Dear MassDEP Commissioner Heiple, Regional Director Worrall and Wetlands Protection Staff Provencal and Ferrick,

 We urge you to protect our wetlands and the natural resources of our community by upholding the Wakefield Conservation Commission’s (the Commission) June 6, 2023 denial of a permit to the Northeast Metropolitan Regional Vocational School (NEMT) to construct a new vocational school in Rare Species and Forest Core habitats identified by the Massachusetts BioMap. The Commission’s denial of the permit demonstrated that the Project will not meet the performance standards for bordering vegetated wetlands or inland bank and no conditions the Project has or can put forth will change this.  

Please closely consider the science-based evidence provided by the ten citizens’ group in their Request for Departmental Action submitted on June 21, 2023. This group closely followed all of the hearings, reviewed all of the Project’s submissions and provided details on the significant alteration of wetlands and buffers that cannot be conditioned to avoid or compensate for this damage. Much of the 0-25 ft buffer zone will become a raised paved road and parking lots. Upland habitat will be blasted. The clear cutting, blasting, paving and the use of thousands of pounds of blasting chemicals, de-icing chemicals and fertilizers will pollute the wetlands and our water supply. There will be an increased risk of flooding and storm damage. Without adequate buffer zones, these wetlands and small pools will not be able to protect water quality and wildlife habitat. 

It is economically and environmentally incomprehensible why the Project chose this location.  There are two cleared sites on the 30 acres of school property that have been judged in the NEMT Project’s own analyses to be practicable and substantially equivalent alternatives to the forested hilltop location for the new school. The hilltop site is in many ways inferior to these alternative sites and involves the loss of over 2000 trees, essential to storing carbon, that is critical to the Commonwealth’s strategy to address the climate emergency, especially given that this region is heating up faster than elsewhere. It is important to know that denying this permit does not mean denying the school because cost-effective, safer and less environmentally destructive options exist and have already been vetted. There would be far less environmental damage and safer access to school for everyone if the school was built on one of these sites.  The current plan for the school in the hilltop forest will require students to climb 1100 feet of ramps and stairs from the parking area to reach the school. 

The Project site is also within Priority Habitat of a rare species (Hentz’s Red-bellied Tiger Beetle) that was mapped and became effective 2021, well before the NEMT Project submitted their permit request in September 2022. A newly recognized population of the Eastern Whip-poor-will is found here, a state listed species of special concern. The Project site is across the street from a state designated Area of Critical Environmental Concern and adjacent to a powerline cut. The forest edge borders shrublands in the powerline right-of-way, creating important edge habitat. Together with wetlands and vernal pools this supports a number of breeding bird species of Greatest Conservation Need in the State Wildlife Action Plan (SWAP). It is an ecosystem benefitting rare and declining species of conservation need.

Our scientists have made the consequences of this intensive and destructive development clear in our submission to MassDEP. There will not be any engineering solutions to the consequences of this project. By denying the permit for the school on the hilltop, the Commission made the decision to protect our wetland resources and the rare species struggling due to loss of habitat. 

This forest, these wetlands, this ecosystem belongs to us all and are our precious natural resources. We need and have a right to the services that nature provides for clean air, water, health and wellbeing. We need a healthy forest and wetlands with flora and fauna that allows us to realize the beauty of the world we live in. It is not to be destroyed and worse, destroyed for no reason. We urge you to DENY the NEMT appeal and issue a Superseding Order of Conditions consistent with the Wakefield Conservation Commission’s decision to deny the project. The school can be built on already cleared land, not on the forested hilltop. Save the forest and our wetlands. 

Sincerely,

Concerned Citizens of Massachusetts and Save the Forest and Build the Voke Coalition

Distribution:

• Bonnie Heiple, Commissioner

  Massachusetts Department of Environmental Protection (MassDEP)

  100 Cambridge St. Suite 900

  Boston, MA 02114 Email: Bonnie.Heiple@mass.gov

• Eric Worrall, Regional Director

  MassDEP - Northeast Regional Office

  150 Presidential Way

  Woburn, MA  01801 Email: Eric.Worrall@mass.gov

• Jill Provencal, Section Chief, Wetlands Program

  MassDEP - Northeast Regional Office

  150 Presidential Way

  Woburn, MA  01801 Email: Jill.Provencal@mass.gov

• Tyler Ferrick, Environmental Analyst

  MassDEP - Northeast Regional Office

  150 Presidential Way

  Woburn, MA  01801 Email: Tyler.Ferrick@mass.gov