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Northampton_10-27790_NPC_SedimentMvmt.pdf September 26, 2018 Matthew A. Beaton, Secretary Executive Office of Energy and Environmental Affairs Attention: MEPA Office Purvi Patel 100 Cambridge Street Boston, Massachusetts 02114 Project Name: Paradise Pond Sediment Management Protocol Proponent: The Trustees of Smith College Location: Paradise Pond, an impoundment of the Mill River Document Reviewed: Notice of Project Change EEA Number: 15282 NHESP Tracking No.: 10-27790 Dear Secretary Beaton: The Natural Heritage & Endangered Species Program and Fisheries Program of the Massachusetts Division of Fisheries & Wildlife (the Division) have reviewed the Notice of Project Change for the Paradise Pond Sediment Management Protocol (the Project) and would like to offer the following comments. The Mill River and Diversion of the River between the Paradise Pond impoundment to the confluence with the Connecticut River is within mapped Priority & Estimated Habitat of the following state-listed species: Taxonomic Group Scientific Name Common Name State-Status Invertebrate Animal: Damselfly Boyeria grafiana Ocellated Darner Special Concern Invertebrate Animal: Dragonfly Gomphus ventricosus Skillet Clubtail Threatened Invertebrate Animal: Mussel Alasmidonta heterodon Dwarf Wedgemussel* Endangered* Invertebrate Animal: Mussel Lampsilis cariosa Yellow Lampmussel Endangered Invertebrate Animal: Mussel Ligumia nasuta Eastern Pondmussel Special Concern Invertebrate Animal: Mussel Strophitus undulatus Creeper Special Concern Vertebrate Animal: Turtle Glyptemys insculpta Wood Turtle Special Concern These species and their habitats are protected pursuant to the implementing regulations of the MESA (321 CMR 10.00) and the rare species provisions of the WPA. Fact sheets for most state-listed species can be found at www.mass.gov/nhesp. *The Dwarf Wedgemussel is also listed pursuant to the federal Endangered Species Act (50 CFR 17.11), which is administered by the United States Fish & Wildlife Service (USFWS). Over the last several years, the Proponents have conducted a series of experimental impoundment releases to develop an adaptive management plan for Paradise Pond. The goal was to determine if using NHESP No. 10-27790, NPC Paradise Pond, page 2 of 2 the low-level outlet to release impounded sediments during higher flow events would both maintain sufficient depth for the College’s recreation and education needs (a minimum water depth of 3 feet below the spillway elevation) while not harm (and hopefully improve) downstream habitats. Post management monitoring results found that only using the low-level outlet would not mobilize sufficient sediment from the impoundment to be self-sustaining to meet the recreational goals. The Proponents have therefore modified the adaptive management plan to include the use of a conventional drawdown to allow for mechanical redistribution of sediments into the “active” channel of the impoundment, which is located around the north end of the impoundment. The riverine sediments moved into the “active” channel will them be mobilized out of the low-level outlet during natural high-flow events. The project would conduct a drawdown to facilitate the mechanical re-distribution of the sediment, which may occur annually. The Proponents have also reduced the target water depth to 2 feet from the initial 3 feet. The results of the past studies suggest that a balance in the interests can be found, with some potential benefits to the overall River habitat below the Smith College Dam. Based on the data collected to date by the Proponents, we anticipate requiring conditions as to the timing and frequency of the drawdown, limits to the amount of suspended sediments during high-flow event to avoid smothering downstream mussels, and ongoing monitoring. We are confident that outstanding details can be resolved during the MESA review process. We will continue to consult with the Proponent during the MESA review process to develop conditions to avoid impacts to state-listed species. The Division will not render a final decision regarding the MESA until the MEPA review process and its associated public comment period is complete, and until all required application materials have been submitted to the Division. As the MESA review process has not formally initiated, no alteration to the soil, surface, or vegetation associated with the Project shall occur until the Division has made a final decision pursuant to 321 CMR 10.14 and 321 CMR 10.18. Sincerely, Thomas W. French, Ph.D. Assistant Director cc: Briscoe Lang, Pare Corporation David Foulis, MA DEP Western Regional Office, Wetlands Paul Sneeringer, US Army Corps of Engineers Sarah LaValley, Northampton Conservation Commission