April 5, 2012

Secretary Richard K. Sullivan, Jr.
EOEA, Attn: MEPA Office
William Gage, EOEA No. 11202
100 Cambridge Street, Suite 900
Boston, MA  02114

Subject:  Environmental Status and Planning Report for EOEA# 11202 – MassDOT Snow and Ice Control Program

Dear Secretary Sullivan,

I am submitting comments on the Environmental Status and Planning Report (ESPR) for the Massachusetts Department of Transportation’s (MassDOT’s) Snow and Ice Control program on behalf the Connecticut River Watershed Council (CRWC).  CRWC is the principal nonprofit environmental advocate for protection, restoration, and sustainable use of the Connecticut River and its watershed.  Because the Connecticut River and its major basin tributaries take up approximately one-third of Massachusetts, MassDOT’s approach to snow and ice removal has a significant effect on our watershed.  We recognize the challenge in keeping roadways safe, yet trying to apply de-icing chemicals in a quantity that is not overly detrimental to the environment.  We submitted a comment letter on the Generic Environmental Impact Report (GEIR) in 2006 and the ESPR Work Plan in 2008.

Our comments on the ESPR document are below.

Operational Changes

CRWC is supportive of MassDOT’s proactive approach to anti-icing that focuses on pre-treating roadways prior to, or at the onset of, a winter storm event.  We are also supportive of the use of new spreader technology improvements, including the requirement for all hired contractors to have pre-wetting equipment on their spreader trucks.

CRWC applauds MassDOT for reducing the use of sand in Districts 1 and 2 by as much as 75 and 95 percent, respectively, over the last five years in comparison to the previous five years.  That reduction has environmental benefits, and we suppose there is a cost savings as well.

Policy and Procedural Changes

We think establishing an internal Snow and Ice Materials Usage Review Committee to periodically review data, policies and procedures to identify changes that would result in greater material usage efficiency.  Based on the January/February 2012 issue of Stormwater magazine (online at http://www.stormh2o.com/SW/Articles/Ice_School_15792.aspx), we have the following suggestions:

  • This article suggests that if a spreader truck moves at speeds over 30 miles per hour, 30% of the salt coming off the truck’s distribution spreader will bounce off the side of the road before doing anything to enhance safety.  We didn’t see anywhere in the ESPR where the issue of spreader speed was addressed.  Has MassDOT considered recommending maximum travel speeds for spreader trucks when spreading dry salt?
  • One person from Illinois interviewed in the article advocated for a policy of loading only the precise amount of salt needed on each assigned route.  According to the article, the approach can provide an instant reduction with a simple change in behavior, since drivers tend to use up what is loaded.  This sounds like an idea worth considering, if it hasn’t been considered already.
  • CRWC is curious if MassDOT has analyzed how hired contractors are paid, and whether the system lends itself to wasteful salt application.  For example, if they are paid for every pound of salt spread, this would be a built-in incentive to use more salt than truly needed.  We could not find any information about this in the ESPR.

Historical Salt Usage vs. Winter Severity Index

CRWC finds the FY 2011 statewide salt usage numbers encouraging, given the severity of the winter.  However, as the saying goes, “one year does not a trend make.”  We’ll need more years of data to see how DOT’s policies have resulted in comparative salt application reductions.

MassDOT reports an average rate of 240 lbs per lane mile, but says that depends on the road and storm conditions at the time.  In looking at Appendix F, which presents the policies for each reduced salt zone in the state, they all say the application rate for 50:50 salt sand is 240 lbs/lane mile.  This doesn’t imply a maximum application rate, or that it’s decided on a case-by-case basis.  Therefore, we wonder what other states are doing and if, given the pre-wetting practice, whether MassDOT could have an application rate notched down slightly, say to 225 lbs/lane mile and see how that goes.

Table 1-3 shows the average salt usage for each district between FY 2002 and FY2011.  Because of the addition of District 6 in FY 2011, the 10-year average for the whole state should be taken from the totals at the bottom of each year.  This number should be 503,566 rather than 502,825.

Comparison of Other New England State’s Snow and Ice Control Practices

We’d like to see an updated table similar to Table 2.6-2 from the 2006 Snow & Ice Control GEIR.  In particular, this table included costs/lane mile by state, tons/lane mile by state, and use of hired equipment.  This information was not included in the 2012 draft ESPR for other states.

Reduced Salt Zones

CRWC supports the idea of using less sand and also less salt in Reduced Salt Zones.

Emerging Technologies

Compared to the 2006 GEIR, MassDOT seems to be more knowledgable and more flexible about trying out new technologies and techniques that could lead to reductions in sand and salt, as well as fuel, use.

Bridge Washing

CRWC appreciates the maintenance advantages to this practice but wonders how bridge washing would be done in a way that minimizes discharges directly to water bodies.

Environmental Effects

For section 2, we also recommend the article by Corsi et al., “A Fresh Look at Road Salt: Aquatic Toxicity and Water-Quality Impacts on Local, Regional, and National Scales” Environ. Sci. Technol., 2010, 44 (19), pp 7376–7382. Online at http://pubs.acs.org/doi/full/10.1021/es101333u

Page 2-20 of the ESPR summarizes the results of the salt TMDL in New Hampshire, which identified commercial parking lots as a major source of salt in impaired water bodies near the I-93 corridor in New Hampshire.  The ESPR concludes that commercial property owners and contractors who maintain their parking lots would also need to be fully involved with implementing measures to reduce salt usage.  That prompted CRWC to wonder how Massachusetts highway rest area parking lots are maintained, and if MassDOT could at least be a guide to reducing impacts from these parking lots.

Recommendations

We think many of the recommendations offered in section 6 are good ideas.  We like the idea of an Annual Report, which could give those interested in the subject of salt application a regular update on how the state is doing.

We aren’t sure what intervals the Snow & Ice Program is to be reviewed through the MEPA office, but it would be nice to get a more detailed update like this ESPR every five years or so.

Thank you for the opportunity to comment on the ESPR.

Sincerely,


Andrea F. Donlon

River Steward

cc:      Laurene Poland, MassDOT

Anne Capra, Pioneer Valley Planning Commission

Kimberly Noake McPhee, Franklin Regional Council of Governments