. What a nightmare it was for the neighbors who ultimately sued
the City and that use of the access road continues to this day. The neighbors have
every right to be concerned and have every right to sue for damages. They will not be
coerced into allowing access to 554 Lexington Street from Lincoln Street Extension.

The current plan for the access road on the Stigmatine property will be located on the
side of a cliff with very steep grades, a growth of trees and an outcropping of ledge. The
proposed emergency access road is shown on the plans as terminating at the top of the
hill at this piece of ledge at elevation 160± ft. Little soil exploration has occurred in the
proposed area of the emergency access road. The topography in the area indicates
grade changes from a low at elevation 125± ft. to a high in the area at elevation 178± ft.
The length of the road is approximately 250± ft. in length resulting in a grade on the
proposed road of 15±%., which will certainly be a challenge for a large piece of
equipment like a fire truck or snowplow. Even smaller vehicles will be challenged in New
England winter weather or other major precipitation events. An acknowledgement of the
grade issues on the Emergency Access road is found on the plans in this area which
show the need for a guardrail for safety purposes. Curiously no drainage structures of
any kind are shown on the Emergency Access Road and most assuredly significant
rainwater or snow/ice melt runoff will occur down this road, given its length and
breadth, onto the private property and/or the private way below, a condition that will
certainly result in a challenge and litigation from the neighbors if not corrected.
Kathleen A. Theoharides
June 19, 2020
Page 11

Reportedly gates will be located at the top and the bottom of the access road to control
use of the road and reportedly to prevent students from using it as a shortcut to and
from school. It will be interesting to see if it has exactly the opposite effect and instead
acts as an invitation to students to hop the fence.

Statutory and Regulatory Requirements

Based on a review of the Statutory and Regulatory Requirements section of the DEIR,
virtually none of the required regulatory approvals and permits have been received to
permit this school project to continue. Several variances and special permits are
referred to but not specifically defined as to the relief sought. Apparently, no permits will
be needed for the quarry operation and massive amount of site work and blasting
needed for this project. The scheduling of the approvals is also suspect and makes no
mention of the opportunities that the neighbors will have to provide public input and
appeal matters that require further scrutiny.

Anti-Segmentation

The proponent continues to say that it will not subsequently expand any aspect of the RC 1
project at hand and when neighbors have asked for written assurances from the
proponent that no additional playing fields, parking lots or expanded facilities will be
added to the project at some later date, those written assurances have not been
forthcoming. An open space/conservation restriction on at least 20 acres of the site
would go a long way toward allaying the neighbor’s worst fears. During discussions
about athletic facilities and specifically those at Leary Field, various improvements and
upgrades have been discussed because of the perceived current inability to locate the
track, the football field, and the baseball field on the proposed campus. Particularly
troublesome are allusions to expansion and relocation over time of many off-site athletic
facilities. Where is the real master plan for the proposed new high school dealing with RC 2
each and every aspect of school facility needs along with the proposed solution? What
about the athletic fields’ master plan and the details of how current and future athletic
field requirements will be met?

Virtually no discussion has taken place regarding the likely disruptions that construction
at 554 Lexington Street will cause to both Kennedy Junior High School and the existing
Waltham High School. Traffic is the obvious thing that may cause disruptions, but it is
likely that pedestrians will be inconvenienced, students traveling to and from school by
foot and bicycle will be inconvenienced, as well as delivery vehicles to both of these
facilities. It is highly probable that with these potential traffic problems, vehicles will
enter and exit both the high school and junior high school from Forest Street and
Woodcliff Drive over the high school access road. Why haven’t any of these issues
been addressed?
Kathleen A. Theoharides
June 19, 2020
Page 12

Land Alteration

One of the major changes made to the project plan is the addition of the six-acre
undisturbed Jericho Hill open space to the property resulting in a total land area of
52.5± acres. Like the site at 554 Lexington Street, Jericho Hill has significant grade
changes from a low of 180± feet in the southeasterly corner to a high point of 330± feet
in the northwest corner. The overall grade change of 150± feet poses significant
challenges especially since the primary subsurface material in this hillside is a very
substantial quantity of ledge. Other assets of this site are its vistas and its woodlands,
both of which contribute to its open space qualities. Unfortunately, none of these
features can be incorporated into the proposed expansion plan for the high school and
instead, a significant portion of the southerly end of the site will be blasted to make way
for the 450-car parking garage with synthetic turf fields on top. The blast wall, which will
surround the westerly and northerly sides of the structure, will vary from an elevation of
0 feet to over 105 feet. The risk imposed by this blast wall apparently have yet to be
realized and there is virtually no discussion by the School Committee, the Mayor or the
School Building Committee about the potential impact of this wall on the persons using
the school building.

One of the most significant aspects of this whole project is the massive amount of
course work that will be needed to provide a suitable site for the school building, the
parking garage/multi-purpose field, surface parking, and means of access and egress to
the site. Virtually no portion of the 24± acre portion of the property that will be developed
will remain undisturbed. Whether it’s blasting, cutting, filling, regrading, or leveling, all
aspects of the work will be very impactful to the site.

Blasting will likely be the most impact aspect of this project. 747,000 cubic yards of rock
removal is due to take place. The only way that such a massive amount of ledge could
be removed is by clear cutting all the trees and vegetation from the blast area, grubbing
and stumping of old tree roots, stripping the top soil from the site, drilling for days on
end, significant blasting, excavation of rock, rock crushing, truck loading, truck travel
over local roadways and State highways, shipping the ledge which has been sold to
buyers of the end line product at various locations likely in and out of state.

The blasting that will take place is so expensive that it extends below the water table in
the hillside of the property. This blasting will have a significant impact even on the ledge
that remains. Fissures of all types and sizes will develop in the remaining rock and
serve as an entry point for any of the surface or subsurface water which accumulates on
the site. Significant precipitation events will likely result in significant quantities of water
entering these fissures and from there, gravity will do the rest. Water flow will likely go in
all directions according to the where the fissures lay and despite this, those significant
hydrogeological study has been completed on this property that provides a detailed
indication of where water will go and whether it will impact lower lying residential
property. In the interest of fairness, they lower lying neighbors deserve to be informed RC 2
about the impact that water flow will have on their property. Failure to complete such a
Kathleen A. Theoharides
June 19, 2020
Page 13

study in advance of any blasting or construction leaves the neighbors at grave risk.
Even after such a study, continued testing and monitoring will likely be required to RC 2
protect the neighbors.

All manner of sensitive receptors will be impacted by this blasting operation. Whether it
is noise, vibration, dust, etc. no one and no property will escape the impact of such an
extensive blasting operation. All manner of testing, monitoring, and reporting on the RC 3
impact of the blasting should take place to protect the community. Streets, utilities,
structures, especially older structures with fieldstone foundations, will likely experience
an impact because of the blasting. People, animals, birds, and even pollinators will first
hear the shrill blast whistle followed by an explosion and vibration thanks to the
invention of George Nobel. Given the size of this blasting operation, not only should the
local fire department be involved in monitoring the creation of this quarry hole, but also
the State Fire Marshal should also be consulted and advised about the level of activity
that will occur at 554 Lexington Street.

Why is it unreasonable for the neighbors to be concerned and to ask questions about
this whole blasting process? Why won’t the proponent explain to the neighbors what the RC 4
process will be before blasting, during blasting, and after blasting if they experience any
kind of a problem or damage resulting from the blasting? Who bears the responsibility
for any damage to persons or property, is it the City, the blasting contractor, the
construction manager, the architect, or all of them? When will the City explain exactly
what the neighbors need to do to file a claim against any responsible party? Will the City
establish a fund that will assist the neighbors in filing a claim against any precipitating
party? Will the City ever respond to the numerous questions and inquiries made by the
abutters, the neighbors and community members about all aspects of this project?

Impervious Area

One of the significant areas of impact from this project is from stormwater flow. This
property has an existing area which has been developed that currently deals with both
stormwater and groundwater. As part of the construction, dramatic changes are
proposed in the property that will impact both stormwater and groundwater significantly.
There are also Federal, State, and Municipal laws and regulations that govern the
impact that a significant developer, like the City of Waltham, can have on both
stormwater flow and groundwater flow. While some analysis has been done regarding
these factors, little substantive discussion has taken place about how the proponent will
meet its obligations under every aspect of each of the three regulatory schemes that
must be satisfied. Since water, both above and below ground, is such a valuable
resource on the Commonwealth, every aspect of protection should be analyzed,
discussed and concrete solutions presented to protect this valuable resource. Minimum
solutions and discussions of problems do not protect the citizens of Waltham and the
Commonwealth whose valuable assets need to be protected. Will the proponent’s RC 5
proposals fully recharge the ground water on the subject property as required by
statute, ordinance and regulations? Will the groundwater drainage structures result in all
Kathleen A. Theoharides
June 19, 2020
Page 14

stormwater staying on the property? What are the neighbors to do if stormwater and
groundwater negatively impact their property? Particularly important in this project is the
impact upon stormwater and groundwater and there should be no reason not to comply
fully with Federal, State and Municipal stormwater standards.

Another important aspect of stormwater and groundwater is the preservation of water

quality. A project like this one should not be a threat to our environment and watershed
resources. Water quality is important on the property and water quality is important as it
leaves the property. Neither the City of the State should be satisfied with substandard
water quality from this project. An important part of this process relates to rainwater
management and groundwater flow. Runoff volumes from both sources should be fully RC 5
analyzed and evaluated so that regulatory standards are not exceeded. Full
understanding of hydrogeological conditions for this property including both surface and
groundwater flow rates, are extremely important. Adequate borings, test wells, pump
tests, and full evaluations need to occur well before a spade full of dirt is turned
signaling the start of this project. Extremely important to the neighbors will be the study
and evaluation of the surface water and groundwater flow and the direction of that flow.
Assurances need to be given that the maximum amount of testing, analysis and design,
has been done as part of this project so that adjacent properties remain fully unaffected
by the work done for the new Waltham High School.

Wetland Delineation and Wildlife Resources

A review of the DEIR indicates a substantial change in the impact that the former
preferred alternative would have on this project. Gone from consideration is the
elimination of the stream and surrounding wetlands found in the central section of the
property. This is a positive step toward improving the project.\

A closer review and analysis of the proposed improvements indicates that any claim of
no impact on the wetland is a distortion of reality. The prime culprit in this distortion
results from the creation of a blast wall within the wetland buffer zone mere feet from
the stream, the bordering vegetative wetlands, the bank, and the watershed. A review of
the proposed plans indicates that the blast wall essentially parallels the watercourse.

The following plan shows the watercourse, the wetland, the undefined wetland, and the
wetland buffer. Also shown is the chain-link fence, the blast wall, the collector trench,
the regraded area, the 24’ wide access driveway, the water/sewer/drainage/gas utilities,
the sidewalk, and the proposed building location.

A review of the blast wall elevations just below the elbow where the blast wall changes
direction indicates that the wall that will be blasted will be 60’-80’ below the adjacent
ground which contains the wetland buffer, the wetland, and the stream. From there the
elevation of the blast wall decreases to 0’ at the southerly end of the wall. A review of
the plans indicates that the proposed elevation (147’) adjacent to the undefined wetland
area is approximately 18’-25’ below the wetland and the stream (165’-170’).
Kathleen A. Theoharides
June 19, 2020
Page 15

Expert from Grading & Utilities Plan I - C-131

When the blast wall is created, fissures will develop in the face of the wall allowing
water from the wetland to flow into the drainage trench at the foot of the wall. The
impact of allowing the water to divert and flow into the fissures caused by the blasting,
will have a negative impact on the water flow both on the property and ultimately into
the Chester Brook. An easy way to portray the impact is to imagine a full bathtub which
when the plug is pulled, drains to the lowest elevation. So, it is here, when the blasting
occurs, the water the of the water will largely be governed by the width and depth of the
fissures which will allow the waterflow through the through the remaining ledge which
has been fractured by the blasting.

Given that the overall project calls for the blasting of 747,000 cubic yards of ledge and
the creation of a blast wall of 1,920± linear feet, the existing wetlands will most definitely
be impacted in a negative way. The rate of flow, the direction of flow, and the amount of
flow cannot but help to be affected by such significant blasting.
Kathleen A. Theoharides
June 19, 2020
Page 16

Other impacts caused by the construction and associated earth work includes sill
placement, pavement, sidewalks, utilities, landscaping, and other activities within the
wetland buffer. Reportedly as part of the new construction, 1.45 acres of the buffer zone
will contain pavement, grading material, lawn, and utility structures. Of course, these
estimates are without the benefit of the fully restored, undefined wetland area that the
City of Waltham Conservation Commission ordered restored. The enforcement order
dated October 10, 2019, requested the City to remove brush and debris and that the
Resource Area be restored and returned to its original condition. So why hasn’t the City
of Waltham restored the wetland area so that we would have an accurate understanding
of where the stream, the bank, and the wetland is located? Without an appropriate
restoration and a corresponding survey, we cannot be certain exactly where the wetland
and the wetland buffer are located.

A review of the plan of the currently preferred alternative, indicates exactly how much
SMMA’s plan extends into the wetland buffer. Aren’t they overreaching by constructing
the building, the access road, and the service driveway in such proximity to the
watershed and wetland resource? The construction poses significant threat to both the
wetland and watershed. Earth work and blasting are parallel to a 280’ lineal section of
the southern portion of the intermittent stream approximately 50’ south of the stream
channel. The bedrock walls, at heights ranging from 0’-40’ along this portion of the wall,
will have a negative impact on the stream and the wetland.

A review of plans covering the watershed area, indicates that a portion of the watershed
will no longer flow into the intermittent stream because of the proposed blasting and
rock wall. The exact area impacted is not known because the wetland area has not
been restored and fully delineated. This is a negative impact on both the wetland and
the stream.

Why hasn’t a subsurface exploration program been conducted before the design of the RC 6
bedrock cuts and blasting for the rock wall? Subsurface exploration is needed in
advance of such a challenging design using explosives. The intricacies of the bedrock
to be removed as well as the intricacies of the bedrock that will remain with their joint
patterns are an absolute must before any environmental approvals of any kind can be
granted in connection with this project. Such a study is necessary to judge the impacts
of the surface flow within the stream channel. Prudent and competent evaluators or
peer reviewers should be consulted prior to undertaking any regulatory permitting for
this project. No errors can be allowed protecting this valuable resource, after all, it will
be impossible to make any corrections once the dynamite explodes.
Although a change has been made since the last preferred alternative, the current
proposal deserves further review and change so that the expansive tentacles of the “X”
shaped school structure should not extend into the wetland. There should be no debate
about whether the children’s education is more important than the full preservation of a
wetland area, the truth is they are both important and can co-exist if a school building is
favorably redesigned to acknowledge all of the site’s constraints. Why can’t creative
Kathleen A. Theoharides
June 19, 2020
Page 17

engineering and architecture be employed to preserve the wetland, the watershed, and
the open space on this property?

Infiltration and Inflow Mitigation

Sewer discharges for a new construction project like the one contemplated here, are
covered both by Waltham City Ordinance and an Administrative Consent Decree with
the Massachusetts Department of Environmental Protection. A full accounting for all RC 7
discharges in the sewer system should be fully documented and presented so that it
can be determined if the City is meeting its required inflow and infiltration requirements
of removing four gallons of infiltration inflow for each additional gallon of wastewater that
will be discharged into the sewer system. A thorough analysis of both 554 and 617
Lexington Street should be documented and presented for all to see. The City and DEP
requirements should be documented, and a complete explanation made of existing
gallonage, proposed gallonage, and the way gallonage will be removed from the sewer
system. An accounting of the details of the sewer bank should be made available and
the analysis for applying the credit disclosed including the requirement for any financial
payment. Bold assertions without full disclosure are unacceptable.

Transportation

All Citizens of Waltham are reminded about the previous review and comments made
by the City’s Traffic Engineer and submitted as part of the ENF process and review.
Most unwanted, but most memorable were his comments about the gridlock that he
anticipates for Lexington Street when Waltham’s schools are in session. He predicts
daily gridlock on Lexington Street during the 7-9 am time. This one observation has
many Waltham Citizens wondering why we would want to place a new high school in
this location, which when all on costs are accounted for, will exceed half a billion dollars,
the most expensive school in the country. Yet after all out planning and design, we
cannot adequately deal with the traffic generated without having significant gridlock
daily. As acknowledged by Mr. Garvin, the best possible location for the new high
school from a traffic perspective is 617 Lexington Street with its dual means of access
and egress and its central location with known traffic impact. Also missing from the
discussion is the impact of the new intersection at Lexington Street, Totten Pond Road
and Bacon Street which could also impact the equation.

Another factor related to transportation which deserves some explication is the

expenditure of $45,000,000+ for the construction of a parking garage? That cost when
combined with the site construction, blasting, and site preparation costs of
$64,282,992 results in over $110 million dollars of construction costs when the complex
finally gets built. What is the environmentally justifiable reason to spend $45 million for
the garage and then another $64.2 million for blasting and site preparation? How does
the expenditure of $45 million for a parking garage reduce in any way the carbon foot
print of the school?
Kathleen A. Theoharides
June 19, 2020
Page 18

Greenhouse Gas Analysis and Sustainability

A review of the DEIR report shows much data and many gyrations to get to a result, but
it fails to answer some basic questions that are an important part of any environmental
analysis? First and most obvious is why is such a costly school not even dealing with a
sustainable energy source? Even the existing high school has solar panels on its roof
that obviously provide both a financial and environmental benefit to the City. Yet the
new high school is designed to hold solar panels, but they are not part of the project
without any justifiable explanation.

The next discussion which fails to meet expectation is why there is no adequate and
realistic discussion about the carbon footprint of the building, the greenhouse gasses
generated and the impact of the project on climate. The discussion that takes place
seems almost perfunctory and directed to a desired result with no detailed explanation,
analysis and justification of the choices made either from an environmental or financial
basis. Even the green roof analysis leaves most readers asking why bother, if you are
not fully committed to it. Here we have the most expensive and theoretically the most
technologically advanced high school in the country and we don’t even receive a
logical, supportable and justifiable explanation about what this building achieves in
protecting the environment.

Another issue around the green roof relates to the Master Plan goal of having an area
for expansion. Recent comments and discussion indicate that because of the
constrained site and the poor design the only place that an expansion could take place
is on the roof of the front section of the building where the green roof is proposed. Why
put the green roof where it will likely be removed soon? Also there has been significant
growth in school enrollment recently so maximum capacity may be achieved sooner
than anticipated. Another reason for choosing this site besides its expansion capability
is that we can avoid classroom interruptions by not locating the new school near the
existing school. Yet here a new floor on the building for expansion purposes will result in
school interruptions that we should be avoiding. How are these issues to be rationalized
and reconciled?

Construction Management Plan

The details of the construction management plan (CMP) in the DEIR contains only
limited information on the issues that will be of the most interest to the abutters, the
neighbors, and the Citizens of Waltham. How will complete transparency achieved with
the contractor, Leftfield, and the neighbors? Let us start with the issue that is seen as
most consequential to the neighbors, the blasting. First, where is the plan and list RC 8
showing the location of all the houses that will be entitled to a pre-blast/pre-demolition
survey in connection with the project. What are the details of how the pre-blast/pre-
demolition survey will be conducted? Will the property owners be provided with copies
Kathleen A. Theoharides
June 19, 2020
Page 19

of the plans, the photos, the videos, and the written survey? What will the pre-
blast/pre/demolition survey consist of, who will complete it and when will it be done?
Next the CMP is silent on what testing, monitoring, reporting, analysis and mitigation RC 9
will be done during demolition, construction, and blasting of vibration (seismograph),
dust and air quality, wind direction, wind speed, and noise? All this testing should be at
the adjacent property lines and should include, 24/7/365 coverage of the construction
site. The results of the testing in the interest of complete transparency should be
published on- line and available for all to see. Construction cameras from all 4 points of
the compass should be available on line 24/7/365 during the period of construction. The RC 10
Mayor has promised repeatedly that sound barriers and sound mitigation will be
available to the neighbors. Please tell us how that will be accomplished and when?

What monitoring of volume and quality of storm water, rainfall, snow fall, ground water, RC 11
storm surges, test well monitoring, and quality testing will occur? Erosion control,
dewatering and groundwater management are extremely important to the downhill
neighbors. Please provide the details of when testing will occur, how, who will do the
testing and how will it be made publicly available?

Who will be the person responsible for handling complaints, and how are they to be RC 12
contacted?

What part will Leftfield/Jacobs play in the construction monitoring process and in the RC 13
interest of complete transparency how will they communicate with the abutters, the
neighbors and the community daily about the project and the problems being
experienced at the job site?

Rodent control is another major concern and there is virtually no information available? RC 14
How will that issue be handled and by who?

Mitigation and Draft Section 61 Findings

A close and careful reading of the mitigation and Draft 61 findings for the project leaves
anyone with even a cursory knowledge of the project asking the question “Who drafted
this section of the DEIR, how did they do it and why did they do it in this way? As to who
drafted the mitigation and Draft 61 findings, the answer is very obvious, it clearly was
SMMA who has quarterbacked every single aspect of this project right from the very
beginning including from the selection of the School Building Committee on November
14, 2016 to build the New High School at 617 Lexington Street Without question they
have facilitated, enabled and made possible every aspect of this project. All of that
clearly shines through their presentation.
Kathleen A. Theoharides
June 19, 2020
Page 20

Ever since the School Committee overturned the School Building Committees vote
SMMA has jumped to their every command; the only issue has been how high? And
now we see how high they are willing to jump. There is virtually no aspect of this project
that is fairly portrayed so that a prudent and unbiased person would buy into every
aspect of this project without at least some significant level of concern about how this
will impact the community in a negative way.

The reason why SMMA has done what they have done is also obvious. The answer
appears in the Architectural and Engineering budget where the sum of $33,834,500 is
set aside for SMMA and their team.

But at what cost is this being pursued without any regard to the neighbors? Those who
have the most to lose in this whole process have not been given a seat at the table,
they have had their questions and requests for information ignored time after time
meeting after meeting by SMMA, the SBC, the SC and the Mayor. There had been no
dialogue on any aspect of this project with anybody outside the Mayor’s inner circle.
We now know who is in charge and it is in the spotlight for everyone to see.

The neighbors, abutters and Citizens of Waltham now know what it feels like to have
someone’s knee on your throat….with no one paying attention to what is going on…. As
the neighbors, abutters and Citizens of Waltham gasp….I CAN’T BREATHE….!

I urge you and the Massachusetts of Office of Energy and Environmental Affairs to
consider my comments and consider extending the period of analysis and review for
this project especially in light of the Governor’s order regarding COVID-19 I also urge RC 15
any and all from Massachusetts of Office of Energy and Environmental Affairs involved
in the decision making on this project to take the time for a complete site inspection
especially because of the Notice of Project Change filed with this DEIR .
Kathleen A. Theoharides
June 19, 2020
Page 21

I thank you for your time and patience in reading the materials assembled in this letter
to you. Please acknowledge that you have received this letter and please keep me on
your mailing list especially for all of your decisions.

Sincerely,

Robert L. Coleman
249 Smith Street
Waltham, MA 02451
rcolema1@ix.netcom.com
781-890-3999
 Section 8: Responses to Comments

8.7.17 Corbett, Amy

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 51

 Section 8: Responses to Comments

8.7.18 Cortellini – Devine, Lynelle

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 52

From: lynelle c
To: Czepiga, Page (EEA)
Subject: Waltham High School, EEA# 16097
Date: Monday, June 1, 2020 3:45:17 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hello,

I am writing in deep support of the new high school planned in Waltham.  I am a mother of
two young elementary school children and I am thrilled that my children will have the
opportunity to attend this new, state-of-the-art, forward-think high school. 

I've lived in Waltham for more than 10 years and during that time I have been witness to the
many concerns that have been raised over the years (and years and years) about the building
of a new school in this city.  This project has been delayed for too long and too many students
continue to miss the opportunity to attend the new school.  My eldest child is now 8 and I am
hopeful he will be one of the first classes to spend his whole high school experience in the
new school.

This project is supported unanimously by city leadership, including the City Council, School
Committee, and School Building Committee. We are all counting on MEPA to help move this
project forward as quickly as possible so that we can make this amazing new educational
facility available for our city.

Thank you,
Lynelle Cortellini-Devine
Waltham, MA
 Section 8: Responses to Comments

8.7.19 Cyr, Rebecca

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 53

 Section 8: Responses to Comments

8.7.20 Davidson, Jaclyn

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 54

 Section 8: Responses to Comments

8.7.21 DeSautels, Michele

MD 1

The DEIR mentions and shows in several places that there will be a security gate on the school side, and a chain link fence
on the public street side. However, there is no mention of any locks on them. Will there be locks and who has access to the
keys?

There will be Knox Locks on both gates and the Fire Department and Police Department will have keys to the
gates.

MD 2

The project still does not discuss the potential impact to ancillary streets, such as Lincoln Street, which is already a cut
through for traffic and documented in a Police community traffic study.

Off Site improvements at subsequent intersections will not be implemented as part of this project. Traffic on
these streets was discussed at the Traffic Commission meeting on August 4, 2020.

Waltham High School | Final Environmental Impact Report 5 | p. 55

June 11, 2020

Secretary Kathleen Theoharides

Energy and Environmental Affairs
State of Massachusetts
100 Cambridge St, Suite 900
Boston, MA 02114

Honorable Theoharides,

I am writing to you about EEA#16097, the Waltham High School Project. Thank you again for deciding
that this project was required to undertake a Draft Environmental Impact Report (DEIR). After
reviewing the voluminous and detailed set of documents, it has become clear that the project team
has addressed many of the concerns that I raised in my letter on the ENF last year. However, there are
still outstanding questions that I have.

• Emergency Access Path – The DEIR mentions and shows in several places that there will be a
security gate on the school side, and a chain link fence on the public street side. However, there
is no mention of any locks on them. Will there be locks and who has access to the keys? Section MD 1
11 lists only “Con” to the DEIR alternative – “Reduces buffer to residential neighbors on south
side”. To help mitigate the impact to residential neighbors, the project application should state
that locks will be utilized and only unlocked in case of emergency.

NOTE for SMMA: on Page 8, there is a reference to Police and Fire Chief letters in the
Appendices, 2.6 and 2.7. The actual numbers are 2.5 and 2.6.

• Traffic – The project still does not discuss the potential impact to ancillary streets, such as MD 2
Lincoln Street, which is already a cut through for traffic and documented in a Police community
traffic study. It is already challenging to take a left onto Lexington Street from Curve Street. The
modifications with a new lane and traffic may exacerbate the problem. It would be helpful if
the City of Waltham could commit to undertaking a traffic study once the school is open to
determine if additional mitigation measures are necessary to reduce the impact on side streets.

• Conformance and compliance – This is a big, expensive construction project. While there is
mention of a construction manager, it is not clear how the project will be monitored, especially
for the expected sound, vibration, and physical damage to surrounding houses. Will the MEPA
office have a requirement for regular public reporting of the items described in the DEIR?

Although there is no requirement to notify ENF commenters of upcoming regulatory requirements as

identified in 2.7, it does not seem like a heavy lift for the project team to email those interested once
they are filed. This type of communication would add a layer of transparency to a complex project.

Thank you for the opportunity to comment on this project.

Sincerely,

Michele DesAutels, 84 Lincoln St, Waltham

 Section 8: Responses to Comments

8.7.22 Devin, James E. Jr.

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 56

From: jdevin501@verizon.net
To: Czepiga, Page (EEA)
Subject: EEA#16097
Date: Thursday, June 18, 2020 7:25:15 PM

CAUTION: This email originated from a sender outside of the  Commonwealth of Massachusetts mail system.  Do
not click on links or open attachments unless you recognize the sender and know the content is safe.

Dear Ms Czepiga:
I am writing because of my concerns related to the building of the new Waltham High School.  There will be
considerable blasting estimated at 900,000 square feet of earth, as well as the related Increase in traffic generated by
construction vehicles to haul the rubble away.  The blasting will result in excessive noise in the neighborhood, as
well as dust and pollution being released in the air.  The cutting down of hundreds of trees and the blasting will
affect the wildlife that lives there.   Consideration must also be given to the wetlands and stream that are on the
property and the water run-off that will occur. Neighborhood homes will be subject to structural damage because of
the blasting.  The blasting and construction will also cause a rodent problem.

Sincerely,
James E. Devin, Jr.
Sent from my iPad
 Section 8: Responses to Comments

8.7.23 Dolobowsky, Reva

RD 1

Emergency access road: how will this impact the environment?

The emergency access road will not impact the environment. It will be used for emergency only by Fire or Police.
The emergency access road is clarified in section 2.4 of the FEIR.

Waltham High School | Final Environmental Impact Report 5 | p. 57

From: Reva Dolobowsky
To: Czepiga, Page (EEA)
Subject: EEA NO. 16097 -Waltham High School - Location: 554 Lexington Street, Waltham, MA 02452
Date: Thursday, June 18, 2020 3:42:08 PM
Attachments: HS project MEPA ltr 6.18.20.docx

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Dear Page,
 
I am writing in response to SMMA’s Draft Environmental Report to once again express my strong
opposition to the choice of the Stigmatine site for a new Waltham High School.  EEA NO. 16097 -
Project: Waltham High School - Location: 554 Lexington Street, Waltham, MA 02452 - Proponent:
City of Waltham. The choice of the Stigmatine site would result in an environmental and financial
disaster for the City of Waltham, for these reasons:
· Enormous cost, due in large part to the huge amount of ledge that would require blasting
and removal. This would likely result in an increased tax burden on Waltham residents and
businesses. Especially in this time of extreme financial losses and uncertainty for our city,
residents, and businesses, this site is a particularly poor choice.
· Greatly increased traffic on Lexington Street and nearby side streets (Lincoln, Curve, Piety
Corner, and others). It is already extremely difficult to turn from Lincoln St. onto Lexington
St., with long lines of cars backed up on Lexington St. at the Totten Pond Rd. intersection for
many hours of the day. As my neighbor Michele Desautels, noted in an earlier comment to
MEPA, “even the City Traffic Engineer went on record on September 26, 2019 saying ‘there
will be gridlock’ “.
· Blasting and removal of ledge from the site: The resulting noise, potential damage to
neighbors’ foundations, enormous wear and tear on Waltham’s streets from vehicles
hauling away the ledge, and influx of rodents..
· Destruction of a pristine green space in our already over-developed city. This includes
destruction of wildlife habitat and mature trees. Once gone, this will be gone forever.
· Major threat to wetlands:  This includes a continuing threat to the stream, the bank, the
bordering vegetated wetlands, the wetland buffer and the watershed, resulting from the
blasting and building location.
· Dangerous, ugly, and enormous rock wall: As another concerned Waltham resident, Evelyn
Reilly,  noted in an earlier comment to MEPA: “The 50-100 foot high, ½ mile long rock wall
would create a scar across the land that would not only be ugly, but dangerously attractive
to adventurous high schoolers.”
· Emergency access road: how will this impact the environment? RD 1
 
Thank you for taking these issues into account. Waltham needs a new high school, but not at the
Stigmatine site.
 
Best wishes,
Reva Dolobowsky
94 Lincoln St.
 Section 8: Responses to Comments

8.7.24 Dunbar, Carol

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 58

From: Carol Dunbar
To: Czepiga, Page (EEA)
Subject: EEA#16097
Date: Friday, June 19, 2020 6:51:24 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
I am writing my following concerns of the proposed building site  for 554
Lexington Street, Waltham.
 
1. The tremendous blasting which can cause structural damage to
foundations in the same vicinity.
2.   The effect on traffic in the area inhibits the flow of cars into 501
Lexington Street, Condo Community Driveway.
3. Un necessary removal of trees and destroying wildlife habit.
4.   This exorbitant building cost would increase taxes for the residents of
Waltham.  There are other land sites that should
Be considered that are less disruptive to the environment.
 
 
Thank you for considering these concerns,
 
Sincerely,
 
Carol Dunbar
501 Lexington Street #6
Waltham, Ma
 
 
 Section 8: Responses to Comments

8.7.25 Durkee, Sean - Councilor

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 59

 Section 8: Responses to Comments

8.7.26 Eposito, Jeffrey

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 60

 Section 8: Responses to Comments

8.7.27 Fils – Aime, Donna

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 61

 Section 8: Responses to Comments

8.7.28 Fintzel, Kit

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 62

From: Fintzel, Kit
To: Czepiga, Page (EEA)
Subject: Waltham High School, EEA# 16097
Date: Monday, June 1, 2020 12:13:45 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Good day,
 
I am writing in support of the new high school.  It is imperative that it continue on schedule.  Not
only will it directly affect the students who can attend, it will affect the entire community as those
who want their children to get an excellent education in a modern facility (well lit, classrooms are
not 118 degrees in Sept, plumbing and duct work is not 70 years old) will find Waltham a suitable
place to live.  Companies look at local education when trying to recruit employees.  A new, modern
school will help our community attract new businesses as well as residents.  All this can build our
local service industry so students of all interests can find local intern possibilities.
 
This city has waited far too long for a new school.  I have a daughter in elementary school and one
who will soon be in kindergarten.  I chose to live in Waltham because of the commitment to
education.  Please help us continue that commitment into the high school.
 
Best regards,
 
Kit Fintzel
Kitfintz@gmail.com
 
The content of this email and of any files transmitted may contain confidential, proprietary or
legally privileged information and is intended solely for the use of the person/s or entity/ies to
whom it is addressed. If you have received this email in error you have no permission
whatsoever to use, copy, disclose or forward all or any of its contents. Please immediately
notify the sender and thereafter delete this email and any attachments.
 Section 8: Responses to Comments

8.7.29 Not Used

Waltham High School | Final Environmental Impact Report 5 | p. 63

 Section 8: Responses to Comments

8.7.30 Fowler, Bill

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 64

From: Bill Fowler
To: Czepiga, Page (EEA)
Subject: EEA#16097
Date: Wednesday, June 17, 2020 8:46:08 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Page Czepiga
EEA#16097
I am writing with my concerns regarding the Waltham High School
project. I was a City Councillor who supported this project from day one
but am very concerned about the direction it has been going since I left
office in January.
As you are aware the council voted to take the 46+ acre Stigmatine
property with the intention of building a campus style high school. That
now has been reduced to a school building and a garage. In February
the school department decided that they couldn’t fit those two buildings
on the 46+ acres. They then decided to transfer the 6 acre Jerrico Hill
parcel that the city had bought for open space so they could build a
parking structure.
There was no public hearing on this matter. In fact, all discussions on
this matter were done in Executive Session, hiding their actions from the
public. Since this was a simple transfer from one department to another
the only reason that this was done was to keep the debate from the
public. I have filed a complaint that is currently being investigated by the
AG’s office.

At the June 8th meeting of the School Building Committee there was a
presentation and a vote to approve the traffic and parking plans for the
site. When asked by a member if the site had enough parking if there
was an event at the school, the design firm’s answer was No. They said
that the plan was to park 50 cars on the grass and the rest across the
street at the old high school site and then run shuttle buses. When
asked about how many cars could queue for parent pick up the answer
was, we don’t know. There were conversations about drop off areas, not
parking, for consumers coming for services at the shops. They never
even mentioned parking for a student run restaurant.
Currently, the plan for a secondary egress is to run a road to the
property line where the city has a utility easement. This easement
through people’s yards does not allow an access road without making a
deal with the property owners.
There are no plans for walking access other than the main entrance on
Lexington St. There are no sidewalks on Lincoln St or College Farm Rd
the two west to east roads on either side of the property. The current
plan for this site involves removing the current bike lanes on Lexington
St. Nothing in this plan will help alleviate the traffic on Lexington St or
reduce the number of cars that will enter the site during the morning and
afternoon rush. Since the old school had two entrances and exits and
the new site only has one the traffic will be horrendous on Lexington St.
To this day, I have not even heard a discussion about water run off into
the surrounding properties. There have been no neighborhood meetings
about the effects of months of blasting and what will be done to protect
the neighborhood surrounding the property.
Respectfully
Bill Fowler
54 Lincoln St
Waltham MA 02451
 Section 8: Responses to Comments

8.7.31 Frost, George - Interim Superintendent

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 65

 Section 8: Responses to Comments

8.7.32 Gagne, Rachel

RG 1

Construction - What will the demolition of this ledge do to the surrounding foundations? The animals? Chesterbrook? Pools
in the area? the traffic with trucks?

Blasting and rock excavation will be conducted in a controlled manner to nor adversely impact the structural
integrity of neighboring residences, including houses and property features such as swimming pools. The
controlled blasting procedures will limit the air blast over pressures and ground vibrations, thus reducing the
impacts to surrounding areas. Human perception of vibration is orders of magnitude below vibration levels
necessary to cause damage to buildings.

Animals in the vicinity of the construction, due to early site preparation and clearing including drilling for blast
holes, will have evacuated the area prior to any blasting.

Chester Brook, located east of the Project site, is located approximately 800 feet east of the closest blasting
area, which would be beyond the area of impact.

Blasting should not impact surrounding traffic outside the project limit.

RG 2

There was talk of there being a restaurant in one of the schematics but in the time of COVID-19 and school shootings, is
that ever an option? That will add more congestion to the already overwhelming area.

The Culinary Arts program has a student run restaurant component which is open for a few hours 3-4 days per
week.

Waltham High School | Final Environmental Impact Report 5 | p. 66

From: Rachel Gagne
To: MEPA (EEA); Czepiga, Page (EEA)
Subject: EEA#16097 - Waltham High project
Date: Friday, June 19, 2020 2:43:02 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hello!

There are a few things I wanted to express since whenever mentioned to any city councilor, I
am met with "yeah yeah yeah, the greater good!" even if the greater good is only 5% of the
city. I've been living in Waltham for 10 years now and have owned property for 2. I have a
few issues with the project and will list them below.

Traffic - Lexington Street is one of the most congested areas in Waltham that already has been
through the process of "traffic relief" which has proven to not be working. Totten Pond Road
is a four lane road that splits in 3 different directions and has been in the discussions of being
revamped for the 10 years I've been here. 

Fire safety - I've sent several emails about there being a lack of a second egress on any of the
schematics for this location. I'm not sure if you've ever heard of the Station Nightclub fire in
West Warwick, RI but it's the first thing I thought of when I saw there was only one egress.
I'm from southeastern MA and that fire had a large impact on my friends and family.

Wildlife/watershed - This is 40 acres of land. The construction will obviously displace animals
and affect water flow in the future. 

Construction - What will the demolition of this ledge do to the surrounding foundations? The RG 1
animals? Chesterbrook? Pools in the area? the traffic with trucks?

The location - This land was unceremoniously taken from people without having a fully
fleshed out plan. There was talk of there being a restaurant in one of the schematics but in the RG 2
type of COVID-19 and school shootings, is that ever an option? That will add more congestion
to the already overwhelming area.

I could go on forever but I'll keep it short and hopefully sweet. I've been to several meetings
regarding this high school where little is discussed and the motivated moms of Waltham make
it their job to belittle you for any criticism of their new multimillion dollar state-of-the-art high
school. Overall, it has left a bad taste in the mouths of many Waltham residents.

Have a great weekend!

-Rachel
 Section 8: Responses to Comments

8.7.33 Guzman, Alison

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 67

 Section 8: Responses to Comments

8.7.34 Guzman, Jose R.

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 68

From: Czepiga, Page (EEA) on behalf of MEPA (EEA)
To: Czepiga, Page (EEA)
Subject: Fw: WHS / PLEASE SUPPORT
Date: Tuesday, June 2, 2020 8:29:08 AM

From: José R. Guzmán <jrman75@hotmail.com>

Sent: Monday, June 1, 2020 3:55 PM
To: MEPA (EEA) <mepa@mass.gov>
Subject: WHS / PLEASE SUPPORT

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hi,

This is the only opportunity for Waltham student’s, most public-school students do
not have the opportunity to attend private school or any high school other than their
city’s or town’s.

Thank you.
José R. Guzmán.
 Section 8: Responses to Comments

8.7.35 Haley, Tom

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 69

 Section 8: Responses to Comments

8.7.36 Hanley, Robert

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 70

 Section 8: Responses to Comments

8.7.37 Hargrove, Robert

RH 1

THE NEED FOR ANOTHER MEPA SITE WALK AND Q& A TO ASSESS THE VALIDITY OF THE EIR As such I think it would be in the
best interest of all concerned for you Page or MEPA to conduct another Site Walk and Q&A session so you can able to
make a valid assessment of the situation before accepting the EIR as given.

The MEPA office has indicated that additional site walks are not required.

Waltham High School | Final Environmental Impact Report 5 | p. 71

From: Robert Hargrove
To: Czepiga, Page (EEA)
Subject: Fwd: Updated Public Comment of Waltham EIR
Date: Wednesday, June 17, 2020 2:15:27 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.

REQUEST FOR PUBLIC COMMENT ON EIR

 

Hello Page, We talked during the site walk and my property is the large one

that directly abuts the Stigmatines or 554 Lexington Street

I want to acknowledge that yours and  MEPAs intervention in the Waltham

High School project has made a significant difference.

 

I want to  acknowledge the Mayor Jeanette McCarthy  for sincerely

addressing what she referred to as "the legitimate  concerns" of the immediate

abutters on Lexington Street.

 

The site location for the New Waltham High School was moved to another area

which I think makes a lot more sense for the city, and will have less

environmental impact. However there is always a however. . .

 
THE CITY OF WALTHAM  ASKED  SSMA ARCHITECTS TO PREPARE
THE EIR  WHICH STANDS TO MAKE $33 MILLION IF THE ERA  IS
ACCEPTED

SSMA  has submitted a 1000-page EIR to MEPA. Concerned citizens are

worried    this has been done in a way to “make a good impression,”  so
as to cover up, distort or obscure significant issues
 ·THE CITY HAS DECLINED  NUMEROUS   REQUESTS FOR

PUBLIC MEETING FROM BOTH CITY COUNSELORS AND

CONCERNEF  REGARDING THE ISSUES

The City of Waltham including its newly appointed “project liaison” has

consistently  declined numerous requests by concerned citizens   to hold

any public meetings to discuss these issues or give the neighbors any

way to influence the process.

· THE NEED FOR ANOTHER MEPA SITE WALK AND Q& A TO RH 1

ASSESS THE VALIDITY OF THE EIR As such 

I think it would be in the best interest of all concerned for you Page or

MEPA to conduct   another Site Walk  and Q&A session so you can able

to make a valid assessment of the situation before accepting the EIR as

given.
 

The concerned citizens of Waltham, and Massachusetts need MEPA to act as 
nuetral third party in determing the validity of the following issues

1)  The WHS proposed site plan involves creating a massive 4-5 story

building in a residential neighborhood

2) The  WHS proposed building  by SSMA architects is too small for the

proposed site  It  involves placing a 400,000 square foot HS building on the

site, along with a 300 Square foot parking garage, with a football field on top of

it, that will require students to take an elevator

4) The project will require blasting 680,000 tons of rock over a four-year period

creating psychic stress on the neighbors and threatening the foundations of their

homes

4) Leveling the ground will  require the building a 130 high rock wall (three

telephone poles high) on Jericho Hill leaving a permanent environmental scar

and safety hazard for students.

5. The water table will be disturbed by this blasting disturbing the wetlands

area  causing flooding issues for the neighbors on Lexington street

 

I appreciate your interest in this project and the positive affect that it has had so

far, in getting the town to adjust the site plan. I would have preferred to discuss

these issues with Waltham City Officials in a public meetings, but did not have

the opportunity to do so,

I hope that this can change in the future

 

Robert Hargrove, abutter

640 Lexington Street

 Section 8: Responses to Comments

8.7.38 Hines, Karina (2 of 2)

KH 1

Alternate Locations - There are at least two alternate locations that are relatively flat, already developed spaces that are
perfectly suitable for the new high school, 617 Lexington St. and 200 Trapelo Rd.

There has been no full environmental analysis of this site?

Alternatives locations presented in the ENF and NPC/DEIR were evaluated and dismissed. This site has received
a full environmental analysis.

KH 2

Sanderson Heights, which is 26.5± acres of dedicated and protected green open space, abuts Jericho Hill, so how can a
significantly destructive development with a 105 ft. high blast wall be allowed right next to the protected area?

Why is there no program of monitoring these impacts on such a fantastic open space resource?

Construction on land adjacent to Conservation land is permitted. The construction activities are not expected to
impact adjacent land due to the construction mitigation measures outlined in Section 6 of the FEIR.

KH 3

The impact of developing the 4- story school building, the 450-car garage beneath the multipurpose synthetic turf field and
the 200-car surface parking lot near wetlands and woodlands requires a full environmental assessment of every aspect of
the project …. please? Please implement the maximum environmental protections possible to protect this site and the
residential neighborhood.

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to avoid any relocation of the intermittent stream and wetland resources.

KH 4

Why is it necessary to build two buildings totaling over 600,000 square feet at the height of over 60 feet and 4 stories high,
40 feet from the adjacent single-family properties on Glen Circle, Lincoln St. Extension, and Lincoln Terrace and 40 feet from
the adjacent open space at Sanderson Heights in violation of the Zoning setbacks?

The education program for the students of Waltham dictates the size of the proposed building. The building
setbacks will meet the zoning or, if not, apply for a zoning variance.

KH 5

Why could not the building shape be altered and reconfigured to make the building fit without such an extraordinary
impact on the site?

The shape of the building is derived from the need of adjacencies of the educational program. The shape of the
building is not within MEPA jurisdiction.

Waltham High School | Final Environmental Impact Report 5 | p. 72

 Section 8: Responses to Comments

KH 6

Also, where will the expansion area for the school be located? If it is on the roof as discussed previously, will not that
significantly disrupt classes and add a fifth floor to the building in the area where the rooftop garden is planned?

What about the ability of the structure to support another story?

The expansion is on the third-floor roof at the roof deck. The structure is being designed to accommodate this
future build out, but not another story. Any disruption to the students could be offset by summer work.

KH 7

How will it affect ALL the surrounding neighborhoods and how will local streets and even the state highway the system be
impacted with such a volume of 18-wheel truck traffic?

There will be increased traffic during construction, there are significant construction projects in Waltham and
surrounding Towns’ that utilize Route 95 every day. Impacts to neighborhoods will be minimized by the
designated trucking route along Lexington Street, Totten Pond Road and Route 95.

KH 8

How will massive quarry style blasting and destruction followed by years of construction affect that? What is the true worth
of 6+ acres green space versus a car park and school playing field?

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to avoid any relocation of the intermittent stream and wetland resources.

KH 9

There is no adequate or appropriate plan shown for the drainage or dewatering from the multipurpose field and beneath
the garage that will stop the water from draining through the fissures in the ledge beneath the garage, caused by blasting.

The drainage design plans are in progress. The project will comply with applicable MassDEP Stormwater
Management Standards for quality and treatment and will not exceed pre-development discharge rates for the
design storms. During the construction period, a Storm Water Pollution Prevention Plan (SWPPP) will be
implemented and maintained throughout construction to monitor and modify temporary control measures as
required. The stormwater is clarified in section 3.2 of the FEIR.

KH 11

Exactly how will the water drain off this 4+ acre environmental monstrosity?

The project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment
and includes not exceeding pre-development discharge rates for the design storms

KH 12

Where will they construct adequate and appropriate noise barriers to protect the neighbors from noise pollution

Waltham High School | Final Environmental Impact Report 5 | p. 73

 Section 8: Responses to Comments

Consigli plans to use sound blankets at the perimeter fence strategically placed to mitigate noise to the adjacent
neighbors. This was presented at the SBC of 8/10/2020. Additionally, sound barriers for the rock crushing are
being developed.

KH 13

Will students try and climb, repel or spray paint this rock wall? We live in a time when childhood mental health and bullying
is a genuine public-school issue; this is a potentially tragic design disaster?

The design team has considered this and fencing will be provided at the top and bottom of the wall.

KH 14

What about the 140 truck trips hauling ledge during site preparation and the impact on traffic? These truck trips will not
only impact the local roads but state highways as well plus the safety and security of the students who will be forced to
walk to school in areas where there are no sidewalks, like Lincoln St., Curve St. Winter St., Totten Pond Rd., and College
Farm Road?

Traffic will be increased during the construction period. It should be noted the existing high school is 785ft north
of the proposed site. The walkers have accessed the same roads referenced for years to the existing high
school.

KH 15

Why is there no program of mandated monitoring during the construction and following especially at the property lines of
abutters?

Testing, monitoring and reporting will be provided as applicable to the construction activities at the time.

Waltham High School | Final Environmental Impact Report 5 | p. 74

From: Karina Hines
To: Czepiga, Page (EEA)
Subject: Fwd: EEA #16097 Waltham High Project
Date: Friday, June 19, 2020 8:38:20 AM
Attachments: Photos 1 of 2 from Karina HInes Waltham High School Project.zip
Communication From Mayor - 5-4-2017 - Re Taking by ED Stigmatines.pdf
Excerpt - OS & Rec Plan 2015 - 2022.pdf

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.

June 19, 2020

 
Kathleen A. Theoharides
The Secretary of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attention: MEPA Office
                                                                                               
Re: EEA #16097 Waltham High Project
Location: 554 Lexington Street, Waltham MA
 
Attention: Page Czepiga,
 
VIA Email: page.czepiga@mass.gov
 
Dear Secretary Theoharides:
 
As a resident of 45 Glen Circle Waltham, I am an abutter to Jericho Hill at 131R Lincoln St.

& The Stigmatine Property at 554 Lexington St, Waltham. The City is planning to build a

414,854 sq. Ft. High School with an elaborate 450 car parking garage with a turf playing

field on top with a bridge to the school and 100+ ft high rock wall surrounding the field.
 

I am writing to ask you to please fully evaluate and investigate the Notice of Project Change

and Draft Environmental Impact Report of the recently revised Waltham High School

proposal that has been submitted to MEPA for 131R Lincoln St., Jericho Hill and 554

Lexington St., the Stigmatines Property. SMMA, the Project Architect, of the school keeps

changing their plans, and the preferred alternative is becoming more impactful each time.  
 

Instead of writing you a a book about my concerns, I am writing a bullet point list; and there
are many. 
 

I have attached pictures so you can get an idea of the topography and the scale of the

project and level of destruction and devastation it is going to cause.   The development will
impact the environment, ecology, local flora and fauna and residents for all the surrounding

neighbourhood, not to mention the generations to come, who will have a car park and

monstrosity of a school building where a beautiful and rare piece of green space used to

be.
 

My bullet points and my concerns are as follows, and I ask for your help.
 
Alternate Locations
There are at least two alternate locations that are relatively flat, already developed spaces KH 1
that are perfectly suitable for the new high school, 617 Lexington St. and 200 Trapelo Rd.

Jericho Hill & the Stigmatines, the preferred site is the most expensive and environmentally

problematic site due to the topography, the soil conditions, the wetlands, the watershed, the

building sizes, the parking, the transportation and traffic conditions and thus is locally most

impactful.
 

The 750,000 cu. Yds. of blasting and the proposed emergency exit will require clear-cutting

hundreds of large pristine trees.  The current existing high school site at 617 Lexington St.

that could be redeveloped for the new high school, already has dual entries and exits and

can efficiently be utilized and will not create any further traffic issues. There has been no KH 1
full environmental analysis of this site?

                                                                                                                    

Does developing Jericho Hill and the Stigmatine Property comes at a higher cost than

developing The Fernald?   I quote this from patch.com "The city-owned Fernald property

was a strong contender but fell out as an option after officials realized environmental issues

were bigger than originally thought."… and yet no full Phase 2 or 3 environmental

evaluation by an Licensed Site Professional has ever been conducted?

 
Green-space, Vernal Pools, Wetlands and Water

Most recently, 6+ acres of Jericho Hill's dedicated green open space that the City took back

in 2001 has been added to this school project to try and make it viable, at an extraordinary

cost to the environment. It is a vital link between other neighbouring green open space like

Sanderson Heights, Prospect Hill, and the Western Greenway.  Sanderson Heights, which

is 26.5± acres of dedicated and protected green open space, abuts Jericho Hill,  so how

can a significantly destructive development with a 105 ft. high blast wall be allowed right KH 2
next to the protected area? The vibration from blasting will likely have a dramatic impact on

the vernal pools, the streams, and the wildlife at Sanderson Heights. Why is there no KH 2
program of monitoring these impacts on such a fantastic open space resource?
 

There are vernal pools documented with fairy shrimp and streams on the adjacent

Sanderson Heights parcel and wetlands on the Stigmatines Site, which your agency has

already said must be protected. Yet the City of Waltham will conduct so much blasting that

the hydrology of the neighbourhood, the watershed, the water table, the wetland buffer, the

streams, and the vernal pools will be damaged permanently by the incessant blasting of

750,000 cu. Yds. of the ledge.

 

Jericho Hill is a dangerous site to develop, and the proposed blasting will be 24 to 46 feet

below the water table which connects this whole area.  The impact of developing the 4-

story school building, the 450-car garage beneath the multipurpose synthetic turf field and

the 200-car surface parking lot near wetlands and woodlands requires a full environmental KH 3
assessment of every aspect of the project …. please?  Please implement the maximum

environmental protections possible to protect this site and the residential neighbourhood.
 

The water from Jericho Hill and 554 Lexington Street runs out in springs right throughout

our yard and organic vegetable garden and the neighbour's yard and out onto the street

and not only on Glen Circle but Lincoln Terrace, and Lexington St. as well. (see attached

photo's)
 
If they blow up Jericho Hill to build a car park where will all this water go and what damage

to buildings, basements, streets, sewage, and drainage occur in all the surrounding historic

neighbourhood? 
 

The car park and the school will cause all the runoff water to be polluted. I grow organic

food, herbs, and a pollinator garden. My neighbours have children who play in their yard.

This project will jeopardize the health and well being of all abutters.
 

Size of The Project in A Single-Family Residential Neighborhood

Why is it necessary to build two buildings totalling over 600,000 square feet at the height of KH 4
over 60 feet and 4 stories high, 40 feet from the adjacent single-family properties on Glen

Circle, Lincoln St. Extension, and Lincoln Terrace and 40 feet from the adjacent open

space at Sanderson Heights in violation of the Zoning setbacks? The height of the ground

floor of both structures is well above the elevation of every single-family roof south of the

project. There is no viable justification for squeezing such a large building into such a

constrained space in the southwest corner of the 52+ acre parcel using a butterfly building

configuration that makes no sense other than to gratify the ego of the architect. It negatively

impacts the stream, the wetland resources, and the wetland buffer as well as the

neighbours on the southerly side of the site. Why could not the building shape be altered KH 5
and reconfigured to make the building fit without such an extraordinary impact on the site?
The building is too wide, and the travel time from the different sections of the structure

exceeds the break time between classes. Also, where will the expansion area for the school KH 6
be located? If it is on the roof as discussed previously, will not that significantly disrupt

classes and add a fifth floor to the building in the area where the rooftop garden is planned?

What about the ability of the structure to support another story?

 

Blasting

Vibration, noise, dust and debris pollution during blasting will turn a quiet neighbourhood in

a residential zone into an industrial quarry like the Polaroid Development at 1265 Main St.,

Waltham, where the Market Basket is located.

https://www.flickr.com/photos/25664139@N06/sets/72157626260565192. 

A local reporter informed me that the Waltham Mayor attended a meeting in 2013 where

people from up to 1/2mile away from the blasting site brought broken wall pictures, parts of

foundations and photos of the damage to their properties. She is aware of what can happen

and yet has repeatedly ignored our pleas for relief! How will blasting and moving thousands

of tons of rock affect people less than 500 feet away at the rate of 70 truckloads daily for a

year and one half?  What a nightmare this will create for our neighbourhood.
 

How will it affect ALL the surrounding neighbourhoods and how will local streets and even KH 7
the state highway the system be impacted with such a volume of 18-wheel truck traffic?  
 

How will it affect the local wildlife and plants in the area and abutting dedicated green open

space?  Lady slippers are growing on Jericho Hill!  There are owls, hawks, birds, coyotes,
fox, deer, groundhogs, racoon, squirrels, frogs, Fisher cats, chipmunks, pollinators, and so

many other small mammals.  We had a copper head snake in our yard a few years ago,

though I do not have a picture to prove it. Garter snakes, wild turkeys, so many native birds,

a family of hummingbirds and finches who return each season. Honeybees, wasps,

dragonflies, pollinators of all types, bugs, and beetles of all kinds - so much wildlife is living

in a suburban neighbourhood and extraordinary green open space area. How will massive KH 8
quarry style blasting and destruction followed by years of construction affect that?  What is

the true worth of 6+ acres green space versus a car park and school playing field?
 

Runoff and Water Pollution

I am particularly concerned that the quarry blasting of 750,000 cu. Yds. of the ledge!  Much

of it is immediately adjacent to the stream, bank, bordering vegetated wetland and

watershed within the wetland buffer zone.  This blasting will cause irreparable harm to the

wetland resources and watershed area at 554 Lexington Street. Much of the blasting will

occur 24 - 46 feet below the water table on the property as indicated by the Geotechnical

Study and borings of Haley & Aldrich submitted as part of the ENF and the DEIR.
 
The primary reason for my concern is that we live directly downhill and abutting 554

Lexington Street, at 45 Glen Circle, 40 ft. from the southerly end of the proposed 450 car

parking garage and 4+ acre multipurpose artificial turf field. There is no adequate or KH 9
appropriate plan shown for the drainage or dewatering from the multipurpose field and

beneath the garage that will stop the water from draining through the fissures in the ledge

beneath the garage, caused by blasting. This water will cascade downhill onto our property

from these fissures, causing irreparable damage and flooding during major precipitation

events.  Further, the effluent water quality in these fissures will be inferior to regulatory

requirements with unacceptable levels of sedimentation and pH levels, and there is no

provision for adequate monitoring and testing or water diversion.  Won't the chemicals in KH 10
the synthetic turf impact the water quality? Gone will be the natural trees, the ground cover,

and the overlying soils which currently attenuate the water flow and mitigate the water

quality. Exactly how will the water drain off this 4+ acre environmental monstrosity? We KH 11
shudder at the environmental calamity planned for 554 Lexington St. 
 

Noise & Light Pollution

Noise pollution daily in a residential neighbourhood will be well above the city noise

ordinance and state laws during construction and after.  What about on "game nights" when

we are all relaxing?  The current ambient background noise on Jericho Hill is less than 35

decibels, which is the equivalent of a whisper. Tree cutting, blasting, excavating, trucking,

sports games, bus, van, and vehicle traffic will violate state and municipal noise ordinance

requirements. It will have a negative impact on the sensitive receptors in the

neighbourhood. Where will they construct adequate and appropriate noise barriers to KH 12
protect the neighbours from noise pollution - it isn't possible at such a level of

environmental devastation!   Light pollution from the construction and final structures will

also be significant, impacting neighbours and creatures of the night. A review of the DEIR

seems to be missing a comprehensive study of all sources of pollution emanating from the

proposed Waltham High School. Aren't the abutters, neighbours and citizens entitled to

such a study?
 
Unsuitable Green Space Site
 
The cost - over $65 million will need to be spent just to clear the site, which results in pure

destruction long before any construction can start.  The other suitable sites (617 Lexington

St. and 200 Trapelo Rd.) are readily available for redevelopment for a new high school at a

fraction of the cost.

 

Jericho Hill and Stigmatines property are the most unsuitable site for a High School.

 I have spoken to people in both the demolition and the construction industry in many

different fields, and they concur; they all agree that this high school plan is fraught with

problems.  Waltham City Mayor and councillors and school committee members have no

experience with massive building development such as this which is reported to be the

most expensive high school in the country. Yet, they are making some terrible decisions

because they want to build a school at any cost. While I understand that and agree this

project is needed, this site is not the way to create a platform for future education,

especially in time of environmental pressure. The pandemic reflects the current health of

our environment. 
 

We are all hoping for your help to protect and preserve the environment!   I have seen

many people walking on Jericho Hill and Sanderson Heights almost every single day

since the Covid-19 order put in place in March; I am not so sure anyone was walking in

any high school concrete car parks though. Secretary, the extensive woodlands, the

dramatic grade changes, the vistas from Jericho Hill, the ledge outcroppings, the stream,

the wetlands, the wetland resources, the watershed, the wildlife, the protected plants like

lady slippers are all-natural resources worthy of protection, monitoring and preservation in

the Commonwealth of Massachusetts, aren't they?

 

The True Cost?

The exact financial and environmental cost is unknown of blasting all that granite ledge and

moving a mountain of rock. The ultimate price and cost to taxpayers of this development

are unknown; they simply cannot know what will happen during construction and after with
water movement. Where will all that extra money come from to deal with these added

problems exactly?  
 

Cost is an environmental problem because if such crazy developments can go ahead, the

price that will be needed to pay for it will come from borrowing and creating more of a

deficit. So, to significantly impact the future of the City, its taxpayers, and generations to

come is a travesty. Our ability to grow in a healthy, sustainable local environment, both

socially and economically, with protected quality natural resources has become

threatened!  The damage to Jericho Hill both financially and environmentally if this
development is permitted, will be incalculable?
 
Education cost-benefit?

With the Covid-19 pandemic, there is a considerable shift in the way we approach

education; this high school design is already out-of-date before being built. Waltham's

economy is struggling already; this is not a city of high-income residents; we are mostly

blue-collar residents. Reports say that over ⅓ one-third of Waltham's school students

currently do not have access to the internet and online education. The level of school

education that Waltham is providing is at a lower standard than the rest of the state.  
Building the most expensive high school in the country is not going to fix that when the

systemic deficiencies are permitted to exist!   Waltham High School ranks 274 out of 324

high schools in the state according to US News & World Report, is overseen by an interim

superintendent and has not had a permanent principal in Two years. Perhaps the $100

million being spent for the car park, the blasting and the site demolition could be better

spent on providing affordable online internet access, devices, online education and more

teachers and keeping the green space available for students to walk in and study. Will the

children of 2030 & 2040 in Waltham all be driving to school?  Will a car parking garage be

used every single day and by how many cars, what is that cost analysis?   
 

Health & Safety Management Issue

The latest car park/school design is not safe for our youth or practical for teachers and

administrators to manage!  With a concrete car park, a bridge and 100+ ft rock walls, there
is a huge safety concern and many management issues for teachers and children's

safety. Will students try and climb, repel or spray paint this rock wall?  We live in a time KH 13
when childhood mental health and bullying is a genuine public-school issue; this is a

potentially tragic design disaster? Even the layout of the interior of the school with its open

floor plan and atriums is a safety hazard and a significant COVID-19 problem.  
 
Three schools within 1 mile: Traffic and transport

The City does not have any safe sidewalks or bike paths in this area around the proposed

site, nor does it have an efficient transport system. Construction of a new High School on

Lexington St will be very, very challenging to residents who live in the surrounding area and

use Lexington St, Lincoln St, Totten Pond Road, Beaver St, College Farm Road etc. to

commute to and from work every day. The traffic is typically quite bad each morning now.

The Waltham Traffic Engineer indicates that there will be daily gridlock on Lexington Street

from 7-9 am when the school project opens. What about the 140 truck trips hauling ledge

during site preparation and the impact on traffic? These truck trips will not only impact the KH 14
local roads but state highways as well plus the safety and security of the students who will

be forced to walk to school in areas where there are no sidewalks, like Lincoln St., Curve

St. Winter St., Totten Pond Rd., and College Farm Road?
 

If Waltham High School is built at 554 Lexington St, there will be three schools within a

mile.  Bentley University, Chapel Hill/Chauncy Hall and Waltham High School within a one-
mile radius all using Lexington and Beaver St. This is not a sustainable proposal for this

area.
 

Monitoring the Impact of the Project on the Neighborhood

Why is there no program of mandated monitoring during the construction and following KH 15

especially at the property lines of abutters? Why is the City not putting in a strict monitoring

program that will track and report on noise, dust, vibration, blasting, light pollution, traffic,

stormwater flow, erosion, construction parking, tree cutting, rock crushing, rodent control

and wetland monitoring? If this project is allowed to proceed, can't the Secretary implement
a program of mandated monitoring, testing, and reporting especially to all of the neighbours

whose lives will be impacted as sensitive receptors by these various major impacts?

Construction cameras from the four points of the compass, monitoring devices on the

property lines and monitoring services are all appropriate considering this project's impacts

on the neighbourhood. These four cameras could also serve to provide students, abutters,

and citizens a personal view of the construction activity.

 

Impact Evaluation

Please fully evaluate all the environmental impacts of this project on every aspect of life in

Waltham and protect our City from one of the most environmentally egregious disasters

ever proposed to this community!

 

Please find attached - due to file size I will send this information in 2 separate emails.

The Mayor's original plans for making this area green open space

Pictures I have taken and labelled so you can see the Vernal Pools, water movement in the

area and the green space.  

 

Thank you for your time and consideration. I would appreciate an acknowledgement

that you have received my letter.

 
Sincerely and with hope,
 
Karina Hines

Eat to Thrive 
Karina Hines
www.botanicalkitchen.com

instagram pinterest facebook linkedin twitter

From: Karina Hines
To: Czepiga, Page (EEA)
Subject: EEA #16097 Waltham High Project - 2nd email with attachments
Date: Friday, June 19, 2020 9:00:06 AM
Attachments: Photos 2 of 2 from Karina HInes Waltham High School Project.zip

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Attention: Page Czepiga,
 
 
Dear Secretary Theoharides,

Please find attached photo attachment 2 of 2 to support my email

regarding the Waltham High Project.
Pictures I have taken and labelled so you can see the Vernal Pools, water
movement in the area and the green space.  

Thank you
Karina Hines

Eat to Thrive 
Karina Hines
www.botanicalkitchen.com

instagram pinterest facebook linkedin twitter

 Section 8: Responses to Comments

8.7.39 Homan, Elizabeth

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 75

 Section 8: Responses to Comments

8.7.40 Hughes, Paula

PH 1

During this process I feel that officials from DEP and/or MEPA should be on site to survey the area and to lookout for the
spotted salamanders that once lived here before the area was polluted as they need to be protected.

No spotted salamanders exist on 554 Lexington Street or Jericho Hill Parcel II.

PH 2

Having these shops near the stream could potentially allow overspray of paint to enter the stream or accidental spillage of
motor oil, antifreeze, brake fluid, gasoline, diesel fuel or paint solvents to leach into the stream and eventually enter the
Chesterbrook stream killing wildlife and plants from these chemicals. Please make this change as part of your ruling to help
protect our waterways, wildlife, and plants.

The loading area or Auto Shops pose no threat to the stream. The project is being designed to capture fluids,
drainage and run off within this area. The grades at this area slope towards the building and away from the
stream. The outdoor learning commons is better suited on the southern side of the building for better daylight
and sunlight.

PH 3

Exactly how will they monitor and mitigate the noise, vibration, dust, and water flow in the fissures resulting from the
blasting and rock crushing?

The actual noise from blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to mitigate
debris, dust and noise. Consigli also plans to use water misters, water trucks, and automatic wheel wash
stations to minimize dust. Finally, Consigli plans to use sound blankets at the perimeter fence strategically
placed to mitigate noise to the adjacent neighbors.

Based on visual observations of the rock core samples and the groundwater elevation data collected to date, it
is anticipated that the stream channel flow will not be impacted, however evaluations will continue as additional
aquifer data becomes available.

PH 4

Previously the Arrigo Farm area of this site (northerly end of 554 Lexington St.) was determined not to be Bordering
Vegetated Wetland area. I feel that this decision should be revisited since David Burke the peer reviewer hired by SMMA &
The City of Waltham Conservation Commission stated, if we could show the area maintaining water for more than 7 day’s
he would reconsider his decision.

David Burke was hired by the Waltham Conservation Commission. This property is not part of the project and
not within MEPA jurisdiction.

Waltham High School | Final Environmental Impact Report 5 | p. 76

 Section 8: Responses to Comments

PH 5

I believe there should be an archeologist study done to protect the history that was left behind before any construction is
allowed to begin on the property.

The site is not within any archaeological register and has been cleared by the Massachusetts Historic
Commission.

PH 6

Won’t the scar in the hillside have a negative impact on the open space? What will they do to monitor the impact on this
valuable natural resource especially if they are blasting below the water table?

The Project will not have an impact on open space. Refer to section 3.1 for the City’s plan on incorporating
additional open space. Based on visual observations of the rock core samples and the groundwater elevation
data collected to date, it is anticipated that the stream channel flow will not be impacted, however evaluations
will continue as additional aquifer data becomes available.

PH 7

I would like to know why the north east side of the project is not having fencing installed to keep students out of our
properties as well.

This project is proposing fencing behind the abutters on Lexington Street.

PH 8

If this project is allowed to move forward, I would like to ask that as part of the certificate The City of Waltham has to
provide the direct abutting neighbors with a unbiased neighborhood liaison appointed by your agency to help us with issues
that arise and that there be a daily monitoring of the dust, dirt, noise, vibration, water, traffic, parking, deliveries and any
other environmentally problematic item that could arise by an independent third party again appointed by your agency.

This is not within MEPA Jurisdiction.

Waltham High School | Final Environmental Impact Report 5 | p. 77

 Paula Hughes
588 Lexington Street
Waltham MA 02452
hughespaula@comcast.net

June 17, 2020

Via Email: Page Czepiga- page.czepiga@mass.gov

The Secretary of Energy and Environmental Affairs
100 Cambridge Street Suite 900
Boston MA 02114
Attention MEPA Office

Re EEA #16097 Waltham High Project

Location 554 Lexington Street Waltham MA

Dear Page,

I wanted to update you on some of my concerns and observations on the pending MEPA DEIR
order.

As a direct abutter this project will not only destroy the environment around me as I have known
it for the last 55+ years but it will permanently destroy the homes of hundreds of wildlife species
and this will be detrimental to our environment and community. It will displace all the creatures
such as but not limited to red squirrels, flying squirrels, gray squirrels, red fox, silver fox, coyotes,
fisher cats, deer, a large variety of owls, bats, red tailed hawks, a huge variety of birds, bees,
walking stick bugs, praying mantis, wood frogs, woodchucks, skunks and the list can go on…

The Waltham Conservation Commission ordered SMMA/City of Waltham to clean up and

delineate the undefined wetland area on the Stream at 554 Lexington St. To date, nothing has
been done or attempted to be done to comply with the Enforcement Order. Asphalt shingles,
scraps of wood, stumps, other debris, sand and rocks litter this area. This area needs to be
brought back to its original state to define the Bordering Vegetated Wetland, the Bank and the
wetland buffer area before demolition and construction are permitted to begin. During this PH 1
process I feel that officials from DEP and/or MEPA should be on site to survey the area and to
lookout for the spotted salamanders that once lived here before the area was polluted as they
need to be protected.

With regard to the wetland area it was suggested to SMMA that they flipflop the first-floor
classroom configuration back to its original plan where the autobody and automotive shops and
the loading dock were on the south side of the building far away from the wetland area to help
protect the stream from potentially hazardous contamination and this has not happened.
Having these shops near the stream could potentially allow overspray of paint to enter the
stream or accidental spillage of motor oil, antifreeze, brake fluid, gasoline, diesel fuel or paint
solvents to leach into the stream and eventually enter the Chesterbrook stream killing wildlife
and plants from these chemicals. Please make this change as part of your ruling to help protect PH 2
our waterways, wildlife and plants.

According to SMMA’s current preferred alternative plans they will be blasting a rock wall 20’±
to 80’ ± below the elevation of the stream within feet of the stream in the wetland buffer
causing water to flow through fissures in the rock into the access road area and possibly into
our properties as I have experienced in the past and once the water has entered these fissures
it cannot be controlled. I am particularly concerned that blasting 747,000 cu. yds. of ledge will
result in water flowing through the fissures in the ledge, that will flow below ground onto our
property, even though they are planning some kind of bioswale on the easterly edge of the turf
field. Exactly how will they monitor and mitigate the noise, vibration, dust, and water flow in PH 3
the fissures resulting from the blasting and rock crushing?

Previously the Arrigo Farm area of this site (northerly end of 554 Lexington St.) was determined
not to be Bordering Vegetated Wetland area. I feel that this decision should be revisited since PH 4
David Burke the peer reviewer hired by SMMA & The City of Waltham Conservation
Commission stated, if we could show the area maintaining water for more that 7 day’s he
would reconsider his decision. (please see attached pictures) Also skunk cabbage, a wetland
indicator plant, has been seen growing along the stone wall in the area.

The City of Waltham has now transferred six acres of Jericho Hill to the school department in
order to build the new school on the 554 site, since this area was once inhibited by Native
Americans, I believe there should be an archeologist study done to protect the history that was PH 5
left behind before any construction is allowed to begin on the property. The name “Waltham”
comes from the Native Americans which means “Little Home in the Woods” it is said that The
Native Americans would camp around Jericho Pond which is at the top of Jericho Hill and in
later years that pond became the main water source to the homes in the Lakeview section of
Waltham before water and sewer lines were installed. The springs that filled that pond still
remain throughout the entire site today.

The blasting of a 100’ high wall into this property will not only displace the wildlife, it will emit
radon gasses into our air, it will create a scar across the land making it not only unsightly and
changing the entire landscape of our neighborhood for eternity and disrupting the peace and
harmony of all abutters, but it will be dangerously attractive to adventurous teenagers. The
100’ rock wall is right next to the Sanderson Heights open space with its vernal pools and
streams. Won’t the scar in the hillside have a negative impact on the open space? What will PH 6
they do to monitor the impact on this valuable natural resource especially if they are blasting
below the water table?
SMMA’s plans show fencing around the south west side of the property once the school is built
to keep students from using abutters properties for a short cut. I would like to know why the PH 7
north east side of the project is not having fencing installed to keep students out of our
properties as well. I share a long curving driveway with a steep hill with another neighbor and if
there were to be students walking through our driveway on a snowy day, we might not be able
to stop or if we try to stop, we might slide right into them. This would be awful for everyone
involved. We should have fencing to keep students out of our properties as well.

With the destruction of this pristine green space in our already over-developed city not only will
there be elimination of mature trees and vegetation from this property which will allow more
ground and surface water to flow into abutting properties but it will also remove the natural air
cleaning system that the mature trees now provide. This includes destruction of wildlife habitat
and every living plant, mature tree, animal, bird and even every pollinator will be removed. Once
gone, they cannot be replaced.

With the additional traffic this site will attract, and the idling vehicles while dropping off students
or waiting for students to come out from school or after school activities, our air quality will
deteriorate significantly. Posting signs that say NO IDLING AREA will not help, there some now at
the Kennedy Middle School across the street and I notice cars engines running there for more
than 10 minutes or longer and there is no enforcement of these signs.

SMMA has moved the underground parking garage structure and playing field to the rear of the
school building to protect Bordering Vegetated Wetland area and will keep the existing natural
turf field as is with the occasional use of that field for overflow parking. I believe using this natural
turf field as a parking lot will again potentially cause gasoline, diesel fuel, antifreeze, brake fluid
or motor oil to leach into the wetland area and again potentially enter the Chesterbrook stream
killing wildlife and plants.

If this project is allowed to move forward, I would like to ask that as part of the certificate The PH 8
City of Waltham has to provide the direct abutting neighbors with a unbiased neighborhood
liaison appointed by your agency to help us with issues that arise and that there be a daily
monitoring of the dust, dirt, noise, vibration, water, traffic, parking, deliveries and any other
environmentally problematic item that could arise by an independent third party again appointed
by your agency. Unfortunately concerned neighbors have never been given the opportunity to
ask a question that actually got an answer and we just keep being discarded by the people who
run the process.

Sincerely,
Paula Hughes
Paula Hughes

Attachments:
 Section 8: Responses to Comments

8.7.41 Hutton, Alicia

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 78

 Section 8: Responses to Comments

8.7.42 Inman Donroe, Tammy

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 79

From: Tammy Donroe
To: Czepiga, Page (EEA)
Subject: Waltham High School, EEA# 16097
Date: Thursday, June 18, 2020 2:59:21 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Dear MEPA:

I'm writing in support of the new public high school in Waltham, MA. As a 20-year resident of
Waltham and parent of two high schoolers, we've been pushing for a new high school for
many, many years. The crumbling infrastructure and lack of science accreditation has been a
disservice to the city's students and teaching staff for too long. While our own children won't
benefit from the new educational facility, the next generation of Waltham families will benefit
immeasurably from a state-of-the-art learning facility for years to come.

Now that all of the environmental concerns have been addressed, and with the support of the
School Committee, School Building Committee, and City Council, I hope we can finally
(FINALLY!) move ahead with construction without delay.

Thank you,
Tammy Donroe Inman
 Section 8: Responses to Comments

8.7.43 Joe, Jeannie (2 of 2)

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 80

 Section 8: Responses to Comments

8.7.44 Johnson, Heather

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 81

From: Heather J
To: Czepiga, Page (EEA)
Subject: Waltham High School EEA#16097
Date: Thursday, June 4, 2020 12:49:33 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hi

I am writing as a Waltham parent of a fourth grader.  Over the past almost 2 years, I
have supported the efforts of a new high school in Waltham for the following reasons:

·      The current building is aging, in need of many significant upgrades, and is
outdated for today’s learning
·      This new building project was developed and designed based on current
and projected best practice educational principals for high school students.
o   Therefore, Waltham public school students will have comparable
education to those communities in the area
o   The range of educational programs being recommended in the new
building will be able educate many diverse learning needs for preparation
from vocational opportunities and higher education opportunities. 
o   Educators are excited to work in a school community that supports
current education trends, including physical environment. 
·      The school committee, school building committee, and the Mayor have
been incredibly supportive of this project over the years.

Our future high school students, including my daughter, need the opportunity to have
optimal learning environment for ALL students. 

Thank you for your consideration of my input.

Heather Johnson

--
Don't cry because it's over. Smile because it happened.
-Theodor Geisel (aka Dr. Seuss)
 Section 8: Responses to Comments

8.7.45 Jones, JP

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 82

From: JP Jones
To: Czepiga, Page (EEA)
Subject: Re: EEA#16097
Date: Friday, June 19, 2020 3:59:52 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Good Afternoon Page:
 
I am writing to you this afternoon to ask the Massachusetts Environmental Protection Agency
to reconsider the proposed relocation of the new Waltham High School to 554 Lexington
Street.
 
I am concerned that the proposal put forth that includes the removal of trees and grass along
with the blasting and the removal of 900,000 square feet of earth will result in the destruction
of wildlife and their habitat. Specifically, remodeling of the site will destroy thousands of trees
and an existing stream and wetland habitat on site that is home to a variety of species.
 
In addition, the relocation of Waltham High School to Lexington Street will result in serious
traffic jams not only during the construction of the high school but during the school year as
well. As I am sure you are aware, Lexington Street is already a very busy, dangerous, and very
congested street.
 
Furthermore, as a homeowner in the area, I am concerned that blasting earth on the site will
not only contribute to noise pollution in this area, but also will contribute to air quality issues
in terms of dust as well as asbestos released into the air. Earth blasting will likely cause
structural damage to homes along Lexington Street as well as to the surrounding area, not
only through the blasting itself but also to changes in water runoff, rodent traffic, and in the
change in the water table for those homes down elevation from the site resulting in flooding
basements.
 
I respectfully ask you to consider the possibility of keeping this land as open space that could
be used by the community as green space and to consider the impact to the area in terms of
traffic congestion, replacing trees and grass with concrete, loss of wildlife and its habitat, as
well as the change in water handling and in the water table that will likely result damaged
property for all homes in the area. As a community we could use it as a space to walk, play
with our children, picnic and enjoy the nice summer evenings and weekends.
 
Please feel free to contact me and I would be happy to set up an appointment with you to
discuss this topic or to answer any questions.
 
 Section 8: Responses to Comments

8.7.46 Kahana, Christy

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 83

From: Christy Kahana
To: Czepiga, Page (EEA)
Subject: Waltham High School: EEA# 16097
Date: Monday, June 1, 2020 12:32:04 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
 
Good Afternoon Page
 
I write to you today as a resident of Waltham, MA in full support of the Waltham High School
Building Project. I have been very closely following this project since day one and I am excited that
my 8 year old twins will get to see this new High School. I am also excited for the thousands of
students in this community who desperately need and will benefit from a new high school. Waltham
is a wonderfully diverse city with children who have wonderfully diverse needs, many of which the
current High School can not provide. I look forward to the new HS being able to benefit ALL children
in Waltham and fostering a strong sense of pride and community by what the school will represent
and the educational plan that will be built within the walls of the HS.
 
This project has been YEARS in the making and without it’s fair share of significant hurdles. I hope
this project progresses as planned to ensure that as many kids as possible get to see the new school.
 
Sincerely,
Christy Kahana
Waltham Resident
 
 
Christy Kahana
Principal
617-999-8908
www.ckhrconsulting.com
 

 
 
 
 Section 8: Responses to Comments

8.7.47 Katz, Jacob

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 84

 Section 8: Responses to Comments

8.7.48 Katz, Paul

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 85

 Section 8: Responses to Comments

8.7.49 Katz, Sharon

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 86

 Section 8: Responses to Comments

8.7.50 Kern, Michelle

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 87

 Section 8: Responses to Comments

8.7.51 King, David

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 88

 Section 8: Responses to Comments

8.7.52 King, Tim

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 89

 Section 8: Responses to Comments

8.7.53 Kuchler, Ben

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 90

 Section 8: Responses to Comments

8.7.54 Kuno, Erika

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 91

From: Erika Kuno
To: Czepiga, Page (EEA)
Subject: EEA 16097
Date: Friday, June 19, 2020 8:53:06 AM
Attachments: IMG_0317.mov

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Good morning Ms. Czepiga,
 
I’m writing about a proposed high school to be built near me on Lexington street.  There’s a portion
of land called Jericho Hill which many of us walk through and admire nature’s beauty.  I have seen
some amazing creatures, to name a few such as foxes, owls, eagles,  deer, and turkeys.  My
neighborhood is truly fortunate to possess such open space with amazing wildlife.
 
Unfortunately there are many including our mayor, planning to destroy Jericho Hill.  I am deeply
concerned about what may take place;
 
1. The tremendous blasting will not only cause loud explosions, but dust and pollution
emitting into the air (asbestos confirmed on 554 Lexington site).
 
2. More traffic to an already dangerous and congested Lexington Street. Hundreds of
construction vehicles will create serious traffic backups.
 
3. Cutting down thousands of trees and blasting earth will destroy wildlife that reside up
there.  This will affect an existing stream and wetlands at 554 Lexington.
 
4. Structural damage to surrounding neighborhood homes will occur due to explosions
from earth blasting.  This will cause rodent and water run-off issues around Lexington
Street.
 
The last time I cut through near Jericho Hill, I was touched by a mother raccoon carrying four
of her little ones.  I managed to capture a video of a cute little guy taking its first climb, you
can hear him cry in the video.  Ok, so many people may care less of raccoons, but what about
birds of every kind nesting up in trees? I cannot imagine cutting down trees and killing them. 
It’s just an awful thought!!!  Please help us convince Waltham on building at its current
location, many other cities and towns did it.
 
I appreciate your time Ms. Czepiga.
 
Erika Kuno
 
 
Sent from Mail for Windows 10
 
 Section 8: Responses to Comments

8.7.55 Lara, Carolina

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 92

From: Carolina Lara
To: Czepiga, Page (EEA)
Cc: Carolina Lara
Subject: Waltham High School, EEA# 16097
Date: Thursday, June 18, 2020 11:47:17 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Attention Page Czepiga
Assistant Director MEPA 
June 18, 2020

I am writing to comment on the Waltham High School matter EEA#16097; and state my
strong voice of support for the construction at 554 Lexington Street Waltham. 
As a town we need this project to stay on track and be the beacon of hope that investing in
education and youth IS indeed. Without Education there is nothing to make us better.  To
reflect on current events nationwide delaying our HS project would be an injustice to future
generations. I understand the plans for the school and it’s complex topography, but I trust the
city and builders are working to make it work for ALL, and the environmental concerns and
determinations have been investigated favorably.
I also read the letter of support by our very own Waltham Land Trust group. 
As a mother of two children who may hopefully one day attend the new HS (partially 1 year &
younger for 4 yrs) I urge you to not deny our town  this opportunity; any and all delay
constitute a let down and failure to be the trusted leaders they deserve.

Thank you, 
Carolina Lara
Waltham Resident -Parent
43 Harvard Street 

Get Outlook for iOS

 Section 8: Responses to Comments

8.7.56 Lear, Elizabeth

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 93

 Section 8: Responses to Comments

8.7.57 Letendre, Megan

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 94

 Section 8: Responses to Comments

8.7.58 Lucente, Donald

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 95

 Section 8: Responses to Comments

8.7.59 MacDonald, Doug

DM 1

With all of the blasting that will be happening, what are you going to do to ensure that the irreparable damage won’t be
done to the foundations of the neighborhood?

Pre-blast condition surveys will be conducted of abutting properties within 500ft of the blast zone. Blasting is a
regulated and controlled activity.

DM 2

One egress - The plans currently do not include any type of emergency fire exit. The mayor has been asked repeatedly and
no answer. There is no place for another exit without taking more land by eminent domain.

The plans included an emergency egress access on Lincoln Street. The emergency access road is clarified in
section 2.4 of the FEIR.

DM 3

Storm water management - There is no plan for storm water. This will end up ruining the watershed in the area.

The project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment
and includes not exceeding pre-development discharge rates for the design storms. During the construction
period, a Storm Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout
construction to monitor and modify temporary control measures as required. The stormwater is clarified in
section 3.2 of the FEIR.

Waltham High School | Final Environmental Impact Report 5 | p. 96

From: Doug
To: Czepiga, Page (EEA); MEPA (EEA)
Subject: EEA#16097 - Waltham High project
Date: Thursday, June 18, 2020 10:49:34 PM

CAUTION: This email originated from a sender outside of the  Commonwealth of Massachusetts mail system.  Do
not click on links or open attachments unless you recognize the sender and know the content is safe.

Hi There!

I would like to keep this brief.  I own at 525 Lexington Street, which is directly across the street of the proposed
Waltham High School project.  There are a whole host of reasons why this will be a complete nightmare for the
neighborhood.  Some reasons listed below.

Chester Brook - This brook is one of my property lines.  This stream will most certainly be effected; both polluted
with dust as well as the flow itself effected when there is all of the construction.  Chester Brook currently has
crayfish, salamanders, frogs, and many other wildlife.

Wildlife - Countless birds and other animals will be displaced from this.  My neighborhood is home to; groundhogs,
turtles, ducks, field mice, squirrels, chipmunks.  I see hawks flying there often and I’ve seen bald eagles there as
well.  These will all be displaced, or worse, killed during construction.

Dust - With all of the dust that will be generated, I will be going through pool filters on a weekly basis. We will also
need to be cleaning all the time.  I have asthma and so does my elderly mother.  This will be a health risk for us.

Neighborhood foundations - I live DIRECTLY across the street.  With all of the blasting that will be happening,
what are you going to do to ensure that the irreparable damage won’t be done to the foundations of the DM 1
neighborhood?

One egress - The plans currently do not include any type of emergency fire exit.  The mayor has been asked DM 2
repeatedly and no answer.  There is no place for another exit without taking more land by eminent domain.

Schooling - What will schools look like in two years?  Will all students be there every day?  This school definitely
does not need to be so large.  This can be must cheaper than 400M.

140 trucks a day? - Lexington Street is not very big and this trucks will dominate.

Noise pollution - 140 trucks per daily plus the blasting as well as the hammering ALL DAY LONG.  This will
negatively effect wildlife as well as property value.

Storm water management - There is no plan for storm water.  This will end up ruining the watershed in the area. DM 3

Lack of city interaction - The city of Waltham has done nothing but make it so this process has been unclear and
shrouded in secrecy.  This has been pushed through with little community involvement save 20 or 30 very motivated
mothers who truly feel that this is best for the city. 

Please know that the entire neighborhood feels the same way. 

Stay healthy!
Doug

Sent from my iPhone

 Section 8: Responses to Comments

8.7.60 MacLellan, Thomas

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 97

From: thomas mac lellan
To: Czepiga, Page (EEA)
Subject: EEA16097
Date: Friday, June 19, 2020 2:11:52 PM

CAUTION: This email originated from a sender outside of the  Commonwealth of Massachusetts mail system.  Do
not click on links or open attachments unless you recognize the sender and know the content is safe.

Sent from my iPhone waltham has a high school that can be replaced on site with a new high school without
destroying a perfectly wonderful environment  in 80 years that new high school might have to be rehabilitated but
the old environment will never be replaced there's a permanent loss to the city into the state to the neighbors and to
all of us
Very truly yours Thomas Maclellan, citizen of Massachusettscvery truly yours Thomas Maclellan, citizen of
Massachusetts
 Section 8: Responses to Comments

8.7.61 Mallik, Pradip

PM 1

The blasting and massive construction work will destroy the peace in the neighborhood. What are the steps?

Any disruption during construction is temporary and has been minimized and mitigated to the extent feasible.

PM 2

what impact will the massive constructions have on their health?

Construction projects include mitigation for noise, dust etc.

PM 3

We have enough land parcel behind the already existing High School on Lexington St. Why is it not utilized?

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed. The parcel behind the existing
High School has many wetland resource areas, making the buildable area too small for the school.

PM 4

Are we not destroying and risking the stream, the bank, the bordering vegetated wetlands, the wetland buffer and the
watershed resulting from the blasting and building location?

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to avoid any relocation of the intermittent stream and wetland resources.

PM 5

Has ALL issues related to Wetland, Environment, Animals, Traffic and Loss of Peaceful neighborhood been addressed?

All environmental impacts have been analyzed and documented through the MEPA process.

PM 6

We have many old and historic buildings in the area. Ours (564 Lexington St) is listed under ‘Historic buildings, Waltham’ –
due the construction plans lot of residential buildings will have the risk of developing cracks, are we not risking too much
here?

Pre-blast condition surveys are intended to commence by the beginning of November or sooner and be
completed within a 4-6 week timeframe. The blasting notification procedures were described in Section 10.1.5 of
the NPC/DEIR and clarified in Section 6.3 of the FEIR.

Waltham High School | Final Environmental Impact Report 5 | p. 98

From: Pradip Mallik
To: Czepiga, Page (EEA)
Cc: MEPA (EEA)
Subject: Waltham New High School at 554, Lexington St - Project: EEA#16097
Date: Friday, June 19, 2020 12:00:26 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Ms. Czepiga,
 
My name is Pradip Mallik - resident of 564 Lexington St, Unit 2, Waltham (Next to the
main entrance to the proposed Waltham New High School  at 554, Lexington St -
Project: EEA#16097)
 
I am sure many residents from our area has already raised their concerns to the
massive construction plans for the proposed new High School, I had written earlier
also expressing my concerns which I am going to highlight below but before I did that,
have a few questions to ask all responsible adult citizens here;
 
As teachers, parents and responsible adults do we not teach our children to protect
the environment?
What are we going to do here at 554, Lexington St - Project: EEA#16097  ?
What answers will we have when the kids of the new building at 554 asks us, “What
happened to the beautiful animals that lived around here? What happened to the
Forest here?
Are we Preaching what we are practicing?
 
Summary of some of my key concerns:
· The blasting and massive construction work will destroy the peace in the PM 1
neighborhood. What are the steps?
· My neighbor –Steve Meuse at 564 Lexington St, Unit 2 is a 4th stage Cancer
patient. We take care of him in small little ways that we can, there are many
residents like him who are not only unhealthy but are also old in our
neighborhood, what impact will the massive constructions have on their PM 2
health?
· We have enough land parcel behind the already existing High School on PM 3
Lexington St. Why is it not utilized? We already have reasonably good
entrance and separate exit  and also have an emergency road (a must in
case of all emergency situation) going towards Bentley. Why are we NOT
utilizing what we have?
· Are we not destroying and risking the stream, the bank, the bordering PM 4
vegetated wetlands, the wetland buffer and the watershed resulting from the
blasting and building location?
· Has ALL issues related to Wetland, Environment, Animals, Traffic and Loss of PM 5
Peaceful neighborhood been addressed.
· We have many old and historic buildings in the area. Ours (564 Lexington St) PM 6
 is listed under ‘Historic buildings, Waltham’ – due the construction plans lot of
residential buildings will have the risk of developing cracks, are we not risking
too much here?
· During this time of Pandemic, is it NOT Wiser and better to utilize funds
properly than it be driven by rigidity and WHIMS?
 
 
 
 

Thanks and regards

Pradip Mallik
 
Busitants, Inc
Director (Operations & Talent Acquisition)
pradipm@busitants.com
W: 401-628-0451
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 Section 8: Responses to Comments

8.7.62 Martuza, Kathi and Cotton, Kester

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 99

From: Kathi Martuza
To: Czepiga, Page (EEA)
Subject: Waltham High School, EEA# 16097
Date: Monday, June 1, 2020 9:32:48 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
To whom it may concern,

We are writing to express our strong support for the construction of a new public high school
in Waltham, MA. We are the parents of two children who will attend the Waltham public high
school. The current building for the public high school in Waltham is out of date and has aging
infrastructure (HVAC, dated classrooms, technology, etc.). With the construction of the new
facility, Waltham students will have access to a school comparable to surrounding towns.
Most public school students do not have the opportunity to attend private institutions - public
school is their only option for education and they deserve access to high quality facility and
staffing. The current plan for the Waltham high school will increase recruitment for, and the
retention of, educators for our students. The new high school will enhance the entire Waltham
community and provide education opportunities for the entire community. It will have a
positive impact on local businesses and the local business work force. The environmental
concerns related to this project have been addressed. This project has been supported by the
School Committee, the School Building Committee and the City Council, and should move
forward immediately.

Sincerely,

Kathi Martuza and Kester Cotton

Kathi Martuza
Dancer, Mother, Teacher, Writer
Certified PEAK Pilates Instructor
Licensed True Body Project Teacher
Certified Intuitive Eating Coach
San Francisco Ballet and Oregon Ballet Theatre Alumnus
 Section 8: Responses to Comments

8.7.63 Matteodo, Christopher

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 100

From: Chris Matteodo
To: Czepiga, Page (EEA)
Subject: MEPA Jericho Hill Environmental Concerns
Date: Monday, June 15, 2020 11:12:56 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hi,

I was provided this contact information by my Waltham City Council representative to address
my environmental concerns regarding the recent taking of the Jericho Hill land parcel by the
School Board in furtherance of the new High School development project.

I live at 8 Larchmont Avenue in Waltham and routinely walk my dog through the paths
located on Jericho Hill. As someone who walks through these woods on a daily basis, I feel
like I am in a unique position to provide some insight regarding the environmental impact that
any modification to this parcel may have.

To begin with, any building project on this parcel will have a detrimental impact on the local
wildlife that reside in the Jericho Hill wooded area. Local wildlife species include but are not
limited to: turkeys, deer, coyotes, turkey vultures, red tailed hawks, and owls. Removing the
wooded areas will force these species into the surrounding communities and roadways.

Further, there is a vernal stream that many of the animals rely on for fresh water. Any
construction around Jericho Hill may have a material impact on this stream as well as have a
major impact on the local water table. Jericho Hill is the second highest point in Waltham and
any modification of its topography may substantially alter water runoff.

The personal enjoyment of this open space by the surrounding residents will also be negatively
impacted. Waltham has very few wooded spaces in immediate proximity to Jericho Hill. The
area itself is extremely hilly and there are no sidewalks. Jericho Hill is the only safe wooded
place where local residents can walk their dogs and otherwise interact with nature. Jericho Hill
presents its local residents the opportunity that once confronted Thoreau. Namely to see what
nature has to teach us. Without these types of open spaces, we are being robbed of the chance
to educate ourselves about the majesty of the great outdoors. Once trees have been removed,
they cannot be easily replaced. The beautiful views and serene atmosphere of Jericho Hill will
forever be altered. The need for a major parking garage and high school may change based on
technology and circumstances. However, once the trees are removed it would take decades for
them to be replaced.

I worry that in the haste to support the new High School these important environmental
impacts are being overlooked. I appreciate your time and consideration. Thank you.

-Christopher Matteodo
 Section 8: Responses to Comments

8.7.64 McCalla, Christina

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 101

 Section 8: Responses to Comments

8.7.65 McCarthy, Jeannette Mayor

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 102

 Section 8: Responses to Comments

8.7.66 McNiece, Paula

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 103

Massachusetts Environmental Protection Agency

To whom it may concern;

The City of Waltham has taken, by eminent domain, property on Lexington Street in Waltham,
MA to build a new high school.

Environmentally speaking, this is the worst place in the city to build this school! The city plans
on developing untouched land where wild life flourishes, one of the few places left in this city.
Of course, wild life will be destroyed and thousands of trees will be cut down. This will affect
existing streams and wetlands nearby also. Waltham, being a very congested city, already has
terrible pollution from thousands of cars, trucks and construction vehicles. There will be
several hundred more vehicles occupying this area once, or if, this school is constructed.

There are other areas in this city where this new high school can be built without causing the
destruction of wildlife habitat, trees and wetlands.

Please help us stop the construction of this project!

Thank you.
Paula McNiece
Gregory Gullotti
Richard Gullotti
26 Chester Brook Road
Waltham, MA 02452
 Section 8: Responses to Comments

8.7.67 Medeiros, Orlando (3 of 3)

OM 1

Inclusion of Jericho Hill Open Space Area – 6+ acres in the 52-acre site with extraordinary topography and ledge
conditions. This was protected Green open space land and now it will be completely deforested.

Jericho Hill Parcel II is not protected Green Open Space. This parcel was acquired by the City in 2001 for all
Public Purposes. The Project will only remove what is needed for construction, safety, and/or tree health.

OM 2

The continuing threat to the stream, the bank, the bordering vegetated wetlands, the wetland buffer and the
watershed resulting from the blasting and building location. Wildlife and natural habitat depend on this!

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to avoid any relocation of the intermittent stream and wetland resources. This FEIR clearly
demonstrates that the City has sought to avoid, minimize, and mitigate Damage to the Environment to the
maximum extent feasible.

OM 3

The traffic and transportation problems during the 4-year construction period including 140 eighteen-wheel truck
trips daily onto city streets and state highways and the permanent gridlock problem on Lexington Street which is
already congested as it is with continuous speeding issues. 50+ vehicle incidents annually based on Police
reports.

There will be increased traffic during construction, there are significant construction projects in Waltham and
surrounding Towns’ that utilize Route 95 every day. Impacts to neighborhoods will be minimized by the
designated trucking route along Lexington Street, Totten Pond Road and Route 95.

OM 4

The Mayor and SMMA stated the current site are unfeasible for education, but they want to keep it for further
education usage?

The current High School is unfeasible to meet the needs of current High School curriculum and programs.
Lowers grades such as middle schools and elementary schools have very different educational requirements.

OM 5

But yet the mayor decided they needed Jericho Hill, an additional 6+ acres of protected land!! They want to
complete turn this into an open field or possible parking lot?!!

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to avoid any relocation of the intermittent stream and wetland resources. This FEIR clearly
demonstrates that the City has sought to avoid, minimize, and mitigate Damage to the Environment to the
maximum extent feasible.

Waltham High School | Final Environmental Impact Report 5 | p. 104

 Section 8: Responses to Comments

OM 6

The lack of delineation and definition of wetland areas on the property and the damage caused by the project to
them. Again, we ask but they refuse to answer.

The wetlands were delineated through the Waltham Conservation Commission(WCC) and the Order of Resource
Area Delineation was issued by WCC on 8.13.2019

OM 7

The failure to consider water flow in the fissures caused by blasting onto adjacent properties. This will be a
major run-off issue, once you alter land you will have a serious drainage problem.

The drainage design plans are in progress. The project will comply with applicable MassDEP Stormwater
Management Standards for quality and treatment and will not exceed pre-development discharge rates for the
design storms. During the construction period, a Storm Water Pollution Prevention Plan (SWPPP) will be
implemented and maintained throughout construction to monitor and modify temporary control measures as
required. The stormwater is clarified in section 3.2 of the FEIR.

OM 8

The failure to provide adequate monitoring of all the impacts of construction on the neighborhood including,
noise, dust, dirt, water flow, erosion, vibration, blasting, timetable, rodent control, wildlife protection, and school
disruption at the existing high school and junior high school. The impact to homes will suffer greatly, wildlife
without question will be disrupted and scared.

The project will comply with applicable laws and regulations regarding testing and monitoring for dust, noise and
air quality. There are multiple activities which will include third party testing – for instance, asbestos abatement
will include clean air testing; blasting will include vibration monitoring; rodent control is being provided and
monitored weekly. Noise monitoring will occur to confirm compliance with Waltham’s noise ordinance.

Consigli plans to use sound blankets at the perimeter fence strategically placed to mitigate noise to the adjacent
neighbors. This was presented at the SBC of 8/10/2020. Additionally, sound barriers for the rock crushing are
being developed.

Waltham High School | Final Environmental Impact Report 5 | p. 105

From: Orlando Medeiros
To: Czepiga, Page (EEA)
Subject: EEA #16097
Date: Friday, June 12, 2020 3:25:52 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hi Page,

I hope you're doing well and staying healthy during these unprecedented times.  I just wanted
to give you a quick heads-up that the Mayor of Waltham has picked a liaison, Bill Hanley,  to
represent abutters and concerned neighbors.

Bill Hanley was not chosen by us, nor does he represent concerned abutters and neighbors. 
He certainly could care less of the environmental impact.  In fact, he was always for the
project regardless if it means destroying wildlife and protected land.

Within his Facebook page, he is asking his followers to email you in support of the project. 
They all know there's an environmental issue at hand, but will not admit or write about it.  Just
so you know.

Have a great weekend and let me know if you require anything pertaining to EEA #16097

Best,
Orlando
From: Orlando Medeiros
To: Czepiga, Page (EEA)
Subject: EEA #16097
Date: Monday, June 15, 2020 5:30:57 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hello Page,
 
First and foremost, let me again say how grateful we are that you are looking into this matter
and the importance of the environmental impact this will have within our neighborhood. 
Please accept my formal comments, concerns, and facts surrounding EEA # 16097. 
Please feel free to contact me with any questions.
 
 
In regard to the link from SMMA to MEPA and others, we need to take into consideration
important matters pertaining to the above SharePoint file.  
 
SMMA mentioned the current high school at 617 Lexington street was not an option to
rebuild.  However, why did the School Committee unanimously agree to rebuild on current
site in November of 2016?  There is more than enough land to construct a new High School.
In fact, no blasting is required as the land is already developed and no trees would need to be
cut down.  Moreover, the former owners of 554 Lexington never intended to sell at all. The
city of Waltham approached them of a possible sale.  When it was denied, the mayor took the
land by eminent domain. Ultimately, it went to court and the ruling favored the Stigmatine
owners as an illegal taking by the city. The city of Waltham of course paid an extra $11
million taxpayer's money through mediation without informing us.  This all happened behind
closed doors and the public was not allowed to hear about it.
 
But from an environmental perspective, serious issues are still at hand such as;
 

1. MEPA Thresholds – Land alteration, creation of impervious area, transportation and

parking, energy, air quality, wetlands.
2. Inclusion of Jericho Hill Open Space Area – 6+ acres in the 52-acre site with OM 1
extraordinary topography and ledge conditions.  This was protected Green open space
land and now it will be completely deforested. 
3. The continuing threat to the stream, the bank, the bordering vegetated wetlands, the OM 2
wetland buffer and the watershed resulting from the blasting and building location. 
Wildlife and natural habitat depend on this!
4. The inability to squeeze two massive buildings into the southwest corner of the site 40
feet from abutting neighbors’ properties at an elevation above the neighboring roof
lines.  When I approached the building dept about this, they refused to answer my
questions.  Hiding something??
5. The traffic and transportation problems during the 4-year construction period including
 140 eighteen-wheel truck trips daily onto city streets and state highways and the OM 3
permanent gridlock problem on Lexington Street which is already congested as it is with
continuous speeding issues. 50+ vehicle incidents annually based on Police reports.
6. The inappropriate alternatives analysis foisted on the City after 617 Lexington St. was
selected by the SBC on November 14, 2016.  The Mayor and SMMA stated the current OM 4
site are unfeasible for education, but they want to keep it for further education usage? 
Flip-flopping here... makes no sense.
7. The Lack of Community engagement and public input.  They refuse to answer any
questions from neighbors and direct abutters.  This is why they chose Bill Hanley to
speak on our behalf.. outrages!! Bill is anti-environment, has always been for the project
and has verbally stated that the sacrifice of deforestation may be needed.  Asked about
wildlife... he says, "they will find other land." Absurd!!
8. The location of the Emergency Access Road.  This is an ongoing issue, the mayor and
SMMA have always stated one entry/exit point is needed.  But that is not the case now.
9. The inability to achieve the Master Plan at 554 Lexington Street.  We are still waiting
for answers on this.
10. The failure to adopt a realistic Master Plan for the site.  The mayor and SMMA have
said the property at 554 Lexington was sufficient and no more land was needed.  But yet
the mayor decided they needed Jericho Hill, an additional 6+ acres of protected land!! OM 5
They want to complete turn this into an open field or possible parking lot?!!
11. The dramatic land alteration that will occur as a result of extraordinary blasting of a hill
over 200 feet high, some of it below the water table.  This will be devastating for
wildlife let alone surrounding neighborhoods. 
12. The increase in impervious portions of the site resulting from construction. We asked
why that is, but yet they refuse to answer.
13. The lack of delineation and definition of wetland areas on the property and the damage OM 6
caused by the project to them.  Again, we ask but they refuse to answer.
14. The failure to consider water flow in the fissures caused by blasting onto adjacent OM 7
properties.  This will be a major run-off issue, once you alter land you will have a
serious drainage problem.
15. The failure to consider and design a realistic program of storm water management. We
ask again, but no answers. 
16. The failure to provide adequate monitoring of all the impacts of construction on the
neighborhood including, noise, dust, dirt, water flow, erosion, vibration, blasting,
timetable, rodent control, wildlife protection, and school disruption at the existing high OM 8
school and junior high school. The impact to homes will suffer greatly, wildlife without
question will be disrupted and scared
off. https://www.mass.gov/files/documents/2018/01/31/noise-interpretation.pdf?
_ga=2.171468128.174921159.1592234740-352760706.1561308292
 17. The impact of the extraordinary environmental impact and carbon footprint caused by
the project including greenhouse gas emissions and failure to use sustainable energy as
part of the project.  The mayor has advocated to reduce our carbon footprint and she
installed bike lanes a couple years back. But she will now remove the bike lanes and
wants to construct a parking lot to accommodate 450+ cars!! What happened to
reducing carbon footprint??!! 
18. The violation of administrative consent orders with MASS DEP and MWRA.  We have
asked many times on answering these questions but to no avail.
19. The construction management plan and construction timetable without adequate
mitigation measures.  Again, we have asked but nothing.
20. Failure to secure any regulatory permits and approvals from any Federal, State or
municipal agencies.  As citizens, we are obligated to file and obtain permits for any
home renovations, additions, etc.  The city of Waltham took two months to approve my
shed, but yet they're above the law when it comes to this major project?  We have asked
on statuses of these permits but again, to no avail.
21. Article 97 issues.  We tried to hire a well-known law firm familiar with this, but it
appears someone else beat us to the punch.  In fact, the law firm could not answer any
questions due to possible conflict of interests. 
22. Impact of project on the immediately adjacent Sanderson Heights Open Space. For
years the mayor fooled former Ward-2 Councilman Bill Fowler.  The mayor used him
for political reasons for this project, until the truth finally came out which ultimately
forced Mr. Fowler not to seek re-election.  Bill Fowler lives by Sanderson Heights and
the true impact towards his neighborhood was a shock to him.

In conclusion, I have mentioned this many time that I have been part of these meetings since
early 2016.  The mayor has said many things to appease the public but has other intentions and
is not honest by any means.  The Fernalds was an option, but of course that was not
convenient for Councilwoman at Large Kathleen B. McMenimen, who happens to live
nearby.  In fact, I oppose to any deforestation and destruction of precious land.  

The mayor and SMMA state a new High School is needed for a student’s success.  But they
have yet to answer my questions as to the following...

According to a USNews article on Massachusetts High Schools:

1. Boston Latin High School is considered #1 in Massachusetts, all within a building built
in 1922
2. Lexington High School currently ranked #7 (before a new school was built in 2017 on
current site)
3. Weston High School currently ranked #8 within building built in 1961

4. Belmont High School currently ranked #9 within building built in 1970 (new school
 addition taking place on current site)

The above article shows these schools have invested in teachers, rather than new buildings and
the results proves its success.  The US Department of Education, William Penn Foundation,
and Generation Ready group,  have all indicated investing in teachers creates the biggest
impact on students rather than new buildings. 
 
Thank you again Page and my apologies on such a long email.  We have opponents who will
email you favoring a new high school, but without addressing the important and critical
matters discussed within this email.

 
Sincerely,
Orlando M. Medeiros
 
From: Orlando Medeiros
To: Czepiga, Page (EEA)
Subject: RE: EEA #16097
Date: Wednesday, June 17, 2020 2:25:27 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hi Page,
 
You’re welcome and thank you again.  Just to give you additional info on what’s going on, we as
neighbors and direct abutters are not receiving any information.  What SMMA is sending you, are
not the answers we are getting when requested.
 
Again, Bill Hanley has always been for this project and had asked his followers to write to you.  But
interesting enough, he took down his page https://www.facebook.com/electhanley/posts with a pre
-filled statement to MEPA.  He is not engaged with our concerns and will not answer our questions. 
Forgive me for being so blunt, but the mayor has chosen a puppet. 
 
We hope MEPA will see this project as a huge environmental impact as well as other major
environmental issues surrounding it.
 
 
Best,
Orlando M. Medeiros
 
 
 
 
From: Czepiga, Page (ENV)
Sent: Monday, June 15, 2020 6:04 PM
To: Orlando Medeiros
Subject: RE: EEA #16097
 
Orlando,
Thank you for providing the below comment letter. I’m writing to confirm receipt.
Take care,
Page
 
From: Orlando Medeiros <medeiom@outlook.com>
Sent: Monday, June 15, 2020 5:31 PM
To: Czepiga, Page (EEA) <page.czepiga@mass.gov>
Subject: EEA #16097

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.

Hello Page,

First and foremost, let me again say how grateful we are that you are looking into this matter
and the importance of the environmental impact this will have within our neighborhood.

Please accept my formal comments, concerns, and facts surrounding EEA # 16097.
Please feel free to contact me with any questions.

In regard to the link from SMMA to MEPA and others, we need to take into consideration
important matters pertaining to the above SharePoint file.

SMMA mentioned the current high school at 617 Lexington street was not an option to
rebuild. However, why did the School Committee unanimously agree to rebuild on current
site in November of 2016? There is more than enough land to construct a new High School.
In fact, no blasting is required as the land is already developed and no trees would need to be
cut down. Moreover, the former owners of 554 Lexington never intended to sell at all. The
city of Waltham approached them of a possible sale. When it was denied, the mayor took the
land by eminent domain. Ultimately, it went to court and the ruling favored the Stigmatine
owners as an illegal taking by the city. The city of Waltham of course paid an extra $11
million taxpayer's money through mediation without informing us. This all happened behind
closed doors and the public was not allowed to hear about it.

But from an environmental perspective, serious issues are still at hand such as;

1. MEPA Thresholds – Land alteration, creation of impervious area, transportation and

parking, energy, air quality, wetlands.
2. Inclusion of Jericho Hill Open Space Area – 6+ acres in the 52-acre site with
extraordinary topography and ledge conditions. This was protected Green open space
land and now it will be completely deforested.
3. The continuing threat to the stream, the bank, the bordering vegetated wetlands, the
wetland buffer and the watershed resulting from the blasting and building location.
Wildlife and natural habitat depend on this!
4. The inability to squeeze two massive buildings into the southwest corner of the site 40
feet from abutting neighbors’ properties at an elevation above the neighboring roof
 lines. When I approached the building dept about this, they refused to answer my
questions. Hiding something??
5. The traffic and transportation problems during the 4-year construction period including
140 eighteen-wheel truck trips daily onto city streets and state highways and the
permanent gridlock problem on Lexington Street which is already congested as it is with
continuous speeding issues. 50+ vehicle incidents annually based on Police reports.
6. The inappropriate alternatives analysis foisted on the City after 617 Lexington St. was
selected by the SBC on November 14, 2016. The Mayor and SMMA stated the current
site are unfeasible for education, but they want to keep it for further education usage?
Flip-flopping here... makes no sense.
7. The Lack of Community engagement and public input. They refuse to answer any
questions from neighbors and direct abutters. This is why they chose Bill Hanley to
speak on our behalf.. outrages!! Bill is anti-environment, has always been for the project
and has verbally stated that the sacrifice of deforestation may be needed. Asked about
wildlife... he says, "they will find other land." Absurd!!
8. The location of the Emergency Access Road. This is an ongoing issue, the mayor and
SMMA have always stated one entry/exit point is needed. But that is not the case now.
9. The inability to achieve the Master Plan at 554 Lexington Street. We are still waiting
for answers on this.
10. The failure to adopt a realistic Master Plan for the site. The mayor and SMMA have
said the property at 554 Lexington was sufficient and no more land was needed. But yet
the mayor decided they needed Jericho Hill, an additional 6+ acres of protected land!!
They want to complete turn this into an open field or possible parking lot?!!
11. The dramatic land alteration that will occur as a result of extraordinary blasting of a hill
over 200 feet high, some of it below the water table. This will be devastating for
wildlife let alone surrounding neighborhoods.
12. The increase in impervious portions of the site resulting from construction. We asked
why that is, but yet they refuse to answer.
13. The lack of delineation and definition of wetland areas on the property and the damage
caused by the project to them. Again, we ask but they refuse to answer.
14. The failure to consider water flow in the fissures caused by blasting onto adjacent
properties. This will be a major run-off issue, once you alter land you will have a
serious drainage problem.
15. The failure to consider and design a realistic program of storm water management. We
ask again, but no answers.
16. The failure to provide adequate monitoring of all the impacts of construction on the
neighborhood including, noise, dust, dirt, water flow, erosion, vibration, blasting,
timetable, rodent control, wildlife protection, and school disruption at the existing high
school and junior high school. The impact to homes will suffer greatly, wildlife without
question will be disrupted and scared
off. https://www.mass.gov/files/documents/2018/01/31/noise-interpretation.pdf?
_ga=2.171468128.174921159.1592234740-352760706.1561308292
17. The impact of the extraordinary environmental impact and carbon footprint caused by
the project including greenhouse gas emissions and failure to use sustainable energy as
part of the project. The mayor has advocated to reduce our carbon footprint and she
 installed bike lanes a couple years back. But she will now remove the bike lanes and
wants to construct a parking lot to accommodate 450+ cars!! What happened to
reducing carbon footprint??!!
18. The violation of administrative consent orders with MASS DEP and MWRA. We have
asked many times on answering these questions but to no avail.
19. The construction management plan and construction timetable without adequate
mitigation measures. Again, we have asked but nothing.
20. Failure to secure any regulatory permits and approvals from any Federal, State or
municipal agencies. As citizens, we are obligated to file and obtain permits for any
home renovations, additions, etc. The city of Waltham took two months to approve my
shed, but yet they're above the law when it comes to this major project? We have asked
on statuses of these permits but again, to no avail.
21. Article 97 issues. We tried to hire a well-known law firm familiar with this, but it
appears someone else beat us to the punch. In fact, the law firm could not answer any
questions due to possible conflict of interests.
22. Impact of project on the immediately adjacent Sanderson Heights Open Space. For
years the mayor fooled former Ward-2 Councilman Bill Fowler. The mayor used him
for political reasons for this project, until the truth finally came out which ultimately
forced Mr. Fowler not to seek re-election. Bill Fowler lives by Sanderson Heights and
the true impact towards his neighborhood was a shock to him.

In conclusion, I have mentioned this many time that I have been part of these meetings since
early 2016. The mayor has said many things to appease the public but has other intentions and
is not honest by any means. The Fernalds was an option, but of course that was not
convenient for Councilwoman at Large Kathleen B. McMenimen, who happens to live
nearby. In fact, I oppose to any deforestation and destruction of precious land.

The mayor and SMMA state a new High School is needed for a student’s success. But they
have yet to answer my questions as to the following...

According to a USNews article on Massachusetts High Schools:

1. Boston Latin High School is considered #1 in Massachusetts, all within a building built
in 1922
2. Lexington High School currently ranked #7 (before a new school was built in 2017 on
current site)
3. Weston High School currently ranked #8 within building built in 1961
4. Belmont High School currently ranked #9 within building built in 1970 (new school
addition taking place on current site)

The above article shows these schools have invested in teachers, rather than new buildings and
the results proves its success. The US Department of Education, William Penn Foundation,
and Generation Ready group, have all indicated investing in teachers creates the biggest
impact on students rather than new buildings. 

Thank you again Page and my apologies on such a long email. We have opponents who will
email you favoring a new high school, but without addressing the important and critical
matters discussed within this email.

Sincerely,

Orlando M. Medeiros
 Section 8: Responses to Comments

8.7.68 Mullin, Kristen

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 106

 Section 8: Responses to Comments

8.7.69 Pandolfi, Luisa

LP 1

No plans are in place to at least have some industry standard monitoring by independent third parties to mitigate the dust,
dirt, pollution, noise, vibration, traffic, parking, deliveries, rodents and any other environmentally problematic issues that
will occur as a result of this project.

The project will comply with applicable laws and regulations regarding testing and monitoring for dust, noise and
air quality. There are multiple activities which will include third party testing – for instance, asbestos abatement
will include clean air testing; blasting will include vibration monitoring; rodent control is being provided and
monitored weekly. Noise monitoring will occur to confirm compliance with Waltham’s noise ordinance.

LP 2

No mitigation measures have been considered for this entirely residential neighborhood.

The City transferred an additional six-acre parcel to the School Committee to relocate the school and
field/parking program to mitigate impact of the intermittent stream and wetland resources.

LP 3

The surrounding neighborhoods are already plagued with flooding and water runoff coming from the wetlands and streams
at 554 Lexington St. And still the hydrology, storm water runoff and erosion on the site are not adequately addressed. No
discussion, dialog or study has been offered on how the city plans to mitigate the issue.

The wetland and stream do not run off to the southern border of the site (Lincoln Street, Lincoln Terrace, Glen
Circle), they are captured at a headwall within the site and piped underground to the Chesterbrook.

Surface run off due to topography has been noted by the abutters as occurring historically. The project will
comply with applicable MassDEP Stormwater Management Standards for quality and treatment and includes not
exceeding pre-development discharge rates for the design storms. During the construction period, a Storm
Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout construction to
monitor and modify temporary control measures as required.

At a high level, the proposed stormwater management system consists of BMPs which are designed to collect,
treat, and mitigate runoff as stated above. The stormwater management system also keeps separate “clean”
water from the stormwater which must be treated. That is, MassDEP’s regulations consider stormwater runoff
from the athletic field and building roof “clean” so this runoff will not be treated prior discharge. Runoff from the
wooded areas above the rock wall and groundwater collected in foundation drains are also considered “clean”
and these sources will be collected and managed separately from the stormwater which requires treatment.

The stormwater is clarified in section 3.2 of the FEIR.

LP 4

Are they planning to take the street by imminent domain?

Waltham High School | Final Environmental Impact Report 5 | p. 107

 Section 8: Responses to Comments

There is no plan or requirement to take Lincoln Street extension by eminent domain. Under the Federal
Constitution and Massachusetts statutes and case law, the Fire Department and Police department have the
right to use this right-of-way under exigent public safety or emergency situations involving potential risks to
public safety. Under such situations, the government’s good faith interest in protecting public safety outweighs
an individual’s private property rights. The emergency access road is further clarified in section 2.4 of the FEIR.

LP 5

although the city already owns two large parcels of land that could accommodate the new high school, no full alternatives
analysis, report or study has been offered for 617 Lexington St. (adjacent to the current high school) or 200 Trapelo Road
(former Fernald Hospital) with full analysis of qualitative and quantitative criteria resulting in the existing selection.

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

LP 6

No full cost analysis has been done to determine the cost of cleanup at the Fernald property (the site supposedly has some
contaminated areas) vs spending upwards of a half billion dollars and creating immense ecological damage at 554 Lexington
St.

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

LP 7

No clear explanation has been offered as to what changed everyone’s mind or what was discussed during those executive
meetings.

This is not within MEPA Jurisdiction.

LP 8

All the blasting, digging and construction will unleash a population of rats into the surrounding neighborhoods. The plans
for the project still do not address this problem.

The project includes rodent control, this will include setting traps and weekly monitoring.

Waltham High School | Final Environmental Impact Report 5 | p. 108

Czepiga, Page (EEA)

From: Luisa Pandolfi <luisa.pandolfi@yahoo.com>

Sent: Monday, June 15, 2020 8:51 AM
To: Czepiga, Page (EEA)
Subject: Waltham High School - EEA#: 16097

CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not
click on links or open attachments unless you recognize the sender and know the content is safe.

Page Czepiga
Assistant Director, MEPA Office
Executive Office of Energy and Environmental Affairs Via Email: page.czepiga@mass.gov

Re: Waltham High School - Waltham

EEA#: 16097
ENF submitted by SMMA

Dear Ms. Czepiga,

I am writing to you in regards to some issues associated with the proposed Waltham High School project that may have
been
omitted from the Draft Environmental Impact Report recently submitted to your office by SMMA on behalf of the City of
Waltham

First, I’d like to point out that the proposed site for the new high school is in the middle of an entirely and solely resident
ial
neighborhood. The proposed buildings, parking lots, fields, etc. would be mere feet from private homes with no buffer s
pace for
noise, light and traffic pollution. Many homes would have either a building, a road, a field or a parking lot literally in their
back
yards or above their roof lines. Please take a close look at the plans SMMA submitted as to proximity of structures, roads
etc. to private homes.

Here are just some of the issues I’d like to bring to your attention:

BLASTING: Leveling the considerable ledge present at both 554 Lexington Street and Jericho Hill will cause structural da
mage to
abutting homes. There has still never been any discussion of the full impacts of the blast wall on the wetlands, watershe
d, environment and hydrology of the site or the impact it will have on the surrounding neighborhoods.
No plans are in place to at least have some industry - LP 1
standard monitoring by independent third parties to mitigate the dust, dirt, pollution, noise, vibration, traffic, parking, d
eliveries, rodents and any other environmentally problematic issues that will occur as a result of this project.
No mitigation measures have been considered for this entirely residential neighborhood. LP 2

How will the quarry activities will be accomplished without major disruption and damage to surrounding neighborhoods,
properties, streets and land?

1
WATER RUNOFF - The surrounding neighborhoods are already plagued with flooding and water runoff coming from the
wetlandsand streams at 554 Lexington St. And still the hydrology, storm water
runoff and erosion on the site are not adequately addressed. No discussion, dialog or study has been offered on how the LP 3
city plans to mitigate the issue.

EMERGENCY ACCESS - when it became evident that an emergency access would be needed, the plans changed and now
the
emergency access road has been planned through a private way. This plan has never been discussed with homeowners
of the
street (which is basically a shared driveway). The city only has an easement for public utilities on this street and no right
to use a private way for public use. Are they planning to take the street by imminent domain? The street is not wide eno LP 4
ugh for
emergency vehicles to navigate and homeowners often park on the street (as they have a right to in their own driveway)
thus making the street even narrower.
Again, no conversation, dialog or communication was had with the people on this street. None.

ALTERNATIVE SITES FOR PROPOSED PROJECT –

although the city already owns two large parcels of land that could accommodate the new high school, no full alternativ LP 5
es
analysis, report or study has been offered for 617 Lexington St. (adjacent to the current high school) or 200 Trapelo Road
(former Fernald Hospital) with full analysis of qualitative and quantitative criteria resulting in the existing selection.

No full cost analysis has been done to determine the cost of clean- LP 6
up at the Fernald property (the site supposedly has some contaminated areas) vs spending upwards of a half billion dolla
rs and creating immense ecological damage at 554 Lexington St.

It is to be noted that the initial preferred site was actually adjacent to the current high school. After some executive mee
tings
behind closed doors, the plans were suddenly changed to the 554 Lexington Street (former Stigmatines site). No clear LP 7
explanation has been offered as to what changed everyone’s mind or what was discussed during those executive meetin
gs. A
Freedom of Information Act request has been made for those minutes but the administration has refused to release the
m.

JERICHO HILL CONSERVATION LAND - In order to accommodate a project that simply does not fit with the topography an
d the
natural hydrology characteristic of the proposed site, in March the City Council voted to transfer about 6 additional acre
s of
conservation land property known as Jericho Hill to the School Department for use as parking and athletic facilities for th
e new high school on the adjacent land.

This land was acquired by the city some years ago for the purpose of conservation land and open space.

No public input, hearing, or neighborhood meeting was allowed for the taking of Jericho Hill. It was handed over easily i
n2
weeks by a majority vote of city council, most of the deliberation again taking place in executive session to avoid public s
crutiny. Abutting neighbors to Jericho Hill, and the whole community were left stunned. The parcel went from conservat
ion land in an entirely residential zone to a planned parking lot and playing field complete with lights and loud speakers.
The plan is to literally "pave paradise to put up a parking lot".

I’d like to cite Article 97 of the Massachusetts Constitution:

2
‘The people shall have the right to clean air and water, freedom from excessive and unnecessary noise, and the natural,
scenic, historic, and esthetic qualities of their environment; and the protection of the people in their right to the conserv
ation, development and utilization of the agricultural, mineral, forest, water, air and other natural resources is hereby de
clared to be a public purpose’

This 6 acre site would require additional blasting, drilling and tree removal, adding to the estimated 900,000 cubic yards
of ledge, trees, soil and vegetation that would already need to be blasted, drilled and removed from the former Stigmati
nes site.

This would essentially create a years-

long quarry operation in the middle of a densely populated residential neighborhood.

RODENTS –
Waltham already has a huge problem with rats. A simple google search will confirm this fact. The city last year declared
a Public Health Emergency.
All the blasting, digging and construction will unleash a population of rats into the surrounding neighborhoods. The plans LP 8
for the project still do not address this problem.

PUBLIC INPUT IGNORED /RESTRICTED - Although the neighbors and abutters have repeatedly expressed concerns and w
orries
about the proposed project, their question have largely gone unanswered and ignored. To this day there’s only been one

neighborhood-
specific meeting and no open dialog has taken place. The public is only allowed 1 minute each person, 5 people max. to
ask
questions or make statements and only at the School Committee/ School Building Committees meetings. Their questions
are
never answered.

See below for School Building Committee Guidelines for public input:

The Waltham School Building Committee will allow for a public input component to the meeting agenda.
The public input will be a total of five minutes and will be governed by the following guidelines:

A sign-
in sheet will be made available at the podium in the Cannon Lecture Hall 15 minutes before the start of the SBC meeting.
Individuals who are interested in speaking should sign-
up before the start of the meeting and will identify themselves by name and Waltham address.
The Chair of the School Building Committee will begin the meeting by asking if there are any
additional members of the Waltham community who would like to speak during public input.
Only Waltham residents will be allowed to speak at each meeting. If multiple individuals sign up, preference will be given
to
abutters of the 554 Lexington Street property and then ordered by number from the sign-in sheet.
Each speaker will be provided one minute to offer remarks. The Chair will alert the speaker when they have 15 seconds r
emaining. At the conclusion of one minute, the Chair will ask the speaker to wrap-up and call the next speaker.
Each speaker may only take one slot and may not reassign their time to others. Written testimony to complement public
input is appreciated and encouraged.
Residents are strongly encouraged to disclose any possible personal financial enrichment
connected to the project or to the 554 Lexington Street property. Residents are also strongly
encouraged to disclose any other conflicts of interest, or the appearance of a conflict of interest, related to the project o
r the 554 Lexington Street property.

3
School Building Committee Members will not respond to any individuals’ remarks. However, topics may be added to curr
ent or future agendas pending a vote of the School Building Committee.

LACK OF COMMUNICATION - Abutters and neighbors have never been contacted or involved. Although many have tried
to reach out to the administration with questions and issues, there seems to be a reluctance by the administration to en
gage in direct conversation with the neighbors.
When a neighborhood meeting was requested, this is what they mayor had to say on the subject:

“Marian,
On advice of internal and external counsels, there is currently litigation in this matter by neighbors and those litigants ar
e represented by Counsel. Furthermore, there is anticipated and threatened litigation by neighbors in this matter. Conse
quently, a neighborhood meeting cannot be scheduled at this time.
Also, on advice of Counsels, elected and appointed officials of the City of Waltham and Waltham School Department are
prohibited by law from acting in conflict with interests of the City, whether there is litigation or not. That applies to all el
ected officials, Mayor, School Committee and City Council and any appointed officials, boards, commissions or individual
s.
Sincerely,
Jeannette A. McCarthy
Mayor”

Out of respect for your time, I will only enumerate some of the other issues, and unresolved matters,
without going into details. I am sure you can appreciate the detrimental impacts each of these problems will have witho
ut me
having to explain them:

100++ft high ledge wall – environmental nightmare

Loss of natural habitat for wildlife
Loss of open space
Traffic
Inability to achieve the Master Plan with the proposed plan
Failure to consider water flow in the fissures caused by blasting onto adjacent properties
Violation of administrative consent orders with MASS DEP and MWRA
No sidewalks on the side streets for kids to walk on
Loss of thousands of trees/climate change
Soil erosion
Disruption of wetlands and streams
No updated list of Federal, State and Municipal permits required for the project
No full evaluation of energy mitigation measures
No analysis of GHG emissions form cars, buses, vans, trucks, etc and effects of the surrounding neighborhoods
Radon emission from blasting
And many more….

This preposterous, environmentally damaging and insensitive project is completely inappropriate for the location and w
ould
cause irreparable damage to the environment, the city, the neighborhood and people’s lives and wellbeing. It will forev
er
impact the abutters, the neighbors and all the citizens of Waltham.
None of this is necessary given that the city already owns more appropriate locations on which to build a new high schoo
l, which would cost far less and not unleash the calamity this proposal would bring to our city.

Thank you for your kind attention and consideration.

4
Luisa Pandolfi
26 Lincoln Terrace

5
 Section 8: Responses to Comments

8.7.70 Parkes, Alysia

AP 1

There has also not been any commitment to the control of the rat population moving up the hill.

The project includes rodent control. This will include setting traps and weekly monitoring.

AP 2

If the building at this site continues I would hope that the state mandates that there be access for alternative transportation
to the school such as sidewalks and bike lanes.

The City and Traffic Engineer believe the shared bike lane is the safest approach for bicyclists along this
corridor. A portion of the route is currently shared so it is extending a current practice. Bicycle detection will be
added to the traffic signal design to aid in activating the lights and additional signage for the bike lane will be
added along the corridor. The project is installing new crosswalks on Lexington Street at the site which will aid
pedestrian safety.

Waltham High School | Final Environmental Impact Report 5 | p. 109

From: Alysia Parkes
To: Czepiga, Page (EEA)
Subject: project Name and EEA#16097 Waltham HS building at 554 Lexington St
Date: Friday, June 19, 2020 4:38:53 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hello,

I am writing today regarding my many concerns regarding the building of the Waltham
High School at 554 Lexington St. My home abuts this project and we have had very little
notice of the impacts of the proposal.

I am specifically concerned that there has not been study of the health effects of blasting the
hill away as well as the loss of wildlife that inhabit the woods. The project details
frequently change with little to no notice and there hasn't been any commitment to the
preservation of as many trees as possible on the remaining open land. There has also not been AP 1
any commitment to the control of the rat population moving up the hill.

My family like so many families around here are now working from home on a permanent
basis due to Corvid 19 and it is possible our kids will be attending school from home in the
Fall. The impact of the blasting on the lives of those who surround the hill can not be
underestimated nor ignored.

If the building at this site continues I would hope that the state mandates that there be access AP 2
for alternative transportation to the school such as sidewalks and bike lanes. The large wall
that separates the back of the high School to the residential area needs to be connected by a
walking and bike path.

I hope that this agency can help mitigate the environmental impacts for the people and animals
that live in this area.

Thank you for your time.

Sincerely,

Alysia Parkes
 Section 8: Responses to Comments

8.7.71 Parrella, Susan

SP 1

There is one existing stream that was once classified as a river

The intermittent stream has never been classified as a river.

Waltham High School | Final Environmental Impact Report 5 | p. 110

From: Susan Parrella
To: Czepiga, Page (EEA)
Subject: EEA#16097
Date: Thursday, June 18, 2020 7:05:10 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Dear Members of MEPA,

This letter is to express my grave concern of the potential destruction of the natural
environment and wildlife that is about to take place at 554 Lexington Street, Waltham.  The
City plans to blast over 900,000 square feet of ledge, leaving a 15 to 18 foot high wall of ledge
behind. This ledge is an invitation to student to try and scale it - hopefully no one will fall.  
The blasting will emit dust and will most likely cause the existing streams and wetland to start
overflowing.  There is one existing stream that was once classified as a river (as reporting in a
public meeting).  What will be the guarantee that it does not become one again?

The traffic on an already busy three lane street will become seriously backed up.  Knowing
there will not be two different streets/lanes/roads used to access the property on a daily basis
lends itself to a potential problem. We have been told there will be an emergency exit (dirt
road) upon completion of the school.  This will create a dangerous situation on a daily basis
for all those who live and travel on Lexington Street, especially with the reality of a truck
hauling ledge breaking down.  We will be adding over 350-400 vehicles on the road daily at
two times of day. 

With all of this, the finished product will sit on a comprised setting do to the traffic problems
and areas of concern.  The ledge walls will become a challenge for high school students to
scale.  A once beautiful piece of property with wildlife and beautiful trees will be barren, other
than a building for the school, a parking garage and small field.  The desire for a campus has
gone out the window due to the amount of ledge on this property.  All the blasting will cause
numerous problems to building/homes in the area.  The cost to remove the ledge would better
serve to population if the site were saved from destruction.

The City has other options that would cost less and serve the community better as they
recently purchase property on Beaver Street.  The development of the two different sited could
be swapped thus the environment would be protected and their would be less destruction.  

Thank you for your attention to this matter and listening to some of my and other concerns.

Sincerely,

Susan Parrella
501 Lexington Street
Waltham, MA 02452
 Section 8: Responses to Comments

8.7.72 Piccirilli, Christin

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 111

 Section 8: Responses to Comments

8.7.73 Proskoczilo, Brandice

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 112

From: Brandice Proskoczilo
To: Czepiga, Page (EEA)
Subject: Waltham High School, EEA# 16097
Date: Monday, June 1, 2020 4:24:01 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Good Day,

I am a Waltham of two children in the Waltham public school system (grade 5 and grade 1).
I'm writing today to voice my support for the Waltham High School project.

My children have had a wonderful experience in elementary school so far. They have received
individualized attention and have had the benefit of attending a relatively new elementary
school that is equipped with the technological architecture to support modern advances (built
in early 2000s). My concern as they grow older is that their experience in high school may not
match the experience they have currently. Waltham is a vibrant community and the city
should have a high school that represents its bright future. The current high school building
has aged and does not meet today's standards (A/C, Science labs for example) . I've seen a few
families move out of the city because of their concern over the high school. The time to
proceed is now.  I pray that my two children will have the opportunity to experience what
could be an amazing school for our diverse and amazing community.

The City Council, School Committee and School Building Committee have overcome and
addressed all environmental concerns that relate to the high school project. Please do not
delay the Waltham High School Project.

Thank you for your consideration.

Kind Regards,
Brandice Proskoczilo
 Section 8: Responses to Comments

8.7.74 Pruy, Karen

KP 1

Jericho Hill is a unique area of open space in our community

Jericho Hill Parcel II was never taken or dedicated as open space/conservation land.

Waltham High School | Final Environmental Impact Report 5 | p. 113

From: Karen Pruy
To: Czepiga, Page (EEA)
Subject: Environmental Concerns with Waltham High School
Date: Friday, June 19, 2020 10:54:41 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Good morning Page.

My name is Karen Pruy. I am a lifelong resident of Waltham, MA. I have lived at my home at
284 Lincoln St. for 25 years.

I am writing to you today to express my deep concerns with the City of Waltham's decision to
transfer 6 acres of land in North Waltham, known as Jericho Hill, to be utilized as a parking
garage for the new Waltham High School.

I live near Jericho Hill so naturally have concerns related to the blasting and other logistical
aspects that will affect our very densely populated neighborhood. However, these are
secondary concerns.

The primary concern of many in my neighborhood and my family is the terrible loss of Jericho
Hill from an environmental perspective. Jericho Hill is a unique area of open space in our
community. It is an environmental haven connected to 26 acres of wooded land (Sanderson
Heights) and is easily accessible for many, including small children and senior citizens like
myself. From the summit of Jericho Hill one is able to see Boston while enjoying the peaceful
solitude of this very special, irreplaceable spot in our neighborhood. We appreciate Jericho
Hill and can not imagine how the destruction of our natural refuge, the felling of mature trees,
and the displacement of abundant wildlife will negatively affect our community. Honestly, it
is heartbreaking to envision. 

As MEPA is evaluating the issues surrounding Jericho Hill, I am hopeful that you will
consider the impact the loss of this unique 6 acres will have on our environment and future
generations of Waltham citizens.

I appreciate being able to reach out to you directly and remain hopeful that a concrete multi-
level parking garage will not replace Jericho Hill.

Sincerely,
Karen Pruy
284 Lincoln St.
Waltham, MA 02451
339.970.4496
 Section 8: Responses to Comments

8.7.75 Remage – Healey, Sarah

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 114

 Section 8: Responses to Comments

8.7.76 Reynolds, Christine

CR 1

The wall will be 105 feet at its highest. Do what is possible to discourage people from climbing up the wall. Fencing at the
top of the wall is already a feature.

Fencing will be provided at the top and bottom of the wall.

CR 2

Is there a possibility that some mature trees could be identified within the woods, and not cut down but by using their
current position be incorporated into the new landscaping?

The project will only remove what is needed for construction, safety, and/or tree health.

CR 3

In addition, the plan estimates 1,851 new ADTs (Average Daily Trips) which exceeds the ENF threshold of 1,491 ADTs on
roadways providing access to a single location.

Is this sustainable?

Traffic improvements include new signals at the school entrance, the City initiative at Totten Pond Road and the
goal to implement adaptive signaling will improve the traffic flow along the Lexington Street corridor.

CR 4

Can anything more be done to mitigate the traffic?

See response to CR 3 above.

CR 5

I would like more clarification on this with the goal of sequencing as many lights as necessary along Lexington Street for
improving the traffic.

Adaptive traffic control system (ATCS) is a traffic management strategy in which traffic signal timing changes, or adapts,
based on actual traffic demand. This is accomplished using an adaptive traffic control system consisting of both hardware
and software. The new signals at the New High School will include this technology; the City will include it at the new Totten
Pond Road signals. As the City upgrades lights along Lexington Street, other signals will include this and the signals will work
together to adapt to traffic.

CR 6

Ensure that “warm” amber LED bulbs are used, with a color temperature of no more than 3000 Kelvins. LED lights in the
blue spectrum are harmful. (see www.energy.gov/eere/ssl/street-lighting-and-blue-light-faqs-health-concerns)

This is under development and not within MEPA jurisdiction.

Waltham High School | Final Environmental Impact Report 5 | p. 115

 Section 8: Responses to Comments

CR 7

Hire an independent professional to monitor that the construction noise, fuel and other health constraints are maintained.
To whom will that person be accountable? How will the public register concerns and issues over the next four years, and
what actions could the public expect?

The Construction Manager (CM) is responsible for adhering to the laws and regulations regarding noise, fuel etc.

Responsible parties for receipt of complaint will vary depending upon the complaint:

Blasting Complaints – Fire Department

Noise complaints – Police Department

Blasting damage complaints – Consigli (CM) will provide a Point of Contact

All other complaints – Inspector of Buildings

CR 8

Are there other fields in Waltham which can be used instead to accommodate large crowds?

This is not within MEPA Jurisdiction.

CR 9

Increase the electronic charging stations from the current 2% to more, since it will be five years from now that the garage
will be used and there will be more electronic cars by then.

The project is providing 7 Electric vehicle charging spaces and reviewing options to provide the infrastructure
now for additional spaces in the future.

Waltham High School | Final Environmental Impact Report 5 | p. 116

Ms. Christine Reynolds
52 Piedmont Avenue
Waltham, MA 02451
Re: Waltham
Waltham High School
554 Lexington Street
EEA #16097
June 18, 2020
Kathleen A. Theoharides, Secretary Executive Office of
Energy & Environmental Affairs 100 Cambridge Street
Boston MA, 02114
Attn: MEPA Unit
Dear Secretary Theoharides:
I am writing in response to the SMMA Draft Environmental Impact Report written on
behalf of the City of Waltham for the proposed new construction of the Waltham High
School at 554 Lexington Street.
I noting here items either not addressed or not addressed fully by SMMA which were
requested in the letter from your office of December 6, 2019. Also included are items
that are of concern. I have sent the text on this page to the DEP.

FO R DEP

WAT ER ISSUES :
• Attached are the images 4.6 Proposed Watershed map and Link 3 Plans C_141 Plant-
ing Plan 1 of the existing stream watershed. It appears that the school is built within the
100-foot buffer zoner of watershed. Will this pose a water issue in the school? Also see
page 4/p1 of the Report itself for further details.
• The debris over the wetland area has not yet been fully cleared away by the city to as-
sess the full extent of the wetland, despite a letter from SMMA to the City on 10.10.19
requesting it to do so (see attached). Are the assumptions the SMMA makes in its
report sufficient without having actually seen the extent of the wetlands after the debris
is removed? See Report 4/p1:“The existing disturbed bank and BVW will be restored
as part of the Project. The fill that has been placed over the presumed resource area
will be removed to allow approximately 270 linear feet of bank and 550 square feet of
BVW to re-establish. The existing headwall and pipe connection at the southern end of
the stream will be replaced. All work will be coordinated with a Wetlands Scientist and
will be detailed in the Notice of Intent reviewed by the City of Waltham Conservation
Commission.”
• Per the Report (2/p3), this plan will create 9.54 acres of impervious area, but the
ENF threshold is only 5.0 acres. Is this an area of concern— can it be addressed?

• Continue to maintain use of porous paving materials for optimum performance.

The Report (3/pg 1) cites: “Porous pavers were previously utilized as a strategy in
reducing impervious cover and were shown at the pedestrian plaza area adjacent to the
synthetic field. The new design decreases the impervious area and minimizes plaza area
associated with the field, so pervious paving materials are no longer proposed.” My
question is why aren’t porous paving materials continued to be used, to minimize as
much as possible excess water?
FO R MEPA 2

• Exchange of six acres of open land

The City Council voted to annex six acres of Jericho Hill Parcel II on March 2, 2020 in
an executive session. There was no discussion with the public users of this area or abut-
ters, who use and appreciate this wooded open land and pathways.
This land was acquired by the city in 2001, and appears as a valued property in the city’s
publication: The City of Waltham, MA 2015– 2022 Open Space and Recreation Plan,
which cites Jericho Hill four times. On page 21 it states “Waltham’s hills are the 2nd
most unique natural feature that in combination with the Charles River basin define
the community’s landscape and include Prospect Hill, Mackerel Hill, Trapelo Hill,
Jericho Hill, Bear Hill, Owl Hill, Pigeon Hill and Stearns Hill [which] are all distinc-
tive landforms that shape Waltham and create scenic quality. This scenic quality can be
maintained and balanced with appropriate development that maintains open space and
vistas.”
I encourage the city in good faith to set aside six acres of land as permanent conserva-
tion land in exchange for these six acres of Jericho Hill.

• Summit, stone wall, and wooded path revitalization

Between the proposed school and the neighborhood with Sachem and Trimount streets
there remains an area of wooded land. It contains a series of dirt paths, stone walls, and
the summit of Jericho Hill. This area could be proactively developed with professionally
designed trails and kiosks to provide an educational experience regarding the history of
the land and stone walls from geological and cultural perspectives, in addition to featur-
ing a view of Boston from the summit. These trails/paths would work in tandem with
the new fence that will be placed along the perimeter of the edges. Taking steps now to
control the paths would protect people, land, and wildlife. Constructed paths could also
lead east down the hill to Lexington Street, and south into the Sanderson Heights area
to connect to existing trails. (See Link3-Plans, C-131 Grading and Utilities Plan 1)

• Safeguards against wall climbing

The wall will be 105 feet at its highest. Do what is possible to discourage people from CR 1
climbing up the wall. Fencing at the top of the wall is already a feature.

• Query on use of existing trees

I appreciate the use of the native plants that will be used in the landscaping. In the Plans
pdf, (Details 1, E3, Page c-501) there’s a detail of a chain link fence which looks to be
used to protect newly planted sapling trees. Is there a possibility that some mature trees
could be identified within the woods, and not cut down but by using their current posi-
CR 2
tion be incorporated into the new landscaping?

• Parking and ADT limits exceeded

In the Appendices (page 28) and the Report (2/p3), the plan proposes 454 new park-
ing spaces, which is over the ENF threshold of 150 or more new parking spaces at a
single location. Though the parking spaces have been reduced by 100 since the previous
plan, the number still exceeds the threshold.
In addition, the plan estimates 1,851 new ADTs (Average Daily Trips) which exceeds
the ENF threshold of 1,491 ADTs on roadways providing access to a single location.
Is this sustainable? CR 3
 3

• Traffic issues
In the months before the pandemic-induced shut down, during the morning rush hour
it often took two to three light changes at the intersection of Lexington, Totten Pond,
and Bacon streets to move from 554 Lexington through the light.
The report created 9.26.19 by traffic engineer J. Michael Garvin cited that “Without a
second access drive, a high school at the proposed location will significantly increase
traffic on Lexington Street, to a point where it is likely the existing street cannot ac-
commodate the increased traffic.” (pg 131). However, there is a difference in opinion
between this assessment and SMMA’s regarding the amount of traffic that would use
“Jack’s Way” and the subsequent traffic flow onto Lexington Street.
The revised Plan now includes a secondary emergency access road, but not a secondary
road that could be used on a regular basis. However, due to its topography, the site
doesn’t seem to be able to accommodate a second access road. It will be helpful, how-
ever, that the lights will be sequenced along Lexington Street and at the intersection of
Lexington, Totten Pond, and Bacon streets.
Can anything more be done to mitigate the traffic? CR 4

• Traffic light sequencing

From Report 12/p2: “The design includes a new signal in Lexington Street which
includes adaptive signal control technology which will be implemented and sequenced
with previous and subsequent traffic lights along Lexington Street.” I would like more CR 5
clarification on this with the goal of sequencing as many lights as necessary along Lex-
ington Street for improving the traffic.

• Confirm use of “warm” LED lights

In the plans there is information on the bases for the light pole bases, but not on the
actual fixture containing the light source. However, I am glad to see that “dark sky”
requirements for exterior light fixtures will be followed: (Per Final Design Program 2/
p82): “Exterior light fixtures and layout are to meet IES TM-15-11 (BUG rating meth-
od) and “dark sky” requirements. Full cut-off, cut-off and glare-free exterior fixtures
will reduce light spillage from the site (light pollution reduction). High efficiency, long-
life LED will be used to illuminate school parking lots, access roads and walkways.”
Note that this must also include the playing field lighting.
Ensure that “warm” amber LED bulbs are used, with a color temperature of no more CR 6
than 3000 Kelvins. LED lights in the blue spectrum are harmful. (see www.energy.gov/
eere/ssl/street-lighting-and-blue-light-faqs-health-concerns)

• Public need for connection to the monitor of noise, air pollution, other issues
Hire an independent professional to monitor that the construction noise, fuel and other
health constraints are maintained. To whom will that person be accountable? How will CR 7
the public register concerns and issues over the next four years, and what actions could
the public expect?

• Concern about excessive noise and light from the field

I am concerned in terms of noise levels about stadium seating for 600 in five tiers,
the lights, and the “high output speakers” that are planned for the field on top of the
parking garage (see pp 4 and 6, Synthetic Field, east side, 5.11.2020 report). Are there
 4

other fields in Waltham which can be used instead to accommodate large crowds? See CR 8
Per Final Design Program 2/pg81: “A local sound system will be provided for the
athletic field. Speakers will be mounted to the sports light poles for announcing sport-
ing events. Inputs will be coordinated further. The system will consist of outdoor high
output speakers, mixer/amplifiers and audio inputs.”

• Parking garage and electronic charging CR 9

Increase the electronic charging stations from the current 2% to more, since it will be
five years from now that the garage will be used and there will be more electronic
cars by then.

• Public input concerns

For the record: Since April 2019 limited opportunity for public participation before
School Building Commitee (SBC) meetings: The Report states on page 2/1:“At the
start of each meeting the SBC opens the floor to the public, giving abutters and com-
munity members an opportunity to express appreciation, concern, and pose questions
to the SBC.” For the record, since April of 2019 the questions and comments from the
public before each SBC meeting were limited to one minute per person for a total of
five minutes. The comments were read by a Council member, since the meetings were
on-line. No one on the Board responded to these comments, as there are no require-
ments for them to do so. It is unclear if these comments were archived. This policy
does not represent adequate public involvement. See last page of this letter for the SBC
policy statement.

Thank you,
Sincerely,
Christine Reynolds

Attached:
Detail of C-121 Layout and Materials Plan 1
Figure 4.6 Proposed Watershed Map
SMMA Removal of Debris letter 10.10.19
Public Session Rules from the School Building Committee dated 4-8-19
 Section 8: Responses to Comments

8.7.77 Roche, Patricia and Brountas, David

PR+DB 1

Inclusion of Jericho Hill Open Space

Jericho Hill Parcel II was never taken or dedicated as open space/conservation land.

PR+DB 2

The inappropriate alternatives analysis foisted on the City after 617 Lexington St. was selected by the SBC on November 14,
2016

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed

PR+DB 3

The lack of delineation and definition of wetland areas on the property and the damage caused by the project to them

The wetlands were delineated through the Waltham Conservation Commission(WCC) and the Order of Resource
Area Delineation was issued by WCC on 8.13.2019

PR+DB 4

The violation of administrative consent orders with MASS DEP and MWRA

There are no violations of consent orders on the Project.

PR+DB 5

How can the city manage additional runoff once trees, vegetation and dirt has been removed? How will underground water
patters be changed due to the blasting?

The project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment
and includes not exceeding pre-development discharge rates for the design storms. During the construction
period, a Storm Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout
construction to monitor and modify temporary control measures as required.

Groundwater flow rates across the site will be estimated based on the results of the aquifer testing program
planned as a part of the ongoing supplemental subsurface exploration program described in section 3.2.3 of the
FEIR. Once available, aquifer testing results can be used to estimate time required for groundwater stabilization.

Waltham High School | Final Environmental Impact Report 5 | p. 117

From: patricia.roche133@verizon.net
To: MEPA (EEA)
Subject: EEA #16097 Waltham Sr High School
Date: Friday, June 19, 2020 2:38:49 PM
Attachments: letter to mepa final.docx

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
To: MEPA,
We have attached a letter outlining our concerns regarding the EEA
#16097  Waltham Sr. High School.

The City has added 6 acres of Open Land to the project with a plan to
blast a hill over 200 feet high, resulting in a 130 foot wall of ledge. 
Some of this will be below the water table.  

The resulting plan places the two buildings in the southwest corner of
the property, at one point 40 feet from a neighbor's house.   

Listed below are some of our concerns;

1. MEPA  Thresholds – Land alteration, creation of impervious

area, transportation and parking, energy, air quality, wetlands
2. Inclusion of Jericho Hill Open Space Area – 6+ acres in the 52
acre site with extraordinary topography and ledge conditions
3. The continuing threat to the stream, the bank, the bordering
vegetated wetlands, the wetland buffer and the watershed
resulting from the blasting and building location
4. The inability to squeeze two massive buildings into the
southwest corner of the site 40 feet from abutting neighbors
properties at an elevation above the neighboring roof lines
5. The traffic and transportation problems during the 4  year
construction period including 140 eighteen wheel truck trips
daily onto city streets and state highways and the permanent
gridlock problem on Lexington Street  
6. The inappropriate alternatives analysis foisted on the City
after 617 Lexington St. was selected by the SBC on November
14, 2016
7. The Lack of Community engagement and public input
 8. The location of the Emergency Access Road
9. The inability to achieve the Master Plan at 554 Lexington
Street
10. The failure adopt a realistic Master Plan for the site
11. The dramatic land alteration that will occur as a result of
extraordinary blasting of a hill over 200 feet high, some of it
below the water table
12. The increase in impervious portions of the site resulting from
construction
13. The lack of delineation and definition of wetland areas on the
property and the damage caused by the project to them
14. The failure to consider water flow in the fissures caused by
blasting onto adjacent properties
15. The failure to consider and design a realistic program of storm
water management
16. The failure to provide adequate monitoring of all of the
impacts of construction on the neighborhood including, noise,
dust, dirt, water flow, erosion, vibration, blasting, time table,
rodent control, wildlife protection, and school disruption at the
existing high school and junior high school
17. The impact of the extraordinary environmental impact and
carbon foot print caused by the project including greenhouse
gas emissions and failure to use sustainable energy as part of
the project
18. The violation of administrative consent orders with MASS DEP
and MWRA
19. The construction management plan and construction
timetable without adequate mitigation measures
20. Failure to secure any regulatory permits and approvals from
any Federal, State or municipal agencies.
21. Article 97 issues
22. Impact of project on the immediately adjacent Sanderson
Heights Open Space

Thank you for your time.

Patricia and David
 
 Patricia A. Roche
David N. Brountas
55 Glen Circle
Waltham, MA 02451

Patricia.roche133@verizon.net
Dbrountas@verizon.net
617-959-4509

Re: Waltham Sr. High School EEA # 16097

We are writing to express our concerns regarding the building of

the Waltham High school at 544 Lexington street, Waltham, MA.

The City of Waltham has added 6+ acres of Open Space land

identified as Jericho Hill to the original 52 Acre build site. They
are now siting the two massive high school buildings into the
southwest corner of the site, 40 feet from abutting neighbors’
properties at an elevation above the neighboring roof lines.
Additionally, the plan is to blast the hill resulting in a 130 foot
wall. It’s at this location on the site, that the parking garage, and
all incoming and exiting traffic will be routed.

This Jericho Hill land has extraordinary topography and ledge

conditions. They estimate it will take a year to blast all the ledge
and result in 140 eighteen wheeled truck trips daily onto city
streets, and state highways which are already over taxed. We
question the amount of alteration to the land, and the energy
required to complete the changes. How will these changes
affect air quality, the stream, bordering vegetated wetlands, the
wetland buffer and the watershed?

The Jericho Hill land and abutting Sanderson Heights already

present extreme amounts of water running on to adjoining
neighbor properties. Previous attempts to develop Sanderson
Heights have been aborted do to the inability to manage runoff.
Years ago, Totten Pond which was located between Totten Pond
Road and Winter Streets was filled in to build apartments. This
had been the catch pond for water runoff. As a result,
Chesterbrook which runs from Winter Street, along Pond End
Land, under the Totten Pond Road interesection, behind
buildings on Lexington Street including O’Reilly’s, the Car Wash
and then over to Linden Street floods during rain storms. How PR+DB 1
can the city manage additional runoff once trees, vegetation and
dirt has been removed? How will underground water patters be
changed due to the blasting ? We have already received a
notice from the City notifying us that we will be fined for water
running off our property. This water comes down the hill from
the Sanderson Heights/Jericho Hill/544 Lexington Street
properties.

Having lived on our property for 60 years, we have seen the

changes which have resulted from land alteration and building
on the site. None have been positive.

We urgently request that you review the new high school plan.

Taking 6 acres of Open Land can never be reversed. This land

has an elevation comparable to Prospect Hill. It is an important
part of our neighborhood.

Thank you for your help.

Sincerely,

Patricia A. Roche
David N. Brountas
55 Glen Circle
Waltham, MA 02451

Patricia.roche133@verizon.net
Dbrountas@verizon.net
617-959-4509
 C
1.
2.
3. MEPA Thresholds – Land alteration, creation of impervious
4. area, transportation and parking, energy, air quality, wetlands
5.
6. Inclusion of Jericho Hill Open Space Area – 6+ acres in the 52
acre site with extraordinary topography and ledge conditions
7. The continuing threat to the stream, the bank, the bordering
vegetated wetlands, the wetland buffer and the watershed
resulting from the blasting and building location
8. The inability to squeeze two massive buildings into the
southwest corner of the site 40 feet from abutting neighbors
properties at an elevation above the neighboring roof lines
9. The traffic and transportation problems during the 4 year
construction period including 140 eighteen wheel truck trips
daily onto city streets and state highways and the permanent
gridlock problem on Lexington Street
10. The inappropriate alternatives analysis foisted on the City
after 617 Lexington St. was selected by the SBC on November
14, 2016
 Section 8: Responses to Comments

8.7.78 Rooney, Patrick

PR 1

I respectfully request that the project proponent go back and provide a greater level of detail and backup information on
their assessment, their conclusions, and proposed mitigations.

The DEIR Certificate was issued noting the project adequately and properly complied with MEPA and its
implementing regulations.

PR 2

The vast extent of bedrock required to be blasted and removed will take at least 4 years. There is not sufficient information
presented on this activity and the required mitigations.

The blasting and rock removal is estimated to take approximately 1 year. The School construction will follow and
be completed by 2024. The blasting notification procedures were described in Section 10.1.5 of the NPC/DEIR
and clarified in Section 6.3 of the FEIR.

PR 3

Aside from some very basic measures silica dust control is not addressed or described.

Methods for controlling silica dust exposure will be in compliance with OSHA section 1926.1153 Table 1. The
CM’s Site Specific Safety Plan includes that any activity which can produce silica dust will use engineering
controls to keep dust to a minimum. There will be no dry cutting of any masonry material allowed; if water
cannot be used then a dustless vacuum system consisting of a HEPA dustless vacuum system shall be used.

PR 4

Rodent infestation is a very real and dangerous hazard (disease vector and property damage to name a few).

No adequate level of detail was provided on this.

The project includes rodent control, this will include setting traps and weekly monitoring.

PR 5

The report did not contain sufficient information to ensure adequate management of water onsite during construction.

The project will comply with applicable MassDEP Stormwater Management Standards for quality and treatment
and includes not exceeding pre-development discharge rates for the design storms. During the construction
period, a Storm Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout
construction to monitor and modify temporary control measures as required.

PR 6

The information presented in the draft EIR does not address the Traffic Commission report that the area cannot sustain this
increase in vehicles and there will be extensive gridlock.

The City Traffic Engineer report referenced this not the Traffic Commission. Traffic improvements include new
signals at the school entrance, the City initiative at Totten Pond Road and the goal to implement adaptive
signaling will improve the traffic flow along the Lexington Street corridor.

Waltham High School | Final Environmental Impact Report 5 | p. 118

 Section 8: Responses to Comments

PR 7

In addition to the safety concerns, the effects of noise and exhaust from construction vehicles, particularly dump trucks,
and from vehicles idling on the roadways during school opening and closing on residents and public health in the
neighborhood was also not adequately addressed.

The no idling policy will be enforced on site via signage and construction management personnel and
subcontractor contractual language. Verbal warnings will be issued followed by written warnings and fines per
incident.

The CM will include the requirement for ultra-low sulfur diesel fuel and equipment retrofitted with emissions
control equipment, including emission control equipment identified in the Commonwealth’s Clean Air
Construction initiative for all subcontractors.

PR 8

Information on the secondary access/egress is not complete.

The emergency access road is clarified in Section 2.4 of the FEIR.

PR 9

The Draft EIR states that the Greenway will not be interrupted. How is this possible with the proposed construction plans?

The Western Greenway does not include 554 Lexington Street.

PR 10

The Draft EIR also refers to “limited” areas of disturbance. With four years of blasting alone and the related traffic, air
quality, noise and rodent issues I truly do not agree with this statement. This is a very large disturbance that is not fully
accounted for in the Draft EIR.

The blasting will take approximately 1 year followed by construction of the school. The DEIR Certificate was
issued noting the project adequately and properly complied with MEPA and its implementing regulations.

Waltham High School | Final Environmental Impact Report 5 | p. 119

Patrick Rooney

536 Lexington St

The Draft EIR does not provide the level of detail required to assess if the proposed project in the
proposed location, nor are the associated mitigation measures adequate to protect public health and
the environment. I have outlined several areas below, where I believe the Draft EIR is inadequate. I PR 1
respectfully request that the project proponent go back and provide a greater level of detail and backup
information on their assessment, their conclusions, and proposed mitigations.

1. Alternative locations were not equally identified and evaluated resulting in a skewed set of
proposed sites for the new high school
2. The proposed project location is an extremely difficult site to build on and a problematic site to
operate a high school on. The benefits DO NOT outweigh the costs.
a. The vast extent of bedrock required to be blasted and removed will take at least 4 years.
There is not sufficient information presented on this activity and the required PR 2
mitigations. And the report states that the Fire Chief or designee will be coordinating
the activity. The project needs to hire a team of fulltime construction management
professionals with extensive experienced in blasting to oversee this activity and the
subcontractor. Not just one person. Expanding the radius to 500’ for pre and post
vibration/structural surveys is still not sufficient. All bordering properties must be
surveyed. There is no information regarding silica exposure. Aside from some very PR 3
basic measures silica dust control is not addressed or described. Rodent infestation is a
very real and dangerous hazard (disease vector and property damage to name a few). PR 4
No adequate level of detail was provided on this. Refuse water management was not
adequately discussed. Given the extent of bedrock there should be very detailed
information on location and size of recharge areas that will actually work and the
process for collecting and moving that water. Downhill properties have a huge exposure
to flooding with the blasting. This comment also applies to stormwater and wastewater
management. Due to the nature of the site conditions all water will end up running
downhill. The report did not contain sufficient information to ensure adequate PR 5
management of water onsite during construction.
b. Traffic from the construction will include up to an additional 250 vehicles per day and
40-70 construction vehicle trips per day. A temporary light is the proposed mitigation.
Blasting alone is expected to last for years. This is not acceptable. Once the school is
operational, an additional 1,491 trips per day is anticipated. The information presented PR 6
in the draft EIR does not address the Traffic Commission report that the area cannot
sustain this increase in vehicles and there will be extensive gridlock. This also presents a
safety concern for access and egress of emergency vehicles and first responders. In
addition to the safety concerns, the effects of noise and exhaust from construction PR 7
vehicles, particularly dump trucks, and from vehicles idling on the roadways during
school opening and closing on residents and public health in the neighborhood was also
not adequately addressed. Just stating that “reasonable efforts will be made” does not
cut it.
 c. Information on the secondary access/egress is not complete. Public safety is a critical PR 8
element in public health. As described, a firetruck cannot navigate the grade. This is a
key component of the proposed school and it was not fully presented.
3. The Draft EIR states that the Greenway will not be interrupted. How is this possible with the PR 9
proposed construction plans?
4. The Draft EIR also refers to “limited” areas of disturbance. With four years of blasting alone and
the related traffic, air quality, noise and rodent issues I truly do not agree with this statement.
This is a very large disturbance that is not fully accounted for in the Draft EIR. PR 10
 Section 8: Responses to Comments

8.7.79 Rose, Jennifer

JR 1

We should return to the original proposal of keeping the high school at its current site.

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

JR 2

Furthermore, after saying that the acreage would be plentiful for its needs, the City of Waltham has now annexed
additional open space—Jericho Hill—for parking (and without a public hearing

Jericho Hill Parcel II was never taken or dedicated as open space/conservation land.

Waltham High School | Final Environmental Impact Report 5 | p. 120

From: Jennifer Rose/Downtown Diva
To: Czepiga, Page (EEA); MEPA (EEA)
Cc: Caren Dunn; Anthony LaFauci
Subject: Waltham High School project, EEA #16097
Date: Friday, June 19, 2020 9:58:56 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Dear Ms. Czepiga:
 
I’m writing in reference to the Waltham High School project, EEA #16097.
 
I live at 35 Chester Brook Road, Waltham, less than 1,000 feet from the proposed site of the new
high school at 554 Lexington Street.
 
I strongly oppose the use of this site for the new high school. Many of the impacts it will
cause are completely unnecessary: major damage to a pristine environment; potential damage
to many nearby historic structures; noise pollution from blasting; excessive construction traffic
(and future users’ traffic) on already overburdened streets; and huge costs to blast into terrain
unsuitable for the project.
 
The process that got us to this site has been flawed. In fact, no real site evaluation was even
possible before the property was taken by eminent domain! And it’s become clearer and clearer
that the site is not a good fit for the high school campus. The police and fire departments had
never reviewed the problematic egress issues before the site was chosen. The amount of
additional traffic on Lexington Street will not only be a result of a larger school, but because of the
rerouting of all the traffic that previously came through a rear access road to the current site and
therefore never went onto Lexington Street.  

Furthermore, after saying that the acreage would be plentiful for its needs, the City of Waltham
has now annexed additional open space—Jericho Hill—for parking (and without a public
hearing).
 
For many years, the city’s Open Space Plan called for the preservation of 554 Lexington
Street. Instead, the proposed plan will utterly destroy it.
 
We should return to the original proposal of keeping the high school at its current site. If JR 1
some of the parking were moved to the 554 Lexington Street site (which already has some paved
areas), the parking area at the existing high school could be reduced and the school building
could easily fit into the property footprint, without having to cut down any of the contiguous woods
(which was strenuously opposed for numerous reasons—many of them similar to why I oppose
the use of 554 Lexington). There could even be some playing fields and offices at the 554
Lexington Street site, without having to blast or disrupt the environment there or take additional
open space.
 
I am not a BANANA (Build Absolutely Nothing Anywhere Near Anything) kind of person. In fact, I
say YIMBY (Yes, In My Back Yard) to the high school, at its current site, which is, literally, just
hundreds of feet from my house.
 
The COVID-19 pandemic has given us an opportunity to pause and reconsider trying to fit
this round peg into a square hole and to try to do something that makes much better
environmental, educational and financial sense.
 
I truly hope your office will help facilitate this so the city can have a new high school that both
serves the current generation of students as well as future students, neighbors, taxpayers, wildlife
and all those who need to inhabit our fragile planet.
 
Thank you for your consideration.
 
Sincerely,
Jennifer Rose

35 Chester Brook Road

Waltham, MA 02452
(617) 548-6330
 
Jennifer Rose
Downtown Diva
35 Chesterbrook Road
Waltham, Massachusetts 02452
(617) 548-6330
www.downtown-diva.com
www.linkedin.com/in/jenniferrose
 Section 8: Responses to Comments

8.7.80 Rose, Tammy

TR 1

I implore that you request someone on site as an environmental watchdog with daily monitoring of all activity under DEP
and MEPA purview.

This is not within MEPA jurisdiction.

TR 2

Where will the secondary emergency access road go?

The emergency access will be at Lincoln Street. The emergency access road is clarified in Section 2.4 of the
FEIR.

TR 3

Make the architects and engineers respond to the DEP request to further analyze the current High School site.

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

Waltham High School | Final Environmental Impact Report 5 | p. 121

My Letter to MEPA

Greetings All,

I grew up walking the trails of Jericho Hill with my father from the moment we moved into our
house in 1976. He led the way through the greenery when I was young, because every path
seemed unique. The topography of these mushrooms, flowers, animals, trees and rock
formations have all formed my understanding of the world. My earliest memories are of walking
with him and identifying landmarks deep in the woods: a clearing, the view of Waltham, and
rusted washing machines and other junk that my fellow citizens dumped deep into the forest
because they assumed that it was a wasteland. In recent years, citizen groups have cleaned
much of the forest and it is now well used by families and dog walkers, especially during the
recent pandemic when parks and playgrounds were closed. Henry David Thoreau was an early
influence on me and my continued walks, and I am now a playwright focusing on works based
on HDT and the Transcendentalists for the Annual Gathering of the Thoreau Society. He was
one of the first to note that the environment was being destroyed in the name of progress. It’s
ironic that the Waltham High School is literally paving paradise to put up a parking lot in the
name of education. Nature can instruct in ways not revealed by words. Construction can
happen alongside preservation. I hope that this letter will further ask the question of what we are
trying to teach both our students and our community by the irrevocable destruction of one of the
few “undeveloped” pieces of land left in Waltham.

As a lifelong resident of Waltham and a lifelong learner, I am aware of the sense of inferiority
that Waltham has always felt about its school infrastructure. Building a grand project will NOT
necessarily improve the quality of education that Waltham students receive. I am sure that you
are aware of the forward momentum that major construction projects insist upon. They steamroll
through regulations like they do trees and will do what they can to build -avoiding issues and
erasing the existing environment to suit them.

Below I have laid out a series of points that I would ask you to evaluate so that the existing
environmental concerns can be properly addressed and not ignored, as the Waltham High
School Committee and supporters are requesting.

The WHS project narrative put forth by SMMA states that it is building on approximately 31
acres of a 46.4 acre site, including 13.6 of which were previously developed, prior to taking
Jericho Hill -which now brings the total parcel to 52+ acres.

This translates to permanently altering between 10-20 acres and stripping it of all existing
vegetation, and biodiversity, reducing the available space for animals to survive and humans to
enjoy and contributing detrimentally to climate chang​e.
I’d like to bring your attention to excerpts from an NPR investigation:

"If we show you a map of tree canopy in virtually any city in America, we're also showing you a map of
income," says Jad Daley, president and CEO of the nonprofit American Forests.

That lack of tree cover can make a neighborhood hotter, and a joint investigation by NPR and the
University of Maryland's Howard Center for Investigative Journalism found just that: Low-income areas in
dozens of major U.S. cities are more likely to be hotter than their wealthier counterparts.

Beyond cooling a city's temperature down, which on its own can improve health, trees have been linked in
prior studies to myriad positive health outcomes: longer life spans, lower levels of stress, better air quality
and lower rates of cardiac disease. But Bhatnagar says those studies haven't been enough to get city
leaders to prioritize trees.

"We're trying to convince other cities that this is worth doing," says Bhatnagar. "Design cities and
neighborhoods that first think about health, not last. That should be the first consideration before you put
a single brick into a neighborhood.”

To a city that has to garner state school building reimbursement percentages based on “Poverty
Factor” and “Poverty Wealth Factors” we are creating the very situation we should be avoiding.

I implore that you request someone on site as an environmental watchdog with daily TR 1
monitoring of all activity under DEP and MEPA purview.

In a questionable political move, the Mayor of Waltham appointed Bill Hanley as the
neighborhood liaison to the school building project. He and the School committee are
determined to frame any environmental concerns as a direct assault against the high school
project.

Bill Hanley, candidate for Ward 2 Councillor in 2019 who lost to Caren Dunn, hosts a website
aimed toward moving the school forward in whatever manner he feels necessary, yet his
request to supporters to write letters (including cheat sheet below and ​attached​) shows
unpreparedness and lack of insight into the process. None of these issues have anything to do
with the location of a much-needed school. NO one disagrees with the first 7-and MEPA is not
the forum for 1-7. We are being tasked with ONLY discussing the impact of the building on
pristine woods that have NEVER been built upon.

Only points 8 and 9 have bearing with regard to this process and #10 is absolutely incorrect.

If you receive letters with the following points in them, know that they were not authored by the
people who wrote in but designed to add quantity over quality by easy cut and paste directions.
Here are the prompts:

1. This is the only opportunity for Waltham student’s, most public-school students do not have
the opportunity to attend private school or any high school other than their city’s or town’s
2. Waltham students may finally have a school comparable to surrounding towns
3. The current building has aging infrastructure (HVAC, dated classrooms, technology, etc.)
4. Too many Waltham students have missed the opportunity to attend school in a modern
building
5. Educator retention and recruitment
6. Enhancement of community and educational opportunities with a comprehensive high school
7. Local business workforce and positive impact
8. Environmental concerns were addressed, and this project should move forward immediately
9. Intermittent stream and wetlands issues were addressed by the current redesign as
requested
10. School Committee, School Building Committee, City Council all supported this project this
project with unanimous votes (this is incorrect, the truth is ​majority ​votes)

The Mayor, City Council, School Committee, School Building Committee, and Waltham Citizens
for Education will all ram this project down our throats, cheerlead for the educational aspects,
make the argument about whether you care about kids vs. the valid concerns about
environmental impacts that are real, long lasting, and devastating to the abutters.

Mayor McCarthy is certain to show up at Waltham Land Trust events for her photo op but does
she really care about the environment? What makes the trees at the Stigmatine site less worthy
of saving than the trees across the street at the current high school? Should we be aiming to
protect undeveloped acreage over previously developed parcels?

Again, please help guide the discourse to staying on the topic of the environment.

Bill Hanley’s website is misleading in its lavish praise of the WLT’s statement to MEPA as it
relates to the WHS building project.

He states:
“Today, the Waltham Land Trust publicly released a statement in support of the new design of
Waltham High School at the selected site. This is a significant step forward and I personally
thank the land trust for stating their support and for their constant efforts to improve Waltham
through conservation.”

Support the for the modern ​design​ of the HS does not mitigate the fact that the :

“WLT continues to have concerns about the overall environmental impact of adding the six
acres of the open space parcel, referred to as “Jericho II” in the DEIR, without further mitigating
measures. When WLT last addressed this issue, it was in early March 2020 as the Waltham City
Council was preparing to vote to transfer the property to the School Department. This transfer
was discussed with minimal notice to the community and largely in executive session.”

Mr. Hanley has publicly bashed council members on his robust Facebook page who have
authored a resolution aimed at protecting 6 acres of land at 554 Lexington St in an effort to
implement a no net loss scenario, claiming that measure was a “stalling tactic” —as though
advocating for the protection of open space was a crime against children.

Please continue to stay focused on the environment, not the cheerleader efforts to foster the
appearance of full support. A lot of the neighborhood has NO IDEA of the impact or even what
is being considered-Facebook is not a universal medium. Trust me, they do not have full
support, though most people are afraid to say otherwise due to fear of reprisals. Waltham is a
city but it is also a small town.

Where will the secondary emergency access road go? It has been moved on maps several TR 2
times over the past year. Perhaps you haven’t seen these maps because the School Building
Committee doesn’t want you to know the road is not determined yet. All of the options below
present difficult conditions for increased traffic flow, even if minor. The main entrance would be
exacerbating the existing traffic nightmare (Lexington St/Totten Pond Rd/128), the secondary
road will be sought out for use by those wanting to avoid the main entrance.

Options presented that DON’T WORK

● Easement out from 588 Lexington to Lexington Street (Doesn’t solve problem of traffic and
distinct ingress/egress to another part of the school building)
● Jericho Hill Road through Sanderson Heights (protected parcel, road would have to be
impervious, difficult to maintain in winter)
● Onto Lincoln Street near Gregory St. (blind corner)
● End of Trimount Street through Jericho Hill - (Private way at the top of a winding residential
neighborhood)
● Lincoln Ext (private way) The latest attempt and the homeowners on this street haven’t even
been contacted by the city to negotiate or even discuss the usage of a road they own.

Public input process that DOESN’T WORK

“High School Building Committee (SBC) meetings continue to be held periodically to review
progress of submissions and design updates and are well attended by the community. SBC
meetings are public meetings and adhere to Open Meeting Laws. Since Governor Baker’s
March 12, 2020 Executive Order, these public meetings have occurred virtually via online video
conferencing. At the start of each meeting the SBC opens the floor to the public, giving abutters
and community members an opportunity to express appreciation, concern, and pose questions
to the SBC.”
On the surface, this seems to be an amicable attempt to involve the public. I have witnessed
public objections being read into the record and then ignored. In fact, please see attached rules
of engagement created by Hanley designed to stifle opposition by pitting the school against the
environment. Who is going to attend these meetings for real results if merely given 1 minute to
ask questions and express concerns only to have the inquiries ignored? Who is going to come
to these meetings bi-weekly to express “praise” for the project? Then only people who will show
up will be the ones that the SBC doesn’t want to see coming…… those against the land
destruction and disruption when other suitable and level locations have been rejected.

Please continue to advocate for walking, hiking and biking. If we aim to instill in children respect
and concern for the environment— and teach it in schools, then let’s put our money where our
mouth is and lead by example. Encourage usage of the existing nature trails behind the school
and connect the Western Greenway that was started by visionaries in the early 90’s.
Encourage bike use instead of closing down a bike lane to make room for the inevitable traffic
expected from such an ill-conceived project location.

Make the architects and engineers respond to the DEP request to further analyze the current TR 3
High School site. You will note that it has been ignored by the report before you.

I’m going to close with something I will admittedly claim as off-topic, yet still pertinent to the
larger project: The astronomical and unprecedented cost of building a school on a granite hill.
Enough said.

Tammy Rose
 Section 8: Responses to Comments

8.7.81 Roy, Jennifer

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 122

 Section 8: Responses to Comments

8.7.82 Schadelbauer, Margaret

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 123

From: margaret j. schadelbauer
To: Czepiga, Page (EEA)
Subject: EEA#16097
Date: Friday, June 19, 2020 5:02:58 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
I am concerned re: construction traffic, asbestos dispersal & blasting @ 554 Lexington St 
I am a Lexington St Resident 
Thank you 
Margaret Schadelbauer 
501 Lexington St #5

Sent from Yahoo Mail for iPhone

 Section 8: Responses to Comments

8.7.83 Seminara, Pat

PS 1

Why have we moved this building several times at 554?

The project team reviews the optimal location for the building on the site during the early design process.

PS 2

What sort of precautions are taken for the neighbors against that sound pollution?

What about the quality of life of those that surround the school?

The actual noise from blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to mitigate
debris, dust and noise. Consigli also plans to use water misters, water trucks, and automatic wheel wash
stations to minimize dust. Finally, Consigli plans to use sound blankets at the perimeter fence strategically
placed to mitigate noise to the adjacent neighbors.

Waltham High School | Final Environmental Impact Report 5 | p. 124

 From: jpnmom@aol.com
To: Czepiga, Page (EEA)
Subject: WHS
Date: Friday, June 19, 2020 4:17:41 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.



let me start by saying Waltham NEEDS a new High School, they have needed it for many
years.

 As a longtime resident of Waltham, I believe a project as large and as polarizing as this High School
Building project should have been put to a city-wide vote. Then we could have been involved in the Q&A and
merits/shortfalls of each proposed property. Shouldn’t we have a say in how our environment is handled? 
This is the last chance to appeal to the Commonwealth to look after its citizens.  We’ve been ignored locally.
 

I’m over 70.  When I bought my house 44 years ago, it was because of the quiet nature of my dead end
street. I bought my home with the bonus of living near a high school.  I raised 3 boys and they all attended
WHS.  They also ran to Leary field. And Brandeis in the winter. We didn’t worry about how far away the
fields were- kids were encouraged to walk or ride bikes where they needed to go.  Now, they need to have a
college-like campus in the middle of a residential neighborhood? Complete with lights and loud speakers.

I am opposed 554 Lexington for both logistical and ecological reasons.

Choosing to build the High School on the Stigmatine land was “cart before the horse”.  First we took the
land, then tried to shoe horn a school onto that land.  When it wasn’t enough that the builders wanted to
REROUTE a stream (!!) they then took Jericho Hill, land we’ve been enjoying for almost 2 decades, with
absolutely no public  input.  
Why have we moved this building several times at 554?  The property is 52+ acres with the taking of Jericho PS 1
Hill and yet the whole school and parking lot is squished up in the southwest corner.  
Why is there opposition to a no net loss to the land taken?  The Waltham Citizens for Education PAC are
concerned that the request to set aside 6 acres of wetlands for a permanent conservation restriction,  is a
tactic to “stall the school project” ? Why such disdain for the environment? The very environment they want
to place their children. 

You almost have to consider following this process a second job! The system has been designed to make it
hard for people to follow what is going on in their own neighborhood.  Responding to this process meant
reading a 1000-page document.  Not many people will invest that amount of time and energy. 
Some residents are intimidated and afraid of reprisals. 
  
I am sure that the majority of citizens in waltham are unaware of the impacts of selecting this site.  Some of
which are: 

The traffic -all of the in/out movement of vehicles will be solely on Lexington St. vs.  the current HS where
40% of cars enter/exit onto Forest St. 

The pollution- 70 trucks daily creeping downtime main streets of Waltham, with tons of crushed rock. 
Carbon released in the air, dust and dirt.  

The construction noise:  the nature of the location forces the builders to crush rock on site before transport.  PS 2
What sort of precautions are taken for the neighbors against that sound pollution? 

Ongoing noise:  What about the quality of life of those that surround the school ? They will be subject to PS 2
screaming fans, loudspeakers, cars at all hours of the day/night, parents idling while dropping off students
and children at the daycare center and more. 
Loss in home value:  this area was once quiet, beautiful and serene, and included open space.  But I guess
they  don’t  “ care”  because it isn’t their neighborhood. The “ woods” are completely decimated, an area that
was once a great place to hike.......someone who had lived in Waltham their entire lives came to visit and
commented that they didn’t know such a peaceful serene area existed in Waltham! 

I resent that the general public wasn’t allowed to participate in the decision making process.   Instead we are
only facing impending impacts.  Please reconsider this destructive location. 
From: Pat Seminara
To: Czepiga, Page (EEA)
Subject: I am so sorry
Date: Friday, June 19, 2020 7:35:37 PM

CAUTION: This email originated from a sender outside of the  Commonwealth of Massachusetts mail system.  Do
not click on links or open attachments unless you recognize the sender and know the content is safe.

I sent you an email and I forgot to sign it! Pat seminara.....the WHS project...
 Section 8: Responses to Comments

8.7.84 Sharpe, Valerie

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 125

 Section 8: Responses to Comments

8.7.85 Simpson, Kathleen

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 126

 Section 8: Responses to Comments

8.7.86 Stein, Nadene

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 127

 Section 8: Responses to Comments

8.7.87 Sumner, Larry (George)

LS 1

adding additional acreage in the form of Jericho Hill Conservation land

Jericho Hill Parcel II was never taken or dedicated as open space/conservation land.

LS 2

How will this be addressed? There is no adequate hydrological study showing a solution to blasting below the water table.

A supplemental subsurface exploration program to aid in the bedrock cut design is currently underway. The
program is comprised of test borings, geophysical testing, laboratory testing, down-the-hole packer testing, and
aquifer pumping tests. Rock core samples collected from test borings and geophysical testing are used to
identify bedrock fracture and joint location and orientation. Down-the-hole packer testing is performed to
evaluate the response of the fractures to injection of water under pressure. That information is used to better
understand the permeability of the rock under a variety of pressures, and evaluate the ability to inject fluids into
the rock fractures. The aquifer pumping tests will allow a better understanding anticipated groundwater inflow
rates to the underdrain system, and expected volume of water exiting the rock face. Down-the-hole packer
testing and pump testing will be performed after the test borings are drilled and the boreholes are flushed. The
test borings are anticipated to be completed by the end of August 2020, and the down-the-hole packer and
pump testing program to be complete by mid-September 2020. Refer to section 3.2.3 in the FEIR for a
discussion on flooding and groundwater.

LS 3

Is the system put forth by SMMA sufficient to manage the runoff on site?

Surface run off due to topography has been noted by the abutters as occurring historically. The Project will
comply with applicable MassDEP Stormwater Management Standards for quality and treatment and includes not
exceeding pre-development discharge rates for the design storms. During the construction period, a Storm
Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout construction to
monitor and modify temporary control measures as required.

LS 4 & LS5

How will we replace 10-15 acres of trees??

How to plant trees in ground that is all ledge?

The Project includes landscaping, the location of those trees and shrubs will be contingent upon the depth of
soils.

LS 6

Much more analysis in an EIR is necessary to determine whether PFAS chemicals may be present in the turf and if so, what
the impacts would be.

As of the date of this document, Massachusetts does not have required test methods and specifications for test
and regulating solid materials, such as synthetic turf. The Project has committed to meeting other available
standards. Refer to section 3.3 of the FEIR for further information on testing and regulations.

Waltham High School | Final Environmental Impact Report 5 | p. 128

 Section 8: Responses to Comments

LS 7

None of the documents submitted include the drainage system under the field. This is close to a 4 acre area turf field
collecting water at the top of a hill- where will it flow?

The draining detail plans are under development. There will be drainage under the field.

LS 8

SMMA vaguely claims mitigation measures will be taken but they don’t say what they are, nor how the issues will be tested,
monitored and reported. We should be requesting an independent peer review (not city employee) of all of the technical
data as well as someone to be on site daily to monitor the mitigation measures for violations.

This is not within MEPA Jurisdiction.

LS 9

… an independent environmental expert should be part of the project to ensure compliance with wetland boundaries,
unnecessary clear cutting, air quality, maintaining the integrity of the historic stone walls on the property, and other
controllable concerns.

This is not within MEPA Jurisdiction.

Waltham High School | Final Environmental Impact Report 5 | p. 129

From: Larry Sumner
To: Czepiga, Page (EEA)
Subject: Proposed High School Construction
Date: Friday, June 19, 2020 6:07:15 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
I’m concerned about the project for the following reasons. 

DEP requested further analysis of the 617 Lexington Street option for building but rather than comply, SMMA
focused only on adding additional acreage in the form of Jericho Hill Conservation land.  I would suggest that they
be forced to reconsider the cost /benefit of building on already flat land.  The land at 554 Lexington Street can be
the site for an alternate educational purpose with a smaller floor area ratio and still meet the requirements of
educational usage. 

Alternate sites didn’t require blasting 747 CY of ledge, site prep costs, and 450 car parking garage,  could be
saving the city roughly $100 MIL.  The garage alone equates to $100,000 per space for a grand total there of $45
million. 

Yet not a cent of it is contributing to the education of the teens of Waltham.  In fact, school system operating
budgets were just cut by $3MIL last week by a vote of City Council.  

One of the primary reasons for the fervor of building a school on 554 Lexington St. was to implement the full
master plan.  This was determined before any engineering, feasibility or analysis of topography and ledge, only to
find that it can’t be achieved.  Does the community realize placing the high school at 554 does not allow the
master plan? No football field, No tennis courts, No track, No baseball field, No expansion, which was one of the
major criteria given for the selection of 554 Lexington St. The concept of the MASTER PLAN has been morphed
and modified to fit the situation. Options that were untenable 4 years ago are now completely acceptable when
push came to shove. 

I feel like now we are at desperation level:  Implement a bike lane on Lexington Street and take it away to make
more room for cars.  Need more space to build a monster school because the land you took by eminent domain
isn’t suitable for a 4 acre building? Take conservation land.  Still not enough room?  Spread the building and
roadways into the wetland buffer zone.  No decent secondary access road location?  Leave it off the map and tell
the community that it’s not necessary.  Police and fire say you need a secondary access road?  Draw it on the
map over a private street without consulting the neighbors or abutters.  When will this pattern stop?  

What happens when we are in over our heads on the costs for this project?  The Mayor has promised not to go
back to the city for more money.  We don’t yet know what the impending impact will be to our taxes and I can
already foresee the request for more funds because, well, it’s for the kids.  

Specifically, these MWRA concerns have not been addressed. 

How the blasted rock wall will affect the water table
The ENF states that because of the site’s topography, rock cuts will be below
groundwater levels in several areas, which will cause groundwater to flow from and exit the site.
Conditions have not changed here. How will this be addressed? There is no adequate hydrological study showing a solution LS 1
to blasting below the water table.

Groundwater is an important component of the site’s overall hydrology, and the ENF does not indicate what impact
this loss of groundwater will have or acknowledge the important  connection between groundwater and the stream and
wetlands on the site.

Minimum compliance
This is particularly concerning because the City has indicated that it will only comply with groundwater recharge
requirements to the maximum extent practicable; it will not fully comply with recharge requirements. 

Continual blasting and vibrations over a year’s time could have a grave negative impact on the watershed and may result in
runoff to all the streets and homes downhill. This could insurance claims against the city- a side effect unknown today but
unplanned for right now.

Ground water sourced from a property will must be contained on said property. Is the system put forth by SMMA sufficient LS 2
to manage the runoff on site?

The groundwater discharge may actually end up forming an intermittent stream in the natural grade and interfering
with proposed roads and paths. Impacts to groundwater and any associated impacts to surface waters should be fully
evaluated in an EIR.

How will we replace 10-15 acres of trees?? LS 3

The City should avoid cutting down as many trees (especially mature trees) as possible. Mitigation of tree removal
should be required onsite and there should be no net loss of trees
from the site – any trees removed should be replaced with trees along proposed roadways and in proposed landscaped
areas to help mitigate temperature impacts. Mature trees should be replaced on a 2 to 1 basis. While the benefits of
new young trees will not be the same as the mature trees removed, it will be a start. 

The extraordinary environmental impact and carbon foot print caused by the project including greenhouse gas
emissions and failure to use sustainable energy as part of the project cannot be made up with saplings.  A 3 inch
diameter tree isn’t adequate to replace a 40 ft. tree in terms of the ability to take pollution out of the air, the same
air the children of Waltham will be breathing in.  

So the question remains.  How to plant trees in ground that is all ledge?  
LS 3

Runoff from turf field- built at the top of a hill, making its way to Chester Brook and the Charles River.
Runoff from the turf field is particularly concerning because toxic PFAS chemicals have been found in artificial turf. 
PFAS chemicals are known to cause serious health problems, including cancer.   If PFAS chemicals are present in the
turf, students using the field will be exposed, and if PFAS chemicals enter stormwater runoff from the field,
downstream communities and waters will also be at risk. 

Waltham Citizens for Education PAC and Facebook group care so much about this project that they are satisfied with
spending any amount necessary to build the most expensive state of the art school in the country- but then allow their children
to play sports on a field that could one day kill them.

Much more analysis in an EIR is necessary to determine whether PFAS chemicals may be present in the turf and if so, LS 4
what the impacts would be. 

Some groundwater recharge is expected to occur through an area of porous pavement. and subsurface infiltration
systems; however, because this is a redevelopment project, the City states that it will only comply with groundwater
recharge requirements to the maximum extent practicable and will not fully comply with recharge requirements.
Porous pavement has since been removed from the site plan and therefore is no longer a mitigation measure. None of the LS 5
documents submitted include the drainage system under the field. This is close to a 4 acre area turf field collecting water at
the top of a hill- where will it flow?

These are just a few of the long term effects of building on virgin land: 

The damage to the ecosystem, wildlife displacement, homeless animals and rodents spreading into surrounding
neighborhood and threatening pets. 

Noise pollution from demolition, blasting, rock crushing, construction and the ongoing noise of an amplified audio
playing field. 

Wetlands damage, dust, water runoff,  blasting dust and vibrations.  

Traffic burdens on Lexington Street, Totten Pond Road and the State Highways. 
Incremental damage to streets from thousands of 18 wheeler trips each carrying 
30,000 pounds of crushed rock. 

SMMA vaguely claims mitigation measures will be taken but they don’t say what they are, nor how the issues will
LS 6
be tested, monitored and reported.  We should be requesting an independent peer review (not city employee) of
all of the technical data as well as someone to be on site daily to monitor the mitigation measures for violations. 

In addition, an independent environmental expert should be part of the project to ensure compliance with wetland LS 7
boundaries, unnecessary clear cutting, air quality, maintaining the integrity of the historic stone walls on the
property, and other controllable concerns. 

Thank you for taking the time to read this letter.  Sincerely,
 Section 8: Responses to Comments

8.7.88 Telenar, Kaj

KT 1

The Jericho Hill neighborhood should have a bike/walking path to the high school. There are several possible routes. This
would reduce traffic on Lexington Street and increase safety for the student population.

There should be a bike/walking path for the Piety corner community. This will also reduce traffic on Lexington Street and
increase safety for the student population.

A bicycle parking area should be built close to the school and covered with solar panels. This will increase the desirability of
riding bicycles, scooters, and motorcycles, which will help Waltham reduce its carbon footprint, while reducing traffic
congestion.

The City and Traffic Engineer believe the shared bike lane is the safest approach for bicyclists along this
corridor. A portion of the route is currently shared so it is extending a current practice. Bicycle detection will be
added to the traffic signal design to aid in activating the lights and additional signage for the bike lane will be
added along the corridor. The project is installing new crosswalks on Lexington Street at the site which will aid
pedestrian safety.

There are no plans to create a bike path from the Jericho Hill neighborhood. The existing trails through this
parcel will be maintained as much as possible.

Bicycle parking will be provided at the high school for 30 bicycles. A solar canopy is not being proposed.

KT 2

The blasting will increase asthma rates for children in the area, and increase radon in the air. More thought should be given
for mitigation.

Radon mitigation is included within the project.

KT 3

We should be trying to reduce car use by students, so no parking lot should be made available for students, unless they
want to park in the old high school parking lot and walk the remaining 2-3 blocks to school.

The parking program is 650 spaces. The existing high school will not be for HS students in the future.

KT 4

I want to be sure that a commitment is made to preserve the woods as much as possible.

The Project will only remove what is needed for construction, safety, and/or tree health.

Waltham High School | Final Environmental Impact Report 5 | p. 130

From: Kaj Telenar
To: Czepiga, Page (EEA)
Subject: Waltham High School EEA#16097 - DEIR Submission
Date: Friday, June 19, 2020 4:40:40 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
I have several issues with the current plans for the high school. 

The Jericho Hill neighborhood should have a bike/walking path to the high school. There are KT 1
several possible routes. This would reduce traffic on Lexington Street and increase safety for
the student population. 

There should be a bike/walking path for the Piety corner community. This will also reduce KT 1
traffic on Lexington Street and increase safety for the student population. 

A bicycle parking area should be built close to the school and covered with solar panels. This KT 1
will increase the desirability of riding bicycles, scooters, and motorcycles, which will help
Waltham reduce its carbon footprint, while reducing traffic congestion. 

The blasting will increase asthma rates for children in the area, and increase radon in the air. KT 2
More thought should be given for mitigation. 

Because the entire hill is connected through the bedrock, foundations all over the hill could be
affected. 

We should be trying to reduce car use by students, so no parking lot should be made available KT 3
for students, unless they want to park in the old high school parking lot and walk the
remaining 2-3 blocks to school. 

There are many animals, such as deer, fox, and turkeys living in the woods. The remaining KT 4
connection between the lower part of the woods and the upper part of the woods is looking
increasingly narrow, and may be problematic for the larger animals. I want to be sure that a
commitment is made to preserve the woods as much as possible. 

Kaj Telenar
13 Larchmont Ave
Waltham, MA 02451

--
A safe and stable climate is possible.
It's up to us. Let's organize.
350mass.betterfutureproject.org
 Section 8: Responses to Comments

8.7.89 Thibodeau, Kristen

KT h 1

Jericho Hill was previously preserved under Article 97.

Jericho Hill Parcel II was never taken or dedicated as open space/conservation land.

Waltham High School | Final Environmental Impact Report 5 | p. 131

Kristen Thibodeau
12 Sachem St
Waltham, MA 02451

June 19, 2020

Re: Waltham High School, EEA 16097

Greetings,
I would like to take this time to ask you that you please not allow the building of
the new Waltham High School at 554 Lexington Street. I am 100% in favor of a new
high school. I went to school in Waltham and have 3 children in the public schools
now. The city is not providing what it promised to provide if the land was taken by
eminent domain. They had 46 acres that were taken and we were promised a
campus and that could not happen. Then the city decided to take the 6 acres from
Jericho Hill, still not providing a campus and now will have to blast even more ledge.
Jericho Hill was previously preserved under article 97. According to Article 97-
“The people shall have the right to clean air and water, freedom from excessive and
unnecessary noise, and the natural, scenic, historic, and esthetic qualities of their
environment; and the protection of the people in their right to conservation,
development and utilization of the agricultural, mineral, forest, water air and other
natural resources is hereby declared to be a public purpose.” –Article 97 of the
Massachusetts Constitution. Taking this land for a four story under ground parking
garage and artificial turf field is not appropriate according to this article.
Jericho Hill has no wetlands or endangered animals so the city decided in
executive sessions to take this land? Not one single neighborhood meeting ever
happened. There are numerous homes that closely abut this land. Remember, the
city promised that they would produce a campus for the students of Waltham if they
had the 46 acres, they cannot even produce a campus with 52 acres.
The Department of Environmental Protection suggested that the site of the current
high school be revisited for a new high school in the correspondence dated
November 26, 2019. The city simply does not want to hear this. What is it going to
take to realize the negative impact building this high school on this site will have not
just on the environment but on the abutting neighbors?

Respectfully,
Kristen Thibodeau
 Section 8: Responses to Comments

8.7.90 Urquhart, Alex

AU 1

I request industry standard monitoring by independent third parties to mitigate the dust, dirt, pollution, noise, vibration,
traffic, parking, deliveries and any other environmentally problematic items occur.

The project will comply with applicable laws and regulations regarding testing and monitoring for dust, noise and
air quality. There are multiple activities which will include third party testing – Asbestos abatement will include
clean air testing; Blasting will include vibration monitoring; rodent control is being provided and monitored
weekly. Noise monitoring will occur to confirm compliance with Waltham noise ordinance.

AU 2

Request mitigation measures as the area as 554 is in an entirely residential neighborhood.

Mitigation measures are included within the project scope. Refer to Section 7 of the FEIR for a comprehensive
list.

AU 3

They have total disregard from the wetland proposing one of these walls of ledge almost on top of the wetland

The wall is not on top of the wetland.

Waltham High School | Final Environmental Impact Report 5 | p. 132

From: ALEX URQUHART
To: Czepiga, Page (EEA)
Subject: EEA #16097
Date: Thursday, June 18, 2020 9:29:54 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
June 18, 2020

Waltham High School Building Project

EEA #16097

Dear Page Czepiga,

I am writing in regards to the property located at 554 Lexington Street Waltham, MA.
This property is under consideration for the new high school. My home directly abuts
this property. I have many environmental concerns.

First, I want you to know that this parcel is mostly undeveloped and is home to many
forms of wildlife large and small. This parcel has been listed on the open space plan
in Waltham for years. Reduction in habitat and clear cutting this wooded parcel will
negatively impact the environment. Stripping vegetation will contribute to further
erosion and water run-off, which is already an issue. The trees have a positive impact
on environment with better air quality. Leveling the considerable ledge will cause
unnecessary damage to abutting home foundations. This is the historic section of
Waltham and mine like others have fieldstone foundations. The amount of blasting is
truly severe. This project is environmentally damaging and insensitive to the abutters,
the neighbors and all the citizens of Waltham. I request industry standard monitoring AU 1
by independent third parties to mitigate the dust, dirt, pollution, noise, vibration, traffic,
parking, deliveries and any other environmentally problematic items occur.  Request AU 2
mitigation measures as the area as 554 is in an entirely residential neighborhood. 

Another, huge concern is the blasting and removal of rock, dirt and gravel on already
gridlocked Lexington Street. Up to 70 truckloads a day. This will essentially be a
quarry operation in a residential neighborhood. The traffic engineer report advised
against building the school at this location due to the high traffic volume. This traffic
will only be worse will idling cars waiting to turn onto the property and contribute a
greater amount of greenhouse gases and further contribute to climate change.

Lastly, the proposed building plans are so flawed. Carving into the hill and making 5,
7 and 10 story high walls of ledge is dangerous and negatively impact the
environment and neighborhood. They have total disregard from the wetland
proposing one of these walls of ledge almost on top of the wetlands. The Waltham
Conservation Commission issues an enforcement order to clean up the wetlands and
there has been no action. It just seems like they don’t care about the environment.

Sincerely,

Alex Urquhart
 Section 8: Responses to Comments

8.7.91 Urquhart, Laura

This letter is identical to Alex Urquhart

LU 1

I request industry standard monitoring by independent third parties to mitigate the dust, dirt, pollution, noise, vibration,
traffic, parking, deliveries and any other environmentally problematic items occur.

The Project will comply with applicable laws and regulations regarding testing and monitoring for dust, noise and
air quality. There are multiple activities which will include third party testing; for instance, asbestos abatement
will include clean air testing; blasting will include vibration monitoring; rodent control is being provided and
monitored weekly. Noise monitoring will occur to confirm compliance with Waltham noise ordinance.

LU 2

Request mitigation measures as the area as 554 is in an entirely residential neighborhood.

Mitigation measures are included within the project scope. Refer to Section 7 of the FEIR for a comprehensive
list.

LU 3

They have total disregard from the wetland proposing one of these walls of ledge almost on top of the wetland

The wall is not on top of the wetland.

Waltham High School | Final Environmental Impact Report 5 | p. 133

June 17, 2020
Waltham High School Building Project
EEA #16097

Dear Page Czepiga,

I am writing in regards to the property located at 554 Lexington Street Waltham,

MA. This property is under consideration for the new high school. My home
directly abuts this property. I have many environmental concerns.
First, I want you to know that this parcel is mostly undeveloped and is home to
many forms of wildlife large and small. On a daily basis I see woodland rabbits,
many song birds, hawks circling overhead, and the nightly bat patrol. Other
frequent wildlife is turkeys, foxes, coyotes, deer, owls, opossums, and even a bald
eagle. This parcel has been listed on the open space plan in Waltham for years.
Vernal pools positively impact our environment as well as plant life such as the
beautiful Lady Slipper. Reduction in habitat and clear cutting this wooded parcel
will negatively impact the environment. Stripping vegetation will contribute to
further erosion and water run-off, which is already an issue. The trees have a
positive impact on environment with better air quality. Leveling the considerable
ledge will cause unnecessary damage to abutting home foundations. This is the
historic section of Waltham and mine like others have fieldstone foundations.
Environmentally damaging and insensitive to the abutters, the neighbors and all
the citizens of Waltham. I request industry standard monitoring by independent LU 1
third parties to mitigate the dust, dirt, pollution, noise, vibration, traffic, parking,
deliveries and any other environmentally problematic items occur. Request LU 2
mitigation measures as the area as 554 is in an entirely residential neighborhood.
Another, huge concern is the blasting and removal of 900,00 cubic yards of rock,
dirt and gravel on already gridlocked Lexington Street. This will essentially be a
quarry operation in a residential neighborhood. The traffic engineer report
advised against building the school at this location due to the high traffic volume.
This traffic will only be worse will idling cars waiting to turn onto the property and
contribute a greater amount of greenhouse gases and further contribute to
climate change.
Lastly, the proposed building plans are so flawed. Carving into the hill and making
5, 7 and 10 story high walls of ledge is dangerous and negatively impact the
environment and neighborhood. They have total disregard from the wetland
proposing one of these walls of ledge almost on top of the wetlands. Attached is a
short video from December 2019, which illustrates the natural streams that flow
from the wetlands into the neighborhoods. There has been very little public input
and concerns have been dismissed as without foundation. The video clearly
shows water flowing naturally. I greatly appreciate your time and consideration.

Sincerely,
Laura Urquhart, MSN, RN, APRN-BC
 Section 8: Responses to Comments

8.7.92 WalkBoston MassBike

WB MB 1

We implore you to rethink the decisions to a.) remove bike lanes on Lexington Street and b.) raise the speed limit on
Lexington Street without other traffic calming measures

The City and Traffic Engineer believe the shared bike lane is the safest approach for bicyclists along this
corridor. A portion of the route is currently shared so it is extending a current practice. Bicycle detection will be
added to the traffic signal design to aid in activating the lights and additional signage for the bike lane will be
added along the corridor. The project is installing new crosswalks on Lexington Street at the site which will aid
pedestrian safety.

The City is not raising the speed limit on Lexington Street. This was a misinterpretation of the Traffic report.

WB MB 2

The City should consider expansion of the 20mph School Zone on Lexington Street to include all three schools, or through
creating a 20mph “Safety Zone,” which was established in 2016 under Mass General Law Chapter 90, Section 18B.

The City will take this under advisement.

Waltham High School | Final Environmental Impact Report 5 | p. 134

June 19, 2020

Secretary of Energy and Environmental Affairs Kathleen Theoharides

Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office, Page Strysky
100 Cambridge Street, Suite 900
Boston MA 02114

Dear Secretary Theoharides,

Thank you for the opportunity to comment on the Waltham High School Project ​#16097 for Waltham
High School located at 554 Lexington Street in Waltham, MA​. WalkBoston and the Massachusetts
Bicycle Coalition (MassBike) would like to submit the following comments based on our reading of
the DEIR as submitted on May 15, 2020.

Though we appreciate the work involved in relocating and constructing a new high school which will
have significant impacts for the City of Waltham for generations to come, our primary concerns arise
from the fact that unless the site is designed so that motor vehicle trips are replaced by safe and
sustainable modes of walking and biking to and from school, this project will unacceptably increase
the amount of expected car and bus traffic coming to and from the site on a daily basis and will have
dramatic impacts to worsen the congestion on Lexington Street and increase greenhouse gas
emissions.

We implore you to rethink the decisions to a.) remove bike lanes on Lexington Street and b.) WB MB
raise the speed limit on Lexington Street without other traffic calming measures.​ As we shared 1
previously in our letter dated November 26, 2019, the TMP noted that the Waltham Police
Department identified speeding “as a significant issue” on Lexington Street. However, when a speed
study was conducted for the high school project, the 85th percentile speed recorded was 41mph,
leading to a new design speed set at 45mph. This does not mitigate the existing problem of speeding
drivers on Lexington Street, but instead legitimizes it. The purpose of this project should ​not​ be to
maximize vehicle speed and throughput. On the contrary, the goal must be to create a ​safe​ access
to the new high school for all modes and ages, especially the most vulnerable on foot and on bike.

The DEIR states:

“It is not possible to accommodate an exclusive bike lane through this portion of Lexington
Street without taking private land along the right-of-way, which the Project will not pursue.”

This is a misleading statement, and this project is only not accommodating exclusive bike lanes due
to the ​addition​ of vehicle turning lanes. We are extremely concerned that adding turn lanes to
“mitigate delays” will reduce safety of people who are walking and biking to the site. The DEIR also
makes statements of “smooth flow,” “to ease traffic congestion,” “improve travel time reliability within
a corridor, and reduce congestion,” but makes ​no​ mention of safety of students, staff, and faculty

1
who are walking or biking to school. Instead, the DEIR is proposing “shared lanes” on Lexington
Street, essentially a “sharrow” which does nothing to separate bicyclists from fast moving traffic. We
believe forcing high school students to ride in “shared lanes” on Lexington Street is a dangerous
option.

In contrast to “mitigating delays” of traffic, the roads around a community school should be safe for
residents to get around, whether by walking, cycling, using transit, or in a vehicle. That safety and
comfort is impacted by the design of our streets and intersections. All existing elementary schools in
Waltham currently participate in the Massachusetts Safe Routes to School Program, which
encourages students and their parents to walk and bike to school, something they hopefully would
continue through high school. Yet we are not confident this roadway design allows for safe bicycling
and walking, especially for students, staff, and faculty coming to the school early in the morning.
Please take a moment to ask yourself:​ Would you want a 14-year old student riding a bike at
6:50am in a “shared” lane, or crossing a multi-lane road that has a design speed of 45mph?

Many students walking to and from school will have to cross Lexington Street, with a design speed of
45 mph, which obviously is not consistent with safe crossing by pedestrians. Yet Lexington Street
has the opportunity to see more students walking and bicycling to school in the years to come: a
proposed new K-8 public school may occupy the site of the existing high school. With additional
vulnerable road users in this area, it is important to ensure that anyone driving on Lexington Street is
doing it at a safe speed, and that safe and comfortable facilities are provided for vulnerable users.
The City should consider expansion of the 20mph School Zone on Lexington Street to include all WB MB
three schools, or through creating a 20mph “Safety Zone,” which was established in 2016 under 2
Mass General Law Chapter 90, Section 18B.

The DIER does mention the placement of bike racks for 5% of the building occupants, though
without detail if these will be protected or covered or otherwise secure, and building occupancy can
be up to 1,830 students, teachers, and staff, plus 600 field spectators. We see no analysis of trips
being taken to and from the site by people on foot or on bike, only that dedicated bike lanes outside
the entrances and exits will be ​removed,​ and crosswalks and ADA accessibility will be studied
further. This omission is telling that this project goes completely against the goals of Safe Routes to
Schools, and the mode-shift goals that Massachusetts is attempting to pursue. This project, as
described in the DEIR, will be a detriment to the sustainable and safety goals that are so essential to
mitigate dangers of traffic and the climate crisis, and goes against our goals for Safe Routes to
Schools. We feel that the City of Waltham should be constructing a school that facilitates and
exemplifies safety and sustainability for their students, staff, and faculty.

Thank you,

Brendan Kearney, Deputy Director, WalkBoston

Galen Mook, Executive Director, MassBike

2
 Section 8: Responses to Comments

8.7.93 Waltham Delegation

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 135

6/8/20

Secretary of Energy and Environmental Affairs

Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office
Page Czepiga, EEA No. 16097
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Waltham High School Project – Draft Environmental Impact Report (EEA#16097)

To Whom It May Concern:

We write to lend our full support for the Waltham High School (WHS) Project’s Draft Environmental
Impact Report. This project has changed since the Environmental Notification Form (ENF) submission
and these changes have resulted in no impact to the intermittent stream and wetland resource areas in
question. Moreover, this project represents a momentous opportunity for the City of Waltham to deliver
the high quality, rigorous, 21st century education which will prepare our students for the continuously
evolving world of work and future studies. The current WHS has outlived its useful life; no longer
meeting the educational standards of our students and risking the loss of NEASC accreditation unless
significant progress is made on a new facility.

After receiving the Environmental Notification Form (ENF) Certificate from the Secretary of Energy and
Environmental Affairs on December 6, 2019, the City sought alternatives to address concerns raised by
the Secretary to mitigate impacts on the environment, specifically the planned location of the playing field
and underground parking facility. An additional 6-acre, city-owned parcel (Jericho Parcel ll) was
identified as an alternative, one that could potentially address the Secretary’s concerns and keep the
project’s timeline on schedule. As such, the Jericho II Parcel has been transferred by the City Council to
the School Department. Not only will the Jericho Parcel II avoid any altering of the Bordering Vegetated
Wetland (BVW) and relocating of the stream, it allows the School Department to accommodate the
overall building program for approximately 1,830 high school students.

The proposed WHS enjoys overwhelming support from all corners of our city, earning endorsements
from the School Building Committee (SBC), School Committee (SC), School Department (WPS), Mayor,
and City Council. Since August 2015, dozens of community meetings have been held on the design and
construction of a new high school. After an exhaustive review process gathered tremendous community
feedback, the SBC and SC both recommended relocating the WHS to the Stigmatine property (554
Lexington Street). This site will allow WPS to deliver on the full WHS master plan.

With a scope and budget of 374.6 million, the proposed WHS is one of the largest and most ambitious
capital projects the City has ever embarked upon. The project is on track to receive significant funds from
the MSB, helping to reduce the burden of local taxpayers to finance the entire costs associated with
building the new facility. With the latest estimates putting the completion of the new WHS in September
2024, and as construction costs continue to soar, MEPA approval is desperately needed so that this
project can stay on-time and on-budget

Waltham is a diverse and growing community with approximately 500 newly enrolled students this fall
alone. Our students deserve every educational opportunity to prepare them for the ever-changing world
they will enter after graduation. Thus, we respectfully request for MEPA to approve the WHS project’s
DEIR.

Thank you for your time and consideration on this matter. Please do not hesitate to contact our offices
with any questions you may have.

Sincerely,

John J. Lawn, Jr.

Rep. Thomas M. Stanley Rep. John J. Lawn, Jr. Sen. Michael J. Barrett
9th Middlesex 10th Middlesex Third Middlesex
 Section 8: Responses to Comments

8.7.94 Waltham Historical Commission

WHC 1

In this sense, it has not been previously "cleared" with the Waltham Historical Commission. There appear to be historic
colonial stone walls in the vicinity of the project, and the effect of the revised project on these walls has not been discussed
with the commission.

There are no stone walls within the 6 – acre parcel, please refer to the existing conditions plan C101. Stone walls
for the boundary (property line) between Jericho Hill Parcel II and Sanderson Heights. Those walls will remain.

Waltham High School | Final Environmental Impact Report 5 | p. 136

From: WHC
To: Czepiga, Page (EEA)
Cc: Lyons, Pamela; ezmsi@rcn.com
Subject: EEA#16097 Waltham High School - Public Comment on DEIR
Date: Friday, June 12, 2020 11:15:24 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Public Comment on:
 
Draft Environmental Impact Report:  Waltham High School,  EEA#16097
 
From:   Mort Isaacson, Chair Waltham Historical Commission
            Waltham, MA
            WHC@city.waltham.ma.us
 
To:       Page Czepiga, EEA No. 16097
            MEPA Office
            100 Cambridg Street, 9th floor
            Boston, MA 02114
            page.czepiga@mass.gov
           
Dear M. Czepiga,
 
I am the chair of the Waltham Historical Commission and I have been requested by the
commission to send you this comment on the DEIR for the new Waltham High School.  In the
DEIR under Section 12.1.10 Historical and Archaeological Resources there is the statement
"The project has been cleared of historic preservation review locally and with the
Massachusetts Historical Commission."  At least as this statement pertains to "locally", the
statement appears to be incorrect. The Waltham Historical Commission was not previously
given an opportunity to comment on the revised project as presented in the DEIR, including
the Jericho II parcel.  In this sense, it has not been previously "cleared" with the Waltham
Historical Commission.  There appear to be historic colonial stone walls in the vicinity of the WHC 1
project, and the effect of the revised project on these walls has not been discussed with the
commission.
 
Thank you for your consideration,
 
Mort Isaacson, Chair

Waltham Historical Commission

www.city.waltham.ma.us/historical-commission
Waltham Historical Commission
Arthur Clark Government Center
119 School Street
Waltham, MA 02452
 Section 8: Responses to Comments

8.7.95 Waltham Land Trust

WLT 1

WLT would encourage that MEPA require this step, in the spirit of Article 97’s “no net loss” requirements.

This is not within MEPA Jurisdiction. The City is considering options for a conservation restriction.

Waltham High School | Final Environmental Impact Report 5 | p. 137

 June 17, 2020

Via Email Only

Page Czepiga, Assistant Director

Massachusetts Environmental Policy Act Office
100 Cambridge Street, 9th Floor, Boston, MA 02114
page.czepiga@mass.gov
Waltham Land Trust, Inc.
P.O. Box 541120
Waltham, MA 02454-1120
Re: Waltham High School EEA#16097 – DEIR Submission
www.walthamlandtrust.org
781-893-3355 Dear Assistant Director Czepiga:
A non-profit organization
dedicated to preserving In accordance with 301 CMR 11.08, the Waltham Land Trust (WLT) writes to
our community’s natural submit the organization’s comments to the Draft Environmental Impact Report
resources through open
space advocacy, education, (DEIR) concerning the plans for the Waltham High School dated May 15, 2020. 1
acquisition, and protection. After carefully reviewing the DEIR, WLT is pleased to see that efforts have been
made to further reduce the amount of land developed and the overall
Board of Directors
environmental impact of the project.
Nadene Stein, PhD, President
Maureen Bagge Fowler, Vice-
President Specifically, WLT would like to acknowledge the following measures which it
Anna Richardson, Clerk views as positive aspects of the new preferred alternative plans:
Marc Rudnick, Treasurer
Martha Creedon
Marie Daly
• Elimination of wetland alterations and alterations to the intermittent
George Darcy, III stream
John Dieckmann • Reduced total acreage of altered land
Natalie Hayes
• Reduced total number of parking spaces
Barbara Jacobs
Brian McCormick • Reduced total impervious surfaces
Daniel Melnechuk
Diana Young WLT has generally supported the location of the High School at 554 Lexington
Street throughout this process. This was in large part because the organization
Advisory Board
recognizes both the unique and urgent need for a new high school, and because it
Kate Buttolph became clear as more information emerged over the past several years that this
Dr. Laura Goldin
land was at high risk of being sold to a private developer – an outcome which
Dr. Eric Olson
Stephen Rourke could have had an even more detrimental environmental impact. WLT also
Michael Squillante supports the City’s desire to repurpose the existing high school to meet other
Mike Tabaczynski educational infrastructure needs so that further development of Waltham’s open
Douglas Waybright
space can be prevented.
Roger Wrubel

Executive Director WLT continues to have concerns about the overall environmental impact of
adding the six acres of the open space parcel, referred to as “Jericho II” in the
Sonja Wadman
DEIR, without further mitigating measures. When WLT last addressed this issue,
it was in early March 2020 as the Waltham City Council was preparing to vote to
Protecting
Waltham’s land
…forever. 1 Please note that the Waltham Land Trust Board includes a City Councillor, a member of the
Waltham Historical Commission, and a member of the School Building Committee. These
individuals recused themselves from the discussion and development of this response.
transfer the property to the School Department. This transfer was discussed with minimal notice to the
community and largely in executive session.

Because City Solicitor Cervone has named WLT specifically in his April 27, 2020 Memorandum
regarding whether Article 97 applies to the Jericho II parcel, we feel compelled to address that issue
briefly here.

Both Article 97 of the Massachusetts Declaration of Rights and MGL c. 30 § 61 recognize that negative
environmental impacts of development in a community also negatively impact the people who live
there. This is especially true with regard to those members of the community who are marginalized or
have the fewest resources and thus more acutely feel the effects of environmental damage, whether it
comes in the form of losing access to safe public woodlands and green space and their attendant
benefits, or bearing the brunt of the negative consequences of climate change.

For these reasons Massachusetts has chosen to give its residents rights, under the Commonwealth’s
Constitution, to the quality of life that clean water and open space provide. Accordingly, the law requires
the use of all practicable means and measures to minimize damage to the environment in projects such
as this one. Article 97’s “no net loss” policy also requires that when one parcel of open space is
developed it is replaced by protecting other land in the community of equal conservation value.

Reasonable minds can differ regarding the interpretation of Smith v. City of Westfield, 478 Mass. 49
(2017), and whether Article 97 protection applies to the Jericho II parcel. There are many reasons that
WLT has suggested in good faith that this is the case – including, but not limited to, the City holding the
property out as protected open space to the public, the public using it continuously for that purpose since
its acquisition, and the inclusion of the parcel as protected open space in a whole host of City plans upon
which it relies for many different purposes, including grant applications. Indeed, in the Project Narrative
of the Environmental Notification Form (ENF) for the high school itself, section 2, page 1, SMMA
states “[t]he building is proposed to be sited in the southwestern quadrant of the property, adjacent to the
Jericho Hill conservation land, such that the footprint of development may be optimized, and open
space preserved… (emphasis added).”

In light of the above, WLT was disheartened to see that the DEIR reflects no plans to permanently
preserve six acres of open space of similar conservation value in exchange for the Jericho II parcel. WLT WLT 1
would encourage that MEPA require this step, in the spirit of Article 97’s “no net loss” requirements. If
development of the Jericho II parcel is truly essential to the high school moving forward, those
mitigating measures are the right thing to do, even if there may be a difference of opinion as to what is
strictly legally required. The law sets a floor but not a ceiling in this regard.

After careful consideration, however, WLT ultimately believes the appropriate manner to address the
majority of its concerns is outside the MEPA review process. While we wholeheartedly reject Attorney
Cervone’s characterization of the organization’s position – particularly as by his definition the majority
of Waltham’s open space is entirely vulnerable to development – WLT intends to make its case to the
Waltham community directly, rather than in this forum.

There are many reasons WLT has reached this conclusion. To say we find ourselves in a different world
now than we were at the beginning of March is at best a massive understatement. WLT recognizes that

Page 2 of 3
our community is feeling exhausted, hurt, isolated, and divided. Yet another protracted disagreement
about the land involved with this project, in addition to all the other serious issues Waltham currently
faces, is simply not in our community’s or WLT membership’s overall best interests. WLT also
recognizes that with state and local budgetary constraints expected to result from the pandemic the need
to move this project forward has grown ever more urgent.

This is a time when unity must carry the day. We hope that all parties involved will likewise commit to
finding a more harmonious way forward. This is not about choosing between supporting conservation or
kids. WLT is working every day towards the same goal as the City and other proponents of this project:
a better future for Waltham’s children.

Sincerely,

Anna Richardson, Clerk

Page 3 of 3
 Section 8: Responses to Comments

8.7.96 Weinstein, Rachel (4 of 4)

RW 1

After this COVID-19 financial wipe out, is there money for a $400,000,000 high school as well as sustained day to day
learning? The tax payers of Waltham are waiting for a fiscal update from the city

This is not within MEPA jurisdiction.

RW 2

How will the dust, noise, blasting affect children and adults' health?

How will it affect neighbors' health living near a massive 4-year construction site being destroyed by jackhammers,
pavement breakers, pile drivers, rock drills and blasting?

The actual noise from blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to mitigate
debris, dust and noise. Consigli also plans to use water misters, water trucks, and automatic wheel wash
stations to minimize dust. Finally, Consigli plans to use sound blankets at the perimeter fence strategically
placed to mitigate noise to the adjacent neighbors.

RW 3

Has the second exit accessibility been fact checked? Is there ten feet for emergency vehicles to enter/exit? Is it truly
accessible

The Access road is a 20ft right-of way. This has been confirmed and acceptable for emergency vehicles. The
emergency access road is further clarified in section 2.4 of the FEIR.

RW 4

How much will the fence cost and with kids being kids what will stop them from cutting holes in the fence to not have to
walk from the field to the exit back to North Waltham?

The cost of the fencing is included in the project budget. The school department is responsible for maintaining
the fence including fixing any holes.

RW 5

The city did not share their latest traffic study with the neighbors

All Traffic Studies are posted on the project website, they are included in MSBA submission.

RW 6

What will happen to the nature wildlife displaced by the 46 acres being destroyed?

46 acres are not being destroyed. Please refer to the NPC/DEIR for land alteration.

Waltham High School | Final Environmental Impact Report 5 | p. 138

 Section 8: Responses to Comments

RW 7

Why isn't flat land being considered to save the state and city $100,000,000 in construction costs and decimation of natural
land? Why has the city not garnered a cost of cleaning up the Fernald?

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

RW 8

Who are the neighbors supposed to call if the contractor does not follow the rules such as moving construction trucks in
and out during rush hour and idling?

Responsible parties for receipt of complaint will vary depending upon the complaint:

Blasting Complaints – Fire Department

Noise complaints – Police Department

Blasting damage complaints – Consigli (CM) will provide a Point of Contact

All other complaints – Inspector of Buildings

RW 9

10.7 - SMMA says they will clearly communicate a blasting schedule with neighbors. This hasn't been done to this point
how will it be done in the future.? What method will SMMA use?

The project team is still evaluating the extent of the blasting on the site and has not finalized the 500-foot blast
radius map at this time. The map below drafted by Haley & Aldridge geotechnical engineers is being refined. This
draft was presented at the SBC Meeting on August 10, 2020. Once finalized, it will be posted on the project
website, reviewed publicly at the SBC meeting, and shared with those within the 500-foot radius via mail. The
map is included in Section 6.3 of the FEIR.

The blasting notification procedures were described in Section 10.1.5 of the NPC/DEIR and clarified in Section
6.3 of the FEIR. The initial contact is typically performed via conventional mail and if contact is unsuccessful;
certified mail will be utilized. Pre-blast condition surveys intended to commence by the beginning of November
or sooner and be completed within a 4-6 week timeframe.

RW 10

13.3.4 says they will put sidewalks. What about sidewalks on Lincoln, Curve and safe walking all the way down Lexington?
Crossing Lincoln and Lexington is a death trap. Will Waltham have money for crossing guards, snow cleaning and other
safety measures after the $400,000,000 is spent on the high school

The City is currently examining sidewalks on Lincoln Street. These off-site improvements are not part of the
project scope.

RW 11

13.7.8 says greenway will not be interrupted. How is that possible?

The Western Greenway is not within 554 Lexington Street.

Waltham High School | Final Environmental Impact Report 5 | p. 139

 Section 8: Responses to Comments

RW 12

13.8.1 - says the project will have no health impact. How is that possible with dust, blasting, massive construction project?

Construction projects while inconvenient for abutters are not inherently unhealthy.

RW 13

Will the noise of construction violate noise ordinances?

No.

RW 14

Once the school is built will noise from the field loudspeakers and lights violate ordinances?

This is under development and not part within MEPA jurisdiction.

RW 15

Is this site violating open space usage?

No.

RW 16

I request a Massachusetts public health official to consult with the project to ensure that neighborhood health is not
impacted by blasting, dust, vibration, noise, light, change in environment and topology

This is not within MEPA Jurisdiction.

RW 17

I would like Preservation Mass, Historic New England Headquarters, Mass Historical Commission and National Trust to
confirm there will be no damage done to historical homes steps from the blasting

This is not within MEPA Jurisdiction.

RW 18

Since the master plan no longer fits, I request the city reexamines sites the provide minimal ecological impact and leave 554
as open space, environmental learning space.

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

RW 19

I am concerned there was no public input in taking of Jericho Hill. This was set aside to conservation land and will now be a
parking lot and synthetic field

Jericho Hill Parcel II was never taken or dedicated as open space/conservation land.

Waltham High School | Final Environmental Impact Report 5 | p. 140

 Section 8: Responses to Comments

RW 20

I ask that the Fernald be part of a feasibility study. I would like a cost/benefit analysis of building the new high school on
the Fernald site to guide data driven decisions to ensure tax payers the city has made a financially responsible decision in
spending $100,000,000 to blast 554 Lexington street.

Alternatives presented in the ENF and NPC/DEIR were evaluated and dismissed.

RW 21

How safe are students with a fence circling the HS? Are there other examples of school enclosed by a fence? Have they had
safety issues?

The fence will provide safety where grade changes occur, the abutters also requested fencing to prevent
students accessing their private properties.

RW 22

What is the impact of the water runoff?

Surface run off due to topography has been noted by the abutters as occurring historically. The Project will
comply with applicable MassDEP Stormwater Management Standards for quality and treatment and includes not
exceeding pre-development discharge rates for the design storms. During the construction period, a Storm
Water Pollution Prevention Plan (SWPPP) will be implemented and maintained throughout construction to
monitor and modify temporary control measures as required.

RW 23

How will run off carcinogen from the field affect our health if it gets into our water, backyards, etc.?

As of the date of this document, Massachusetts does not have required test methods and specifications for test
and regulating solid materials, such as synthetic turf. The Project has committed to meeting other available
standards. Refer to section 3.3 of the FEIR for further information on testing and regulations.

RW 24

How will blasting a mountain, one of the highest points in Waltham, affect my house, which is in the lowest part of
Waltham

A pre-blast condition survey will be available. The initial contact is typically performed via conventional mail and
if contact is unsuccessful; certified mail will be utilized. Pre-blast condition surveys intended to commence by
the beginning of November or sooner and be completed within a 4-6 week timeframe.

Waltham High School | Final Environmental Impact Report 5 | p. 141

From: Rachel Weinstein
To: Czepiga, Page (EEA)
Subject: Re: Waltham High School EEA#16097 - DEIR Submission
Date: Thursday, June 4, 2020 7:21:42 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Here is the link documenting the request from the Attorney General by Bill Fowler, former Ward
2 counselor for concealed public meeting minutes and letter from the city refusing to
share. https://docs.digital.mass.gov/dataset/open-meeting-law-pending-complaints-attorney-
general%E2%80%99s-division-open-government/resource#{}

Thank you and I look forward to a post analysis of abutter's concerns and comments. 

Rachel Weinstein
cell: 978.590.0877 - text, Whatsapp
Land Line: 781.893.1636

https://www.linkedin.com/in/rachel-weinstein-msw-med-4134a21/

From: Czepiga, Page (ENV) <page.czepiga@state.ma.us>

Sent: Wednesday, June 3, 2020 4:11 PM
To: Rachel Weinstein <rachel_weinstein@hotmail.com>
Subject: RE: Waltham High School EEA#16097 - DEIR Submission

Rachel,
I’m writing to confirm receipt of the below comment letter. I’ll reach out with any questions and will
also include it in the project record.
Take care,
Page

Page Czepiga | Assistant Director

Massachusetts Environmental Policy Act Office
100 Cambridge Street, 9th Floor, Boston, MA 02114

From: Rachel Weinstein <rachel_weinstein@hotmail.com>

Sent: Wednesday, June 3, 2020 3:24 PM
To: Viola, John D. (DEP) <john.d.viola@mass.gov>; Worrall, Eric (DEP) <eric.worrall@mass.gov>;
Freed, Rachel (DEP) <rachel.freed@mass.gov>; Lally, Kyle (DEP) <Kyle.Lally@mass.gov>; Czepiga,
Page (EEA) <page.czepiga@mass.gov>; Boccadoro, Helena (DEP) <helena.boccadoro@mass.gov>;
Viola, John D. (DEP) <john.d.viola@mass.gov>; brona.simon@state.ma.us
<brona.simon@sec.state.ma.us>; mhc@sec.state.ma.us
From: Rachel Weinstein
To: Czepiga, Page (EEA)
Subject: Re: Waltham High School EEA#16097 - DEIR Submission
Date: Thursday, June 4, 2020 9:29:26 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.

VIA EMAIL: Czepiga, Page (ENV) page.czepiga@state.ma.us  

Kathleen A. Theoharides
The Secretary of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attention: MEPA Office
                                                                                            
Re: EEA #16097 Waltham High Project
Location: 554 Lexington Street, Waltham MA
 Attention: Page Czepiga,

I read the close to 1000 pages of documents submitted for the environmental review.  Here are
my thoughts as a neighbor at 78 Lincoln Street Waltham. 

A significant number of Massachusetts towns are building their new high schools adjacent
to their current site.  A shiny new building will not change a city's educational core values
and delivery of education.  There needs to be dollar for dollar investment in teacher
training, materials, after school enrichment, etc. After this COVID-19 financial wipe out, is
there money for a $400,000,000 high school as well as sustained day to day learning?  The RW 1
tax payers of Waltham are waiting for a fiscal update from the city. 
The city of Waltham offers no public health data on how this construction project will RW 2
affect the neighbor's health such as asthma, and cancer rates. How will the dust, noise,
blasting affect children and adults' health?  The mantra in Waltham is to build the school
for the children but it is these same children, my children, who will be breathing in all the
dust, suffering from the construction noise, breathing in the exhaust from the construction
trucks.  How will it affect neighbors' health living near a massive 4-year construction site
being destroyed by jackhammers, pavement breakers, pile drivers, rock drills and blasting?  
There is documented evidence showing a direct correlation between viruses and
deforestation. Seeing how COVID-19 has upended our lives, building at 554 Lexington
would additionally contribute to this mess we are in right now.   If we truly want to fight
climate change and eliminate greenhouse gasses then choose another flat available space to
build; there is plenty of space behind the current HS.  The Stigmatine site does not fit the
original plan due to wetlands, so a smaller space may now be considered.  The land was
taken by eminent domain before proper analysis.  
If we continue destroying green space, and can't contain the coronavirus, we will need to
shelter in place indefinitely then there will be no reason for schools, we will all be
working/learning from home.  
I think it is pure irony that the city is destroying acres of green space to build a Green
certified building.  
Has the second exit accessibility been fact checked?  Is there ten feet for emergency RW 3
vehicles to enter/exit?  Is it truly accessible?  At this point, we have documented proof
firetrucks cannot climb the egress. 
What is the distance from the field to the exit?  How much will the fence cost and with kids RW 4
being kids what will stop them from cutting holes in the fence to not have to walk from the
field to the exit back to North Waltham? 
Now that the new high school must be fenced in, we must think about how safe we feel
having children enclosed if there is a fire or other emergency situation and only one
egress.  
With the $400,000,000 being spent on this project, will there be money left for
sustainability, teachers' salaries, consumables and upkeep?  With Black Lives Matters voices
being heard, will Waltham have the money to buy updated curriculum to create an
equitable learning environment - recruit teachers of all backgrounds, diversify the
curriculum, train staff in education equity? 
There has been no communication from the city of Waltham on how much taxes will go up
and how much this project will impact individual homeowners and businesses.  We can see
with our own eyes and pockets the devastation of COVID-19 on our personal and
communal economy.  Is a $400,000,000 high school and destruction of nature the best
choice right now? Why aren't we considering a school that blends into nature rather than
destroys it?  Why haven't the architects presented a plan the blends with the elevation
rather than destroys it? 
There are bike racks added into the master plan but bike lanes are either non-existent or
being eliminated from the streets of Waltham. The traffic commissioner has put in writing
that traffic will increase up to 50%, gridlock will be expected.  He documented the existing
street cannot accommodate all this new traffic.  It is a death trap now.  I can't imagine the
traffic with the on-going construction, removal of an infinity amount of dirt and only one
exit and entrance. 
Waltham is a traffic nightmare.  There are NO traffic calming and abatement measures in
place. I have spoken at multiple traffic commission meetings and have been waved off. 
The police tell me Waltham is staffed at 1980 levels.  Waltham does not have the human
power to change batteries in traffic radars.  Waltham REFUSES to put in traffic calming
measures when parents have requested them.  The new high school is being built in a
neighborhood without sidewalks, crosswalks nor traffic lights.  The city did not share their RW 5
latest traffic study with the neighbors.  The city either tells me there is no traffic problem or
they will solve it and there is no follow up.  
The report says that construction trucks will be making 40 - 70 trips a day.  I can't imagine
how all that will happen, driving by my house between 8:15 - 2, 3 - 4:30.  
What will happen to the nature wildlife displaced by the 46 acres being destroyed?  RW 6
I have emailed close to ten people to get the cost of cleaning up the Fernald.  Not one
person has neither responded nor given me a dollar amount.  How can we as tax paying
citizens know that our tax dollars are being spent ethically and consciously without a dollar
amount to compare it to.  Why isn't flat land being considered to save the state and city RW 7
$100,000,000 in construction costs and decimation of natural land?  Why has the city not
garnered a cost of cleaning up the Fernald? 
Table 2.2. should read city wide meetings as these meetings were held before the Stigmatine
site was chosen. City wide meetings should not be confused with neighborhood meetings.  
Who are the neighbors supposed to call if the contractor does not follow the rules such as RW 8
moving construction trucks in and out during rush hour and idling?  
Alongside my neighbors, I am concerned about 
 blasting, 
the 100' wall, 
wildlife displacement, 
rodents, 
wetlands, 
storm water management, 
water runoff, 
loss of open space, 
loss of trees, 
 reckless spending, 
noise, 
vibration, 
water, 
destruction to my home

Waltham is notorious for closed door meeting.  The former Ward 2 counselor filed a
motion with the Massachusetts to unseal minutes from a closed-door meeting. We, as
neighbors, are still waiting on these minutes.  The city refused to release them as there were
pending law suits.  The law suits have been resolved.  Where are the minutes?  Why are
public meetings being held behind closed doors and what was said?  There has been such a
lack of transparency during this process. 
10.7 - SMMA says they will clearly communicate a blasting schedule with neighbors.  This RW 9
hasn't been done to this point how will it be done in the future.? What method will SSMA
use?  Neighbors questions and concerns have been completely ignored to this point, so it is
hard to trust SMMA going forward. 
12.3 - the historical society said there will be no damage to historical houses.  That's just
ridiculous.  They are feet away from blasting. 
13.2.6 states there will be no long-term ecological impact.  That is just a complete
scam.  How can blasting a mountain and removing all those trees have no
ecological impact?  
13.3.4 says they will put sidewalks.  What about sidewalks on Lincoln, Curve and safe RW 10
walking all the way down Lexington? Crossing Lincoln and Lexington is a death trap. Will
Waltham have money for crossing guards, snow cleaning and other safety measures after
the $400,000,000 is spent on the high school? 
13.7.8 says greenway will not be interrupted.  How is that possible?  RW 11
13.8.1 - says the project will have no health impact.  How is that possible with dust, RW 12
blasting, massive construction project? 
13.14.1 Talks about limited areas of disturbances.  Seriously?  The area is massive. 

Thank you for the opportunity to respond, 

Rachel Weinstein
cell: 978.590.0877 - text, Whatsapp
Land Line: 781.893.1636

https://www.linkedin.com/in/rachel-weinstein-msw-med-4134a21/
From: Rachel Weinstein
To: Viola, John D. (DEP); Worrall, Eric (DEP); Freed, Rachel (DEP); Lally, Kyle (DEP); Czepiga, Page (EEA);
Boccadoro, Helena (DEP); Viola, John D. (DEP); brona.simon@state.ma.us; mhc@sec.state.ma.us
Subject: 17 Addendums to MEPA for Waltham High School EEA#16097 - DEIR Submission
Date: Tuesday, June 16, 2020 2:10:29 PM
Attachments: Mold-Weinstein-Waltham-Basement.pdf

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Dear MEPA, 

Given the time we had to respond to the DEIR, I have been able to dig even deeper into the
environmental report and wish to express further concerns: 

1 - Will the noise of construction violate noise ordinances?   RW 13

2 - Once the school is built will noise from the field loudspeakers and lights violate ordinances?   RW 14
3 - Is this site violating open space usage? .  RW 15
4 - I request a Massachusetts public health official to consult with the project to ensure that RW 16
neighborhood health is not impacted by blasting, dust, vibration, noise, light, change in
environment and topology.  I am worried about respiratory issues, asthma, cancer rates and other
health consequences of living near a massive construction site. 
5 - I would like Preservation Mass, Historic New England Headquarters, Mass Historical RW 17
Commission and National Trust to confirm there will be no damage done to historical homes
steps from the blasting.  The Waltham historical commission is composed of individuals
appointed by the mayor so they will rubber stamp her projects. This project needs state level
checks and balances.  
6 - 554 Lexington was taken - prior to any testing - by eminent domain to fit a master educational
plan.  Now that the site has been tested, the master plan does not fit; sound, financially
accountable leadership would then explore other locations where the same school can be built
without such ecological destruction.  Since the master plan no longer fits, I request the city RW 18
reexamines sites the provide minimal ecological impact and leave 554 as open space,
environmental learning space. 
7 - I am concerned there was no public input in taking of Jericho Hill.  This was set aside to
conservation land and will now be a parking lot and synthetic field.   
8 - I ask that the Fernald be part of a feasibility study .  I would like a cost/benefit analysis of RW 19
building the new high school on the Fernald site to guide data driven decisions to ensure tax
payers the city has made a financially responsible decision in spending $100,000,000 to blast 554
Lexington street..  
9- How safe are students with a fence circling the HS? Are there other examples of school RW 20
enclosed by a fence?  Have they had safety issues?  
1 0 - What is the impact of the water runoff? RW 21
11 - How will run off carcinogen from the field affect our health if it gets into our water, RW 22
backyards, etc. ? 
12 - How will blasting a mountain, one of the highest points in Waltham, affect my house, which RW 23
is in the lowest part of Waltham.  I attached photos of the mold growth in my basement as well as
the mold report.  This mold which will cost $3000 to remove is caused by living in one of the
lowest 
13 - I would like to speak to the quality of life brought on by this construction project - abutters
are losing sleep, feeling anxiety and high stress.  We are worried about losing the value of our
houses, the emotional toll of losing the greenery in our backyard, financial stress, living in a four
+ -year traffic jam, being unheard during the process.    
14 - I would like to see the plan of how the greenway will not be disturbed. 
15 - I would like a clear-cut plan on how blasting will be executed and clearly communicated to
neighbors. 
16 - Finally, I request further studies done by someone other than the construction company who
have enormous financial skin in the game to have a third-party check and balance on
disturbances, and potential long-term ecological impact. 

PLEASE NOTE A CRITICAL UPDATE IN THIS PROJECT: The mayor nominated a political
supporter as neighborhood liaison.  He used his social media platforms to encourage parents to
use the MEPA report to advocate for educational reform in Waltham not analyze the long-term
environmental impacts of this project.  If you get inundated with parents saying they want a new
school so their children can get an education, this is pushed by the neighborhood liaison.  We all
want our children learning in a state-of-the-art high school; we just want sound financial and
environmental decisions made.  PLEASE NOTE: the neighborhood liaison lives in the
neighborhood, is pro this project, uses social media to harass those that express legitimate data
driven environmental, financial, or health concerns about the project and responds to legitimate
concerns with threatening emails.  This appointee is symbolic of the malfeasance abutters have
been observing throughout this project. 

Thank you so much for the opportunity to dig deeper into the environmental report.  I look
forward to hearing next steps.  

Rachel Weinstein
78 Lincoln Street Waltham
cell: 978.590.0877 - text, Whatsapp
Land Line: 781.893.1636

https://www.linkedin.com/in/rachel-weinstein-msw-med-4134a21/

From: Czepiga, Page (ENV) <page.czepiga@state.ma.us>

Sent: Wednesday, June 3, 2020 4:11 PM
To: Rachel Weinstein <rachel_weinstein@hotmail.com>
Subject: RE: Waltham High School EEA#16097 - DEIR Submission

Rachel,
I’m writing to confirm receipt of the below comment letter. I’ll reach out with any questions and will
also include it in the project record.
Take care,
Page

Page Czepiga | Assistant Director

Massachusetts Environmental Policy Act Office
100 Cambridge Street, 9th Floor, Boston, MA 02114

From: Rachel Weinstein <rachel_weinstein@hotmail.com>

From: Rachel Weinstein
To: pbrasco@brascofuneralhome.com; kmcmenimen@city.waltham.ma.us; pobrien@city.waltham.ma.us; Stanley,
Thomas - Rep. (HOU); rleblanc@city.waltham.ma.us; cvidal@city.waltham.ma.us; alafauci@city.waltham.ma.us;
Dunn, Caren; councilw3@city.waltham.ma.us; jmclaughlin@city.waltham.ma.us; jlacava@city.waltham.ma.us;
sdurkee@city.waltham.ma.us; kmackin@city.waltham.ma.us; charris@city.waltham.ma.us;
jpaz@city.waltham.ma.us; Mayor; George Frost; Liz AlJammal; margaretdonnelly@walthampublicschools.org;
johnfrassica@walthampublicschools.org; janegately@walthampublicschools.org;
stephenrando@walthampublicschools.org; edmundtarallo@walthampublicschools.org; Kim, Tori (EEA); Czepiga,
Page (EEA); MA-IGO-General-Mail@state.ma.us; IGO-FightFraud@state.ma.us; Email Correspondence (AGO)
Subject: ABUSE OF POWER BY WALTHAM NEIGHBORHOOD LIAISON
Date: Wednesday, June 17, 2020 1:59:36 PM
Attachments: WHS comments to MEPA.pdf
Hanley Screen shot.png
6-8-20 Neighborhood Liaison.pdf

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
1 -I am very concerned that Bill Hanley is abusing his appointed volunteer position by directing
people to send comments to the Massachusetts Environmental Protection Agency. that have
NOTHING to do with the environment but about the educational needs of Waltham students. 
2 - Bill Hanley created a lobbying website where he advises people to click on a link which will
bring them to MEPA.  THE LINK DOES NOT!!!! It brings them to another link which lists his
lobbyist comments.  This is disturbing misrepresentation, seems downright ILLEGAL and
highly deceptive.  https://walthamma.wixsite.com/walthamhigh
3- Bill Hanley started a NEW FB page where he retitled himself COMMUNITY LIAISON. The
Mayor's attached government document she named him neighborhood liaison.  His FB page
already has close to 600 people.  Bill is representing himself as having all the answers when I have
not seen him at the SBC/SC meetings that I attended. 
 https://www.facebook.com/groups/whscommunityliaison/  Also, is Facebook the best page to
share government information?  Not everyone has a FB account.  
4 - Having read the 1000-page MEPA report, I asked Mr. Hanley to meet with me and the
neighbors to go over my list of concerns.  He refused to meet with me either individually or in a
small group (at least 'til Phase 3), but his personal FB page shows him in a large group without
masks.  https://www.facebook.com/bill.hanley

I DEMAND a new neighborhood liaison as of immediately!  This $400,000,000

construction project deserves better than this! 

Rachel Weinstein
78 Lincoln 
cell: 978.590.0877 - text, Whatsapp
Land Line: 781.893.1636

https://www.linkedin.com/in/rachel-weinstein-msw-med-4134a21/
 Section 8: Responses to Comments

8.7.97 Weitz, Donna

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 142

 Section 8: Responses to Comments

8.7.98 Westner, David (2 of 2)

DW 1

But I feel now is the time to address the noise concerns for the Waltham high school and parking garage/playing field site
before it is too late and too costly to do anything about it.

The actual noise from blasting during shot hole drilling is similar to typical construction site noise, with
occasional louder but very short duration peaks at the immediate moment of blast shot ignition. Technical
provisions for Controlled Blasting will require the Contractor to comply with the rules and regulations of the
Commonwealth of Massachusetts 527 CMR 13.00 – Board of Fire Prevention Regulations for Explosives and
City of Waltham Fire Department (WFD) Regulations. On site rock crushing will be mitigated with earth berms or
other sound barriers. Per the WFD, double matting will be utilized during all blasting operations to mitigate
debris, dust and noise. Consigli also plans to use water misters, water trucks, and automatic wheel wash
stations to minimize dust. Finally, Consigli plans to use sound blankets at the perimeter fence strategically
placed to mitigate noise to the adjacent neighbors.

The permanent systems of the High School are being designed to comply with the local Noise Ordinance.
Playing fields are exempt from the ordinance.

Waltham High School | Final Environmental Impact Report 5 | p. 143

From: dave westner
To: Czepiga, Page (EEA)
Subject: Re: EEA # 16097 - Waltham High School Project
Date: Tuesday, June 2, 2020 8:56:13 AM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Hi Page, thanks for getting back to me.
Yes, I would like to re-submit.  Can I do that just by responding to this email, or do I need to do
something else?
I would also like to quickly reiterate that a new site inspection is being requested and I am hopeful
that the comment period will be extended due to the Convid-19 crisis.  I know that during this
shutdown, a lot of local residents have been distracted by all the terrible news of the crisis and likely
have not had the bandwidth to pay close attention to this matter, even though the city has been
rushing forward with their plans.  I had made mention of this issue on a local message board, and
several of the responses were along the lines of, "you can't be seriously talking about this issue
NOW?"
My requests are not just comments but a sincere attempt to maintain the integrity and prudence of
the process by having these two important factors addressed by the Secretary before the comment
period expires.
Thank you
David Westner

On Tue, Jun 2, 2020 at 7:38 AM Czepiga, Page (ENV) <page.czepiga@state.ma.us> wrote:

Dave,

Thanks for reaching out. I intended to reach back out to you to let you know that the project wasn’t
under review when we received your original comments on 5/18. The Waltham High School DEIR was
published in the Environmental Monitor on 5/20 which commenced the public comment period.

Now that the project is officially under review, would you like to re-submit your comments for the
official project record?

Thanks,

Page

Page Czepiga | Assistant Director

Massachusetts Environmental Policy Act Office

100 Cambridge Street, 9th Floor, Boston, MA 02114

From: dave westner <davidwestner@gmail.com>

Sent: Monday, June 1, 2020 2:49 PM
From: dave westner
To: Czepiga, Page (EEA)
Subject: EEA # 16097 - Waltham High School Project
Date: Monday, May 18, 2020 3:33:44 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
May 18, 2020

VIA EMAIL: Czepiga, Page (ENV) page.czepiga@state.ma.us

Kathleen A. Theoharides

The Secretary of Energy and Environmental Affairs

100 Cambridge Street, Suite 900

Boston, MA 02114

Attention: MEPA Office

                                                                                                 
Re: EEA #16097 Waltham High Project
Location: 554 Lexington Street, Waltham MA

Attention: Page Czepiga,

As an abutter, resident and citizen of North Waltham, Massachusetts, who resides with my
wife 40 feet from the proposed new parking garage that will be blasted into Jericho Hill,  I am
writing to express my dire continuing concern about the proposed new Waltham High School
at 554 Lexington Street and the now expanded site including 131R Lincoln Street in Waltham. I
have previously commented on the Environmental Notification Form submitted by the City of
Waltham.

Since the December 6, 2019, Certificate of The Secretary of Energy And Environmental Affairs
On The Environmental Notification Form Decision issued, SMMA, the architect for the project
has set about devising a new Preferred Alternate Option scheme with substantial and dramatic
changes impacting the environment involving the addition of an additional 6+ acre parcel of
open space to the site resulting in a new site area totaling 52+ acres. Attached to this email are
recent project updates by SMMA covering the expanded and revised Preferred Alternate
Option. I call your attention to page 22 of the 5/11/2020 update entitled DEIR Schedule which
indicates that on Friday May 15, 2020, SMMA intends to submit the DEIR and a Notice of
Project Change to the Secretary of EEA and the MEPA office.

I also call to your attention to pages 5 and 7 of the 3/23/2020 Project Update, pages 5 and 6 of 
the 4/13/2020 Project Update and pages 4, 6, 8-12 of the 5/6/2020 Project Update which spell
out the major changes proposed. The specific changes I call your attention to are as follows:

1. The addition of the Jericho Hill parcel at 131 R Lincoln Street, a 6 + acre parcel of
city owned open space which with the 554 Lexington Street parcel forms the new 52+
acre Preferred Alternate Option. The parcel is shown on pages 4, 6, 8 – 13 of the
5/6/2020 Project Update. The parcel is also  listed on page 37 of the City of Waltham
Open Space and Recreation Plan I 2015-2022 which abuts the 26.26-acre Sanderson
Heights, Lincoln Woods open space also listed on page 37.

2. The relocation of the proposed 450 Car parking garage and multipurpose field
onto a portion of the 6+acre Jericho Hill Parcel requiring the blasting of 750,000 cu.
yds. of ledge and the creation of a 105 ft. high blast wall estimated to be 1,800 ± ft.
long as shown on pages, 8 -13 of the 5/6/2020 Project Update to within 40 feet of the
nearest abutting residential property and to within 10 ft. of the Sanderson Heights
parcel. This garage is being built 40 feet from the edge of my property line.

3. The relocation of the high school building as indicated most recently on pages, 8
-13 of the 5/6/2020 Project Update to within 65 feet of the nearest abutting
residential property on the southerly side of the parcel and within feet of the stream,
bank, bordering vegetated wetland and within the 100 ft. wetland buffer as indicated
on pages 5 and 7  of  the 3/23/2020 Project Update.

4. The proposed construction of the Emergency Access Road, southeast of the

proposed 450 car garage, leading down the very steep embankment to the unnamed
20 foot private way abutting 79-85 Lincoln Street  and further leading ultimately to the
public portion of Lincoln Street as shown on page 8 -12 of the 5/6/2020 Project
Update.

Because of these significant and dramatic project changes, I am writing to request a new public
site inspection of the enlarged 52+ acre site, which now comprises the new Preferred Alternate
Option, by the City of Waltham representatives, the public, the Secretary of EEA and the staff
of MEPA, observing the Governor’s COVID-19 guidelines,  prior to the expiration public
comment period. The reason for this request is so that the environmental consequences and
impacts of the new Preferred Alternate Option will become readily apparent to the Secretary,
MEPA and all other participants. To fail to conduct this new inspection and public hearing is
both imprudent and would indicate a true lack of environmental stewardship.
I would also like to inquire about the possibility of extending the public comment period for at
least an additional 45 days because of the Governor’s Emergency Proclamation regarding
COVID-19 and because of the unprecedented conditions which we find ourselves in currently. I
believe that it is within the Secretary of EEA’s power to grant such and extension and I believe
that prudence warrants an extension given the current extraordinary conditions that currently
exist.

I thank you for your time and consideration and would appreciate an acknowledgement  and
response to my requests.

Here is a link to download pertinent information that I was not able to send directly to you
because of data limitations of your email address

https://we.tl/t-cE1aoH9rBH

Sincerely,

David Westner
David Westner

45 Glen Circle

Waltham, MA 02452

781 883 7745

davidwestner@gmail.com
From: dave westner
To: Czepiga, Page (EEA)
Subject: EEA#16097 Waltham High School Project
Date: Thursday, June 18, 2020 9:05:43 AM
Attachments: Additional Concerns Waltham HS-Westner.rtf

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Dear Page,
I am writing to voice my concern with the noise pollution that will immediately and
indefinitely come to be once the city of Waltham starts building and occupying the new high
school at 554 Lexington Street. **

This is a subject that often gets ignored until it's such an obvious problem that it's too late to
do anything about it.

I work in the fields of music and audio.  I think about this kind of thing constantly.

What the city wants to do, with no real consideration of those that live near the property, is to
turn a beautifully quiet neighborhood into an unbearably loud quarry and construction site for
4+ years, then when they are done with the building phase and move to the occupancy phase,
have it continue to be a noisy environment. 

You may be aware that there are plans to build a 450 car parking with a playing field on top of
it. 
On the light poles on the field there is a plan to install a "large outdoor high output" sound
system. This building and field will be above our house by several dozen or more feet and any
time there is a game going on, it will be excessively loud. 
There is also the issue of the 450 cars that will be coming and going each day.

I may have forgotten to mention that my wife, Karina Hines, and I are the closest abutters to
the playing field in the entire city of Waltham.  There are a few neighbors on either side of us
who are also abutting the garage, but we are closer than they are.  We live at 45 Glen Circle. 

It has been mentioned to me that I should bring up the term, "sensitive receptor" to describe
myself and I am worried that it will be completely discarded as an overused or perhaps
misused term because I am not a hospital or home for the elderly, but understand please, that
as a musician, producer and sound engineer, that I am indeed a sensitive receptor in regards to
noise pollution.  A motorcycle loudly driving by will nearly  stop me in my tracks and
definitely make my stick my fingers in my ears hoping that it will pass quickly.  The thought
of 4+ years of construction followed by decades of additional noise from a giant public
building has caused me many a sleepless night and constant anxiety.  Both my livelihood and
mental well being are at risk here. 

2 years ago this summer, across the street from our house, was a housing construction site, and
every morning at 7am sharp, the excavator with a rock breaking device started hammering on
the bedrock that they needed to remove to dig out the foundations for the new house. 
What I quickly realized was that my house was on the same piece of bedrock as the property
across the street, and for 10+hrs each day, it sounded as if they were banging on the
foundation of my house.  You see, sound travels better through solids than through the air. 
And by the way, not only was it loud in my house, but it was loud outside my house because
sound does indeed travel through air and those things are noisy. 
For a solid 18 months this went on and my life was miserable as a result. 

I hope you can take a moment to imagine what life would be like if you had to sit through an
aural assault day in and day out for months on end.  Please imagine someone banging loudly
on the wall of your office from the moment you walk in til the moment that you leave, every
day for 18 months..... 
Perhaps you are luckier than I am and can ignore sounds like this. Some people are quite
capable of tuning things like this out.  Unfortunately, I am not one of those people.  Which is
probably why I get paid to listen to things as a record producer. 

I was thinking about these noise issues early today and mention of the fairly recent Russian oil
spill came through on the radio.   I wondered if anyone was wishing they could go back in
time and do a better job of rust proofing their storage containers to prevent that particular
environmental disaster.  I wonder if they had had the opportunity to do anything but ignored
the problem or if they just weren't aware of the issue.  I don't know. 

But I feel now is the time to address the noise concerns for the Waltham high school and DW 1
parking garage/playing field site before it is too late and too costly to do anything about it.  As
it stands right now, the noise pollution increase could certainly be construed as an
environmental disaster by those that are sensitive to noise, and will eventually be construed as
such by those less sensitive to noise once they realize how noisy it will be.

It's an astonishingly preventable problem and there have been solutions suggested in the
appendix the DEIR, but most of them are presumptive and not matter of fact.  As someone
who has worked with sound in the real world for nearly 30 years, I find many of the
suggestions impractical and some of them impossible.  You cannot stop sound from travelling
through bedrock without digging a gigantic sound proof moat.  Sound proofing is extremely
expensive and much more complicated than putting a few egg cartons on the wall or hanging a
few blankets up. 

I believe it is important to note that my concerns with these sound issues have gone
unanswered and mostly ignored by the city, which is why I am asking for your help.

Right now, at 4pm on June 16, 2020, in my backyard, about 45 feet from where the parking
garage wall is meant to be, the ambient sound is sitting below 48dBa, which is as low as my
decibel meter will read.  My footsteps thru the underbrush read at 60dBa.  The ambient sounds
consisted of chipmunk squeaks, birdsong, wind rustling through the leaves of the trees, in the
distance, the quiet hum of traffic waking up from it's shutdown-sleep.  Not much else.  I am
dreading the introduction of machinery, banging, yelling, trucks, falling trees, and eventually
the sounds of 1700+ people coming and going day in and day out. 

I will leave you with this definition of noise pollution and a last thought:
"Noise pollution is an invisible danger. It cannot be seen, but it is present nonetheless, both on
land and under the sea. Noise pollution is considered to be any unwanted or disturbing sound
that affects the health and well-being of humans and other organisms."
From my point of view, as a direct and the closest abbutter to the proposed complex, my
quality of life will be severely and negatively impacted by a major and permanent increase in
background sound.

Thank you,
Dave Westner
781 883 7745
45 Glen Cir
Waltham, MA 02451

**Please note that there are many other issues that concern me regarding the environmental
damage that this project is likely to create, but I know you will have received many other
letters stating those issues and I wanted to write on a subject that is passionate and important
to me and also one that I understand in a much more concrete way than the other subjects.  I
am also fairly certain that I will be the only professional full time sound engineer you will hear
from and I thought it was important to get into more detail on this subject than others would be
able to do.  I have attached a bullet point list of some of the issues that are of equal importance
that I expect others will have covered in greater detail.

https://scholar.google.com/scholar?
hl=en&as_sdt=0%2C22&as_vis=1&q=noise+and+health&btnG=

https://www.newyorker.com/magazine/2019/05/13/is-noise-pollution-the-next-big-public-
health-crisis

https://www.neurologytimes.com/blog/misophonia-triggers-management
 Section 8: Responses to Comments

8.7.99 Wolff, Steven

No comments required

Waltham High School | Final Environmental Impact Report 5 | p. 144

From: Steve Wolff
To: Czepiga, Page (EEA)
Subject: Concern of noise pollution with planned Waltham High School
Date: Monday, June 15, 2020 12:30:47 PM

CAUTION: This email originated from a sender outside of the Commonwealth of

Massachusetts mail system.  Do not click on links or open attachments unless you
recognize the sender and know the content is safe.
Page,

I am writing with a concern of noise pollution regarding plans for the new high school being
built in Waltham. It appears that they are going to install loudspeakers on the playing field. I
live close enough that I will be able to hear the noise, which is troubling to me. I work at home
and often have video meetings. If there is background noise, I won't be able to work.
Furthermore, to be disturbed with loud speakers is distressing and it will lower the value of my
house. Please intervene and insist that the loudspeakers not be allowed as the noise pollution
they create will be costly both emotionally and financially.

Thank you,
Steven Wolff
 Section 8: Responses to Comments

8.7.100 Woodside, Celeste

In support, no comments required

Waltham High School | Final Environmental Impact Report 5 | p. 145

Appendices 9
(under separate cover)
4.1 Stationary Source GHG Calculations
4.2 LCCA Calculations
4.3 Mobile Source GHG Calculations
6.2 Acentech Community Noise Report
9.1 Site Plans
C-101 Existing Conditions Plan I
C-102 Existing Conditions Plan II
C-111 Site Preparation Plan I
C-112 Site Preparation Plan II
C-121 Layout and Materials Plan I
C-122 Layout and Materials Plan II
C-131 Grading and Utilities Plan I
C-132 Grading and Utilities Plan II
C-141 Planting Plan I
C-142 Planting Plan II
C-161 Schematic Traffic Signal Plan
C-501 Details I
C-502 Details II
C-503 Details III
C-504 Details IV
C-505 Details V
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