20221215 deir lakeshore center phase 4

Draft Environmental Impact Report
EEA # 16558
Lakeshore Center Phase 4

Bridgewater, MA
Prepared for:
Executive Office of Energy and Environmental Affairs
MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114
Submitted by: Prepared by:

Claremont Companies Epsilon Associates, Inc.
Two Lakeshore Center 3 Mill & Main Place, Suite 250
Bridgewater, MA 02324 Maynard, MA 01754
In Association with:
Silva Engineering Associates, P.C.
McMahon Associates, Inc.
Goddard Consulting, LLC
Public Archaeology Laboratory, Inc.
December 15, 2022

Draft Environmental Impact Report
EEA # 16558
Lakeshore Center Phase 4
Submitted to: Prepared by:

Executive Office of Energy and Epsilon Associates, Inc.
Environmental Affairs 3 Mill & Main Place, Suite 250
MEPA Office100 Cambridge Street, Suite 900 Maynard, Massachusetts 01754
Boston, Massachusetts 02114
Submitted by: In Association with:

Claremont Companies Silva Engineering Associates, P.C.
Two Lakeshore Center McMahon Associates, Inc.
Bridgewater, MA 02324 Goddard Consulting, LLC
Public Archaeology Laboratory, Inc.
December 15, 2022

Table of Contents
Table of Contents
1.0 PROJECT DESCRIPTION 1-1

1.1 Introduction 1-1
1.2 Project Site 1-1
1.3 Project Description 1-5
1.4 Changes Since the ENF 1-15
1.5 Statutory and Regulatory Standards 1-16
2.0 ALTERNATIVES ANALYSIS 2-1

2.2 Measures Considered to Reduce Impacts 2-2
2.2.1 Increasing Building Height to Reduce Building Footprint on Lots 6 & 7 2-2
2.2.2 Feasibility of Constructing a Central Parking Garage 2-4
2.2.3 Feasibility of Shared Surface Parking 2-4
2.2.4 Feasibility of Underground Parking 2-5
2.2.5 Feasibility of Podium Parking with Building Above on Lots 6 & 7 2-5
2.2.6 Parking Space Banking 2-6
2.3 Summary 2-6
3.0 LAND ALTERATION, OPEN SPACE, AND FARMLAND CONVERSION 3-1

3.2 Land Alteration 3-1
3.2.1 Mitigation Measures to Reduce Land Alteration 3-2
3.3 Open Space 3-3
3.4 Agricultural Lands 3-3
4.0 TRANSPORTATION 4-1

4.1 Project Description 4-1
4.2 Study Methodology 4-3
4.3 2022 Existing Conditions 4-4
4.3.1 Roadway Network 4-4
4.3.2 Signalized Intersections 4-5
4.3.3 Unsignalized Intersections 4-6
4.3.4 Traffic Volume Data 4-7
4.3.5 Traffic Volume Adjustments 4-8
4.3.6 Multi-Modal Accommodations 4-8
4.3.7 Safety Evaluation 4-11
4.3.8 Field Calibration 4-13
4.3.9 2022 Existing Capacity Analysis 4-14
6491/Lakeshore Center Phase 4 i Table of Contents

Epsilon Associates, Inc.
Table of Contents (Continued)
4.4 2029 No Build Conditions 4-15

4.4.1 Background Traffic Growth 4-15
4.4.2 Future Roadway Improvements 4-16
4.4.3 2029 No Build Capacity Analysis 4-16
4.5 2029 Build Conditions 4-19
4.5.1 Trip Generation 4-19
4.5.2 Trip Distribution 4-20
4.5.3 2029 Build Capacity Analysis 4-42
4.5.4 Site Access and Circulation 4-43
4.5.5 Sight Distance 4-44
4.6 Mitigation 4-46
4.6.1 Transportation Demand Management 4-46
4.6.2 Transportation Monitoring Program 4-47
5.0 RARE SPECIES 5-1

5.1 Eastern Box Turtle 5-1
5.2 Northern Lot 5-1
6.0 AREA OF CRITICAL ENVIRONMENTAL CONCERN 6-1

6.2 Impacts to the ACEC 6-1
6.2.1 Groundwater 6-1
6.2.2 Habitat 6-1
6.2.3 Flood Control and Storm Damage Prevention 6-2
6.2.4 Historic and Archaeological Resources 6-2
6.2.5 Scenic and Recreational Resources 6-3
6.3 Bio-Inventory 6-3
7.0 WETLANDS AND STORMWATER 7-1

7.1 Wetland Resources 7-1
7.1.1 Existing Conditions 7-1
7.1.2 Impacts to Resource Areas and Buffer Zones 7-1
7.1.3 Proposed Wetland Mitigation 7-2
7.2 Floodplain 7-2
7.3 Proposed Stormwater Management System 7-3
7.3.1 Stormwater Runoff Analysis 7-3
7.3.1.1 Existing Conditions 7-3
7.3.1.2 Soils 7-4
7.3.1.3 Land Cover Changes 7-8
7.3.1.4 Proposed Conditions 7-8
7.3.1.5 Watersheds 7-10
6491/Lakeshore Center Phase 4 ii Table of Contents

7.3.1.6 Pre-Development Conditions 7-10

7.3.1.7 Post-Development Conditions 7-11
7.3.2 Stormwater Mitigation 7-16
7.3.3 Stormwater Management Policy Standards 7-16
7.3.4 Erosion Control Procedures 7-22
7.3.5 Low Impact Development Strategies 7-24
7.3.6 Consistency with Bridgewater’s Stormwater Management Program 7-25
7.3.7 Consistency with the National Pollutant Discharge Elimination System
(NPDES) General Permit 7-26
7.3.8 Construction Stage Best Management Practices 7-26
7.3.9 Stormwater Pollution Prevention Plan (SWPPP) 7-27
7.3.10 Operation and Maintenance Plan 7-28
7.3.11 Spill Prevention Program 7-29
8.0 WATER AND WASTEWATER 8-1

8.1 Anticipated Water Demand and Wastewater Generation 8-1
8.2 Proposed Water Conservation Measures 8-2
8.3 Inflow and Infiltration 8-2
8.4 Irrigation 8-3
9.0 HISTORIC AND ARCHAEOLOGICAL RESOURCES 9-1
10.0 CLIMATE CHANGE ADAPTATION AND RESILIENCY 10-1

10.2 Potential Vulnerabilities to Climate Change 10-1
10.2.1 RMAT Introduction 10-1
10.2.1.1 RMAT Results 10-1
10.2.2 Town of Bridgewater: Climate Change Study 10-2
10.2.3 Old Colony Planning Council: Regional Policy Plan 10-2
10.3 Adaptation and Resiliency Measures 10-2
10.3.1 Extreme Heat Events / Drought Conditions 10-2
10.3.2 Extreme Precipitation for Urban and Riverine Flooding 10-3
10.3.3 Sea Level Rise / Storm Surge 10-3
11.0 GREENHOUSE GAS ANALYSIS 11-1

11.1 Introduction and Project Overview 11-1
11.1.1 MEPA Greenhouse Gas Emissions Policy and Protocol 11-1
11.1.2 Stationary Source Methodology 11-1
11.1.3 Project Overview 11-2
11.2 Stationary Sources 11-2
11.2.1 Building Envelope 11-3
11.2.2 HVAC and Mechanical 11-5
6491/Lakeshore Center Phase 4 iii Table of Contents

11.2.3 Solar Photovoltaics 11-7

11.2.4 Electric Vehicle Parking 11-7
11.2.5 Building Energy Modeling 11-7
11.2.6 Restaurant and Cafe 11-11
11.2.7 Incentives 11-11
11.3 Mobile Source Emissions 11-11
11.3.1 Traffic GHG Analysis 11-11
11.3.2 Traffic GHG Analysis Results 11-12
11.3.3 Summary 11-13
11.4 Summary and Mitigation Commitments 11-14
11.4.1 Project GHG Summary 11-14
11.4.2 Proponent’s Commitments to GHG Reduction 11-15
11.4.3 Proponents’ Commitments to Self-Certification 11-16
12.0 CONSTRUCTION PERIOD IMPACTS 12-1

12.2 Construction Schedule 12-1
12.3 Construction Methodology/Public Safety 12-1
12.4 Construction Noise 12-2
12.5 Construction Air Quality 12-2
12.6 Construction Solid Waste and Recycling 12-3
12.7 Construction Employment and Worker Transportation 12-4
12.8 Construction Access and Staging 12-4
12.9 Erosion and Sedimentation Control 12-4
13.0 MITIGATION AND DRAFT SECTION 61 FINDINGS 13-1

13.2 Anticipated State Permits and Approvals 13-1
13.3 Proposed Section 61 Findings 13-1
14.0 RESPONSE TO COMMENTS 14-1

14.1 MEPA Certificate and Associated Comment Letters 14-1
List of Attachments
Attachment A Transportation Data

Attachment B Bio-Inventory Report
Attachment C RMAT Report
Attachment D Greenhouse Gas
Attachment E Northern Lot Stream Determination
Attachment F MHC MOA
Attachment G Circulation List
6491/Lakeshore Center Phase 4 iv Table of Contents

List of Figures
Figure 1-1 USGS Locus Map 1-2

Figure 1-2 Aerial Locus Map 1-3
Figure 1-3 Existing Conditions Plan 1-4
Figure 1-4 DEP Wetlands, NHESP Features, FEMA Flood Zones 1-6
Figure 1-5 Environmental Constraints 1-7
Figure 1-6 Proposed Site Plan 1-8
Figure 1-7 Lot 1 Proposed Site Features 1-9
Figure 1-12 Northern Lot Proposed Site Features 1-+14
Figure 2-1 Aerial View of Proposed Site Plan 2-3

Figure 2-2 Lot 4 Potential Reduced Parking 2-7
Figure 3-1 Lot 1 Grading Plan 3-4

Figure 3-6 Northern Lot Grading Plan 3-9
Figure 3-7 Project area to remain undisturbed 3-10
Figure 3-8 Potential Conservation Restriction Areas 3-11
Figure 4-1 Site Location Map 4-2

Figure 4-2 2022 Existing Weekday Morning Peak Hour Traffic Volumes 4-9
Figure 4-3 2022 Existing Weekday Afternoon Peak Hour Traffic Volumes 4-10
Figure 4-4 2029 No Build Weekday Morning Peak Hour Traffic Volumes 4-17
Figure 4-5 2029 No Build Weekday Afternoon Peak Hour Traffic Volumes 4-18
Figure 4-6 Proposed Restaurant Directions of Arrival and Departure 4-22
Figure 4-7 Proposed Café Directions of Arrival and Departure 4-23
Figure 4-8 Proposed Assisted Living Directions of Arrival and Departure 4-24
Figure 4-9 Proposed Senior Housing Directions of Arrival and Departure 4-25
Figure 4-10 Proposed Hotel Directions of Arrival and Departure 4-26
Figure 4-11 Proposed Condominiums Directions of Arrival and Departure 4-27
Figure 4-12 Weekday Morning Peak Hour New Restaurant Trips 4-28
Figure 4-13 Weekday Afternoon Peak Hour New Restaurant Trips 4-29
Figure 4-14 Weekday Morning Peak Hour New Cafe Trips 4-30
6491/Lakeshore Center Phase 4 v Table of Contents

List of Figures (Continued)
Figure 4-15 Weekday Afternoon Peak Hour New Cafe Trips 4-31
Figure 4-16 Weekday Morning Peak Hour New Assisted Living Trips 4-32
Figure 4-17 Weekday Afternoon Peak Hour New Assisted Living Trips 4-33
Figure 4-18 Weekday Morning Peak Hour New Senior Housing Trips 4-34
Figure 4-19 Weekday Afternoon Peak Hour New Senior Housing Trips 4-35
Figure 4-20 Weekday Morning Peak Hour New Hotel Trips 4-36
Figure 4-21 Weekday Afternoon Peak Hour New Hotel Trips 4-37
Figure 4-22 Weekday Morning Peak Hour New Condominium Trips 4-38
Figure 4-23 Weekday Afternoon Peak Hour New Condominium Trips 4-39
Figure 4-24 2029 Build Weekday Morning Peak Hour Traffic Volumes 4-40
Figure 4-25 2029 Build Weekday Afternoon Peak Hour Traffic Volumes 4-41
Figure 6-1 Locus map of all properties presently associated with the Lakeshore Center 6-5
Figure 6-2 Aerial view of the Lakeshore Center, facing north towards Lake Nippenicket 6-6
Figure 7-1 Existing Stormwater Drainage Conditions 7-5

Figure 7-2 Soil Conditions 7-6
Figure 7-3 Surficial Geology Map 7-7
Figure 7-4 Aerial View of Lakeshore Center from April 2013 7-9
Figure 7-5 Outlet 1 – Intermittent Stream #1 7-12
Figure 7-8 Outlet 4 – Culvert under Route 495 7-15
Figure 7-9 V-Notch Weir Diagram 7-30
List of Tables
Table 1-1 Comparison of the ENF and DEIR Preferred Alternatives 1-15
Table 1-2 List of Local Permits 1-17
Table 2-1 Existing Amounts of Undeveloped Land by Parcel 2-1

Table 2-2 Pre- and Post-Development Disturbed Land Totals 2-1
Table 2-3 Parking Spaces Summary 2-6
Table 3-1 Land Alteration Summary 3-1

Table 3-2 Alteration of Previously Undisturbed Areas 3-1
Table 3-3 Tree Clearing Summary 3-2
Table 3-4 Potential Land Preservation Areas (Wetlands) 3-3
6491/Lakeshore Center Phase 4 vi Table of Contents

List of Tables (Continued)
Table 4-1 ATR Summary 4-7

Table 4-2 Crash Rate Summary 4-12
Table 4-3 Risk-Based Screening Summary 4-13
Table 4-4 2022 Existing Capacity Analysis Summary 4-15
Table 4-5 2029 No Build Capacity Analysis Summary 4-16
Table 4-6 Trip Generation 4-20
Table 4-7 2029 Build Capacity Analysis Summary 4-42
Table 4-8 Sight Distance Evaluation 4-45
Table 7-1 Site Soils 7-4
Table 8-1 Anticipated Water Demand and Sewer Generation 8-1
Table 11-1 55+ Multi-Family and Condominium Buildings Passive House Cost Analysis 11-6
Table 11-2 Hotel Energy Modeling Results 11-9
Table 11-3 Assisted Living Building Energy Modeling Results 11-10
Table 11-4 Regional Traffic GHG Emissions Analysis Summary (No-Build) 11-13
Table 11-5 Regional Traffic GHG Emissions Analysis Summary (Build) 11-13
Table 11-6 Regional Traffic GHG Emissions Analysis Summary 11-14
Table 11-7 Project Traffic GHG Emissions Analysis Summary 11-14
Table 11-8 Project GHG Emissions Summary 11-15
Table 13-1 Summary of Mitigation Measures 13-2
Table 14-1 Secretary’s Certificate and Comment Letters 14-1
6491/Lakeshore Center Phase 4 vii Table of Contents

Chapter 1
Project Description
1.0 PROJECT DESCRIPTION
1.1 Introduction
Claremont Companies, LLC (the “Proponent”) proposes to develop an approximately 68.2-acre

(ac) site within the 167.5-acre 1 Lakeshore Center Development off of Pleasant Street (Route 104)
in Bridgewater. The site is currently partially developed. The Proponent is proposing to build new
developments on Lots 1, 4, 6, and 7 within the current Lakeshore Center Development south of
Pleasant Street as well as on a newly added parcel on north side of Pleasant Street.
The Project is subject to review under the Massachusetts Environmental Policy Act (MEPA)
because it will require a State Permit and exceeds one or more MEPA review thresholds. The
Proponent filed an Environmental Notification Form (ENF) with the MEPA Office on May 16, 2022.
On June 24, 2022, the Secretary of Energy and Environmental Affairs (EEA) issued a Certificate on
the ENF requiring a Draft Environmental Impact Report (DEIR). This DEIR responds directly to the
Scope set out in the Secretary’s Certificate.
1.2 Project Site
The Project Site off of Pleasant Street (Route 104) in Bridgewater is bounded to the north by
Route 104 and Lake Nippenicket, to the east by a Commonwealth of Massachusetts Salvage
Inspection lot and Route 24, to the south by the Route 24 southbound to Route 495 northbound
ramp, and to the west by Route 495 and Route 104/North Main Street. A Locus Map is included
as Figure 1-1 and an Aerial View of the Site as Figure 1-2.
The existing Lakeshore Center development comprises of a mix of uses. A 4-building, 289-unit
residential complex and 574 associated parking spaces occupy the western section. Within the
central portion of the Site, there is a 96-room, 4-story hotel with 103 parking spaces on Lot 1; an
approximately 77,000 gross square foot (GSF), 3 story office building with 237 parking spaces on
Lot 2; an approximately 65,000 GSF, 4-story office building with 227 parking spaces on Lot 3; and
a 300-unit, 5-story apartment complex with 600 parking spaces on Lot 5. An approximately
100,000 GSF flex space warehouse with 162 parking spaces and 27 loading docks is located in the
eastern section on Lot 8. An Existing Conditions Site Plan is included as Figure 1-3.
The proposed development area includes Lots 1, 4, 6, and 7 within the Lakeshore Center
Development and an additional parcel located on the north side of Pleasant Street (Northern Lot).
Lots 1 and 4 are in the Central portion of the Lakeshore Development on the west side of the
Lakeshore Center central access road. Lots 6 and 7 are on the east side of the central access road
1
The overall Lakeshore Center Development has expanded in recent years in two areas. Lot 1 was increased in
size to add a parking lot and the Northern Lot was acquired. Prior MEPA filings excluded the approximately 1.3-
acre development on Lot 1 and the approximately 1.9-acre development on the Northern Lot, both of which are
included in this current filing.
6491/Lakeshore Center Phase 4 1-1 Project Description

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and are currently unimproved. Lots 6 and 7 are constrained for development by wetlands located
on their eastern side. The entire Lakeshore Center Development falls within the Hockomock
Swamp Area of Critical Environmental Concern (ACEC) Figures 1-4 and 1-5 present the
environmental constraints at the Project site.
The proposed Project is not within a 1-mile radius of any Environmental Justice communities as
shown on the Commonwealth’s Environmental Justice Populations in Massachusetts website
map. 2 The Project is not expected to generate 150 diesel truck trips per day; therefore, the
Project’s Designated Geographic Area (DGA) is one mile and a 5-mile radius was not considered.
1.3 Project Description
The proposed Project includes new development on Lots 1, 4, 6, and 7 of the Lakeshore Center
Development and on the north side of Pleasant Street. See Figure 1-6 for an overall conceptual
site plan. Development will include the following components:
♦ A 1-story, approximately 1,800 SF café shop on Lot 1;
♦ A 5-story, 150-unit (200,000 SF) assisted living facility on Lot 4;
♦ A 4-story, 225-unit (307,400 SF) 55+ residential community on Lot 6;
♦ A 4-story, 106-room hotel (69,640 SF), and a 4-story, 160-unit (225,000 SF) condominium
community on Lot 7; and
♦ A 179-seat (6,000 SF) restaurant on the north side of Pleasant Street adjacent to Lake
Nippenicket.
A total of 1,114 parking spaces are proposed to accommodate the varied uses across the site.
Figures 1-7 through 1-12 present more detailed plans for each of the development areas.
Overall, the Project will disturb approximately 27.85 acres and create 12.74 acres of new
impervious area. The Project has been designed to avoid directly filling wetlands. It will, however,
require work within the buffer zone of bordering vegetated wetland (BVW). As such, it will require
an Order of Conditions from the Bridgewater Conservation Commission.
2
The Environmental Justice Populations in Massachusetts website map can be found online at:
https://mass-eoeea.maps.arcgis.com/apps/MapSeries/index.html?appid=535e4419dc0545be980545a0eeaf9b53

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Figure 1-5
Environmental Constraints
Figure 1-6
Proposed Site Plan
Figure 1-7
Lot 1 Proposed Site Features
Figure 1-8
Figure 1-9
Figure 1-10
Figure 1-11
Figure 1-12
Northern Lot Proposed Site Features
The Project will affect some priority habitat on the north side of Pleasant Street; however, the
Massachusetts Natural Heritage and Endangered Species Program (MNH&ESP) has issued a “No-
Take” letter dated November 18, 2022, which confirms that the proposed Project will not result
in a take, and that no Conservation Management Permit will be required for this portion of the
Project. Please refer to the Chapter 5 for more information on Rare Species.
The Project will also impact two known archaeological sites on Lots 6 and 7. A data recovery
program has been implemented and archaeological fieldwork completed on the two sites in
accordance with a Memorandum of Agreement (MOA) with the Massachusetts Historic
Commission (MHC). Analysis of recovered cultural materials and other categories of
archaeological information and preparation of a technical report on the data recovery program
by PAL is in progress. Please refer to the Chapter 9 for more information.
1.4 Changes Since the ENF
The Proposed Project is essentially the same as was presented in the ENF in terms of both uses
and their proposed locations. As the design has been advanced, the size of the 55+ residential
building on Lot 6 and the hotel on Lot 7 have been increased along with a slight increase in the
number of parking spaces. Table 1-1 summarizes changes between the ENF and the current
Preferred Alternative.
Table 1-1 Comparison of the ENF and DEIR Preferred Alternatives
Lot ENF Alternative DEIR Preferred Alternative Change
North Restaurant (179 seats) Restaurant (179 seats)

6,000 SF 6,000 SF -5 parking spaces
64 parking spaces 59 parking spaces
1 Café Shop (1,800 SF) Café Shop (1,800 SF)

No change
4 Assisted Living (150 units) Assisted Living (150 units)

200,000 SF 200,00 SF -12 parking spaces
6 55+ Residential (225 units) 55+ Residential (225 units)

+107,400 SF
200,000 SF 307,400 SF
+34 parking spaces

Table 1-1 Comparison of the ENF and DEIR Preferred Alternatives (Continued)
Lot ENF Alternative DEIR Preferred Alternative Change
7 Hotel (102 Rooms) 56,000 SF Hotel (106 Rooms) 69,640 SF Hotel (+4 rooms)
105 parking spaces 121 parking spaces +13,640 SF
+16 parking spaces
Condominiums (160 units) Condominiums (160 units)
225,000 SF 225,000 SF Condominiums
320 parking spaces 318 Parking Spaces -2 parking spaces
Total 688,800 SF 809,840 SF +121,040 SF

1,083 Parking Spaces 1,114 Parking Spaces +31 parking spaces
As discussed in Chapter 2, the Proponent will “bank” 260 of the proposed parking spaces and not
construct them unless demand requires it once the development is in full operation. This will
reduce impervious area by approximately 42,100 square-feet.
1.5 Statutory and Regulatory Standards
The Project will require local, state, and federal approvals.
At the local level, the Proponent will be submitting an application for a Special Permit for a
Planned Development and site plan approval for the hotel on Lot 7 to the Bridgewater Planning
Board in early 2023. A Notice of Intent will also be filed with the Town of Bridgewater
Conservation Commission within the same time period.
The Proponent will also be submitting a Zoning Change to Town Council for the 55+ proposal on
Lot 6 in early 2023. The Proponent expects to submit the relevant applications for the other
buildings to the Town of Bridgewater after 2023. Table 1-1 presents the local permits required for
the Project.
The only state permit anticipated to be required is an Access Permit from MassDOT. This permit
will be applied for at the conclusion of the MEPA process.
At the federal level, the Project will require a National Pollutant Discharge Elimination System
Construction General Permit (NPDES CGP) from the United States Environmental Protection
Agency (EPA). The NPDES program requires that a construction project that will disturb one or
more acres of land and will discharge stormwater into waters of the United States obtain coverage
under a U.S. Environmental Protection Agency (EPA) Construction General Permit to minimize
pollutant runoff from the site.

The NPDES CGP requirements involve: (1) the filing of a Notice of Intent that identifies the general
operator of the site and provides information on the site itself, (2) the development and
implementation of a Stormwater Pollution Prevention Plan with appropriate best management
practices (BMPs) to minimize discharge of pollutants from the site, and (3) the submittal of a
Notice of Termination when the site has achieved final stabilization or stormwater is no longer
being discharged.
Table 1-2 List of Local Permits
Agency Name Permit or Action

Lot 1 Coffee Shop
Town Council Zoning Variance
Planning Board Special Permit for a Planned Development and a Site
Plan Approval or an Amendment to the Existing Permits
for Lot 1
Conservation Commission Notice of Intent and an Order of Conditions
Lot 4 Assisted Living
Town Council Zoning Change
Planning Board Special Permit for a Planned Development and a
Site Plan Approval
Lot 6 55+ Residential Building
Site Plan Approval
Lot 7 Hotel
Site Plan Approval
Lot 7 Condo
Town Council Zoning Amendment
Site Plan Approval
Restaurant
Planning Board Site Plan Approval

Chapter 2
Alternatives Analysis
2.0 ALTERNATIVES ANALYSIS
2.1 Introduction
This chapter presents further information related to the Proponent’s ability to minimize the land
disturbance, tree clearing, and impervious area required by the proposed Project, while
maintaining the scope of the project needed to make it financially viable. It focuses on reducing
potential means to limit the amount of parking on each of the development lots within the
Project.
The overall Project comprises approximately 68.2 acres of land of which 60.5 acres are currently
undisturbed and in a natural condition, most of which is forested. Table 2-1 summarizes the
amount of undisturbed land by development parcel.
Table 2-1 Existing Amounts of Undeveloped Land by Parcel
Disturbed Area Undisturbed Area Total Area

Lot
(ac) (ac) (ac)
1 3.6 1.7 5.3
4 1.2 8.9 10.1
6 0.4 29.9 30.3
7 1.9 18.0 19.9
North 0.6 2.0 2.6
Total 7.7 60.5 68.2
The Preferred Alternative presented in this DEIR will occupy both disturbed and undisturbed
areas. Table 2-2 summarizes the proposed disturbance by development parcel.
Table 2-2 Pre- and Post-Development Disturbed Land Totals
Predevelopment Post Development

Disturbed Area Undisturbed Area Undisturbed Area
Disturbed Area (ac)
(ac) (ac) (ac)
Lot
1 3.6 1.7 3.6 1.7
4 1.2 8.9 6.9 3.2
6 0.4 29.9 7.9 22.4
7 1.9 18 10.9 9.0
North 0.6 2.0 1.4 1.2
Total 7.7 60.5 30.7 37.5
6491/Lakeshore Center Phase 4 2-1 Alternatives Analysis

As can be seen in Table 2-2, the greatest amount of new land disturbance will occur on Lots 6
(7.5 ac), 7 (9.0 ac) and 4 (5.7 ac). Continued development of Lot 1 will not impact any new areas
and the proposed restaurant development on the North Lot will impact only 0.8 ac of undisturbed
area.
Figure 2-1 shows the proposed Project overlaid on an aerial base. Again, as can be seen in the
figure, the greatest amount of new land disturbance and forest clearing will occur on Lots 6, 7,
and 4. Given this, the Proponent has focused efforts to identify potential means of reducing
impacts on these three lots, and to a lesser extent on the northern lot. Lot 1 was not studied as it
is already completely impervious and the proposed Project’s land impacts on that lot will be
insignificant.
In general, the Proponent has focused the analysis on means to reduce impervious area while
maintaining the same proposed development program to be economically viable. While reducing
the program, for example by reducing the size of the number of rooms in the hotel and the
number of units in the proposed residential building on Lot 7, would result in reduced impacts,
the Proponent has already determined that these uses need to be at least the proposed size in
order to be economically viable. In fact, given recent inflation, supply chain issues, and worker
shortages, development costs have increased significantly, making it even more important that
the Proponent maintain at least the proposed scale of development in order to obtain an
adequate financial performance.
2.2 Measures Considered to Reduce Impacts
To reduce land impacts, i.e., the Project footprint, while maintaining the current proposed
development program, the Proponent focused on measures to reduce the area and amount of
associated parking on a per lot basis. In general, the following strategies were considered:
♦ Increasing the height of the buildings to reduce footprint;

♦ The potential for a central parking garage structure to serve multiple lots;
♦ Sharing surface parking among the development lots;
♦ Placing parking underground on each lot;
♦ Placing parking on surface beneath buildings on each lot; and
♦ Banking a portion of the parking during initial construction and constructing it only once
there is a demonstrated demand for it.
2.2.1 Increasing Building Height to Reduce Building Footprint on Lots 6 & 7
As a means of reducing their footprints and impervious area, while maintaining the proposed
program, the Proponent examined the potential to increase the height of the hotel proposed on
Lot 7 and the 55+ residential building on Lot 6. The analysis considered increasing the height of
each building from four to five stories.

Figure 2-1
Aerial View of Proposed Site Plan
In the case of the proposed hotel on Lot 7, the analysis found that the footprint could be reduced
by only approximately 1,500 square feet; however, because the additional floor would require
elevator access and egress stairs, more overall square footage would need to be constructed to
accommodate the same number of rooms. This added square footage translated into an
additional cost of approximately $1,200,000 or $800 per square foot of impervious area
reduction. The Proponent finds this additional cost to be infeasible.
Similarly, study indicates that increasing the height of the 55+ residential building on Lot 6 would
enable the building footprint to be reduced by approximately by 11,700 square feet; however, it
would increase the building’s overall square-footage by approximately 16,600, and increase its
cost by approximately $3,518,000, or approximately $300/square foot of impervious reduction.
Again, the Proponent finds this to be economically infeasible.
2.2.2 Feasibility of Constructing a Central Parking Garage
The Proponent considered the possibility of construction a large central aboveground parking
garage to serve the parking needs of one or more of the development lots but found it to be both
impracticable and economically infeasible.
A central garage would be impracticable because there is no workable location for it to be

constructed. A garage would need to be centrally located among lots 4, 6, and 7 in order to
provide a short enough walk to all of the uses. The central area on the east side of the Lakeshore
Center Drive is constrained by wetlands. Placing it on Lot 4 would preclude that lot’s development
for the proposed assisted living facility. There is insufficient room of Lots 6 & 7 and constructing
a garage on either would be too far from the other use to be practical.
Constructing it on Lots 2 or 3 would displace the parking needed for those existing uses and
require an even larger garage that again would be too far from the developments on Lots 6 and 7
to be practical.
The cost for a large central garage is also prohibitively expensive and could not be supported by
the rents that can be obtained in the Project’s market. A parking garage is estimated to cost
approximately $24,000 per space compared to just $8,000 per space for surface parking. A central
garage having 700 spaces to serve most of the needs of Lots 6 and 7 would therefore cost
approximately an additional $11,000,000, which is prohibitively expensive
2.2.3 Feasibility of Shared Surface Parking
The Proponent also considered using shared surface parking among the various uses on the
different lots, but this too has been found to be impractical. There are no logical uses on the
proposed development lots that will have opposite time of day parking demand, say for example,
in the way residential and office would. All of the proposed uses on Lots 6 and 7 are in a sense
“residential” with full overnight parking demand. All of the uses, particularly the condominiums
and hotel on Lot 7 and the 55+ residential building on Lot 6 would be far less attractive from a
marketing perspective were parking not available immediately at their sites. Therefore, while it

may be feasible for some overnight parking to occur on the surface lots on Lots 2 and 3, it is not
practical to plan to rely on that approach. Based on this research, shared parking among the uses
has been dismissed as a viable means of reducing the overall number of parking spaces needing
to be constructed.
2.2.4 Feasibility of Underground Parking
The Proponent considered the potential to construct one or more underground parking garages
but determined that it would be both impracticable and economically infeasible.
The average cost per parking space in an underground parking lot ranges from $25,000 to
$50,000, depending on site-specific conditions, with costs increasing with each level added.
Structural support needed for below-ground garages can substantially drive costs upward, as up
to 70 percent of a parking garage’s cost is tied into the structural system. This is necessary to
support buildings above the parking garage.
Below grade parking also must address structural issues related to groundwater and shoring. For
the proposed buildings on Lots 6 and 7, high groundwater levels (as little as 42 inches to 52 inches
below the ground surface) make underground garage construction impracticable.
2.2.5 Feasibility of Podium Parking with Building Above on Lots 6 & 7
The Proponent considered the potential for constructing the hotel proposed on Lot 7 and the 55+
residential building proposed for Lot 6 on a podium with parking beneath the building in order to
reduce the overall impervious footprint.
Costs for indoor parking are estimated at approximately $45,000 to $55,000 per space compared
to just $8,000 to $12,000 per space for outdoor parking for the Lot 7 hotel. The building would
need a wider first floor to accommodate two rows of parking having a 24-foot wide drive aisle. It
was estimated that approximately 50 spaces could be put beneath the building, but that the
added cost would be in the range of $1,650,000 and $2,3500,000, again making this option
economically infeasible.
If parking were to replace the currently planned public space on the first floor of the 55+
residential building on Lot 6, the building could accommodate approximately 200 indoor spaces.
Beyond that would require expanding the podium footprint. A 5th story would also be required.
The cost impact for the additional indoor spaces, including the surface parking deduct is similar
to that for the hotel, estimated to be $33,0000 - $47,000 per space. To increase the currently
planned 79 indoor parking count to 221, the cost impact would be in the range of $4,686,000 to
$6,674,000, plus the added expense of the 5th floor (estimated to be approximately $3,518,400);
therefore, the total added expense would be in the range of $8,000,000 to $10,000,000. This is
not economically feasible for the Proponent.

2.2.6 Parking Space Banking
Based upon further analysis of projected parking demand, the Proponent has determined that the
level of parking proposed could potentially be reduced, which would in turn lead to reduced
amounts of impervious area.
Table 2-3 presents a summary of the proposed parking.
Table 2-3 Parking Spaces Summary
Potential
Current Number of Reduction
ENF Number Reduction in
Lot Number Spaces Required Potential
Proposed Impervious1
Proposed by Zoning
(square feet)
1 19 19 19 0
4 261 249 180 -60 9,720
6 314 348 245 -100 16,200
7 425 439 332 -100 16,200
North 64 59 59 0 0
Total 1,083 1,114 835 260 42,100
1. Based on 162 square feet per space.
As shown in the table, there is the potential to reduce parking by approximately 260 spaces which
would reduce impervious area by almost an acre (42,100 square feet, 0.96 acres). Figures 2-2
through 2-4 show the location of the potential parking reductions on Lots 4, 6, and 7, respectively.
The Proponent proposes to seek approval for the current number of proposed spaces (1,114) but
will only build 854 initially and will “bank” the remaining 260 spaces, which will be built only if
demand requires it.
2.3 Summary
The Proponent proposes to bank 260 parking spaces and construct them only if necessary to meet
demand. While the Proponent’s market research and experience at the site indicates that parking
demand is greater than what is required by the Bridgewater Zoning regulations, the Proponent is
willing to lower the amount of parking to the minimum amount needed to serve the various uses
based on actual experience.

Figure 2-2
Lot 4 Potential Parking Reduction
Figure 2-3
Figure 2-4
Chapter 3
Land Alteration, Open Space, and Farmland Conversion

3.0 LAND ALTERATION, OPEN SPACE, AND FARMLAND CONVERSION
3.1 Introduction
This Chapter responds directly to the Secretary’s Certificate on the ENF which required further
detail on the Project’s land alteration impacts and the amount of impervious area to be created.
3.2 Land Alteration
The overall Site consists of both previously disturbed/altered areas that are developed or
landscaped as well as undeveloped areas that are largely forested and/or wetland. Overall, the
proposed new development will alter 64.2-acres, of which 60.5 acres is currently undisturbed.
Table 3-1 summarizes the proposed land alteration for the Project by category.
Table 3-1 Land Alteration Summary
Lot 1: Lot 4: Lot 6: Lot 7: Northern Total

Site Feature
Area (ac) Area (ac) Area (ac) Area (ac) Lot (ac) Area (ac)
Total Land Area 1.31 10.06 30.3 19.9 2.6
Total Amount of Land Altered 0.8 7.0 8.0 10.9 1.15 27.85
Building 0.04 0.9 1.80 1.64 0.14 4.52
Parking and other paved areas 0.33 2.4 2.2 3.8 0.70 9.43
Above Ground Stormwater
0.19 1.1 1.0 1.2 0 3.49
Features
Landscaping 0.24 2.6 3.0 4.26 0.31 10.41
Undeveloped Areas Remaining 0.5 3.06 22.3 9.0 1.45 36.31
1
Total land area for Lot 1 is 5.3 acres. Total area for this redevelopment portion is 1.3 acres.
The Project proposes development on previously undisturbed areas on Lots 4, 6, and 7.

Table 3-2 summarizes the type and amount of alteration in these areas.
Table 3-2 Alteration of Previously Undisturbed Areas
Site Feature Area (acres)

Total Amount of Currently Undisturbed
25.9
Land to be Altered (Lots 4, 6, & 7)
Buildings 4.34
Internal Roadways 0
Parking and other paved areas 8.4
Above Ground Stormwater Features 3.3
Landscaping 7.86
Undeveloped areas 34.36
Wastewater 0
6491/Lakeshore Center Phase 4 3-1 Land Alteration

As shown in Table 3-2, the Project will convert approximately 12.74 acres of previously
undisturbed area to impervious (building and parking lots). As discussed in Chapter 7, the
proposed stormwater management system will be designed such that the peak rate will be
90 percent of the existing condition, and a reduction in stormwater volume by ten percent will
be achieved using infiltration methods to ensure recharge of the aquifer is accomplished. Water
quality mitigation using various Best Management Practices (BMPs) will be used to achieve
compliance with Massachusetts Stormwater Management Standards and protect the wetland
resource areas and the drinking water aquifer of the neighboring Town of Raynham.
The grading of the Project Site for construction will require the removal of existing trees and
disturbance of vegetation and soils. Table 3-3 depicts the anticipated amount of tree clearing
included in the proposed Project. See Figures 3-1 through 3-6 for conceptual grading plans of
the development lots.
Table 3-3 Tree Clearing Summary
Location Area (acres)

Lot 1 0
Lot 4 4.7
Lot 6 7.5
Lot 7 9.4
Northern Lot 0.6
Total 22.2
3.2.1 Mitigation Measures to Reduce Land Alteration
As discussed in Chapter 2, the Proponent considered a number of design alternatives to limit the
Project’s overall footprint; however, given the market location of the Project away from dense
urban areas, it is economically infeasible to undertake the two primary means that would
otherwise be available to significantly reduce the Project area, namely constructing either above
or below-ground parking garages. One mitigation measure was identified which is to initially
bank approximately 260 parking spaces, thereby reducing impervious area by nearly an acre.
Although, it is not feasible to significantly reduce the Project’s footprint from what was
presented in the ENF without sacrificing the Project’s program goals, it should be noted that the
initial design for the Project reflects a thoughtful approach that completely avoids wetland filling
and which has no disturbance within the 25-foot buffer zone around the wetlands. Retaining
walls are planned on Lots 1, 6, 7, and the North Lot to prevent limit the Project footprint and
avoid encroachment into the 25-foot buffer zone.

Figure 3-1
Lot 1 Grading Plan
Figure 3-2
Lot 4 Grading Plan
Figure 3-3
Lot 6 Grading Plan
Figure 3-4
Lot 7 Grading Plan
Figure 3-5
Lot 7 Grading Plan
Figure 3-6
Northern Lot Grading Plan
3.3 Open Space
The proposed Project will leave approximately 33.5 acres of the overall Lakeshore Center
undeveloped. Figure 3-7 shows the Project area to remain undisturbed. To enhance the long-
term protection of these undeveloped areas, the Proponent is investigating the
feasibility/practicality of placing a deed restriction, or similar land preservation mechanism, on
the property to restrict future development from occurring. Figure 3-8 depicts the potential
areas for conservation restrictions.
Table 3-4 Potential Land Preservation Areas (Wetlands)
Location Area (acres)

Lot 1 1.2
Lot 4 2.9
Lot 6 21.1
Lot 7 8.3
Total 33.5
3.4 Agricultural Lands
In their comment letter on the ENF, the MassDEP observed that the MassGIS website
(“MassMapper”) indicates that portions of the site include agricultural soils. The Secretary’s
Certificate requested that the Proponent indicate whether the Proponent as owner of the land
has benefited from any tax savings pursuant to MGL 61A Assessment of Taxation of Agricultural
and Horticultural Land. The Proponent has not, and it is not applicable to the Project site.

Figure 3-7
Project Area to Remain Undisturbed
Figure 3-8
Potential Conservation Restriction Areas
Chapter 4
Transportation
4.0 TRANSPORTATION
This Chapter provides a summary of the operational analysis of the study area intersections and
provides information in response to MassDOT’s comments submitted on the ENF. The capacity
analysis results presented reflect the Preferred Build alternative consisting of a 6,000 square
foot (sf) restaurant, an 1,800-sf café with a drive-through window, 150 assisted living units,
225 senior housing units, a 106-room hotel, and 160 condominium units.
4.1 Project Description
The Project is an expansion of the existing Lakeshore Center properties located on Pleasant
Street (Route 104), approximately 0.5 miles west of Route 24, as shown in Figure 4-1. The
project site includes seven lots in the central area (Central Lots 1-7) and one lot on the northern
area (Northern Lot). Of the central area, Lots 2, 3, and 5 are already developed and do not
include any expansion or proposed change. The currently proposed Lakeshore Center
development phase consists of the construction on Central Lots 1, 4, 6, and 7 and the Northern
Lot. Central Lot 1 is proposed to add an 1,800-sf café with a drive-through window; Central Lot 4
is proposed to include 150 assisted living residential units; Central Lot 6 is proposed to include
225 55+ residential units; Central Lot 7 is proposed to include 160 condominium units and 106
hotel rooms; and the Northern Lot is proposed to include a 6,000-sf restaurant.
Access to the proposed café on Central Lot 1 would be provided by two new full-access
driveways to the west of the Residence Inn driveway on the south side of Pleasant Street. For
the purposes of traffic assessment, the new driveways on Central Lot 1 have been analyzed as a
single access location. Access to Central Lots 4 and 6 would be provided by the existing full-
access Lakeshore Center driveway on the south side of Pleasant Street. Access to Central Lot 7
would be provided by the existing full-access Lakeshore Center driveway on the south side of
Pleasant Street and a proposed full-access driveway connecting to Pleasant Street at Old
Pleasant Street. No changes to the Old Pleasant Street angled parking or existing circulation are
proposed as part of the project. Access to the Northern Lot would be provided via three new
full-access driveways on the north side of Pleasant Street. For the purposes of traffic
assessment, the new driveways for the Northern Lot have been analyzed as two access
locations, one of which is located across from Old Pleasant Street.
6491/Lakeshore Center Phase 4 4-1 Transportation

Figure 4-1
Site Location
4.2 Study Methodology
As noted in the comments provided by MassDOT, the traffic assessment included an evaluation
of the quality of traffic flow utilizing capacity analysis at the study area intersections during the
weekday morning and weekday afternoon peak hours under 2022 Existing, 2029 No Build
(without project) and 2029 Build (with project) conditions. Intersection capacity analyses were
conducted using the Synchro capacity analysis software at the study area intersections under
the 2022 Existing, 2029 No Build and 2029 Build peak hour traffic conditions. The analysis is
based on Synchro capacity analysis methodologies and procedures contained in the Highway
Capacity Manual, 6th Edition (HCM).
Based on a review of the anticipated traffic-generating characteristic of the proposed project,

the following study area intersections, as shown in Figure 4-1, were included:
♦ North Main Street (Route 104) at Pleasant Street/Elm Street E.
♦ Pleasant Street at Residence Inn Driveway
♦ Pleasant Street at Lakeshore Center
♦ Pleasant Street at Old Pleasant Street
♦ Pleasant Street at Lakeside Drive/ Fruit Street
♦ Pleasant Street at Route 24 Southbound Ramps
♦ Pleasant Street at Route 24 Northbound Ramps
The traffic analysis was conducted in three steps. The first step includes an inventory of existing
traffic conditions within the project study area. This included a field visit to document the
existing intersection and roadway geometries and posted speed limits. A safety analysis
including a crash summary for the study area intersections and an evaluation of the available
sight distance at the proposed driveway locations was also completed as part of the existing
conditions inventory.
The second step of the Transportation Impact Study (TIS) builds upon the data collected as part
of the existing conditions inventory to establish the future baseline traffic conditions. This step
includes coordination with the Town and regional planning agency to forecast the existing traffic
conditions to future baseline conditions for the seven-year study horizon (2022 to 2029).
The third step for the TIS evaluates traffic impacts directly related to the project site and
determines if any potential mitigation measures would be appropriate.

4.3 2022 Existing Conditions
4.3.1 Roadway Network
A brief description of the principal roadways and public transportation providing access to the
project site is presented below.
Pleasant Street (Route 104)
Pleasant Street generally runs in an east-west direction through the Town of Bridgewater.
Pleasant Street is classified as an urban minor arterial under the Town of Bridgewater
jurisdiction with the exception of the portion of roadway that is located adjacent to the Route
24 ramps, which is under MassDOT jurisdiction. Pleasant Street provides an approximately
12-foot-wide travel lane in each direction and approximately 8-foot-wide shoulders on both
sides of the roadway in the vicinity of the project site. An approximately 5-foot-wide sidewalk is
provided on the northern side of Pleasant Street for the entirety of the study area and on the
southern side of Pleasant Street between Summit Drive and Lakeshore Center. The posted
speed limit on Pleasant Street in the vicinity of the project site is 40 miles per hour (mph).
North Main Street (Route 104)
North Main Street (Route 104) generally runs in a north-south direction and is classified as an
urban minor arterial under the Town of Raynham jurisdiction. North Main Street (Route 104)
extends from the Bridgewater/Raynham Town Line southerly through the Town of Raynham.
North Main Street (Route 104) provides an approximately 12-foot-wide travel lane in each
direction with an approximately 4-foot-wide sidewalk on the west side and approximately
8-foot-wide bicycle lanes on both sides of the roadway. The posted speed limit on North Main
Street is 40 mph.
Lakeshore Center
Lakeshore Center runs in a general north-south direction and is classified as a local roadway. The
roadway provides access to offices and an apartment complex. Lakeshore Center provides an
approximately 12-foot-wide travel lane in each direction with approximately 7-foot-wide
shoulders and 5-foot-wide sidewalks on both sides of the roadway.
Old Pleasant Street
Old Pleasant Street runs in an east-west direction from Pleasant Street to Fruit Street. Old
Pleasant Street is approximately 36 feet wide and includes angled parking along the northern
side of the roadway. No pavement markings are provided on Old Pleasant Street.

Lakeside Drive
Lakeside Drive generally runs in a north-south direction and is classified as a local road under
Town of Bridgewater jurisdiction. Lakeside Drive is approximately 26 feet wide providing two-
way travel. Pavement markings are generally not provided on Lakeside Drive with the exception
of the intersection with Pleasant Street. Sidewalks are provided on the Lakeside Drive approach
to the intersection of Pleasant Street, measuring approximately six feet in width. Lakeside Drive
provides access to residential land uses and the posted speed limit is 20 mph.
Fruit Street
Fruit Street generally runs in a north-south direction and is classified as a local road under the
Town of Bridgewater jurisdiction. Fruit Street provides an approximately 12-foot-wide travel
lane in each direction and provides access to industrial land uses. There is no posted speed limit
on Fruit Street.
Route 24 (Fall River Expressway)
Route 24 runs in a general north-south direction through southeastern Massachusetts. Route 24

is classified as an urban principal arterial and the ramps connecting to Pleasant Street are
classified as urban minor arterials. Route 24 is under MassDOT jurisdiction and provides access
to the project site via a signalized partial cloverleaf interchange at Exit 24.
4.3.2 Signalized Intersections
Pleasant Street at Route 24 Southbound Ramps
The signalized intersection of Pleasant Street at Route 24 is a T-shaped intersection with

Pleasant Street forming the eastbound and westbound approaches and the Route 24
Southbound Ramps forming the southbound approach. The Pleasant Street eastbound approach
consists of a shared left-turn/through-lane. The Pleasant Street westbound approach consists of
a through-lane and a channelized right-turn lane. The Route 24 Southbound Ramps approach
consists of an exclusive left-turn lane and a channelized right-turn lane under yield control.
The intersection is controlled by an actuated, coordinated traffic signal with two phases for
vehicular traffic including a phase for eastbound and westbound traffic and a phase for
southbound traffic. Pedestrian traffic is accommodated by a push-button activated exclusive
pedestrian phase that control the crosswalks located across the Route 24 Southbound Ramps.
Pleasant Street at Route 24 Northbound Ramps
The signalized intersection of Pleasant Street at Route 24 is a T-shaped intersection with

Pleasant Street forming the eastbound and westbound approaches and the Route 24
Northbound Ramps forming the northbound approach. The Pleasant Street eastbound approach
consists of a through-lane and a channelized right-turn lane. The Pleasant Street westbound

approach consists of a shared left-turn/through lane and a through-lane. The Route 24
Northbound Ramps approach consists of an exclusive left-turn lane and a channelized right-turn
lane under yield control.
The intersection is controlled by an actuated, coordinated traffic signal with three phases for
vehicular traffic including a lead phase for westbound traffic, a phase for eastbound and
westbound traffic and a phase for northbound traffic.
4.3.3 Unsignalized Intersections
Pleasant Street/North Main Street (Route 104) at Elm Street East
The unsignalized intersection of Pleasant Street/North Main Street (Route 104) at Elm Street
East is a T-shaped intersection with Pleasant Street forming the southbound approach, North
Main Street (Route 104) forming the northbound approach, and Elm Street East forming the
eastbound approach. All approaches consist of a single lane permitting left and right turn
movements. The eastbound Elm Street East approach operates under stop control.
Pleasant Street at Residence Inn Driveway
The unsignalized intersection of Pleasant Street at Residence Inn Driveway is a T-shaped

intersection with Pleasant Street forming the eastbound and westbound approaches and
Residence Inn Driveway forming the northbound approach. All approaches consist of a single
lane and the northbound Residence Inn Driveway approach operates under stop control.
Pleasant Street at Lakeshore Center
The unsignalized intersection of Pleasant Street at Lakeshore Center is a T-shaped intersection

with Pleasant Street forming the eastbound and westbound approaches and Lakeshore Center
forming the northbound approach. The Pleasant Street eastbound and westbound approaches
each consist of a single lane permitting turn movements. The northbound Lakeshore Center
approach consists of an exclusive left-turn lane and an exclusive right-turn lane and operates
under stop control.
Pleasant Street at Old Pleasant Street
The unsignalized intersection of Pleasant Street at Old Pleasant Street is a T-shaped intersection
with Pleasant Street forming the eastbound and westbound approaches and Old Pleasant Street
forming the northbound approach. All approaches consist of a single lane permitting turn
movements.

Pleasant Street at Lakeside Drive/Fruit Street
The unsignalized intersection of Pleasant Street at Lakeside Drive/Fruit Street is a four-way

intersection with Pleasant Street forming the eastbound and westbound approaches, Lakeside
Drive forming the southbound approach, and Fruit Street forming the northbound approach. All
approaches consist of a single lane permitting left and right turn movements. The southbound
Lakeside Drive approach and northbound Fruit Street approach operate under stop control.
4.3.4 Traffic Volume Data
To assess peak hour traffic conditions, manual turning movement counts (MTMC) were
collected on Thursday, April 28, 2022, from 7:00 AM to 9:00 AM and from 4:00 PM to 6:00 PM.
The four highest consecutive 15-minute intervals during each of these count periods constitute
the peak hours that are the basis of the traffic analysis provided in this report. Based on a
review of the peak period traffic data, the weekday morning peak hour at the study area
intersections was identified as 7:00 AM to 8:00 AM and the weekday afternoon peak hour was
identified as 4:00 PM to 5:00 PM. During the MTMC conducted on April 28, 2022 the Fruit Street
roadway was closed during the weekday morning and weekday afternoon peak periods.
Therefore, McMahon collected supplemental turning movement data for Fruit Street on
November 3, 2022 during the peak hour intervals identified above when Fruit Street was open.
The results of the MTMCs are tabulated by 15-minute periods and are provided in Attachment
A.
No bicycles were recorded at the study area intersections during the data collection efforts of
the project. Thereby, no volume or speed data was available to review.
Automatic traffic recorder (ATR) data was obtained on Pleasant Street, just west of Lakeshore
Center for a 48-hour from Wednesday, April 27 to Thursday, April 28, 2022. The ATR data is
summarized in Table 4-1 and provided in Attachment A.
Table 4-1 ATR Summary
Vehicle Speed Limit

Roadway Direction ADT1 HV%2
Speeds 3
(MPH)
Pleasant Street (Route 104)
Eastbound 5,805 2.8% 45 40
West of Lakeshore Center
Westbound 6,245 2.8% 44 40
Total 12,050 2.8%
1 Average daily traffic volumes in vehicles per day (VPD)
2 Percentage of heavy vehicles
3 Based on 85th percentile speeds

As shown in Table 4-1, the average daily traffic (ADT) on Pleasant Street, west of Lakeshore
Center is approximately 12,050 (5,805 eastbound vehicles and 6,245 westbound vehicles)
vehicles per day (vpd). The 85th percentile speeds on Pleasant Street were measured to be
45 and 44 in the eastbound and westbound directions, respectively.
4.3.5 Traffic Volume Adjustments
To account for seasonal variation in traffic volumes, the MassDOT 2019 Weekday Seasonal
Adjustment Factors were reviewed. Based on the data, traffic volumes collected during the
month of April along urban principal arterial, urban minor arterial roadways, and urban collector
roadways are higher than the average month. To present a conservative analysis, the April
volumes were not adjusted downwards to reflect an average month.
Based on recent guidance from MassDOT, traffic count data collected on or after March 1, 2022
is not subject to COVID-19 adjustments. Therefore, no COVID-19 adjustment was applied to the
peak hour volumes.
The 2022 Existing weekday morning and weekday afternoon peak hour traffic volumes at the
study area intersections are presented in Figures 4-2 and 4-3, respectively.
4.3.6 Multi-Modal Accommodations
An inventory of the multimodal access accommodations in the study area was performed by
McMahon on October 20, 2022. The study area in primarily access by passenger vehicles but
does provide some infrastructure to support other modes of transportation. A bituminous
concrete sidewalk is provided on the north side of Pleasant Street for the entirety of the study
area. A concrete sidewalk is provided on the south side of Pleasant Street from Summit Drive in
the west to Lakeshore Center in the east. Crosswalks are provided across the Route 24
Southbound ramps, across Pleasant Street just west of Lakeshore Center, across the Residence
Inn Driveway, across Pleasant Street just east of Summit Drive, and across Summit Drive. Push
button activated flashing light signage is provided for the crosswalk across Pleasant Street just
east of Summit Drive.
Approximately 7- to 8-foot-wide bicycle lanes are provided on North Main Street south of Elm
Street East. Shoulders, approximately seven to eight feet in width, are provided along Pleasant
Street from Elm Street East to Lakeside Drive/Fruit Street. Based on data collected, there is
limited existing bicycle activity within the study area. Bicycles traveling along the Pleasant Street
segment of the study area would be expected to travel within the existing shoulders along the
roadway. East of the Route 24 ramps, the shoulders on Pleasant Street are significantly
narrowing, and bicycle travel would be expected to occur within the vehicular travel lanes.
Public transportation in Bridgewater is provided by the Massachusetts Bay Transportation

Authority (MBTA) and the Brockton Area Transit Authority (BAT). The MBTA
Middleborough/Lakeville Commuter Rail Line provides access to Bridgewater at the Bridgewater

Figure 4-2
2022 Existing Weekday Morning Peak Hour Traffic Volumes
Figure 4-3
2022 Existing Weekday Afternoon Peak Hour Traffic Volumes
State University College Campus approximately 5.5 miles east of the project site. The
Middleborough/Lakeville Line provides service from South Station in Boston to Lakeville seven
days a week. BAT provides a Dial-A-Ride paratransit program that operates in Bridgewater,
providing transportation for qualified individuals include elderly and disabled population. No
regularly scheduled or fixed route public transportation services are provided in the immediate
vicinity of the project site.
McMahon contacted the Greater Attleboro Taunton Regional Transit Authority (GATRA) and
Brockton Area Transit Authority (BAT) to determine potential multimodal connections in and
around the project site. McMahon had a meeting with BAT representatives on November 14,
2022. During the meeting, BAT noted that there are no current plans to expand fixed route
service to this area. Given the distance of the project site from existing transit services,
expanding fixed route service to the study area does not appear to be feasible without an
identified funding source and potential collaboration with GATRA. Service to the project site
through the Dial-a-Bat program was discussed for the proposed assisted living and 55+
residential developments. A request for covered pick-up and drop-off areas was made for the
assisted living and 55+ buildings. This type of area is already proposed for the 55+ building and
the project team is committed to the inclusion of a covered pick-up and drop-off area for the
assisted living facility as well. No conversations have been made with GATRA as of December 2,
2022.
4.3.7 Safety Evaluation
Crash data was obtained from MassDOT for the most recent five-year period available to
understand the existing safety operations of the study area intersections. This included a review
of crash data from 2015 through 2019. A summary of the crash data is presented in
Attachment A.
The crash rates at the study area intersections were calculated to determine whether the crash
frequencies at the study area intersections were unusually high given the travel demands at
each location. The intersection crash rate is expressed in crashes per million entering vehicles
(MEV). The calculated rate was then compared to the average rate for signalized and
unsignalized intersections statewide and within MassDOT District 5. For signalized intersections,
the statewide average crash rate is 0.78 crashes per MEV and the MassDOT District 5 crash rate
is 0.75 crashes per MEV. For unsignalized intersections, the statewide average and MassDOT
District 5 crash rate is 0.57 crashes per MEV. The table below includes a summary of the
calculated crash rates for each intersection.
The crash rates at each study area intersection are summarized in Table 4-2 below.

Table 4-2 Crash Rate Summary
Intersection Control Crash Rate

Pleasant Street at North Main Street/Elm Street East Unsignalized 0.13
Pleasant Street at Residence Inn Driveway Unsignalized 0.00
Pleasant Street at Lakeshore Center Unsignalized 0.09
Pleasant Street at Old Pleasant Street Unsignalized 0.00
Pleasant Street at Lakeside Drive/Fruit Street Unsignalized 0.82
Pleasant Street at Route 24 Southbound Ramps Signalized 0.38
Pleasant Street at Route 24 Northbound Ramps Signalized 0.30
As shown in Table 4-2, the only intersection shown to have a crash rate higher than the
MassDOT District 5 and statewide averages is Pleasant Street at Lakeside Drive/Fruit Street. The
unsignalized intersection of Pleasant Street at Lakeside Drive/Fruit Street is reported to have
experienced a total of 20 crashes during the five-year period analyzed. Of the 20 reported
crashes at the intersection, nine crashes were rear-end collisions, six crashes were angle
collisions, three crashes were sideswipe collisions, and two crashes were single vehicle
collisions. Five of the reported crashes resulted in personal injury and the remaining 15 crashes
resulted in property damage only.
None of the study area intersections are listed as a Highway Safety Improvement Plan (HSIP)
cluster.
The study area intersections and roadway approaches were also reviewed using the IMPACT
Safety Analysis Tools. The network screening, using the Network Screening Risk-Based and
Crash-Based tools, provides the ability to visualize locations of top crash segments which exceed
the predicted number of crashes for a given roadway segment. The information is based on
crashes recorded between 2013 and 2017. Table 4-3 below summarizes the risk factors
identified for the study area roadways.

Table 4-3 Risk-Based Screening Summary
Crash Statewide Ranking1

Risk Factor Primary Risk Site Secondary Risk Site
Bicyclist Related N/A N/A
Distracted Driving N/A Pleasant St at Route 24 SB Ramps
Pleasant St at Route 24 NB Ramps
Impaired Driving N/A Lakeside Drive
Fruit Street
Old Pleasant Street
Route 24 SB Ramps
Pleasant St at Route 24 Ramps
Route 24 NB Ramps
Intersection (In-Development) N/A N/A
Lane Departure N/A Pleasant St at Route 24 NB Ramps
Motorcycle N/A Pleasant St (Route 104)
Route 24 SB Ramps
Route 24 NB Ramps
Fatal and Injury N/A N/A
Occupant Protection N/A N/A
Older Driver N/A Pleasant St (Route 104)
Route 24 SB Ramps
Route 24 NB Ramps
Pedestrian Related N/A N/A
Speeding N/A N/A
Truck Related N/A N/A
Young Driver N/A N/A
1
MassDOT Impact Portal
None of the study area intersections or approach roadways have been identified as primary risk
sites or part of the Top 5 or Next 10 for crashes based on the Network Screening-Crash Based
tool.
4.3.8 Field Calibration
To confirm that the existing field conditions are consistent with the outputs from the Synchro
capacity analysis software, a field gap acceptance study and delay study were conducted at the
intersection of Pleasant Street at North Main Street/Elm Street East on Thursday, November 3,
2022. The gap acceptance study and delay study were each conducted for a 30-minute period
during the weekday afternoon.

Gap Acceptance Study
The gap acceptance study was conducted to measure the shortest gaps that drivers travelling
southbound turning onto Pleasant Street were willing to accept. These gaps were compared to
the default values in the Highway Capacity Manual, 6th Edition (HCM). During the study period,
vehicles turning onto Pleasant Street from Elm Street East were observed to accept gaps less
than 5.5 seconds, which is smaller than the HCM default values.
Delay Study
The delay study included measuring the number of queued vehicles at the stop-controlled Elm
Street East southbound approach to Pleasant Street every 15 seconds for a 30-minuate
afternoon period. A review of the delay study determined that the average delay for the
approach was 29.2 seconds.
To better estimate the vehicle operations at the intersection of Pleasant Street at North Main
Street/Elm Street East, the Synchro capacity analysis was calibrated to reflect the delay
measured in the field using a critical gap of 5.6 seconds for left and right turns. These critical
gaps are greater than the minimum accepted gaps and are consistent with the observed gaps
during the gap acceptance study. The critical gaps of 5.6 seconds were also applied to the
southbound approach at the Lakeside Drive intersection with Pleasant Street/Fruit Street.
4.3.9 2022 Existing Capacity Analysis
This section describes the overall quality of the traffic flow at the study area intersections during
the weekday morning and weekday afternoon peak hours under 2022 Existing conditions. As a
basis for this assessment, intersection capacity analysis was conducted using Synchro capacity
analysis software at the study area intersections. The analysis is based on Synchro capacity
analysis methodologies and procedures contained in the HCM, which is summarized in
Attachment A.
The Synchro capacity analysis results of the study area intersections for the weekday morning
and weekday afternoon peak hours under 2022 Existing conditions are summarized in Table 4-4
below. The overall intersection capacity analysis results are summarized for the signalized study
area intersections and the critical stop-controlled results are summarized for the unsignalized
study area intersections. A more detailed summary of the capacity analysis for each study area
intersection and queue graphics are provided in Attachment A.

Table 4-4 2022 Existing Capacity Analysis Summary
Intersection Peak Hour Movement LOS1 Delay2 V/C or ICU3

Pleasant Street/North Main Street AM C 19.9 0.49
SB - LR
at Elm Street East PM D 29.8 0.62
Pleasant Street AM C 16.0 0.07
NB - LR
at Residence Inn Driveway PM B 13.5 0.02
NB - L
at Lakeshore Center PM C 24.6 0.07
Pleasant Street AM B 14.8 0.03
NB - LR
at Old Pleasant Street PM B 13.2 0.04
NB - LTR
at Lakeside Drive/Fruit Street PM B 11.6 0.02
Pleasant Street AM A 8.8 0.72
Overall
at Route 24 Southbound Ramps PM B 14.0 0.81
Overall
at Route 24 Northbound Ramps PM A 4.4 0.87
1 Level-of-Service
2 Average vehicle delay in seconds
3 Volume to capacity ratio for unsignalized intersections and intersection capacity utilization ratio for signalized intersections
As shown in Table 4-4, the critical stop-controlled movements all at unsignalized study area
intersections are shown to operate at LOS D or better under 2022 Existing conditions during the
weekday morning and weekday afternoon peak hours. The signalized intersections are shown to
operate at overall LOS B or better under 2022 Existing conditions during the weekday morning
and weekday afternoon peak hours.
4.4 2029 No Build Conditions
4.4.1 Background Traffic Growth
To determine future traffic demands on the study area roadways and intersections, the 2022
Existing traffic volumes were projected to the future-year 2029 based on general growth and
other planned development projects, independent of the proposed project in the study area.
To project the existing 2022 traffic volumes into the future-year 2029, the Old Colony Planning
Council (OCPC) was contacted to establish the appropriate growth rate for the study area. OCPC
recommended a growth rate of 1.0 percent per year within the study area for the analysis of
future conditions.

The Town of Bridgewater was contacted to determine any other developments in the area that
would be anticipated to impact traffic volumes within the study area. No other developments
were identified.
The resulting 2029 No Build weekday morning and weekday afternoon peak hour traffic volumes
are presented in Figures 4-4 and 4-5, respectively.
4.4.2 Future Roadway Improvements
Based on discussions with the Town of Bridgewater and a review of available MassDOT project
information, no future town, state, or federally funded roadway improvement projects are
currently proposed in the vicinity of the project site that would be expected to impact traffic
volumes or operations.
4.4.3 2029 No Build Capacity Analysis
The Synchro capacity analysis results of the study area intersections for the weekday morning
and weekday afternoon peak hours under the 2029 No Build conditions are summarized in Table
4-5. The overall intersection capacity results are summarized for the signalized study area
intersections and the critical stop-controlled results are summarized for the unsignalized study
area intersections. A more detailed summary of the capacity analysis for each study area
intersection and queue graphics are provided in Attachment A.
Table 4-5 2029 No Build Capacity Analysis Summary

SB - LR
at Elm Street East PM E 35.8 0.70
NB - LR
at Residence Inn Driveway PM B 14.4 0.02
NB - L
at Lakeshore Center PM D 27.8 0.07
NB - LR
at Old Pleasant Street PM B 13.8 0.04
NB - LTR
Overall
Overall
1 Level-of-Service

Figure 4-4
2029 No Build Weekday Morning Peak Hour Traffic Volumes
Figure 4-5
2029 No Build Weekday Afternoon Peak Hour Traffic Volumes
intersections are shown to operate at LOS E or better under 2029 No Build conditions during the
weekday morning and weekday afternoon peak hours. The signalized intersections are shown to
operate at overall LOS B or better under 2029 No Build conditions during the weekday morning
and weekday afternoon peak hours.
4.5 2029 Build Conditions
To evaluate the projected impacts to the study area roadways and intersections, trips associated
with the proposed project were added to the 2029 No Build volumes to determine the 2029
Build (with project) traffic volumes. A discussion of the estimation of project site traffic is
provided below.
4.5.1 Trip Generation
To estimate the number of vehicle trips associated with the proposed Lakeshore Center Phase IV
development, the Institute of Transportation Engineers (ITE) publication Trip Generation
Manual, 11th Edition was used. Vehicles trip estimates for the project were developed using
Land Use Code (LUC) 932 (High-Turnover Sit-Down Restaurant), LUC 937 (Coffee/Donut Shop
with Drive-Through Window), LUC 254 (Assisted Living), LUC 252 (Senior Adult Housing –
Multifamily), LUC 310 (Hotel), and LUC 221 (Multifamily Housing Mid-Rise, Not Close to Rail
Transit). These references establish vehicle trip rates (expressed in trips per square foot of gross
floor area or trips per unit) based on actual traffic counts conducted at similar types of existing
land uses.
Not all trips to commercial land uses such as the proposed coffee shop and restaurant are
considered new trips. A portion of the total trips attracted to these types of uses would be
expected to come from vehicles already traveling within the study area network, which are
considered pass-by trips. For pass-by trips, ITE’s Trip Generation Handbook, 3rd Edition, was
referenced for LUC 934 (Fast-Food Restaurant with Drive-Through Window) and LUC 932 (High-
Turnover (Sit-Down) Restaurant) to estimate the pass-by trips associated with the project. ITE
does not provide pass-by trip data for LUC 937, so pass-by data for LUC 934 was used instead.
Based on ITE data, approximately 50 percent of the weekday morning trips and 55 percent of
the weekday afternoon trips to the proposed coffee shop could be attributed to pass-by trips.
Based on LUC 932, approximately 43 percent of the weekday afternoon peak hour trips to the
proposed restaurant could be attributed to pass-by trips. ITE does not provide weekday
morning pass-by data for LUC 932; therefore, the weekday afternoon rate was applied to the
weekday morning peak hour.
A summary of the number of estimated vehicles trips associated with the proposed project is
shown in Table 4-6.

Table 4-6 Trip Generation
Weekday AM Weekday PM
Description Size In Out Total In Out Total
Proposed Restaurant 1
6 ksf 32 26 58 33 21 54
Pass-by Trips -12 -12 -24 -12 -12 -24
Proposed Cafe 2
1.8 ksf 79 76 155 35 35 70
Pass-by Trips -39 -39 -78 -19 -19 -38
Proposed Assisted Living 3
150 beds 16 11 27 14 22 36
Proposed 55+ Residential 4
225 units 15 30 45 32 25 57
Proposed Hotel 5
106 rooms 26 20 46 26 25 51
Proposed Condominiums6 160 units 14 45 59 38 24 62
Total New Trips 131 157 289 147 121 268
1 ITE Land Use Code 932 (High-Turnover Sit-Down Restaurant) trip generation, based on 6,000 sf building.
2 ITE Land Use Code 937 (Coffee/Donut Shop with Drive-Through Window) trip generation, based on 1,800 sf building.
3 ITE Land Use Code 254 (Assisted Living) trip generation, based on 150 beds.
4 ITE Land Use Code 252 (Senior Adult Housing - Multifamily) trip generation, based on 225 units.
5 ITE Land Use Code 310 (Hotel) trip generation, based on 106 rooms.
6 ITE Land Use Code 221 (Multifamily Housing Mid-Rise, Not Close to Rail Transit) trip generation, based on 160 units.
As shown in Table 4-6, the project is estimated to generate approximately 289 new vehicle trips
(131 entering vehicles and 157 exiting vehicles) during the weekday morning peak hour. During
the weekday afternoon peak hour, approximately 268 new vehicle trips (147 entering vehicles
and 121 exiting vehicles) are projected. As noted previously in the ENF, the project is estimated
to result in a total of approximately 4,296 trips per typical weekday (2,148 entering trips and
2,148 exiting trips).
4.5.2 Trip Distribution
The additional traffic estimated to be generated by the proposed development was distributed
onto the study area roadways and intersections based on existing travel patterns, logical travel
routes, and U.S. Census Journey-to-Work data for the Town of Bridgewater. Traffic associated
with the restaurant and café were distributed on the study area roadways based on the existing
travel patterns and logical travel routes. Project trips for the assisted living facility and hotel
were distributed onto the roadways based on Journey-to-Work data for employees of
Bridgewater. The project trips associated with the senior housing and condominiums were
distributed based on Journey-to-Work data for residents of Bridgewater. A summary of the
Journey-to-Work data for employees and residents of Bridgewater is provided in Attachment A.

The arrival and departure patterns for each land use are shown on Figures 4-6 through 4-11. The
resultant new trip assignment for each land use and each peak hour are shown on Figures 4-12
through 4-23. The distributed trips were added to the 2029 No Build peak hour volumes. The
resulting 2029 Build weekday morning and weekday afternoon peak hour traffic volumes are
presented in Figures 4-24 and 4-25, respectively and are also shown in the traffic projection
model provided in Attachment A.

Figure 4-6
Proposed Restaurant Directions of Arrival and Departure
Figure 4-7
Proposed Café Directions of Arrival and Departure
Figure 4-8
Proposed Assisted Living Directions of Arrival and Departure
Figure 4-9
Proposed Senior Housing Directions of Arrival and Departure
Figure 4-10
Proposed Hotel Directions of Arrival and Departure
Figure 4-11
Proposed Condominiums Directions of Arrival and Departure
Figure 4-12
Weekday Morning Peak Hour New Restaurant Trips
Figure 4-13
Weekday Afternoon Peak Hour New Restaurant Trips
Figure 4-14
Weekday Morning Peak Hour New Cafe Trips
Figure 4-15
Weekday Afternoon Peak Hour New Cafe Trips
Figure 4-16
Weekday Morning Peak Hour New Assisted Living Trips
Figure 4-17
Weekday Afternoon Peak Hour New Assisted Living Trips
Figure 4-18
Weekday Morning Peak Hour New Senior Housing Trips
Figure 4-19
Weekday Afternoon Peak Hour New Senior Housing Trips
Figure 4-20
Weekday Morning Peak Hour New Hotel Trips
Figure 4-21
Weekday Afternoon Peak Hour New Hotel Trips
Figure 4-22
Weekday Morning Peak Hour New Condominium Trips
Figure 4-23
Weekday Afternoon Peak Hour New Condominium Trips
Figure 4-24
2029 Build Weekday Morning Peak Hour Traffic Volumes
Figure 4-25
2029 Build Weekday Afternoon Peak Hour Traffic Volumes
4.5.3 2029 Build Capacity Analysis
Intersection capacity analysis was conducted at the study area intersections under the 2029
Build conditions during the weekday morning and weekday afternoon peak hours and are
summarized in Table 4-7 below. The overall intersection capacity results are summarized for the
signalized study area intersections and the critical stop-controlled results are summarized for
the unsignalized study area intersections. A more detailed summary of the capacity analysis for
each study area intersection and queue graphics are provided in Attachment A.
Table 4-7 2029 Build Capacity Analysis Summary

SB - LR
at Elm Street East PM E 40.6 0.75
NB - LR
at Café Driveway PM C 18.6 0.13
NB - LR
at Residence Inn Driveway PM C 15.0 0.02
Pleasant Street AM D 27.0 0.11
NB - L
at Lakeshore Center PM E 38.8 0.16
SB - LR
Restaurant Driveway 1 PM C 23.6 0.05
NB - LTR
at Old Pleasant Street PM C 17.8 0.18
Pleasant Street AM D 28.8 0.05
NB - LTR
Overall
Overall
1 Level-of-Service
intersections are shown to continue to operate at LOS E or better under 2029 Build conditions
during the weekday morning and weekday afternoon peak hours. Each of the stop-controlled
approaches is shown to continue to operate under capacity during the weekday morning and
weekday afternoon peak hours. The largest increase in delay is shown to occur for the
northbound left-turn movement for the Lakeshore Center approach. All other unsignalized
movements are shown to experience an increase in delay of less than eight seconds.

The signalized study area intersections are shown to continue to operate at overall LOS B or
better under 2029 Build conditions during the weekday morning and weekday afternoon peak
hours. The overall delay at the signalized intersections is shown to increase by three seconds or
less over No Build conditions. As shown in the queue diagrams included in Attachment A, the
95th percentile vehicle queues for the Pleasant Street (Route 24) eastbound approach to the
Route 24 southbound ramps are shown to extend towards the intersection of Fruit
Street/Lakeside Drive, while the 50th percentile queues are shown to be much shorter. Due to
limitations within Synchro analysis methodologies to reflect operations in the field such as
through vehicle passing a waiting left-turning vehicle, the 95th percentile queues may be
overstated for the movement. The vehicle queues on the Route 24 ramps are not shown to
extend to the Route 24 mainline during the weekday morning and weekday afternoon peak
hours under the 2029 Build condition.
4.5.4 Site Access and Circulation
Under the proposed project, access would be provided to each of the developed lots within the
Lakeshore Center project. Access to the proposed café on Central Lot 1 would be provided by
two new full-access driveways to the west of the Residence Inn driveway on the south side of
Pleasant Street. Access to Central Lots 4 and 6 would be provided by the existing full-access
Lakeshore Center driveway on the south side of Pleasant Street. Access to Central Lot 7 would
be provided by the existing full-access Lakeshore Center driveway on the south side of Pleasant
Street and a proposed full-access driveway connecting to Pleasant Street at Old Pleasant Street.
Access to the Northern Lot would be provided via three new full-access driveways on the north
side of Pleasant Street.
Sidewalks within Lakeshore Center and the adjacent roadways provide the ability for residents
and employees of Lakeshore Center to walk within the site and around the study area.
Additional mitigation measures outlined below would provide enhancements to existing
infrastructure and additional pedestrian connections to support increase pedestrian activity
within the study area.
Dedicated bicycle infrastructure is not currently present directly within the project study area.
However, bicycle lanes on North Main Street, south of the Raynham town line, have been
striped within the shoulders. Similar width shoulders currently exist along Pleasant Street
within the study area. The project is proposing to maintain those shoulders to allow for the
existing occasional bicycle travel by not proposing any additional turn lanes for vehicular travel
along that segment of Pleasant Street Route 104. Potential routes for future bicycle travel to
and from the project site would be expected to continue along existing bicycle routes primarily
on the Pleasant Street roadway within the existing shoulders.

As discussed in previous sections of this report, BAT service is expected to be provided via the
existing Dial-a-Bat program for the elderly and disabled population who may reside within the
project. The project team has committed to providing covered pick-up and drop-off areas
within the 55+ and assisted living building to aid and support that element of available transit
service.
4.5.5 Sight Distance
A field review of the available sight distance was conducted at the proposed site driveways on
Pleasant Street and at Lakeshore Center. The American Association of State Highway and
Transportation Officials (AASHTO) publication, A Policy on Geometric Design, 2018 Edition, was
referenced as it defines minimum and recommended sight distances at intersections. The
minimum sight distance is based on the required stopping sight distance (SSD) for vehicles
traveling along the main road. The desirable sight distance allows vehicles to enter the main
street traffic flow without requiring the mainline traffic to slow to less than 70 percent of their
speed and is referred to as intersection sight distance (ISD). According to AASHTO, “If the
available sight distance for an entering or crossing vehicle is equal to the appropriate stopping
sight distance for the major road, then drivers have sufficient time to anticipate and avoid
collisions”.
Table 4-8 summarizes the AASHTO sight distance standard based on the measured 85th
percentile speeds on Pleasant Street for the proposed site driveways and Lakeshore Center.

Table 4-8 Sight Distance Evaluation
Speed 85th % Sight Exceeds Exceeds

SSD1 ISD2
Site Driveway Location Looking Limit Speed Distance Required Recommended
Required Recommended
(mph) (mph) Measured SSD? ISD?
Pleasant Street at Left (West) 40 45 360 500 600+ Yes Yes
Café Driveway 1 Right (East) 40 44 350 490 600+ Yes Yes
Café Driveway 2 Right (East) 40 44 350 490 600+ Yes Yes
Pleasant Street at Left (East) 40 44 350 490 600+ Yes Yes
Restaurant Driveway 1 (Center) Right (West) 40 45 360 500 600+ Yes Yes
Restaurant Driveway 2 (Eastern) Right (West) 40 45 360 500 600+ Yes Yes
Restaurant Driveway 3 (Western) Right (West) 40 45 360 500 600+ Yes Yes
Old Pleasant Street Right (East) 40 44 350 490 600+ Yes Yes
Lakeshore Center Right (East) 40 44 350 490 600+ Yes Yes
1 Stopping sight distance (see AASHTO equations 3-2 and 3-3) based on the 85th percentile speeds.
2 Intersection sight distance (see AASHTO equations 9-1 and 9-2) based on the 85th percentile speeds.

As shown in Table 4-8, the available sight distance exceeds the required AASHTO required SSD
and recommended ISD for the 85th percentile speeds. It is recommended that this vegetation
be maintained adjacent to the proposed driveway locations and all sight triangles be kept clear
to maximize sight lines. Any plantings in the vicinity of the sight triangles should remain below
2.5-feet in height.
4.6 Mitigation
As requested in the ENF certificate, a multimodal mitigation package has been identified to
support the increase in walking, bicycling, and transit by employees and residents. In response
to this request, the following mitigation measures are proposed to be implemented as part of
the project.
♦ Installation of push button actuated rapid rectangular flashing beacons (RRFB) at the
existing crosswalk across Pleasant Street just west of Lakeshore Center
♦ Construction of a new crosswalk and RRFBs across Pleasant Street west of Old Pleasant
Street providing a direct connection to the proposed restaurant.
♦ Repaint existing crosswalks across Pleasant Street just west of Lakeshore Center and just
east of Summit Drive
4.6.1 Transportation Demand Management
The proposed project will implement a Transportation Demand Management (TDM) to

encourage the use of alternative modes of transportation to reduce single occupancy vehicles
(SOV) trips to the site. As part of the project’s commitment to supporting alternative
transportation measures, the following elements would be implemented as part of the project’s
TDM:
♦ Establish TDM Coordinator – The project would establish a TDM coordinator to oversee
site-related transportation demand management, provide central commuter
information centers within the site to assist employees, including posting Greater
Attleboro Taunton Regional Transit Authority (GATRA) and Brockton Area Transit
Authority (BAT) bus schedules at central points.
♦ Employee Scheduling – Site operations will be designed to stagger employee shifts to

minimize peak arrival and departure at the site. Employees will be scheduled to
minimize arrival and departure during peak hours to minimize the impacts to traffic
operations on the surrounding roadways and intersections.
♦ Bicycle Storage – On-site bicycle racks and storage will be installed to promote bicycle
use by employees and customers.

♦ Pedestrian Access – As part of the development of the site, sidewalks, internal to the
site, will be installed around each of the proposed buildings and ADA compliant curb
ramps, crosswalks, and van-accessible ADA parking spaces would be installed within the
site.
♦ Car sharing/Carpooling – The development will provide information on State resources

available for carpools, taxis, and on-demand ride-hailing services. Mass.gov provides
information on various resources for trips, ranging from carpool and vanpool options, to
help finding local taxi service, to information on local transportation provides by cities
and towns, including:
o RideMatch: An online searchable directory open to the public to find public, private
and accessible transportation options. The main providers listed for Bridgewater are
A&A Metro Transportation – Bill’s Taxi Service, Bridgewater Council on Aging (Dial-
A-Bat), and BSU Blue Line.
4.6.2 Transportation Monitoring Program
The proposed project will complete an annual transportation monitoring program for a period
of five years, beginning six months after occupancy of the full-build project, to evaluate the
adequacy of the mitigation measures and determine the effectiveness of the TDM program. The
program will include:
♦ Simultaneous automatic traffic recorder (ATR) counts at each proposed site driveway for
a continuous 24-hour period on a typical weekday
♦ Travel survey of employees and patrons at the site (to be administered by the
Transportation Coordinator)
♦ Weekday AM and PM and Saturday peak hour turning movement counts (TMCs) and
operations analysis at “mitigated” intersections, including those involving site driveways
♦ Transit ridership counts of services provided by Dial-a-Bat, as able to be obtained from

Brockton Area Transit.

Chapter 5
Rare Species
5.0 RARE SPECIES
This chapter responds to two rare species issues in the Secretary’s Certificate on the ENF related to the
Conservation Management Permit for Eastern Box Turtle and the potential for rare species impacts on
the Northern Lot.
5.1 Eastern Box Turtle
The entirety of the Lakeshore Center Development was previously mapped as Priority Habitat for
the eastern box turtle (Terrapene carolina) based in the 14th edition of the Natural Heritage Atlas
(2017). In 2021, the 15th edition of this Atlas was issued, removing the Priority Habitat designation
for box turtle from the site. Prior to this revision, a Conservation Management Permit was issued
on February 7, 2019, permitting work associated with the Lakeshore Development to
conditionally proceed. The conditions of this approval are still to be upheld regardless of the
delisting of the area as Priority Habitat. The Proponent must implement a Turtle Protection Plan
during construction in which a barrier will be established around the limit of work preventing
turtles from accessing the Project Site during construction. Qualified biologists will then spend an
appropriate amount of time walking through the Project Site and physically handling and
removing any encountered box turtles from the limit of work to directly avoid mortality during
construction. Regular inspections of this barrier fence will occur throughout the active season for
the turtles (April 15- October 15) to ensure that the barrier remains in working condition. The
Proponent also has agreed to contribute $100,800 to the Nature Conservancy’s Eastern Box Turtle
Mitigation Bank with an additional $12,096 in administrative fees.
5.2 Northern Lot
Regarding the Northern Lot within the Project Site, this area is mapped as Priority Habitat for the
aquatic plants, Plymouth Gentian (Sabatia kennedyana) and the round-fruited seedbox (Ludwigia
sphaerocarpa). The Proponent has filed a MESA Checklist with NHESP to confirm whether or not
the proposed Project will result in a take of either species. NHESP has issued a “No-Take” letter
dated November 18, 2022, which confirms that the proposed Project will not result in a take and
that no Conservation Management Permit will be required for this portion of the Project. We note
that at its closest point, the limit of work for this Project is approximately 26 feet from the bank
of Lake Nippenicket, a distance regarded by NHESP as sufficient to avoid a take determination.
Erosion control barriers will be established along the downgradient limit of work during
construction and until the site is stabilized, preventing any impacts from the pond shore habitat
of these species.
6491/Lakeshore Center Phase 4 5-1 Rare Species

Goddard Consulting
Chapter 6
Area of Critical Environmental Concern

6.0 AREA OF CRITICAL ENVIRONMENTAL CONCERN
6.1 Introduction
The Lakeshore Center Development represents a small part of the nearly 17,000-acre Hockomock
Swamp Area of Critical Environmental Concern (ACEC). As indicated on the Mass.gov ACEC
Program website, ACECs are designated by the Commonwealth as areas to “receive special
recognition because of the quality, uniqueness, and significance of its natural and cultural
resources.”
As also pointed out on the website, it is important to note that an ACEC designation “does not
supersede local regulations or zoning, change or affect land ownership, allow public access on
private property, or prohibit or stop land development.”
6.2 Impacts to the ACEC
The Secretary’s Certificate on the ENF asks that the DEIR discuss the Project’s impacts to several
of the ACEC’s values including groundwater, habitat, biodiversity, storm damage prevention, flood
control, historic and archaeological resources as well as scenic and recreational resources. The
following sections address each of these categories.
6.2.1 Groundwater
The proposed Project is not expected to adversely affect groundwater. As discussed in Section 7.3,
the Project includes a modern stormwater management system that will comply with the
MassDEP Stormwater Management Standards, the U.S. Environmental Protection Agency’s
National Pollutant Discharge Elimination System (NPDES) requirements, and the Town of
Bridgewater’s Stormwater Management Program. Infiltration basins and leaching chambers are
among the best management practices (BMPs) proposed to be employed to help protect
groundwater.
As described in Section 7.3, the Project will employ a long-term Operation and Maintenance
(O&M) Plan to ensure that stormwater management systems function as designed and will
develop a spill prevention program as part of the overall Stormwater Pollution Prevention Plan
(SWPPP) to protect groundwater in the event of an accidental spill. See Section 7.3.11.
6.2.2 Habitat
As described below in Section 6.3, the Proponent has undertaken a bio-inventory of the currently
undisturbed areas that will be impacted by the proposed Project to identify the presence and
location of potential wildlife and plant habitat, and to serve as a guide for the assessment of the
development’s effects on the Site.
6491/Lakeshore Center Phase 4 6-1 ACEC

The assessment found that the Project site does not contain exemplary or unique habitat features
within areas of proposed impact. The site itself is completely isolated from surrounding habitats,
as adjacent roadways fragment the site from the nearby habitat complexes.
Areas of impact across the site consist of upland forest, many of which contain substantial
quantities of invasive species that have the potential to spread to more naturalized areas both on
and off the Site. No unique vegetation was observed during the field surveys.
The clearing of upland forest will impact the local vegetation and wildlife community; however,
impacts to wildlife beyond the site are expected to be nominal as there is limited connectivity to
other natural areas and the area has no exemplary or unique habitat features that would attract
wildlife. It is not anticipated that there will be impacts to wetland-dependent species or rare
species.
6.2.3 Flood Control and Storm Damage Prevention
Please refer to Sections 7.2 and 7.3 for a discussion of the floodplain in the development area and
the proposed stormwater management system. The vast wetland resource area of the
Hockomock Swamp surrounding Lake Nippenicket and the expansive wetland areas bordering the
central upland area provide substantial capacity to withstand the largest storms historically
experienced in this region. While climate changes and the possibility of substantial increases in
the expected stormwater runoff levels by the year 2070 are of concern, this area is expected to
accommodate the increases without impact to the Project site. The impacts of the higher future
rainfall events will result in greater stormwater peaks and volume, but the wetland system will
provide a substantial buffer, minimizing any observable impacts to the area of the Lake. At the
same time, the proposed stormwater management system will preserve existing conditions by
maintaining existing drainage patterns and proportional discharges to the wetlands and the
existing culverts on the site.
The proposed stormwater management systems will provide the necessary storage and recharge
to reduce the peak rate and volume of runoff from the 2-, 10-, 25-, 50-, and 100-year storm events
to below 90% of the pre-development for all developed sub watersheds. The undeveloped sub
watersheds have a component of runoff that cannot be changed and are still within practical limits
of pre-development considering the large scale of the watersheds being analyzed. The design and
construction of the individual sites will be done in compliance with the NPDES, the Massachusetts
DEP Stormwater Management Regulations, and with local requirements of the Town of
Bridgewater.
6.2.4 Historic and Archaeological Resources
The proposed Project will impact two known archaeological sites on Lots 6 and 7; however, the
Proponent has entered into a Memorandum of Agreement (MOA) with the Massachusetts
Historical Commission (MHC) that outlines stipulations to mitigate the adverse effects. As

specified in the MOA, the Proponent has undertaken an archaeological data recovery program for
the two sites. Analysis of the materials recovered and preparation of a technical report are in
progress.
The Proponent has also conducted an archaeological sensitivity assessment of the Northern Lot.
An archaeologically sensitive zone was identified in the Northern Lot with the potential to contain
unrecorded pre-contact Native American and post contact Euro-American sites. An intensive
archaeological survey with subsurface testing conducted by PAL identified the Lakeshore Drive
Site, an unrecorded Native American site. This site does not have sufficient integrity to be
considered a potentially significant archaeological resource and no further investigation is
recommended.
Please see Chapter 9 for more detail on archaeological resources.
6.2.5 Scenic and Recreational Resources
As described in the Hockomock Swamp ACEC Designation Report, “The special use areas of the
ACEC include undeveloped, natural areas, public recreational areas and significant scenic sites.
The approximately 5,000 acres of land owned by the Commonwealth's Division of Fisheries and
Wildlife (DFW) provide public access for several forms of recreation, including boating, fishing,
hunting, canoeing, picnicking, hiking, birdwatching, swimming and wintertime sports.”
Most importantly, the Project will not directly affect the Hockomock Swamp itself, which is
located generally north of Route 104 and Lake Nippenicket. The main currently undeveloped areas
proposed for new development within the ACEC, namely Lots 4, 6, and 7, are not active recreation
areas, likely because they are private property and ringed by I-495 and Route 24 making access to
the area difficult.
The proposed Project will not significantly impact the scenic and recreational resources of Lake
Nippenicket. While the Project does include redevelopment of property adjacent to the boat ramp
on Lake Nippenicket, the Project will not have any impacts that would interfere with the public’s
ability to utilize this recreational area. Additionally, the Project is not anticipated to significantly
impact the scenic resource of Lake Nippenicket. The proposed restaurant building will generally
occupy a lot that is currently developed, and most of the lot will remain in a natural state. Overall,
views to and from the lake will not be significantly changed.
6.3 Bio-Inventory
The Secretary’s Certificate on the ENF also requested that the Proponent perform a Bio-Inventory
of the undisturbed areas of the Project Site that will be disturbed. This is largely the areas on Lots
6 and 7 and to some extent Lot 4.

In September of 2022, Wildlife Biologists from Goddard Consulting performed a Bio-Inventory and
Habitat Assessment on the Project site. The study’s purpose is to identify the presence and
location of potential wildlife and plant habitat, and to serve as a guide for the assessment of the
development’s effects on the Site. The Site currently consists of mixed uses, including residential
and commercial developments, with most of the area currently wooded and undeveloped. See
Figures 6-1 & 6-2.
The assessment found that the Project Site does not contain exemplary or unique habitat features
within areas of proposed impact. The Site itself is completely isolated from surrounding habitats,
given it is bordered on all sides by Route 495 and Route 24 to the east and south, as well as
Pleasant Street to the north and west. These adjacent roadways fragment the Site from the
nearby habitat complexes.
Areas of impact across the Site consist of upland forest, many of which are fragmented from other
natural areas and contain substantial quantities of invasive species that have the potential to
spread to more naturalized areas both on and off the Site. No unique vegetation was observed
during the field surveys.
Mammals observed on the Project Site during the survey included grey squirrels, eastern
cottontail, and eastern chipmunks. Evidence of other mammal utilization of the Site included
white-tailed deer scat and trails. No other evidence was observed during the survey. It is expected
that small rodents, including mice and shrews, will utilize the Site for foraging and overwintering.
Due to the suburban nature of the location, it is also anticipated that mammals such as opossums,
raccoons, grey fox, eastern coyote, and skunks will utilize the Site for travel and foraging.
Mammalian migratory patterns through the Site are expected to be somewhat limited due to the
surrounding development and fragmentation of the Site. It appears that the Project Site is of low
importance and use by mammals within the broader landscape in the Site’s vicinity.
The deep leaf litter observed in portions of the Site may provide adequate cover for small
amphibian travel and migration; however, the sparse to moderate canopy cover and low density
of coarse woody debris and other cover objects may not provide sufficient shade during the
warmer months and winter cover. Given the Site’s somewhat fragmented and terrestrial habitat,
it is anticipated to find herptiles species, or reptiles and amphibians, on-site that are tolerant to
urbanization, including garter snake, northern brown snake, American toad, and, to a lesser
extent, eastern redback salamander. These species would likely utilize the Site for travel and
limited foraging.
As with the mammals, it is expected that herptile migratory patterns through the Site are also
somewhat limited due to the surrounding development and fragmentation of the Site. It is
important to note that no impacts to on-site wetlands are proposed, allowing these areas to
remain as herptile habitat.

Figure 6-1
Locus map of all properties presently associated with the Lakeshore Center
Figure 6-2
Aerial view of the Lakeshore Center, facing north towards Lake Nippenicket
Bird species observed during the survey consisted of urban-tolerant passerine species, including
blue jay, black-capped chickadee, song sparrow, red-bellied woodpecker, white-breasted
nuthatch, American crow, American robin, and tufted titmouse. In several locations on the Site,
standing dead trees were noted that may facilitate habitat for cavity nesting birds. These species,
as well as other common suburban avian species, are expected to utilize the Site in various stages
of their life cycles for migration, forage, breeding, and/or nesting. Fruit-producing plant species
observed, including lowbush blueberry, may also provide forage and nesting habitat for various
avian species.
It does not appear that the forested upland portions of the Project Site provide significant or
important habitat for neither the avian species observed nor those anticipated to utilize the Site,
as no specialized habitat was observed. Urban-tolerant avian species tend to be opportunistic,
utilizing forested habitat in various sizes and stages of succession, or varying states of ecological
change that can be observed over time. Larger areas of contiguous mixed deciduous and
coniferous forest are present to the north of the Site, associated with the Hockomock Swamp.
The most unique specialized avian habitat observed involved the lakeshore area along the
southern edge of Lake Nippenicket. This area could be utilized by marsh birds and migratory
waterfowl. However, the Project does not propose any impacts to this area.
The clearing of upland forest will have some level of impact to the local vegetation and wildlife
community; nevertheless, based on the habitats and wildlife observed, it is not expected to be
detrimental to the overall wildlife habitat of the general area. The loss of forested upland habitat
on Site will reduce forage, cover, and shelter for generalist mammals and passerine birds. Herptile
impacts are nominal from lack of herptile habitat. Impacts to wildlife beyond the Site are nominal
as there is limited connectivity to other natural areas and the area has no exemplary or unique
habitat features that would attract wildlife. It is not anticipated that there will be impacts to
wetland-dependent species or rare species.
For additional information, refer to Attachment B for the complete Bio-Inventory report.

Chapter 7
Wetlands and Stormwater

7.0 WETLANDS AND STORMWATER
7.1 Wetland Resources
7.1.1 Existing Conditions
The work described in this DEIR is the final phase of over twenty years of development of
Lakeshore Center, a Planned Development in the western sector of the Town of Bridgewater
abutting the Town of Raynham. The property is approximately 166.48 acres and, although
trisected by extensive wetland areas, incorporated all the land bordered by major highways to
connect Bridgewater to locations in all four directions. The ease of access to these major highways
made the land ideal for business, industrial, and residential needs of the region. The available
areas in the eastern, central, and western sectors of the project area were unconnected to each
other.
The eastern area was utilized to develop a warehouse site; the western area, an apartment
complex; and the central area, a mix of uses, including two offices and an apartment complex.
The proposed buildout of the remaining sites in the central area include an aged restricted
residential community and an assisted living facility. The central area abuts Route 104 (Pleasant
Street) where the hotel site will be augmented to include a café and a second hotel will be built
adjacent to upscale condominium units with a view of Lake Nippenicket. Across the roadway,
along the waterfront, an existing residential site will be redeveloped to add an upscale restaurant
with spectacular views of the lake. This area has included recreational activities in the past, known
as Pilgrim Park.
Areas of BVW and associated Buffer Zones are shown on the Master Plan (Figure 1-6) and the
individual site plans on Figures 1-7 through 1-12. There is an intermittent stream on the east side
of the North Lot adjacent to Lake Nippenicket. Documentation concerning its status as an
intermittent stream is provided in Attachment E.
7.1.2 Impacts to Resource Areas and Buffer Zones
The proposed Project will not impact the bordering vegetated wetlands (BVW), as all of the
proposed alterations will take place on the upland areas and in wetland buffer zones. The
proposed Project will be designed to comply with the Town of Bridgewater Wetland Bylaw 25-
foot-no-disturb buffer from BVW and the applicable performance standards under the Wetland
Protection Act (WPA) for work within the buffer zone. Where the Project is in proximity to
previously designated turtle habitat areas 1, a protective fence will be constructed and maintained.
1
Portions of the site were previously mapped by NHESP as Priority Habitat for the eastern box turtle, but this
designation was later removed with the issuance of the 15th edition of the Priority Habitat mappings issued by
NHESP in 2021. The Project Site is however still subject to turtle protection measures as a result of a previous
Conservation Management Permit issued by NHESP, involving the installation of a turtle barrier fence and turtle
sweeps by a qualified biologist prior to the start of any construction. Chapter 5 provides additional information.
6491/Lakeshore Center Phase 4 7-1 Wetlands and Stormwater

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The developed sites are served by municipal water and sewer, further protecting the resource
areas from any impacts related to development. Stormwater treatment and attenuation will
involve recharge of clean water and detention of stormwater to reduce both the peak rates and
volume resulting from the change in use of the buffer areas. Higher standards will be employed
in design because the area is designated as “An Area of Critical Environmental Concern” and
because the Project Site contributes to the recharge of the municipal wells of Raynham.
7.1.3 Proposed Wetland Mitigation
No wetland alteration is planned on the Project Site. There will be no activity that is completed
within 25 feet of a BVW. Every effort will be made to maximize separation to the resource areas
and protective measures will be employed to minimize potential impacts. Silt fencing, straw
wattles, and turtle barriers will project and demark the limits of work to avoid any unintended
intrusion into these sensitive areas.
7.2 Floodplain
Previous development within the overall Lakeshore Center Development have involved the
detailed evaluation of the floodplain and the establishment of a base flood elevation. The
Lakeshore Development area is not part of a detailed study area and the Project Site is not
governed by a known elevation for the 100-year storm event.
When development of the western site was completed, FEMA approval was sought to establish a
base flood elevation (BFE) for the area. That elevation was utilized when Lot 5 was developed and
will be adhered to when work adjacent to the Western wetland, Lots 1 and 4, is designed.
Likewise, the areas related to Lots 6 and 7 and the Northern Lot will utilize the BFE, previously
determined since flooding in this region is controlled by the conditions along Lake Nippenicket.
The vast wetland resource area of the Hockomock Swamp surrounding the Lake and the expansive
wetland areas bordering the central upland area provide substantial capacity to withstand the
largest storms historically experienced in this region.
Potential climate changes and the possibility of substantial increases in the expected stormwater
runoff levels by the year 2070 are of concern; however, this area is expected to accommodate the
increases without impact to the Project Site. The impacts of the higher rainfall events will result
in stormwater peak and volume predictions to be extreme, but the wetland system will provide a
substantial buffer, minimizing any observable impacts to the area of the Lake.
The Lake has significant capacity to absorb the increased runoff and, coupled with an Arch Dam
management strategy that reduces potential impacts to the Town River, large storms can be
managed and controlled to the downstream community of West Bridgewater and eastern portion
of Bridgewater. Ultimately, flow from this region travels to the Taunton River and eventually to
the waters of Mount Hope Bay. Compliance with Executive Order 11988 is paramount to all
projects and avoidance of work within the floodplain is always the preferred route to follow. If it

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is unavoidable, appropriate measures are taken to establish building heights above the floodplain
and, if filling of available flood storage area is compromised, replacement of the equivalent
storage volume is identified and included within the design plan. Fortunately, this area has
minimal potential for flooding and expansive wetland resources to handle the temporary
stormwater storage that may be required.
7.3 Proposed Stormwater Management System
7.3.1 Stormwater Runoff Analysis
The overall Lakeshore Development site is in the upper reaches of the Taunton River Basin
adjacent to Lake Nippenicket from which flows the Town River, a major tributary of the Taunton
River. The Project Site is located within the Hockomock Swamp, a designated ACEC and one of the
largest inland swamps in New England. It is also located within a designated Zone II to the drinking
water wells in the nearby Town of Raynham. The Project is subject to stormwater treatment and
discharge standards as set forth in the Massachusetts Stormwater Management Standards and
the Stormwater By Laws. The past developments within the overall site have included two office
buildings, a hotel, two apartment complexes, and a large warehouse. The remaining Project Site
includes Lot 1 (amended), Lot 4, Lot 6, Lot 7, and new area across Route 104 along the lake.
Estimates of stormwater runoff associated with the proposed Project were previously determined
using the USDA NRCS publication TR-55, the basis of HydroCAD 10.0. This methodology uses soil
type, time of concentration, vegetative cover, and topographical conditions to develop
hydrographs for various storm events. For the detailed study of each location, the NOAA ATLAS
14 rainfall estimates for the 2, 10, 25, 50, and 100-year storm events were analyzed. The
calculations estimate the pre- and post-development peak runoff rates and stormwater volumes
for each storm event. In each location, the peak rate is designed to be 90% of the existing
condition and a reduction in stormwater volume by 10% is achieved using infiltration methods to
ensure recharge of the aquifer is accomplished. Water quality mitigation using various Best
Management Practices (BMPs) are identified to achieve compliance with Massachusetts
Stormwater Management Standards and protect the wetland resource areas and the drinking
water aquifer of the neighboring Town of Raynham.
7.3.1.1 Existing Conditions
The Project Site, excluding the Northern Lot, consists of 163.88 acres of land which is comprised
of 86.86 acres of uplands and 77.02 acres of wetlands. Although primarily in the Town of
Bridgewater, a portion of the Project Site is located within the Town of Raynham. There is no work
proposed on the Raynham property. The Northern Lot added approximately two acres to the
overall Lakeshore area and the current application for the remaining sites is 166.48 acres in size.
Of the total area, there is 88.76 acres of uplands.
The Project Site is comprised of three large upland tracts separated by two expansive wetland
areas. The upland tracts are designated as Eastern, Central, and Western and the wetland tracts

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are designated as Eastern Wetland and Western Wetland. These two wetland areas drain
northerly toward Lake Nippenicket through three culverts with a portion of the flow also moving
southerly to a fourth culvert under Route 495. Three of the remaining sites are located between
the wetland areas along Lakeshore Drive, one north of the western wetland and the other across
Route 104 along the Lakefront. The areas outside the existing developed portion of the property
consist of mainly wooded areas, an existing parking lot, and a home site along the Lake.
Historically, the overall site was previously utilized for farming and a few houses, church
campground and the private function hall known as the “Beagle Club.” Figure 7-1 depicts the
existing stormwater drainage conditions.
Drainage from the Eastern upland flows towards the Eastern Wetlands and towards the third
culvert (3) and intermittent stream designated on the Site. The drainage for the Central upland
tract is divided into three sections. A portion of the Central tract drains easterly towards the
Eastern Wetlands and culvert number three (3); another section of the Site drains westerly
towards the second culvert (2) via an intermittent stream in the Western Wetlands. The rear
portion of this tract drains southerly towards an existing culvert (4) that passes under Route 495.
The Western tract drains in a radial pattern from the top of the open field towards the wetlands
and eventually the first culvert (1) and second culvert (2) via intermittent streams one and two.
7.3.1.2 Soils
A review of Plymouth County Soil Survey of 1969 revealed the Site soils to be included in several
soil categories which are mostly sandy loam. The current Web Soil Survey operated by the USDA
NRCS will be used in the drainage calculations for the remaining development. See Figure 7-2.
Table 7-1 Site Soils
Map Unit Soil Name Hydraulic

Soil Group
254B Merrimac fine sandy loam, 3 to 8 percent slopes loamy glaciofluvial A
deposits derived from granite, schist, and gneiss over sandy and
gravelly glaciofluvial deposits derived from granite, schist, and gneiss
254C Merrimac fine sandy loam, 8 to 15 percent slopes A
256A Deerfield loamy fine sand, 0 to 3 percent slopes sandy outwash A
derived from granite, gneiss, and/or quartzite
51A Swansea muck: highly decomposed organic material over loose sandy B/D
and gravelly glaciofluvial deposits
The surficial geology map published by the US Geological Survey and identified as Bulletin 1163-
D, dated 1967 indicates that the wetland areas were part of “Titicut Swamp” prior to the
construction of Route 495. The upland areas are identified as “undivided glaciaflucial deposits,”
Qgf, described as “irregular landforms and large areas of sand and gravel morphologically not
distinct enough to map by origin; includes lenticular masses of flow till.” See Figure 7-3 for the
surficial geology map.

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Figure 7-1
Existing Stormwater Drainage Conditions
Figure 7-2
Soil Conditions
Figure 7-3
Surficial Geology Map
To supplement available soil data, Silva Engineering Associates conducted a number of test pits
throughout the entire site. These test holes confirmed groundwater elevations and supported the
classifications identified in the USGS soil survey for drainage design.
7.3.1.3 Land Cover Changes
The entire Lakeshore Center Development has changed forested uplands, agricultural and
livestock pastures into various projects since it was initiated in 1999.
The Eastern portion of the site consisted generally of forested uplands between Route 495 and
the Eastern Wetlands. The only portion of this wooded area that had been developed was for a
large warehouse.
The Western portion of the site consisted mostly of an existing open field with pasture grasses as
the dominant feature. Surrounding this pasture are some areas of forested uplands and wetlands.
Here, an affordable housing project was constructed, leaving the Raynham land undisturbed and
most of the wooded uplands and wetlands.
The Central upland area of the site has included the development of two office buildings, a hotel,
and an affordable housing project. Three of the remaining sites, Lots 4, 6 and 7 border Lakeshore
Center Drive. These sites contain regrowth wooded areas that were primarily pastureland in the
past. The clearing of these sites was offset by the extensive backdrop of wooded wetlands,
landscaping, tree planting, and expansive open drainage basins, trimmed with new trees. The
proposed changes on Lots 4, 6, and 7 will mimic the neighboring development sites and will
protect the vast wetland systems that connect to Lake Nippenicket.
The two Route 104 sites are different in that they have very limited alteration planned to
undisturbed areas of vegetation. The Lot 1 change involves replacement of a portion of the
existing paved parking lot with a small café building. Likewise, the Northern Lot will replace a
residential home and an overgrown recreational area with an upscale restaurant. Figure 7-4
depicts an aerial view of Lakeshore Center from April 2013.
7.3.1.4 Proposed Conditions
Since most of the Project Site is in proximity to known wetlands and habitat areas for turtles and
other species of concern, the design of all sites will attempt to meet the following:
♦ No disturbance within 25 feet of the wetlands.
♦ Stormwater management facilities located between 25 and 100 feet of the wetland
buffer.
♦ No pavement, where practical, within 75 feet of the wetlands.
♦ No buildings within 50 feet of the wetlands.

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Figure 7-4
Aerial View of Lakeshore Center from April 2013
The vast majority of the 100-foot buffer zone will remain in its natural undisturbed state.
Stormwater basins constructed in the buffer zone will be naturalized and their down gradient
embankments revegetated with native plantings. A turtle barrier within the Central area will be
provided along the top of slope allowing access for the turtles and other wildlife to the naturalized
basins while preventing migration onto access drives and parking facilities. No disturbance of any
wetland resource is proposed for the development of the remaining sites.
The Preferred Alternative, which was the scenario evaluated for proposed drainage layout, will
preserve the “existing conditions” by maintaining existing drainage patterns and proportional
discharges to the wetlands and the existing culverts on the site. All proposed roof runoff shall be
recharged through a series of leaching chambers. In the rare event the chambers cannot recharge,
the entire runoff volume overflow from the chambers will be directed towards the wetland
buffers where it will be discharged into rip rap covered level spreaders in the lower reaches of the
buffer zone or the chambers will discharge into the proposed stormwater basins.
Parking lots, roadways, and landscaped areas will shed runoff to oil grit separators, deep sump
catchbasins, and manholes which will direct discharge towards sediment forebays before
eventually flowing into infiltration/detention basins. The mitigation measures employed will
remove more than 44% of total suspended solids (TSS) before any infiltration and more than 80%
TSS before final discharge. Since the Project is within a designated ACEC and Zone II, the required
water quality volume to be treated equals 1.0 inch of runoff times the total impervious area of
the post-development Project Site.
The outlet structures for the drainage basins generally consist of V-notch and rectangular weirs
at varying elevations depending on the amount of throttling that must be done to regulate the
rate of stormwater discharge. The use of a level spreader or plunge pool beyond the control
structure will also reduce the velocity of the discharge stream and eliminate erosion of
downgradient areas.
7.3.1.5 Watersheds
Three distinct upland tracts (Eastern, Central, and Western) comprise the buildable portions of
the Site. The upland areas slope to the adjacent wetlands, which in turn drain into Lake
Nippenicket or a small portion towards Route 495. The drainage evaluation includes a comparison
of stormwater estimates for the pre-development conditions and the expected runoff for the
proposed development. In addition, the design features to regulate stormwater discharge and
improve the quality of stormwater are discussed.
7.3.1.6 Pre-Development Conditions
The overall site has been divided into five sub catchment areas for the purpose of completing a
hydrologic analysis with four general directions of offsite flow. Stormwater flows through one of
three existing culverts to the north of Pleasant Street and Lake Nippenicket and an existing portion
of the site that sheds towards the south under Route 495.

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♦ EX-W3 consists of 31.22 acres in the Western portion of the site that drains towards the
west and Intermittent Stream #1 which flows north to Lake Nippenicket.
♦ EX-W1 consists of 10.01 acres that drains northerly to Lake Nippenicket via Intermittent
Stream #2
♦ EX-W2 consists of 42.24 acres that drains towards an old farm pond culvert and northerly
to Lake Nippenicket via Intermittent Stream #2
♦ EX-E1 consists of 59.79 acres that drains westerly and then north to Lake Nippenicket via
Intermittent Stream #3
♦ EX-E2 consists of 21.02 acres that drains towards the south toward a culvert passing under
Route 495.
Figures 7-5 to 7-8 depict these conditions.
7.3.1.7 Post-Development Conditions
The post development conditions will follow the same drainage patterns that currently exist. The
proposed site changes will include building, pavement, and landscaped areas. The proposed
development conditions for the five remaining lots are summarized below:
Lot 1 – Proposed Café
This location does not require significant alteration in the amount of impervious area. A portion
of the existing parking lot will be replaced with a building and some reworking of the drainage will
be included to meet stormwater requirements.
Lot 4 – Proposed Assisted Living Facility (150 Units)
This location will result in the clearing of a forested area approximately seven acres in size. The
development includes an approximately 39,800 sf building, 2.4 acres of parking and other
impervious areas, 2.6 acres of landscape and lawn area, and 1.1 acres dedicated to stormwater
management. The lot is bordered to the north by an existing office building and to the south by a
residential apartment complex.
Lot 6 – Proposed Age Restricted Residential Community (225 Units)
This area is located across from Lot 4, also fronting on Lakeshore Drive. Of the approximately 30
acres, 9.2 acres are uplands and it is proposed to clear about 7.5 acres of forested uplands to
complete the required development. The multi-story building with a parking garage is
approximately 1.82 acres and includes a recreational courtyard in the center of the building

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Figure 7-5
Outlet 1 – Intermittent Stream #1
Figure 7-6
Figure 7-7
Figure 7-8
Outlet 4 – Culvert under Route 495
footprint. Other impervious areas for parking and access drives are approximately 2.2 acres and
landscape and lawn areas are estimated to include approximately 3.0 acres of area.
Approximately one acre of land will be dedicated to stormwater management.
Lot 7 – Proposed Hotel (106 Room) and Condominium Residential Community (160 Units)
This area fronts on Lakeshore Drive and Route 104 (Pleasant Street) on a lot with an area of
approximately twenty acres. Of the approximately 11.6 acres of upland, approximately 9.4 acres
will be cleared for the overall development.
The 4-story hotel will have a footprint of approximately 0.38 acres and the 4-story Condominium
complex with an included garage will have a footprint of approximately 1.27 acres. To support
parking and access of these building sites, an additional impervious area of approximately 3.8
acres for parking and access is planned. Landscape and lawn areas for this site will exceed
2.0 acres with approximately 1.2 acres dedicated to stormwater management.
Northern Lot – Proposed Restaurant (179 Seat)
The restaurant is proposed on an approximately 2-acre site which currently includes a residential
home, and the former area of Pilgrim Park, a lakefront recreational area that had small
commercial buildings and boat rentals in the past. Clearing and demolition will encompass
1.1 acres of area, a small portion of which will involve tree clearing. The proposed 6,000sf (.1 ac)
building will require 0.7 acres of impervious area for access and parking and 0.3 acres will be
dedicated to landscaping and lawn areas. Stormwater management will be accomplished
underground with cleaning of runoff followed by recharge to the underlying aquifer.
7.3.2 Stormwater Mitigation
The peak rate and volume of stormwater leaving the site is not expected to be increased as a
result of the proposed development. The proposed stormwater management systems will provide
the necessary storage and recharge to reduce the peak rate and volume of runoff from the 2-, 10-
, 25-, 50-, and 100-year storm events to below 90% of the pre-development for all developed sub
watersheds. The undeveloped sub watersheds have a component of runoff that cannot be
changed and are still within practical limits of pre-development considering the large scale of the
watersheds being analyzed. The design and construction of the individual sites will be done in
compliance with the NPDES, the Massachusetts DEP Stormwater Management Regulations, and
with local requirements of the Town of Bridgewater.
7.3.3 Stormwater Management Policy Standards
In 1996, the Massachusetts Department of Environmental Protection (the “Department” or

“MassDEP”) issued the Stormwater Policy that established Stormwater Management Standards
aimed at encouraging recharge and preventing stormwater discharges from causing or
contributing to the pollution of the surface waters and ground waters of the Commonwealth. In
1997, MassDEP published the Massachusetts Stormwater Handbook as guidance on the

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Stormwater Policy. In January 2008 MassDEP revised the Stormwater Management Standards and
the Massachusetts Stormwater Handbook to promote increased stormwater recharge, the
treatment of more runoff from polluting land uses, low impact development (LID) techniques,
pollution prevention, the removal of illicit discharges to stormwater management systems, and
improved operation and maintenance of stormwater best management practices (BMPs).
Ten performance standards are identified for design and evaluation of drainage systems. Each
DEP standard is discussed below with a discussion as to how the Project will meet each standard.
Standard 1: Untreated Direct Discharge of Stormwater
No new stormwater conveyances (e.g., outfalls) may discharge untreated stormwater directly to
or cause erosion in wetlands or waters of the Commonwealth.
The level of treatment required is based on treating one inch of rainfall over the paved surfaces
due to the impacts to critical areas, including the Zone II.
BMPs planned to be utilized on site to meet this Standards’ requirements are:
♦ Treatment
o Deep sump catch basins
o Oil/grit separators as required by local bylaws for Aquifer Protection Districts
o Sediment Forebays
o Street Sweeping
o Erosion control
o Plunge pools and level spreaders
Standard 2: Post Development Peak Discharge
Stormwater management systems shall be designed so that the post-development peak discharge
rates do not exceed pre-development peak discharge rates. This Standard may be waived for
discharges to land subject to coastal storm flowage as defined in 310 CMR 10.04. To meet
Standard 2, the post-development peak discharge rate must be equal to or less than pre-
development rates to prevent storm damage and downstream and offsite flooding from the 2-
year and the 10-year 24-hour storm events.
BMPs proposed to be used on site to meet this Standards’ requirements are:
♦ Infiltration Basins

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♦ Leaching chambers
♦ Drainage basin
Standard 3: Recharge to Groundwater
Loss of annual recharge to ground water shall be eliminated or minimized through the use of
environmentally sensitive site design, low impact development techniques, stormwater best
management practices, and good operation and maintenance.
BMPs suited to the site to meet this Standards’ requirements are:
♦ Infiltration Basins
♦ Leaching chambers
Standard 4: TSS Removal
Stormwater management systems shall be designed to remove 80% of the average annual post-
construction load of Total Suspended Solids (TSS). This standard is met when:
♦ Suitable practices for source control and pollution prevention are identified in a long-term
pollution prevention plan, and thereafter are implemented and maintained;
♦ Structural stormwater best management practices are sized to capture the required water
quality volume as determined in accordance with the Massachusetts Stormwater
Handbook; and
♦ Pretreatment is provided in accordance with the Massachusetts Stormwater Handbook.
BMPs suited to the site to meet this Standards’ requirements are listed below:
♦ Deep sump catch basins
♦ Oil/grit separators
♦ Sediment Forebays
♦ Street Sweeping

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Total Suspended Solids will be reduced to a 44% removal rate prior to discharge into the
infiltration basin as shown in the table below and required in a Zone II:
TSS Removal Calculation Worksheet

B C D E F
BMP TSS Removal Starting TSS Load Amount Removed Remaining Load
Rate (C*D) (D-E)
Oil Grit Separator 0.25 1.00 0.25 0.75

Deep Sump and 0.25 0.75 0.19 0.56
Hooded Catch Basin
Total TSS Removal (1.00-0.56)*100%= 44%
After the train of BMPs used to reduce sediment to 44%, the runoff will enter the infiltration basin
after passing through two sediment forebays: one as part of the requirement for infiltration basin
and one to provide more removal of solids and pollutants. This final step will provide the rest of
the TSS removal required and provide a final TSS removal of 89%, greater than the 80% required.
This is shown in the table below.
TSS Removal Calculation Worksheet

B C D E F
BMP TSS Removal Starting TSS Load Amount Removed Remaining Load
Rate (C*D) (D-E)
Oil Grit Separator 0.25 1.00 0.25 0.75

Deep Sump and 0.25 0.75 0.19 0.56
Hooded Catch Basin
Infiltration Basin 0.80 0.56 0.45 0.11
w/sediment forebay
Total TSS Removal (1.00-0.11)*100%= 89%
Standard 5: Higher Potential Pollutant Loads
For land uses with higher potential pollutant loads, source control and pollution prevention shall
be implemented in accordance with the Massachusetts Stormwater Handbook to eliminate or
reduce the discharge of stormwater runoff from such land uses to the maximum extent
practicable. If, through source control and/or pollution prevention, all land uses with higher
potential pollutant loads cannot be completely protected from exposure to rain, snow, snow melt
and stormwater runoff, the proponent shall use the specific structural stormwater.

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The only potential for higher pollutant loads is due to the high intensity use parking lots that
generate more than 1,000 vehicle trips per day. The BMP’s suited to the site to meet this
Standards’ requirements have been listed under the previous sections; oil grit separators, deep
sump and hooded catch basins, and sediment forebays.
Standard 6: Protection of Critical Areas
Stormwater discharges within the Zone II or Interim Wellhead Protection Area of a public water
supply require the use of the specific source control and pollution prevention measures and the
specific structural stormwater best management practices determined by the Department to be
suitable for managing discharges to such areas, as provided in the most recent version of the
Massachusetts Stormwater Handbook.
The BMP’s suited to the site to meet this Standards’ requirements have been listed under the
previous sections; oil grit separators, deep sump and hooded catch basins, sediment forebays,
and infiltration basins. A water quality volume of 1-inch of rainfall has been provided and 44% TSS
removal rate is provided prior to discharge to the infiltration basins. Proposed sediment forebays
and infiltration basins bring the total TSS removal rate to 89%. A Spill Prevention Plan will also be
implemented for the site and will be in the Storm Water Pollution Prevention Plan (SWPPP).
Each lot on the Project Site has been designed to respect the 25-foot buffer zone of the bordering
vegetated wetlands. To that end, the wetland limits previously established on the site, and
marked with permanent green pipes, has been re-evaluated to determine the current conditions.
Minor changes to the previously approved wetland line will be presented to the Conservation
Commission with each site plan for approval.
Standard 7: Redevelopment Project
This Project is not considered a redevelopment project.
Standard 8: Erosion/Sediment Control
A plan to control construction-related impacts, including erosion, sedimentation, and other

pollutant sources during construction and land disturbance activities (construction period erosion,
sedimentation, and pollution prevention plan) shall be developed and implemented.
The Project will require a filing under the NPDES program and the development of a SWPPP.
Provisions for erosion control planned in the SWPPP include but are not limited to:
♦ Preserving areas of existing vegetation from erosion during construction
♦ Phasing grading and stabilization activities to minimize the overall amount of disturbed
soil that will be subject to potential erosion at one time.

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♦ Structural design elements (e.g., diversions, berms, ditches, storage basins) used to divert
flows from exposed soils, retain or detain flows, or otherwise limit runoff and the
discharge of pollutants from exposed areas of the site.
♦ Protection of storm drain inlets both existing and proposed.
♦ Establishment of perimeter controls and sediment barriers (e.g., silt fence and/or
haybales)
♦ Establish stabilized construction entrance/exits
A list of measures to be utilized in the development of the site can be found in Section 7.3.4
Erosion Control Procedures.
Standard 9: Operation and Maintenance Plan
A Long-Term Operation and Maintenance (O&M) Plan shall be developed and implemented to
ensure that stormwater management systems function as designed. The Operation and
Maintenance Plan shall identify best management practices for implementing maintenance
activities in a manner that minimizes impacts to wetland resource areas. To avoid duplication of
effort, the proponent will prepare one plan for the operation and maintenance of stormwater
BMPs that fulfills the requirements of Standard 8 and the applicable NPDES general stormwater
permit. At a minimum, the plan will include:
1. Stormwater management system(s) owners;

2. The party or parties responsible for operation and maintenance, including how future
property owners will be notified of the presence of the stormwater management system
and the requirement for proper operation and maintenance;
3. The routine and non-routine maintenance tasks to be undertaken after construction is
complete and a schedule for implementing those tasks;
4. A plan that is drawn to scale and shows the location of all stormwater BMPs in each
treatment train along with the discharge point;
5. A description and delineation of public safety features; and
6. An estimated operations and maintenance budget.
Standard 10: No Illicit Discharges
The stormwater management system is the system for conveying, treating, and infiltrating
stormwater on-site, including stormwater best management practices and any pipes intended to
transport stormwater to the groundwater, a surface water, or municipal separate storm sewer
system. Illicit discharges to the stormwater management system are discharges that are not
entirely comprised of stormwater. Notwithstanding the foregoing, an illicit discharge does not
include discharges from the following activities or facilities: firefighting, water line flushing,
landscape irrigation, uncontaminated groundwater, potable water sources, foundation drains, air

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conditioning condensation, footing drains, individual resident car washing, flows from riparian
habitats and wetlands, dechlorinated water from swimming pools, water used for street washing
and water used to clean residential buildings without detergents.
A statement demonstrating compliance with this requirement shall be submitted to the issuing
authority verifying that no illicit discharges exist on the site and by including in the pollution
prevention plan measures to prevent illicit discharges to the stormwater management system,
including wastewater discharges and discharges of stormwater contaminated by contact with
process wastes, raw materials, toxic pollutants, hazardous substances, oil, or grease.
7.3.4 Erosion Control Procedures
The following sections outline the elements of an erosion and sedimentation plan.
1. Temporary Gravel Construction Entrance/Exit:
A temporary gravel entrance shall be installed for dust mitigation. Crushed stone (3/4” to 1 ½”)
shall be placed a minimum of thirty (50) feet into site at entrance ways during construction
activities. During wet weather it may be necessary to wash vehicle tires at this location. The
entrance will be graded so runoff water will not be directed to critical resources areas.
2. Catch Basin/Water Quality Inlet Protection:
A temporary silt sack will be installed on all inlets and be protected by haybales until such time as
deemed appropriate after stabilization of the proposed drainage system.
3. Tree Preservation and Protection:
A minimum 2.0 ft. high protective fence will be erected around any trees that are to remain on
site during and after construction activities. Sediment fence materials may be used for this
purpose.
4. Land Grading:
All cut slopes will be 3:1 or flatter to avoid instability due to wetness, provide fill material, create
an open area around the buildings, and allow vegetated slopes to be mowed. Cut slopes will be
fine graded immediately after rough grading; the surface will be disked and vegetated. The
finished slope face will not be back-bladed. The top 2 to 6 inches will be left in a loose and
roughened condition.
Plantings will be protected with mulch. A minimum 15-ft undisturbed buffer zone will be
maintained around the perimeter of the disturbed area. (Note: This will reduce water and wind
erosion, help contain sediment, reduce dust, and reduce final landscaping costs.)

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5. Sediment Fence:
A sediment fence will be constructed around the topsoil stockpile and adjacent to the deep cut
areas as necessary to prevent erosion and sediment from entering critical areas.
6. Grass-Lined Channel:
Any grass-lined swales to be constructed will be protected with temporary straw-net liners until
stabilized.
7. Riprap-Lined and Paved Channels:
Any riprap channel and/or paved channels will be protected on the down gradient side with
haybales and cleaned after construction.
8. Construction Road Stabilization:
As soon as final grade is reached on the road, the sub grade will be sloped and stabilized with a 6-
inch course of NC DOT standard ABC stone. The parking area and its entrance road will also be
stabilized with ABC stone to prevent erosion and dust during the construction of the buildings
prior to paving.
9. Outlet Stabilization Structure:
A riprap apron will be located at any drainage outlets as indicated on the plans to prevent scour.
10. Surface Roughening:
The 3:1 cut slopes will be lightly roughened by disking just prior to vegetating and the surface 4
to 6 inches of the 2:1 fill slopes will be left in a loose condition and grooved on the contour.
11. Surface Stabilization:
Stabilization of the surface will be accomplished with vegetation and mulch. Roadway and parking
lot base courses will be installed as soon as finished grade is reached.
12. Dust Control:
The Contractor shall take steps to minimize the amount of dust generated on the site including
those procedures contained in this document.
♦ Surface Wetting: The Contractor shall ensure that all surfaces to be excavated are wet
prior to and, if necessary, during excavation. Other potential wetting and/or dust control
agents may be proposed for use by the Contractor and must be approved by the Town
prior to use on site. If water is applied to the site, it shall not be applied in sufficient
quantity or pressure to cause channeling or erosion of the surface to which it is applied.

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♦ Soil Stockpiles: Soil excavated from the site and stockpiled on site pending disposal shall
be covered at the end of the workday with a tarpaulin or other impermeable material.
The tarpaulin shall be securely fastened so that no significant quantity of dust is generated
from the soil stockpile. The stockpile and tarpaulin shall be positioned so that
precipitation is directed away from the stockpile.
♦ Pavement Cleaning: During periods when trucks are transporting soil and/or landscaping
materials to or from the site, dirt that may have been tracked off the site shall be removed
daily from the pavement and sidewalks. The area to be cleaned is to extend to the limit
of noticeable dirt tracked from the site or for a distance of 100 feet on each side of a
vehicle entrance or exit, whichever is greater. If water is used to clean the sidewalk or
street then the quantity of water used shall not result in sediment being washed into the
storm sewer catch basins or for excess water to freeze on the street. Street sweepings
shall not be disposed in any catch basin or any sewer. Street sweepings shall be disposed
of as a waste along with waste soil in accordance with applicable regulations.
♦ Entry/Exit Points: All equipment, including but not limited to vehicles, trucks, excavating
equipment and hand tools, leaving the site must be free of dirt prior to removal (either
temporarily or permanently) from the site.
♦ Designated Routes: All vehicles transporting soil or other materials to or from the site
shall follow designated routes within the site. These routes are to be established by the
contractor and marked by the contractor. The primary purpose of these routes is to
reduce the contact between vehicles and impacted areas of the site. The location of the
designated routes on the site shall be subject to environmental and geotechnical
requirements.
♦ Tarped Loads: All trucks leaving the site which have been loaded with soil or debris shall
be tarped in accordance with applicable regulations.
7.3.5 Low Impact Development Strategies
Low impact development (LID) techniques are defined as innovative stormwater management
systems that are modeled after natural hydrologic features. More specifically, designs that
incorporate environmentally sensitive features that allow the land to filter, recharge the water
back into the ground, and parking designs that reduce the amount of impervious area are a critical
first step in creating a sustainable development.
Parking lots being considered for this application are those that are out of the way and not
intended for everyday parking or heavy loading. Porous pavement works by having a paved
surface with a higher than normal percentage of air voids to allow water to pass through it and
infiltrate into the subsoil. There are limited areas for this application since most of the parking

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included in the Project is expected to be utilized year-round and extensive use of permeable
pavement in these areas would not be appropriate for the sensitive nature of the site within the
ACEC and Zone II of the Raynham Lake Nippenicket drinking water wells.
Reduction of the constructed parking areas where zoning requirements are less than the
proposed parking proposed may involve delaying construction of a portion of the parking spaces
until it is demonstrated that the Project needs the added spaces to function at an acceptable level.
Permeable sidewalk pavers are not yet proposed for sidewalk areas of the development.
Permeable sidewalk pavers, when utilized, could allow a reduction in runoff volume by
encouraging infiltration in these areas. Water quality could also be improved by reducing the Total
Suspended Solid (TSS), nutrient, metal, and thermal loadings. Choosing sidewalks for this
application may provide additional protection to the aquifer by minimizing any potential vehicle
contaminants from infiltrating. Areas that may be candidates of this type of construction will be
evaluated during the detailed site design and permitting process.
Bioretention areas may be proposed for a few select areas. These “bio-cells,” as they are also
called, function as soil and plant-based filtration devices that remove pollutants through a variety
of physical, biological, and chemical treatment processes. The proposed locations selected for
these bio-cells are areas that are not selected for snow removal and are in areas that would see
minimal impacts from large amounts of pollutants. During the detailed site design process, the
feasibility of incorporating these LID techniques will be explored further.
The individual site designs propose to filter and recharge all the runoff from the buildings on the
site. Each design provides a minimum of two feet separation to the estimated seasonal historic
groundwater (ESHGW) and 44% TSS removal before any infiltration occurs.
7.3.6 Consistency with Bridgewater’s Stormwater Management Program
The standards developed in DEP’s Stormwater Management Policy and the requirements of the
National Pollutant Discharge Elimination System provide the framework that is consistent with
the Town of Bridgewater’s Stormwater Policy and include:
♦ A Plan to Control Wastes generated by the construction activity on the construction site
including:
o Areas designated and controlled for equipment storage, maintenance, and repair
o Convenient locations for waste receptacles and a schedule for regular removal
o Wash down areas for vehicles selected to prevent contamination of Stormwater
o Covered storage areas for chemicals, paints, and solvents. Fertilizers and other toxic
materials

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o Adequately maintained sanitary facilities
♦ Erosion and Sedimentation Control Plan
♦ Plan to Construct Stormwater Management Measures
♦ Plan for Operation and Maintenance of Stormwater Management Measures including:
o A description of the annual maintenance activities that will be performed and

identification of the individual or entity who will perform them
o An estimate of the annual cost of these maintenance activities and a description of

the operation and maintenance fund that the applicant will establish
o The language of a covenant and restriction which the applicant will record in the
Plymouth Registry of Deeds binding and enforceable against the Construction Site
and the Owner from time to time thereof of to maintain the Stormwater
Management Measures.
The local approving authorities (Planning Board and Conservation Commission) will provide
additional review and conditions as each individual site plan is submitted for approval.
7.3.7 Consistency with the National Pollutant Discharge Elimination System (NPDES)
General Permit
Construction activities that disturb one acre or more are regulated under the NPDES stormwater
program. EPA will be requested to issue a Construction General Permit (CGP) that covers
discharges of stormwater from each construction site. These permits include details on inspection
requirements and SWPPP documentation requirements. Operators of each construction site will
be required to develop and implement SWPPPs and to obtain permit coverage from EPA.
7.3.8 Construction Stage Best Management Practices
A SWPPP will be drafted with all the elements proposed for the construction of each individual
site once a contractor has been chosen and a clearer plan for phasing is in place. A general permit
from the EPA will be requested a minimum 2 weeks prior to any construction activities on site.
During construction certain BMPs will be utilized to ensure that natural resources are protected
and to ensure the safety of the environment and the construction workers. BMPs for construction
include but are not limited to minimizing disturbed areas; protecting natural features; controlling
stormwater flowing onto and through the site; stabilizing soils and slopes; controlling vehicle
washing and fueling; providing concrete washout areas; implementing a spill prevention plan; and
implement an inspection schedule and trainings for the contractor and sub-contractors.

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7.3.9 Stormwater Pollution Prevention Plan (SWPPP)
The SWPPP will include eight sections as outlined below. Separate plans will be prepared for each
project location and will contain the following:
♦ Section 1: Site Evaluation, Assessment, and Planning: includes general information about
the site including location, existing vegetative cover and slopes, receiving water, sensitive
areas to be protected, potential sources of pollution, identifying potential endangered
species, and historic locations.
♦ Section 2: Erosion and Sediment Control BMPs: identifies natural features to protect,
encourages construction phasing, provides controls to control stormwater flowing onto
and through the site, measure to stabilize soils and slopes, measures to control dust on
and off site, protection for storm inlets, providing sediment barriers, and establishing
stabilized construction entrance/exit.
♦ Section 3: Good Housekeeping BMPs: establishes material handling and waste

management guidelines for the construction site, proper building material handling
staging areas, identifies designated concrete washout areas, establishes proper
equipment/vehicle fueling and maintenance practices, implements a spill prevention and
control plan, and identifies management for allowable non-stormwater discharge.
♦ Section 4: Selecting Post-Construction BMPs: this section identifies the final site BMPs
implemented to reduce site runoff and how to maintain them.
♦ Section 5: Inspections: this section identifies responsibly educated parties to ensure that
BMPs are installed and maintained properly.
♦ Section 6: Recordkeeping and Training: provides a log for changes implemented to the
SWPPP after its initial inception and to ensure that contractor, sub-contractors, and all
personnel on site are trained in the proper manner established for the site.
♦ Section 7: Final Stabilization: This section identifies the measures to be taken to provide
final stabilization of the site and to ensure no erosion of sedimentation occurs due to
construction practices.
♦ Section 8: Certification and Notification: this is the section reserved for the general permit
issued by the EPA.

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7.3.10 Operation and Maintenance Plan
As required in the Stormwater Management Policy Standards, Standard 9, the applicant shall
develop a Long-Term Operation and Maintenance (O&M) Plan to ensure that stormwater
management systems function as designed. To avoid duplication of effort, the Proponent will
prepare one plan for the operation and maintenance of stormwater BMPs that fulfills the
requirements of Standard 9 and the applicable NPDES general stormwater permit.
The Town of Bridgewater adopted its own requirements for the development of the long-term
operation and maintenance of Stormwater Management Measures that will be implemented at
the construction site. The plan must include the following:
1. A description of the annual maintenance activities that will be performed and

identification of the individual or entity who will perform them, and
2. An estimate of the annual cost of these maintenance activities and a description of the
operation and maintenance fund that the Applicant will establish, and
3. The language of a covenant and restriction which Applicant will record in the Plymouth
Registry of Deeds binding and enforceable against the Construction Site, the Owner from
time to time thereof to maintain the Stormwater Management Measures.
The Operation and Maintenance Plan will identify best management practices for implementing
maintenance activities in a manner that will minimize impacts to wetland resource areas. This
Project is subject to jurisdiction under the Wetlands Protection Act and as such the Conservation
Commission and Mass DEP will take the actions set forth below to ensure compliance with
Standard 9. Unless and until another party accepts responsibility, the Conservation Commission
and Mass DEP shall presume that the owner of the BMP is the landowner of the Property on which
the BMP is located, unless there is a legally binding agreement with another entity that accepts
responsibility for the operation and maintenance. The Order of Conditions issued by the
Conservation Commission may require the responsible party to:
1. Implement the Operation and Maintenance Plan

2. Maintain a log of all operation and maintenance activities including without limitation
inspections, repairs, replacement, and disposal (for disposal, the log shall indicate the type
of material and the disposal location)
3. Make this log available to the Mass DEP and the Conservation Commission
4. Allow the Mass DEP and the Conservation Commission to inspect each BMP to determine
whether the responsible party is implementing the Operation and Maintenance Plan
5. Submit the O & M Compliance Statement when requesting a Certificate of Compliance.
The O & M Compliance Statement shall identify the party responsible for implementation
of the Operation and Maintenance Plan and state that:
• The site has been inspected for erosion and appropriate steps have been taken to
permanently stabilize any eroded areas;

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• All aspects of the stormwater BMP’s have been inspected for damage, wear and
malfunction, and appropriate steps have been taken to repair or replace the system or
portions of the system so that the stormwater at the site may be managed in accordance
with the Stormwater Management Standards;
• Future responsible parties must be notified of their continuing legal responsibility to
operate and maintain the structure; and
• The Operation and Maintenance Plan for the stormwater BMP’s is being implemented.
7.3.11 Spill Prevention Program
Due to the sensitive nature of the Project in the Zone II, a spill prevention plan will be
implemented to ensure that any release of fuel (i.e., oil or gas) is managed quickly and efficiently.
This plan is incorporated into the Draft SWPPP.
The largest quantity most probable to be released is the contents of a single fuel storage tank of
a vehicle or truck. The points of entry to the drainage system are via catch basins with sumps and
hoods, with outlets from these catch basins into oil grit separators, and then into the two
sediment forebays before final discharge to the infiltration basin. The deep sump hooded catch
basin and oil grit separator will provide the bulk for the protection and allow time for cleaning in
these units. The detention time within the first and second forebays will allow for a secondary
measure of action to place absorbent booms or pads in these areas. The third and final control
measure is to close the outlet structures within the two sediment forebays before discharge can
be made into the infiltration basin. The v-notch weir can be closed using the pivoting plate that is
shown in Figure 7-9. The plate can be swung into position thereby limiting the potential for
contaminants to leave the site via the drainage system.
Irrigation wells located within the infiltration basins would be shut down and require cleaning and
testing prior to future use. This protection measure will be included in the spill prevention plan.

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Figure 7-9
V-Notch Weir Diagram
Chapter 8
Water and Wastewater

8.0 WATER AND WASTEWATER
8.1 Anticipated Water Demand and Wastewater Generation
The entire Lakeshore Center Development has included prior substantial improvements to the
Town’s infrastructure. When the first office building was completed, the Proponent extended
water one mile and sewer three miles, across Route 24 to the westernmost area of the Town.
These utility improvements opened opportunities for the Town of Bridgewater to expand
commercial and industrial development along Elm Street and within the Gateway District that
includes Pleasant Street east of Route 24.
The antiquated asbestos cement water line was replaced with a 16-inch ductile iron water main
that provided consumptive and fire protective water to the Lake Nippenicket area of Town. The
extension of sewer with a 6-inch forced main and two pump stations revitalized western
Bridgewater and provided a needed alternative to onsite septic systems and their potential
impact to the water quality of Lake Nippenicket.
The overall Lakeshore Center Development progressed in concert with the extension of water and
sewer along Pleasant Street to the Raynham town line and along Fruit Street, enhancing the
commercial tax base.
This final phase of the development will also benefit from the utility extensions and will allow for
continued protection of Lake Nippenicket and the Raynham aquifer. Using Title 5 estimated usage
rates and assuming that sewer is 80% of the overall water consumption, the estimated volumes
of water and sewer for the proposed Project are as follows.
Table 8-1 Anticipated Water Demand and Sewer Generation
Lot 1 Lot 4 Lot 6 Lot 7 Northern Lot

Assisted Living 55+ Residential Condominium Total
Café Shop Hotel Restaurant
Facility Community Community
Sewer
1,500 22,500 49,500 11,660 35,200 6,265 126,625
Demand (GPD)
Water
1,875 28,125 61,875 14,575 44,000 7,830 158,280
Demand (GPD)
6491/Lakeshore Center Phase 4 8-1 Water and Wastewater

8.2 Proposed Water Conservation Measures
The proposed Project will utilize conservation measures to reduce the potential water
consumption and associated impacts to the Bridgewater water supply and wastewater systems.
Specific mitigation measures will be in strict compliance with the Water Conservation Standards
of 2006 issued by the Executive Office of Energy and Environmental Affairs (EOEEA) and the Water
Resources Commission (WRC) and include the following:
♦ Utilization of 1.6-gallons per flush gravity water tanks for toilet fixtures.
♦ Use of 1.0 gallons per flush urinals.
♦ Utilization of 1.5 gallons per minute flow controllers on domestic hot and cold water
connections to lavatories.
♦ Utilization of 2.0 gallon per minute flow controllers on hot and cold-water connections to
cafeteria and food service areas.
♦ Utilization of 2.2 gallon per minute flow controllers for showerheads in the proposed
hotel.
♦ Utilization of 4.5 gallon per load appliances for dishwashers within the hotel and
restaurant and clothes washers with 9 gallons or less of water used per cycle per cubic
foot.
♦ Utilization of native plants in the landscape design
♦ Onsite wells for landscaping irrigation
Collectively, a concerted effort to reduce water consumption could result in a reduction in

sewerage generation of 25-30 percent as compared to similar projects constructed just a few
years ago.
8.3 Inflow and Infiltration
The Town of Bridgewater, as part of their connection fee process requires either a 3 for 1
reduction for I&I or a cash contribution to allow the Town to reduce inflow and infiltration
elsewhere in the municipal system. The Proponent is in communication with the Town of
Bridgewater and expects to make the appropriate monetary contribution for I/I mitigation for the
Project at the appropriate time.
Each Lot will be reviewed with the Town of Bridgewater during the permitting approval process
to ensure that adequate public water services are available to support the Project post-
construction. All stormwater will be infiltrated and managed onsite per the MassDEP
requirements. No stormwater will be connected to public utility drainage systems.

8.4 Irrigation
Water consumption and conservation of potable water has been a priority of the Town of
Bridgewater Water Department. The rules and regulations of the Town prohibit the use of water
supplied by the Town to be connected to irrigation systems. All Lots within the Project Site have
installed irrigation wells to supply water for the landscaped areas’ maintenance. In addition, since
the entire Lakeshore Center Development is within the ACEC and the aquifer for the Raynham
drinking wells, use of chemicals for fertilization is restricted. The Proponent will continue to
comply with the rules and regulations of both the Town of Bridgewater and the Town of Raynham,
including local regulations regarding outdoor water use restrictions.

Chapter 9
Historic and Archaeological Resources

9.0 HISTORIC AND ARCHAEOLOGICAL RESOURCES
Two significant Native American archaeological sites Bassett Site (19-PL- 497) and Tomb Road Area B Site
(19-PL-498) are within the area of direct effects (vegetation removal, grading, filling, etc.) from the
proposed Project on Lots 6 and 7. In March 2021, the Proponent signed a Memorandum of Agreement
(MOA) prepared by the Massachusetts Historical Commission (MHC) that outlines stipulations to mitigate
the “adverse effects” (36 CFR 800.5 and 950 CMR 71.05(a)) of proposed development on significant
archaeological resources in the Lakeshore Center project area. The MOA is included as Attachment F. As
described in Stipulation II of the MOA, implementation of the archaeological data recovery program on
the Tomb Road, Area B and Bassett sites will provide compliance with Section 106 of the National Historic
Preservation Act of 1966 as amended (36 CFR 800.6); Massachusetts General Laws, Chapter 9, Sections
26-27C, as amended by Chapter 254 of the Acts of 1988 (950 CMR 71); and the Massachusetts
Environmental Policy Act (MEPA), (G.L. c. 30, ss 61-62H and Section 11.10 of the MEPA regulations, 301
CMR 11.00).
The data recovery program has been implemented and archaeological fieldwork completed on the Bassett
and Tomb Road Area B sites by the Proponent’s consultant, The Public Archaeology Laboratory, Inc. (PAL).
Analysis of recovered cultural materials and other categories of archaeological information and
preparation of a technical report on the data recovery program by PAL is in progress.
The Proponent, assisted by PAL, has also participated in consultation and coordination with federally
recognized Native American tribes (Mashpee Wampanoag, Wampanoag Tribe of Gay Head /Aquinnah),
and the Massachusetts Commission on Indian Affairs (MCIA) during implementation of the archaeological
data recovery program on the Bassett and Tomb Road Area B sites.
Some adjustments in the Project design and specifications have been made through consultation with the
federally recognized tribes, MCIA, and the MHC. This consultation included development of a plan to
preserve in place four subsurface Native American features on the Bassett Site. A plan to remove an
unmarked Native American feature from the Tomb Road Area B Site and re-inter it at another location
selected by the tribes has been implemented. These plans to preserve and protect specific archaeological
features were carried out under an amendment to the current MHC permit and no modifications to the
MOA were necessary.
In August 2022, in response to a request from the MHC, PAL conducted an archaeological sensitivity
assessment of the Northern Lot. An archaeologically sensitive zone was identified in the Northern Lot with
the potential to contain unrecorded pre-contact Native American and post contact Euro-American sites.
An intensive archaeological survey with subsurface testing conducted by PAL identified the Lakeshore
Drive Site, an unrecorded Native American site. This site does not have sufficient integrity to be considered
a potentially significant archaeological resource and no further investigation is recommended.
6491/Lakeshore Center Phase 4 9-1 Historic and Archaeological Resources

PAL, Inc.
Chapter 10
Climate Change Adaptation and Resiliency

10.0 CLIMATE CHANGE ADAPTATION AND RESILIENCY
10.1 Introduction
The Town of Bridgewater’s Municipal Preparedness Plan, the Old Colony Planning Council’s
(OCPC) Regional Policy Plan, and the Resilient Massachusetts Action Team (RMAT) Report were
reviewed to identify climate-related hazards; assess existing and future climate vulnerabilities of
critical building infrastructure, stormwater, transportation, water, energy, and vulnerable
populations; and understand possible adaptation and resiliency opportunities.
Please refer to Attachment C for the RMAT Report.
10.2 Potential Vulnerabilities to Climate Change
10.2.1 RMAT Introduction
At the recommendation of the MEPA office, the RMAT Climate Resilience Design Standards Tool
was consulted. While the Tool is intended for use in state-funded projects with physical assets
owned and maintained by state agencies, not private developments, the Project Team used the
tool for information on climate risks. We do also note the limitations stated in the Tool that, “The
Standards do not and are not intended to replace existing practices, regulatory requirements,
codes, or existing standards required by other agencies.”
The Tool evaluates a Project Site’s Preliminary Climate Exposure Rating and Preliminary Climate
Risk Rating for Project Assets. The Tool groups these exposures and risks into the following three
climate parameters:
1. Sea level rise/storm surge

2. Extreme precipitation for urban and riverine flooding
3. Extreme heat
At a high level, the Tool evaluates these metrics based on location, useful life of the project, and
criticality from environmental, social, and economic perspectives. The output of the Tool is
recommended design criteria and standards to serve as a consistent data source for basis-of-
design. The Tool takes a 3-tiered approach based on the criticality of the asset in question. The
tiers represent the level of effort, with tier 3 being the highest and, subsequently, the most critical.
10.2.1.1 RMAT Results
The RMAT Tool determined that the Project Site is not exposed to sea level rise/storm surge and
is exposed to extreme precipitation and extreme heat.
6491/Lakeshore Center Phase 4 10-1 Climate Change

It should be noted that these results are based on the Project’s location and useful life and does
not account for aspects of the Project that are designed to address these exposure concerns, such
as stormwater best management practices, green infrastructure, redundant systems, and
efficient mechanical units and electrification.
10.2.2 Town of Bridgewater: Climate Change Study
In February of 2019, the Town of Bridgewater held two Municipal Vulnerabilities Preparedness
(MVP) workshops. Following the meetings, the “Town of Bridgewater Municipal Vulnerability
Preparedness (MVP) Plan and Summary of Findings” Report was published which provides
recommendations to address the climate change related hazards the Town of Bridgewater
anticipates facing. The Report was published in June of 2019 and identifies “flooding, wind
(including Blizzards/Nor’easters etc.), winter storms/extreme cold, and drought/extreme heat” as
the hazards most pertinent for the Town to consider.
10.2.3 Old Colony Planning Council: Regional Policy Plan
The Old Colony Planning Council (OCPC) completed a Regional Policy Plan in 2018. The Report
indicates the Region’s plan for “growth, sustainability, resiliency, and equity, addresses the
challenges of climate change on multiple fronts.” The Report indicates the greatest climate
change risks are sea level rise, changes in precipitation, rising temperatures, vector borne
diseases, and extreme weather. OCPC is looking to expand support to communities in climate
change planning by assisting in evaluation and analysis of vulnerabilities, increasing awareness of
hazard mitigation benefits, coordinating among local agencies, promoting cost-effective hazard
mitigation actions, and evaluating the effectiveness of these actions. The Report outlines
strategies to build “climate smart communities” by reducing carbon pollution, using green
infrastructure, improving water conservation and efficiency in urban and commercial settings,
improving agricultural water efficiency and water quality management, increasing use of
reclaimed wastewater, preserving and restoring wildlife habitats, improving land-use planning,
and ensuring effective emergency response.
10.3 Adaptation and Resiliency Measures
10.3.1 Extreme Heat Events / Drought Conditions
The MVP and RMAT Reports identified Extreme Temperatures as one of the top hazards for the
Town of Bridgewater: “It was concluded that with climate change, extreme temperatures in both
directions will become more common, and with warmer temperatures, increased potential for
droughts will exist”, as discussed in the MVP Report. The Report provides the following definition,
“Generally, extreme heat is considered to be over 90 degrees F, because at temperatures above
that threshold, heat-related illnesses and mortality show a marked increase”.
To adapt to more days with temperatures over 90 degrees, the Project has been designed to
include high-performance building envelopes to reduce cooling loads in the summer and the
installation of high-performance HVAC equipment. In order to reduce the urban heat island effect,

the Project will maximize vegetated surfaces and incorporate reflective roofs as well. The
landscape design is anticipated to incorporate native and adaptive plant materials to minimize
the Project’s susceptibility to drought conditions.
10.3.2 Extreme Precipitation for Urban and Riverine Flooding
To adapt to more frequent and intense storms, the Proponent will take measures to minimize
stormwater runoff and protect the Project’s mechanical equipment. The peak rate and volume of
stormwater leaving the Project Site is not expected to be increased as a result of the proposed
Project. The proposed stormwater management systems will provide the necessary storage and
recharge to reduce the peak rate and volume of runoff from the 2, 10, 25, 50, and 100-year storm
events to zero for all developed sub-watersheds. The design and construction of the individual
Lots will comply with the NPDES, the Massachusetts DEP Stormwater Management Regulations,
and local requirements of the Town of Bridgewater. Refer to Section 7.3 for additional
information.
10.3.3 Sea Level Rise / Storm Surge
Due to the Project Site not being located within the predicted mean high-water shoreline by 2030,
no historic coastal flooding at the Project Site, and not being located within the Massachusetts
Coast Flood Risk Model (MC-FRM), the RMAT Tool classified the Project Site as “Not Exposed” to
sea level rise/storm surge.

Chapter 11
Greenhouse Gas Analysis

11.0 GREENHOUSE GAS ANALYSIS
The Proponent is taking strong, practical steps to reduce fossil fuel usage while balancing its operational
imperatives to serve the needs of future tenants, as described in this chapter. The proposed Project,
including the building envelopes and mechanical systems, is being designed to minimize energy use to the
maximum extent practicable, and with an understanding of the need to reduce carbon emissions.
This chapter presents a greenhouse gas (“GHG”) analysis that complies with the MEPA Greenhouse Gas
Emissions Policy and Protocol (“GHG Policy”) of May 2010, as amended.
11.1 Introduction and Project Overview
11.1.1 MEPA Greenhouse Gas Emissions Policy and Protocol
This chapter addresses GHG emissions generated by operation of the proposed Lakeshore Center
Phase IV Development, and options that may reduce those emissions in accordance with MEPA’s
GHG Policy. The GHG Policy requires that GHG emissions are quantified and that measures to
avoid, minimize, or mitigate such emissions are identified. The GHG Policy requires proponents
to quantify the impact of proposed mitigation in terms of energy savings and GHG emissions.
The analysis provided herein focuses on emissions of carbon dioxide (“CO2”). As noted in the GHG
Policy, although there are other GHGs, CO2 is the predominant contributor to global warming.
Furthermore, CO2 is by far the predominant GHG emitted from the types of sources related to the
Project, and CO2 emissions can be calculated for these source types with readily available data.
GHG emissions sources can be categorized into two groups: stationary sources, or emissions
related to activities that are stationary on a site; and mobile sources, or emissions related to
transportation. Stationary sources can be broken down further into direct sources and indirect
sources. Direct sources include GHG emissions from fuel combustion, and indirect sources include
GHG emissions associated with electricity and other forms of energy that are imported from off-
site power plants via the regional electrical grid or local steam distribution system for use on-site.
The GHG Policy requires the Proponent to calculate and compare the GHG emissions of a code-
compliant base case to the proposed case.
11.1.2 Stationary Source Methodology
The base case is the baseline from which progress in energy use and GHG emissions reductions is
measured. The baseline is a hypothetical building designed to meet the Massachusetts State
Building Code (the “Code”), as it is in effect at the time of this PCN filing. That edition of the Code
will remain the baseline for all future energy modeling for GHG Policy compliance. The baseline is
a reference point from which to measure the effectiveness of energy efficiency improvements in
the proposed development.
6491/Lakeshore Center Phase 4 11-1 Greenhouse Gas

The current Massachusetts State Building Code is the 9th Edition, amended to incorporate the
building energy provisions of International Energy Conservation Code (“IECC”) 2015.
Massachusetts energy-efficiency amendments were adopted in February 2020. The
Massachusetts Stretch Energy Code requires buildings to achieve a 10% energy savings compared
to ASHRAE 90.1-2013 Attachment G with Massachusetts Amendments. The Massachusetts
Stretch Energy Code, together with the guidance of the modeling protocol of ASHRAE 90.1
Attachment G, defines the baseline for this GHG analysis.
The Massachusetts Stretch Energy Code is anticipated to be updated in July of 2023. At this time,
it is unknown whether the buildings will apply for their building permits prior to July 2023. The
following GHG Analysis complies with The Stretch Energy Code as it currently exists. To the extent
that the code changes when the buildings apply for their building permits, the buildings will
comply with the code updates at that time.
For the stationary source component, the proposed case presents the proposed Project including
GHG mitigation measures anticipated to be incorporated into the building design. Please refer to
Section 5.2, below, for the Stationary Source Analysis.
11.1.3 Project Overview
The Project comprises four buildings and two out-parcels:
♦ 55+ multi-family, 225 units, 307,404 sf
♦ Condominium, 4-story, 160 units, 225,000 sf
♦ Hotel, 4-story, 106 Guestrooms, 69,640 sf
♦ Assisted living, 5-story, 150 units, 200,000 sf
♦ 1,800 sf café
♦ 6,000 sf restaurant
The 55+ multi-family and the hotel both have design teams under contract. The condominium
building and the assisted living building do not yet have design teams under contract. For
purposes of this analysis, the 55+ multi-family and the condominium building will be grouped into
a similar typology (“kitchen” typology). The hotel and the assisted living building will comprise a
second typology (“non-kitchen” typology). These typologies are studied herein.
11.2 Stationary Sources
As part of the Project’s due diligence, the design team evaluated the practicality of means and
measures to minimize greenhouse gas emissions from the Project’s stationary sources, focusing
on the following categories:

♦ Building envelope
♦ Heating Ventilation and Air Conditioning (HVAC) and mechanical systems
♦ Heat recovery
♦ Solar Photovoltaics (PV)
This section evaluates the impacts of alternatives for each of these categories. Building energy
modeling is then described, followed by a description of incentives.
11.2.1 Building Envelope
A high-performing building envelope is essential to any emissions reduction strategy. Through an

iterative, collaborative process, the Project team has developed proposed building envelope
strategies for the Project that maximize energy efficiency, while simultaneously allowing the
Project to meet its unique objectives. The envelope discussed below represents the proposed
envelope as currently envisioned. Envelope specifics are likely to change as the design progresses.
Thermal Bridges
When calculating the thermal performance of the envelopes, the architect will ensure that all
scenarios properly account for thermal bridges. Thermal breaks will be incorporated in all
scenarios to ensure that proposed wall, roof, and window performance is being delivered. The
reported U-values reflect the performance after accounting for thermal bridges.
Air Infiltration
At this time, all modeling, baseline and proposed, currently assumes an air infiltration rate of 0.25
cfm per sf at 75 Pa. Please refer to Attachment D for modeling assumption tables.
The 55+ Multi-Family and the Condominium Buildings
The 55+ Multi-Family residential building will consist of a steel structural frame with concrete &
metal floor decks over a 1st floor concrete slab on grade. The ground floor will consist of lobby,
tenant amenity space, storage, indoor vehicular parking spaces and units. The upper floors will
contain units and utility spaces with the Fourth floor also having an amenity roof deck for tenants.
The building envelope for the structure will be as follows:
♦ Exterior walls will be constructed of 6” metal stud framing with cavity insulation and will
have a minimum U-value of 0.048.
♦ Unit windows will be Vinyl window units. The WWR ratio for the building is 30% and
consist of double-glazed high performance insulting glass. Operable unit windows
(16,120sf) will have a u-value of 0.300

♦ Unit balcony doors will be Vinyl sliding units (3,240sf) and will have a u-value of 0.270
♦ First floor non-unit glazing & select areas of upper floor unit fixed glazing (14,888sf) will
be comprised of a thermally-broken aluminum storefront system with non-operable
glazing and a u-value of 0.380.
♦ The roof assembly will consist of EPDM or TPO roofing, R-30 continuous insulation that
will have a minimum u-value of 0.034
♦ The slab on grade will consist of a 4” reinforced concrete slab with perimeter concrete
foundation wall. 4ft of R-10 vertical continuous insulation will be installed to the
perimeter foundation wall.
The Condominium building will have a similar construction.
Please refer to Attachment D for detailed envelope calculations.
The Hotel and the Assisted Living Buildings
The 106-room hotel, designed and operated as a franchised Hilton Garden Inn will consist of a
steel structural frame with concrete and metal floor decks over a 1st floor concrete slab on grade.
The ground floor will consist of Lobby, Bar, Lounge, Kitchen, Meeting Space, Fitness Center,
Swimming Pool, mechanical, Laundry and Back of House support space and guestrooms. The
upper floors will contain guestrooms, linen and storage spaces.
The building envelope for the structure will be as follows:
♦ Exterior walls will be constructed of 6” metal stud framing with cavity insulation and
exterior continuous insulation at façade areas utilizing EIFS finishes. Non-EIFS exterior
walls (4,772sf) will have a minimum U-value of 0.048. EIFS exterior walls (18,378sf) will
have a minimum U-value of 0.035.
♦ Guestroom windows will be thermally broken aluminum window units. The WWR ratio
for the building is 30% and will consist of double-glazed high performance insulting glass.
Fixed guestroom windows (3,800sf) will have a u-value of 0.310. Operable guestroom
windows (3,395sf) will have a u-value of 0.420
♦ First floor non-guestroom glazing (2,254sf) will be comprised of a thermally-broken
aluminum storefront system with non-operable glazing and a u-value of 0.380.
♦ The roof assembly will consist of EPDM or TPO roofing, R-30 continuous insulation that
will have a minimum u-value of 0.034
♦ The slab on grade will consist of a 4” reinforced concrete slab with perimeter concrete
foundation wall. Four feet of R-10 vertical continuous insulation will be installed to the
perimeter foundation wall.

The Assisted Living Building will have a similar construction. Please refer to Attachment D for
detailed envelope calculations.
11.2.2 HVAC and Mechanical
The HVAC and mechanical systems design have been evaluated for opportunities to reduce GHG
emissions. The evaluation includes a review of options to maximize the use of electricity as an
energy source, based on the expectation that the electric grid will continue its downward GHG
emissions trend due to a greater reliance on renewable sources, and that electrification of HVAC
systems would allow the Project’s GHG emissions to mirror that downward trend. The design
team has considered available incentives and operational savings in evaluating these alternatives.
The 55+ Multi-Family and the Condominium Buildings
The proposed design will incorporate in-unit gas-fired combination boilers generating domestic
hot water as well as hydronic hot water for in-unit air handlers for space heating. The air handlers
will use split-direct expansion cooling for air conditioning, and will be paired with in-unit exhaust
fans and natural ventilation. Common spaces will be served with gas-fired packaged air handlers
with direct expansion cooling and total enthalpy energy recovery ventilators (ERVs). Because
utility bills will be the responsibility of each unit occupant, any systems installed must be unitary
in nature within each dwelling unit, which limits the consideration of centralized systems.
Kitchen stoves are planned to be gas and clothes dryers are planned to be electric.
As part of this analysis, alternate systems have been evaluated and compared to the proposed
systems. These systems included:
♦ HERS 45 alternative that uses high-efficiency Low temperature rated electric heat pumps
and local heat pump hot water heaters in lieu of combination boiler for dwelling units and
gas fired furnaces in common areas as well as energy recovery ventilators in each unit.
♦ A PassiveHouse alternative that uses the same systems at the HERS 45 alternative plus
improved window glass and reduced air infiltration.
The all-electric and PassiveHouse alternatives showed reductions in GHG. The cost to employ cold-
temperature heat pumps in lieu of combination boilers is negligible for both the 55+ Multifamily
and the Condominium building. There is an added cost to replace the combination boilers with
heat pump water heaters. There is also added cost to improve the envelope in both cases. There
are additional soft costs associated with Passive House certification. There would be MassSave and
State incentives available to the buildings for either using heat pumps or for achieving Passive
house. Please see Table 11-1 for cost breakdowns for these buildings.

Table 11-1 55+ Multi-Family and Condominium Buildings Passive House Cost Analysis
Measure Cost
Condo 55+
Heat pump water ILO combination boilers $775,000 $1,071,000
Improved Roof $510,000 $694,000
Improved Walls $375,000 $510,000
Improved Vision glass $188,000 $256,000
Reduced Infiltration $883,000 $1,201,000
Added Soft Costs $112,000 $158,000
Total Added cost $2,843,000 $3,890,000

Passive House Incentive -$480,000 -$675,000
Net Added Cost $2,363,000 $3,215,000
Given that tenants see the benefit in reduced energy costs, the added cost of the HERS 45 and
Passive House alternatives do not pay back for the owner. Due to the ongoing volatility and
uncertainty of market conditions, construction costs, and potential future code changes, the
Proponent cannot commit to pursue HERS 45 or Passive House on these buildings at this time.
The team will, however, continue to evaluate Passive House design as the Project progresses.
Please refer to Attachment D for modeling input assumptions.
The Hotel and the Assisted Living Buildings
As a franchise approved development, building mechanical systems for the hotel will need to
comply with franchise brand standards. Similar systems have been assumed for the Assisted Living
building analysis. Enhancements to the required systems will be evaluated as design proceeds.
The proposed systems are listed below for the initial design approach.
♦ Guest rooms: Vertical Terminal Air Conditioners (VTACs) with backup electric heat. No
VTACs are currently available in the current market which satisfy brand standards and
have low temperature heat pump functionality. A Dedicated Outside Air (DOAS) system
will utilize an energy recovery wheel to centralize all ventilation and exhaust air for both
the guest rooms and common spaces.
♦ Common Spaces: gas-fired packaged air handlers with direct expansion cooling will be
provided.
♦ Domestic Hot Water: Gas-fired high efficiency central hot water plant (“intellihot” or
equal)
♦ As part of this analysis, all-electric alternate systems have been evaluated and compared
to the proposed systems. These systems include: low temperature heating-capable VRF
systems serving guest rooms in lieu of VTACs with backup heat.
♦ Air Source Heat Pumps to supply domestic hot water production

Because the hotel and assisted living rooms do not have kitchens, they do not qualify for the
MassSave Passive House incentive, and would pursue MassSave’s whole-building performance
incentives instead.
While the all-electric alternative showed a reduction in GHG, the cost to employ VRF in lieu of
VTACs is $890,000 for the hotel and $2.4 million for the Assisted Living building. As detailed in the
cost and energy analysis included in Attachment D, the all-electric alternative is not financially
feasible.
Please refer to Attachment D for mechanical system details.
11.2.3 Solar Photovoltaics
The design team has evaluated options for the local generation of electricity with the use of
photovoltaic (PV) panels. The evaluation included a review of roof spaces for physical availability
of space, shading, constructability, potential conflicts with uses, and potential electric generation.
The design team has evaluated potential locations for the opportunity to install PV arrays. Due to
competing space requirements of the mechanical systems, unencumbered roof space is limited.
PV-ready zones will be provided as required by code, a minimum of 40% of the roof area. As design
progresses, the design team will endeavor to group mechanical equipment in order to maximize
the PV-ready zone on each building’s roof. The size of this PV-ready area will be determined as
design progresses.
11.2.4 Electric Vehicle Parking
The Proponent is committed to supporting the State’s mission of transitioning to renewable

energy sources by employing electric systems wherever feasible. Accordingly, the Proponent has
committed to the installation of EV charging stations to serve 36 parking spaces for this Project;
six spaces will be located at the Hotel, and 10 spaces at each of the 55+, Condominium, and
Assisted Living buildings. In addition, 36 additional spaces will be built “EV-ready” with the
infrastructure in place for future EV installation.
11.2.5 Building Energy Modeling
Building energy modeling was performed by The Green Engineer. Modeling for the hotel and
assisted living buildings was performed using eQuest v3.65. The modeled “Baseline Case” is based
on ASHRAE 90.1‐2013 Appendix G, with three additional Efficiency Package Options in the
baseline model per C406.1. At this time, the following Packages have been assumed and have
been included in the baseline for the buildings:
♦ 10% more efficient HVAC performance in accordance with C406.2

♦ 10% reduced lighting power per C406.3
♦ Enhanced Envelope performance in accordance with Section C406.8

Modeling for the 55+ multi-family and the condominium was performed using REM/Rate 16.3.3.
Because the HERS Analysis does not utilize an ASHRAE basecase, those results are presented in
the Green Engineer’s MEPA Assessment, included as part of Attachment D.
Modeling results for the hotel and assisted living buildings are summarized in Tables 11-2 and 11-
3. Compared to a code-compliant building, the “Proposed Case” Project is expected to decrease
GHG emissions by approximately 15.3 percent or approximately 108 tons of CO2/year.
Energy Use Intensity (EUI) is a measure of annual building energy use per square foot of
conditioned space. EUI values for the Project are included in modeling output. Detailed modeling
inputs and outputs are provided in Attachment D.

Table 11-2 Hotel Energy Modeling Results
Hotel
Modeled Conditioned space 66,940 sf

Design Conditioned space 66,940 sf
Factor 1.0
Baseline Case Proposed

(ASHRAE 90.1- All-Electric ASHP
2013, App. G) heat and hot water
DIRECT (NATURAL GAS) MMBtu/yr MMBtu/yr

subtotal 1,910 513
INDIRECT (ELECTRICITY) MWh/yr MWh/yr

subtotal 270 438
ENERGY USE INDEX PNNL reference3 kBtu/sf/yr kBtu/sf/yr

47.6 42.3 30.0
Diff, % (compared to baseline) -29%
GHG EMISSIONS tons/yr tons/yr

Direct Gas-Burning 101 27
Indirect Electricity 77 126
Total 179 153
Diff, tpy -26
Diff, % (compared to baseline) -14.4%
CARBON EMISSION INTENSITY kg CO2 /sf/yr

Current 2.29
2035 1.16
CO 2 Emission Factors:
Year 2022 2035
1
Electricity 633 391 lb/MWh
2
Natural Gas 117 117 lb/MMBtu
1
2019 ISO New Engl a nd El ectri c Genera tor Ai r Emi s s i ons Report
2
EIA Fuel Emi s s i ons Fa ctors , Wei ghted Na ti ona l Avera ge (1029 Btu/s cf)
3
Pa ci fi c Northwes t Na ti ona l La bora tory s tudy, Ma s s a chus etts Zone 5A, ASHRAE
90.1-2013, Mi d-Ri s e Apt.

Table 11-3 Assisted Living Building Energy Modeling Results
Assisted Living
Modeled Conditioned space 200,000 sf

Design Conditioned space 200,000 sf
Factor 1.0
Baseline Case Proposed

(ASHRAE 90.1- All-Electric ASHP
2013, App. G) heat and hot water
DIRECT (NATURAL GAS) MMBtu/yr MMBtu/yr

subtotal 5,707 1,531
INDIRECT (ELECTRICITY) MWh/yr MWh/yr

subtotal 805 1,309
ENERGY USE INDEX PNNL reference3 kBtu/sf/yr kBtu/sf/yr

47.6 42.3 30.0
Diff, % (compared to baseline) -29%
GHG EMISSIONS tons/yr tons/yr

Direct Gas-Burning 303 81
Indirect Electricity 223 363
Total 526 444
Diff, tpy -82
Diff, % (compared to baseline) -15.6%
CARBON EMISSION INTENSITY kg CO2 /sf/yr

Current 2.22
2035 1.16
CO 2 Emission Factors:
Year 2022 2035
1
Electricity 611 391 lb/MWh
2
Natural Gas 117 117 lb/MMBtu
1
2019 ISO New Engl a nd El ectri c Genera tor Ai r Emi s s i ons Report
2
EIA Fuel Emi s s i ons Fa ctors , Wei ghted Na ti ona l Avera ge (1029 Btu/s cf)
3
Pa ci fi c Northwes t Na ti ona l La bora tory s tudy, Ma s s a chus etts Zone 5A, ASHRAE
90.1-2013, Mi d-Ri s e Apt.

11.2.6 Restaurant and Cafe
The 6,000 sf restaurant and the 1,800 sf café will likely be sold as permitted pads to franchise
developers. These buildings will be built with all required energy efficiency measures as specified
in the Massachusetts Energy Code in effect at the time of their construction.
11.2.7 Incentives
The Project team has engaged with MassSave early in the design process to maximize incentives,
including a meeting with MassSave on August 26, 2022. The Project intends to participate in
MassSave’s whole-building performance incentive or Passive House incentive as applicable.
MassSave incentives have been estimated and factored into the payback analysis for the design
decisions. This revenue stream will continue to be used to inform the selection and
implementation of energy efficiency measures as the Project advances through design.
The team will continue to engage with MassCEC to take full advantage of any new incentives that
may apply to the Project.
11.3 Mobile Source Emissions
As part of the GHG analysis, emissions of GHGs, measured as carbon dioxide equivalents (CO2e),
from regional traffic associated with the Project were evaluated.
11.3.1 Traffic GHG Analysis
In accordance with the MEPA GHG Policy, GHG emissions were estimated for mobile sources
within the transportation study area (see Attachment A for the transportation analysis). For
mobile source GHG emissions, the methodology follows the same methodology that is outlined
in MassDEP guidance for mesoscale analyses. 1
A mesoscale GHG analysis predicts the change in regional CO2e due to the Project. The analysis
includes a comparison of the future Build condition to the No-Build condition. If emissions are
greater for the Build condition, reasonable and feasible mitigation measures will be evaluated.
The methodology and parameters for the mesoscale GHG analysis follow methodology approved
by MassDEP.
The mesoscale analysis performed for this Project predicts the change in regional GHG emissions
due to the Project. The total vehicle pollutant burden was estimated for the 2022 Existing
condition and the No-Build and Build conditions for year 2029. Traffic conditions are described in
more detail in Attachment A.
1
MassDEP, Guidelines for Performing Mesoscale Analysis of Indirect Sources, May 1991.

The EPA has developed an emissions factor model called MOVES3, and MassDEP provides state-
and county-specific inputs required for this model. Therefore, the MOVES3 computer program
was used to estimate motor vehicle emissions of greenhouse gases on the roadway network in
the Project area. Average hourly emission estimates were calculated using the vehicle count data
provided in the transportation study, mileage between intersections, and county-specific model
inputs provided by MassDEP. Due to time constraints, Plymouth County 2029 inputs from
MassDEP were unable to be obtained, so the 2029 MOVES3 outputs were generated using 2028
factors for all values except the vehicle counts from the transportation study. These results are
conservative, since MOVES3 inputs reflect the fact that newer vehicles with fewer emissions
replace older vehicles each year.
Traffic volumes provided in Attachment A form the basis of the mesoscale GHG study.
Approximately 20 roadway links and 7 intersections were included in the emissions analysis (with
9 intersections in the 2029 Build case). Peak hour traffic volumes were provided in the traffic
analysis. Estimates of average daily traffic (ADT) were made from the peak hour volumes
assuming a 10 percent K-Factor. This ADT was then converted into average hourly volumes by
dividing by 24. Average speed was assumed based on roadway type (typically 10-40 mph for
arterial roads) for all links. Distances for the links were estimated with mapping software.
MOVES output emissions are in grams per hour. Since average hourly traffic data were input,
emissions in tons per year were calculated assuming a seven-day week for 52 weeks per year.
For intersection emissions, idle vehicle emission rates were obtained in MOVES3 by using an
artificial roadway link with 1 vehicle and a zero miles per hour vehicle speed. Emission rates are
outputted with units of grams/second (mass per hour) for idling vehicles. This method is
recommended by EPA to get emission factors for air quality concentration analyses of idling
vehicles at intersections (microscale analyses). 2 These emission factors were then used with
vehicle counts and delay information from the traffic analyses to estimate vehicle emissions at
intersections.
GHG Mobile Source Tables, included as part of Attachment D, present the intersection emissions
calculations, and the Project-specific link data input into the MOVES3 program.
11.3.2 Traffic GHG Analysis Results
Table 11-4 represents the difference between the Existing case and the future No-Build case (i.e.,
traffic expected without the addition of the Project to the area). Anticipated improvements in
vehicle engine and emissions technologies, which are expected to reduce the per-vehicle emission
rates, typically reduce future emissions. This results in a 6% decrease in GHG.
2
U.S. EPA, 2021. Using MOVES in Project-Level Carbon Monoxide Analyses. EPA-420-B-21-047

Table 11-4 Regional Traffic GHG Emissions Analysis Summary (No-Build)
CO2e CO2e
Pollutant
(lbs/day) (tons/yr)
2022 Existing 12,073 2,203
2029 No-Build 11,341 2,070
Difference -732 -134
Difference (%) -6% -6%
Table 11-5 represents the differences between the No-Build case and the Build case (i.e., traffic
associated with the addition of the Project to the area without any Proponent-proposed
mitigation).
As shown, the 2029 Build condition exhibits a 13 percent increase of CO2e emissions compared to
2029 No-Build condition. This is due to the increase in vehicular traffic and subsequent increased
delay times generated by the proposed Project alone. The increased vehicle volumes produce
increased delays at nearby intersections.
Table 11-5 Regional Traffic GHG Emissions Analysis Summary (Build)
Pollutant CO2e lbs/day CO2e tons/yr
2029 No-Build 11,341 2,070

2029 Build 12,847 2,345
Difference 1,506 275
Difference (%) 13% 13%
11.3.3 Summary
Table 11-6 shows the details of the mobile source GHG analysis from case to case. Changes are
based on the case to the left. Vehicle miles traveled (VMT) represents the approximate mileage
of all vehicles traveling on the modeled roadway network, and the net VMT change represents
the difference from the prior case. A zero change in VMT means that there are no vehicles added
or removed from the network for that case. Net delay represents the time sum of all idle traffic
at all network intersections over the course of a day.
While all VMT considered do occur or are expected to occur in the Project area, the majority of
vehicle trips to and from this Project are expected to be drawn from vehicles already travelling
past the Project Site.

Table 11-6 Regional Traffic GHG Emissions Analysis Summary
2022
Units 2029 No-Build 2029 Build
Existing
Daily VMT veh-miles/day 8,161 8,736 10,258
Net Change veh-miles/day - 575 1,523
Net Delay veh-hrs/day 41 49 71
Net Change veh-hrs/day - 7 22
Roadway CO2e tpy 2,150 2,015 2,264

Intersection CO2e tpy 54 55 80
Total CO2e tpy 2,203 2,070 2,345
Net CO2e Change tpy - -134 275
GHG emissions between the No-Build and Build conditions are compared to determine the mobile
source GHG emissions related to the Project. Table 11-7 shows the Project-related mobile source
GHG emissions.
Table 11-7 Project Traffic GHG Emissions Analysis Summary
Case 1
units 2029 Build minus 2029 No-
Build
Daily VMT veh-miles/day 1,522
Net Delay veh-hrs/day 22
Roadway CO2e tpy 250
Intersection CO2e tpy 25
Net CO2e Emissions tpy 275
11.4 Summary and Mitigation Commitments
11.4.1 Project GHG Summary
Table 11-8 presents a summary of the project GHG emissions for the Baseline and Proposed cases.
Because the HERS studies do not calculate a baseline, the Project summary includes the Hotel and
Assisted Living buildings only. GHG emissions from the Project’s stationary sources are calculated
to be 597 tons per year compared to a baseline of 705 tons per year. This 108-ton reduction
represents a 15.3 percent reduction in GHG emissions.

Table 11-8 Project GHG Emissions Summary
Baseline Proposed Percent

Source Difference
Tons/year tons/yea Change
Stationary 705 597 -108 -15.3%
Mobile 2,070 2,345 275 13.3%
11.4.2 Proponent’s Commitments to GHG Reduction
The Proponent has detailed its commitments to mitigate project GHG emissions. Additional
mitigation measures have not been quantified, primarily because the degree of accuracy or the
reliability of the quantification method is uncertain.
The Proponent is committed to environmental stewardship. As the Project design develops

further, the Proponent expects that additional technologies described previously, or possibly new
technologies developed in the interim period, may be adopted that will further decrease GHG
emissions, but these are not yet ripe for selection. The Proponent will encourage the continued
evaluation of energy efficiency and renewable energy measures throughout the life of the Project.
The Proponent is committed to the following mitigation elements for the Project:
♦ High performance building envelope;
♦ Light or reflective roofs;
♦ Reduced lighting power densities;
♦ High-efficiency HVAC equipment;
♦ High performance exterior lighting;
♦ Energy Star appliances;
♦ Low-flow fixtures;
♦ Recycling collection areas; and
♦ Construction waste recycling.
The Proponent has included in the design of the building, all feasible GHG emissions mitigation in
order to avoid, reduce, minimize, or mitigate damage to the environment.
The Proponent is committed to implementing the energy efficiency and GHG emission reduction
measures presented in this analysis but must retain an amount of design flexibility to allow for
changes that will inevitably occur as design progresses. If, during design of the project, a specific

combination of design strategies proves more advantageous from an engineering, economic, or
space utilization perspective, the design of the buildings may vary from what has been described
herein. Energy performance minima and associated GHG emission reductions will be adhered to.
11.4.3 Proponents’ Commitments to Self-Certification
Upon completion of each building or group of buildings, the Proponent will submit a self-
certification to the MEPA Office, prepared in accordance with the GHG Policy. This certification
will identify the GHG mitigation measures incorporated into the building and will illustrate the
degree of GHG reduction from a Baseline case, as Baseline is defined herein, and how such
reductions are achieved. Details of the Proponent’s implementation of operational measures will
also be included.

Chapter 12
Construction Period Impacts

12.0 CONSTRUCTION PERIOD IMPACTS
12.1 Introduction
Construction impacts are temporary in nature since they are limited to the duration of the
construction period. Construction impacts are typically related to noise, air quality, water quality,
and traffic. Temporary construction-period impacts related to the Project will be managed to
minimize disruption to the surrounding neighborhood. The Proponent will prepare a Construction
Management Plan in consultation with the Town of Bridgewater.
During the construction phases of the Project, the Proponent will also provide the name,
telephone number, and address of a contact person that will serve as a community liaison relative
to mitigating construction period impacts. The construction contact person will be responsible for
responding to questions, comments, and concerns of the residents and businesses in the
neighborhood.
12.2 Construction Schedule
The Project will be constructed in two phases, as described below. Phase 1 is anticipated to start
in 2023 once all necessary permits and approvals have been obtained. Phasing may be adjusted
due to market conditions.
♦ Phase 1: Construction will begin with the 4-story, 225-unit 55+ residential community on
Lot 6 and the 4-story, 106-room hotel on Lot 7. Phase 1 is anticipated to take
approximately 1 year.
♦ Phase 2: Construction is anticipated to start for the rest of the development components
starting in 2025, consisting of the 4-story, 160-unit condominium community on Lot 7;
the 5-story, 150-unit assisted living facility on Lot 4; 6,000 GSF restaurant on the north
side of Pleasant Street adjacent to Lake Nippenicket; and the 1-story, approximately 1,800
GSF café shop on Lot 1. Phase 2 is anticipated to take approximately 4 years.
12.3 Construction Methodology/Public Safety
Construction management approaches which appropriately ensure public safety and protect
nearby residences and businesses will be employed. Techniques such as barricades, walkways,
wayfinding elements and signage will be used as appropriate to mitigate the impacts on local
businesses and residents. The Construction Manager will prepare routing plans for trucking and
deliveries, plans for the protection of existing utilities, and measures to control noise and dust.
Secure fencing, signage and covered walkways may be employed to ensure the safety and
efficiency of pedestrian and vehicular traffic flows. In addition, sidewalk areas and walkways near
construction will be well marked and lighted to protect pedestrians and ensure their safety. Public
safety for pedestrians on abutting sidewalks will also include covered pedestrian walkways when
appropriate. If required, police details will be provided to facilitate traffic flow.
6491/Lakeshore Center Phase 4 12-1 Construction Period Impacts

12.4 Construction Noise
The Proponent is committed to mitigating noise impacts from Project construction. While it is
understood that most construction activities will produce noise and vibration, the Proponent’s
contractor will be required to adhere to noise and vibration standards established at the
beginning of the Project in order to mitigate local noise and vibration impacts.
The CMP will incorporate appropriate construction noise mitigation measures, including as
necessary:
♦ Instituting a proactive program to ensure compliance with applicable noise regulations;
♦ Using appropriate mufflers on all equipment and ongoing maintenance of intake and
exhaust mufflers;
♦ Muffling enclosures on continuously running equipment, such as air compressors and

welding generators;
♦ Replacing specific construction operations and techniques by less noisy ones where
feasible;
♦ Selecting the quietest of alternative items of equipment where feasible;
♦ Scheduling equipment operations to keep average noise levels low, to synchronize the
noisiest operations with times of highest ambient levels, and to maintain relatively
uniform noise levels;
♦ Turning off idling equipment where feasible; and
♦ Locating noisy equipment at locations that protect sensitive locations by shielding or

distance where feasible.
12.5 Construction Air Quality
Short-term air quality impacts from fugitive dust may be expected during excavation and the early
phases of construction. Plans for controlling fugitive dust during excavation and construction
include mechanical street sweeping, wetting portions of the site during periods of high wind, and
careful removal of soil and debris by covered trucks. The construction contract will provide for a
number of strictly enforced measures to be used by contractors to reduce potential emissions and
minimize impacts. These measures are expected to include:
♦ Using wetting agents on areas of exposed soil on a scheduled basis;
♦ Using covered trucks when feasible;
♦ Minimizing spoils on the construction site;

♦ Monitoring of actual construction practices to ensure that unnecessary transfers and
mechanical disturbances of loose materials are minimized;
♦ Minimizing storage of debris on the site; and
♦ Periodic street and sidewalk cleaning with water to minimize dust accumulations.
Massachusetts law (MGL Chapter 90, Section 16A and 310 CMR 7.11) requires that vehicles idle
for no more than five minutes. To reduce engine idling, the selected contractor(s) will be notified
of the Massachusetts anti-idling regulations.
MassDEP implements the Diesel Retrofit Program for construction equipment engines. The
Proponent will investigate compliance with MassDEP’s Diesel Retrofit Program and will comply
with requirements for the use of ultra-low sulfur diesel (ULSD) in off-road engines. The Diesel
Retrofit Program, formerly called the Clear Air Construction Initiative of the Clean Construction
Equipment Initiative, originated as an air quality mitigation measure for the Central Artery/Tunnel
Project. The Program encourages users of diesel construction equipment to install exhaust
emission controls such as oxidation catalysts or particulate filters on their diesel engines.
The Proponent acknowledges the importance of emission controls and will encourage contractors
to comply with the Diesel Retrofit Program. Proper emission controls, use of clean fuels, control
of truck and equipment idling times, and conducting operations without affect to neighbors’ clean
air are all important priorities to the Proponent, and the Proponent will mitigate the construction
period impacts of diesel emissions to the maximum extent feasible.
In addition to the items listed above, all trucks leaving the site must have all dirt/mud removed
from the wheels and undercarriage of the truck prior to leaving the site. In addition, any loads
containing soil for off-site disposal will be covered. Construction vehicles and equipment will not
be permitted to be washed in the streets outside of the Project Site. Excess water from the wheel
wash stations will be managed, and catch basins in the surrounding street will be protected from
potential runoff from the cleaning operations.
12.6 Construction Solid Waste and Recycling
The Proponent will take an active role with regard to the reprocessing and recycling of
construction waste, and construction and demolition recycling (C&D) will be a sustainable
measure for the Project. A construction and demolition waste management plan will be prepared,
which will establish waste diversion goals, specify commingled versus site separated strategies,
and describe where the material will be taken and how the recycling facility will process the
material. The goal for C&D recycling on the Project will be to divert 75% of construction and
demolition debris from landfills. Disposal contracts will include specific requirements that will
ensure that construction and demolition procedures allow for the necessary segregation,

reprocessing, reuse and recycling of materials when possible. Construction and demolition
activities will be conducted so that materials that may be recycled are segregated from those
materials not recyclable to enable disposal at an approved solid waste facility.
For those materials that cannot be recycled, solid waste will be transported in covered trucks to
an approved solid waste facility, per MassDEP Regulations for Solid Waste Facilities, 310 CMR
16.00. This requirement will be specified in the disposal contract.
If asbestos containing material or other hazardous materials are encountered, it will be handled
and disposed of in full compliance with all applicable regulations
12.7 Construction Employment and Worker Transportation
To reduce vehicle trips to and from the construction site, minimal construction worker parking
will be available at the site and all workers will be strongly encouraged to use public
transportation and ridesharing options. The general contractors will work aggressively to ensure
that construction workers are well informed of the public transportation options serving the area.
Space on-site will be made available for workers' supplies and tools so they do not have to be
brought to the site each day.
12.8 Construction Access and Staging
Although specific construction and staging details have not been finalized, the Proponent and its
construction management consultant will work to ensure that staging areas will be located to
minimize impacts to pedestrian and vehicular flow. Secure fencing and barricades will be used to
isolate construction areas from pedestrian traffic adjacent to the site. Construction procedures
will be designed to meet all Occupational Safety and Health Administration (OSHA) safety
standards for specific site construction activities.
12.9 Erosion and Sedimentation Control
During the site work, particularly during the site grading process, measures will be taken to
provide erosion sedimentation protection. Bio-fence and straw bales will be located on a drawing
and installed in accordance with that plan to provide erosion control. Surface water will be
controlled through the use of diversion swales and pumping. Grading will be performed as such
to allow erosion control measures to be effective during rainfall events.
The Project is subject to the provisions of the National Pollutant Discharge Elimination System
(NPDES) because the proposed development results in the disturbance of more than one acre of
land. Prior to the start of construction, the property owner and/or general contractor must file a
Notice of Intent (NOI) with the U.S. Environmental Protection Agency (EPA) under the NPDES
General Permit for Construction Activities. The NOI will include a Stormwater Pollution Prevention
Plan (SWPPP). The SWPPP will include a project description, construction schedule and sequence,
required erosion and sedimentation control, soil stabilization, documentation regarding
inspections and maintenance, and a spill prevention plan. The SWPPP will be certified by the site

owner and the general contractor, and the general contractor and all subcontractors will be
responsible for the implementation and maintenance of the plan. The SWPPP will be periodically
inspected by authorized personnel. A Preliminary SWPPP for the Project will be prepared that is
intended to serve as the framework for the SWPPP prepared by the site contractor in coordination
with the Proponent.
The SWPPP will be implemented during construction to comply with the requirements of the
NPDES General Permit for Construction Activities. The project contractor will be responsible for
implementing and maintaining all erosion and sedimentation control measures. Below are specific
recording and inspection requirements:
♦ A copy of the NPDES submittal and SWPPP must be kept on-site at all times during
construction and will be made available to all interested parties.
♦ Records must be maintained by the permittee for a period of three years from the date
of stabilization of the site. Stabilization occurs when the site has over 70 percent
vegetative growth and/or mechanical stabilization throughout.
♦ The detailed plans of completed work must be added to the NPDES and SWPPP
information specified above as they become available.
All inspections will be conducted by qualified personnel who will produce written quantitative
and qualitative reports on the construction methods, general condition of the site, the condition
of erosion control measures, and the status of the installation of drainage structures.
♦ Inspections are required during site alteration a minimum of one of every seven days
while surfaces are not stabilized.
♦ Inspections are required within 24 hours of storms which produce 0.25-inches or greater
of precipitation.
♦ The inspection reports / forms become part of the contractor’s SWPPP and should be
maintained for a minimum of 3-years after the filing of the Notice of Termination.
If dewatering is required to control groundwater during construction and the groundwater

contains pollutants, then a NPDES Remediation General Permit may be required.

Chapter 13
Mitigation and Draft Section 61 Findings

13.0 MITIGATION AND DRAFT SECTION 61 FINDINGS
This Chapter provides a summary of proposed mitigation and Proposed Section 61 Findings for the Project.
13.1 Introduction
M.G.L.c.30, s.61 requires that “[a]ll authorities of the Commonwealth … review, evaluate, and
determine the impact on the natural environment of all works, projects or activities conducted by
them and … use all practicable means and measures to minimize [their] damage to the
environment. … Any determination made by an agency of the Commonwealth shall include a
finding describing the environmental impact, if any, of the project and a finding that all feasible
measures have been taken to avoid or minimize said impact.” Each state agency that issues a
permit for the Project shall issue a Section 61 Finding in connection with permit issuance,
identifying mitigation that is relied upon to satisfy the Section 61 requirement. A proposed
Section 61 Finding is provided in Section 11.3, and a table of mitigation measures is included as
part of the Section 61 Finding. All mitigation will be the responsibility of the Proponent.
13.2 Anticipated State Permits and Approvals
The only State Action for the Project is the issuance of a Vehicular Access Permit by the
Massachusetts Department of Transportation (MassDOT).
In accordance with section 11.16(3), the Proponent will circulate the Draft EIR to any State and
municipal agencies from which the Proponent will seek permits or approvals. See Attachment G
for the Circulation List.
13.3 Proposed Section 61 Findings
Project Name: Lake Shore Center Phase 4
Project Location: Bridgewater, MA
Project Proponent: Claremont Companies
EEA Number: 16558
Date Noticed in Monitor: December 23, 2022
The potential environmental impacts of the Project have been characterized and quantified in the
ENF dated October 31, 2022 and this Draft EIR, which are incorporated by reference into this
proposed Section 61 Finding. Throughout the planning and environmental review process, the
Proponent 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, MassDOT finds
that there are no significant unmitigated impacts.
6491/Lakeshore Center Phase 4 13-1 Mitigation and Draft Section 61 Findings

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 MEPA. The
Proponent has accordingly prepared the annexed Table of Impacts and Mitigation Measures that
specifies the mitigation that the Proponent will provide.
Now, therefore, [AGENCY], having reviewed the MEPA filings for the Project, including the
mitigation measures itemized on the annexed Table of Impacts and Mitigation Measures, finds
pursuant to M.G.L. C. 30, S. 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]
Table 13-1, beginning on the following page summarizes the mitigation measures related to the
required state actions and the schedule for implementation. The Proponent will be responsible
for all mitigation measures.

Table 13-1 Summary of Mitigation Measures
Mitigation Schedule Cost

Lake Shore Center Phase 4
Transportation
As requested in the ENF certificate, a multimodal mitigation package has been During Part of
identified to support the increase in walking, bicycling, and transit by construction overall cost
employees and residents. In response to this request, the following mitigation
measures are proposed to be implemented as part of the project.
• Installation of push button actuated rapid rectangular flashing
beacons (RRFB) at the existing crosswalk across Pleasant Street just
west of Lakeshore Center
• Construction of a new crosswalk and RRFBs across Pleasant Street
west of Old Pleasant Street providing a direct connection to the
proposed restaurant.
• Repaint existing crosswalks across Pleasant Street just west of
Lakeshore Center and just east of Summit Drive
The proposed Project will implement a Transportation Demand Management During Part of
(TDM) to encourage the use of alternative modes of transportation to reduce operation operating
single occupancy vehicles (SOV) trips to the site. As part of the project’s cost
commitment to supporting alternative transportation measures, the following
elements would be implemented as part of the project’s TDM:
• Establish TDM Coordinator – The project would establish a TDM
coordinator to oversee site-related transportation demand
management, provide central commuter information centers within
the site to assist employees, including posting Greater Attleboro
Taunton Regional Transit Authority (GATRA) and Brockton Area
Transit Authority (BAT) bus schedules at central points.
• Employee Scheduling – Site operations will be designed to stagger
employee shifts to minimize peak arrival and departure at the site.
Employees will be scheduled to minimize arrival and departure during
peak hours to minimize the impacts to traffic operations on the
surrounding roadways and intersections.
• Bicycle Storage – On-site bicycle racks and storage will be installed to
promote bicycle use by employees and customers.
• Pedestrian Access – As part of the development of the site, sidewalks,
internal to the site, will be installed around each of the proposed
buildings and ADA compliant curb ramps, crosswalks, and van-
accessible ADA parking spaces would be installed within the site.
• Car sharing/Carpooling – The development will provide information
on State resources available for carpools, taxis, and on-demand ride-
hailing services. Mass.gov provides information on various resources

Table 13-1 Summary of Mitigation Measures (Continued)

Transportation
for trips, ranging from carpool and vanpool options, to help finding
local taxi service, to information on local transportation provides by
cities and towns, including:
o RideMatch: An online searchable directory open to the public to
find public, private and accessible transportation options. The
main providers listed for Bridgewater are A&A Metro
Transportation – Bill’s Taxi Service, Bridgewater Council on Aging
(Dial-A-Bat), and BSU Blue Line.
The proposed project will complete an annual transportation monitoring During Part of
program for a period of five years, beginning six months after occupancy of the operation operating
full-build project, to evaluate the adequacy of the mitigation measures and cost
determine the effectiveness of the TDM program. The program will include:
• Simultaneous automatic traffic recorder (ATR) counts at each
proposed site driveway for a continuous 24-hour period on a typical
weekday
• Travel survey of employees and patrons at the site (to be administered
by the Transportation Coordinator)
• Weekday AM and PM and Saturday peak hour turning movement
counts (TMCs) and operations analysis at “mitigated” intersections,
including those involving site driveways
• Transit ridership counts of services provided by Dial-a-Bat, as able to
be obtained from Brockton Area Transit.
Land Impacts
The amount of land alteration necessary for the Project has been minimized During Part of
through a variety of design measures, including the following: construction overall
• Several retaining walls are proposed on-site to limit the amount of construction
grading and remain outside the 25-foot no-disturb zone around BVW. cost
• Placing stormwater management features and structures underneath
paved areas that will already be disturbed;
• Banking 260 parking spaces and not constructing them unless it is
determined there is a shortage upon full occupancy.
• Leaving approximately 33.5 acres undeveloped.
• The Proponent is investigating the feasibility/practicality of placing a
deed restriction, or similar land preservation mechanism, on the
undeveloped property to restrict future development from occurring
in perpetuity.


Stormwater Management
The Project will comply with the standards as set forth in the Massachusetts During Part of
Stormwater Management Standards and the Bridgewater Stormwater By Laws. construction overall
construction
The peak rate is designed to be 90% of the existing condition for the 2, 10, 25, cost
50, and 100-year storm events based on NOAA ATLAS 14 rainfall estimates.
Wetlands
The Project has been designed to avoid alterations to wetland resource areas During Part of
and is expected to meet the following standards: construction overall
• No disturbance within 25 feet of the wetlands. construction
• Stormwater management facilities located between 25 and 100 feet cost
of the BVW buffer zone.
• No pavement, where practical, within 75 feet of the wetlands.
• No buildings within 50 feet of the wetlands.
Climate Change
• The Project has been designed to include high-performance building During Part of
envelopes to reduce cooling loads in the summer and the installation construction overall
of high-performance HVAC equipment. construction
• The Project will maximize vegetated surfaces and incorporate cost
reflective roofs as well.
• The landscape design is anticipated to incorporate native and
adaptive plant materials to minimize the Project’s susceptibility to
drought conditions.
• The proposed stormwater management systems will provide the
necessary storage and recharge to reduce the peak rate and volume
of runoff from the 2, 10, 25, 50, and 100-year storm events to zero for
all developed sub-watersheds.
Greenhouse Gas
The Proponent has included in the design of the building, all feasible
GHG emissions mitigation in order to avoid, reduce, minimize, or
mitigate damage to the environment. The Proponent is committed to
the following mitigation elements for the Project:
• High performance building envelope;
• Light or reflective roofs;
• Reduced lighting power densities;
• High-efficiency HVAC equipment;
• High performance exterior lighting;
•


Greenhouse Gas
• Energy Star appliances;
• Low-flow fixtures;
• Recycling collection areas; and
• Construction waste recycling.
Upon completion of each building or group of buildings, the Proponent will Completion of Part of
submit a self-certification to the MEPA Office, prepared in accordance with the Construction operating
GHG Policy. This certification will identify the GHG mitigation measures cost
incorporated into the building and will illustrate the degree of GHG reduction
from a Baseline case, as Baseline is defined herein, and how such reductions
are achieved. Details of the Proponent’s implementation of operational
measures will also be included.
Construction
• The Project will take measures to reduce potential emissions and During Part of
minimize impacts from construction vehicles including: construction construction
• Using Ultra-Low Sulphur Diesel for all trucks and construction cost.
machinery.
• On-site idling will be limited to five minutes in accordance with the
Massachusetts Anti Idling Law. “No Idling” signs will be posted at all
appropriate locations.
• Minimizing exposed storage of debris on-site, using wetting agents,
and cleaning streets and sidewalks regularly on a scheduled basis to
minimize dust.
• Monitoring construction practices to reduce unnecessary transfers
and mechanical disturbances of loose materials.
• The Proponent will strongly encourage contractors to use diesel-
powered non-road construction equipment and vehicles greater than
50 brake horsepower (hp) to have (1) engines that meet the EPA
particulate matter Tier emission standards in effect for non-road
diesel engines for the applicable engine power group or, (2) emission
control technology verified by EPA or the California Air Resources
Board (CARB) for use with "non-road engines" or (3) emission control
technology verified by EPA or CARB for use with "on-road engines"
provided that such equipment is operated with Ultra Low Sulfur Diesel
(ULSD) fuel) or (4) emission control technology certified by
manufacturers to meet or exceed emission reductions provided by
either "on-road" or "non-road" emission control technology verified
by EPA or CARB.


Construction
All construction and demolition (C&D) activities will be managed in accordance During Part of
with applicable MassDEP’s regulations regarding Air Pollution Control (310 construction construction
CMR 7.01, 7.09-7.10), and Solid Waste Facilities (310 CMR 16.00 and 310 CMR cost.
19.00, including the waste ban provision at 310 CMR 19.017) and that all C&D
activities shall be undertaken in compliance with the conditions of all State and
local permits.
Construction will be performed so as to minimize soil erosion and During Part of
sedimentation. Work will be carried out in accordance with the Order of construction construction
Conditions issued by the Conservation Commission and will follow the SWPPP cost.
prepared as part of the Stormwater Report and included in the NPDES General
Permit for Construction.
The Project will incorporate appropriate construction noise mitigation During Part of
measures, including as necessary: construction construction
• Instituting a proactive program to ensure compliance with applicable cost.
noise regulations;
• Using appropriate mufflers on all equipment and ongoing
maintenance of intake and exhaust mufflers;
• Muffling enclosures on continuously running equipment, such as air
compressors and welding generators;
• Replacing specific construction operations and techniques by less
noisy ones where feasible;
• Selecting the quietest of alternative items of equipment where
feasible;
• Scheduling equipment operations to keep average noise levels low, to
synchronize the noisiest operations with times of highest ambient
levels, and to maintain relatively uniform noise levels;
• Turning off idling equipment; and
• Locating noisy equipment at locations that protect sensitive locations
by shielding or distance.
Public Health
Please see the Construction mitigation measures above related to air and noise During Part of
mitigation. construction construction
cost.
The Project will include 36 electric vehicle charging stations. The Proponent will During Part of
work closely with the Town of Bridgewater to agree on appropriate construction construction
arrangements regarding EV charging and readiness for the project. cost.

Chapter 14
Response to Comments
14.0 RESPONSE TO COMMENTS
14.1 MEPA Certificate and Associated Comment Letters
The DEIR should contain a copy of this Certificate and a copy of each comment letter received. To
ensure that the issues raised by commenters are addressed, the DEIR 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 DEIR beyond what has been
expressly identified in this certificate.
Table 14-1 Secretary’s Certificate and Comment Letters
Commenter Abbreviation
EEA Secretary’s Certificate on the ENF MEPA
The Natural Heritage & Endangered Species Program of the Massachusetts Division of NHESP
Fisheries & Wildlife (the Division)
Staff of the Massachusetts Historical Commission MHC
The Department of Conservation and Recreation DCR
The Southeast Regional Office of the Department of Environmental Protection MADEP
Massachusetts Department of Transportation MADOT
Department of Energy Resources DOER
The Lake Nippenicket Action Focus Team LNAFT
Bridgewater Open Space Committee BOSC
Taunton River Watershed Alliance TRWA
Gary Abrams GAbrams
Nancy Abrams NAbrams
Jean DiBattista DiBattista
Robert DiBattista R.DiBattista
Sam Baumgarten Baumgarten
Donna Auger Auger
Linda Schmuck Schmuck
Linda Schmuck Letter with
Duplicate Concerns
Evelyn DeLutis DeLutis
Julia Blanchard Blanchard
Michael and Nathalie Berkowitz Berkowitz
Anthony Oliveira Oliveira
Janet and David Hanson Hanson
Kelly Cannizzaro Cannizzaro
Leiry Melendez-Sullivan Melendez-Sullivan
Marc Sullivan Sullivan
Mark Peterson Peterson
Ramonita Mulero Mulero
6491/Lakeshore Center Phase 4 14-1 Response to Comments

Table 14-1 Secretary’s Certificate and Comment Letters (Continued)
Commenter Abbreviation
Susan MacDonald MacDonald
Jeff Napior Napior
Andrea Monteith Monteith
Kevin Curry Curry
Melissa Ramondetta Ramondetta
Patricia Neary Neary
Samantha Melendez SMelendez

The Commonwealth of Massachusetts
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
Bethany A. Card
SECRETARY
June 24, 2022
CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS

ON THE
ENVIRONMENTAL NOTIFICATION FORM
PROJECT NAME : Lake Shore Center Phase 4

PROJECT MUNICIPALITY : Bridgewater
PROJECT WATERSHED : Taunton River
EEA NUMBER : 16558
PROJECT PROPONENT : Claremont Companies
DATE NOTICED IN MONITOR : May 25, 2022
Pursuant to the Massachusetts Environmental Policy Act (MEPA; M.G.L. c. 30, ss. 61-62L) and
Section 11.06 of the MEPA Regulations (301 CMR 11.00), I have reviewed the Environmental
Notification Form (ENF) and hereby determine that this project requires a mandatory Environmental
Impact Report (EIR). The Proponent should submit a Draft EIR (DEIR) in accordance with the Scope
included in this Certificate.
Project Description
As described in the ENF, the project consists of ±688,800 square feet (sf) of new mixed-use
development on Lots 1, 4, 6, and 7 of the Lakeshore Center Development (EEA#4959) and a new parcel
located on the north side of Pleasant Street (Route 104) that was not previously reviewed as part of the
Lakeshore Center Development in Bridgewater. The project proposes to construct a one-story, ±1,800-sf
café shop on Lot 1; five-story, 150-unit assisted living facility on Lot 4; a four-story, 225-unit 55+
residential community on Lot 6; a four-story, 102-room hotel, and a four-story, 160-unit condominium
community on Lot 7; and a 6,000-sf restaurant on the parcel on the north side of Pleasant Street adjacent
to Lake Nippenicket (Northern Parcel). The project also proposes to construct a stormwater management
system, parking (1,083 spaces) and loading areas, utilities, lighting, and landscaping. Access will
continue to be provided from the Lakeshore Center central access road from Pleasant Street. The project
will be served by municipal water and sewer. The project is expected to be constructed in two phases as
EEA# 16558 ENF Certificate June 24, 2022
follows: the independent living community on Lot 6 and the hotel on Lot 7 (Phase 1); and the coffee
shop on Lot 1, the assisted living community on Lot 4, the condominium on Lot 7, and the restaurant on
Lake Nippenicket (Phase 2).
Procedural History
In October 1983, an ENF was submitted for the Lakeside Corporate Center (EEA#4959), which
proposed ±1,051,000 sf of mixed uses including manufacturing, office and distribution space on 155
acres of land. It required a mandatory EIR, and Draft and Final EIRs were submitted. The FEIR was
determined to be adequate in a Certificate issued on September 14, 1985. The project was not
constructed.
A Notice of Project Change (NPC), submitted in May 1989, described the proposed Bridgewater
Crossroads development at the same project site, in lieu of the Lakeside Corporate Center project, which
consisted of a 925,000-sf regional shopping mall with ±285,000 sf of office space and a 150-room hotel.
The Certificate on the NPC (issued on June 6, 1989) required submission of an EIR. In response to this
proposal, a citizens group nominated the site and the area of Lake Nippenicket for designation as an
Area of Critical Environmental Concern (ACEC). In January 1990, a DEIR was submitted for this
project and, subsequently, the area was designated as an ACEC. On March 5, 1990, a Certificate was
issued indicating that the DEIR was adequate and that the Final EIR (FEIR) would be subject to a higher
standard of review based on the site’s designation as an ACEC. On July 18, 1990, a Certificate was
issued that determined the FEIR to be inadequate. In December 1990, a Supplemental FEIR (SFEIR)
was submitted for Bridgewater Crossroads, which by that time proposed a 550,000-sf shopping center,
135,000 sf of office/research space, and a 150-room hotel. On January 30, 1991, the SFEIR was
determined to be adequate. The project was not constructed and instead was abandoned. In August 1997,
a second NPC was filed for the Lakeside Corporate Center which proposed a nearly identical project as
the 1983 Lakeside Corporate Center. The November 6, 1997 Certificate on the NPC required a
Supplemental EIR to address significant changes proposed since 1991. The project was not constructed.
In June 1998, the Proponent submitted a third NPC, and requested a Phase I Waiver to allow
construction of a 75,000-sf office building prior to completion of MEPA review for the project as
proposed in 1997. In the July 24, 1998 Certificate on the NPC, the waiver request was denied and a
Supplemental EIR was required for the entire project. A fourth NPC was submitted in January 1999 for
a 1,100,000-sf project in lieu of the 1997 proposal. The Certificate on this fourth NPC also required a
Supplemental EIR. In June 1999, the Proponent voluntarily withdrew the project from MEPA review
and in 2000 proceeded with construction of a 77,000-sf office building 1 with an on-site septic system,
which did not require any Agency Actions; however, the Proponent agreed that subsequent development
of the site would require MEPA review.
The Proponent filed a fifth NPC in January 2000 which proposed 1,121,776 sf of mixed-use
space, including 789,940 sf of office space. The April 12, 2000 Certificate on the NPC determined that
the project continued to require an EIR. A DEIR was submitted in January 2001 for the Lakeshore
Corporate Center which identified three alternative development programs. The Certificate issued on
February 16, 2001 indicated that the DEIR was inadequate and required filing of a Supplemental DEIR
(SDEIR). The SDEIR proposed 1.177 million sf of office space, in lieu of the mixed-use development
1
This 77,000-sf office building is located on Lot 2 of the ±163-acre Lakeshore Center project site.
2
proposed in January 2000. A Certificate was issued on August 31, 2001 that determined that the SDEIR
was inadequate and included a scope for a Second SDEIR (SSDEIR). In 2002, the Proponent reduced
the project to 930,000 sf and eliminated an office building to avoid impacts to rare species. A Certificate
issued on December 16, 2002 determined that the SSDEIR was adequate while identifying significant
issues that remained to be resolved in the FEIR. The FEIR was never filed.
In May 2007, the Proponent submitted a sixth NPC for Lakeshore Center which identified
acquisition of abutting parcels and proposed 686,300 sf of mixed-use development including 449,000 sf
of retail/restaurant space, a hotel, and a 154,000-sf office building. The site was increased to 162.5 acres
as part of the Lakeshore Center Development. On June 22, 2007, a Certificate on the NPC required a
Third SDEIR. A Certificate was issued on December 17, 2008 which determined that the Third SDEIR
was adequate and included a scope for the FEIR. The FEIR was determined to be inadequate, in a
Certificate dated March 19, 2010, and included a scope for a SFEIR.
In August 2013, the Proponent submitted a seventh NPC/SFEIR which identified phasing of the
project and two components of the Lakeshore Center Project that the Proponent proposed to permit and
construct. These included a 289-unit rental housing development on the Western Site (Phase I), and a
103-room Marriott Hotel (75,100 sf) on the Central Site (Phase II). Phase III and IV on the Central Site 2
were identified as conceptual. As described in the NPC/SFEIR, the project would use an additional
54,883 gallons of per day (gpd) of water, for a total of 107,000 gpd; would generate an additional 52,117
gpd of wastewater, for a total of 107,000 gpd; alter 58.9 acres of land; create 36.4 acres of impervious
area; include 321 fewer parking spaces, for a total of 2,636 parking spaces; and generate 23,668 fewer
new adt, for a total of 2,436 adt. The Certificate (September 13, 2013) on the NPC/SFEIR indicated that
an NPC should be filed to analyze associated environmental impacts once more specific development
plans were known, and established baseline environmental impacts from which the subsequent NPC
would be assessed. Phases I and II were constructed after conclusion of the 2013 MEPA review.
In December 2017, the Proponent submitted an eighth NPC (2017 NPC) which described
construction of a ±57,000-sf office building, 218 parking spaces and associated infrastructure on Lot 3
as part of Phase III on the Central Site. During MEPA review of the 2017 NPC, the Proponent disclosed
its intention to construct a residential development (two buildings with 300 units) pursuant to Chapter
40B on Lot 5 of the Central Site as part of Phase III. However, the 2017 NPC did not include a
description or project plans for this development. On January 19, 2018, a Certificate on the 2017 NPC
required the Proponent to submit an NPC to describe plans for the 300-unit residential development
including identification of potential environmental impacts, alternatives to avoid and minimize impacts,
and revised Section 61 Findings; provide an update on future development of the entire project site
including Lots 4, 5, 6, and 7 on the Central Site and Lot 8 on the Eastern Site; and provide a summary
table of development to date and cumulative environmental impacts.
In June 2018, the Proponent submitted a ninth NPC (2018 NPC) that proposed construction of a
300-unit residential development (Viva Lakeshore) consisting of two five-story buildings on Lot 5
(1,942 vehicle trips per day and 600 parking spaces). An internal roadway, Lakeshore Center Drive,
would also be extended to serve proposed residential buildings. The 2018 NPC also described
2
The Certificate on the FSEIR indicates that Phases III and IV were conceptually proposed on the Western Site; however,
this ENF (2022) appears to indicate that these phases were, in fact, proposed within the Central Site. The only construction
on the Western Site consists of the existing 289-unit 5-story residential building.
3
conceptual plans for Lots 4, 6, 7 and 8, which consisted of two retail office buildings (65,500 sf total), a
100,000-sf office building, a 200,000-sf assisted living facility, and a 92,000-sf warehouse. As required
by the Certificate on the 2018 NPC, the Proponent submitted a Draft Supplemental EIR (DSEIR) in
September 2018. A Certificate on October 12, 2018 indicated that the DSEIR adequately and properly
complied with MEPA and its implementing regulations and included a Scope for the Final Supplemental
EIR (FSEIR), which was filed October 2018. On December 28, 2018, a Certificate determined that the
FSEIR was adequate and properly complied with MEPA. The FSEIR indicated that development of Lots
4, 6 and 7 (Phase IV) was not feasible at that time and that, when development of those three lots was
proposed, the Proponent would file a new ENF to initiate MEPA review. Lots 5 and 8 subsequently
proceeded to construction.
The ENF reviewed herein now discloses plans for Lots 4, 6 and 7 (Phase IV) on the Central Site
of the project site as previously disclosed in NPC filings between 2007 and 2018. It also describes an
additional use on Lot 1 (coffee shop) and enlargement of the project site to include the newly acquired
Northern Parcel with a new proposed use on that parcel (restaurant). According to the Certificate on the
FSEIR, the entire site of the Lakeshore Corporate Center, as reviewed through the 2007 to 2018 filings,
totaled 162.5 acres. As detailed below, the site of the project activities disclosed in this ENF is 67.2
acres.
Project Site
The ±67.2-acre 3 project site is located within the 163.87-acre Lakeshore Center Development 4
off Pleasant Street (Route 104); 154.19 acres are located in Bridgewater and 9.68 acres are located in
Raynham. The project site is bounded to the north by Route 104 and Lake Nippenicket, to the east by a
Commonwealth of Massachusetts Salvage Inspection lot and Route 24, to the south by the Route 24
southbound to Interstate 495 (I-495) northbound ramp and a rest stop, and to the west by Route 495 and
Route 104/North Main Street. Route 24 and I-495 are under the jurisdiction of the Massachusetts
Department of Transportation (MassDOT). The project site was separated into three distinct areas
(Western, Central (Lots 1 through 7) and Eastern (Lot 8) development sites). The existing Lakeshore
Center Development comprises a mix of uses including a four-building, 289-unit residential complex
and 574 associated parking spaces in the Western Site; a 96-room, four-story hotel with 103 parking
spaces on Lot 1; a ±77,000 sf, three-story office building with 237 parking spaces on Lot 2; a ±65,000
sf, four-story office building with 227 parking spaces on Lot 3; a 300-unit, five-story apartment complex
with 600 parking spaces on Lot 5; and a ±100,000 sf flex space warehouse with 162 parking spaces and
27 loading docks in the eastern section on Lot 8. The site is within the Planned Development District
and Industrial Zoning District. Access to the site is directly via Pleasant Street or via a central driveway
(Lakeshore Center Drive) forming a three-way intersection with Pleasant Street.
The ±62.7-acre project site is comprised of Lot 1 (5.3 acres), Lot 4 (9.1 acres), Lot 6 (30.3
acres), and Lot 7 (19.9 acres) within the Central Site of the original Lakeshore Center Development and
a recently acquired 2.6-acre Northern Parcel located on the north side of Pleasant Street adjacent to Lake
3
This area was incorrectly identified in the ENF as 62.7 acres.
4
According to the December 2018 Certificate on the FSEIR. However, according to the ENF (Preferred Option Plan), the
estimated total project site would total 154.4 acres in Bridgewater including the 24.3-acre Western Site (24.3 acres), 5.3-acre
Lot 1, 6.2-acre Lot 2, 6.0-acre Lot 3, 9.1-acre Lot 4, 25.9-acre Lot 5, 30.3-acre Lot 6, 19.9-acre Lot 7, 24.8-acre Lot 8, and
2.6-acre Northern Parcel. The ENF appears to discount portions of the project site within Raynham where there is no existing
or proposed construction.
4
Nippenicket. Lots 1 and 4 are located on the west side of Lakeshore Center Drive and Lots 6 and 7 are
located on the east side of this drive. Lots 4, 6 and 7 are undeveloped and include significant areas of
wetlands and forested areas.
Lake Nippenicket is a Great Pond subject to the jurisdiction of Chapter 91. Wetland resource
areas onsite include Bordering Vegetated Wetlands (BVW), Bank, and Bordering Land Subject to
Flooding (BLSF). According to the Federal Emergency Management Agency (FEMA) Flood Insurance
Rate Map (FIRM) (Map No. 25023C0282J, effective July 17, 2012), portions of the project site are
within the mapped floodplain without a base flood elevation (BFE). 5 The entire project site is located
within the Hockomock Swamp ACEC. The site is located within a Zone II of a public water supply in
the Town of Raynham. The project site includes structures that are listed in the State Register of Historic
Places or Inventory of Historic and Archeological Assets of the Commonwealth (Inventory) (Lots 6 and
7). The project site contained areas previously identified by the Massachusetts Division of Fisheries and
Wildlife’s Natural Heritage and Endangered Species Program (NHESP) as mapped Priority and
Estimated Habitat for the Eastern Box Turtle; the entire project site is no longer mapped for this species.
The Northern Parcel contains mapped habitat for two listed species of plants.
The project site is not located within one mile of an Environmental Justice (EJ) population. 6 Two
EJ populations are within five miles of the project site (±4.5 miles, respectively) and are characterized
by Minority and Income. The project is not expected to generate 150 diesel truck trips per day;
therefore, a 5-mile radius was not considered. Because the “designated geographic area” (DGA) for the
project is 1 mile, and no EJ populations are present within that DGA, the project is not required to
comply with new EJ protocols that went into effect on January 1, 2022. 7
Environmental Impacts and Mitigation
Potential environmental impacts of the project include alteration of 25.8 acres of land; creation
of 14.0 acres of impervious area (site total of 16.3 acres); alteration of an undisclosed amount of buffer
zone to BVW; generation of 4,262 new average daily trips (adt) on a typical weekday; construction of
1,083 parking spaces; new water use of 133,794 gpd (project total of 146,862 gpd); new water
withdrawal of 35,000 gpd (project total of 39,000 gpd); and new wastewater generation of 111,495 gpd
(project total of 122,385). Greenhouse Gas (GHG) emissions and other air pollutants are associated with
the burning of fossil fuels for onsite energy use and for vehicle trips generated by the project.
Measures to avoid, minimize and mitigate Damage to the Environment include avoiding all
impacts to wetland resource areas, construction of a stormwater management system, and construction
period best management practices (BMPs). The ENF does not describe project mitigation with any
degree of specificity. The DEIR should provide comprehensive analyses to demonstrate that the project
includes measures to avoid, minimize and mitigate environmental impacts, including land, traffic, rare
species, wetland resources, stormwater, historic resources, water/wastewater, construction period and
stationary- and mobile-source GHG emissions.
5
All elevations referenced in this Certificate are based on North American Vertical Datum of 1988 (NAVD88) unless
otherwise specified.
6
“Environmental Justice Population” is defined in M.G.L. c. 30, § 62 under four categories: Minority, Income, English
Isolation, and a combined category of Minority and Income.
7
https://www.mass.gov/service-details/important-update-concerning-mepa-operations
5
Jurisdiction and Permitting
The project is subject to the preparation of a Mandatory EIR pursuant to 301 CMR
11.03(1)(a)(2), 11.03(6)(a)(6), and 11.03(6)(a)(7) because it requires Agency Action and will create ten
or more acres of impervious area, generate 3,000 or more new adt on roadways providing access to a
single location, and construct 1,000 or more new parking spaces at a single location. The project also
exceeds the Environmental Notification Form (ENF) thresholds 8 under 301 CMR 11.03(1)(b)(1) for
direct alteration of 25 or more acres of land; 301 CMR 11.03(5)(b)(4)(a) for new discharge or expansion
in discharge to a sewer system of 100,000 gpd of sewage; 9 and 301 CMR 11.03(11)(b) for any project
within a designated ACEC. The project requires an Access Permit from MassDOT and review from the
Massachusetts Division of Fisheries and Wildlife Natural Heritage and Endangered Species Program
(NHESP). The project is subject to review under the May 2010 MEPA GHG Emissions Policy and
Protocol (GHG Policy).
The project requires an Order of Conditions from the Bridgewater Conservation Commission
(and, on appeal only, a Superseding Order of Conditions from the Massachusetts Department of
Environmental Protection (MassDEP)), review by the Massachusetts Historical Commission (MHC)
pursuant to M.G.L. c. 9, §§ 26-27C (and implementing regulations at 950 CMR 71.00) and a National
Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) from the U.S.
Environmental Protection Agency (EPA). The project also requires numerous permits and zoning
amendments/variances from local boards and commissions including the Bridgewater Town Council,
Bridgewater Zoning Board of Appeals, and Bridgewater Planning Board.
Because the project is not seeking Financial Assistance from an Agency, MEPA jurisdiction
extends to those aspects of the project that are within the subject matter of any required or potentially
required Agency Actions and that may cause Damage to the Environment, as defined in the MEPA
regulations.
Review of the ENF
The ENF includes a brief description of existing site conditions, project description, an
alternatives analysis and conceptual plans of proposed conditions. It provides a preliminary assessment
of impacts. Consistent with the MEPA Interim Protocol on Climate Change Adaptation and Resiliency,
the ENF contains an output report from the MA Climate Resilience Design Standards Tool prepared by
the Resilient Massachusetts Action Team (RMAT) (the “MA Resilience Design Tool”), 10 together with
information on climate resilience strategies to be undertaken by the project.
Analysis of project impacts and measures to avoid, minimize and mitigate impacts is necessary.
Among other items detailed in the Scope below, the DEIR should evaluate design changes that would
comprehensively reduce impacts within an ACEC, reduce land alteration, impervious area and parking;
reduce vehicle trips; increase open space; integrate low impact development (LID) techniques into the
drainage system; and improve resiliency of the site to the effects of climate change. I expect that the
8
According to the ENF, the Proponent has entered into a Memorandum of Agreement (MOA) with the Massachusetts
Historical Commission (MHC) that has been the subject of public notice and comment; therefore, the ENF threshold at 301
CMR 11.03(10)(b) is not applicable.
9
The ENF did not identify that the project exceeds this ENF threshold.
10
https://resilientma.org/rmat_home/designstandards/
6
DEIR will thoroughly address the thoughtful and detailed comments provided by the Taunton River
Watershed Alliance and numerous abutters and residents of Bridgewater which identify concerns
regarding the project’s impacts.
SCOPE
General
The DEIR should follow Section 11.07 of the MEPA regulations for form and content and
provide the information and analyses required in this Scope. It should clearly demonstrate that the MEPA.01
Proponent has sought to avoid, minimize and mitigate Damage to the Environment to the maximum
extent practicable.
Project Description and Permitting
The DEIR should identify any changes to the project since the filing of the ENF. The DEIR MEPA.02
should provide a more detailed description of existing and proposed conditions and a comprehensive MEPA.03
review of the project’s impacts and measures to avoid, minimize and mitigate such impacts on the
project site. It should identify and describe State, federal and local permitting and review requirements MEPA.04
associated with the project and provide an update on the status of each of these pending actions. The
DEIR should include a description and analysis of applicable statutory and regulatory standards and MEPA.05
requirements, and a discussion of the project’s consistency with those standards. The DEIR should MEPA.06
include detailed site plans for existing and post-development conditions at a legible scale, which clearly
identify project elements such as buildings, access roads, stormwater and utility infrastructure, and
wetland resource areas and buffer zones. The DEIR should confirm the size of the project size and MEPA.07
explain the discrepancy between the 162.5-acre site described in prior NPC and EIR filings, the 163.87-
acre site described in the Certificate on the FSEIR, and the estimates provided in the ENF. The Town MEPA.08
should provide a clear breakdown of for each lot within both Bridgewater and Raynham, which also
includes the Northern Parcel.
Alternatives Analysis
The ENF includes an analysis of the following alternatives for the project site: No Build;
Zoning-Compliant; Reduced Build; and Preferred Alternative (as described herein). The analysis
includes conceptual plans and a tabular comparison of impacts associated with each alternative. The No
Build Alternative would maintain existing conditions. Although this alternative would not result in any
additional environmental impacts (i.e., land alteration, impervious area, traffic, stormwater, etc.), the
ENF maintains that the site is zoned for development and has long been planned for further growth.
According to the ENF, the No-Build Alternative would not meet project goals to develop the site and
would deny the Town of the economic benefits associated with development.
According to the ENF, the project site’s zoning allows for a variety of uses at the site which
would result in varying impacts. The Zoning-Compliant Alternative would consist of uses based on the
site’s overlay zoning and would include the following: two single-family residences totaling 3,300 sf on
Lot 1; a 69,000 sf, 15-dock, industrial research and development (R&D) use on Lot 4 with 145 parking
7
spaces, six van spaces, and 11 trailer spaces; an 86,000 sf, 11-dock industrial R&D use on Lot 6 with
224 parking spaces, six van spaces, and 14 trailer spaces; a 65,500 sf retail plaza with 507 parking
spaces on Lot 7; and two single-family residences totaling 6,000 sf on the Northern Parcel. According to
the ENF, while this alternative is feasible under the site’s existing zoning, it does not meet the overall
project goals for Lakeshore Center. The Proponent does not consider single-family homes as the best use
for Lot 1 or the Northern Parcel. Industrial R&D uses on Lots 4 and 6 would be incompatible with
adjacent residential and office uses on Lots 3 and 5. The ENF asserts that the site is not well-suited for
retail use based on market research.
The Reduced-Build Alternative would consist of uses based on the site’s underlying zoning as
residential and represents a quasi-residential subdivision use that would include the following: a 1,500-sf
coffee shop with 14 parking spaces on Lot 1; four single-family homes totaling 10,000 sf on Lot 4; five
single-family homes totaling 13,000 sf on Lot 6; ten single-family homes totaling 26,000 sf on Lot 7;
and a 4,000-sf restaurant with 40 parking spaces on the Northern Parcel. According to the ENF, this
alternative was rejected because it would not represent the best use of the site and would not meet the
Proponent’s economic requirements for a return on investment.
The DEIR should include an expanded alternatives analysis that considers a Reduced Build MEPA.09
Alternative for the site that minimizes tree clearing and incorporates strategies for avoiding land
alteration and creation of impervious area in an ACEC such as clustered and denser buildings, structured
parking, etc. The DEIR should document proposed conditions for this alternative including MEPA.10
programming for the site, quantify environmental impacts and provide a conceptual plan. It should
compare the environmental impacts of this alternative with the Preferred Alternatives, in particular, with
respect to land alteration within an ACEC, impervious area/stormwater management, wetland resource MEPA.11
areas, traffic, historic resources, water/wastewater, and GHG emissions impacts and climate resiliency.
Traffic and Transportation
The project requires a Vehicular Access Permit from MassDOT as the project site abuts I-495
and Route 24 and project development is anticipated to result in significant impacts on Route 24, a state
jurisdictional roadway. The DEIR should include a Transportation Impact Analysis (TIA) developed in
accordance with MassDOT/EOEEA’s Transportation Impact Assessment Guidelines and in consultation MEPA.12
with the Town of Bridgewater (Town) and MassDOT. The study should include a comprehensive MEPA.13
assessment of the transportation impacts of the project. The TIA should provide capacity analyses of MEPA.14
existing conditions, future No-Build conditions, and future Build conditions, particularly at state
highway locations. The future Build conditions should include an analysis of operations both with and MEPA.15
without any improvements suggested to mitigate project impacts. The study should propose an
integrated multimodal mitigation package intended to improve vehicular traffic operations while MEPA.16
supporting increased use of walking, bicycling, and transit by employees and residents. The Proponent MEPA.17
should continue consultation with the Town and appropriate MassDOT units, including PPDU, Traffic
Operations, and the District 5 Office during preparation of the DEIR.
According to the ENF, the project is expected to generate a total of 4,262 unadjusted adt in
accordance with the Institute of Transportation Engineers (ITE) Trip Generation Manual, using Land
Use Code (LUC) 251: Senior Adult Housing (Single Family), 252: Senior Adult Housing (Multi-
family), 254: Assisted Living, 310: Hotel, 931: High Turnover (Sit-Down) Restaurant, and 937:
Coffee/Donut Shop with Drive-Through Window. This estimated trip generation represents an increase
8
over the existing commercial and residential uses present at the project site. A total of 1,083 parking
spaces are proposed to accommodate the varied uses across the site. The DEIR should ensure that any MEPA.18
analysis of pass-by trips is consistent with MassDOT TIA Guidelines.
Trip Distribution
The TIA should provide a trip distribution for the project based on a gravity model or similar MEPA.19
model that uses factors such as census data, origin-destination, travel time, and distance to determine trip
characteristics for visitors, residents and employees of the project. The DEIR should provide all
appropriate back up documentation to verify how the different percentages are calculated and assigned MEPA.20
to the roadway network and the transit system.
Study Area
The TIA should include analysis of intersections and roadways where site traffic exceeds 100 MEPA.21
vehicle trips per hour or 5% of existing volume. The ENF proposes intersections to be included in the
TIA study area along Route 104 at proposed site driveways, at Route 24 northbound/southbound ramps,
and at Lakeside Drive/Fruit Street, Old Pleasant Street, at Lakeshore Center Drive, at Residence Inn
Driveway, and North Main Street.
Traffic Count Data
The TIA should address the atypical traffic conditions resulting from the COVID-19 pandemic MEPA.22
and follow MassDOT’s Guidance on Traffic Count Data, as detailed in Engineering Directive number
E-20-005 (issued May 11, 2020), which allows for use of historical traffic data (no older than 2014) on
any project to supplement and/or replace existing traffic counts. The Proponent should consult with the MEPA.23
Highway Division Traffic and Safety Section on the most recent updates of the MassDOT guidance on
traffic count data.
Safety
The TIA should include crash analyses for all intersections in the study area using the MassDOT MEPA.24
crash database for the most recent five years of accepted/available data. The study area intersections that
are identified as Highway Safety Improvement Program (HSIP) clusters should be reviewed to MEPA.25
determine whether Road Safety Audits (RSAs) are required or if any further actions may be taken to
improve safety. Additionally, the Route 104 study corridor should be reviewed in the MassDOT Impact MEPA.26
portal, in particular, the crash-based and risk-based screening tools. Proposed mitigation should reduce
the number of crashes along high crash corridors as well as address any risks identified. The DEIR
MEPA.27
should describe if additional mitigation measures will be provided at intersections to improve safety.
Traffic Operations
The TIA should include operational analysis of existing traffic conditions at the intersections and MEPA.28
roadways included in the study area identified in the ENF and MassDOT comments. The TIA should MEPA.29
include capacity analyses for the weekday morning and evening peak hours for both existing and future
conditions for the project. In addition, capacity analyses for Build with Mitigation conditions should be MEPA.30
provided for all intersections, particularly those with impacts to the state highway system. Of particular
9
concern is the operation of the Route 24 interchange with Route 104. The TIA should provide
MEPA.31
illustrations depicting the peak hour 50th (average) and 95th percentile queue lengths for each lane
group/turning movement at each study area intersection, for all analysis scenarios. The information
MEPA.32
contained in these illustrations should clearly demonstrate that the project would not result in any
extended queues that would block vehicle movements to/from study area intersections, particularly those
involving state highways. The analysis should include queue length to demonstrate that the project MEPA.33
would not result in queues extending to the Route 24 mainline. The DEIR should identify appropriate MEPA.34
mitigation if necessary to address this concern.
Multimodal Access Accommodations
The TIA should provide an inventory of existing sidewalks and crosswalks within the study area MEPA.35
and should address the quality and condition of those facilities. It should include a commitment to MEPA.36
improvements in any areas that are structurally deficient or not meeting current codes for accessibility,
including sidewalks, crosswalks, ramps, and pedestrian equipment. Special attention should be given to MEPA.37
linking the proposed development to adjacent complementary land uses and transit facilities.
The TIA should include a detailed inventory of the bicycle network to include bikeway types, MEPA.38
bikeway widths, and bicycle volumes and speeds. It should identify the likely travel routes for bicyclists MEPA.39
within the study area and examine the degree to which these routes can safely support bicycle travel. MEPA.40
The TIA should reevaluate these routes based on the origin-destination of potential employees and
visitors. Based on this analysis, the TIA should consider the feasibility of expanding some of these MEPA.41
existing routes or considering new routes to encourage bicycle travel in and around the site.
The project site is not located within an area currently served by transit. The Proponent should MEPA.42
consult with the Brockton Area Transit and the Greater Attleborough-Taunton Regional Transit
Authority regarding the feasibility of extending transit services to the site. Additionally, the Proponent MEPA.43
should consult with the Council on Aging for potential services to the elderly population of the project.
The DEIR should provide a summary of the outcome of these consultations.
Parking
The TIA should explain the methodology used to determine the total parking required (1,083 MEPA.44
parking spaces proposed). The ITE Parking Generation Manual (5th Edition) generally provides a
reasonable basis for comparison to parking requirements under local zoning. The TIA should include a MEPA.45
summary of parking need and supply for comparable facilities based on multiple data sources. The TIA
MEPA.46
should determine the number of parking spaces occupied at various times of day and identify periods of
peak use. The Proponent should seek opportunities to share parking with the existing uses on-site. The MEPA.47
DEIR should describe further reduction of site parking spaces.
It is critical to maximize electric vehicle (EV) charging stations and EV ready spaces as it is
significantly cheaper and easier to size electrical service and install wiring or wiring conduit during
construction rather than retrofitting a project later. The DEIR should identify the number of EV ready MEPA.48
spaces that will be provided on the project site.
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Transportation Demand Management
The DEIR should include a detailed Transportation Demand Management (TDM) program MEPA.49
intended to reduce single-occupancy vehicle (SOV) trips to the project site and to promote the use of
alternative modes of transportation. The DEIR should include sufficiently detailed conceptual plans MEPA.50
(minimum of 80-scale) for any proposed roadway improvements to verify the feasibility of constructing
such improvements and demonstrate consistency with appropriate MassDOT design standards including
Complete Streets. These plans should clearly show proposed lane widths and offsets, layout lines and MEPA.51
jurisdictions, and land uses adjacent to areas where improvements are proposed. All proposed roadway MEPA.52
signage and lighting must comply with MUTCD standards.
Transportation Monitoring Program
The DEIR should commit to the implementation of an annual Traffic Monitoring Program MEPA.53
(TMP) for a period of five years, beginning six months after occupancy of the full-build project, which
will include:
• Simultaneous automatic traffic recorder (ATR) counts at each site driveway for a continuous
24-hour period on a typical weekday
• Travel survey of employees and patrons at the site (to be administered by the Transportation
Coordinator)
• Weekday AM and PM and Saturday peak hour turning movement counts (TMCs) and
operations analysis at “mitigated” intersections, including those involving site driveways
• Transit Ridership counts
The goals of the monitoring program will be to evaluate the assumptions made in the DEIR and
the adequacy of the mitigation measures, as well as to determine the effectiveness of the TDM program.
Land Alteration, Open Space and Farmland Conversion
The ENF indicates that the project will alter 25.8 acres of land and create 14.0 acres of
impervious area. The DEIR should provide an update on impacts associated with new land alteration and
impervious area creation. I encourage the Proponent to continue to explore onsite alternatives to reduce MEPA.54
environmental impacts and features to further mitigate potential impacts and preserve open space and
tree cover. The DEIR should quantify the total amount of alteration associated with the project including MEPA.55
areas to be altered for buildings, roadways, parking, wastewater, water and stormwater infrastructure,
landscaping, and other project components. It should include a breakdown showing the amount of MEPA.56
alteration for each project element. It should clarify the location, type and amount of alteration in MEPA.57
previously undisturbed areas. The DEIR should include site plans that clearly locate and delineate areas MEPA.58
proposed for development and those to be left undisturbed. It should specifically estimate the amount of MEPA.59
tree clearing that will be required. It should show the locations where fill will be placed for regrading
purposes and the depth of fill. The DEIR should identify how the project is designed to avoid and MEPA.60
minimize land alteration.
The DEIR should identify open space that will remain undisturbed and/or restored upon MEPA.61
completion of construction. Given the size of the project site, the DEIR should consider placing a
conservation restriction on portion(s) of the site designated as open space, including areas containing MEPA.62
11
wetlands, to ensure their permanent protection.
The DEIR should identify all easements and public utilities on the site and provide information MEPA.63
on the parties to the easements and location and condition of public infrastructure. It should describe any MEPA.64
constraints on project design or use of the site posed by these conditions.
The project will occur in more than one phase. The DEIR should clearly identify the activities MEPA.65
proposed for each phase and the area to be developed. Regardless of any phasing of construction, the MEPA.66
DEIR should describe how proposed land alteration, such as clearing, regrading or paving, will be
limited to the minimum area necessary at any time.
As described in MassDEP comments, the DEIR should demonstrate, if the land in agricultural
use, as shown on a MassMapper overlay, has benefited from the tax savings provided by M.G.L. MEPA.67
Chapter 61A Assessment And Taxation Of Agricultural And Horticultural Land and has met its
obligations under Section 13: Change of use: Liability for roll-back taxes. The Proponent should also MEPA.68
demonstrate, as required under Section 17 of this statute, that prior to the sale of this property that a
notice of intent to the Town of Bridgewater was given for its first rights of refusal to purchase the land
prior to its proposed nonagricultural use. If the U.S. Department of Agriculture Natural Resources
Conservation Service has provided technical assistance to the farm that has certain contractual MEPA.69
obligations, the Proponent must demonstrate that those contract conditions have been met prior to the
conversion of this farmland to its proposed nonagricultural use.
Rare Species
The project site was mapped for the Eastern Box Turtle and determined to result in a take of the
species during previous MEPA review. NHESP issued a Conservation and Management Permit for the
original project on February 7, 2019. Measures to minimize impacts to turtles included approved
implementation of a Turtle Protection Plan to remove turtles from the project’s limit of work prior to
construction. As mitigation for the impacts, the Proponent will contribute $100,800 to The Nature
Conservancy’s Eastern Box Turtle Mitigation Bank and an additional $12,096 in administrative fees.
According to the ENF, the site is no longer mapped for the Eastern Box Turtle based on the 15th MEPA.70
Edition of the Natural Heritage Atlas (2021); however, the conditions approved in the 2019 permit for
turtle protection and mitigation still apply for future site activities. New work is proposed on the
Northern Parcel on the north side of Pleasant Street adjacent to Lake Nippenicket associated with the
construction of a restaurant. This area is mapped for two listed species of plant, Plymouth gentian
(Sabatia kennedyana) and round-fruited seedbox (Ludwigia sphaerocarpa). These species and their
habitat are protected pursuant to the Massachusetts Endangered Species Act (MESA) and its
implementing regulations (312 CMR 10.00). The Proponent is currently in consultation with NHESP to
determine whether additional work will result in a take of these species; if botanical surveys will be
required for mapped plant species; and if measures to avoid, minimize and mitigate project-related
impacts for the listed plant species will be necessary. The DEIR should provide a summary of the
outcome of consultations with NHESP, indicate if a Conservation and Management Permit will be MEPA.71
required for work on the Northern Parcel, and identify additional measures to protect listed plants.
12
ACEC
As previously mentioned, the entirety of the project site is located within the Hockomock
Swamp ACEC. The Hockomock Swamp ACEC designation document, dated February 10, 1990,
described wetland resource areas included in the ACEC as significant to the protection of groundwater
supply and public and private water supplies, the prevention of pollution, flood control, the prevention
of storm damage, the protection of fisheries, and the protection of wildlife habitat. The Hockomock
Swamp is the largest vegetated freshwater wetland area in Massachusetts. Further description of the
extensive system of surface waters, wetlands, floodplains, and high-yield aquifers included in the
Hockomock Swamp ACEC explicitly describes Lake Nippenicket as one of these resources. The entirety
of the project site is also mapped as a Zone II Approved Wellhead Protection Area by MassDEP.
The ENF indicates that impacts to the ACEC and Zone II will include stormwater runoff from
new impervious surfaces. I received numerous comments from the abutters, and residents of
Bridgewater citing significant concerns regarding impacts to the ACEC from the proposed project,
particularly in light of the important resources the ACEC provides to protect historical, cultural, and
scenic values, fish/wildlife habitat and other natural resources, and the area’s groundwater supply and
public and private water supplies. Many of the comments specifically reference opposition to the
proposed restaurant on the Northern Parcel adjacent to Lake Nippenicket. Comments from the
Bridgewater Open Space Committee indicate that elements of the project are inconsistent with the 2017 MEPA.72
Bridgewater Open Space Plan and the ACEC designation.
The DEIR should clearly and comprehensively define, describe, and document how the project MEPA.73
will minimize adverse effects on groundwater quality, habitat values, biodiversity, storm damage
prevention, flood control, historic and archeological resources, scenic and recreational resources, and
other natural resource values of the ACEC pursuant to 301 CMR 12.00. The DEIR should include a MEPA.74
narrative to describe the project’s impacts to each of these resource values, an analysis of alternatives
that prioritizes avoiding impacts to ACEC, and justification as to why the impacts associated with the
Preferred Alternative cannot be avoided. The DEIR should include a bio-inventory for areas of proposed MEPA.75
alteration within the ACEC to evaluate proposed impacts to biodiversity and related functions and
values of the existing habitats, wildlife, and natural communities. Extensive clearing, grading and
increased impervious surface proposed in the ACEC, and increased discharges of runoff to the ACEC,
may result in impacts and long-term effects on the wetlands and streams in the ACEC. The DEIR should MEPA.76
explore alternative designs that will improve, restore, and enhance the ACEC and avoid adverse effects
on the land and water resources and other values described above and in the designation document for
the Hockomock Swamp ACEC.
The DEIR should demonstrate that the project will avoid and minimize adverse effects on the MEPA.77
natural resource values of the area and address how project planning and development can promote
preservation, restoration, or enhancement of resource areas within the ACEC. The project will alter an
additional 25.8 acres of ACEC and create 14 acres of new impervious area within the ACEC. The DEIR MEPA.78
should describe if the project will permanently protect open space on-site adjacent to wetland resource
areas. It should include a description of the measures that will be implemented to afford greater MEPA.79
protection to the resources within the ACEC including reduction of impervious surface, significant use
of LID features and retention of trees on-site. I expect the DEIR will provide a detailed response to MEPA.80
comments from residents/abutters to address their concerns and demonstrate that all reasonable and
feasible measures will be taken to avoid, minimize and mitigate impacts to the ACEC.
13
Wetlands and Stormwater
The project will impact buffer zone to BVW. The Bridgewater Conservation Commission will
review the project for its consistency with the Wetlands Protection Act (WPA), Wetlands Regulations
(310 CMR 10.00) and associated performance standards including stormwater management standards
(SMS) and local bylaws. Proposed construction will be located outside of floodplain and other wetland
resource areas. The DEIR should affirm that impacts to wetland resource areas regulated under the WPA MEPA.81
are not proposed for activities onsite. The DEIR should confirm whether the stream which flows into
Lake Nippenicket is perennial or intermittent and provide supporting documentation. The DEIR should MEPA.82
describe project activities proposed in 100-foot buffer zone to BVW, quantify these impacts and identify
consistency with the WPA. MassDEP comments indicate that there does not appear to be any proposed
activities within Chapter 91 jurisdiction.
The DEIR should address comments from the Massachusetts Department of Conservation and MEPA.83
Recreation (DCR) Flood Hazard Management Program (FHMP) which indicate that the Proponent will
be required to develop BFE information for use in this project meeting the requirements of the WPA
regulations and the local floodplain regulations of Bridgewater because unnumbered A zones do not
include BFEs. The DEIR should describe the project’s compliance with federal Executive Order 11988, MEPA.84
Floodplain Management, which requires an eight-step decision-making process including analysis of
alternatives, avoiding impacts to floodplain when possible, and minimizing impacts when avoidance is
not possible.
The project will add 14.0 acres of impervious area onsite and will remove a substantial number
of existing mature trees from the site. The project site is in the upper reaches of the Taunton River Basin
adjacent to Lake Nippenicket from which flows the Town River, a major tributary of the Taunton River.
The project site is located within the Hockomock Swamp ACEC, as well as a designated Zone II to
drinking water wells in the Town of Raynham. The ENF includes a preliminary discussion of how the
stormwater management system will be designed in accordance with the MassDEP Stormwater
Handbook to fully meet the SMS for new development. A number of BMPs will be used to treat one-
inch of runoff, remove more than 44% of total suspended solids (TSS) before any infiltration, and
remove more than 80% of TSS before final discharge to achieve compliance with the SMS including
Standard 6 (Critical Areas). The DEIR should include a comprehensive stormwater discussion and MEPA.85
report for the project.
The DEIR should describe the extent to which the project will preserve existing tree canopies MEPA.86
and plant additional trees, including estimates of the number of trees that will be planted. The DEIR MEPA.87
should demonstrate that LID strategies have been incorporated into the stormwater design to the
maximum extent practicable. The DEIR should demonstrate the system will be designed to MEPA.88
accommodate larger storm events. It should include a plan showing the location of BMPs. The DEIR MEPA.89
should provide analysis of the capacity of the stormwater management system under future climate
conditions, as described below.
The DEIR should describe if the project will convey stormwater through underground MEPA.90
stormwater infiltration structures that qualify under the jurisdiction of the MassDEP Underground
Injection Control (UIC) program and which must be registered with the MassDEP.
14
Water and Wastewater
The project will use a total of 146,862 gpd of water (133,794 gpd new) that will be provided by MEPA.91
the Town and generate a total of 122,385 gpd of wastewater (111,495 gpd new). According to MassDEP
comments, the Town has the capacity to provide the requested volume for this project based on its
renewed Water Management Act (WMA) permit issued on January 5, 2021 and its recent water use. The
DEIR should provide a discussion of the project’s exceedance of the ENF threshold related to
wastewater and additional mitigation to offset those impacts. The DEIR should evaluate and identify MEPA.92
which water conservation measures and BMPs will be implemented at the project site. The DEIR should MEPA.93
describe the Proponent’s efforts to work with the public water system (PWS) to mitigate the additional
demands on the system proposed by the project including removal of infiltration and inflow (I/I). The MEPA.94
Proponent should consult with the Town to identify appropriate I/I mitigation for this project. The DEIR MEPA.95
should include a commitment to I/I removal and identify any mitigation projects or monetary
contribution by the Proponent. The DEIR should confirm the Proponent will restrict irrigation use, if MEPA.96
there is any, when the Town implements its nonessential outdoor water use restriction requirements.
Historic Resources
According to the ENF, the project will impact two significant archaeological sites (Bassett Site
on Lot 6 (central portion of the site) and Tomb Road Area B Site on Lot 7 (northern portion of the site))
that are within the area of direct effects (vegetation removal, grading, filling, etc.). Specifically, the
project will involve destruction of both ancient Native American sites, which have been determined by
MHC to be eligible for listing in the National Register of Historic Places. The ENF describes the
outcome of previous consultation with MHC which resulted in development of a Memorandum of
Agreement (MOA), prepared by MHC and signed by the Proponent, that outlines measures to mitigate
the adverse effects to both sites (36 CFR 800.5 and 950 CMR 71.05(a)) from the project on significant
archaeological resources in the Lakeshore Center project area. As described in Stipulation II of the
MOA, implementation of the archaeological data recovery program on the two sites will provide
compliance with Section 106 of the National Historic Preservation Act of 1966 as amended (36 CFR
800.6) and M.G.L., Chapter 9, Sections 26- 27C, as amended by Chapter 254 of the Acts of 1988 (950
CMR 71). The Proponent has also participated in consultation and coordination with federally
recognized Native American tribes (Mashpee Wampanoag and Wampanoag Tribe of Gay Head
(Aquinnah)) during implementation of the archaeological data recovery program. MHC comments
indicate that it received no comments about the project’s effects to historic and archaeological resources
from the public nor from any agencies during the long history of MEPA reviews of development
proposed at the site of the Lakeshore Center.
According to MHC, it encouraged analysis of alternatives that indicated there were no prudent
and feasible alternatives to adversely affecting the two archaeological sites. MHC assisted in
development of proposed mitigation measures for the archaeological data recovery program. The MOA
stipulations prepared by MHC primarily relate to technical issues in archaeology to ensure that data
recovery is conducted to meet professional standards for archaeology.
The DEIR should provide additional context, to the extent possible, regarding the nature of MEPA.97
proposed activities that involves destruction of both Native American sites and a rationale for proposed
impacts to these sites. The DEIR should provide additional information regarding the archaeological MEPA.98
data recovery program, to the extent possible, including potential removal and archiving of sensitive
15
archaeological resources. The DEIR should include the alternatives analysis for Lots 6 and 7 prepared in MEPA.99
2020 11 and a copy of the MOA. The DEIR should describe the public notice and comment that was MEPA.100
conducted as part of the MOA process. The DEIR should describe the measures that the Proponent,
assisted by their consultant The Public Archaeology Laboratory, Inc., will continue to consider and MEPA.101
implement involving minor project adjustments in design and specifications that could avoid and protect
particular areas of interest to Tribal Historic Preservation Officers of the Mashpee Wampanoag Tribe
and of the Wampanoag Tribe of Gay Head (Aquinnah), to the Massachusetts Commission on Indian
Affairs (MCIA), and to the MHC.
According to MHC, the expanded project area on the north side of Pleasant Street adjacent to the
shore of Lake Nippenicket (Northern Parcel) has not been previously surveyed for archaeological
resources and may be archaeologically sensitive. The DEIR should confirm that the Proponent will MEPA.102
conduct a reconnaissance archaeological survey (950 CMR 70) for this Northern Parcel, which includes
limited subsurface testing to evaluate subsurface soil conditions and identify any archaeologically
sensitive areas. Specific archaeological site information and technical archaeological reports, which are
not a public record and confidential to protect fragile archaeological sites from vandalism (M.G.L. c. 9,
ss. 26A & 27C), should not be included in documents prepared for public review. The DEIR should MEPA.103
describe any additional proposed mitigation based on the outcome of MHC review and the results of the
archaeological survey on the Northern Parcel. It should provide an update of consultation with MHC and
indicate if the MOA will be modified to reflect additional mitigation measures in consultation with MEPA.104
MHC, the Tribes listed above, and the MCIA. The DEIR should provide a response to the comments
MEPA.105
from residents which identify concerns related to the destruction of both ancient Native American sites.
Climate Change
Executive Order 569: Establishing an Integrated Climate Change Strategy for the
Commonwealth (September 16, 2016) recognizes the serious threat presented by climate change and
directs Executive Branch agencies to develop and implement an integrated strategy that leverages state
resources to combat climate change and prepare for its impacts. The urgent need to address climate
change was again recognized by Governor Baker and the Massachusetts Legislature with the recent
passage of St. 2021, c. 8, An Act Creating a Next Generation Roadmap for Massachusetts Climate
Policy, which sets a goal of Net Zero emissions by 2050. The MEPA statute directs all Agencies to
consider reasonably foreseeable climate change impacts, including additional GHG 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).
Adaptation and Resiliency
The Town is a participant in the Commonwealth’s Municipal Vulnerability Preparedness (MVP)

program, which 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 Town can take to
reduce risk and build resilience. Through the MVP program, the Town received funding to conduct a
planning process for climate change resiliency and implementing priority projects. The results of the
initial community-driven process were presented in the “Summary of Findings” (the Report), dated May
11
As described in MHC’s comment letter this alternatives analysis was prepared by VHB, Inc. and Landvest.
16
2021. The Report identified heat waves, flooding, drought, and intense storms as top climate hazards
in Bridgewater.
Effective October 1, 2021, all MEPA projects are required to submit an output report from the
MA Resilience Design Tool to assess the climate risks of the project. Based on the output report
attached to the ENF, the project has a high exposure based on the project’s location for the following
climate parameters: extreme precipitation (urban and riverine flooding) and extreme heat; it also is rated
high risk for the same three climate parameters. Based on the minimum 50-year useful life identified for
the project and the self-assessed criticality of project assets, the Tool recommends a planning horizon of
2070 and a return period associated with a 25-year (4% annual chance) storm event when designing the
proposed buildings. This recommendation appears to be based on a “Medium” criticality assessment
(based on user inputs) for proposed buildings. In addition, the MA Resilience Design Tool recommends
estimating a useful life of 40 to 60 years for most “long-lived” buildings and infrastructure, such as most
new building construction. 12 For a useful life of 51 to 100 years, the Tool recommends a longer planning
horizon and return periods associated with a 50-year to 100-year storm event for extreme precipitation
for similar assets (i.e., buildings) of medium to high criticality. 13
Much of the project site is currently located within a mapped 100-year floodplain with an
uncalculated BFE (zone A) and is rated “High” risk for extreme precipitation (urban and riverine
flooding) during the useful life of the project. According to the ENF, all proposed activities is proposed
in upland areas outside the floodplain. However, the “High” risk rating in the MA Resilient Design Tool
takes into account future climate conditions and is not limited to areas currently mapped as flood plain MEPA.106
(based on historical rainfall projections). The ENF does not provide information about anticipated future
conditions at the site due to the effects of climate change.
The DEIR should identify the project site’s vulnerabilities to climate change and potential MEPA.107
measures to increase its resilience. The DEIR should provide a review of the Town’s studies and MEPA.108
resiliency plans on climate vulnerabilities and potential solutions, including regional solutions requiring
coordination between the Proponent and abutters and other stakeholders. The DEIR should include a MEPA.109
comprehensive discussion of the potential effects of climate change on the project site and describe
features incorporated into the project design (including climate-related design specifications and
standards) that will increase the resiliency of the site to these changes. The DEIR should include MEPA.110
information about the potential adaptation of the project to future conditions. In particular, the DEIR
should analyze how the elevation of the proposed buildings was determined in light of the potential for MEPA.111
future urban and riverine flooding.
The DEIR should discuss how the stormwater system will be sized to address future climate MEPA.112
conditions. Effective April 25, 2022, the MA Resilience Design Tool provides rainfall volumes
associated with a 24-hour storm for multiple storm scenarios and planning horizons for projects subject
to extreme precipitation risks. The DEIR should consult these volumes for the 25-year, 50-year and 100- MEPA.113
year storm as of 2070 to assess the efficacy of the stormwater management system to accommodate
future climate conditions. The DEIR should discuss, with quantitative modeling to the extent
practicable, whether the stormwater management system will attenuate peak flows and meet pollutant MEPA.114
12
See Section 2, Climate Resilience Design Standards Overview (Attachment 2.3 Useful Life Guidance Tables), available at
https://resilientma.org/rmat_home/designstandards/.
13
See https://eea-nescaum-dataservices-assets-
prd.s3.amazonaws.com/cms/GUIDELINES/20210401Section3ClimateResilienceDesignStandardsOverview.pdf, at p. 19.
17
loading requirements based on future climate conditions in 2070. Estimates can be provided in lieu of
exact calculations, to the extent stormwater design is not advanced enough by the time of the DEIR. The MEPA.115
DEIR should also discuss whether the proposed elevation of buildings is anticipated to be resilient to a
future BFE associated with the 25-year, 50-year and 100-year storm as of 2070. To the extent the project
is unable to accommodate future year storm scenarios, the DEIR should discuss whether the project has MEPA.116
engaged in flexible adaptative strategies, and whether current designs allow for future upgrades to be
made to adapt to climate change. General guidance on flexible adaptive strategies is available on the
MA Resilience Design Tool website. 14
The DEIR should continue to identify opportunities to increase resilience through enhancement MEPA.117
of the site, including retention of mature trees on-site, increased open space and permeable surfaces. The
DEIR should demonstrate that the Proponent is developing appropriate strategies to adapt to extreme MEPA.118
heat conditions throughout the useful life of the project. The DEIR should document all efforts taken to
maximize the use of LID strategies for stormwater management, including rain gardens, bioretention MEPA.119
areas, tree box filters, water quality swales. and green roofs.
In addressing climate change as described above, the DEIR should consider incorporating
MEPA.120
additional climate adaption and resiliency features into the project design to the maximum extent
practicable, including:
• Ecosystem-based adaptation measures to reduce heat island effect and mitigate stormwater
runoff, such as integration of tree canopy cover, rain gardens, and LID stormwater
management techniques
• Use of on-site renewable energy systems that may provide added resiliency during periods of
power loss during storms
• Protection of emergency generator fuel supplies from effects of extreme weather and flood-
proofing of parking garages and other structures
• Expansion of the size of emergency generators to allow for select common areas and other
emergency and life safety systems to remain operational for a period of time beyond code
requirements
Greenhouse Gas (GHG) Emissions
This project is subject to review under the May 5, 2010 MEPA GHG Policy, which requires
Proponents to quantify carbon dioxide (CO2) emissions and identify measures to avoid, minimize or
mitigate such emissions. The analysis should quantify the direct and indirect CO2 emissions of the MEPA.121
project's energy use (stationary sources) and transportation-related emissions (mobile sources). Direct MEPA.122
emissions include on-site stationary sources, which typically emit GHGs by burning fossil fuel for heat,
hot water, steam and other processes. Indirect emissions result from the consumption of energy, such as
electricity, that is generated off-site by burning of fossil fuels, and from emissions from vehicles used by
residents, employees, visitors, and others.
The DEIR should include a GHG analysis prepared in accordance with the GHG Policy, MEPA.123
guidance and recommendations provided in the comment letter submitted by the Massachusetts
14
https://eea-nescaum-dataservices-assets-
prd.s3.amazonaws.com/cms/GUIDELINES/20210330FlexibleAdaptationPathwaysFormFinal.pdf
18
Department of Energy Resources (DOER), which is incorporated in this Certificate in its entirety, and
this Scope.
Stationary Sources
The DEIR should include an analysis that calculates and compares GHG emissions associated MEPA.124
with a Base Case that conforms to the 9th Edition of the Massachusetts Building Code, which references
the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) 90.1-2013
and the International Energy Conservation Code (IECC) 2015, and a Preferred Alternative that achieves
greater reductions in GHG emissions. The project will be required to meet the applicable version of the MEPA.125
Massachusetts Stretch Energy in effect at the time of construction, which currently requires a 10%
energy performance improvement over ASHRAE 90.1-2013-Appendix G plus Massachusetts
amendments including C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and
C406 (three additional efficiency measures). The analysis should include the three C406 additional MEPA.126
efficiency measures in the Baseline.
The GHG analysis should clearly demonstrate consistency with the key objective of MEPA MEPA.127
review, which is to document the means by which Damage to the Environment can be avoided,
minimized and mitigated to the maximum extent feasible. The DEIR should identify the model used to MEPA.128
analyze GHG emissions, clearly state modeling assumptions, explicitly note which GHG reduction
measures have been modeled, and identify whether certain building design or operational GHG
reduction measures will be mandated by the Proponent to future occupants or merely encouraged for
adoption and implementation. The DEIR should include the modeling printouts for each alternative and MEPA.129
emission tables that compare base case emissions in tons per year (tpy) with the Preferred Alternative
showing the anticipated reduction in tpy and percentage by emissions source. Other tables and graphs,
such as the table of mitigation measures recommended by DOER, may also be included to convey the
GHG emissions and potential reductions associated with various mitigation measures as necessary. The MEPA.130
DEIR should provide data and analysis in the format requested in DOER’s letter.
The DEIR should present an evaluation of mitigation measures identified in DOER’s comment MEPA.131
letter. In particular, the feasibility of each of the mitigation measures outlined below should be assessed
for each of the major project elements, and if feasible, GHG emissions reduction potential associated
with major mitigation elements should be evaluated to assess the relative benefits of each measure. The
DEIR should explain, in reasonable detail, why certain measures that could provide significant GHG MEPA.132
reductions were not selected – either because it is not applicable to the project or is deemed technically
or financially infeasible. If financially infeasible, the DEIR should describe the cost effectiveness MEPA.133
metrics that were used to evaluate feasibility, whether energy savings that would accrue to future tenants
were considered, and what “payback period” the Proponent would deem to be reasonable given the
financial constraints identified. It should include a review of available financial incentives potentially MEPA.134
available for the project, as described in DOER’s comment letter. At a minimum, the DEIR should MEPA.135
consider the following GHG mitigation measures:
• Building design and construction practices that result in low heating and cooling thermal
energy demand intensity (TEDI) by:
o High-performance window and walls
o Thermally broken windows and other components to eliminate thermal bridges
o Low air-infiltration
19
o Ventilation energy recovery

o Energy recovery during concurrent heating and cooling
o Solar gain management via external shading, recessed windows, and/or low solar heat
gain coefficient (SHGC)
• Passivehouse including engagement with a MassSave funded consultant
• Efficient electrification of space and water heating
• Extensive rooftop solar photovoltaic (PV)
• EV charging stations and EV ready parking spaces
The DEIR should evaluate the specific scenarios for each typology/use of building detailed in MEPA.136
DOER’s comment letter for baseline meeting minimum code (mandatory code building scenarios),
improved scenarios (HERS 45, Passivehouse, low heating TEDI, etc.) and sub-scenarios for each of the
six buildings including the four-story 225-unit residential building, four-story 160-unit condo building,
five-story 150-unit assisted living building, four-story 102-unit hotel, 1,800-sf café, and 6,000-sf
restaurant.
The DEIR should review the financial incentives identified in DOER’s comment letter and MEPA.137
incorporate these potential funding sources in analyses of Passivehouse design and electrification of
space and water heating. Significant incentives may be available including MassSave® incentives 15,
Alternative Energy Credits (AECs) 16, and Solar Massachusetts Renewable Target (SMART) 17 credits
(in addition to federal and state tax incentives). For qualifying multifamily buildings, the MassSave
incentive for Passivehouse is ±$3,000 per dwelling unit or ±$1.125 million for the project (plus
generous feasibility and design incentives). Currently, there are over 6,700 Passivehouse units being
planned, designed or under construction in Massachusetts.
The SMART program includes pathways which allow solar production to be sold without off-
takers. The project will incorporate solar-ready roofs. The DEIR should review opportunities to MEPA.138
maximize onsite PV systems by setting aside as much roof space as possible for future rooftop PV. Even
if PV is not installed during building construction, it is important to plan the project to ensure that roof
space is set aside for PV and that roof space does not become unnecessarily encroached with HVAC
appurtenances, diminishing the opportunities for future PV.
The Proponent should consult with staff from DOER and the MEPA Office prior to submitting
the DEIR. The DEIR should clearly demonstrate that the Proponent is taking all feasible measures to MEPA.139
mitigate GHG impacts to the maximum extent practicable, and provide a clear justification if energy
efficiency measures that appear technically feasible will not be adopted for the project.
Mobile sources
The GHG analysis should include an evaluation of potential GHG emissions associated with MEPA.140
mobile emissions sources. The DEIR should follow the guidance provided in the GHG Policy for
Indirect Emissions from Transportation to determine mobile emissions for Existing Conditions, Build
15
https://www.masssave.com/en/saving/business-rebates/new-buildings-and-major-renovations/ and
https://www.masssave.com/saving/residential-rebates/passive-house-incentives
16
https://www.mass.gov/guides/aps-renewable-thermal-statement-of-qualification-application
17
https://www.mass.gov/solar-massachusetts-renewable-target-smart
20
Conditions, and Build Conditions with Mitigation. The Proponent should thoroughly explore means to
reduce overall SOV trips. The DEIR should also review measures to promote the use of low-emissions MEPA.141
vehicles, including installing EV charging stations and providing designated parking spaces for these
vehicles (a minimum of 25% of proposed spaces) with the balance of spaces being EV ready for future
installation. 18 The Build with Mitigation model should incorporate TDM measures and any roadway MEPA.142
improvements implemented by the project, and document the reductions in GHG emissions associated
with the mitigation. The DEIR should explain how TDM measures will be monitored and adjusted over MEPA.143
time and provide a methodology for quantifying emission reductions impacts rather than an assumed
percentage reduction.
GHG Self-Certification
The DEIR should include a commitment to provide a GHG self-certification to the MEPA Office
MEPA.144
upon construction of the project. It should be signed by an appropriate professional (e.g., engineer,
architect, transportation planner, general contractor) indicating that all of the GHG mitigation measures,
or equivalent measures that are designed to collectively achieve identified reductions in stationary
source GHG emission and transportation-related measures, have been incorporated into the project. If
equivalent measures are adopted, the project is encouraged to commit to achieving the same level of
GHG emissions (i.e., “carbon footprint”) identified in the Preferred Alternative expressed as
a volumetric measure (tpy) in addition to a percentage GHG reduction from Base Case.
Construction Period
The DEIR should provide a comprehensive review of the project’s construction-period impacts MEPA.145
and mitigation relative to noise, traffic, air quality, and water quality. The DEIR should include
measures that will minimize damage to the site and adjacent areas that could result from storms during MEPA.146
the construction period. The DEIR should describe implementation of a construction management plan MEPA.147
(CMP) to minimize disturbances. It should identify the schedule for construction. It should confirm that MEPA.148
construction equipment will use Ultra Low Sulfur Diesel fuel. The DEIR should describe consistency MEPA.149
with EPA’s Tier 4 emissions limits and discuss the use of after-engine emissions controls, such as
oxidation catalysts or diesel particulate filters. The DEIR should provide more information regarding the MEPA.150
project’s generation, handling, recycling, and disposal of construction and demolition (C&D) debris and
identify measures to reduce solid waste generated by the project. I encourage the Proponent to commit MEPA.151
to C&D recycling activities as a sustainable measure for the project. The project will develop a
Stormwater Pollution Prevention Plan (SWPPP) in accordance with its NPDES CGP to manage
MEPA.152
stormwater during the construction period. The DEIR should describe stormwater management
measures that will be implemented during construction. It should describe potential construction period MEPA.153
dewatering requirements, discuss how dewatering will be conducted, and identify any necessary permits.
If oil and/or hazardous material are identified during the implementation of the project, notification MEPA.154
pursuant to the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000) must be made to MassDEP,
MEPA.155
if necessary. The DEIR should commit to developing a spill contingency plan as described in MassDEP
comments.
18
More information on EV infrastructure can be obtained from the MassEVolves program at www.massevolves.org.
21
Mitigation/Draft Section 61 Findings
The DEIR should include a separate chapter summarizing all proposed mitigation measures MEPA.156
including construction-period measures. This chapter should also include a comprehensive list of all
commitments made by the Proponent to avoid, minimize and mitigate the impacts of the project. The
DEIR 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. The list of commitments should be provided in a tabular format
organized by subject matter (land, traffic, water/wastewater, GHG, etc.) and identify the Agency Action
or Permit associated with each category of impact. Draft Section 61 Findings should be separately
included for each Agency Action to be taken on the project.
Responses to Comments
The DEIR should contain a copy of this Certificate and a copy of each comment letter received. MEPA.157
It should include a comprehensive response to comments on the ENF that specifically address each issue
raised in the comment letter; references to a chapter or sections of the DEIR alone are not adequate and
should only be used, with reference to specific page numbers, to support a direct response. This directive
is not intended to, and shall not be construed to, enlarge the Scope of the DEIR beyond what has been
Circulation
In accordance with 301 CMR 11.16, the Proponent should circulate the DEIR to each Person or MEPA.158
Agency who commented on the ENF, each Agency from which the project will seek Permits, Land
Transfers or Financial Assistance, and to any other Agency or Person identified in the Scope. Pursuant
to 301 CMR 11.16(5), the Proponent may circulate copies of the DEIR to commenters in a digital format
(e.g., CD-ROM, USB drive) or post to an online website. However, the Proponent should make
available a reasonable number of hard copies to accommodate those without convenient access to a
computer to be distributed upon request on a first come, first served basis. The Proponent should send a
letter accompanying the digital copy or identifying the web address of the online version of the DEIR
indicating that hard copies are available upon request, noting relevant comment deadlines, and
appropriate addresses for submission of comments. If submitted in hard copy, the DEIR submitted to the
MEPA office should include a digital copy of the complete document. A copy of the DEIR should be
made available for review in the Bridgewater Public Library.
June 24, 2022 _____________________________

Date Bethany A. Card
22
Comments received:
05/31/2022 Gary Abrams

05/31/2022 Nancy Abrams
06/01/2022 Jean DiBattista (second comments submitted 06/04/2022)
06/04/2022 Robert DiBattista
06/06/2022 Sam Baumgarten
06/08/2022 Massachusetts Division of Fisheries and Wildlife Natural Heritage and Endangered
Species Program (NHESP)
06/09/2022 Massachusetts Historical Commission (MHC)
06/09/2022 Sharon Cumiskey
06/10/2022 Massachusetts Department of Conservation and Recreation (DCR)
06/10/2022 Linda Schmuck (second comments submitted 06/10/2022)
06/10/2022 Donna Auger
06/11/2022 Julia Blanchard (attachment consists of duplicate letter)
06/11/2022 Evelyn DeLutis
06/12/2022 Michael and Nathalie Berkowitz
06/13/2022 Massachusetts Department of Environmental Protection (MassDEP) –
Southeast Regional Office (SERO)
06/13/2022 Mark Peterson
06/13/2022 Lake Nippenicket Action Focus Team (also submitted video entitled “Perennial Stream”
– duplicate comments submitted on 06/13/2022 by Melissa Ramondetta)
06/13/2022 Linda Young
06/13/2022 Ramonita Mulero
06/13/2022 Anthony Oliveira
06/13/2022 Leiry Melendez-Sullivan
06/13/2022 Susan MacDonald
06/13/2022 Janet Hanson and David Hanson
06/13/2022 Kelly Cannizzaro
06/13/2022 Marc Sullivan
06/14/2022 Melissa Ramondetta
06/14/2022 Amanda and Jeff Napior
06/14/2022 Samantha Melendez
06/14/2022 Eileen Hiney, Bridgewater Open Space Committee
06/14/2022 Kevin D. Curry
06/14/2022 Patricia Neary
06/14/2022 Taunton River Watershed Alliance (TRWA)
06/14/2022 Andrea Monteith
06/16/2022 Massachusetts Department of Transportation (MassDOT)
06/23/2022 Massachusetts Department of Energy Resources (DOER)
BAC/PPP/ppp
23
SECRETARY’S CERTIFICATE ON THE DRAFT EIR
MEPA.01 The DEIR should follow Section 11.07 of the MEPA regulations for form and content and
provide the information and analyses required in this Scope. It should clearly
demonstrate that the Proponent has sought to avoid, minimize and mitigate Damage
to the Environment to the maximum extent practicable.
This DEIR complies with the MEPA Regulations in terms of format and content. It
demonstrates that all feasible measures to avoid, minimize and mitigate Damage to the
Environment have been taken in terms of land alteration, wetland impact, transportation,
greenhouse gas, etc.
MEPA.02 The DEIR should identify any changes to the project since the filing of the ENF.
The Proposed Project is essentially the same as was presented in the ENF in terms of both
uses and their proposed locations. As the design has been advanced, the size of the 55+
residential building on Lot 6 and the hotel on Lot 7 have been increased along with a slight
increase in the number of parking spaces. Table 1-1 summarizes changes between the
ENF and the current Preferred Alternative.
MEPA.03 The DEIR should provide a more detailed description of existing and proposed
conditions and a comprehensive review of the project’s impacts and measures to avoid,
minimize and mitigate such impacts on the project site.
The DEIR presents more detailed site development plans in Chapter 1. Chapter 2 discusses
alternatives that were considered to reduce the Project’s overall footprint.
MEPA.04 It should identify and describe State, federal and local permitting and review
requirements associated with the project and provide an update on the status of each
of these pending actions.
The Project will require local permits and approvals, a MassDOT Access Permit, and a U.S.
EPA NPDES Construction General Permit. Please refer to Section 1.
MEPA.05 The DEIR should include a description and analysis of applicable statutory and
regulatory standards and requirements, and a discussion of the project’s consistency
with those standards.
The Project will be designed to be in compliance with all applicable regulations. Notably,
the Project’s stormwater management system will comply with the MassDEP Stormwater
Management Policy Standards. Section 1.

MEPA.06 The DEIR should include detailed site plans for existing and post-development
conditions at a legible scale, which clearly identify project elements such as buildings,
access roads, stormwater and utility infrastructure, and wetland resource areas and
buffer zones.
Please see Chapter 1 for figures showing the overall master plan (Figure 1-6) and
conceptual plans (Figures 1-7 through 1-12) for each of the individual development lots.
MEPA.07 The DEIR should confirm the size of the project size and explain the discrepancy
between the 162.5-acre site described in prior NPC and EIR filings, the 163.87-acre site
described in the Certificate on the FSEIR, and the estimates provided in the ENF.
The overall Lakeshore Center Development has expanded in recent years in two areas.
Lot 1 was increased in size to add a parking lot and the Northern Lot was acquired. Prior
MEPA filings excluded the approximately 1.3-acre development on Lot 1 and the
approximately 1.9-acre development on the Northern Lot, both of which are included in
this current filing.
MEPA.08 The Town should provide a clear breakdown of for each lot within both Bridgewater
and Raynham, which also includes the Northern Parcel.
All of the development areas proposed in this DEIR are within Bridgewater.
MEPA.09 The DEIR should include an expanded alternatives analysis that considers a Reduced
Build Alternative for the site that minimizes tree clearing and incorporates strategies
for avoiding land alteration and creation of impervious area in an ACEC such as clustered
and denser buildings, structured parking, etc.
Chapter 2 discusses the various strategies that were examined as a means of reducing the
Project’s overall footprint. The Project will employ retaining walls throughout the
development to limit the Project footprint and avoid encroachment into the 25-foot no
disturb zone around wetland resources.
MEPA.10 The DEIR should document proposed conditions for this alternative including
programming for the site, quantify environmental impacts and provide a conceptual
plan.
Project’s overall footprint. As a means of reducing impervious areas, the Proponent is
proposing to bank 260 parking spaces and construct them only if it is found necessary
upon full operations. If successful, this will reduce impervious area by 42,100 sf.

MEPA.11 It should compare the environmental impacts of this alternative with the Preferred
Alternatives, in particular, with respect to land alteration within an ACEC, impervious
area/stormwater management, wetland resource areas, traffic, historic resources,
water/wastewater, and GHG emissions impacts and climate resiliency.
Project’s overall footprint. As a means of reducing impervious areas, the Proponent is
proposing to bank 260 parking spaces and construct them only if it is found necessary
upon full operations. If successful, this will reduce impervious area by 42,100 sf.
MEPA.12 The DEIR should include a Transportation Impact Analysis (TIA) developed in
accordance with MassDOT/EOEEA’s Transportation Impact Assessment Guidelines and
in consultation with the Town of Bridgewater (Town) and MassDOT.
Chapter 4 presents the TIA which has been prepared in accordance with the
MassDOT/EOEEA’s Transportation Impact Assessment Guidelines.
MEPA.13 The study should include a comprehensive assessment of the transportation impacts of
the project.
Chapter 4 provides a comprehensive summary of the operational analysis of the study

area intersections.
MEPA.14 The TIA should provide capacity analyses of existing conditions, future No-Build
conditions, and future Build conditions, particularly at state highway locations.
The Transportation Section (Chapter 4) of the DEIR includes the capacity analyses of
Existing, No Build, and Build conditions at the following study area locations:
♦ North Main Street (Route 104) at Pleasant Street/Elm Street E
♦ Pleasant Street at Lakeside Drive/Fruit Street

MEPA.15 The future Build conditions should include an analysis of operations both with and
without any improvements suggested to mitigate project impacts.
Based on the results of the capacity analysis, no mitigation for vehicles that would be
reflected in the capacity analysis is proposed. A comparison and discussion of the 2029
Build Conditions capacity analysis results is provided in Section 4.5 and Attachment A of
the DEIR.
The Project also proposes a robust TDM program to help reduce single occupancy vehicles
trips. See Section 4.6.
MEPA.16 The study should propose an integrated multimodal mitigation package intended to
improve vehicular traffic operations while supporting increased use of walking,
bicycling, and transit by employees and residents.
The Project will include a Transportation Demand Management (TDM) and a mitigation
package to support the use of alternative modes of transportation to reduce single
occupancy vehicles (SOV) trips to the Project Site. Please refer to Section 4.6. for
additional information.
MEPA.17 The Proponent should continue consultation with the Town and appropriate MassDOT
units, including PPDU, Traffic Operations, and the District 5 Office during preparation of
the DEIR.
McMahon has been in consultation with the personnel necessary for the preparation of
the DEIR.
MEPA.18 The DEIR should ensure that any analysis of pass-by trips is consistent with MassDOT
TIA Guidelines.
The analysis of pass-by trips described in the Transportation Chapter of the DEIR is
consistent with the MassDOT TIA guidelines.
MEPA.19 The TIA should provide a trip distribution for the project based on a gravity model or
similar model that uses factors such as census data, origin-destination, travel time, and
distance to determine trip characteristics for visitors, residents and employees of the
project.
The additional traffic estimated to be generated by the proposed development was

distributed onto the study area roadways and intersections based on existing travel
patterns, logical travel routes, and U.S. Census Journey-to-Work data for the Town of
Bridgewater. See Section 4.5.2 for additional information.

MEPA.20 The DEIR should provide all appropriate back up documentation to verify how the
different percentages are calculated and assigned to the roadway network and the
transit system.

Bridgewater. See Section 4.5.2 for additional information on the anticipated trip
distribution and Attachment A for the data used to create these estimates.
MEPA.21 The TIA should include analysis of intersections and roadways where site traffic exceeds
100 vehicle trips per hour or 5% of existing volume. The ENF proposes intersections to
be included in the TIA study area along Route 104 at proposed site driveways, at Route
24 northbound/southbound ramps, and at Lakeside Drive/Fruit Street, Old Pleasant
Street, at Lakeshore Center Drive, at Residence Inn Driveway, and North Main Street.
The study area intersection include:
♦ North Main Street (Route 104) at Pleasant Street/Elm Street E
♦ Pleasant Street at Lakeside Drive/Fruit Street
Additional site traffic is not anticipated to exceed the 5% threshold of intersections

outside those listed above and included in the DEIR.
MEPA.22 The TIA should address the atypical traffic conditions resulting from the COVID-19
pandemic and follow MassDOT’s Guidance on Traffic Count Data, as detailed in
Engineering Directive number E-20-005 (issued May 11, 2020), which allows for use of
historical traffic data (no older than 2014) on any project to supplement and/or replace
existing traffic counts.
Since the receipt of this comment, Engineering Directive E-20-005 has been replaced with
Engineering Directive E-22-003 which notes an update to the Traffic and Safety
Engineering 25% Design Submission Guidelines and the Traffic Volume guidance. The new
guidelines from MassDOT indicate that traffic count data collected on or after March 1,

2022 is not subject to COVID-19 adjustments. The traffic counts for the Project were
conducted in April 2022; therefore, no COVID-19 adjustment was applied. Please refer to
Section 4.3.5 for additional information.
MEPA.23 The Proponent should consult with the Highway Division Traffic and Safety Section on
the most recent updates of the MassDOT guidance on traffic count data.
McMahon has followed the most recent MassDOT guidance regarding traffic count data.
MEPA.24 The TIA should include crash analyses for all intersections in the study area using the
MassDOT crash database for the most recent five years of accepted/available data.
understand the existing safety operations of the study area intersections. This included a
review of crash data from 2015 through 2019. A summary of the crash data is presented
in Attachment A. Please refer to Section 4.3.7 for additional information.
MEPA.25 The study area intersections that are identified as Highway Safety Improvement
Program (HSIP) clusters should be reviewed to determine whether Road Safety Audits
(RSAs) are required or if any further actions may be taken to improve safety.
None of the study area intersections are listed as a Highway Safety Improvement Plan
(HSIP) cluster. Please refer to Section 4.3.7 for additional information.
MEPA.26 Additionally, the Route 104 study corridor should be reviewed in the MassDOT Impact
portal, in particular, the crash-based and risk-based screening tools. Proposed
mitigation should reduce the number of crashes along high crash corridors as well as
address any risks identified.
The Route 104 corridor was reviewed in the MassDOT Impact Portal utilizing the crash
based and risk-based screening tools. Please refer to Section 4.3.7 and Table 4-3 for
MEPA.27 The DEIR should describe if additional mitigation measures will be provided at
intersections to improve safety.
Utilizing the crash-based and risk-based screening tools, the Pleasant Street (Route 104)
corridor within the study area is not shown to be primary risk roadway for crashes. Section
4.3.7 provides additional information.

MEPA.28 The TIA should include operational analysis of existing traffic conditions at the
intersections and roadways included in the study area identified in the ENF and
MassDOT comments.
McMahon Associates conducted an analysis of existing traffic conditions as part of the

TIA. Section 4.3 provides additional information.
MEPA.29 The TIA should include capacity analyses for the weekday morning and evening peak
hours for both existing and future conditions for the project.
The Synchro capacity analysis results of the study area intersections for the weekday
morning and weekday afternoon peak hours under the 2022 Existing conditions are
summarized in Table 4-4 , under the 2029 No Build conditions are summarized in Table
4-5, and under the 2029 Build conditions are summarized in Table 4-7. A more detailed
summary of the capacity analysis for each study area intersection and queue graphics
are provided in Attachment A.
MEPA.30 In addition, capacity analyses for Build with Mitigation conditions should be provided
for all intersections, particularly those with impacts to the state highway system. Of
particular concern is the operation of the Route 24 interchange with Route 104.
Based on the results of the capacity analysis, mitigation to address vehicular operations
is not proposed. Please refer to Section 4.5.3 for the 2029 Build Capacity Analysis.
MEPA.31 The TIA should provide illustrations depicting the peak hour 50th (average) and 95th
percentile queue lengths for each lane group/turning movement at each study area
intersection, for all analysis scenarios.
The queue diagrams for weekday morning and weekday afternoon peak hours for existing
and future conditions are included in the Attachment A.
MEPA.32 The information contained in these illustrations should clearly demonstrate that the
project would not result in any extended queues that would block vehicle movements
to/from study area intersections, particularly those involving state highways.
The queues diagrams, included in Attachment A, demonstrate that the project would not
result in any extended queues that would block vehicle movements to/from the study
area intersections including the state highways.
MEPA.33 The analysis should include queue length to demonstrate that the project would not
result in queues extending to the Route 24 mainline.
and future conditions are included in Attachment A. The queues demonstrate that the

Project would not result in queues extending to the Route 24 mainline under the existing
and future conditions analyzed. Section 4.5.3 provides additional information.
MEPA.34 The DEIR should identify appropriate mitigation if necessary to address this concern.
Based on the queueing results in the capacity analysis, mitigation is not proposed as part
of the Project.
MEPA.35 The TIA should provide an inventory of existing sidewalks and crosswalks within the
study area and should address the quality and condition of those facilities.
McMahon conducted an inventory of existing sidewalks and crosswalks within the study
area. Please refer to Sections 4.3.1 and 4.3.6 for additional information.
MEPA.36 It should include a commitment to improvements in any areas that are structurally
deficient or not meeting current codes for accessibility, including sidewalks, crosswalks,
ramps, and pedestrian equipment.
To provide enhanced pedestrian infrastructure within the study area, mitigation has been
proposed to support the increase in walking, bicycling, and transit by employees and
residents. Please refer to Section 4.6 for additional information.
MEPA.37 Special attention should be given to linking the proposed development to adjacent
complementary land uses and transit facilities.
To provide enhanced pedestrian infrastructure within the study area to connect to the
existing pedestrian network, mitigation has been proposed and is outlined in Section 4.6.
No existing transit services and limited complementary land uses are located within close
proximity of the Project Site.
MEPA.38 The TIA should include a detailed inventory of the bicycle network to include bikeway
types, bikeway widths, and bicycle volumes and speeds.
McMahon conducted an inventory of the bicycle network within the study area. No
bicycles were recorded during the data collection conducted for the project; therefore,
no bicycle volumes or speeds are available to review. Refer to Section 4.3.6 for
information on the inventory of the multimodal access accommodations in the study area
and Section 4.3.4 for additional information on the traffic volume data.
MEPA.39 It should identify the likely travel routes for bicyclists within the study area and examine
the degree to which these routes can safely support bicycle travel.
Potential routes for future bicycle travel to and from the project site would be expected
to continue along existing bicycle routes primarily on the Pleasant Street (Route 104)
roadway within the existing shoulders. Refer to Section 4.5.4 for additional information.

MEPA.40 The TIA should reevaluate these routes based on the origin-destination of potential
employees and visitors.
roadway within the existing shoulders. Refer to Section 4.5.4 for additional information
MEPA.41 Based on this analysis, the TIA should consider the feasibility of expanding some of
these existing routes or considering new routes to encourage bicycle travel in and
around the site.
Dedicated bicycle infrastructure is not currently present directly within the project study
area. However, bicycle lanes on North Main Street, south of the Raynham town line, have
been striped within the shoulders. Similar width shoulders currently exist along Pleasant
Street (Route 104) within the study area. The project is proposing to maintain those
shoulders to allow for the existing occasional bicycle travel by not proposing any
additional turn lanes for vehicular travel along that segment of Pleasant Street Route 104.
Section 4.5.4 provides additional information.
MEPA.42 The project site is not located within an area currently served by transit. The Proponent
should consult with the Brockton Area Transit and the Greater Attleborough-Taunton
Regional Transit Authority regarding the feasibility of extending transit services to the
site.
McMahon contacted the Greater Attleboro Taunton Regional Transit Authority (GATRA)
and Brockton Area Transit Authority (BAT) to determine potential multimodal service
near the project site. McMahon had a meeting with BAT on November 14, 2022 to discuss
potential connections. No conversations have been made with GATRA as of December 2,
2022. An overview of the meeting is provided in Section 4.3.6.
MEPA.43 Additionally, the Proponent should consult with the Council on Aging for potential
services to the elderly population of the project. The DEIR should provide a summary of
the outcome of these consultations.
The Project team will coordinate with the Council on Aging during the local permitting
process for the Project once more details of development have been identified.
MEPA.44 The TIA should explain the methodology used to determine the total parking required
(1,083 parking spaces proposed). The ITE Parking Generation Manual (5th Edition)
generally provides a reasonable basis for comparison to parking requirements under
local zoning.
Please refer to Table 2-3 which presents a summary of the proposed parking program
compared to that required by local zoning. The Proponent is proposing to initially bank

260 spaces being proposed and not construct them unless they are found to be needed
once the project is fully occupied.
MEPA.45 The TIA should include a summary of parking need and supply for comparable facilities
based on multiple data sources.
The parking program proposed is based upon a number of factors, including the
Proponent’s extensive experience at the Project site, industry standards, and zoning. The
amount proposed is the minimum that the Proponent believes is needed to satisfactorily
service the proposed development. Note that the Proponent is proposing to initially bank
260 spaces and will not construct those spaces unless it found to be required based on
full operations.
MEPA.46 The TIA should determine the number of parking spaces occupied at various times of
day and identify periods of peak use.
Peak parking use will be in the evenings when guests of the proposed hotel, and residents
of the condominiums, 55+ building are present. Section 2.2.3 discusses the potential for
shared parking among the different uses on the site.
MEPA.47 The Proponent should seek opportunities to share parking with the existing uses on-
site. The DEIR should describe further reduction of site parking spaces
The Proponent considered using shared surface parking among the various uses on the
different lots but has been found it to be impractical. Please see Section 2.2.3.
MEPA.48 The DEIR should identify the number of EV ready spaces that will be provided on the
project site.
The Proponent has committed to the installation of EV charging stations to serve 36

parking spaces for this Project. See Section 11.2.4.
MEPA.49 The DEIR should include a detailed Transportation Demand Management (TDM)
program intended to reduce single-occupancy vehicle (SOV) trips to the project site and
to promote the use of alternative modes of transportation.
The proposed Project will implement a Transportation Demand Management (TDM) to

encourage the use of alternative modes of transportation to reduce single occupancy
vehicles (SOV) trips to the site. Section 4.6 provides additional information.
MEPA.50 The DEIR should include sufficiently detailed conceptual plans (minimum of 80-scale)
for any proposed roadway improvements to verify the feasibility of constructing such

improvements and demonstrate consistency with appropriate MassDOT design
standards including Complete Streets.
Other than a new crosswalk, the Proponent is not proposing any new roadway
construction.
MEPA.51 These plans should clearly show proposed lane widths and offsets, layout lines and
jurisdictions, and land uses adjacent to areas where improvements are proposed.
The Proponent is not proposing any new roadway construction.
MEPA.52 All proposed roadway signage and lighting must comply with MUTCD standards.
Comment noted. Any lighting or signs installed will comply with the standards. The new
crosswalk proposed across Pleasant Street west of Old Pleasant Street to access the
Northern Lot will be designed in compliance with MassDOT standards.
MEPA.53 The DEIR should commit to the implementation of an annual Traffic Monitoring
Program (TMP) for a period of five years, beginning six months after occupancy of the
full-build project, which will include: • Simultaneous automatic traffic recorder (ATR)
counts at each site driveway for a continuous 24-hour period on a typical weekday •
Travel survey of employees and patrons at the site (to be administered by the
Transportation Coordinator) • Weekday AM and PM and Saturday peak hour turning
movement counts (TMCs) and operations analysis at “mitigated” intersections,
including those involving site driveways • Transit Ridership counts.
Section 4.6.2 includes a discussion of the monitoring program. The proposed project will
complete an annual transportation monitoring program for a period of five years,
beginning six months after occupancy of the full-build project, to evaluate the adequacy
of the mitigation measures and determine the effectiveness of the TDM program.
MEPA.54 The DEIR should provide an update on impacts associated with new land alteration and
impervious area creation. I encourage the Proponent to continue to explore onsite
alternatives to reduce environmental impacts and features to further mitigate potential
impacts and preserve open space and tree cover.
Please refer to Chapter 3 for information on the proposed land alteration associated with
the Project. Table 3-1 summarizes the impervious area proposed on a per lot basis.
Chapter 2 discusses various alternatives considered to reduce impervious areas.

MEPA.55 The DEIR should quantify the total amount of alteration associated with the project
including areas to be altered for buildings, roadways, parking, wastewater, water and
stormwater infrastructure, landscaping, and other project components.
Please refer to Table 3-1 for this information. The table summarizes the proposed land
alteration for the Project by category.
MEPA.56 It should include a breakdown showing the amount of alteration for each project
element.
Please refer to Table 3-1 for this information.
MEPA.57 It should clarify the location, type and amount of alteration in previously undisturbed
areas.
The Project proposes development on previously undisturbed areas, namely Lots 4, 6, 7

and the lot on the north side of Route 104 next to Lake Nippenicket. Table 3-2 summarizes
the type and amount of alteration in these areas.
MEPA.58 The DEIR should include site plans that clearly locate and delineate areas proposed for
development and those to be left undisturbed.
Conceptual site plans for each of the development lots are presented in Figures 1-7
through 1-12. In addition, please
MEPA.59 It should specifically estimate the amount of tree clearing that will be required. It should
show the locations where fill will be placed for regrading purposes and the depth of fill.
The Proponent estimates that the Project will require approximately 22.2 acres of tree
clearing. See Table 3-3. Grading plans are included as Figures
MEPA.60 The DEIR should identify how the project is designed to avoid and minimize land
alteration.
The amount of land alteration necessary for the Project has been minimized through a
variety of design measures. Section 3.2.1 provides additional information.
MEPA.61 The DEIR should identify open space that will remain undisturbed and/or restored upon
completion of construction.
The proposed Project will leave approximately 33.5 acres of the overall Lakeshore Center
undeveloped. Please see Section 3.3 and Figure 3-7.

MEPA.62 Given the size of the project site, the DEIR should consider placing a conservation
restriction on portion(s) of the site designated as open space, including areas containing
wetlands, to ensure their permanent protection.
The proposed Project will leave approximately 33.5 acres of the Project site undeveloped.
To enhance the long-term protection of these undeveloped areas, the Proponent is
investigating the feasibility/practicality of placing a deed restriction, or similar land
preservation mechanism, on the property to restrict future development from occurring.
Please see Figure 3-8.
MEPA.63 The DEIR should identify all easements and public utilities on the site and provide
information on the parties to the easements and location and condition of public
infrastructure.
Utilities are shown on the conceptual site plans for each of the development lots on
Figures 1-7 through 1-12.
MEPA.64 It should describe any constraints on project design or use of the site posed by these
conditions.
Utilities are shown on the conceptual site plans for each of the development lots on
Figures 1-7 through 1-12. The Proponent foresees no difficulty presented by the utility
infrastructure.
MEPA.65 The project will occur in more than one phase. The DEIR should clearly identify the
activities proposed for each phase and the area to be developed.
The Proponent anticipates starting construction once all appropriate permits are
obtained and expects to begin with Lot 7 then 6. Later lots (i.e., 1, 4, and the North Lot)
are expected to be built later depending on market conditions.
MEPA.66 Regardless of any phasing of construction, the DEIR should describe how proposed land
alteration, such as clearing, regrading or paving, will be limited to the minimum area
necessary at any time.
The Proponent will take appropriate steps during construction to minimize areas of
disturbance. The NPDES SWPPP will include measures for temporary stabilization of soils
during construction. See Section 12.9.
MEPA.67 As described in MassDEP comments, the DEIR should demonstrate, if the land in
agricultural use, as shown on a MassMapper overlay, has benefited from the tax savings
provided by M.G.L. Chapter 61A Assessment And Taxation Of Agricultural And
Horticultural Land and has met its obligations under Section 13: Change of use: Liability
for roll-back taxes.

The Proponent as owner of the land has not benefited from any tax savings pursuant to
MGL 61A Assessment of Taxation of Agricultural and Horticultural Land and is not
applicable to the Project site.
MEPA.68 The Proponent should also demonstrate, as required under Section 17 of this statute,
that prior to the sale of this property that a notice of intent to the Town of Bridgewater
was given for its first rights of refusal to purchase the land prior to its proposed
nonagricultural use.
MEPA.69 If the U.S. Department of Agriculture Natural Resources Conservation Service has
provided technical assistance to the farm that has certain contractual obligations, the
Proponent must demonstrate that those contract conditions have been met prior to the
conversion of this farmland to its proposed nonagricultural use.
MEPA.70 According to the ENF, the site is no longer mapped for the Eastern Box Turtle based on
the 15th Edition of the Natural Heritage Atlas (2021); however, the conditions approved
in the 2019 permit for turtle protection and mitigation still apply for future site
activities. New work is proposed on the Northern Parcel on the north side of Pleasant
Street adjacent to Lake Nippenicket associated with the construction of a restaurant.
This area is mapped for two listed species of plant, Plymouth gentian (Sabatia
kennedyana) and round-fruited seedbox (Ludwigia sphaerocarpa). These species and
their habitat are protected pursuant to the Massachusetts Endangered Species Act
(MESA) and its implementing regulations (312 CMR 10.00). The Proponent is currently
in consultation with NHESP to determine whether additional work will result in a take
of these species; if botanical surveys will be required for mapped plant species; and if
measures to avoid, minimize and mitigate project-related impacts for the listed plant
species will be necessary.
The Proponent has filed a MESA Checklist with NHESP to confirm whether or not the
proposed Project will result in a take of either species. NHESP has issued a “No-Take”
letter dated November 18, 2022, which confirms that the proposed Project will not result
in a take and that no Conservation Management Permit will be required for this portion
of the Project. Section 5.2 provides additional information.

MEPA.71 The DEIR should provide a summary of the outcome of consultations with NHESP,
indicate if a Conservation and Management Permit will be required for work on the
Northern Parcel, and identify additional measures to protect listed plants.
in a take and that no Conservation Management Permit will be required for this portion
of the Project. Section 5.2 provides additional information.
MEPA.72 Comments from the Bridgewater Open Space Committee indicate that elements of the
project are inconsistent with the 2017 Bridgewater Open Space Plan and the ACEC
designation.
With regard to the Bridgewater Open Space Plan, the Proponent notes that the Project is
being built entirely on private land which it controls. The primary areas of development,
Lots 6 & 7, while wooded are not actively used for recreation and public open space.
The ACEC designation does not prohibit development and, as required by ACEC
guidelines, the Proponent will limit or avoid adverse environmental impacts to the
greatest extent possible. Please refer to Chapter 6 for additional information.
MEPA.73 The DEIR should clearly and comprehensively define, describe, and document how the
project will minimize adverse effects on groundwater quality, habitat values,
biodiversity, storm damage prevention, flood control, historic and archeological
resources, scenic and recreational resources, and other natural resource values of the
ACEC pursuant to 301 CMR 12.00.
The proposed Project is not expected to adversely affect groundwater quality, habitat
values, biodiversity, storm damage prevention, flood control, historic and archeological
resources, or scenic and recreational resources. Section 6.2 provides additional details on
each of these categories.
MEPA.74 The DEIR should include a narrative to describe the project’s impacts to each of these
resource values, an analysis of alternatives that prioritizes avoiding impacts to ACEC,
and justification as to why the impacts associated with the Preferred Alternative cannot
be avoided.
The proposed Project is not expected to adversely affect groundwater quality, habitat
values, biodiversity, storm damage prevention, flood control, historic and archeological
resources, or scenic and recreational resources. Section 6.2 provides additional details on
each of these categories.

Chapter 2 presents further information related to the Proponent’s ability to minimize the
land disturbance, tree clearing, and impervious area required by the proposed Project,
while maintaining the scope of the project needed to make it financially viable.
MEPA.75 The DEIR should include a bio-inventory for areas of proposed alteration within the
ACEC to evaluate proposed impacts to biodiversity and related functions and values of
the existing habitats, wildlife, and natural communities. Extensive clearing, grading and
increased impervious surface proposed in the ACEC, and increased discharges of runoff
to the ACEC, may result in impacts and long-term effects on the wetlands and streams
in the ACEC.
In September of 2022, Wildlife Biologists from Goddard Consulting performed a Bio-

Inventory and Habitat Assessment on the Project Site located off Pleasant Street (Route
104) in Bridgewater, MA. The report concluded that the clearing of upland forest will have
some level of impact to the local vegetation and wildlife community; nevertheless, based
on the habitats and wildlife observed, it is not expected to be detrimental to the overall
wildlife habitat of the general area. Please refer to Section 6.3 for additional information.
MEPA.76 The DEIR should explore alternative designs that will improve, restore, and enhance the
ACEC and avoid adverse effects on the land and water resources and other values
described above and in the designation document for the Hockomock Swamp ACEC.
land disturbance, tree clearing, and impervious area required by the proposed Project,
while maintaining the scope of the project needed to make it financially viable.
MEPA.77 The DEIR should demonstrate that the project will avoid and minimize adverse effects
on the natural resource values of the area and address how project planning and
development can promote preservation, restoration, or enhancement of resource areas
within the ACEC.
land disturbance, tree clearing, and impervious area required by the proposed Project.
Section 3.2.1 discusses the measures the Proponent has and will take to minimize
impacts, including the use of retaining walls to limit the Project’s footprint and banking
parking spaces. As discussed in Section 3.3, the Proponent is also investigating the
feasibility of placing a deed restriction, or similar land preservation mechanism, on the
property to further protect resources within the ACEC.

MEPA.78 The DEIR should describe if the project will permanently protect open space on-site
adjacent to wetland resource areas.
To enhance the long-term protection of the undeveloped areas, the Proponent is

investigating the feasibility/practicality of placing a deed restriction, or similar land
preservation mechanism, on the property to restrict future development from occurring.
MEPA.79 It should include a description of the measures that will be implemented to afford
greater protection to the resources within the ACEC including reduction of impervious
surface, significant use of LID features and retention of trees on-site.
Impervious surfaces have been limited to the greatest extent practicable. Please see
Chapter 2 which discusses the alternatives the Proponent considered to reduce the
Project’s footprint. Section 3.2.1 discusses mitigation measures to reduce impacts. Figure
3-7 shows the areas that will be left undisturbed and Figure 3-8 shows the areas of a
potential conservation restriction. The stormwater BMPs are discussed in Section 7.3.5
discusses the proposed LID measures, which include the use of bioretention areas.
MEPA.80 I expect the DEIR will provide a detailed response to comments from residents/abutters
to address their concerns and demonstrate that all reasonable and feasible measures
will be taken to avoid, minimize and mitigate impacts to the ACEC.
This Chapter provides responses to the comments submitted by residents/abutters.

Please refer to Chapter 6 for information regarding the Proponent’s anticipated measures
to minimize adverse impacts to the ACEC.
MEPA.81 The DEIR should affirm that impacts to wetland resource areas regulated under the
WPA are not proposed for activities onsite. The DEIR should confirm whether the
stream which flows into Lake Nippenicket is perennial or intermittent and provide
supporting documentation.
The proposed Project will not impact the bordering vegetated wetlands (BVW), as all of
the proposed alterations will take place on the upland areas and in wetland buffer zones.
The proposed Project will be designed to comply with the Town of Bridgewater Wetland
Bylaw 25-foot-no-disturb buffer from BVW and the applicable performance standards
under the Wetland Protection Act (WPA) for work within the buffer zone. Section 7.1.2
provides additional information.
The stream that flows into Lake Nippenicket has previously been determined to be
intermittent. The question has been raised in the past and the DEP in 2009 provided an
opinion that the stream was not perennial. The documentation is provided in
Attachment E.

MEPA.82 The DEIR should describe project activities proposed in 100-foot buffer zone to BVW,
quantify these impacts and identify consistency with the WPA. MassDEP comments
indicate that there does not appear to be any proposed activities within Chapter 91
jurisdiction.
The vast majority of the 100-foot buffer zone will remain in its natural undisturbed state.
Stormwater basins constructed in the buffer zone will be naturalized and their down
gradient embankments revegetated with native plantings. A turtle barrier within the
Central area will be provided along the top of slope allowing access for the turtles and
other wildlife to the naturalized basins while preventing migration onto access drives and
parking facilities. No disturbance of any wetland resource is proposed for the
development of the remaining sites. Section 7.3.1.4 provides additional information.
MEPA.83 The DEIR should address comments from the Massachusetts Department of
Conservation and Recreation (DCR) Flood Hazard Management Program (FHMP) which
indicate that the Proponent will be required to develop BFE information for use in this
project meeting the requirements of the WPA regulations and the local floodplain
regulations of Bridgewater because unnumbered A zones do not include BFEs.
When development of the western site was completed, FEMA approval was sought to
establish a base flood elevation (BFE) for the area. That elevation was utilized when Lot 5
was developed and will be adhered to when work adjacent to the Western wetland, Lots
1 and 4, is designed. Likewise, the areas related to Lots 6 and 7 and the Northern Lot will
utilize the BFE, previously determined since flooding in this region is controlled by the
conditions along Lake Nippenicket. Section 7.2 provides additional information.
MEPA.84 The DEIR should describe the project’s compliance with federal Executive Order 11988,
Floodplain Management, which requires an eight-step decision-making process
including analysis of alternatives, avoiding impacts to floodplain when possible, and
minimizing impacts when avoidance is not possible.
Compliance with Executive Order 11988 is paramount to all projects and avoidance of
work within the floodplain is always the preferred route to follow. If it is unavoidable,
appropriate measures are taken to establish building heights above the floodplain and, if
filling of available flood storage area is compromised, replacement of the equivalent
storage volume is identified and included within the design plan. Fortunately, this area
has minimal potential for flooding and expansive wetland resources to handle the
temporary stormwater storage that may be required.
MEPA.85 The DEIR should include a comprehensive stormwater discussion and report for the
project.
Section 7.3 provides a comprehensive discussion of the Project’s proposed stormwater

management system.

MEPA.86 The DEIR should describe the extent to which the project will preserve existing tree
canopies and plant additional trees, including estimates of the number of trees that will
be planted.
Section 3.3 shows the areas that will remain undisturbed. A landscape plan for the
developed portion of the Project has not yet been developed; however, the Proponent is
committed to creating a green, high-quality, well landscaped development in keeping
with the existing development.
MEPA.87 The DEIR should demonstrate that LID strategies have been incorporated into the
stormwater design to the maximum extent practicable.
The stormwater BMPs are discussed in Section 7.3.5 discusses the proposed LID
measures, which include the use of bioretention areas.
During the detailed site design process, the feasibility of incorporating these LID
techniques will be explored further.
MEPA.88 The DEIR should demonstrate the system will be designed to accommodate larger storm
events. It should include a plan showing the location of BMPs.
Please see Section 7.3.1 for a discussion of the stormwater runoff analysis and Section
6.2.3 for a discussion of flood control and storm damage prevention. The conceptual site
plans in Figures 1-7 through 1-12 show the location of the stormwater system.
MEPA.89 The DEIR should provide analysis of the capacity of the stormwater management
system under future climate conditions, as described below.
The proposed stormwater management systems will provide the necessary storage and
recharge to reduce the peak rate and volume of runoff from the 2-, 10-, 25-, 50-, and 100-
year storm events to below 90% of the pre-development for all developed sub
watersheds. The undeveloped sub watersheds have a component of runoff that cannot
be changed and are still within practical limits of pre-development considering the large
scale of the watersheds being analyzed. The design and construction of the individual sites
will be done in compliance with the NPDES, the Massachusetts DEP Stormwater
Management Regulations, and with local requirements of the Town of Bridgewater.
MEPA.90 The DEIR should describe if the project will convey stormwater through underground
stormwater infiltration structures that qualify under the jurisdiction of the MassDEP
Underground Injection Control (UIC) program and which must be registered with the
MassDEP
The design and construction of the individual sites will be done in compliance with the
NPDES, the Massachusetts DEP Stormwater Management Regulations, and with local
requirements of the Town of Bridgewater. Underground infiltration is not planned.

MEPA.91 The project will use a total of 146,862 gpd of water (133,794 gpd new) that will be
provided by the Town and generate a total of 122,385 gpd of wastewater (111,495 gpd
new). According to MassDEP comments, the Town has the capacity to provide the
requested volume for this project based on its renewed Water Management Act (WMA)
permit issued on January 5, 2021 and its recent water use. The DEIR should provide a
discussion of the project’s exceedance of the ENF threshold related to wastewater and
additional mitigation to offset those impacts.
consumption and associated impacts to the Bridgewater water supply and wastewater
systems. Specific mitigation measures will be in strict compliance with the Water
Conservation Standards of 2006 issued by the Executive Office of Energy and
Environmental Affairs (EOEEA) and the Water Resources Commission (WRC). Sections 8.1
and 8.2 provide additional information.
MEPA.92 The DEIR should evaluate and identify which water conservation measures and BMPs
will be implemented at the project site.
systems. Specific mitigation measures will be in strict compliance with the Water
Conservation Standards of 2006 issued by the Executive Office of Energy and
Environmental Affairs (EOEEA) and the Water Resources Commission (WRC). Section 8.2
provides additional information.
MEPA.93 The DEIR should describe the Proponent’s efforts to work with the public water system
(PWS) to mitigate the additional demands on the system proposed by the project
including removal of infiltration and inflow (I/I).
Each Lot will be reviewed with the town during the permitting approval process to ensure
that adequate public water services are available to support the Project post-
construction. All stormwater will be infiltrated and managed onsite per the ACEC
requirements. No stormwater will be connected to public utility drainage systems.
MEPA.94 The Proponent should consult with the Town to identify appropriate I/I mitigation for
this project.
The Proponent is in communication with the Town of Bridgewater about an appropriate

monetary contribution for I/I mitigation for the Project. This amount will be paid based
on the Town’s requirements and regulations. Additional information is provided in
Section 8.3.

MEPA.95 The DEIR should include a commitment to I/I removal and identify any mitigation
projects or monetary contribution by the Proponent.
The Proponent is in communication with the Town of Bridgewater about an appropriate

monetary contribution for I/I mitigation for the Project. This amount will be paid based
on the Town’s requirements and regulations. Additional information is provided in
Section 8.3.
MEPA.96 The DEIR should confirm the Proponent will restrict irrigation use, if there is any, when
the Town implements its nonessential outdoor water use restriction requirements.
Water consumption and conservation of potable water has been a priority of the Town of
Bridgewater Water Department. The rules and regulations of the Town prohibit the use
of water supplied by the Town to be connected to irrigation systems. The Proponent will
continue to comply with the rules and regulations of both the Town of Bridgewater and
the Town of Raynham, including local regulations regarding outdoor water use
restrictions. Section 8.4 provides additional information.
MEPA.97 The DEIR should provide additional context, to the extent possible, regarding the nature
of proposed activities that involves destruction of both Native American sites and a
rationale for proposed impacts to these sites.
In March 2021, the Proponent signed a Memorandum of Agreement (MOA) prepared by

the Massachusetts Historical Commission (MHC) that outlines stipulations to mitigate the
“adverse effects” (36 CFR 800.5 and 950 CMR 71.05(a)) of proposed development on
significant archaeological resources in the Lakeshore Center project area. Chapter 9
provides additional information. The MOA is provided as Attachment F.
MEPA.98 The DEIR should provide additional information regarding the archaeological data
recovery program, to the extent possible, including potential removal and archiving of
sensitive archaeological resources.
The data recovery program has been implemented and archaeological fieldwork
completed on the Bassett and Tomb Road Area B sites by the Proponent’s consultant, The
Public Archaeology Laboratory, Inc. (PAL). Analysis of recovered cultural materials and
other categories of archaeological information and preparation of a technical report on
the data recovery program by PAL is in progress. Chapter 9 provides additional
information.
MEPA.99 The DEIR should include the alternatives analysis for Lots 6 and 7 prepared in 2020 and
a copy of the MOA. As described in MHC’s comment letter this alternatives analysis was
prepared by VHB, Inc. and Landvest.
The MOA is provided in Attachment F.

MEPA.100 The DEIR should describe the public notice and comment that was conducted as part of
the MOA process.
The MOA is provided in Attachment F. At the time of filing, the Proponent was still
researching how MHC handled the public comment.
MEPA.101 The DEIR should describe the measures that the Proponent, assisted by their consultant
The Public Archaeology Laboratory, Inc., will continue to consider and implement
involving minor project adjustments in design and specifications that could avoid and
protect particular areas of interest to Tribal Historic Preservation Officers of the
Mashpee Wampanoag Tribe and of the Wampanoag Tribe of Gay Head (Aquinnah), to
the Massachusetts Commission on Indian Affairs (MCIA), and to the MHC
Some adjustments in the Project design and specifications have been made through
consultation with the federally recognized tribes, MCIA, and the MHC. This consultation
included development of a plan to preserve in place four subsurface Native American
features on the Bassett Site. A plan to remove an unmarked Native American feature from
the Tomb Road Area B Site and re-inter it at another location selected by the tribes has
been implemented. These plans to preserve and protect specific archaeological features
were carried out under an amendment to the current MHC permit and no modifications
to the MOA were necessary. Chapter 9 provides additional information.
MEPA.102 According to MHC, the expanded project area on the north side of Pleasant Street
adjacent to the shore of Lake Nippenicket (Northern Parcel) has not been previously
surveyed for archaeological resources and may be archaeologically sensitive. The DEIR
should confirm that the Proponent will conduct a reconnaissance archaeological survey
(950 CMR 70) for this Northern Parcel, which includes limited subsurface testing to
evaluate subsurface soil conditions and identify any archaeologically sensitive areas.
In August 2022, in response to a request from the MHC, PAL conducted an archaeological
sensitivity assessment of the Northern Lot. Chapter 9 provides additional information.
MEPA.103 The DEIR should describe any additional proposed mitigation based on the outcome of
MHC review and the results of the archaeological survey on the Northern Parcel.
sensitivity assessment of the Northern Lot and concluded that no additional mitigation is
proposed at this time. Chapter 9 provides additional information.

MEPA.104 It should provide an update of consultation with MHC and indicate if the MOA will be
modified to reflect additional mitigation measures in consultation with MHC, the Tribes
listed above, and the MCIA.
sensitivity assessment of the Northern Lot and concluded that no additional mitigation is
proposed at this time. Chapter 9 provides additional information.
MEPA.105 The DEIR should provide a response to the comments from residents which identify
concerns related to the destruction of both ancient Native American sites.
This Chapter provides responses to the comments submitted by residents. Please refer to
Chapter 9 for information regarding the Proponent’s anticipated measures to minimize
adverse impacts to the Native American archaeological sites.
MEPA.106 According to the ENF, all proposed activities is proposed in upland areas outside the
floodplain. However, the “High” risk rating in the MA Resilient Design Tool takes into
account future climate conditions and is not limited to areas currently mapped as flood
plain (based on historical rainfall projections). The ENF does not provide information
about anticipated future conditions at the site due to the effects of climate change.
Chapter 10 provides a comprehensive review of the anticipated future conditions at the

Project Site due to climate change and potential adaptation measures to limit these
adverse effects.
MEPA.107 The DEIR should identify the project site’s vulnerabilities to climate change and
potential measures to increase its resilience.
The Town of Bridgewater’s Municipal Preparedness Plan, the Old Colony Planning
Council’s (OCPC) Regional Policy Plan, and the Resilient Massachusetts Action Team
(RMAT) Report were reviewed to identify climate-related hazards; assess existing and
future climate vulnerabilities of critical building infrastructure, stormwater,
transportation, water, energy, and vulnerable populations; and understand possible
adaptation and resiliency opportunities. Chapter 10 provides additional information.
MEPA.108 The DEIR should provide a review of the Town’s studies and resiliency plans on climate
vulnerabilities and potential solutions, including regional solutions requiring
coordination between the Proponent and abutters and other stakeholders.
The Proponent reviewed the Town of Bridgewater’s Municipal Vulnerabilities

Preparedness Workshop Report and the Old Colony Planning Council’s Regional Policy
Plan to gain an understanding of the Project’s climate vulnerabilities and potential
solutions that could be implemented. Please refer to Chapter 10 for additional
information.

MEPA.109 The DEIR should include a comprehensive discussion of the potential effects of climate
change on the project site and describe features incorporated into the project design
(including climate-related design specifications and standards) that will increase the
resiliency of the site to these changes.
The Town of Bridgewater’s Municipal Preparedness Plan, the Old Colony Planning
Council’s (OCPC) Regional Policy Plan, and the Resilient Massachusetts Action Team
(RMAT) Report were reviewed to identify climate-related hazards; assess existing and
future climate vulnerabilities of critical building infrastructure, stormwater,
transportation, water, energy, and vulnerable populations; and understand possible
adaptation and resiliency opportunities. Chapter 10 provides additional information.
MEPA.110 The DEIR should include information about the potential adaptation of the project to
future conditions.
Section 10.3 provides information on the Project’s anticipated adaptation measures to

extreme heat events/drought conditions, extreme precipitation for urban and riverine
flooding, and sea level rise/storm surge.
MEPA.111 In particular, the DEIR should analyze how the elevation of the proposed buildings was
determined in light of the potential for future urban and riverine flooding.
Potential climate changes and the possibility of substantial increases in the expected
stormwater runoff levels by the year 2070 are of concern; however, this area is expected
to accommodate the increases without impact to the Project Site. The impacts of the
higher rainfall events will result in stormwater peak and volume predictions to be
extreme, but the wetland system will provide a substantial buffer, minimizing any
observable impacts to the area of the Lake. Section 7.2 provides additional information.
MEPA.112 The DEIR should discuss how the stormwater system will be sized to address future
climate conditions. Effective April 25, 2022, the MA Resilience Design Tool provides
rainfall volumes associated with a 24-hour storm for multiple storm scenarios and
planning horizons for projects subject to extreme precipitation risks.
Please refer to Sections 7.2 and 7.3 for a discussion of the floodplain in the development
area and the proposed stormwater management system. The vast wetland resource area
of the Hockomock Swamp surrounding Lake Nippenicket and the expansive wetland areas
bordering the central upland area provide substantial capacity to withstand the largest
storms historically experienced in this region. While climate changes and the possibility
of substantial increases in the expected stormwater runoff levels by the year 2070 are of
concern, this area is expected to accommodate the increases without impact to the
Project site. The impacts of the higher future rainfall events will result in greater
stormwater peaks and volume, but the wetland system will provide a substantial buffer,
minimizing any observable impacts to the area of the Lake. At the same time, the

proposed stormwater management system will preserve existing conditions by
maintaining existing drainage patterns and proportional discharges to the wetlands and
the existing culverts on the site.
watersheds.
MEPA.113 The DEIR should consult these volumes for the 25-year, 50-year and 100- year storm as
of 2070 to assess the efficacy of the stormwater management system to accommodate
future climate conditions
For the detailed study of each location, the NOAA ATLAS 14 rainfall estimates for the 2,
10, 25, 50, and 100-year storm events were analyzed to generate estimates of stormwater
runoff associated with the proposed Project. Section 7.3 provides additional information.
MEPA.114 The DEIR should discuss, with quantitative modeling to the extent practicable, whether
the stormwater management system will attenuate peak flows and meet pollutant
loading requirements based on future climate conditions in 2070. Estimates can be
provided in lieu of exact calculations, to the extent stormwater design is not advanced
enough by the time of the DEIR.
to accommodate the increases without impact to the Project Site. The impacts of the
higher rainfall events will result in stormwater peak and volume predictions to be
extreme, but the wetland system will provide a substantial buffer, minimizing any
observable impacts to the area of the Lake. Refer to Section 7.2 for additional
information.
MEPA.115 The DEIR should also discuss whether the proposed elevation of buildings is anticipated
to be resilient to a future BFE associated with the 25-year, 50-year and 100-year storm
as of 2070.
Potential climate changes and the potential for substantial increases in the expected
stormwater runoff levels by the year 2070, are of concern, however, this area can
accommodate the increases without impact to the project area. The impacts of the higher
rainfall events will result in stormwater peak and volume predictions to be excessive, but
the wetland system will provide a substantial buffer, minimizing any observable impacts
to the area of the Lake.

MEPA.116 To the extent the project is unable to accommodate future year storm scenarios, the
DEIR should discuss whether the project has engaged in flexible adaptative strategies,
and whether current designs allow for future upgrades to be made to adapt to climate
change. General guidance on flexible adaptive strategies is available on the MA
Resilience Design Tool website.
to accommodate the increases without impact to the Project Site. Refer to Section 7.2 for
MEPA.117 The DEIR should continue to identify opportunities to increase resilience through
enhancement of the site, including retention of mature trees on-site, increased open
space and permeable surfaces.
The proposed Project will leave 33.5 acres undeveloped, much of which is wetland
capable of absorbing increases in runoff. Tree clearing has been minimized to the extent
practicable, and the Proponent’s will implement a robust landscaping plan.
MEPA.118 The DEIR should demonstrate that the Proponent is developing appropriate strategies
to adapt to extreme heat conditions throughout the useful life of the project.
To adapt to more days with temperatures over 90 degrees, the Project has been designed
to include high-performance building envelopes to reduce cooling loads in the summer
and the installation of high-performance HVAC equipment. In order to reduce the urban
heat island effect, the Project will maximize vegetated surfaces and incorporate reflective
roofs as well. The landscape design is anticipated to incorporate native and adaptive plant
materials to minimize the Project’s susceptibility to drought conditions.
MEPA.119 The DEIR should document all efforts taken to maximize the use of LID strategies for
stormwater management, including rain gardens, bioretention areas, tree box filters,
water quality swales. and green roofs.
Please refer to Section 7.3 for a description of the conceptual stormwater management
plan and Section 7.3.5 in particular for a discussion of LID strategies.
MEPA.120 In addressing climate change as described above, the DEIR should consider
incorporating additional climate adaption and resiliency features into the project design
to the maximum extent practicable, including: Ecosystem-based adaptation measures
to reduce heat island effect and mitigate stormwater runoff, such as integration of tree
canopy cover, rain gardens, and LID stormwater management techniques. Use of on-
site renewable energy systems that may provide added resiliency during periods of
power loss during storms Protection of emergency generator fuel supplies from effects
of extreme weather and floodproofing of parking garages and other structures.

Expansion of the size of emergency generators to allow for select common areas and
other emergency and life safety systems to remain operational for a period of time
beyond code requirements.
Section 10.3 discusses adaptation and resiliency measures. To adapt to more days with
temperatures over 90 degrees, the Project has been designed to include high-
performance building envelopes to reduce cooling loads in the summer and the
installation of high-performance HVAC equipment. In order to reduce the urban heat
island effect, the Project will maximize vegetated surfaces and incorporate reflective
roofs as well. The landscape design is anticipated to incorporate native and adaptive plant
materials to minimize the Project’s susceptibility to drought conditions.
The design team has evaluated potential locations for the opportunity to install PV arrays.
The size of this PV-ready area will be determined as design progresses. See Section 11.2.3.
Critical equipment will be located to protect it from the effects of future flooding. All
proposed construction is outside the current 100-year floodplain.
MEPA.121 This project is subject to review under the May 5, 2010 MEPA GHG Policy, which
requires Proponents to quantify carbon dioxide (CO2) emissions and identify measures
to avoid, minimize or mitigate such emissions. The analysis should quantify the direct
and indirect CO2 emissions of the project's energy use (stationary sources) and
transportation-related emissions (mobile sources).
Please refer to Chapter 11 for a complete GHG Analysis consistent with the 2010 MEPA
GHG Policy.
MEPA.122 Direct emissions include on-site stationary sources, which typically emit GHGs by
burning fossil fuel for heat, hot water, steam and other processes. Indirect emissions
result from the consumption of energy, such as electricity, that is generated off-site by
burning of fossil fuels, and from emissions from vehicles used by residents, employees,
visitors, and others.
Please refer to Chapter 11 for a complete GHG Analysis accounting of direct and indirect
GHG emissions.
MEPA.123 The DEIR should include a GHG analysis prepared in accordance with the GHG Policy,
guidance and recommendations provided in the comment letter submitted by the
Massachusetts Department of Energy Resources (DOER), which is incorporated in this
Certificate in its entirety, and this Scope.
Please refer to Chapter 11 for a complete GHG Analysis prepared in accordance with
DOER comments.

MEPA.124 The DEIR should include an analysis that calculates and compares GHG emissions
associated with a Base Case that conforms to the 9th Edition of the Massachusetts
Building Code, which references the American Society of Heating, Refrigerating and Air-
Conditioning Engineers (ASHRAE) 90.1-2013 and the International Energy Conservation
Code (IECC) 2015, and a Preferred Alternative that achieves greater reductions in GHG
emissions.
Please refer to Chapter 11 for a complete GHG Analysis that compares a base case that
conforms to the 9th edition of the Massachusetts Building Code with the Preferred
Alternative.
MEPA.125 The project will be required to meet the applicable version of the Massachusetts Stretch
Energy in effect at the time of construction, which currently requires a 10% energy
performance improvement over ASHRAE 90.1-2013-Appendix G plus Massachusetts
amendments including C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV
charging), and C406 (three additional efficiency measures).
Please refer to Chapter 11 for details of the analysis, including the Project’s conformance
with Massachusetts Amendments.
MEPA.126 The analysis should include the three C406 additional efficiency measures in the
Baseline.
The three C406 measures included are detailed in Section 11.2.5.
MEPA.127 The GHG analysis should clearly demonstrate consistency with the key objective of
MEPA review, which is to document the means by which Damage to the Environment
can be avoided, minimized and mitigated to the maximum extent feasible.
Please refer to Chapter 11 for a complete GHG Analysis that is consistent with MEPA
objectives.
MEPA.128 The DEIR should identify the model used to analyze GHG emissions, clearly state
modeling assumptions, explicitly note which GHG reduction measures have been
modeled, and identify whether certain building design or operational GHG reduction
measures will be mandated by the Proponent to future occupants or merely
encouraged for adoption and implementation.
Please refer to Section 11.2.5 for modeling details.
MEPA.129 The DEIR should include the modeling printouts for each alternative and emission tables
that compare base case emissions in tons per year (tpy) with the Preferred Alternative
showing the anticipated reduction in tpy and percentage by emissions source. Other
tables and graphs, such as the table of mitigation measures recommended by DOER,

may also be included to convey the GHG emissions and potential reductions associated
with various mitigation measures as necessary.
Please refer to Attachment D for the Energy Model report with relevant modeling
information.
MEPA.130 The DEIR should provide data and analysis in the format requested in DOER’s letter.
Chapter 11 provides data and analysis in the format requested in DOER’s letter.
MEPA.131 The DEIR should present an evaluation of mitigation measures identified in DOER’s
comment letter. In particular, the feasibility of each of the mitigation measures outlined
below should be assessed for each of the major project elements, and if feasible, GHG
emissions reduction potential associated with major mitigation elements should be
evaluated to assess the relative benefits of each measure.
The GHG Chapter 11 evaluates mitigation measures identified in DOER’s comment letter.
The GHG reduction potential and the feasibility of each of these measures has been
presented.
MEPA.132 The DEIR should explain, in reasonable detail, why certain measures that could provide
significant GHG reductions were not selected – either because it is not applicable to the
project or is deemed technically or financially infeasible.
The GHG Chapter 11 explains why certain measures that could provide GHG reductions
have not been selected.
MEPA.133 If financially infeasible, the DEIR should describe the cost effectiveness metrics that
were used to evaluate feasibility, whether energy savings that would accrue to future
tenants were considered, and what “payback period” the Proponent would deem to be
reasonable given the financial constraints identified.
Chapter 11 and Attachment D detail cost metrics used to evaluate the feasibility of certain
measures that could provide GHG reductions.
MEPA.134 It should include a review of available financial incentives potentially available for the
project, as described in DOER’s comment letter.
Please refer to Section 11.2.7. The Proponent has met with MassSave to review available
incentives and has incorporated all available incentives into their decision-making
process.
MEPA.135 At a minimum, the DEIR should consider the following GHG mitigation measures: •
Building design and construction practices that result in low heating and cooling
thermal energy demand intensity (TEDI) by: High-performance window and walls,

Thermally broken windows and other components to eliminate thermal bridges, Low
air-infiltration, Ventilation energy recovery, Energy recovery during concurrent heating
and cooling, Solar gain management via external shading, recessed windows, and/or
low solar heat gain coefficient (SHGC) • Passivehouse including engagement with a
MassSave funded consultant • Efficient electrification of space and water heating •
Extensive rooftop solar photovoltaic (PV) • EV charging stations and EV ready parking
spaces
Each of the measures outlined above have been included in the GHG Analysis included as
Chapter 11.
MEPA.136 The DEIR should evaluate the specific scenarios for each typology/use of building
detailed in DOER’s comment letter for baseline meeting minimum code (mandatory
code building scenarios), improved scenarios (HERS 45, Passivehouse, low heating TEDI,
etc.) and sub-scenarios for each of the six buildings including the four-story 225-unit
residential building, four-story 160-unit condo building, five-story 150-unit assisted
living building, four-story 102-unit hotel, 1,800-sf café, and 6,000-sf restaurant.
Each of the four major buildings has been evaluated as agreed upon during the group
meeting on August 26 and outlined in the follow-up memo provided by Epsilon. As
discussed, the two small outparcels were not modeled but rather discussed qualitatively.
MEPA.137 The DEIR should review the financial incentives identified in DOER’s comment letter and
incorporate these potential funding sources in analyses of Passivehouse design and
electrification of space and water heating. Significant incentives may be available
including MassSave® incentives15, Alternative Energy Credits (AECs), and Solar
Massachusetts Renewable Target (SMART)17 credits (in addition to federal and state
tax incentives). For qualifying multifamily buildings, the MassSave incentive for
Passivehouse is ±$3,000 per dwelling unit or ±$1.125 million for the project (plus
generous feasibility and design incentives). Currently, there are over 6,700
Passivehouse units being planned, designed or under construction in Massachusetts.
All available incentives currently available have been identified and included as part of
the Proponent’s decision-making process. MassSave Passive House incentives have been
included in the Passive House discussion in Section 11.2.2.
MEPA.138 The DEIR should review opportunities to maximize onsite PV systems by setting aside
as much roof space as possible for future rooftop PV. Even if PV is not installed during
building construction, it is important to plan the project to ensure that roof space is set
aside for PV and that roof space does not become unnecessarily encroached with HVAC
appurtenances, diminishing the opportunities for future PV.
Please refer to Section 11.2.2 for the Proponent’s rooftop photovoltaic commitment.

MEPA.139 The Proponent should consult with staff from DOER and the MEPA Office prior to
submitting the DEIR. The DEIR should clearly demonstrate that the Proponent is taking
all feasible measures to mitigate GHG impacts to the maximum extent practicable, and
provide a clear justification if energy efficiency measures that appear technically
feasible will not be adopted for the project
The Proponent met with MEPA and DOER staff on August 26, 2021, to review the
proposed GHG Analysis methodology. This was followed up with a memo from Epsilon
outlining the agreed upon analyses.
MEPA.140 The GHG analysis should include an evaluation of potential GHG emissions associated
with mobile emissions sources. The DEIR should follow the guidance provided in the
GHG Policy for Indirect Emissions from Transportation to determine mobile emissions
for Existing Conditions, Build Conditions, and Build Conditions with Mitigation. The
Proponent should thoroughly explore means to reduce overall SOV trips.
Please refer to Section 11.3 for a Mobile Source GHG analysis consistent with the GH
Policy.
MEPA.141 The DEIR should also review measures to promote the use of low-emissions vehicles,
including installing EV charging stations and providing designated parking spaces for
these vehicles (a minimum of 25% of proposed spaces) with the balance of spaces being
EV ready for future installation.
Please refer to Section 11.2.4 for the Proponent’s electric vehicle parking commitment.
MEPA.142 The Build with Mitigation model should incorporate TDM measures and any roadway
improvements implemented by the project, and document the reductions in GHG
emissions associated with the mitigation
The Build condition analysis accounts for the Proponent’s TDM program which is intended
to decrease single occupancy vehicle use and increase alternative modes of
transportation (i.e., transit, bicycling, walking), which in turn reduce GHG emissions.
However, the GHG emission reduction from the TDM program cannot be quantified
because of the methodology used for the Build condition transportation analysis.
MEPA.143 The DEIR should explain how TDM measures will be monitored and adjusted over time
and provide a methodology for quantifying emission reductions impacts rather than an
assumed percentage reduction.
The proposed Project will complete an annual transportation monitoring program for a
period of five years, beginning six months after occupancy of the full-build project, to
evaluate the adequacy of the mitigation measures and determine the effectiveness of the
TDM program. See Section 4.6.2 for details.

MEPA.144 The DEIR should include a commitment to provide a GHG self-certification to the MEPA
Office upon construction of the project. It should be signed by an appropriate
professional (e.g., engineer, architect, transportation planner, general contractor)
indicating that all of the GHG mitigation measures, or equivalent measures that are
designed to collectively achieve identified reductions in stationary source GHG emission
and transportation-related measures, have been incorporated into the project. If
equivalent measures are adopted, the project is encouraged to commit to achieving the
same level of GHG emissions (i.e., “carbon footprint”) identified in the Preferred
Alternative expressed as a volumetric measure (tpy) in addition to a percentage GHG
reduction from Base Case.
Please refer to Section 11.4.3 for the Proponent’s commitment to GHG self-certification.
MEPA.145 The DEIR should provide a comprehensive review of the project’s construction-period
impacts and mitigation relative to noise, traffic, air quality, and water quality.
Construction will be managed to minimize impacts and nuisance conditions. Please refer
to Chapter 12 for additional information.
MEPA.146 The DEIR should include measures that will minimize damage to the site and adjacent
areas that could result from storms during the construction period.
The Project will implement appropriate erosion and sentiment control measures during
construction. Please refer to Section 12.9 for additional information.
MEPA.147 The DEIR should describe implementation of a construction management plan (CMP) to
minimize disturbances.
Chapter 12 includes a description of the construction management plan (CMP) that will
be implemented as part of the Project.
MEPA.148 It should identify the schedule for construction.
The Project will be constructed in two phases. Phase 1 is anticipated to start in 2023 once
all necessary permits and approvals have been obtained. Phasing may be adjusted due to
market conditions. Section 12.2 provides additional information.
MEPA.149 It should confirm that construction equipment will use Ultra Low Sulfur Diesel fuel. The
DEIR should describe consistency with EPA’s Tier 4 emissions limits and discuss the use
of after-engine emissions controls, such as oxidation catalysts or diesel particulate
filters.
The Proponent will investigate compliance with MassDEP’s Diesel Retrofit Program and
will comply with requirements for the use of ultra-low sulfur diesel (ULSD) in off-road
engines. The Program encourages users of diesel construction equipment to install

exhaust emission controls such as oxidation catalysts or particulate filters on their diesel
engines. The Proponent acknowledges the importance of emission controls and will
encourage contractors to comply with the Diesel Retrofit Program. Section 12.5 provides
MEPA.150 The DEIR should provide more information regarding the project’s generation, handling,
recycling, and disposal of construction and demolition (C&D) debris and identify
measures to reduce solid waste generated by the project. I encourage the Proponent to
commit to C&D recycling activities as a sustainable measure for the project.
Information regarding the Project’s construction waste is provided in Section 12.6.
MEPA.151 The project will develop a Stormwater Pollution Prevention Plan (SWPPP) in accordance
with its NPDES CGP to manage stormwater during the construction period.
The SWPPP will be implemented during construction to comply with the requirements of
the NPDES General Permit for Construction Activities.
MEPA.152 The DEIR should describe stormwater management measures that will be implemented
during construction.
The Project will implement appropriate erosion and sentiment control measures during
construction. Please refer to Section 12.9 for additional information.
MEPA.153 It should describe potential construction period dewatering requirements, discuss how
dewatering will be conducted, and identify any necessary permits.
If dewatering is required to control groundwater during construction and the

groundwater contains pollutants, then a NPDES Remediation General Permit may be
required.
MEPA.154 If oil and/or hazardous material are identified during the implementation of the project,
notification pursuant to the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000)
must be made to MassDEP, if necessary.
Comment noted.
MEPA.155 The DEIR should commit to developing a spill contingency plan as described in MassDEP
comments.
implemented to ensure that any release of fuel (i.e., oil or gas) is managed quickly and
efficiently. This plan is incorporated into the Draft SWPPP.

MEPA.156 The DEIR should include a separate chapter summarizing all proposed mitigation
measures including construction-period measures. This chapter should also include a
comprehensive list of all commitments made by the Proponent to avoid, minimize and
mitigate the impacts of the project. The DEIR 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. The list of commitments should be provided in a tabular format
organized by subject matter (land, traffic, water/wastewater, GHG, etc.) and identify
the Agency Action or Permit associated with each category of impact. Draft Section 61
Findings should be separately included for each Agency Action to be taken on the
project.
Chapter 13 presents the phased delivery of the proposed mitigation measures.
MEPA.157 The DEIR should contain a copy of this Certificate and a copy of each comment letter
received. It should include a comprehensive response to comments on the ENF that
specifically address each issue raised in the comment letter; references to a chapter or
sections of the DEIR alone are not adequate and should only be used, with reference to
specific page numbers, to support a direct response. This directive is not intended to,
and shall not be construed to, enlarge the Scope of the DEIR beyond what has been
A copy of the Certificate on the ENF, each comment letter, and responses to the
comments is provided in this Chapter.
MEPA.158 In accordance with 301 CMR 11.16, the Proponent should circulate the DEIR to each
Person or Agency who commented on the ENF, each Agency from which the project will
seek Permits, Land Transfers or Financial Assistance, and to any other Agency or Person
identified in the Scope. Pursuant to 301 CMR 11.16(5), the Proponent may circulate
copies of the DEIR to commenters in a digital format (e.g., CD-ROM, USB drive) or post
to an online website. However, the Proponent should make available a reasonable
number of hard copies to accommodate those without convenient access to a computer
to be distributed upon request on a first come, first served basis. The Proponent should
send a letter accompanying the digital copy or identifying the web address of the online
version of the DEIR indicating that hard copies are available upon request, noting
relevant comment deadlines, and appropriate addresses for submission of comments.
If submitted in hard copy, the DEIR submitted to the MEPA office should include a digital
copy of the complete document. A copy of the DEIR should be made available for review
in the Bridgewater Public Library.
Comment noted. Please see Attachment E for the Circulation List.

From: Paulson, David (FWE)
To: Patel, Purvi (EEA)
Cc: Cheeseman, Melany (FWE)
Subject: Lakeshore Center Phase 4 ENF (16558, 00-8132/019-333.DFW)
Date: Wednesday, June 8, 2022 6:56:31 AM
June 8, 2022

Bethany A. Card, Secretary
Attention: Purvi Patel, MEPA Office
100 Cambridge St.

Project Name: Lakeshore Center Phase 4
Proponent: Claremont Companies
Location: Bridgewater
Document Reviewed: Environmental Notification Form
EEA No.: 16558
NHESP No.: 00-8132/019-333.DFW

Dear Secretary Card:

The Natural Heritage & Endangered Species Program of the Massachusetts Division of Fisheries &
Wildlife (the Division) has reviewed the Environmental Notification Form for the proposed Lakeshore
Center Phase 4 Project and would like to offer the following comments regarding state-listed rare
species and their habitats.

On February 7, 2019, the Division issues a Conservation and Management Permit for the above
referenced project. The Division has recently been in consultation with the Proponent on the NHESP.01
expanded limit of work that is located to the North of Pleasant Street (Route 104). We look forward
to reviewing the MESA application for this new limit of work.

We appreciate the opportunity to comment on this project. If you have any questions about this
letter, please contact David Paulson, Senior Endangered Species Review Biologist, at (508) 389-6366
or david.paulson@state.ma.us.

David Paulson
Senior Endangered Species Review Biologist
Massachusetts Division of Fisheries & Wildlife
1 Rabbit Hill Road, Westborough, MA 01581
Temporary Phone: (845)-262-0481 | e: david.paulson@state.ma.us
mass.gov/masswildlife | facebook.com/masswildlife

THE NATURAL HERITAGE & ENDANGERED SPECIES PROGRAM OF THE MASSACHUSETTS
DIVISION OF FISHERIES & WILDLIFE
NHESP.01 On February 7, 2019, the Division issues a Conservation and Management Permit for
the above referenced project. The Division has recently been in consultation with the
Proponent on the expanded limit of work that is located to the North of Pleasant Street
(Route 104). We look forward to reviewing the MESA application for this new limit of
work
Regarding the Northern Lot within the Project Site, this area is mapped as Priority Habitat
for the aquatic plants, Plymouth Gentian (Sabatia kennedyana) and the round-fruited
seedbox (Ludwigia sphaerocarpa). The Proponent has filed a MESA Checklist with NHESP
to confirm whether or not the proposed Project will result in a take of either species.
NHESP has issued a “No-Take” letter dated November 18, 2022, which confirms that the
proposed Project will not result in a take and that no Conservation Management Permit
will be required for this portion of the Project.

June 9, 2022 The Commonwealth of Massachusetts
William Francis Galvin, Secretary of the Commonwealth
Secretary Bethany Card Massachusetts Historical Commission
Executive Office of Energy & Environmental Affairs
100 Cambridge St., Ste. 900
Boston, MA 02114
Attn.: Purvi Patel, MEPA office
RE: Claremont Companies Lakeshore Center Phase 4 Project, Bridgewater, MA.

PAL #4092. MHC #RC.2038. EEA #4959 and #16558.
Dear Secretary C~rd:
Staff of the Massachusetts Historical Commission (MHC) have reviewed the Environmental Notification
Form (ENF) submitted for the project referenced above, and the MHC's files. The ENF indicates that a
Draft Environmental Impact Report (EIR) will be prepared for the project.
The ENF accurately describes the results of previous consultation that reached agreement to develop a
Memorandum of Agreement (MOA) that outlines measures to mitigate the adverse effects to the Bassett
Site (19-PL-497 in Lot 6), and the Tomb Road A & B Site (19-PL-498 in Lot 7), two ancient Native
American archaeological sites located in the project area.
During the long history of the MEP A reviews of development proposals for this location, the MHC
received no comments about the project effects to historic and archaeological resources from members of
the public nor from any agencies.
The MHC's staff encouraged the alternatives analysis that indicated there were no prudent and feasible
alternatives to adversely affecting the two archaeological sites. The MHC's staff assisted in development
of the proposed mitigation measures for a program of archaeological data recovery that are outlined in the
MOA. The MOA stipulations prepared by MHC's staff chiefly pertain to technical issues in archaeology
to ensure that the program of archaeological data recovery is conducted to meet professional standards for
archaeology.
The MHC suggests that the alternatives analysis for Lots 6 and 7 prepared by VHB with Landvest, dated MHC.01
October 14, 2020, and a copy of the MOA be included in the Draft EIR.
The project proponent, assisted by their consultant The Public Archaeology Laboratory, Inc., continues to
consider and implement measures that involve minor project adjustments in design and specifications that
could avoid and protect particular areas of interest to Tribal Historic Preservation Officers of the Mashpee
Wampanoag Tribe and of the Wampanoag Tribe of Gay Head (Aquinnah), to the Massachusetts
Commission on Indian Affairs, and to the MHC.
The ENF includes information about an area on the north side of Pleasant Street, adjoining the present
shore of Lake Nippenicket, where a restaurant may be constructed. That part of the project area has not MHC.02
been previously surveyed for archaeological resources and may be archaeologically sensitive. The MHC
recommends that a reconnaissance archaeological survey (950 CMR 70) be conducted for the area of the
project on the n01th side of Pleasant Street. The scope of the. survey should include limited subsurface MHC.03
220 Morrissey Boulevard, Boston, Massachusetts 02125
(617) 727-8470 • Fax: (617) 727-5128
www.state.ma. us/sec/mhc
testing with a hand-held 1" soil corer and/or shovel test pits to evaluate subsurface soil conditions, and to
identify any archaeologically sensitive areas.
As always, specific archaeological site locational information and technical archaeological reports, which
are not a public record and confidential to protect fragile archaeological sites from vandalism (M.G.L. c.
9, ss. 26A & 27C), should never be included in documents prepared for public review.
These comments are offered to assist in compliance with M.G.L. c. 9, ss. 26-27C (950 CMR 70-71),
MEPA (301 CMR 11), and the terms of the MOA. If you have any questions or need any additional
information, please contact Edward L. Bell, Deputy State Historic Preservation Office and Senior
Archaeologist at the MHC.
~f~
Brana Simon
State Historic Preservation Officer
Executive Director
State Archaeologist
Massachusetts Historical Commission
xc:
Michael Shunta, Claremont Companies
Bettina Washington, Wampanoag Tribe of Gay Head (Aquinnah)
David Weeden, Mashpee Wampanoag Tribe
John A. Peters, Jr., Massachusetts Commission on Indian Affairs
Bridgewater Historical Commission
David Hewett, Epsilon Associates
Nicole Benjamin-Ma, VHB
Deborah C. Cox, PAL, attn. Duncan Ritchie
MASSACHUSETTS HISTORICAL COMMISSION
MHC.01 The MHC suggests that the alternatives analysis for Lots 6 and 7 prepared by VHB with
Landvest, dated October 14, 2020, and a copy of the MOA be included in the Draft EIR.
The MOA is provided as Attachment F.
MHC.02 The ENF includes information about an area on the north side of Pleasant Street,
adjoining the present shore of Lake Nippenicket, where a restaurant may be
constructed. That part of the project area has not been previously surveyed for
archaeological resources and may be archaeologically sensitive. The MHC recommends
that a reconnaissance archaeological survey (950 CMR 70) be conducted for the area of
the project on the north side of Pleasant Street.
sensitivity assessment of the Northern Lot. Chapter 9 provides additional information.
MHC.03 The scope of the survey should include limited subsurface testing with a hand-held 1"
soil corer and/or shovel test pits to evaluate subsurface soil conditions, and to identify
any archaeologically sensitive areas.
The survey was done per MHC requirements.

dcr
Massachusetts
0 June 10, 2022
Secretary Bethany A. Card

Attn: Purvi Patel, MEPA Office
Re: EEA#16558 – Lakeshore Center Phase 4 (Bridgewater) ENF
The Department of Conservation and Recreation (“DCR” or “the Department”) is pleased to submit the
following comments in response to the Environmental Notification Form (“ENF”) filed by the Claremont
Companies (the “Proponent”) for the Proposed Lakeshore Center Phase 4 (the “Project”) in Bridgewater.
As proposed, the Project involves activities within a 100-year floodplain as delineated on the current effective
Flood Insurance Rate Map (“FIRM”) for Plymouth County, dated July 7, 2021. In its role as the state
coordinating agency for the National Flood Insurance Program (“NFIP”), DCR submits the following
comments.
DCR's Flood Hazard Management Program (“FHMP”), under agreement with the Federal Emergency
Management Agency (“FEMA”), is the state coordinating agency for the NFIP. As such, the FHMP provides
technical assistance to communities that participate in the NFIP related directly to the program, and also
related to floodplain management in general. Communities that participate in the NFIP are required by
FEMA, as a condition of their participation, to regulate development within the 100-year floodplain in a
manner that meets or exceeds the minimum standards established by FEMA, located at 44 CFR 60.3.
Participating communities such as Bridgewater are required to adopt the NFIP requirements through locally
enforceable measures. In Massachusetts, many of the requirements contained in 44 CFR 60.3 are enforced
through existing state regulations such as the State Building Code (780 CMR) and Wetlands Protection Act
regulations (310 CMR 10.00). Communities typically adopt the remainder of the requirements as part of a
zoning ordinance or other locally enforceable measure. Bridgewater has a zoning bylaw that includes a
Floodplain District section which has been accepted by FEMA as meeting their requirements under the NFIP.
In our role as NFIP coordinator, the FHMP offers comments on the proposed Project’s relationship to many
of the above regulations and requirements. The FHMP does not administer any of these requirements and
therefore does not provide official determinations as to compliance with them; rather, our comments are
provided as an overview of the requirements and the documentation that the FHMP believes may be
necessary to demonstrate compliance with these requirements.
The Project includes construction of several buildings and other associated work. Based on information
submitted with the ENF, much of the site is located within the 100-year floodplain on the current effective
FIRM, specifically a zone A (unnumbered A zones do not include base flood elevations). Because of its
C O MM O NW E A LT H O F MA S SA C H U SE T TS · E X E C U T I VE O F F IC E OF E NE R GY & E NV IR O NME N TA L AF F A IR S
Department of Conservation and Recreation Charles D. Baker Bethany A. Card, Secretary
251 Causeway Street, Suite 600 Governor Executive Office of Energy & Environmental Affairs
Boston, MA 02114-2199
617-626-1250 617-626-1351 Fax Karyn E. Polito Stephanie C. Cooper, Acting Commissioner
www.mass.gov/dcr Lt. Governor Department of Conservation & Recreation
EEA #16558 ENF
Page 2 of 2
location in the 100-year floodplain, compliance with the requirements of several federal, state, and local
measures related to floodplain development is required.
Because unnumbered A zones do not include base flood elevations, the proponent will be required to develop DCR.01
base flood elevation information for use in this project meeting the requirements of the Wetlands Protection
Act regulations and the local floodplain regulations of Bridgewater. (See Bridgewater Zoning, Section 14.33,
b, see also NFIP regulations, 44 CFR 60.3, (b), (3).)
Additionally, projects within the 100-year floodplain involving any federal action (e.g., permit, funding) must DCR.02
also comply with federal Executive Order 11988, Floodplain Management. This executive order requires an
eight-step decision-making process which includes analysis of alternatives, avoiding impacts when possible,
and minimizing impacts when avoidance is not possible. Because this project requires a National Pollutant
Discharge Elimination System (“NPDES”) and Construction General Permit, compliance with this process
is necessary.
DCR appreciates the opportunity to comment on the ENF. If you have any questions regarding these
comments, or to request additional information or coordination with DCR, please contact Eric Carlson at
eric.carlson@mass.gov.
Sincerely,
Stephanie C. Cooper
Acting Commissioner
cc: Eric Carlson, Priscilla Geigis, Patrice Kish, Tom LaRosa

DEPARTMENT OF CONSERVATION AND RECREATION
DCR.01 Because unnumbered A zones do not include base flood elevations, the proponent will
be required to develop base flood elevation information for use in this project meeting
the requirements of the Wetlands Protection Act regulations and the local floodplain
regulations of Bridgewater. (See Bridgewater Zoning, Section 14.33, b, see also NFIP
regulations, 44 CFR 60.3, (b), (3).)
When development of the western site was completed, FEMA approval was sought to
establish a base flood elevation (BFE) for the area. That elevation was utilized when Lot 5
was developed and will be adhered to when work adjacent to the Western wetland, Lots
1 and 4, is designed. Likewise, the areas related to Lots 6 and 7 and the Northern Lot will
utilize the BFE, previously determined since flooding in this region is controlled by the
conditions along Lake Nippenicket. Section 7.2 provides additional information.
DCR.02 Additionally, projects within the 100-year floodplain involving any federal action (e.g.,
permit, funding) must also comply with federal Executive Order 11988, Floodplain
Management. This executive order requires an eight-step decision-making process
which includes analysis of alternatives, avoiding impacts when possible, and minimizing
impacts when avoidance is not possible. Because this project requires a National
Pollutant Discharge Elimination System (“NPDES”) and Construction General Permit,
compliance with this process is necessary.
The Proponent is aware of this requirement.

Commonwealth of Massachusetts
Executive Office of Energy & Environmental Affair s
Department of Environmental Protection

Southeast Regional Office• 20 Riverside Drive, Lakeville MA 02347 • 508-946-2700
Charles D. Baker Bethany A. Card

Governor Secretary
Karyn E. Polito Martin Suuberg

Lieutenant Governor Commissioner
June 14, 2022
Bethany A. Card RE: ENF Review. EOEEA #16558

Secretary of Energy and Environment BRIDGWATER Lakeshore Center Phase 4,
Executive Office of Energy and Environmental at Pleasant Street (Route 104)
Affairs
ATTN: MEPA Office
Boston, MA 02114
Dear Secretary Card,
The Southeast Regional Office of the Department of Environmental Protection (MassDEP) has reviewed
the Environmental Notification Form (ENF) for the Lakeshore Center Phase 4 Project, located at
Pleasant Street (Route 104), Bridgewater, Massachusetts (EOEEA #16558). The Project Proponent
provides the following information for the Project:
The proposed project includes new development on Lots 1, 4, 6, and 7 of the Lakeshore Center Development and
on the north side of Pleasant Street. See Figure 5 in Attachment A for a conceptual site plan. Development will
include the following components:
• A 1-story, approximately 1,800 GSF café shop on Lot 1;
• A 5-story, 150-unit assisted living facility on Lot 4;
• An 4-story, 225-unit 55+ residential community on Lot 6;
• A 4-story, 102-room hotel, and a
• 4-story, 160-unit condominium community on Lot 7; and
• A 6,000 GSF restaurant on the north side of Pleasant Street adjacent to Lake Nippenicket.
 A total of 1,083 parking spaces are proposed to accommodate the varied uses across the site.
Overall, the Project will disturb approximately 25.8 acres and create 14 acres of new impervious area. The project
has been designed to avoid directly filling wetlands. It will, however, require work within the buffer zone of
bordering vegetated wetland (BVW). As such, it will require an Order of Conditions from the Bridgewater
Conservation Commission. The project will affect some priority habitat on the north side of Pleasant Street and
also impact two known archaeological sites on Lots 6 and 7. Please refer to the Rare Species and Historical and
Archaeological Resources Sections for more detail
This information is available in alternate format. Contact Glynis Bugg at 617-348-4040.

TTY# MassRelay Service 1-800-439-2370
MassDEP Website: www.mass.gov/dep
Printed on Recycled Paper
EEA No. 16558 June 14, 2022
Bureau of Water Resources Comments

The Project Proponent has indicated that a Notice of Intent will be filed for work in the 100-foot
regulatory buffer zone to Bordering Vegetated Wetland. At the time the NOI is filed, Wetlands Program
Staff will review it, comment on the filing, and issue a DEP Wetlands File Number. The program will
review the Order of Conditions when issued to determine Project compliance with the regulatory
performance standards.
Waterways. Based on the information contained in the ENF, there does not appear to be any proposed
activities within Chapter 91 jurisdiction.
NPDES Construction General Stormwater Permit. The Project Proponent has acknowledged the need to
apply for a NPDES Stormwater Permit for Construction Permit because its construction activities are
scheduled to disturb more than an acre of land. The Proponent can access information regarding the
NPDES Stormwater requirements and an application for the Construction General Permit by completing
and submitting a Notice of Intent (NOI) to EPA via the Stormwater Discharges from Construction
Activities | National Pollutant Discharge Elimination System (NPDES) | US EPA.
The Proponent is advised to consult with Sania Kamran (Kamran.Sania@epa.gov, 617- 918-1522) for
questions regarding EPA’s NPDES Construction General Permit requirements.
In addition, the Proponent is reminded that local Planning Boards (and/or other local authorities) may MADEP.01
require stormwater controls beyond that of the Wetlands protection Act. These controls are usually
created to keep stormwater onsite so as not to create nuisance conditions offsite.
Water Management. According to the current and previous ENFs, it is anticipated that the water use for
the Lakeshore Center will be 146,862 gallons per day and will be provided by the Town of Bridgewater.
The Town of Bridgewater has the capacity to provide the requested volume for this Project based on its
renewed WMA permit issued on January 5, 2021 and its recent water use. MassDEP suggests the MADEP.02
Proponent continue evaluating and implementing conservation efforts that incorporate Best Management
Practices (BMPs) at the Project site. MassDEP also encourages Project Proponents that add additional
MADEP.03
demand to the public water system (PWS) to work with the PWS to mitigate the additional demands
proposed by the Project. The Project Proponent should also restrict irrigation use, if there is any, when MADEP.04
the Town of Bridgewater implements its nonessential outdoor water use restriction requirements.
Underground Injection Control. The Proponent is advised that the use of conveyances of stormwater
through underground stormwater infiltration structures that qualify as under the jurisdiction of the
MADEP.05
MassDEP Underground Injection Control (UIC) program must be registered with the MassDEP UIC
program through the submittal of a BRP WS-06 UIC Registration application through MassDEP’s
electronic filing system, eDEP.
The statewide UIC program contact is Joe Cerutti, who can be reached at Joseph.Cerutti@mass.gov. All
information regarding on-line (eDEP) UIC registration applications may be obtained at the following
web page under the category “Applications & Forms”: https://www.mass.gov/underground-injection-
control-uic.
Bureau of Waste Site Cleanup Comments

Based upon the information provided, the Bureau of Waste Site Cleanup (BWSC) searched its databases
for disposal sites and release notifications that have occurred at or might impact the proposed Project
EEA No. 16558 June 14, 2022
area. A disposal site is a location where there has been a release to the environment of oil and/or
hazardous material that is regulated under M.G.L. c. 21E, and the Massachusetts Contingency Plan
[MCP – 310 CMR 40.0000].
There are no listed MCP disposal sites located at or in the vicinity of the site that would appear to impact
the proposed Project area. Interested parties may view a map showing the location of BWSC disposal
sites using the MassGIS data viewer at MassMapper. Under the Available Data Layers listed on the
right sidebar, select “Regulated Areas”, and then “DEP Tier Classified 21E Sites”. MCP reports and the
compliance status of specific disposal sites may be viewed using the BWSC Waste Sites/Reportable
Release Lookup at: https://eeaonline.eea.state.ma.us/portal#!/search/wastesite
The Project Proponent is advised that if oil and/or hazardous material are identified during the
implementation of this Project, notification pursuant to the Massachusetts Contingency Plan (310 CMR
40.0000) must be made to MassDEP, if necessary. A Licensed Site Professional (LSP) should be
retained to determine if notification is required and, if need be, to render appropriate opinions. The
LSP may evaluate whether risk reduction measures are necessary if contamination is present. The
BWSC may be contacted for guidance if questions arise regarding cleanup.
Spill Prevention and Control. A spills contingency plan addressing prevention and management of MADEP.06
potential releases of oil and/or hazardous materials from pre- and post-construction activities should be
presented to workers at the site and enforced. The plan should include but not be limited to, refueling of
machinery, storage of fuels, and potential on-site activity releases.
Bureau of Air and Waste (BAW) Comments

Air Quality. Construction and operation activities shall not cause or contribute to a condition of air
MADEP.07
pollution due to dust, odor or noise. To determine the appropriate requirements please refer to:
310 CMR 7.09 Dust, Odor, Construction, and Demolition
310 CMR 7.10 Noise
Many commercial and institutional development activities have facility heating and supplemental or
emergency power generation associated with them that require air quality permitting from MassDEP
before construction and/or operation.
The determination of when a permit is required is based on the size of the proposed combustion unit.
Smaller units and specifically, engines (emergency and non-emergency), combined heat and power (CHP)
units and some boilers may not require a specific Plan Approval but are subject to performance standards
and certification, the requirements for which are found at 310 CMR 7.26.
Specifically:
 310 CMR 7.26(30) thru (37) – Boilers;
 310 CMR 7.26(40) thru (44) Engines & Turbines (including 310 CMR 7.26(42) specific to
Emergency Engines and Turbines); and
 310 CMR 7.26(45) Combined Heat and Power
Any unit that exceeds the size limit or does not meet the applicability requirements of the above listed MADEP.08
regulations will require a permit under 310 CMR 7.02.
EEA No. 16558 June 14, 2022
Construction-Related Measures
MassDEP requests that all non-road diesel equipment rated 50 horsepower or greater meet EPA’s Tier 4 MADEP.09
emission limits, which are the most stringent emission standards currently available for off-road engines.
If a piece of equipment is not available in the Tier 4 configuration, the Proponent should then use
construction equipment that has been retrofitted with appropriate emissions reduction equipment.
Emission reduction equipment includes EPA-verified, CARB-verified, or MassDEP-approved diesel
oxidation catalysts (DOCs) or Diesel Particulate Filters (DPFs). The Proponent should maintain a list of MADEP.10
the engines, their emission tiers, and, if applicable, the best available control technology installed on
each piece of equipment on file for Departmental review.
Massachusetts Idling Regulation

The Project Proponent reports “Maintaining an “idle free” work zone by providing supplemental MADEP.11
electrical equipment along with “just-in-time” delivery methods. On-site idling will be limited to five
minutes in accordance with the Massachusetts Anti Idling Law. “No Idling” signs will be posted at all
appropriate locations.
MassDEP reminds the Proponent that unnecessary idling (i.e., in excess of five minutes), with limited
exception, is not permitted during the construction and operations phase of the Project (Section 7.11 of
310 CMR 7.00). Regarding construction period activity, typical methods of reducing idling include
driver training, periodic inspections by site supervisors, and posting signage. In addition, to ensure
compliance with this regulation once the Project is occupied, MassDEP requests that the Proponent MADEP.12
install permanent signs limiting idling to five minutes or less on-site.
Backup Generators
Many industrial, commercial, and institutional development activities have facility heating and
supplemental or emergency power generation associated with them that require air quality permitting
from MassDEP before construction and/or operation.
The determination of when a permit is required is based on the size of the proposed combustion unit.
Smaller units and specifically, engines (emergency and non-emergency), combined heat and power (CHP)
units and some boilers may not require a specific Plan Approval but are subject to performance standards
and certification, the requirements for which are found at 310 CMR 7.26. Specifically:
 310 CMR 7.26(30) thru (37) – Boilers;

 310 CMR 7.26(40) thru (44) Engines & Turbines (including 310 CMR 7.26(42) specific to
Emergency Engines and Turbines); and
 310 CMR 7.26(45) Combined Heat and Power
Any unit that exceeds the size limit or does not meet the applicability requirements of the above listed
regulations will require a permit under 310 CMR 7.02.
It should be noted that should facilities operate one or more on-site back-up power generators when
there is a threat of power loss as an operational practice rather than waiting for an actual power loss,
operation of these generators under these conditions may exceed the emergency generator performance
standard requirement of 300 hours during a 12-month rolling average. It is the obligation of the facility
operator to determine which of the performance standards best fits the planned operational needs and
comply with those standards. The Business Compliance Unit of MassDEP’s Boston Office is willing to
provide assistance regarding the applicability of these generators to the regulations.
EEA No. 16558 June 14, 2022
Hazardous Waste Management. If any occupant of the Project generates hazardous waste and/or waste MADEP.13
oil, that entity must notify the MassDEP of such activity and obtain an EPA Identification number, as
applicable, in accordance with 310 CMR 30.000. Further information can be located on the
Department’s website at: http://www.mass.gov/eea/agencies/massdep/recycle/hazardous/
Solid Waste Management. The Project Proponent reports: “The contractor will take an active role with
regard to the reprocessing and recycling of construction waste. The excavation contracts will include
specific requirements to ensure construction procedures allow for the necessary segregation,
reprocessing, reuse, and recycling of materials. A Construction Waste Management Plan will be
developed to ensure that a minimal amount of waste debris is disposed of in landfills and to pursue the
goal of diverting at least 75 percent of Project-generated construction waste from landfills. For those
materials that cannot be recycled, solid waste will be transported in covered trucks to an approved solid
waste facility per the DEP Regulation for Solid Waste Facilities, 310 CMR 16.00. This requirement will
be specified in the contract documents.”
The Project Proponent is advised of the following requirements:
1. Reuse of any demolition material requires submittal of MassDEP’s BWP SW41 – Beneficial Use
Determination – Restricted Applications. The permit is intended to protect public health, safety, and
the environment by comprehensively regulating the reuse of waste materials as effective substitutes
for a commercial product or commodity. Information pertaining to this requirement is available at
https://www.mass.gov/doc/instructions-sw-39-40-41-42-beneficial-use-determinations/download.
2. Compliance with Waste Ban Regulations: Waste materials discovered during construction that are MADEP.14
determined to be solid waste (e.g., construction and demolition waste) and/or recyclable material (e.g.,
metal, asphalt, brick, and concrete) shall be disposed, recycled, and/or otherwise handled in
accordance with the Solid Waste Regulations including 310 CMR 19.017: Waste Bans. Waste Ban
regulations prohibit the disposal, transfer for disposal, or contracting for disposal of certain hazardous,
recyclable, or compostable items at solid waste facilities in Massachusetts, including, but not limited
to, metal, wood, asphalt pavement, brick, concrete, and clean gypsum wallboard. The goals of the
waste bans are to: promote reuse, waste reduction, or recycling; reduce the adverse impacts of solid
waste management on the environment; conserve capacity at existing solid waste disposal facilities;
minimize the need for construction of new solid waste disposal facilities; and support the recycling
industry by ensuring that large volumes of material are available on a consistent basis. Further
guidance can be found at: https://www.mass.gov/guides/massdep-waste-disposal-bans.
MassDEP recommends the Proponent consider source separation or separating different recyclable
materials at the job site. Source separation may lead to higher recycling rates and lower recycling costs.
Further guidance can be found at: https://recyclingworksma.com/construction-demolition-materials-
guidance/
For more information on how to prevent banned materials from entering the waste stream the
Proponent should contact the RecyclingWorks in Massachusetts program at (888) 254-5525 or via
email at info@recyclingworksma.com. RecyclingWorks in Massachusetts also provides a website that
includes a searchable database of recycling service providers, available at
http://www.recyclingworksma.com.
EEA No. 16558 June 14, 2022
3. Asphalt, brick, and concrete (ABC) rubble, such as the rubble generated by the demolition of buildings MADEP.15
or other structures must be handled in accordance with the Solid Waste regulations. These regulations
allow, and MassDEP encourages, the recycling/reuse of ABC rubble. The Proponent should refer to
MassDEP's Information Sheet, entitled " Using or Processing Asphalt Pavement, Brick and Concrete
Rubble, Updated February 27, 2017 ", that answers commonly asked questions about ABC rubble and
identifies the provisions of the solid waste regulations that pertain to recycling/reusing ABC
rubble. This policy can be found on-line at the MassDEP website:
https://www.mass.gov/files/documents/2018/03/19/abc-rubble.pdf.
4. Tree removal/land clearing/clean wood: As defined in 310 CMR 16.02, clean wood means “discarded
material consisting of trees, stumps and brush, including but limited to sawdust, chips, shavings, bark,
and new or used lumber”…etc. Clean wood does not include wood from commingled construction
and demolition waste, engineered wood products, and wood containing or likely to contain asbestos,
chemical preservatives, or paints, stains or other coatings, or adhesives. The Proponent should be
aware that wood is not allowed to be buried or disposed of at the Site pursuant to 310 CMR 16.00 &
310 CMR 19.000 unless otherwise approved by MassDEP. Clean wood may be handled in accordance
with 310 CMR 16.03(2)(c)7 which allows for the on-site processing (i.e., chipping) of wood for use
at the Site (i.e., use as landscaping material) and/or the wood to be transported to a permitted facility
(i.e., wood waste reclamation facility) or other facility that is permitted to accept and process wood.
5. Organic Waste. As of 2014, commercial organic material (defined as disposal of one ton or more per
week) has been added to the list of banned material. Please be advised that depending on the specifics
of the owner/operator at your facility, you may be subject to the commercial organic material ban if
more than one ton of commercial organic material is being disposed of from your facility per week.
The ban is one of MassDEP’s initiatives for diverting at least 35% of all food waste from disposal
statewide by 2020. Diverted food waste may be composted, converted to energy (through anaerobic
digestion), recycled, or reused. Additional information on the Commercial Food Material Disposal
Ban can be found at: https://www.mass.gov/guides/commercial-food-material-disposal-ban.
If you have any questions regarding the Solid Waste Management Program comments above, please
contact Mark Dakers at Mark.Dakers@mass.gov or Elza Bystrom at Elza.Bystrom@mass.gov.
Farmland Conversion to Commercial Use

The Proponent should demonstrate, if the land in agricultural use has benefited from the tax savings
MADEP.16
provided by Massachusetts General Law, Chapter 61A ASSESSMENT AND TAXATION OF
AGRICULTURAL AND HORTICULTURAL LAND and has met its obligations under Section 13:
Change of use: Liability for roll-back taxes. The Proponent should also demonstrate, as required under MADEP.17
Section 17 of this statute, that prior to the sale of this property that a notice of intent to the town of
Acushnet was given for its first rights of refusal to purchase the land prior to its proposed non-
agricultural use. If the United States Department of Agriculture Natural Resources Conservation Service
has provided technical assistance to the farm that has certain contractual obligations, the Proponent must MADEP.18
demonstrate that those contract conditions have been met prior to the conversion of this farmland to its
proposed nonagricultural use.
Climate Change
Greenhouse Gas Emissions Green House Gas Mitigation. To offset the energy usage of the Project, the MADEP.19
Proponent is encouraged to consider photovoltaics on the building roof and other locations, possibly
with energy storage. Project Proponents are advised of the incentives now available through the Solar
EEA No. 16558 June 14, 2022
Massachusetts Renewable Target (SMART) program: https://www.mass.gov/solar-massachusetts-

renewable-targetsmart. Those who enroll in SMART benefit from not only from the tax credit for
photovoltaic installation but also from long-term electric utility savings and income for the power not
used from its photovoltaics – while at the same time contributing to support the Commonwealth’s
NetZero carbon emission’s goal by 2050 https://www.mass.gov/info-details/ma-decarbonization-
roadmap.
Proposed s.61 Findings

The “Certificate of the Secretary of Energy and Environmental Affairs on the Environmental
Notification Form” may indicate that this Project requires further MEPA review and the preparation of
an Environmental Impact Report. Pursuant to MEPA Regulations 301 CMR 11.12(5)(d), the Proponent MADEP.20
will prepare Proposed Section 61 Findings to be included in the EIR in a separate chapter updating and
summarizing proposed mitigation measures. In accordance with 301 CMR 11.07(6)(k), this chapter
should also include separate updated draft Section 61 Findings for each State agency that will issue
permits for the Project. The draft Section 61 Findings should contain clear commitments to implement
mitigation measures, estimate the individual costs of each proposed measure, identify the parties
responsible for implementation, and contain a schedule for implementation.
The MassDEP Southeast Regional Office appreciates the opportunity to comment on this proposed
Project. If you have any questions regarding these comments, please contact George Zoto at
George.Zoto@mass.gov or Jonathan Hobill at Jonathan.Hobill@mass.gov.
Very truly yours,
Jonathan E. Hobill,
Regional Engineer,
Bureau of Water Resources
JH/GZ
Cc: DEP/SERO
ATTN: Millie Garcia-Serrano, Regional Director

Gerard Martin, Deputy Regional Director, BWR
Seth Pickering, Deputy Regional Director, BAW
John Handrahan, Acting Deputy Regional Director, BWSC
Jennifer Viveiros, Deputy Regional Director, ADMIN
Dan Gilmore, Chief, Wetlands and Waterways, BWR
Brendan Mullaney, Waterways, BAW
Carlos Fragata, Waterways, BAW
Duane LeVangie, Chief, Water Management Act, BWR/Boston
Shi Chen, Water Management Act, BWR/Boston
Joseph Cerutti, Underground Injection Control Program, BWR/Boston
Mark Dakers, Chief, Solid Waste Management, BAW
Elza Bystrom, Solid Waste Management, BAW
Allen Hemberger, Site Management, BWSC
SOUTHEST REGIONAL OFFICE OF THE DEPARTMENT OF ENVIRONMENTAL PROTECTION
MADEP.01 In addition, the Proponent is reminded that local Planning Boards (and/or other local
authorities) may require stormwater controls beyond that of the Wetlands protection
Act. These controls are usually created to keep stormwater onsite so as not to create
nuisance conditions offsite
Comment noted. The design and construction of the Lots will be done in compliance with
the NPDES, the Massachusetts DEP Stormwater Management Regulations, and with local
requirements of the Town of Bridgewater.
MADEP.02 The Town of Bridgewater has the capacity to provide the requested volume for this
Project based on its renewed WMA permit issued on January 5, 2021 and its recent
water use. MassDEP suggests the Proponent continue evaluating and implementing
conservation efforts that incorporate Best Management Practices (BMPs) at the Project
site.
Comment noted. Water quality mitigation using various Best Management Practices
(BMPs) are identified to achieve compliance with Massachusetts Stormwater
Management Standards and protect the wetland resource areas and the drinking water
aquifer of the neighboring Town of Raynham.
MADEP.03 MassDEP also encourages Project Proponents that add additional demand to the public
water system (PWS) to work with the PWS to mitigate the additional demands
proposed by the Project.
Each Lot will be reviewed with the Town of Bridgewater during the permitting approval
process to ensure that adequate public water services are available to support the Project
post-construction.
MADEP.04 The Project Proponent should also restrict irrigation use, if there is any, when the Town
of Bridgewater implements its nonessential outdoor water use restriction
requirements.
The Proponent will comply with all local regulations regarding water use restrictions. All
water for irrigation systems will be provided by local onsite irrigation wells.
MADEP.05 The Proponent is advised that the use of conveyances of stormwater through
underground stormwater infiltration structures that qualify as under the jurisdiction of
the MassDEP Underground Injection Control (UIC) program must be registered with the

MassDEP UIC program through the submittal of a BRP WS-06 UIC Registration
application through MassDEP’s electronic filing system, eDEP.
The design and construction of the individual sites will be done in compliance with the
NPDES, the Massachusetts DEP Stormwater Management Regulations, and with local
requirements of the Town of Bridgewater. Underground infiltration is not proposed.
MADEP.06 A spills contingency plan addressing prevention and management of potential releases
of oil and/or hazardous materials from pre- and post-construction activities should be
presented to workers at the site and enforced. The plan should include but not be
limited to, refueling of machinery, storage of fuels, and potential on-site activity
releases.
implemented to ensure that any release of fuel (i.e., oil or gas) is managed quickly and
efficiently. This plan is incorporated into the Draft SWPPP. Section 7.3.11 provides
MADEP.07 Construction and operation activities shall not cause or contribute to a condition of air
pollution due to dust, odor or noise. To determine the appropriate requirements please
refer to: 310 CMR 7.09 Dust, Odor, Construction, and Demolition; 310 CMR 7.10 Noise.
All construction and demolition (C&D) activities will be managed in accordance with
applicable MassDEP’s regulations regarding Air Pollution Control (310 CMR 7.01, 7.09-
7.10), and Solid Waste Facilities (310 CMR 16.00 and 310 CMR 19.00, including the waste
ban provision at 310 CMR 19.017) and that all C&D activities shall be undertaken in
compliance with the conditions of all State and local permits. Please refer to Chapter 12
for additional information.
MADEP.08 Any unit that exceeds the size limit or does not meet the applicability requirements of
the above listed regulations will require a permit under 310 CMR 7.02.
Comment noted. If applicable, a permit will be obtained.
MADEP.09 MassDEP requests that all non-road diesel equipment rated 50 horsepower or greater
meet EPA’s Tier 4 emission limits, which are the most stringent emission standards
currently available for off-road engines. If a piece of equipment is not available in the
Tier 4 configuration, the Proponent should then use construction equipment that has
been retrofitted with appropriate emissions reduction equipment. Emission reduction
equipment includes EPA-verified, CARB-verified, or MassDEP-approved diesel oxidation
catalysts (DOCs) or Diesel Particulate Filters (DPFs).
The Proponent will investigate compliance with MassDEP’s Diesel Retrofit Program and
will comply with requirements for the use of ultra-low sulfur diesel (ULSD) in off-road
engines. The Program encourages users of diesel construction equipment to install

exhaust emission controls such as oxidation catalysts or particulate filters on their diesel
engines.
MADEP.10 The Proponent should maintain a list of the engines, their emission tiers, and, if
applicable, the best available control technology installed on each piece of equipment
on file for Departmental review.
Comment noted.
MADEP.11 The Project Proponent reports “Maintaining an “idle free” work zone by providing
supplemental electrical equipment along with “just-in-time” delivery methods. On-site
idling will be limited to five minutes in accordance with the Massachusetts Anti Idling
Law. “No Idling” signs will be posted at all appropriate locations.
Comment noted. Specific measures to be taken to reduce diesel emissions and other
construction related air quality impacts. Please refer to Chapter 12 for additional
information.
MADEP.12 Regarding construction period activity, typical methods of reducing idling include driver
training, periodic inspections by site supervisors, and posting signage. In addition, to
ensure compliance with this regulation once the Project is occupied, MassDEP requests
that the Proponent install permanent signs limiting idling to five minutes or less on-site.
Comment noted. “Do Not Idle” signs will be posted at appropriate locations. Please refer
to Chapter 12 for additional information.
MADEP.13 If any occupant of the Project generates hazardous waste and/or waste oil, that entity
must notify the MassDEP of such activity and obtain an EPA Identification number, as
applicable, in accordance with 310 CMR 30.000.
Comment noted. If applicable, the MassDEP will be contacted to obtain an EPA

Identification number.
MADEP.14 Waste materials discovered during construction that are determined to be solid waste
(e.g., construction and demolition waste) and/or recyclable material (e.g., metal,
asphalt, brick, and concrete) shall be disposed, recycled, and/or otherwise handled in
accordance with the Solid Waste Regulations including 310 CMR 19.017: Waste Bans.
The Proponent will take an active role with regard to the reprocessing and recycling of
construction waste, and construction and demolition recycling (C&D) will be a sustainable
measure for the Project. A construction and demolition waste management plan will be
prepared, which will establish waste diversion goals, specify commingled versus site
separated strategies, and describe where the material will be taken and how the recycling
facility will process the material.

MADEP.15 Asphalt, brick, and concrete (ABC) rubble, such as the rubble generated by the
demolition of buildings or other structures must be handled in accordance with the
Solid Waste regulations. These regulations allow, and MassDEP encourages, the
recycling/reuse of ABC rubble. The Proponent should refer to MassDEP's Information
Sheet, entitled "Using or Processing Asphalt Pavement, Brick and Concrete Rubble,
Updated February 27, 2017", that answers commonly asked questions about ABC
rubble and identifies the provisions of the solid waste regulations that pertain to
recycling/reusing ABC rubble.
The Proponent is aware of these regulations and will comply with them.
MADEP.16 The Proponent should demonstrate, if the land in agricultural use has benefited from
the tax savings provided by Massachusetts General Law, Chapter 61A ASSESSMENT AND
TAXATION OF AGRICULTURAL AND HORTICULTURAL LAND and has met its obligations
under Section 13: Change of use: Liability for roll-back taxes.
MADEP.17 The Proponent should also demonstrate, as required under Section 17 of this statute,
that prior to the sale of this property that a notice of intent to the town of Acushnet
was given for its first rights of refusal to purchase the land prior to its proposed non-
agricultural use.
MADEP.18 If the United States Department of Agriculture Natural Resources Conservation Service
has provided technical assistance to the farm that has certain contractual obligations,
the Proponent must demonstrate that those contract conditions have been met prior
to the conversion of this farmland to its proposed nonagricultural use.
USDA has not provided technical assistance so this is not applicable.
MADEP.19 To offset the energy usage of the Project, the Proponent is encouraged to consider
photovoltaics on the building roof and other locations, possibly with energy storage.
The design team has evaluated potential locations for the opportunity to install PV arrays.
Due to competing space requirements of the mechanical systems, unencumbered roof
space is limited. PV-ready zones will be provided as required by code, a minimum of 40%
of the roof area. As design progresses, the design team will endeavor to group mechanical
equipment in order to maximize the PV-ready zone on each building’s roof. The size of
this PV-ready area will be determined as design progresses.

MADEP.20 Pursuant to MEPA Regulations 301 CMR 11.12(5)(d), the Proponent will prepare
Proposed Section 61 Findings to be included in the EIR in a separate chapter updating
and summarizing proposed mitigation measures. In accordance with 301 CMR
11.07(6)(k), this chapter should also include separate updated draft Section 61 Findings
for each State agency that will issue permits for the Project. The draft Section 61
Findings should contain clear commitments to implement mitigation measures,
estimate the individual costs of each proposed measure, identify the parties responsible
for implementation, and contain a schedule for implementation.
A Draft Section 61 Finding is included in Chapter 13.

Charles D . Baker, Governor
Karyn E. Polito, Lieutenant Governor
Jamey Tesler, Secretary & CEO
massDOT
Massachusetts Department of Transportation
June 15, 2022
Bethany A. Card, Secretary

Boston, MA 02114-2150
RE: Bridgewater – Lakeshore Center Phase IV

(EEA #16558)
ATTN: MEPA Unit

Purvi Patel
On behalf of the Massachusetts Department of Transportation, I am submitting comments

regarding the Environmental Notification Form filed for the proposed Lakeshore Center Phase IV
project located in Bridgewater as prepared by the Office of Transportation Planning. If you have
any questions regarding these comments, please contact J. Lionel Lucien, P.E., Manager of the
Public/Private Development Unit, at (857) 368-8862.
Sincerely,
David J. Mohler
Executive Director
Office of Transportation Planning
DJM/jll
Ten Park Plaza, Suite 4160, Boston, MA 02116

Tel: 857-368-4636, TTY: 857-368-0655
www.mass.gov/massdot
Bridgewater – Lakeshore Center Page 2 6/15/2022
cc: Jonathan Gulliver, Administrator, Highway Division

Carrie Lavallee, P.E., Chief Engineer, Highway Division
Mary-Joe Perry, District 5 Highway Director
Neil Boudreau, Assistant Administrator of Traffic and Highway Safety
Southeastern Regional Planning and Economic Development District (SRPEDD)
Planning Board, Town of Bridgewater
Charles D . Baker, Governor
Karyn E. Polito, Lieutenant Governor
Jamey Tesler, Secretary & CEO
massDOT
Massachusetts Department of Transportation
MEMORANDUM
TO: David J. Mohler, Executive Director

Office of Transportation Planning
FROM: J. Lionel Lucien, P.E., Manager

Public/Private Development Unit
DATE: June 15, 2022
RE: Bridgewater – Lakeshore Center Phase 4

(EEA #16558)
The Public/Private Development Unit (PPDU) has reviewed the Environmental

Notification Form (ENF) for the Lakeshore Center Phase 4 (the “Project”) on Pleasant Street
(Route 104) in Bridgewater submitted by the Claremont Companies (the “Proponent”). The
approximately 62.7-acre Project Site is located within the 127.5-acre Lakeshore Center
Development off of Pleasant Street (Route 104) in Bridgewater. The Project Site is bounded
to the north by Route 104 and Lake Nippenicket, to the east by a Commonwealth of
Massachusetts Salvage Inspection lot and Route 24, to the south by the Route 24 southbound
to Route 495 northbound ramp and a rest stop, and to the west by Route 495 and Route
104/North Main Street.
The existing Lakeshore Center development comprises of a mix of uses. A 4-building,

289-unit residential complex and 574 associated parking spaces occupy the western section.
Within the central portion of the Site, there is a 96-room, 4-story hotel with 103 parking
spaces on Lot 1; an approximately 77,000 Gross Square Feet (GSF), 3-story office building
with 237 parking spaces on Lot 2; an approximately 65,000 GSF, 4-story office building with
227 parking spaces on Lot 3; and a 300-unit, 5-story apartment complex with 600 parking
spaces on Lot 5. An approximately 100,000 GSF flex space warehouse with 162 parking
spaces and 27 loading docks is located in the eastern section on Lot 8. The most recent filing
was a Final Supplemental EIR that was filed on October 31, 2018. On December 28, 2018, the
Secretary issued a Certificate finding that the FSEIR adequately and properly complied with
MEPA.
The proposed Project includes new development on Lots 1, 4, 6, and 7 of the

Lakeshore Center Development and on the north side of Route 104. Lots 1 and 4 are in the
Central portion of the Lakeshore Development on the west side of the Lakeshore Center
central access road. Lots 6 and 7 are on the east side of the central access road and are
currently unimproved. Lots 6 and 7 are constrained for development by wetlands located on
their eastern side.
The development program will include the following components:

• A 1-story, approximately 1,800-sf café shop on Lot 1;
Ten Park Plaza, Suite 4160, Boston, MA 02116
Tel: 857-368-4636, TTY: 857-368-0655
www.mass.gov/massdot

• A 4-story, 225-unit 55+ residential community on Lot 6;
• A 4-story, 102-room hotel, and a 4-story, 160-unit condominium community on Lot
7; and
• A 6,000-sf restaurant on the north side of Pleasant Street adjacent to Lake
Nippenicket.
According to the ENF, the Project is expected to generate a total of 4,262 unadjusted
daily vehicle trips in accordance with the Institute of Transportation Engineers (ITE) Trip
Generation Manual, utilizing Land Use Code (LUC) 251: Senior Adult Housing (Single
Family), LUC 252: Senior Adult Housing (Multi-family), LUC 254: Assisted Living, LUC
310: Hotel, LUC 931: High Turnover (Sit-Down) Restaurant, and LUC 937: Coffee/Donut
Shop with Drive-Through Window. This estimated trip generation represents an increase over
the existing commercial and residential uses present at the Project site. A total of 1,083
parking spaces are proposed to accommodate the varied uses across the site.
The Project exceeds MEPA thresholds for the preparation of an Environmental Impact
Review (EIR) due to transportation impacts per 301 CMR 11.03(6). The Project additionally
requires an EIR per 301 CMR 11.06(7)(b) as a project within the Designated Geographic Area
surrounding an Environmental Justice Population. The Project requires a Vehicular Access
Permit from MassDOT as the Project Site abuts I-495 and Route 24 and Project development
is anticipated to result in significant impacts on Route 24, a state jurisdictional roadway.
Scope of Work
The Draft EIR (DEIR) should include a Transportation Impact Analysis (TIA) MADOT.01
developed in accordance with MassDOT/EOEEA’s Transportation Impact Assessment
Guidelines. The study should include a comprehensive assessment of the transportation
impacts of the project. The TIA should provide capacity analyses of existing conditions,
future No-Build conditions, and future Build conditions, particularly at state highway
locations. The future Build conditions should include an analysis of operations both with and
without any improvements suggested to mitigate project impacts. The study should propose an
integrated multimodal mitigation package intended to improve vehicular traffic operations
while supporting increased use of walking, bicycling, and transit by employees and residents.
Trip Distribution
The TIA should provide a trip distribution for the project based on a gravity model or MADOT.02
distance to determine trip characteristics for visitors and employees of the Project. The DEIR
should provide all appropriate back up documentation to verify how the different percentages
are calculated and assigned to the roadway network and the transit system.
Study Area and Scope
The TIA should include analysis of intersections and roadways where site traffic MADOT.03
exceeds 100 vehicle trips per hour or 5% of existing volume. In the ENF, the Proponent
proposes the following intersections to be included in the TIA study area:
• Route 24 Northbound ramps/Route 104;

• Route 24 Southbound ramps/Route 104;
• Route 104 at Lakeside Drive/Fruit Street;
• Route 104 at Old Pleasant Street;
• Route 104 at Lakeshore Center Drive;
• Route 104 at Residence Inn Driveway;
• Route 104 at North Main Street (Route 104);
• Route 104 at the site driveways
Traffic Count Data
The TIA should address the atypical traffic conditions resulting from the COVID-19 MADOT.04
virus pandemic and follow the MassDOT’s Guidance on Traffic Count Data, as detailed in the
Engineering Directive number E-20-005, issued by the Chief Engineer on May 11, 2020,
which allows for the use of historical traffic data (no older than 2014) on any project to
supplement and/or replace existing traffic counts. The Proponent should consult with the MADOT.05
Highway Division Traffic and Safety Section on the most recent updates of the MassDOT
guidance on traffic count data.
Safety
The TIA should include crash analyses for all intersections in the study area using the MADOT.06
MassDOT crash database for the most recent five years of accepted/available data. The study
area intersections that are identified as Highway Safety Improvement Program (HSIP) clusters MADOT.07
should be reviewed to determine whether Road Safety Audits (RSAs) are required or if any
further actions may be taken to improve safety. Additionally, the Route 104 study corridor MADOT.08
should be reviewed in the MassDOT Impact portal and specifically look at the crash based
and risk-based screening tools. The mitigation proposed should reduce the number of crashes
along high crash corridors as well as address any risks identified.
Traffic Operations
The TIA should include operational analysis of existing traffic conditions at the MADOT.09
intersections and roadways included in the study area as identified above. The TIA should MADOT.10
include capacity analyses for the weekday morning and evening peak hours for both existing
and future conditions for the Project. In addition, capacity analyses for Build with mitigation MADOT.11
conditions should be provided for all intersections, particularly those with impacts to the state
highway system. Of particular concern is the operation of the Route 24 interchange with
Route 104.
The TIA should provide illustrations depicting the peak hour 50th (average) and 95th MADOT.12
intersection, for all analysis scenarios. The information contained in these illustrations should
clearly demonstrate that the Project would not result in any extended queues that would block
vehicle movements to/from study area intersections, particularly those involving state
highways. The analysis should include queue length to demonstrate that the Project would not
result in queues extending to the Route 24 mainline. Appropriate mitigation should be MADOT.13
identified if necessary to address this concern.
Multimodal Access Accommodations
The TIA should provide an inventory of existing sidewalks and crosswalks within the MADOT.14
study area and should address the quality and condition of those facilities. The TIA should MADOT.15
include a commitment to improvements in any areas that are structurally deficient or not
meeting current codes for accessibility, including sidewalks, crosswalks, ramps, and
pedestrian equipment. Special attention should be given to linking the proposed development MADOT.16
to adjacent complementary land uses and transit facilities.
The TIA should include a detailed inventory of the bicycle network to include bikeway MADOT.17
types, bikeway widths, and bicycle volumes and speeds. The Proponent should identify the MADOT.18
likely travel routes for bicyclists within the study area. The degree to which these routes can
safely support bicycle travel should also be examined. The TIA should reevaluate these routes MADOT.19
based on the origin-destination of potential employees and visitors. Based on this analysis, the
MADOT.20
Proponent should consider the feasibility of expanding some of these existing routes or
considering new routes to encourage bicycle travel in and around the site.
The Project is not located within an area currently served by transit. The Proponent
MADOT.21
Regional Transit Authority regarding the feasibility of extending transit services to the site. MADOT.22
Additionally, the Proponent should consult with the Council on Aging for potential services to
the elderly population of the Project.
Parking
According to the ENF, the Project would include the provision of 1,083 parking
spaces. The TIA should explain the methodology used to determine the total parking required. MADOT.23
The ITE Parking Generation Manual (5th Edition) generally provides a reasonable basis for
comparison to parking requirements under local zoning. The TIA should include a summary MADOT.24
of parking need and supply for comparable facilities based on multiple data sources. The TIA MADOT.25
should also determine the number of parking spaces occupied at various times of day and
identify periods of peak use. The Proponent should seek opportunities to share parking with MADOT.26
the existing uses on site.
Transportation Demand Management
The DEIR should include a detailed Transportation Demand Management (TDM) MADOT.27
program intended to reduce single-occupancy vehicle trips to the Project site. MassDOT
defers substantive commentary on proposed TDM measures until analysis of traffic impact is
completed in the TIA.
The DEIR should include sufficiently detailed conceptual plans (minimum of 80-
scale) for proposed roadway improvements to verify the feasibility of constructing such MADOT.28
improvements. These plans should clearly show proposed lane widths and offsets, layout lines MADOT.29
and jurisdictions, and land uses adjacent to areas where improvements are proposed. All
MADOT.30
proposed roadway signage and lighting must comply with MUTCD standards.
Transportation Monitoring Program
The Proponent will be required to conduct an annual Traffic Monitoring Program MADOT.31
(TMP) for a period of five years, beginning six months after occupancy of the full-build
project. The TMP will include:
• Simultaneous automatic traffic recorder (ATR) counts at each site driveway for a
continuous 24-hour period on a typical weekday;
• Travel survey of employees and patrons at the site (to be administered by the
Transportation Coordinator);
• Weekday AM and PM and Saturday peak hour turning movement counts (TMCs)
and operations analysis at “mitigated” intersections, including those involving site
driveways, and;
• Transit Ridership counts.
The goals of the monitoring program will be to evaluate the assumptions made in the
DEIR and the adequacy of the mitigation measures, as well as to determine the effectiveness
of the TDM program.
Section 61 Finding
The DEIR should include a Draft Section 61 Finding, outlining the mitigation MADOT.32
measures the Proponent has committed to implementing in conjunction with this project. The
Draft Section 61 Finding will be the basis for MassDOT to issue a final Section 61 Finding for
the project.
The Proponent should continue consultation with appropriate MassDOT units,

including PPDU, Traffic Operations, and the District 5 Office during the preparation of the MADOT.33
DEIR for the project. If you have any questions regarding these comments, please contact me
at Lionel.Lucien@dot.state.ma.us.
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
MADOT.01 The Draft EIR (DEIR) should include a Transportation Impact Analysis (TIA) developed in
accordance with MassDOT/EOEEA’s Transportation Impact Assessment Guidelines. The
study should include a comprehensive assessment of the transportation impacts of the
project. The TIA should provide capacity analyses of existing conditions, future No-Build
conditions, and future Build conditions, particularly at state highway locations. The
future Build conditions should include an analysis of operations both with and without
any improvements suggested to mitigate project impacts. The study should propose an
integrated multimodal mitigation package intended to improve vehicular traffic
operations while supporting increased use of walking, bicycling, and transit by
employees and residents.
Please see the comprehensive discussion of transportation impacts in Chapter 4.
MADOT.02 The TIA should provide a trip distribution for the project based on a gravity model or
distance to determine trip characteristics for visitors and employees of the Project. The
DEIR should provide all appropriate back up documentation to verify how the different
percentages are calculated and assigned to the roadway network and the transit
system.

Bridgewater. See Section 4.5.2 for additional information on the anticipated trip
distribution and Attachment A for the data used to create these estimates.
MADOT.03 The TIA should include analysis of intersections and roadways where site traffic exceeds
100 vehicle trips per hour or 5% of existing volume.
The study area intersection include:
♦ Pleasant Street/North Main Street (Route 104) at Elm Street East
♦ Pleasant Street (Route 104) at Residence Inn Driveway
♦ Pleasant Street (Route 104) at Lakeshore Center
♦ Pleasant Street (Route 104) at Old Pleasant Street
♦ Pleasant Street (Route 104) at Lakeside Drive/Fruit Street
♦ Pleasant Street (Route 104) at Route 24 Southbound Ramps

♦ Pleasant Street (Route 104) at Route 24 Northbound Ramps
Additional site traffic is not anticipated to exceed the 5% threshold of intersections

outside those listed above and included in the DEIR.
MADOT.04 The TIA should address the atypical traffic conditions resulting from the COVID-19 virus
pandemic and follow the MassDOT’s Guidance on Traffic Count Data, as detailed in the
Engineering Directive number E-20-005, issued by the Chief Engineer on May 11, 2020,
which allows for the use of historical traffic data (no older than 2014) on any project to
supplement and/or replace existing traffic counts.
Since the receipt of this comment, Engineering Directive E-20-005 has been replaced with
Engineering Directive E-22-003 which notes an update to the Traffic and Safety
Engineering 25% Design Submission Guidelines and the Traffic Volume guidance. The new
guidelines from MassDOT indicate that traffic count data collected on or after March 1,
2022 is not subject to COVID-19 adjustments. The traffic counts for the Project were
conducted in April 2022; therefore, no COVID-19 adjustment was applied. Please refer to
Section 4.3.5 for additional information.
MADOT.05 The Proponent should consult with the Highway Division Traffic and Safety Section on
the most recent updates of the MassDOT guidance on traffic count data.
McMahon has followed the most recent MassDOT guidance regarding traffic count data.
MADOT.06 The TIA should include crash analyses for all intersections in the study area using the
MassDOT crash database for the most recent five years of accepted/available data.
understand the existing safety operations of the study area intersections. This included a
review of crash data from 2015 through 2019. A summary of the crash data is presented
in Attachment A. Please refer to Section 4.3.7 for additional information.
MADOT.07 The study area intersections that are identified as Highway Safety Improvement
Program (HSIP) clusters should be reviewed to determine whether Road Safety Audits
(RSAs) are required or if any further actions may be taken to improve safety.
None of the study area intersections are listed as a Highway Safety Improvement Plan
(HSIP) cluster. Please refer to Section 4.3.7 for additional information.
MADOT.08 Additionally, the Route 104 study corridor should be reviewed in the MassDOT Impact
portal and specifically look at the crash based and risk-based screening tools. The
mitigation proposed should reduce the number of crashes along high crash corridors as
well as address any risks identified.

The Route 104 corridor was reviewed in the MassDOT Impact Portal utilizing the crash
based and risk-based screening tools. Utilizing the crash-based and risk-based screening
tools, the Pleasant Street (Route 104) corridor within the study area is not shown to be
primary risk roadway for crashes. Please refer to Section 4.3.7 and Table 4-3 for additional
information.
MADOT.09 The TIA should include operational analysis of existing traffic conditions at the
intersections and roadways included in the study area as identified above.
McMahon Associates conducted an analysis of existing traffic conditions as part of the

TIA. Section 4.3 provides additional information.
MADOT.10 The TIA should include capacity analyses for the weekday morning and evening peak
hours for both existing and future conditions for the Project
The Synchro capacity analysis results of the study area intersections for the weekday
morning and weekday afternoon peak hours under the 2022 Existing conditions are
summarized in Table 4-4, under the 2029 No Build conditions are summarized in Table 4-
5, and under the 2029 Build conditions are summarized in Table 4-7. A more detailed
summary of the capacity analysis for each study area intersection and queue graphics are
provided in Attachment A.
MADOT.11 In addition, capacity analyses for Build with mitigation conditions should be provided
for all intersections, particularly those with impacts to the state highway system. Of
particular concern is the operation of the Route 24 interchange with Route 104.
Based on the results of the capacity analysis, mitigation to address vehicular operations
is not proposed. Please refer to Section 4.5.3 for the 2029 Build Capacity Analysis.
MADOT.12 The TIA should provide illustrations depicting the peak hour 50th (average) and 95th
intersection, for all analysis scenarios. The information contained in these illustrations
should clearly demonstrate that the Project would not result in any extended queues
that would block vehicle movements to/from study area intersections, particularly
those involving state highways. The analysis should include queue length to
demonstrate that the Project would not result in queues extending to the Route 24
mainline.
and future conditions are included in Attachment A. The queues demonstrate that the
Project would not result in any extended queues that would block vehicle movements
to/from the study area intersections including the state highways, including the Route 24
mainline under the existing and future conditions analyzed. Section 4.5.3 provides

MADOT.13 Appropriate mitigation should be identified if necessary to address this concern.
Based on the queueing results in the capacity analysis, mitigation is not proposed as part
of the Project.
MADOT.14 The TIA should provide an inventory of existing sidewalks and crosswalks within the
study area and should address the quality and condition of those facilities.
McMahon conducted an inventory of existing sidewalks and crosswalks within the study
area. Please refer to Sections 4.3.1 and 4.3.6 for additional information.
MADOT.15 The TIA should include a commitment to improvements in any areas that are
structurally deficient or not meeting current codes for accessibility, including sidewalks,
crosswalks, ramps, and pedestrian equipment.
To provide enhanced pedestrian infrastructure within the study area, mitigation has been
proposed to support the increase in walking, bicycling, and transit by employees and
residents. Please refer to Section 4.6 for additional information.
MADOT.16 Special attention should be given to linking the proposed development to adjacent
complementary land uses and transit facilities.
To provide enhanced pedestrian infrastructure within the study area to connect to the
existing pedestrian network, mitigation has been proposed and is outlined in Section 4.6.
No existing transit services and limited complementary land uses are located within close
proximity of the Project Site.
MADOT.17 The TIA should include a detailed inventory of the bicycle network to include bikeway
types, bikeway widths, and bicycle volumes and speeds.
McMahon conducted an inventory of the bicycle network within the study area. No
bicycles were recorded during the data collection conducted for the project; therefore,
no bicycle volumes or speeds are available to review. Refer to Section 4.3.6 for
information on the inventory of the multimodal access accommodations in the study area
and Section 4.3.4 for additional information on the traffic volume data.
MADOT.18 The Proponent should identify the likely travel routes for bicyclists within the study
area. The degree to which these routes can safely support bicycle travel should also be
examined.

MADOT.19 The TIA should reevaluate these routes based on the origin-destination of potential
employees and visitors.
MADOT.20 Based on this analysis, the Proponent should consider the feasibility of expanding some
of these existing routes or considering new routes to encourage bicycle travel in and
around the site.
Dedicated bicycle infrastructure is not currently present directly within the project study
area. However, bicycle lanes on North Main Street, south of the Raynham town line, have
been striped within the shoulders. Similar width shoulders currently exist along Pleasant
Street (Route 104) within the study area. The project is proposing to maintain those
shoulders to allow for the existing occasional bicycle travel by not proposing any
additional turn lanes for vehicular travel along that segment of Pleasant Street Route 104.
Section 4.5.4 provides additional information.
MADOT.21 The Project is not located within an area currently served by transit. The Proponent
Regional Transit Authority regarding the feasibility of extending transit services to the
site.
McMahon contacted the Greater Attleboro Taunton Regional Transit Authority (GATRA)
and Brockton Area Transit Authority (BAT) to determine potential multimodal service
near the project site. McMahon had a meeting with BAT on November 14, 2022 to discuss
potential connections. No conversations have been made with GATRA as of December 2,
2022. An overview of the meeting is provided in Section 4.3.6.
MADOT.22 Additionally, the Proponent should consult with the Council on Aging for potential
services to the elderly population of the Project.
The Project team will coordinate with the Council on Aging during the local permitting
process for the Project once more details of development have been identified.
MADOT.23 According to the ENF, the Project would include the provision of 1,083 parking spaces.
The TIA should explain the methodology used to determine the total parking required.
The ITE Parking Generation Manual (5th Edition) generally provides a reasonable basis
for comparison to parking requirements under local zoning.
Please refer to Table 2-3 which presents a summary of the proposed parking program
compared to that required by local zoning. The Proponent is proposing to initially bank
260 spaces being proposed and not construct them unless they are found to be needed
once the project is fully occupied.

MADOT.24 The TIA should include a summary of parking need and supply for comparable facilities
based on multiple data sources.
The parking program proposed is based upon a number of factors, including the
Proponent’s extensive experience at the Project site, industry standards, and zoning. The
amount proposed is the minimum that the Proponent believes is needed to satisfactorily
service the proposed development. Note that the Proponent is proposing to initially bank
260 spaces and will not construct those spaces unless it found to be required based on
full operations.
MADOT.25 The TIA should also determine the number of parking spaces occupied at various times
of day and identify periods of peak use.
Peak parking use will be in the evenings when guests of the proposed hotel, and residents
of the condominiums, 55+ building are present. Section 2.2.3 discusses the potential for
shared parking among the different uses on the site.
MADOT.26 The Proponent should seek opportunities to share parking with the existing uses on site.
The Proponent considered using shared surface parking among the various uses on the
different lots but been found it to be impractical. Please see Section 2.2.3.
MADOT.27 The DEIR should include a detailed Transportation Demand Management (TDM)
program intended to reduce single-occupancy vehicle trips to the Project site. MassDOT
defers substantive commentary on proposed TDM measures until analysis of traffic
impact is completed in the TIA.
The proposed Project will implement a Transportation Demand Management (TDM) to

encourage the use of alternative modes of transportation to reduce single occupancy
vehicles (SOV) trips to the site. Section 4.6 provides additional information.
MADOT.28 The DEIR should include sufficiently detailed conceptual plans (minimum of 80- scale)
for proposed roadway improvements to verify the feasibility of constructing such
improvements.
Other than a new crosswalk, the Proponent is not proposing any new roadway
construction.
MADOT.29 These plans should clearly show proposed lane widths and offsets, layout lines and
jurisdictions, and land uses adjacent to areas where improvements are proposed.
The Proponent is not proposing any new roadway construction.
MADOT.30 All proposed roadway signage and lighting must comply with MUTCD standards.

Comment noted. Any lighting or signs installed will comply with the standards. The new
crosswalk proposed across Pleasant Street west of Old Pleasant Street to access the
Northern Lot will be designed in compliance with MassDOT standards.
MADOT.31 The Proponent will be required to conduct an annual Traffic Monitoring Program (TMP)
for a period of five years, beginning six months after occupancy of the full-build project.
The TMP will include: • Simultaneous automatic traffic recorder (ATR) counts at each
site driveway for a continuous 24-hour period on a typical weekday; • Travel survey of
employees and patrons at the site (to be administered by the Transportation
Coordinator); • Weekday AM and PM and Saturday peak hour turning movement
counts (TMCs) and operations analysis at “mitigated” intersections, including those
involving site driveways, and; • Transit Ridership counts.
Section 4.6.2 includes a discussion of the monitoring program. The proposed project will
complete an annual transportation monitoring program for a period of five years,
beginning six months after occupancy of the full-build project, to evaluate the adequacy
of the mitigation measures and determine the effectiveness of the TDM program.
MADOT.32 The DEIR should include a Draft Section 61 Finding, outlining the mitigation measures
the Proponent has committed to implementing in conjunction with this project. The
Draft Section 61 Finding will be the basis for MassDOT to issue a final Section 61 Finding
for the project.
A Draft Section 61 Finding is included in Chapter 13.
MADOT.33 The Proponent should continue consultation with appropriate MassDOT units, including
PPDU, Traffic Operations, and the District 5 Office during the preparation of the DEIR
for the project. If you have any questions regarding these comments, please contact me
at Lionel.Lucien@dot.state.ma.us
The Proponent will continue to work collaboratively with MassDOT to coordinate the
proposed mitigation on public roadways.

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 Beth Card

Governor Secretary
Karyn E. Polito Patrick Woodcock

Lt. Governor Commissioner
23 June 2022
Beth Card, Secretary

Executive Office of Energy & Environmental Affairs
100 Cambridge Street
Attn: MEPA Unit
RE: Lakeshore Center Phase 4, Bridgewater, Massachusetts, EEA #16558
Cc: Maggie McCarey, Director of Energy Efficiency, Department of Energy Resource

Patrick Woodcock, Commissioner, Department of Energy Resources
We’ve reviewed the Environmental Notification Form (ENF) for the proposed project. The project
includes the following: 1,800-sf café, 5-story 150 unit assisted living building, 4-story 225 unit
residential building, 4-story 225 unit hotel, 4-story 160 unit condominium, and a 6,000-sf
restaurant. The objective of this letter is to share strategies for the project to reduce greenhouse
gas emissions (GHG), improve resiliency, and affordability.
Key Strategies
The following are the anticipated key strategies:
• Low heating and cooling thermal energy demand intensity (TEDI) design;
• Passivehouse;
• Efficient electrification of space and water heating;
• Rooftop solar PV;

Lakeshore Center Phase 4, EEA #16558
Bridgewater, Massachusetts
• EV charging.
Low Heating and Cooling Thermal Energy Demand Intensity (TEDI)

 
The combination of quality envelope, low air infiltration, energy recovery, and management of
solar gains can result in significant reduction in heating (and cooling) thermal energy demand
intensity (TEDI, units of kBtu/sf-yr)1,2.    In addition to reduced utility costs and emissions, the
value of a targeted focus on heating and cooling TEDI results in:   
 
• Simplified space heating electrification; 
• Reduction, and possible elimination, of perimeter heating and other systems; 
• Improved resiliency; 
• Reduced peak demands; 
• Improved occupant comfort; 
• Reduced maintenance. 
 
Specific TEDI reduction strategies are: 
 
• High-performance window and walls;  
• Thermally-broken windows and other components to eliminate thermal bridges; 
• Low air infiltration; 
• Ventilation energy recovery; 
• Energy recovery during concurrent heating and cooling;
• Solar gain management via external shading, recessed windows, and/or low solar heat gain
coefficient (SHGC) 
 
We recommend that the next submission evaluate scenarios implementing the strategies above to
achieve low heating and cooling TEDI targets. Specific recommendations are contained in a
subsequent section.
Passivehouse
Passivehouse3 is an energy efficiency building standard which uses low TEDI strategies at its core.
As a result, Passivehouse results in an ultra-low energy building requiring little energy use for
space heating and cooling. This is achieved by focusing on envelope performance, low air
1
See “Guide to Low Thermal Energy Demand for Large Buildings”, BC Housing Research Centre, 2018 for detailed information
about heating and cooling TEDI.
2
Although they have the same units, heating and cooling TEDI is not the same as heating and cooling EUI. TEDI represents
energy requirement, or demand, not energy consumption. For guidance on how to extract TEDI information from building
models see “Energy Modeling Guidelines”, City of Vancouver, Planning, Urban Design and Sustainability Department, Land Use
Development and Policy Guidelines, Version 2.0, amended 18 July 2018 and “Designing to TEDI, TEUI, and GHGI Performance
Metrics”, International Building Performance Simulation Association (IBPSA), by Chan et al.
3
The term “Passivehouse” herein means a building built to either Passivehouse Institute US (PHIUS) standard, or Passivehouse
International (PHI) standard.
Page 2 of 12
infiltration, and energy recovery. Passivehouse projects also typically have electrified heating and
much smaller and simpler HVAC systems.
Passivehouse is an energy code standard which is unlike other energy efficient building approaches
in that its truly performance based by requiring mandatory, rigorous in-field tests to confirm that
strict standards are being met. Passivehouse methods are recognized by both Massachusetts
building Code, MassSave®, and incentives under Massachusetts’ Alternative Portfolio Standard
(APS).
For the 225-unit residential building and 150-unit condominium, the MassSave® construction
incentive for Passivehouse is approximately $3,000 per dwelling unit, or $1.125M when applied
across these two buildings. It’s not clear if the 150-unit assisted living facility would qualify for
this incentive. If it does quality, the Passivehouse incentive for this building would be $450,000,
bringing, the total incentive to $1.575M. Passivehouse feasibility and design incentives are also
available (more below).
Passivehouse also delivers:
• Significant reduction in utility costs: thus is much more affordable to residents;
• Improved resiliency: Passivehouse buildings can stay warm (or cool, in the summer) for
extended periods of time even with loss of power.
At this time there are over 6,700 Passivehouse units being planned, designed, or under construction
in Massachusetts.
Passivehouse has been used across a wide variety of building sizes, styles, and uses. Below are
some examples of Passivehouse in Massachusetts.
Page 3 of 12
The Distillery Bunker Hill Housing Development Garfield House

Boston, MA Charlestown, MA Williamstown, MA
Newton Northland Finch Cambridge

Newton, MA Cambridge, MA
As mentioned above, MassSave® provides significant incentives for Passivehouse. In addition to

a potential construction incentive, MassSave® also offers generous feasibility and design
incentives, summarized as follows4:
Passive House Incentive Structure for Multi-Family (5 units or more)
Incentive Timing Activity Incentive Amount M ax. Incentive
Up to 100% Feasibility
Feasibility Study $5,000
costs
Pre-Construction 75% of Energy $500/Unit, max.

Energy Modeling
Modeling costs $20,000
Pre-Certification $500/unit
Certification $2,500/unit
NIA
Post-
$0.75/kWh
Construction Net Performance
Bonus
$7.50/therm
We recommend that the proponent utilize the above incentive to engage a MassSave® Passivehouse
consultant for this project.
4
See https://www.masssave.com/saving/residential-rebates/passive-house-incentives for detailed information
Page 4 of 12
Efficient Electrification
Efficient electrification entails swapping from fossil fuels (natural gas, oil, and propane) to electric
heat pumps.
Efficient electrification is a key mitigation strategy with significant short- and long-term
implications on GHG emissions.  Massachusetts grid emissions rates continue to decline with the
implementation of clean energy policies that increase renewable electricity sources.  The
implication is that efficient electrification results in much lower emissions than other fossil-fuel
based heating options, including best-in-class (95% efficient) condensing natural gas equipment,
in both the short term and long term. 
Currently, efficient electric heating has approximately 50% lower emissions in

Massachusetts than condensing natural gas heating.  By 2050, efficient electric heating is expected
to have approximately 85% lower emissions in Massachusetts than condensing natural gas
heating.  See illustration below. 
Emissions - 1 MM Btu of Space Heating

140
120
100
50% Less 85% Less
N
O 80
u
V,
..c 60
-
40
20
95% Eff Gas Condensing 2020 2050

Boiler
Cold Climate Air Source Heat

Pump/VRF
Efficient Electrification – Space Heating
Efficient electrification of space heating using electric air source heat pumps is readily feasible for
all buildings on this project and is recommended. Note that Passivehouse and other “low heating
TEDI” buildings are readily able to utilize electric air source heat pumps for space heating.
Efficient Electrification – Water Heating
Efficient electrification of water heating (using electric air source heat pump water heater
appliances) is potentially feasible for the café and restaurant. We recommend both air source and
electric resistance be evaluated.
Page 5 of 12
Electric air source water heating can be challenging in multifamily and hotel buildings. We
recommend the following be evaluated for these buildings:
• Electric air source heat pump water heating appliances in each unit
• Centrally-located, in-building air source water heating with hot water distribution to each
unit
• Electric resistance water heating in each unit
• For the hotel building, centrally located in-building gas heating with hot water distrubtion
to each unit.
Solar PV
Rooftop PV can provide significant GHG benefits as well as significant financial benefits. Even
if PV is not installed during building construction, it’s important to plan the project to ensure that
roof space is set aside for PV and that roof space doesn’t become unnecessarily encroached with
HVAC appurtenances, diminishing the opportunities for future PV.
Note that all buildings 5 stories or less are required to have a solar ready zone in accordance with
2018 IECC Appendix CA.
We recommend the project plan to maximize solar readiness as much as possible, including
incorporating solar-readiness above-and beyond the mandated solar readiness per Appendix CA.
Electric Vehicle (EV) Ready Parking Spaces
EV charging stations are critical for the continual transition towards electric mobility. Consistent
with recommendations by leading cities such as Boston, we recommend that a substantial number
of spaces, in the order of 25%, be built with EV charging stations and the balance of spaces be
made EV ready for future installations.
Incentives
Buildings which incorporate the above strategies can qualify for significant incentives:
• MassSave® Passivehouse incentive described above5.
• MassSave® performance-based incentives6 offer incentives for every kWh or therm saved
compared to a program-provided energy model. The above energy efficiency strategies
offer opportunities for large kWh and therm savings.
• Alternative Energy Credits (AECs)7 offer incentives to electrify building space heating
using heat pumps and/or VRF. This program also includes multipliers which increase
value if the building meets Passivehouse standards or buildings built to HERs 50 or less.
5
https://www.masssave.com/saving/residential-rebates/passive-house-incentives
6 https://www.masssave.com/en/saving/business-rebates/new-buildings-and-major-renovations/
7 https://www.mass.gov/guides/aps-renewable-thermal-statement-of-qualification-application
Page 6 of 12
These credits may be distributed on a quarterly basis over time; or, may be distributed in a
lump sum to the developer if certain conditions are met.
• Massachusetts SMART program8 provides significant incentives for solar development on

top of federal and state tax incentives. SMART includes pathways which allow solar
production to be sold without off-takers. This may be of potential interest to building
developers as this allows them to develop rooftop solar without necessarily engaging with
building tenants. For this reason, setting aside rooftop solar PV areas helps ensure that
building owners’ ability to monetize the roof is not impacted.
Codes and Baseline
Massachusetts Stretch Code applies to all the proposed buildings 100,000-sf or larger. Stretch
Code requires a 10% energy performance improvement over ASHRAE 90.1-2013-Appendix G
plus Massachusetts amendments including C402.1.5 (envelope), C402.3 (solar readiness), C405.3
and C405.4 (lighting), C405.10 (EV charging), and C406 (three additional efficiency measures).
Projects should include the three C406 additional efficiency measures in their Baseline.
In addition to above, all buildings 4 stories or less which have dwelling units containing a kitchen
and at least one bathroom shall also show that all dwelling units have a HERs rating of 55 or less.
This is required for all building sizes, even those less than 100,000-sf.
Massachusetts base code applies to all buildings less than 100,000-sf. Base code requires
conformance with 2018 IECC plus Massachusetts amendments including C402.3 (solar readiness),
C405.10 (EV readiness), and C406 (three additional efficiency measures).
Recommendations for Subsequent Submission
Recommendations are as follows:
1. Ensure that all scenarios representing mandatory code meet all code requirements including
relevant MA amendments. Clearly indicate which three C406 measures are being used. DOER.1
For residential buildings 4 stories or less as described above, mandatory code building
scenarios should be HERS 55 or lower.
2. Develop two UA analysis tables:

DOER.2
a. One table that shows how the mandatory code scenario complies with Table 5.5-5
of ASHRAE 90.1 2013 Appendix G plus Massachusetts Amendment C401.2.4.
b. A second table that shows how the proposed scenario complies with 2018 IECC
Tables C-402.1.3, C402.1.4, and C-402.4. Fenestration limit shall be 30%.
8 https://www.mass.gov/solar-massachusetts-renewable-target-smart
Page 7 of 12
3. Ensure that all scenarios properly account for thermal bridges. Thermal breaks should be DOER.3
incorporated in all scenarios, including mandatory code scenarios, to ensure that the
mandatory wall and window performance in (2) above are being delivered. Thermal bridge
accounting as described in the Building Envelope Thermal Bridging Guide9 is
recommended
4. Separately for both the 4-story, 225 unit residential building and the 4-story, 160-unit DOER.4
condo building, perform the following scenarios:
a. Baseline meeting minimum code: use 8760 compliant energy model to show
building meeting ASHRAE 90.1 2013 with amendments, improved by 10% on an
energy use intensity basis. (In the unlikely event that the building is less than
100,000-sf, use 8760 energy model meeting prescriptive 2018 IECC, plus
Massachusetts amendments.) Then, confirm that a “top/corner” unit would have
HERs 55 or lower using a HERs compliant model. Report the following using
output from the 8760 compliant energy model:
i. Heating and cooling thermal energy demand intensity TEDI (kBtu/sf-yr)
ii. Heating and cooling peak loads for each month (MBH)
iii. Peak energy use for each month, broken down by energy type (MBH)
iv. Total annual heating and cooling (MMbtu/yr)
v. Total annual energy use, broken down by energy type (MMbtu/yr)
b. Improved meeting HERS 45: Use HERS model to develop an improved scenario
incorporating: reduced air infiltration, improved windows, improved walls/roof,
electric air source heat pump space heating, and improved energy recovery that
results in a HERS of 45 or lower (for a “top/corner” unit). Lighting, appliance
energy use, or other non-water heating miscellaneous energy uses should be
consistent in baseline and improved scenarios. Then, use an 8760 compliant model
to reproduce improved scenario to report items (i) through (v) from 4a above.
c. Improved meeting Passivehouse: Engage with a MassSave funded consultant for

them to develop a scenario meeting Passivehouse. Then, use an 8760 compliant
model to reproduce the Passivehouse scenario to report items (i) through (v) from
4a above.
d. Develop sub-scenarios of (a), (b), and (c) above to evaluate water heating options
including: in-unit air source heat pump, in-unit electric resistance, in-building
central air source heat pump with distributed water to each unit.
5. For the 5-story, 150-unit assisted living building, perform the following scenarios: DOER.5
building meeting ASHRAE 90.1 2013 with amendments, improved by 10% on an
energy use intensity basis. (If the building is less than 100,000-sf, use 8760 energy
9
Building Envelope Thermal Bridging Guide, Version 1.2, 2018, BC Hydro available here
https://www.bchydro.com/content/dam/BCHydro/customer-portal/documents/power-smart/business/programs/building-
envelope-thermal-bridging-guide-version-1.2.pdf
Page 8 of 12
model meeting prescriptive 2018 IECC, plus Massachusetts amendments.) Report

the following using output from the 8760 compliant energy model:
b. Improved with low heating TEDI: Use 8760 model to develop an improved
scenario incorporating: reduced air infiltration, improved windows, improved
walls/roof, electric air source heat pump space heating, and improved energy
recovery that results in a reduction in heating TEDI, targeting about 2 to 3 kBtu/sf-
yr. Lighting, appliance energy use, or other non-water heating miscellaneous
energy uses should be consistent in baseline and improved scenarios. Report items
(i) through (v) from 5a above.
c. Improved meeting Passivehouse: If this building type qualifies for MassSave

Passivehouse incentive, engage with a MassSave funded consultant for them to
develop a scenario meeting Passivehouse. Then, use an 8760 compliant model to
reproduce the Passivehouse scenario to report items (i) through (v) from 5a above.
d. Develop sub-scenarios of (a), (b), and (c) above to evaluate water heating options
central air source heat pump with distributed water to each unit.
6. For the 4-story, 102-unit hotel, perform the following scenarios: DOER.6
building meeting prescriptive 2018 IECC, plus Massachusetts amendments. (If the
building is 100,000-sf or larger, use ASHRAE 90.1 2013 with amendments,
improved by 10% on an energy use intensity basis.) Report the following using
output from the 8760 compliant energy model:
i. Heating and cooling thermal energy demand intensity TEDI (kBtu/sf-
yr)
recovery that results in a reduction in heating TEDI, targeting about 2 to 3 kBtu/sf-
yr. Lighting, appliance energy use, or other non-water heating miscellaneous
energy uses should be consistent in baseline and improved scenarios. Report items
(i) through (v) from 6a above.
Page 9 of 12
c. Develop sub-scenarios of (a) and (b) above to evaluate water heating options
central air source heat pump with distributed water to each unit, and in-building
central natural gas system with distributed water to each unit.
7. Separately for both the 1,800-sf café and 6,000-sf restaurant, perform the following DOER.7
scenarios:
building meeting prescriptive requirements of 2018 IECC with amendments.
Report the following using output from the 8760 compliant energy model:
recovery that results in a reduction in heating TEDI. Lighting, appliance energy
use, or other non-water heating miscellaneous energy uses should be consistent in
baseline and improved scenarios. Report items (i) through (v) from 7a above.
c. Develop sub-scenarios of (a) and (b) above to evaluate water heating options
including: air source heat pump and electric resistance.
8. Evaluate incentives, including DOER.8
a. Estimates of MassSave® incentives, based on meeting with utility, including:

▪ Incentives for Passivehouse scenarios
▪ Incentives for other performance-based non-Passivehouse scenarios
▪ Incentives for efficient electrification.
b. Estimate of Alternative Energy Credits
9. Evaluate solar PV. DOER.9
a. Investigate models of ownership and operation under SMART, including Qualified

Facility pathway.
b. Meet utility to discuss interconnection.
c. Include scaled building roof plans showing location of planned solar and location
of roof HVAC equipment and other appurtenances for each building
d. Indicate on the plans the code-required extent of solar readiness, if applicable.
Page 10 of 12
e. Map out maximum area available for solar.
f. Estimate GHG reduction as a result of solar PV.
10. Evaluate opportunities for EV ready and installed EV spaces. DOER.10
DOER.11
11. Submit project modeling files to the DOER on a flash drive.
12. Compare model results total and individual end uses with representative, prototype DOER.12
buildings developed by Pacific Northwest National Labs/Department of Energy found at
the link below. Provide a summary explaining potential differences.
▪ https://www.energycodes.gov/sites/default/files/documents/BECP_901_2013_Progress_Indicator_
0_0.pdf
▪ http://www.energycodes.gov/sites/default/files/documents/2013EndUseTables.zip
▪ https://www.energycodes.gov/commercial-energy-cost-savings-analysis
13. Include a table similar to the example below. For “code value” ensure that the value DOER.13
incorporates any improved efficiency per requirements of Section C406.1 of the
Massachusetts’ amendments. Add columns as necessary to accommodate the improved
scenarios.
Measure/Area Base Code Improved Scenario % Change Comment

AC Efficiency (EER)
Bldg 1 code value design value %
ERV Effectiveness (%)
Boiler (% efficiency)
LPD (Watts/sq ft)
(continue to include service water, equipment, etc)
Sincerely,
~
Paul F. Ormond, P.E.
Page 11 of 12
Energy Efficiency Engineer

Massachusetts Department of Energy Resources
Page 12 of 12
DEPARTMENT OF ENERGY RESOURCES
DOER.1 Ensure that all scenarios representing mandatory code meet all code requirements
including relevant MA amendments. Clearly indicate which three C406 measures are
being used. For residential buildings 4 stories or less as described above, mandatory
code building scenarios should be HERS 55 or lower.
Chapter 11 contains a GHG Analysis consistent with current Massachusetts Code,

including Massachusetts Amendments.
DOER.2 Develop two UA analysis tables: a. One table that shows how the mandatory code
scenario complies with Table 5.5-5 of ASHRAE 90.1 2013 Appendix G plus Massachusetts
Amendment C401.2.4. b. A second table that shows how the proposed scenario
complies with 2018 IECC Tables C-402.1.3, C402.1.4, and C-402.4. Fenestration limit
shall be 30%.
Envelope performance tables have been included in Attachment D.
DOER.3 Ensure that all scenarios properly account for thermal bridges. Thermal breaks should
be incorporated in all scenarios, including mandatory code scenarios, to ensure that the
mandatory wall and window performance in (2) above are being delivered. Thermal
bridge accounting as described in the Building Envelope Thermal Bridging Guide is
recommended.
Please refer to Section 11.2.1 for a discussion of Thermal Bridges.
DOER.4 Separately for both the 4-story, 225-unit residential building and the 4-story, 160-unit
condo building, perform the following scenarios: a. Baseline meeting minimum code b.
Improved meeting HERS 45 c. Improved meeting Passivehouse d. Develop sub-scenarios
The requested HERS modeling has been performed for both the 55+ Multi-family and
condominium buildings. Please refer to Section 11.2.5 and Attachment D for modeling
details.
DOER.5 For the 5-story, 150-unit assisted living building, perform the following scenarios: a.
Baseline meeting minimum code b. Improved with low heating TEDI c. Improved
meeting Passivehouse d. Develop sub-scenarios
The requested energy modeling has been performed for the assisted living building.
Passive House scenario was not modeled as the assisted living building would not qualify
for MassSave Passive House incentives. Please refer to Section 11.2.5 and Attachment D
for modeling details.
DOER.6 For the 4-story, 102-unit hotel, perform the following scenarios: a. Baseline meeting
minimum code b. Improved with low heating TEDI c. Develop sub-scenarios

The requested energy modeling has been performed for the hotel. Please refer to Section
11.2.5 and Attachment D for modeling details.
DOER.7 Separately for both the 1,800-sf café and 6,000-sf restaurant, perform the following
scenarios: a. Baseline meeting minimum code b. Improved with low heating TEDI c.
Develop sub-scenarios
As discussed in the meeting with DOER and MEPA, energy modeling will not be performed
on these small out-parcels. Instead, these parcels have been discussed qualitatively in
Section 11.2.6.
DOER.8 Evaluate incentives, including a. Estimates of MassSave® incentives, based on meeting

with utility, including: ▪ Incentives for Passivehouse scenarios ▪ Incentives for other
performance-based non-Passivehouse scenarios ▪ Incentives for efficient electrification.
b. Estimate of Alternative Energy Credits
The team has engaged with MassSave and expects to participate in either their
PassiveHouse or performance-based incentive programs. Other incentives have been
estimated and included in the Proponent’s decision-making process. Please refer to
Section 11.2.7.
DOER.9 Evaluate solar PV. a. Investigate models of ownership and operation under SMART,
including Qualified Facility pathway. b. Meet utility to discuss interconnection. c.
Include scaled building roof plans showing location of planned solar and location of roof
HVAC equipment and other appurtenances for each building d. Indicate on the plans
the code-required extent of solar readiness, if applicable. e. Map out maximum area
available for solar. f. Estimate GHG reduction as a result of solar PV
The design team has evaluated options for the local generation of electricity with the use
of rooftop PV panels. PV-ready zones will be provided and future PV installations will be
considered as design progresses. Please refer to Section 11.2.3 for additional information.
DOER.10 Evaluate opportunities for EV ready and installed EV spaces.
The Proponent is committed to supporting the State’s mission of transitioning to

renewable energy sources by employing electric systems wherever feasible. Accordingly,
the Proponent has committed to the installation of EV charging stations to serve 36
parking spaces for this Project. An additional 36 spaces will be built “EV-ready” with the
infrastructure in place for future EV installation. Please refer to Section 11.2.4 for
DOER.11 Submit project modeling files to the DOER on a flash drive.
Modeling files can be provided upon request.

DOER.12 Compare model results total and individual end uses with representative, prototype
buildings developed by Pacific Northwest National Labs/Department of Energy found
at the link below. Provide a summary explaining potential differences.
Please refer to Section 11.2.5 for building energy model tables including comparisons with
PNNL prototype buildings.
DOER.13 Include a table similar to the example below. For “code value” ensure that the value
incorporates any improved efficiency per requirements of Section C406.1 of the
Massachusetts’ amendments. Add columns as necessary to accommodate the
improved scenarios.
Please refer to Attachment D for an Energy Model Report prepared by The Green Engineer
containing the requested information.

d dMass.gov | Executive Office of Energy & Environmental Affairs (EEA) An official application of the Commonwealth of Massachusetts
~(https:/Energy & Environmental Affairs

/www.mass.gov/orgs/executive-office-of-energy-and-environmental-affairs)
~ Public Comments Portal

purvi.patel@mass.gov
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Comment Details
EEA #/MEPA ID First Name Address Line 1 Organization

16558 Melissa -- Lake Nippenicket Action Focus Team
Comments Submit Date Last Name Address Line 2 Affiliation Description

6-13-2022 Ramondetta -- Individual
Certificate Action Date Phone State Status

6-14-2022 +15086972118 -- Opened
Reviewer Email Zip Code

Purvi Patel, (617)874-0668,
purvi.patel@mass.gov lnaft@outlook.com --
Comment Title or Subject
Topic: EEA #/MEPA ID* 16558 / Lakeshore Center Phase 4 / Bridgewater, MA
Comments
      Segoe UI  10 pt          Paragraph            
Please ¦nd comments from the Lake Nippenicket Action Focus Team attached re: EEA # / MEPA ID 16558 / Lakeshore Center Phase 4 in Bridgewater, MA.
Please acknowledge receipt, thank you.
With kind regards.
Attachments
LNAFT COMMENTS_MEPA_ENF 16558 LAKESHORE CENTER PHASE IV_061322.pdf(null)
Perennial Stream - North Site Video_060922.mov(null)
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June 13, 2022
Purvi Patel
Environmental Analyst
MEPA Office Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900
Boston, MA 02114
purvi.patel@state.mass.us
RE: EEA #16558 : Lakeshore Center Phase IV, Bridgewater MA
Dear Ms. Patel:
The Lake Nippenicket Action Focus Team (LNAFT) submits the following comments on the
Environmental Notification Form (ENF / EEA 16558) for Lakeshore Center Phase IV, published in the
Environmental Monitor on May 25, 2022.
Northern Site:
The narrow parcels of land that are the subject of the Northern site include a 1,080 square foot
residence (purchased in 2018) and undeveloped parcels of land that run along approximately .30 miles
of shoreline of Lake Nippenicket. The parcels are located next to the Lake Nippenicket Boat Ramp and
Parking Lot. The Northern Site parcels are not part of the existing Lakeshore Center development and
are located across Route 104. The site is not zoned as part of the Planned Development District and the
parcels were not part of previous Lakeshore Center MEPA filings by the proponent.
The South Coast Rail Community Priority Area 5-Year Update Project Report dated August 2013,
prepared by the Old Colony Planning Council in partnership with the Metropolitan Planning Organization
and the Southeastern Regional Planning and Economic Development District shows the Northern Site
parcel (Figure 1) located within the Priority Protection Area (PPA). As defined in this report, Priority
Protection Areas (PPAs) are areas that are important to protect due to the presence of significant natural
or cultural resources including endangered species habitats, areas critical to water supply, historic
resources, scenic vistas, and farms. Like PDAs, the PPAs can vary greatly in size. Sites may be candidates
for protection through acquisition or conservation restrictions. (1)
11re 1: 2013 Bridgewater Community Priority Area Map
Town of Bridgewater
Commun ity Priority
Areas, 2013
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Figure 1: South Coast Rail Community Priority Area 5-Year Update Project Report (2013)
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Figure 2: BioMap2: Natural Heritage and Endangered Species Program

(http://maps.massgis.state.ma.us/dfg/biomap2.htm)
The Northern Site parcel is mapped in BioMap2 (Figure 2) by the Natural Heritage and Endangered
Species Program as Core Habitat and Critical Landscape including Priority Natural Communities; Species
of Conservation Concern and the CNL components: Upland Buffer of Aquatic Core; Upland Buffer of
Wetland Core and Landscape Blocks. (2) These parcels are Located within the Hockomock Swamp ACEC
and are an important part of the Town River and Lake Nippenicket watershed and wildlife habitat that
must be protected.
Under Water Resources (page 6), Lake Nippenicket is identified as an impaired water body and Category
4A. In Appendix 24 Taunton River Watershed Assessment and Listing Decision Summary Final
Massachusetts Integrated List of Waters for the Clean Water Act 2018/2020 Reporting Cycle It notes
“During the 1996 MassDEP lake synoptic survey of Lake Nippenicket the non-native aquatic macrophyte
Cabomba caroliniana was documented. The fieldsheets also indicate the presence of an unconfirmed
species of Myriophyllum which was thought to be heterophyllum. The species needs confirmation, ideally
when flowering heads are present. The Aquatic Life Use is for Lake Nippenicket is assessed as not
supporting based on the presence of the nonnative aquatic macrophyte Cabomba caroliniana. An
additional species, M. heterophyllum, may also infest the pond (identified as an Alert Status) however
further confirmation of this infestation is needed.” Both Cabomba caroliniana and M. heterophyllum are
competitive and able to outcompete other aquatic plants. They can prevent water flow, reduce sunlight
and reduce oxygen availability that can harm or kill aquatic organisms. The proponent has indicated
that:
Plymouth gentian (Special Concern) https://www.mass.gov/news/species-spotlight-plymouth-gentian
Round-fruited seedbox (Endangered)

https://www.mass.gov/files/documents/2016/08/tm/ludsph.pdf?msclkid=e6b653c1b5b211ecb45cc69e
20a55695
are likely to be on the Northern Site and potentially would be “taken” by the development proposed. As LNAFT.01
noted by the TRWA Summary, there are issues already with regard to invasive species Lake Nippenicket.
Any “take” of beneficial plants would risk further growth of the invasive species in the Lake and the
potential harm or death or aquatic organisms. Further study of the infestation of Cabomba caroliniana LNAFT.02
and M. heterophyllum is needed. (4)
On the eastern side of the Northern Site is a perennial stream that connects Lake Nippenicket to
wetlands located across Route 104 on the Lakeshore Center development. The stream is subject to the
protections of the River Protection Act and is visible on the MassMapper site as a perennial stream. The
LNAFT.03
perennial stream has not been mentioned in the proponent’s ENF and on the “Preferred Option Plan” a
parking lot is planned within the 200 foot buffer zone. The proponent has mistakenly identified this
stream as something other than perennial. A video of the stream taken on June 9, 2022 is below. The
stream is a vital connector of the Town River/Lake Nippenicket and must be protected from any
development that would impact these important hydrological connectors.
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Figure 3: Mass Mapper (Oliver) dated June 8, 2022 & Video of Perennial Stream on North Site taken
on June 9, 2022. (4)
Video.mov
The narrow Northern Site parcels must receive heightened MEPA attention and verification of the high LNAFT.04
water mark of the Lake due to Chapter 91 protections. These protections are triggered if any work is
proposed within its jurisdiction. Lake Nippenicket is a Great Pond within an ACEC which affords
significant protections from the high-water mark seaward. The proponent has indicated during the June
6th (2022) Zoom meeting that they intend to build a 4,000 sf restaurant with a 2,000 sf deck. MEPA
should request an analysis from the Waterways team to verify the high-water mark and request a LNAFT.05
review of detailed site plans with regard to the proposed project. The lakefront site is too narrow for a
restaurant and its extensive parking areas.
Other concerns include impacts on wildlife habitat; proximity to residential neighborhoods; traffic; noise
pollution; trash and infestations of rats and other creatures.
On page 12 of the ENF the proponent states: “The open space at the Project Site is not useable as it is
along a busy corridor between Route 24 and Route 495.” Under the Section, Compatibility with
Adjacent Land Uses, the proponent notes proximity to highways and compatible adjacent uses as
commercial and residential. The proponent has omitted another important use of this area which is LNAFT.06
recreational enjoyment of open space. The Northern Site is largely undeveloped; sits on the lakeshore;
and is next to the Lake Nippenicket Boat Ramp which is a recreational open space hub for the
community for fishing, picnicking, canoeing, kayaking and boating. The area is popular for its beautiful
sunsets. Further west to this site is Rozena’s Field that is often the host of competitive horse shows. The LNAFT.07
proponent should ensure that all uses of this area are considered under this filing, including recreational
enjoyment of open space as it has largely been ignored in this ENF. The Northern Site and its location
next to the Lake Nippenicket Boat Ramp would be an ideal area to consider for conservation restriction
and passive recreation as the development of a restaurant on the site would have a negative impact on
the recreational enjoyment of open space on Lake Nippenicket.
Eastern Site:
The Eastern Site is comprised of a 19.9 acre undeveloped parcel (Bridgewater Assessors Map 83, Parcel
85) of land fronting Route 104 and a 30.3 acre undeveloped parcel behind it (Bridgewater Assessors
Map 96, Parcel 19). The proponent has also developed a 100,000 square foot flexible warehouse space
on the easternmost portion of the site. A large portion of this land is covered by wetlands that feed into
Lake Nippenicket, the headwaters of the Town River. Out of the undeveloped 50.2 acres, 29.40 acres are
wetlands or 58%.
The “Preferred Option Plan” that the proponent is proposing would add 535 living units plus 102 hotel
rooms to the currently undeveloped Eastern Site. It should be noted that the proponent’s plan
emphasizes scale and monetary return. Every parcel of land that is not a wetland is being developed to
its fullest degree. We would encourage MEPA to recommend a sizing down of Eastern Site Phase IV that
allow the wetlands a full 100 foot buffer without work as these wetlands feed into Lake Nippenicket and
are part of the hydrologically connected Hockomock Swamp and headwaters of the Town River. The
focus should be on reducing project size and maximizing protection of the natural resources and habitat
on the site. The watershed is small and any watershed degradation from this development will have
tremendous impact on waterflow.
In the MEPA Filing Instructions to prepare an ENF on page 4 under Project Description, it notes that the
LNAFT.08
proponent must discuss the infrastructure requirements of the project and the capacity of the municipal
and or regional infrastructure to sustain these requirements into the future. The capacity issues of
Bridgewater including water, sewer, etc. are not discussed by the proponent in this ENF. Total WMA
Authorization for Bridgewater is 1.98 MGD (722.70 MGY). Annual usage for 2021 according to the
Consumer Confidence Report was 1.59 MGD. If the maximum water usage of the Lakeshore
Development is added to this total (ie: 146,862 gpd), it would bring Bridgewater very close to its annual
water capacity. It should be noted that there are other large building projects ongoing in Bridgewater
that will also add to this capacity. The proponent should provide additional detail regarding LNAFT.09
Bridgewater’s capacity to sustain the requirements of an additional 535 living units plus 102 hotel rooms
into the future.
Also, according to the MEPA Filing Instructions #5. Plan, at an appropriate scale, of proposed conditions
upon completion of project (if construction of the project is proposed to be phased, there should be a site
LNAFT.10
plan showing conditions upon the completion of each phase). The current ENF does not include phased
plans and instead, shows all phases in one plan. It also does not break down in any summary of impacts,
the phases of the project. It would be helpful to know the impacts per phase, as opposed to the
wholesale approach taken in this current ENF.
Enhanced analysis with regard to Environmental Justice populations (16 in total) within a five-mile radius
is needed. Due to the numerous triggers of air pollution within this area (ie: Route 24, Route 495, Elm LNAFT.11
Street Industrial District, Cities (Brockton and Taunton)) and the fact that the proponent is looking to
increase vehicle trips per day by 4,262 and waste water by 122,385 gallons per day, further studies (ex:
air modeling data & wastewater studies) should be done to verify impact to determine if enhanced
analysis and mitigation is necessary. Please take note of Figure 5 that illustrates air pollution in the area
on June 9, 2022.
From the Massachusetts Environmental Justice Policy: 1) Exceed a mandatory EIR threshold for air, solid
and hazardous waste (other than remediation projects), or wastewater and sewage sludge treatment
and disposal; and 2) Are located within one mile of an EJ Population (or in the case of projects exceeding
a mandatory EIR threshold for air, within five miles of an EJ Population). (5)
Also, it should be noted that according to Envirofacts, a General Permit Covered Facility for Two
Lakeshore Center for non-potable water (sludge) has expired. (6)
FACILITY NAME (1). TWO LAKESHORE CENTER OFFICE BUILDING NPDES MAR10014R
STREET 1 2 LAKESHORE CENTE R SIC CODE
CITY MAJOR 1MINOR
COUNTY NAME TYPE OF OWNERSHIP
STATE MA ACTIVITY STATUS Effective
ZIP CODE 02324 INACTIVE DATE
REGION Region 1 TYPE OF PERMIT ISSUED General Permit Covered Facility
LATITUDE 41 .9599 ORIGINAL PERMIT ISSUE DATE 08-FEB-20 18
LONGITUDE -71.0360 PERMIT ISSUED DATE 08-FEB-20 18
LAT/LON CODE OF ACCURACY so PERMIT EXPIRED DATE 15-FEB-2022
LAT/LON METHOD Unknown
LAT/LON SCALE USGS HYDRO BASIN CODE
LAT/LON DATUM NAD83 FLOW
RECEIVING WATERS FEDERAL GRANT IND
PRETREATMENT CODE SLUDGE CLASS FAC IND NON-POTW
Figure 4: Envirofacts (https://www.epa.gov/enviro/envirofacts-overview)

~ow Interactive Map of Air Quality
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Figure 5: Air Now (https://gispub.epa.gov/airnow/?contours=ozonepm&monitors=none&xmin=-

8609102.49575933&xmax=-
7669844.292191132&ymin=5002012.1693443395&ymax=5376247.859828545) Air quality on this day
(6/9/22) was moderate at 54. Primary pollutant is PM2.5.
A large portion of the Eastern site is located within Flood Zone A (FEMA). A functioning floodplain is
important for the surrounding ecosystem. The proponent is planning to work within the 100 foot buffer
zone of the wetlands surrounding the development. Any work within the 100 foot buffer zone should be
LNAFT.12
prohibited due to impacts on the wetlands that feed into Lake Nippenicket and the Town River, an
integral part of the Hockomock Swamp. (7)
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https://msc.fema.gov/portal/search?AddressQuery=02324#searchresultsanchor
The map below from MassGis shows a sobering statistic that 30-45% of Bridgewater’s residential land
are located within a 100-year flood zone. It is hoped that MEPA will review this statistic in the interest of
reducing the size of this significant development that will increase the number of residences within a
100-year flood zone.(8)
Community Q. •
Percent of Population Not White by
tJ Community
Percent With Less than High School
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Figure 7: Climate Vulnerability / MassMapper / Percent of Residential Area in a 100-year Flood Zone.
The two listed archaeological sites, the Bassett Site (19-PL-497) and Tomb Road Area B Site (190-PL-498)
will be destroyed and replaced with a short-stay hotel and residential community. According to the
Massachusetts Historical Commission, archaeological sites in the vicinity of these wetlands are known to LNAFT.13
span 9000 years. A Memorandum of Agreement has been prepared by the MHC that allows the
destruction of the site under certain conditions as noted in the National Historic Preservation Act of
1966. It is not clear whether MEPA now has the authority to encourage the preservation of these sites,
as an MOA has been signed, however, it should be encouraged.
According to the MA ENDANGERED SPECIES ACT (G.L. c.131A) CONSERVATION AND MANAGEMENT
PERMIT dated February 7, 2019, The Division has determined that this project, as proposed, will result in
a Take (321 CMR 10.18 (2)(b)) of the Eastern Box Turtle through the loss and fragmentation of suitable
habitat and disruption of feeding, aestivating, overwintering, sheltering and migratory behaviors. A total
of 14.4 acres of suitable habitat will be lost. The Box Turtle Habitat Map below shows the extent of the
“take” of this species. (9) It is unfortunate and disheartening to see that the “take” was permitted and
that efforts to scale down the project were not encouraged.
Figure 9: Box Turtle Habitat Impact Map, Lakeshore Center (9)
The Lake Nippenicket Action Focus Team recommends the following:
1. No development on the Northern Site.

2. Significant reductions to be made on the other sites to allow a full 100-foot buffer zone to the
wetlands without work. Proponent should not be permitted to stretch out development to the
maximum.
3. No further allowances by state agencies to “take” additional species and instead, insistence on
protecting important habitat.
4. Reconsider decision to allow destruction of historic sites.
5. Significant reductions in project scope and size that will address municipal and state air, water,
waste and traffic concerns. Further studies needed.
6. Green space plan must be incorporated into overall plan to include recreational open space and
preservation of important natural resources.
7. Protection of the headwaters and watershed of the Town River and Lake Nippenicket.
Thank you for hearing our concerns and reviewing our comments.
With kind regards,
Melissa Ramondetta
Coordinator, Lake Nippenicket Action Focus Team
317 Lakeside Drive
Bridgewater, MA 02324
For Further Reading:
(1) South Coast Rail Community Priority Area 5-Year Update Project Report (August 2013)
https://archive.org/details/scr-priority-area-5-year-update-project-2013-bridgewater-
community-report
(2) BioMap2: Conserving Biodiversity in a Changing World
https://www.mass.gov/service-details/biomap2-conserving-biodiversity-in-a-changing-world
(3) Mass Mapper https://maps.massgis.digital.mass.gov/MassMapper/MassMapper.html
(4) Appendix 24 Taunton River Watershed Assessment and Listing Decision Summary Final
Massachusetts Integrated List of Waters for the Clean Water Act 2018/2020 Reporting Cycle
https://www.mass.gov/doc/20182020-integrated-list-of-waters-appendix-24-taunton-river-
watershed-assessment-and-listing-decision-summary/download
(5) https://www.mass.gov/doc/environmental-justice-policy6242021-update/download
(6) https://enviro.epa.gov/enviro/multisys2_v2.get_list?facility_uin=110070202535
(7) FEMA Flood Map
https://msc.fema.gov/portal/search?AddressQuery=02324#searchresultsanchor
(8) Climate Vulnerability
https://maps.massgis.digital.mass.gov/MassMapper/MassMapper-CC-Vuln.html
(9) MA ENDANGERED SPECIES ACT (G.L. c.131A) CONSERVATION AND MANAGEMENT PERMIT
(Eastern Box Turtle) dated 2/7/2019.
0 Perennial
Stream - ~N orth
Site
Video 060922
LAKE NIPPENICKET ACTION FOCUS TEAM
LNAFT.01 As noted by the TRWA Summary, there are issues already with regard to invasive
species Lake Nippenicket. Any “take” of beneficial plants would risk further growth of
the invasive species in the Lake and the potential harm or death or aquatic organisms.
in a take.
LNAFT.02 On the eastern side of the Northern Site is a perennial stream that connects Lake
Nippenicket to wetlands located across Route 104 on the Lakeshore Center
development. The stream is subject to the protections of the River Protection Act and
is visible on the MassMapper site as a perennial stream.
The stream has previously been determined to be intermittent. The question has been
raised in the past and the DEP in 2009 provided an opinion that the stream was not
perennial. The documentation is provided in Attachment E.
LNAFT.03 The perennial stream has not been mentioned in the proponent’s ENF and on the
“Preferred Option Plan” a parking lot is planned within the 200-foot buffer zone. The
proponent has mistakenly identified this stream as something other than perennial. A
video of the stream taken on June 9, 2022 is below. The stream is a vital connector of
the Town River/Lake Nippenicket and must be protected from any development that
would impact these important hydrological connectors.
The stream has previously been determined to be intermittent. The question has been
raised in the past and the DEP in 2009 provided an opinion that the stream was not
perennial. The documentation is provided in Attachment E.
LNAFT.04 The narrow Northern Site parcels must receive heightened MEPA attention and
verification of the high water mark of the Lake due to Chapter 91 protections. These
protections are triggered if any work is proposed within its jurisdiction. Lake
Nippenicket is a Great Pond within an ACEC which affords significant protections from
the high-water mark seaward. The proponent has indicated during the June 6th (2022)
Zoom meeting that they intend to build a 4,000-sf restaurant with a 2,000-sf deck.
As stated in the ENF Certificate, “MassDEP comments indicate that there does not appear
to be any proposed activities within Chapter 91 jurisdiction”; therefore, because MEPA
jurisdiction is limited to only the aspects of the Project that require or potentially require
a permit from a state agency, the Proponent is not required to conduct this analysis of
the high-water mark.

The Proponent will limit or avoid impacts to the ACEC to the greatest extent possible.
Please refer to Chapter 6 for additional information.
LNAFT.05 MEPA should request an analysis from the Waterways team to verify the high-water
mark and request a review of detailed site plans with regard to the proposed project.
The lakefront site is too narrow for a restaurant and its extensive parking areas. Other
concerns include impacts on wildlife habitat; proximity to residential neighborhoods;
traffic; noise pollution; trash and infestations of rats and other creatures.

Based on the capacity analysis, the Project is shown to result in a limited increase in delay
to the study area intersections. The overall delay at the intersections of Pleasant Street
at the Route 24 Ramps are anticipated to increase by approximately 3 seconds from
No-Build to Build conditions, showing the minimal impact.
The Project is not anticipated to generate a significant amount of noise. Furthermore, the
Project will abide by local and state noise ordinances.
The Project design includes waste and recycling facilities to appropriately process the
waste and recycling generated by the various proposed uses.
LNAFT.06 The proponent has omitted another important use of this area which is recreational
enjoyment of open space. The Northern Site is largely undeveloped; sits on the
lakeshore; and is next to the Lake Nippenicket Boat Ramp which is a recreational open
space hub for the community for fishing, picnicking, canoeing, kayaking and boating.
The area is popular for its beautiful sunsets. Further west to this site is Rozena’s Field
that is often the host of competitive horse shows.
The Proponent does not anticipate the Project will impact the recreational aspects of Lake
Nippenicket.
LNAFT.07 The proponent should ensure that all uses of this area are considered under this filing,
including recreational enjoyment of open space as it has largely been ignored in this
ENF. The Northern Site and its location next to the Lake Nippenicket Boat Ramp would
be an ideal area to consider for conservation restriction and passive recreation as the
development of a restaurant on the site would have a negative impact on the
recreational enjoyment of open space on Lake Nippenicket.

The proposed restaurant site is a former residential property. The Proponent is not
proposing to convert it to an open space recreation area.
LNAFT.08 In the MEPA Filing Instructions to prepare an ENF on page 4 under Project Description,
it notes that the proponent must discuss the infrastructure requirements of the project
and the capacity of the municipal and or regional infrastructure to sustain these
requirements into the future. The capacity issues of Bridgewater including water,
sewer, etc. are not discussed by the proponent in this ENF. Total WMA Authorization
for Bridgewater is 1.98 MGD (722.70 MGY). Annual usage for 2021 according to the
Consumer Confidence Report was 1.59 MGD. If the maximum water usage of the
Lakeshore Development is added to this total (i.e.: 146,862 gpd), it would bring
Bridgewater very close to its annual water capacity. It should be noted that there are
other large building projects ongoing in Bridgewater that will also add to this capacity.
As stated in the Certificate on the ENF, “According to MassDEP comments, the Town has
the capacity to provide the requested volume for this project based on its renewed Water
Management Act (WMA) permit issued on January 5, 2021 and its recent water use.” The
Project will employ water conservation measures to reduce demand to the greatest
extent practicable.
LNAFT.09 The proponent should provide additional detail regarding Bridgewater’s capacity to
sustain the requirements of an additional 535 living units plus 102 hotel rooms into the
future.
The Town’s infrastructure is anticipated to be adequate to support the Project. Please

refer to Chapters 4 (Transportation), 7 (Stormwater), and 8 (Water and Wastewater) for
LNAFT.10 Also, according to the MEPA Filing Instructions #5. Plan, at an appropriate scale, of
proposed conditions upon completion of project (if construction of the project is
proposed to be phased, there should be a site plan showing conditions upon the
completion of each phase). The current ENF does not include phased plans and instead,
shows all phases in one plan. It also does not break down in any summary of impacts,
the phases of the project. It would be helpful to know the impacts per phase, as
opposed to the wholesale approach taken in this current ENF.
The DEIR provides individual site plans as Figures 1-7 through 1-12. And impacts are
generally broken down by lot in Chapter 3. Section The Proponent expects to seek
approvals for Lots 7 and 6 in 2023 and proceed with construction once approvals are in
place. Other phases will be advanced according to market demand.
LNAFT.11 Enhanced analysis with regard to Environmental Justice populations (16 in total) within
a five-mile radius is needed. Due to the numerous triggers of air pollution within this
area (ie: Route 24, Route 495, Elm Street Industrial District, Cities (Brockton and

Taunton)) and the fact that the proponent is looking to increase vehicle trips per day by
4,262 and wastewater by 122,385 gallons per day, further studies (ex: air modeling data
& wastewater studies) should be done to verify impact to determine if enhanced
analysis and mitigation is necessary. Please take note of Figure 5 that illustrates air
pollution in the area on June 9, 2022.
The proposed Project Site is not anticipated to exceed MEPA air quality thresholds or
generate more than 150 diesel truck trips per day. Therefore, it is not necessary to identify
EJ populations within five miles of the Site.
LNAFT.12 A large portion of the Eastern site is located within Flood Zone A (FEMA). A functioning
floodplain is important for the surrounding ecosystem. The proponent is planning to
work within the 100-foot buffer zone of the wetlands surrounding the development.
Any work within the 100-foot buffer zone should be prohibited due to impacts on the
wetlands that feed into Lake Nippenicket and the Town River, an integral part of the
Hockomock Swamp.
The Proponent will seek an Order of Conditions from the Bridgewater Conservation
Commission for the proposed work within the Buffer Zone and abide by any conditions of
approval.
LNAFT.13 The two listed archaeological sites, the Bassett Site (19-PL-497) and Tomb Road Area B
Site (190-PL-498) will be destroyed and replaced with a short-stay hotel and residential
community. According to the Massachusetts Historical Commission, archaeological
sites in the vicinity of these wetlands are known to span 9000 years. A Memorandum
of Agreement has been prepared by the MHC that allows the destruction of the site
under certain conditions as noted in the National Historic Preservation Act of 1966. It is
not clear whether MEPA now has the authority to encourage the preservation of these
sites, as an MOA has been signed, however, it should be encouraged.
As stipulated in the MOA to mitigate the “adverse effects” (36 CFR 800.5 and 950 CMR
71.05(a)) of proposed development on significant archaeological resources in the
Lakeshore Center project area, a data recovery program has been implemented and
archaeological fieldwork completed on the Bassett and Tomb Road Area B sites by the
Proponent’s consultant, The Public Archaeology Laboratory, Inc. (PAL). Analysis of
recovered cultural materials and other categories of archaeological information and

From: Eileen Hiney
Subject: Lake Shore Center Phase 4
Date: Tuesday, June 14, 2022 11:47:14 AM
Attachments: MEPACommentltr6_14_22.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 Ms. Patel,
It was nice to meet you last week on the site visit. Please find the comments of the
Bridgewater Open Space Committee on this project.
Eileen Hiney, Chair

Bridgewater Open Space Committee
June 14, 2022
Subject: EEA Project #16558; Lake Shore Center Phase 4, Bridgewater
Dear Ms. Patel:
The Bridgewater Open Space Committee (OSC)* submits that elements of the above-referenced project BOSC.01
will harm the natural resources of the project area and are inconsistent with the 2017 Bridgewater Open
Space Plan and the ACEC status of the area. We strongly oppose the construction of a restaurant on the
shore of Lake Nippenicket, the part of the proposal that was not previously subject to MEPA review.
The Bridgewater Open Space Plan identifies, among its Goals and Objectives, the following
(https://www.bridgewaterma.org/DocumentCenter/View/2158/Bridgewater-OSRP-2017-
Update_FINAL_FOR-STATE-APPROVAL_082018):
Goal 5. To protect and preserve environmentally sensitive areas that promote local and regional
ecological and environmental integrities.
Objectives: 1. Improve water quality of rivers and other surface water bodies
A restaurant will not protect and preserve Lake Nip, an environmentally sensitive area. On the contrary,
it will lead to degradation of its waters, disruption of its shoreline, possible impacts to wildlife, and
impaired views of the Lake. Whatever mitigation or local requirements and restrictions might be
imposed on a permitted restaurant, they will not eliminate the harm from construction and operation of
a restaurant including, runoff, litter, noise, lighting, and impacts on the stream that flows into the Lake
at this location. Of great significance is the fact that Lake Nippenicket shoreline parcels are among
properties included in the Hockomock Swamp ACEC. The ACEC designation, which was achieved largely
through the work of interested Bridgewater citizens and officials, was granted by the Secretary of
Environmental Affairs in 1990. The purpose of an ACEC designation is the “long term preservation, BOSC.02
management, and stewardship of critical resources and ecosystems”. A restaurant at this location is
clearly inconsistent with this purpose.
In addition, the Bridgewater 2017 Open Space Plan identifies a number of potential Scenic Ways
including Lakeside Drive along the edge of Lake Nippenicket. While these “ways” do not have additional
regulatory protection based on their recognized scenic value, they nonetheless, have been recognized
through the Town’s planning processes as worthy of protection. A restaurant on the edge of the Lake BOSC.03
will impede scenic views of the Lake for everyone except the restaurant patrons.
Thank you for your consideration of our comments.
Respectfully submitted,
Bridgewater Open Space Committee

Eileen Hiney, Chair
Nicole Holmes
Kevin Mandeville
Maureen Minasian
Lauren Webb
* The Open Space Committee advises and otherwise assists the Town Manager on the preservation of open space,
and updating the Open Space Plan. The Committee evaluates opportunities for the acquisition and protection of
open space parcels against a number of criteria, including whether the Town’s acquisition of the parcel would (i)
help preserve Bridgewater’s character, (ii) protect Bridgewater’s water resources, (iii)abut or conjoin existing
conservation lands, (iv) provide public access for walking, biking or other passive recreation, (v) preserve or
enhance distinctive streetscapes, views or vistas, or (vi) preserve important wildlife and/or vegetation habitat. To
this end, the Committee works with Town residents, local officials, state and federal agencies, and private
nonprofit land conservation organizations to further these open space objectives. The Committee advises the
Town Manager on the development and content of the Open Space Plan. The Open Space Committee is an
advisory committee in the Town.
BRIDGEWATER OPEN SPACE COMMITTEE
BOSC.01 The Bridgewater Open Space Committee (OSC)* submits that elements of the above-
referenced project will harm the natural resources of the project area and are
inconsistent with the 2017 Bridgewater Open Space Plan and the ACEC status of the
area. We strongly oppose the construction of a restaurant on the shore of Lake
Nippenicket, the part of the proposal that was not previously subject to MEPA review.

wildlife habitat of the general area. Please refer to Chapter 6 for additional information.
As stated on Mass.gov, “Projects within an ACEC that are subject to state agency
jurisdiction or regulation, particularly those that are initiated by an agency, require a state
permit, or are funded by a state agency, are reviewed with closer scrutiny to avoid or
minimize adverse environmental impacts.” In this regard, the ACEC designation does not
prohibit development and as required by ACEC guidelines, the Proponent will limit or
avoid adverse environmental impacts to the greatest extent possible. Please refer to
Chapter 6 for additional information.
BOSC.02 The ACEC designation, which was achieved largely through the work of interested
Bridgewater citizens and officials, was granted by the Secretary of Environmental
Affairs in 1990. The purpose of an ACEC designation is the “long term preservation,
management, and stewardship of critical resources and ecosystems”. A restaurant at
this location is clearly inconsistent with this purpose.

wildlife habitat of the general area. Please refer to Chapter 6 for additional information.
BOSC.03 In addition, the Bridgewater 2017 Open Space Plan identifies a number of potential
Scenic Ways including Lakeside Drive along the edge of Lake Nippenicket. While these
“ways” do not have additional regulatory protection based on their recognized scenic
value, they nonetheless, have been recognized through the Town’s planning processes
as worthy of protection. A restaurant on the edge of the Lake will impede scenic views
of the Lake for everyone except the restaurant patrons.

The proposed restaurant on the Northern Lot will be reviewed by the Town Council and
the Planning Board and its design will need to adhere to the requirements of all local
approvals.

TAUNTON RIVERWATERSHEDALLIANCE
A VOICEFORTHERIVERSINCE1988
June 14, 2022
Purvi Patel
MEPA Office
100 Cambridge St., Suite 900
Boston, MA 02114
Re: EEA No 16558: ENF : Lake Shore Center Phase 4 (Bridgewater)
Dear Ms. Patel:
On behalf of the Taunton River Watershed Alliance (TRWA) and the membership we represent including many who
reside within the Town of Bridgewater, we are writing to urge that the Secretary of EEA extend the public comment
period a minimum of 30 days to allow the public additional time to review this complex multi-phase project which has
significant potential to adversely affect the headwaters watershed of Lake Nippenickett , Lake Nippenicket itself and the
Town River, a primary tributary of the Wild and Scenic Taunton River. As discussed below, there are many reasons to
question this major project in such a small vulnerable headwaters watershed which is already suffering adverse impacts
from previously completed project phases. There is a need for greater information for adequate review by both
interested citizens and public agencies.
TRWA.01
TRWA requests that MEPA approval not be granted for this project until more is known about:
x The environmental impact of the phases of development completed to date, the stormwater pollution load
generated by the project’s phases completed to date (particularly the phosphorus load to the perennial stream
on site, Lake Nippenickett and the Town River),
x Pollutant loads (particularly phosphorus load) projected to be generated from each proposed phase of new
development,
x Analysis/assessment of the current state of eutrophication of the perennial stream on site, Lake Nippenickett
and the Town River, along with an analysis of the assimilative capacity (if any) of these waterbodies to accept
the additional loadings from the proposed phases.
Since 1988, the Taunton River Watershed Alliance (TRWA) has been a voice for the 562 square mile Taunton River
watershed which extends from Mount Hope Bay in Fall River to the City of Brockton, including all or parts of 43 cities
and towns. We are an advocate for environmental protection, sustainable development, and responsible stewardship
of our precious water resources. We are an Alliance of concerned residents, businesses, and organizations united to
restore and properly manage water and related natural resources within the Taunton River Watershed.
Our Mission: ... to protect and restore the watershed's natural resources for current and future generations.
Taunton River Watershed Alliance, at Sweets Knoll State Park, 1387 Somerset Ave., (Rt. 138), Dighton
Mailing address: P.O. Box 1116, Taunton, MA 02780 • 508 -828-1101 • www.savethetaunton.org
The purposes of the Alliance are:
x To protect and restore the watershed’s natural resources for current and future generations
x To build and support responsible stewardship of fragile ecosystems, water quality, forests, farmland, and
wetlands
x To provide opportunities for people to enjoy the river and the watershed’s open space
x To be an integral resource for environmental education and be voice for threatened land and water resources.
The residents of the area report and have pictures of significant eutrophication (algae, weed growth, impaired
transparency) in Lake Nippenickett. This is not surprising due to the low water depth and large surface area of the lake
along with the significant development which has taken place in this small sub watershed. We believe the Lake has
reached and indeed exceeded its assimilative capacity to absorb additional phosphorus and pollution from stormwater.
It is not good enough for the applicant to vaguely propose to meet state stormwater rules that are not designed to
address atypical water quality limited waters. This is why MEPA review is so important.
We believe that stormwater management, including remediation of existing inadequate stormwater controls from
TRWA.02
previous phases, should assure no discharge of stormwater to the perennial stream, Lake Nippenickett and ultimately
the phosphorus impaired Town River which the Town of Bridgewater is being required to install advanced treatment
phosphorus controls to address. Pervious pavement, infiltration best management practices (BMPs) such as gravel
wetlands, redirection of BMP overflows from the Lake watershed, minimization of impervious cover in project design,
weekly vacuuming of impervious roadways and parking areas to remove sediment and phosphorus deposition,
collection of roof runoff and storage for landscape irrigation and other measures are needed and should be detailed TRWA.03
before MEPA approval.
As far back as 1978, in a report titled Route 495 Areawide Approach to Growth, Part II, the Southeastern Regional
Planning and Economic Development District (SRPEDD) identified the necessity to provide guaranteed protection of the
Hockomock and Titicut Swamps, Lake Nippenicket, and the adjoining wetlands from the potential impacts of
development (this document was in fact submitted with the original Hockomock Area of Critical Environmental Concern
– ACEC - nomination in June of 1989). The area of the proposed development lies in the ACEC of the Hockomock Swamp
as well as inside the Zone II aquifer for Town of Raynham drinking water wells. It requires special protection, not the
additional creation of up to 14 acres of impervious surface, much of which is on the additional parcel located on the
north side of Pleasant Street where a restaurant and parking lot is proposed immediately adjacent to Lake Nippenickett.
This is antithetic to an ACEC especially on a Lake and bordering wetlands which feed the Town River, a headwater of the
Wild and Scenic Taunton River. This area should not be developed but instead be utilized as open space. The “no build
alternative” is the best alternative in this case. Loss of pervious surfaces and vegetation does in fact create susceptibility
to climate change in opposition to proponents’ argument. TRWA.04
The proponent intends to use Massachusetts State Stormwater Standards which require only 80% removal of total
TRWA.05
suspended solids. Solids that can carry nitrates, phosphates and oil from runoff into surface water. Because of the
sensitivity of the Lake Nippenickett area, higher standards should be in effect and periodic testing of best management
standards (i.e. deep sump catch basins, oil/grit separators, sediment forebays) as well as where proponent intends to
install them should be subject to review and required to be tested to ensure no impact to the perennial stream,
wetlands and Lake Nippenickett. This should be included in the Operation and Management Plan prepared for the TRWA.06
project. Additionally, any fill material trucked in from off-site sources should be tested at a 1/200 ton ratio and included
with clean certifications of the fill material’s origin.
2
Also, we ask that the proponent describe the specific mitigation measures to prevent disturbance and destruction of TRWA.07
significant archaeological resources identified on the site. Although the proponent has been in consultation with the
federally recognized Wampanoag Tribe, the Taunton River Stewardship Council also recognizes and respects the culture
and heritage landscapes of all indigenous peoples in the watershed, including the Massachuset Tribe, who also
populated areas in the Bridgewaters; the Sagamore should at the very least be notified of this proposed development.
Because of the damage that has been done from existing development in the Nippenickett Lake watershed and large TRWA.08
amount of existing stressors, no exceptions to state recommended buffer requirements should be approved for any part
of the proposed phases. The project adjacent to the Lake on the North side of 104 should be abandoned. The existing
structures on this location should be removed and the land deeded to the Town of Bridgewater for a park adjacent to TRWA.09
the existing boat ramp to mitigate the harm from the current development North of Route 104 and any adverse effects
from the new proposed phases despite taking the measures suggested here.
We believe the applicant should be required to conduct a monitoring program (2/month, April through October) of the
perennial stream and the Town River at 2 to 3 locations above the Bridgewater wastewater treatment plant for total TRWA.10
phosphorus, chlorophyll-a, blue green algae, nitrate-N, E. coli bacteria, temperature, pH, specific conductivity and TRWA.11
chlorides. A sampling program for Lake Nippenickett should be developed in consultation with the MassDEP Watershed
Planning Program. Representative locations recommended by MassDEP such as near route 104, the Town River outlet
and several locations in the lake should be sampled 2 times per month for transparency (Secchi Disk), dissolved oxygen,
total phosphorus, nitrate-N, chlorophyll-a, blue green algae, temperature, pH, and specific conductivity at depths and
final locations recommended by MassDEP. The applicant should consult with the MassDEP Watershed Planning Program
and obtain a Quality Assurance Project Plan (QAPP) approval for this monitoring program. Each year a summary report
with data interpretation and analysis should be submitted to the Town or Bridgewater, MassDEP Planning Program and
TRWA.12
placed on a website for citizen access.
For the reasons stated above Taunton River Watershed Alliance, Inc. (TRWA), the Wild & Scenic Taunton River
Stewardship Council (TRSC) and SRPEDD request that a MEPA approval not be granted until more information is
available concerning this project.
Sincerely,
Joseph Callahan
Joseph Callahan
President, Taunton River Watershed Alliance
Bill Napolitano
Bill Napolitano
Rivers, Trails and Watersheds Coordinator
Southeastern Regional Planning and Economic Development District (SRPEDD)
Donna Desrosiers
Co-Chair, Taunton River Stewardship Council (TRSC)
3
cc: via email to,
Kathleen A. Theoharides, Secretary EOEEA

Thelma Murphy, EPA Region 1
Mark Voorhees, EPA Region 1
Laura Schifman, MassDEP
Richard Carey, MassDEP
Dan Arsenault, EPA Region 1
Helen Zincavage, Southeastern Regional Planning & Economic Development District
Kate McPherson, Save the Bay
Heidi Ricci, Massachusetts Audubon
Danielle Perry, Massachusetts Audubon
Jamie Fosburgh, National Park Service, Wild and Scenic River Program
Paul M. Maniccia U.S. Army Corps of Engineers
Edward Reiner, EPA Region 1
David Paulson, Mass Wildlife
Massachusetts Archeological
Massachusetts Historical Commission
4
TAUNTON RIVER WATERSHED ALLIANCE
TRWA.01 TRWA requests that MEPA approval not be granted for this project until more is known
about: - The environmental impact of the phases of development completed to date,
the stormwater pollution load generated by the project’s phases completed to date
(particularly the phosphorus load to the perennial stream on site, Lake Nippenickett
and the Town River) - Pollutant loads (particularly phosphorus load) projected to be
generated from each proposed phase of new development - Analysis/assessment of
the current state of eutrophication of the perennial stream on site, Lake Nippenickett
and the Town River, along with an analysis of the assimilative capacity (if any) of these
waterbodies to accept the additional loadings from the proposed phases.
The proposed Project will be reviewed by the Bridgewater Conservation Commission. The
proposed stormwater management system will be designed in full compliance with
MassDEP Stormwater Management Standards and will include BMPs to address TSS and
other pollutants.
TRWA.02 We believe that stormwater management, including remediation of existing

inadequate stormwater controls from previous phases, should assure no discharge of
stormwater to the perennial stream, Lake Nippenickett and ultimately the phosphorus
impaired Town River which the Town of Bridgewater is being required to install
advanced treatment phosphorus controls to address.
The proposed Project will be reviewed by the Bridgewater Conservation Commission. The
proposed stormwater management system will be designed in full compliance with
MassDEP Stormwater Management Standards and will include BMPs to address TSS and
other pollutants.
TRWA.03 Pervious pavement, infiltration best management practices (BMPs) such as gravel
wetlands, redirection of BMP overflows from the Lake watershed, minimization of
impervious cover in project design, weekly vacuuming of impervious roadways and
parking areas to remove sediment and phosphorus deposition, collection of roof runoff
and storage for landscape irrigation and other measures are needed and should be
detailed before MEPA approval.
Please refer to Section 7.3 for a discussion of Construction BMPs, the proposed SWPPP,
and the O&M plan, all of which are designed help protect water quality.
TRWA.04 This area should not be developed but instead be utilized as open space. The “no build
alternative” is the best alternative in this case. Loss of pervious surfaces and vegetation
does in fact create susceptibility to climate change in opposition to proponents’
argument.

Comment noted. The proposed Project is not expected to adversely impact the
Hockomock ACEC. Please refer to Chapter 6 for a discussion of the Hocokomok’s
resources. It is important to note that an ACEC designation “does not supersede local
regulations or zoning, change or affect land ownership, allow public access on private
property, or prohibit or stop land development.
TRWA.05 The proponent intends to use Massachusetts State Stormwater Standards which
require only 80% removal of total suspended solids. Solids that can carry nitrates,
phosphates and oil from runoff into surface water. Because of the sensitivity of the Lake
Nippenickett area, higher standards should be in effect and periodic testing of best
management standards (i.e., deep sump catch basins, oil/grit separators, sediment
forebays) as well as where proponent intends to install them should be subject to
review and required to be tested to ensure no impact to the perennial stream, wetlands
and Lake Nippenickett. This should be included in the Operation and Management Plan
prepared for the project.
The Project will be designed to be in full compliance with MassDEP Stormwater

Management Standards. An O&M plan is discussed in Section 7.3.10.
TRWA.06 Additionally, any fill material trucked in from off-site sources should be tested at a
1/200 ton ratio and included with clean certifications of the fill material’s origin.
All fill material will be handled in accordance with applicable regulations.
TRWA.07 Also, we ask that the proponent describe the specific mitigation measures to prevent
disturbance and destruction of significant archaeological resources identified on the
site. Although the proponent has been in consultation with the federally recognized
Wampanoag Tribe, the Taunton River Stewardship Council also recognizes and respects
the culture and heritage landscapes of all indigenous peoples in the watershed,
including the Massachuset Tribe, who also populated areas in the Bridgewaters; the
Sagamore should at the very least be notified of this proposed development.
Comment noted.
TRWA.08 Because of the damage that has been done from existing development in the
Nippenickett Lake watershed and large amount of existing stressors, no exceptions to
state recommended buffer requirements should be approved for any part of the
proposed phases. The project adjacent to the Lake on the North side of 104 should be
abandoned.
Commission for the proposed work within the Buffer Zone. This Order of Conditions will
determine if the proposed work is allowed and, if so, any requirements the Proponent
might have to abide by to protect the wetlands resource area.

TRWA.09 The existing structures on this location should be removed and the land deeded to the
Town of Bridgewater for a park adjacent to the existing boat ramp to mitigate the harm
from the current development North of Route 104 and any adverse effects from the
new proposed phases despite taking the measures suggested here.
The proposed Project is a part of the existing Lakeshore Center Development and the
Proponent is choosing to develop the remaining Lots on the site.
TRWA.10 We believe the applicant should be required to conduct a monitoring program

(2/month, April through October) of the perennial stream and the Town River at 2 to 3
locations above the Bridgewater wastewater treatment plant for total phosphorus,
chlorophyll-a, blue green algae, nitrate-N, E. coli bacteria, temperature, pH, specific
conductivity and chlorides.
Comment noted. The Proponent will file a Notice of Intent with the Bridgewater
Conservation Commission and comply with all requirements of the Order of Conditions
once issued.
TRWA.11 A sampling program for Lake Nippenickett should be developed in consultation with the
MassDEP Watershed Planning Program. Representative locations recommended by
MassDEP such as near route 104, the Town River outlet and several locations in the lake
should be sampled 2 times per month for transparency (Secchi Disk), dissolved oxygen,
total phosphorus, nitrate-N, chlorophyll-a, blue green algae, temperature, pH, and
specific conductivity at depths and final locations recommended by MassDEP.
once issued.
TRWA.12 The applicant should consult with the MassDEP Watershed Planning Program and
obtain a Quality Assurance Project Plan (QAPP) approval for this monitoring program.
Each year a summary report with data interpretation and analysis should be submitted
to the Town or Bridgewater, MassDEP Planning Program and placed on a website for
citizen access. For the reasons stated above Taunton River Watershed Alliance, Inc.
(TRWA), the Wild & Scenic Taunton River Stewardship Council (TRSC) and SRPEDD
request that a MEPA approval not be granted until more information is available
concerning this project.
once issued.



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Comment Details

16558 gary 90 Goodwater Way --

5-31-2022 abrams -- Individual

6-14-2022 -- MASSACHUSETTS Opened

Purvi Patel, (617)874-0668,
purvi.patel@mass.gov ga1960boston@yahoo.com 02324
Topic: I am against it
Comments
As a neighbor and resident of this proposed project,I am against this much additional construction in the area.
The tra¨c impact,the environmental impact,the noise impact and light pollution have already taken their toll on the area around lake Nippenicket.The road,which is already in bad disrepair cannot handle the
additional tra¨c.
Taking wetlands for development is horrible for the wildlife and nature in general.
Another hotel?A cafe(so what does that mean?Dunkin or Starbucks?-So much tra¨c in and out),A 3RD apartment complex and an assisted living facility(Ambulances coming and going all day,every day)plus
another 160 unit condo building too?
And the proposed Restaurant???So its ok for them to build on the lake but not for anyone that lives there already?
Will the developer been required to improve the roadway on Pleasant st?It should and also it should be required to pay for improvements to ALL the roads surrounding the lake as well!At the very least this would GAbrams.01
be something for the residents to get as an incentive to be more welcoming to all the work proposed!
Everyone who bought a house on the lake did so because of the serene and beautiful area,we ALL pay taxes too but it seems as though we get ZERO consideration in return.This is especially true of the area
around the lake on the west side of rt 24,seems like the town doesnt care about it and the impact it has on the residents at all.
Does every square yard of area NEED to be developed?Please consider the tax paying residents of the lake area before you decide to rubber stamp everything this company wants! GAbrams.02
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GARY ABRAMS
GAbrams.01 Will the developer been required to improve the roadway on Pleasant St? It should and
also it should be required to pay for improvements to ALL the roads surrounding the
lake as well! At the very least this would be something for the residents to get as an
incentive to be more welcoming to all the work proposed!
Pleasant Street is controlled by MassDOT. The Proponent will abide by the terms of the
Access Permit issued by MassDOT for the proposed Project.
GAbrams.02 Does every square yard of area NEED to be developed? Please consider the tax paying
residents of the lake area before you decide to rubber stamp everything this company
wants.
The Project will leave approximately 33.5 acres undeveloped, and the Proponent is
studying the feasibility of placing a deed restriction, or similar land preservation
mechanism, on the property to restrict future development from occurring.

@. Energy & Environmental Affairs

(https://www.mass.gov/orgs/executive-office-of-energy-and-environmental-affairs)

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Comment Details

16558 Nancy 90 Goodwater Way --

5-31-2022 Abrams -- --


Purvi Patel, (617)874-0668,
purvi.patel@mass.gov ndmom94@yahoo.com 02324
Topic: Environmental and historical impacts
Comments
NAbrams.01
This area is highly congested with tra¨c ever since the condos went in, putting in more condos etc is only going to make the tra¨c worse. I do wish a tra¨c study would happen before approval. This project
also has a very high impact on wildlife that are already losing homes because of the current construction. Lastly, an historic archeological structure will be destroyed. Please consider the environment and the
history of this land before destroying it. NAbrams.02
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NANCY ABRAMS
NAbrams.01 This area is highly congested with traffic ever since the condos went in, putting in more
condos etc. is only going to make the traffic worse. I do wish a traffic study would
happen before approval.
The DEIR includes a Transportation Impact Assessment. Based on the capacity analysis,
the Project is shown to result in a limited increase in delay to the study area intersections.
The overall delay at the intersections of Pleasant Street at the Route 24 Ramps are
anticipated to increase by approximately 3 seconds from No-Build to Build conditions,
showing the minimal impact.
Nabrams.02 This project also has a very high impact on wildlife that are already losing homes
because of the current construction. Lastly, an historic archeological structure will be
destroyed. Please consider the environment and the history of this land before
destroying it.


From: Jean DiBattista
Subject: #16558 - Lake Shore Center Phase 4 Proposed Project
Date: Saturday, June 4, 2022 11:05:15 AM

Dear Purvi:
I recently submitted some comments regarding the above project via the online
portal, and wanted to add more concerns to those I have already provided to you via
that method. For your convenience, I have included those comments with the ones
listed below so you can just view one document (this email) to see everything.
In general, I am concerned about the above project and its impact on Lake
Nippenicket and the surrounding areas/neighborhoods. My concerns about the
Planned Lake Shore Center Phase 4 Project include the following:
ENVIRONMENT: It substantially impacts an Area of Critical Environmental Concern,
the Hockomock Swamp, including Lake Nippenicket and its nearly wetlands. The
project site also falls within mapped rare species habitat and I am concerned about
the impact that this project will have on the surrounding wildlife.
TRAFFIC: It involves a large increase in traffic on Route 104 (estimated by Claremont

to be 4,262 extra trips per day) impacting surrounding neighborhoods, and all
members of the public which would like to use the lake for peaceful recreation. It
should be noted, that for some surrounding neighborhoods, Route 104 represents DiBattista.01
the only way in and out of the neighborhood, and access to the public boating dock
by members of the public is also dependent on access to Route 104. In addition, it
directly impacts the commuting route of all individuals in the local area who must
use Route 104 to get to Route 24 and connecting highways to go to work.
WATER USAGE: It involves a large increase in water usage and Bridgewater is

already on "Restricted Water Usage". In addition, during the seven year
construction phase, I am concerned that water will be turned off multiple times. DiBattista.02
NOISE: The project will likely increase noise substantially (due to increased traffic
and restaurant activity) which will have a significant impact on the activities of local
wildlife and the quality of life of all nearby residents and all members of the public
whom would like to use the lake for peaceful recreation.
WASTE/TRASH – I am concerned that specific aspects of this project will increase DiBattista.03
waste and trash in the overall area and find its way into Lake Nippenicket and
surrounding neighborhoods and areas.
POLLUTION – Increased air pollution may also be generated by the large number of
cars that will need to use a two-lane road. I believe this will impact the health and
enjoyment of the lake by members of the community and public.
LAND ALTERATION - A substantial amount of open space will be destroyed by the

project, impacting the beauty of the lake, surrounding areas, and possibly setting the
stage for additional climate change impacts to the immediate area.
ARCHAEOLOGICAL HISTORICAL SITE DESTRUCTION – Two sites of archaeological

historical significance will be destroyed.
OPEN SPACE: Finally, I also dispute this statement made by Claremont in the ENF
Document/Report: “The open space at the Project Site is not useable as it is along DiBattista.04
a busy corridor between Route 24 and Route 495.” This space could be used to
support additional recreational activities for the adjacent Boat Ramp/Parking Lot
area by adding additional space for members of the community to picnic and walk.
Many of us chose to live here because of the area’s beauty and open space.
Thank you for your consideration of my comments and concerns.
Please acknowledge receipt of this email.
Warm Regards,
Jean DiBattista


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Comment Details

16558 Jean -- To MEPA

6-1-2022 DiBattista -- Individual


Purvi Patel, (617)874-0668,
purvi.patel@mass.gov jcdibattista@gmail.com 02324
Topic: Lake Shore Center Phase 4
Comments
I am concerned about the above project and its impact on Lake Nippenicket and the surrounding areas/neighborhoods.Á My concerns include the following:
It substantially impacts an area of critical environmental concern.Á
It involves a large increase in water usage and Bridgewater is already onÁ "Restricted Water Usage".
It involves a large increase in tra¨c on Route 104 (estimated by Claremont at 4,262 extra trips per day) impacting surrounding neighborhoods, and all members of the public which would like to use the lake for
peaceful recreation.Á It should be noted, that for some surrounding neighborhoods, Route 104 represents the only way in and out of the neighborhood, and access to the public boating dock by members of the
public is also dependent on access to Route 104.ÁÁ
It involves a large increase in noise and light especially because of the planned restaurant and tra¨c which would impact both wildlife and the quality of life of all nearby residents and all members of the public
which would like to use the lake for peaceful recreation.Á ÁThis noise and light most likely would also have signi¦cant impacts on wildlife such as the turtles that are currently laying eggs in this area, nesting DiBattista.05
birds, etc.
It impacts two historical sites.
Sincerely,
Jean DiBattista
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JEAN DIBATTISTA
DiBattista.01 It should be noted, that for some surrounding neighborhoods, Route 104 represents the
only way in and out of the neighborhood, and access to the public boating dock by
members of the public is also dependent on access to Route 104.
DiBattista.02 It involves a large increase in water usage and Bridgewater is already on "Restricted
Water Usage". In addition, during the 7-year construction phase, I am concerned that
water will be turned off multiple times.
systems. Additionally, the Proponent does not anticipate that construction will require
any water shut-offs to other parts of the Town of Bridgewater. Please refer to Section 8.2
for additional information on the proposed water conservation measures.
DiBattista.03 I am concerned that specific aspects of this project will increase waste and trash in the
overall area and find its way into Lake Nippenicket and surrounding neighborhoods and
areas
The Project design includes waste and recycling facilities to appropriately process the
waste and recycling generated by the various proposed uses.
DiBattista.04 Finally, I also dispute this statement made by Claremont in the ENF Document/Report:
“The open space at the Project Site is not useable as it is along a busy corridor between
Route 24 and Route 495.” This space could be used to support additional recreational
activities for the adjacent Boat Ramp/Parking Lot area by adding additional space for
members of the community to picnic and walk. Many of us chose to live here because
of the area’s beauty and open space.
Comment noted. The statement in the ENF was referring primarily to the wooded areas
of Lots 6 and 7 which are surrounded by highways.
DiBattista.05 It involves a large increase in noise and light especially because of the planned
restaurant and traffic which would impact both wildlife and the quality of life of all
nearby residents and all members of the public which would like to use the lake for
peaceful recreation. This noise and light most likely would also have significant impacts
on wildlife such as the turtles that are currently laying eggs in this area, nesting birds,
etc.

The Project is not anticipated to generate a significant amount of noise and light.
Furthermore, the Project will abide by local and state noise ordinances.

From: Robert DiBattista
Subject: #16558 - Lake Shore Center Project
Date: Saturday, June 4, 2022 11:32:48 AM

Hello Purvi, I would like to express my concerns for the proposed expansion of the Lake
Shore Center project #16558. This expansion would put a tremendous amount of stress on the
already fragile environmental conditions here. The proposed expansion would further destroy
the existing ecological conditions.
R.DiBattista If you visit the site please survey the water level in the Lake. It has already been reduced to no
more than a deep puddle at this time. We must stop destroying these last few critical
environmental areas just to build another hotel or this last nature rich area will disappear.
Thank you for you time,

Robert DiBattista
ROBERT DIBATTISTA
R.DiBattista If you visit the site please survey the water level in the Lake.
Comment noted.

From: sbaumgarten@verizon.net
Subject: Lakeshore Center Phase 4
Date: Monday, June 6, 2022 3:49:47 PM

Dear Ms. Patel,
Comments re: Lakeshore Center Phase 4 Proposal:
I will expand on the comments I made at today’s Zoom meeting. First, from the
philosophical side, with a somewhat cynical bent: Why allow a project of this size in
an area designated as an “ACEC,” which is meant to “protect important historical,
cultural, and scenic values, or fish and wildlife or other natural resources?” Despite
the “mitigations,” this project cannot really protect anything. And, frankly, when I see
the word “mitigations” used multiple times in a report, meaning tons of exceptions are
needed to go forward with the project, I know there are problems.
Secondly, and more specifically, 3,000 plus “adts” will have huge impacts on traffic.
Rt. 104, from the highway into Town, is already backed up during rush hours. The Baumgarten.01
additional “adts” will worsen these backups. And, as someone else commented,
turning left out of Lakeside Drive to head east on 104 will become a real challenge
and increasingly dangerous.
Third, regarding water use, there was a Facebook thread today on the Bridgewater
Residents’ Page about households that routinely have brown-colored water. This
issue is raised regularly. Clearly, the Town has a problem with providing clean, clear
water to all of its residents. And yet, this project will add over 130,000 gallons of
water use to the existing demand. That doesn’t bode well for town water quality.
Fourth, how can a restaurant right on the lake not be harmful to the shore area and Baumgarten.02
water quality? The cynic says: This is just so some people can have a place to eat
and watch beautiful sunsets. They don’t care much about the quality of the lake.
Finally, if you were one of the turtles that had to be moved, how would you feel????
Thanks for adding these thoughts to the response file.
Sam Baumgarten
60 Short Street
774-208-2933
SAM BAUMGARTEN
Baumgarten.01 Secondly, and more specifically, 3,000 plus “adts” will have huge impacts on traffic. Rt.
104, from the highway into Town, is already backed up during rush hours. The additional
“adts” will worsen these backups. And, as someone else commented, turning left out
of Lakeside Drive to head east on 104 will become a real challenge and increasingly
dangerous.
Baumgarten.02 Third, regarding water use, there was a Facebook thread today on the Bridgewater
Residents’ Page about households that routinely have brown-colored water. This issue
is raised regularly. Clearly, the Town has a problem with providing clean, clear water to
all of its residents. And yet, this project will add over 130,000 gallons of water use to
the existing demand. That doesn’t bode well for town water quality. Fourth, how can a
restaurant right on the lake not be harmful to the shore area and water quality? The
cynic says: This is just so some people can have a place to eat and watch beautiful
sunsets. They don’t care much about the quality of the lake. Finally, if you were one of
the turtles that had to be moved, how would you feel???? Thanks for adding these
thoughts to the response file.
As stated in the Certificate on the ENF, “According to MassDEP comments, the Town has
the capacity to provide the requested volume for this project based on its renewed Water
Management Act (WMA) permit issued on January 5, 2021 and its recent water use.”
Any potential impacts from the restaurant construction will be appropriately mitigated or
avoided to the greatest extent possible through the MEPA review process.


The Proponent notes this letter but observes

no comments requiring a response.
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Comment Details

16558 Sharon 15 Lakeview Park Lane --

6-9-2022 Cumiskey -- Individual


Purvi Patel, (617)874-0668,
purvi.patel@mass.gov skey1952@comcast.net 02324
Topic: The Nip
Comments
I am very disheartened to learn of the intended addition of more buildings on the lands surrounding Lake Nippenicket.Á This area has already been severely impacted with noise, tra¨c, police calls and loss of
habitat for the few animals left.Á Claremont has not been keeping up their end of the bargain in terms of respecting EPA guidlelines as enforced by our town's Conservation Commission.Á We neighbors
repeatedly have to call as another "new" landscaper comes to clear bush within the no cut zone.Á The police or CC come and we never see that landscaper again- until we see another one.Á They do not regard the
law as applying to them.Á In the same way they don't feel the zoning should apply to them.
Within the last few years our tra¨c has more than doubled.Á Some mornings it can take 10 minutes to get onto Rte 104 from myÁ road.Á The sirens heading to the existing apartment complex at all hours of the
day and night are a major headache- as well as taxing our local ¦re department.Á
As a scientist with access to GIS maps I was able to locate a protected brook and lands around the Nip which held them off for a couple of years, but now they are back wanting to make changes that will line
their pocketbooks without regard to our waters, wildlife or their neighbors.ÁÁ
Please recommend that the zoning not be changed and Claremont be required to follow the law as it is currently written.ÁÁ
Thank you,
Sharon Cumiskey
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From: Donna M Auger
Subject: Development on Lake Nippenicket by the Claremont Corp
Date: Friday, June 10, 2022 4:36:39 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 to voice my concern about this development. I know there are environmental concerns but I am Auger.01
focused on 2 areas. One is 4000 extra cars on Rt24. The road can barely handle the traffic we have now. The second Auger.02
is water usage. We already have a water shortage and elevated PFAS6. Our water is always brown and tastes
terrible. We purchase water for drinking and cooking.
Please consider these as well as the threat to the environment.
Donna Auger
Sent from my iPad

DONNA AUGER
Auger.01 I am writing to voice my concern about this development. I know there are
environmental concerns but I am focused on 2 areas. One is 4000 extra cars on Rt24.
The road can barely handle the traffic we have now.
Auger.02 The second is water usage. We already have a water shortage and elevated PFAS6. Our
water is always brown and tastes terrible. We purchase water for drinking and cooking.
Please consider these as well as the threat to the environment.
The proposed Project is not expected to adversely impact the quality of the town water
supply in any way.



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Comment Details

16558 Linda 15 Sunset Ln --

6-10-2022 Schmuck -- Individual


Purvi Patel, (617)874-0668,
purvi.patel@mass.gov tschmuck@aol.com 02324
Topic: Concern for the wetlands and surrounding community
Comments
ÁAs a neighbor, since 1997, of Lake Nippenicket and the surrounding wetlands I have multiple concerns about the above project. Namely, the alteration of land that will have a signi¦cantÁ impact on the wetlands.
I am concerned that the increase in daily tra¨c will lead to further congestion, noise, pollution and trash in the area. This project will have major impacts on the environment including the wildlife and rare Schmuck.01
species living in the area. I disagree with the destruction of an archaeological historical site. The north side of route 104 is completely residential, putting commercial buildings there will destoy the peace and
beauty of our homes. When are we going to stop destroying this Area of Critical Environmental Concern? Thank you for considering my views and concerns, Linda M. Schmuck
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From: tschmuck@aol.com
Subject: Comments on Lake Shore Center Phase 4
Date: Friday, June 10, 2022 3:08:57 PM

Good Afternoon Purvi,
I have been a resident of the Lake community since 1997. I have many concerns about this new project
and it's impact on the Lake and the neighborhoods. Since the construction of multiple projects by the
Claremont companies, our environment has changed dramatically. Although Claremont professes to be a
good neighbor, they have little concern for our quality of life.
The traffic on Rte.104 has increased dramatically, leading to many accidents. Now, they want to increase
the traffic even further (and extra 4,000 plus trips a day) leading to more congestion, noise pollution and
trash. The amount of trash and water pollution at the lake is disappointing and Claremont does not even
consider it their responsibility to remove the trash accumulated on their own property at the waters' edge.
These Hobomock wetlands are being impacted and altered. We need to be good stewards of the
land. The habitat of the wildlife in the area has also been disturbed. I am not in favor of disturbing the
archaeological historical site, nor am I in favor of any commercial building on the north (lakeside) of Rte.
104. The open space in this community has been and will continue to be dramatically reduced if this
project is allowed to go through as proposed.
Thank you for taking the time to consider my concerns.
Sincerely, Linda
Linda M. Schmuck
15 Sunset Ln
LINDA SCHMUCK
Schmuck.01 As a neighbor, since 1997, of Lake Nippenicket and the surrounding wetlands I have
multiple concerns about the above project. Namely, the alteration of land that will have
a significant impact on the wetlands. I am concerned that the increase in daily traffic
will lead to further congestion, noise, pollution and trash in the area. This project will
have major impacts on the environment including the wildlife and rare species living in
the area. I disagree with the destruction of an archaeological historical site. The north
side of route 104 is completely residential, putting commercial buildings there will
destroy the peace and beauty of our homes. When are we going to stop destroying this
Area of Critical Environmental Concern? Thank you for considering my views and
concerns
The Project is not anticipated to result in permanent or temporary impacts to the wetland
resource areas on the property. The Proponent will seek an Order of Conditions from the
Bridgewater Conservation Commission for the proposed work within the Buffer Zone. This
Order of Conditions will determine if the proposed work is allowed and, if so, any
requirements the Proponent might have to abide by to protect the wetlands resource
area
at the Route 24 Ramps are anticipated to increase by approximately three seconds from

Regarding the Northern Lot within the Project Site, this area is mapped as Priority Habitat
for the aquatic plants, Plymouth Gentian (Sabatia kennedyana) and the round-fruited
seedbox (Ludwigia sphaerocarpa). The Proponent has filed a MESA Checklist with NHESP
to confirm whether or not the proposed Project will result in a take of either species.
NHESP has issued a “No-Take” letter dated November 18, 2022, which confirms that the
proposed Project will not result in a take and that no Conservation Management Permit
will be required for this portion of the Project.

From: Evelyn DeLutis
Subject: Bridgewater Nip area
Date: Saturday, June 11, 2022 7:42:40 PM

Sat, June 11th, 2022. I am writing as a long time Bridgewater
resident and dependable voter with my serious concerns about the
proposed Lakeshore project.
Presently our town is struggling with water quality. It truly needs DeLutis.01
to be addressed before any more building projects are initiated.
We also have to deal with more than the typical traffic for a town
due to the University in the town which brings traffic into and out
of the town year round. Many of the back roads (this 2 lane road
is one) tend to be used due to the traffic backups on the main
roads.
My personal concern is for this historical area of the town and the
archeology that happens constantly as well as through the
University which will be disrupted with the plans of Lakeshore.
The Nip being a source of recreation will suffer as a result of less
parking for boaters and fishing as well as trash and waste.
Our town has been becoming more and more built up with less
and less open space for animals and open space for the simple
enjoyment of people.
Consequently, I am asking that all of the above be considered
before any decision is made about the Lakeshore Project. Thank
you for hearing my opinion. Sincerely, Evelyn DeLutis
May we say yes to healing with our signatures, our prayers, our
voices, our action, our doing justice and loving mercy and walking
humbly. - Ashlee Eiland
EVELYN DELUTIS
Delutis.01 Presently our town is struggling with water quality. It truly needs to be addressed
before any more building projects are initiated. We also have to deal with more than
the typical traffic for a town due to the University in the town which brings traffic into
and out of the town year-round. Many of the back roads (this 2-lane road is one) tend
to be used due to the traffic backups on the main roads. My personal concern is for this
historical area of the town and the archeology that happens constantly as well as
through the University which will be disrupted with the plans of Lakeshore. The Nip
being a source of recreation will suffer as a result of less parking for boaters and fishing
as well as trash and waste. Our town has been becoming more and more built up with
less and less open space for animals and open space for the simple enjoyment of people.
Consequently, I am asking that all of the above be considered before any decision is
made about the Lakeshore Project. Thank you for hearing my opinion.
The proposed Project is not expected to affect the water quality of the town’s water
supply in any way.
anticipated to increase by approximately 3 seconds from No-Build to Build conditions,
showing the minimal impact
The proposed Project will not reduce parking for users of the boat ramp.



View Comment
Comment Details

16558 Julia 27 Bridle Rd --

6-11-2022 Blanchard -- Individual


Purvi Patel, (617)874-0668,
purvi.patel@mass.gov julia.blanchard5310@gmail.com 02324
Topic: Please deny this Request
Comments
I’m writing to express my deep concerns about the proposed Lakeshore Center Phase 4 project. Claremont has already had a negative impact on our quality of life in the neighborhood, and
we don’t need it to get four times worse. Traffic has multiplied shockingly, and wildlife I used see in the area has decreased dramatically. For example, I have not seen the Great Blue Herons
for about 2 years now.
Here is what they want to build:
• A 1-story, approximately 1,800 GSF café shop on Lot 1;
• A 4-story, 225-unit 55+ residential community on Lot 6;
• A 4-story, 102-room hotel, and a 4-story, 160-unit condominium community on Lot 7; and
• A 6,000 GSF restaurant on the north side of Pleasant Street adjacent to Lake Nippenicket.
This huge project would have an incredibly bad impact on the area and our quality of life. It necessarily involves an even bigger increase in traffic on Rt. 104. It’s hard enough to get out of Blanchard.01
the neighborhood now, especially for my morning commute.
We live in a nice peaceful lakeside area and don’t want it to become a commercial center filled with traffic and more and more people. Noise pollution and trash around the lake area are
already becoming a problem. We could not hear the highway before Claremont cut down all those trees, now it sounds like a racetrack. While the increased noise is upsetting to me, I
wonder what impact it has on the local wildlife. This project would increase it even more. It’s just intolerable.
Blanchard.02
The environmental impact of this large project cannot be understated. It involves an Area of Critical Environment Concern, including the Hockomock swamp, Lake Nippenicket,. These Blanchard.03
wetlands are fragile and should not be tampered with. Once you ruin them you can’t get them back again. There are rare and endangered species in that area as well. Blanchard.04
“The Hockomock Swamp is a vast natural and scenic area. Because of its size, it is a unique and irreplaceable wildlife habitat. It is also the location of at least 13
rare and endangered species. According to the Massachusetts Historical Commission, the archaeological sites in the vicinity of this wetland complex are known to
span a period of 9000 years; the potential quality and significance of the archaeological resources are enormous. Productive agricultural lands are located on the
uplands adjacent to the wetlands, brooks, and rivers.”
https://www.mass.gov/service-details/hockomock-swamp-acec(https://www.mass.gov/service-details/hockomock-swamp-acec)
The article above also mentions archaeological sites. The project is proposing to destroy two of these sites in the name of development; the Bassett site and the Tomb Road site, which I’m Blanchard.05
told is from the Viking era. Again, once these sites are bulldozed, they can never be recovered for study and are gone forever.
The Town of Bridgewater cannot handle all these extra residents; water usage in particular is of huge concern. We already have to ration our water and have several issues with PFAs and Blanchard.06
superfluous minerals. This would put an undeniable strain on that as well as other town services such as schools, police, fire, etc.
I urge you to deny this request. We do not need these developments in our town to destroy our beautiful neighborhood on the Lake.
Thank you for your consideration,
Julia A. Blanchard
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JULIA A. BLANCHARD
Blanchard.01 This huge project would have an incredibly bad impact on the area and our quality of
life. It necessarily involves an even bigger increase in traffic on Rt. 104.
Blanchard.02 The environmental impact of this large project cannot be understated. It involves an
Area of Critical Environment Concern, including the Hockomock swamp, Lake
Nippenicket.
prohibit development and, as required by ACEC guidelines, the Proponent will limit or
Chapter 6 for additional information on these efforts.
Blanchard.03 These wetlands are fragile and should not be tampered with.
Commission for the proposed work within the Buffer Zone. This Order of Conditions will
determine if the proposed work is allowed and, if so, any requirements the Proponent
might have to abide by to protect the wetlands resource area.
Blanchard.04 There are rare and endangered species in that area as well.
Please see Section 5.2. The Proponent has filed a MESA Checklist with NHESP to confirm
whether or not the proposed Project will result in a take of either species. NHESP has
issued a “No-Take” letter dated November 18, 2022, which confirms that the proposed
Project will not result in a take and that no Conservation Management Permit will be
required for this portion of the Project.
Blanchard.05 The article above also mentions archaeological sites. The project is proposing to destroy
two of these sites in the name of development; the Bassett site and the Tomb Road site,
which I’m told is from the Viking era. Again, once these sites are bulldozed, they can
never be recovered for study and are gone forever.

Blanchard.06 The Town of Bridgewater cannot handle all these extra residents; water usage in
particular is of huge concern.
The proposed Project will be reviewed by the Bridgewater Planning Board which will
include an evaluation of water usage. Section 8.2 lists the proposed water conservation
measures.

From: Nathalie Berkowitz
Subject: #16558 - Lake Shore Center Phase 4
Date: Sunday, June 12, 2022 2:00:30 PM

Mr. Patel:
We are very concerned about the above project and its impact on Lake Nippenicket and the
neighborhood we chose to live in because of its uniqueness and beauty:
The traffic in this area will be greatly increased. Coming from Lakeside Drive onto Route Berkowitz.01
104 is already a problem, and it is the only way in and out of our neighborhood. There will be
4,262 extra trips by Lakeside Drive per day onto a two lane road;
There will be a large increase in water use, and we have had problems with our water Berkowitz.02
supply in the past. We are already on "Restricted Water Usage";
There will be increased air pollution from the increased number of cars on Route 104; and
The amount of waste and trash will be increased polluting Lake Nippenicket and the
surrounding neighborhoods.
The above concerns will impact the quality of life in this area which we chose because of its
natural beauty and open space. Our health and comfort and home value will be diminished if
this project progresses.
Please consider these strong objections and help us and our neighbors enjoy the quality of life
we worked hard for and choose to maintain.
Sincerely,
Michael and Nathalie Berkowitz

39 Paddock Road
MICHAEL AND NATHALIE BERKOWITZ
Berkowitz.01 The traffic in this area will be greatly increased. Coming from Lakeside Drive onto Route
104 is already a problem, and it is the only way in and out of our neighborhood. There
will be 4,262 extra trips by Lakeside Drive per day onto a 2-lane road;
Berkowitz.02 There will be a large increase in water use, and we have had problems with our water
supply in the past. We are already on "Restricted Water Usage";
measures.

From: Oliveira, Anthony J
Subject: Lake Shore Center Lake Nippenicket Bridgewater, MA - Proposal Comments for Consideration of MEPA Please
Attachments: image001.png
Importance: High

Hello Purvi,
May I please ask for your inclusion of my concerns outline below on the Lake Shore Center -
Lake Nippenicket , Bridgewater, MA plans by Claremont Companies please ?
An environmental notification form ( ENF) has been submitted by Clermont companies to the
Massachusetts environment policy act office for the project that if approved will impact the lake
and the surrounding areas forever.
( 16558- Lake Shore Center Phase 4 )

Oliveira.01
This project if approved what are the effect the lake and it's nearby wetlands. The project site Oliveira.02
falls within mapping of species habitat and surrounding wildlife. The fragile ecosystem that
already exists on the lake will be even more put to the test. Turtles, fish, geese, and ducks all will
cease to exist head instead this restaurant will bring about more congestion waste and trash
pollution and possible rodents due to food waste so near to the borders of the lake.
A large increase to traffic on route 104 estimated by Clermont to be 4.262 extra trips per day will Oliveira.03
impact not only does surrounding neighborhoods and the members of our community but also
the use of peaceful recreation and enjoyment of the gem that is Lake Nip.
The water usage will dramatically be increased for this area which heavily relies on well water Oliveira.04
and will deplete the existing aqueduct that supplies water to many of the homes surrounding
the lake . Also need to stress that Bridgewater as a town is already on a restricted water usage .
The lake already is assaulted during the summer months by visitors from out of town with
boaters and jet skiers who pollute the waters of the lake with oil and gasoline . Having this public
building ( restaurant ) so near to the state boat slip will only increase that population and
destroy the habitat for so many of the wildlife that depend on it for its survival. The wildlife often
is the victim of the speeding boats and jet skis it has not only been once or twice that we have
seen a dead duck or fish wash up on shore after a weekend of jet skiers and speed boats. Having
this project will only encourage more activity on the lake and possibly driving under the
influence boaters and jet skiers to do more damage to its wildlife.
I respectfully ask your office to take these into consideration and please help us to keep this gem
From: Janet Hanson
Hello,
My name is Janet Hanson and reside in Bridgewater, MA not far from the proposed project by Claremnot
Companies.
I am very concerned about the propsed further development on that property especially lot 6 and 7.
As noted in the General Project Description, those two lots are wetlands plus there are in an Archelogical areas Hanson.01
which need to be protected along with what is left of the wetlands.
Even with buffer zones (which in past have been stetched to the limit by this compnay already), the wetland will be
disturbed.
There has already been much building on the entrie property with much habitat being destroyed and encroached
upon to the limit.
To allow them to build in the proposed areas will strain the wetlands and native species.
They are proposing to build a 55+ cimmunity with four floors wwith 25 units per acre. That seems excessive plus if
it is for elderly housing, why would they put them 4 stories high? But this question is probably not within your
juridisication.
The proposed restaurant on the Nip side has been discussed numerous times. They have attempted to put a
restuarunat in by requesting numerous changes to our Planned Development District to make it fit. Even with these
changes it still would not fit. Currently that piece of property is zoned residential. They want to make it PDD but
not enough acres to allow that so they wanted to add their own verbage to have Rt 104 be a right away and add that
property to the larger property to allow it to meet thta acreage . They also want to reduce the water edge buffer zone
to allow the restaurant to over look the water and decrease setback from road to be 35 feet not the 200 feet feet
required.
There was at least 6 proposed changes they wanted the town to do so they could put the restaurant in- none of which
protected the Lake.
The lake is part of the Hockomock Swamp Area of Critical Enviroment Concern )ACEC) as you are fully aware. Hanson.02
To allow this business in the propsed area will be of concern for the water and wildlife in the area not to mention
light and noise pollution.
The amount of building the Claremont VCompany is proposing for what is left of the property seems excessive and
what wetlands and archaeological areas that are left need to be protected.
It will ultimately impact the ACEC areas and traffic will be of concerned.
I implore you to look deeply to the areas of concern and hopefully take everything into consideration and vote
unfavorably to their requests.
Thank you for your time in the sensitive matter.
Janet Hanson and David Hanson

665 Pleasant St
Resident of 43 yrs and 66 yrs
affectionately known as Lake Nip for future generations. She is surrounded on that side of the
lake near Rt 104 by so much that can do harm to her that she needs someone to be her voice.
Please be her voice.
Respectfully,
Anthony Oliveira
35 Birch Hill Road
Raynham, MA 02767
Anthony Joseph Oliveira

Payer Relations Account Manager
Combined Professional Billing Office
617-724-8920 |617-643-7941 Cell 617-653-9224
A MASSACIIUS177 , · IRAL
JlWl PHYSIG~'JS ORG,\NIZt\ ION
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this e-mail was sent to you in error and the e-mail contains patient information, please contact the
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wish to continue to communicate over unencrypted e-mail.
ANTHONY OLIVEIRA
Oliveira.01 This project if approved what are the effect the lake and its nearby wetlands.
area.
Oliveira.02 The project site falls within mapping of species habitat and surrounding wildlife.
Please see Section 5.2. The Proponent has filed a MESA Checklist with NHESP to confirm
whether or not the proposed Project will result in a take of either species. NHESP has
issued a “No-Take” letter dated November 18, 2022, which confirms that the proposed
Project will not result in a take and that no Conservation Management Permit will be
required for this portion of the Project.
Oliveira.03 A large increase to traffic on route 104 estimated by Clermont to be 4.262 extra trips
per day will impact not only does surrounding neighborhoods and the members of our
community but also the use of peaceful recreation and enjoyment of the gem that is
Lake Nip.
Oliveira.04 The water usage will dramatically be increased for this area which heavily relies on well
water and will deplete the existing aqueduct that supplies water to many of the homes
surrounding the lake. Also need to stress that Bridgewater as a town is already on a
restricted water usage.
measures.

From: Janet Hanson
Hello,
My name is Janet Hanson and reside in Bridgewater, MA not far from the proposed project by Claremnot
Companies.
I am very concerned about the propsed further development on that property especially lot 6 and 7.
As noted in the General Project Description, those two lots are wetlands plus there are in an Archelogical areas Hanson.01
which need to be protected along with what is left of the wetlands.
Even with buffer zones (which in past have been stetched to the limit by this compnay already), the wetland will be
disturbed.
There has already been much building on the entrie property with much habitat being destroyed and encroached
upon to the limit.
To allow them to build in the proposed areas will strain the wetlands and native species.
They are proposing to build a 55+ cimmunity with four floors wwith 25 units per acre. That seems excessive plus if
it is for elderly housing, why would they put them 4 stories high? But this question is probably not within your
juridisication.
The proposed restaurant on the Nip side has been discussed numerous times. They have attempted to put a
restuarunat in by requesting numerous changes to our Planned Development District to make it fit. Even with these
changes it still would not fit. Currently that piece of property is zoned residential. They want to make it PDD but
not enough acres to allow that so they wanted to add their own verbage to have Rt 104 be a right away and add that
property to the larger property to allow it to meet thta acreage . They also want to reduce the water edge buffer zone
to allow the restaurant to over look the water and decrease setback from road to be 35 feet not the 200 feet feet
required.
There was at least 6 proposed changes they wanted the town to do so they could put the restaurant in- none of which
protected the Lake.
The lake is part of the Hockomock Swamp Area of Critical Enviroment Concern )ACEC) as you are fully aware. Hanson.02
To allow this business in the propsed area will be of concern for the water and wildlife in the area not to mention
light and noise pollution.
The amount of building the Claremont VCompany is proposing for what is left of the property seems excessive and
what wetlands and archaeological areas that are left need to be protected.
It will ultimately impact the ACEC areas and traffic will be of concerned.
I implore you to look deeply to the areas of concern and hopefully take everything into consideration and vote
unfavorably to their requests.
Thank you for your time in the sensitive matter.
Janet Hanson and David Hanson

665 Pleasant St
Resident of 43 yrs and 66 yrs
JANET AND DAVID HANSON
Hanson.01 As noted in the General Project Description, those two lots are wetlands plus there are
in an Archaeological areas which need to be protected along with what is left of the
wetlands. Even with buffer zones (which in past have been stretched to the limit by this
company already), the wetland will be disturbed.
area.
Hanson.02 The lake is part of the Hockomock Swamp Area of Critical Environmental Concern (ACEC)
as you are fully aware. To allow this business in the proposed area will be of concern
for the water and wildlife in the area not to mention light and noise pollution.
prohibit development and, as required by ACEC guidelines, the Proponent will limit or
Chapter 6 for additional information on these efforts.

From: KELLY-FRANK CANNIZZARO
Subject: EEA #16558 - Lake Shore Center Phase 4, Bridgewater, Claremont Companies

Good evening Purvi,
I would like to voice my concerns regarding this proposed project and the impact that this
project will have on Lake Nippenicket ("Nip") and the surrounding areas/neighborhoods.
First, the restaurant portion of the project will have a significant impact on the Nip. In order to
construct the planned restaurant, a significant amount of trees that are directly on the
parameter of the Nip will have to be removed and this will directly destroy the habitats of the
many species of animals that live in or around the Nip. I, personally, have lived on the Nip for
23 years and have noticed first-hand since the construction of the hotel and large apartment
complexes from the first phase of this project the impact that the construction has had on the
species. I have seen a large volume of dead turtles, fish, and geese. I no longer see the cranes
and swans that I used to see. As Claremont is continually allowed to build more and more
near the Nip, these animals are forced farther and farther away from their habitats and if
Claremont is allowed to proceed with the Phase, this will happen again because there will no
longer be any place for them to go.
Second, the traffic in or around this area will increase tremendously. Claremont is looking to
cram a lot more businesses into a small area where at points, there is only 1 lane for traffic.
This area is already very congested as it is. People come to enjoy the Nip for peaceful
recreation and the increased traffic and noise from a restaurant located right on the water in
particular (between trash and delivery trucks arriving and departing) will all but ruin this. The
only parking lot that people can use to come and enjoy the Nip is directly next to the proposed Cannizzaro.01
restaurant location and will no doubt be used as overflow parking for this restaurant even if
they are instructed that it is prohibited because there will not be enough parking and there will
be no one there to enforce it. There is also a public parking area across the street and people
may choose to park there which would be a hazard because of the close proximity to the exit
ramp right off Route 24 and people attempting to cross the road to go to the restaurant. People
exiiting the highway usually do so at a high rate of speed. The increase in the amount of
traffic is also a very large concern as it will create more pollution which will effect the people
trying to enjoy the Nip or people living in the surrounding neighborhoods. People often picnic
and walk in this area. The lights that will be installed (especially around the restaurant) will
have a huge impact on the people that live along the Nip. They will be shining in their
windows causing them to install blinds and prevent them from enjoying the beautiful views
they now enjoy.
Third, these plans require a large increase in the water usage and I believe Bridgewater is
already restricted as it is.
Fourth, Claremont has already tremendously altered the land surrounding the Nip by what they
have already constructed (hotel, 2 large office buildings, and 2 housing complexes). Further
construction will continue to alter the land and create more pollution.
In conclusion, the Nip is a precious part of the community as well as the Commonwealth and
we are very fortunate to have it. If we continue to invade the ecosystems and habitats of the
wildlife, they will cease to exist. I would like to protect this beautiful area so that people can
continue to come and enjoy a peaceful place to relax. We cannot undue it once it has been
done and we would be fools if we continue to build-up this area and not think that the Nip and
the surrounding areas will be affected.
Thank you for you consideration of my concerns.
Sincerely,
Kelly Cannizzaro
KELLY-FRANK CANNIZZARO
Cannizzaro.01 Claremont is looking to cram a lot more businesses into a small area where at points,
there is only 1 lane for traffic. This area is already very congested as it is. People come
to enjoy the Nip for peaceful recreation and the increased traffic and noise from a
restaurant located right on the water in particular (between trash and delivery trucks
arriving and departing) will all but ruin this. The only parking lot that people can use to
come and enjoy the Nip is directly next to the proposed restaurant location and will no
doubt be used as overflow parking for this restaurant even if they are instructed that it
is prohibited because there will not be enough parking and there will be no one there
to enforce it. There is also a public parking area across the street and people may choose
to park there which would be a hazard because of the close proximity to the exit ramp
right off Route 24 and people attempting to cross the road to go to the restaurant.
People exiting the highway usually do so at a high rate of speed. The increase in the
amount of traffic is also a very large concern as it will create more pollution which will
affect the people trying to enjoy the Nip or people living in the surrounding
neighborhoods. People often picnic and walk in this area. The lights that will be installed
(especially around the restaurant) will have a huge impact on the people that live along
the Nip. They will be shining in their windows causing them to install blinds and prevent
them from enjoying the beautiful views they now enjoy.
anticipated to increase by approximately three seconds from No-Build to Build conditions,
showing the minimal impact.

From: Leiry Melendez
Subject: Important Concerns Regarding Claremont Proposed Project

To Whom It May Concern,
I am a resident of the Lakeshore Neighborhood. I am concerned about the Claremont Proposed Project
and its impact on our lake and neighborhood. My concerns about the Planned Project include:
Environment: It substantially impacts an Area of Critical Environmental Concerns, the Hockomock

Swamp, including Lake Nippennickets, a Great Pond and its nearby wetlands. The project site falls within
mapped rare species habitat and I am concerned about the impact this project will have on the
surrounding wildlife. My kids enjoy all the different animals around the shore and area and it would be
really sad for them to loss this experience.
TRAFFIC: It involves a large increase in traffic on Route 104 (estimated by Claremont to be 4,262 extra
trips per dart) impacting surrounding neighborhoods, and all members of which would like to use the lake
for peaceful recreation. My mother is an elderly driver and enjoys been able to still drive and drive our
children around with her. Entering and exiting our neighborhood its already hard at times due to the high
volume of traffic on Route 104 and we fear it will become worst and possibly dangerous. It should be
noted, that for some surrounding neighborhoods, Route 104 represented the only way in and out of the
neighborhood, and access to the public boating dock by members of the public is also dependent on
Melendez-
access to Route 104. In addition, it directly impacts the commuting route of the comminuting route of all Sullivan.01
individuals in the local area who must use Route 104 to get to Route 24 and connecting highways to go to
work like my myself and my husbands specially since we are consider essential personnel at our jobs
and no matter need to be at our positions. Also extremely important for my mother and my children to go
to school, sports and/or doctors appointments.
WATER USAGE: It involves a large increase in water usage and Bridgewater is already on "Restricted
Water Usage".
NOISE: The project will likely increase noise which will have a substantial impact on the activities of local
wildlife and the QUALITY of life of all nearby residents and all the members of the public whom would like
to use the lake peaceful recreation. We have many elderly people like my mother and our neighbors who
love to go for their peaceful walks or bike rides, young moms walking their newborn children and kids just
enjoying nature which now days is very rare to see.
WASTE/TRASH: I am very concerned that specific aspects of this project will increase waste and trash in
the overall area and find its way into Lake Nippenicket and surrounding neighborhoods and areas. My
husband loves to go fishing with our boys and our boys go fishing with their friends very often. I would
hate for them to lose that experience due to waste and trash that more than like will increase.
POLLUTION: Increased air pollution will also be generated by the large number of cars that will need to
use a two-lane road. Once again, impacting the health and enjoyment of the lake by members of the
community and public.
LAND ALTERATION: A substantial amount of open space will destroyed by the project, impacting the
beauty of the lake, surrounding areas, and setting the stage for additional climate change impacts to the
immediate area.
ARCHAEOLOGICAL HISTORICAL SITE DESTRUCTION: Two sites of archaeological historical

significance will be destroyed.
OPEN SPACE: Finally, I also dispute the statement made by Claremont in the ENF Document/Report
"The open space at the Project Site is not useable as it is along a busy corridor between Route 24 and
Melendez-
Routh 495". This space could be used to support additional recreational activities for the adjacent Boat Sullivan.02
Ramp/Parking Lot area by adding space for members of the community to picnic and walk. Which during
the pandemic we saw an increase of members of the public utilizing and enjoying as a away to enjoy
fresh air and nature. Many of us chose to lived here because of the area's beauty and open space. We
chose this quiet and beautiful area as a way to escape the busy, overcrowded, annoying levels of noise,
garbage, excessive traffic at all hours of the day, absence of wild life, lack regards for nature and the
need for QUALITY of life that we experience when we lived in the city.
Thank you for your taking the time to read our concerns and your consideration on this important matter,
Leiry Melendez-Sullivan
12 Lakewood Lane
LEIRY MELENDEZ-SULLIVAN
Melendez-Sullivan.01 It should be noted, that for some surrounding neighborhoods, Route 104
represented the only way in and out of the neighborhood, and access to the public
boating dock by members of the public is also dependent on access to Route 104. In
addition, it directly impacts the commuting route of the comminuting route of all
individuals in the local area who must use Route 104 to get to Route 24 and connecting
highways to go to work like my myself and my husband’s specially since we are consider
essential personnel at our jobs and no matter need to be at our positions. Also,
extremely important for my mother and my children to go to school, sports and/or
doctors’ appointments.
Melendez-Sullivan.02 Finally, I also dispute the statement made by Claremont in the ENF
Document/Report "The open space at the Project Site is not useable as it is along a busy
corridor between Route 24 and Routh 495". This space could be used to support
additional recreational activities for the adjacent Boat Ramp/Parking Lot area by adding
space for members of the community to picnic and walk. Which during the pandemic
we saw an increase of members of the public utilizing and enjoying as a way to enjoy
fresh air and nature. Many of us chose to live here because of the area's beauty and
open space. We chose this quiet and beautiful area as a way to escape the busy,
overcrowded, annoying levels of noise, garbage, excessive traffic at all hours of the day,
absence of wildlife, lack regards for nature and the need for QUALITY of life that we
experience when we lived in the city.

The Proponent notes this letter but observes
no comments requiring a response.
From: lwdy5861@aol.com
Subject: Claremont proposed project
Date: Monday, June 13, 2022 8:29:13 AM

The surrounding Nippenicket area has dramatically changed since
Claremont moved into the neighborhood.
The lake was cleaner, air quality was better, and it was quieter. We
chose to live on the lake because it is a beautiful, healthy, calming
way of life. Much has changed and now Claremont wants to add
more?
Everyone around the lake and surrounding streets are adamantly

against any more disruption.
Water runoff that used to sink into the ground, now runs off the
massive amount of tar areas
and into the lake.
The warehouse, (the newest project completed), resulted in extreme

highway noise because there is very little buffer space. This only
magnifies the fact that the fumes from the constant cars and trucks
is adding yet more air pollution into the area.
The deer are being slowly phased out into other areas leaving them
at a loss for new places to eat and sleep. Just last week there was a
deer in my yard mid afternoon. He or she then walked up the middle
of the street. This I have never seen before in the many years I've
lived here. In just the past few months, twice, I saw a dead deer on
the sidewalk across the street from the hotel, no doubt killed by
traffic. It was almost the same spot both times on different days.
Who knows how many more were killed this year. They were trying
to find a new place to roam, eat of whatever. Dead deer is a new
phenomenon here.
Assisted living is a nice idea for Bridgewater but certainly not in this
area, We are full up and fed up, No more. Many believe we have
allowed too much already. Perhaps over by Scotland Links. There
appears to be much more free space over there, Anyone who has
eyes can see that the trees left here are so limited that it has had a
severe negative affect on our wildlife.
Linda Young
12 Saddle Drive
%ULGJHZDWHU0D
From: Marc Sullivan
Subject: Concerns about the Bridgewater Claremont Project.

I am a resident of the Lakeshore Neighborhood. I have lived here for several years with my
wife and 2 young children. I am concerned about the Claremont Proposed Project and its
impact on our lake and our neighborhood. My concerns about the Planned Project include:
It substantially impacts an Area of Critical Environmental Concerns, the Hockomock Swamp,

including Lake Nippennickets, a Great Pond and its nearby wetlands. The project site falls
within mapped rare species habitat and I am concerned about the impact this project will have
on the surrounding wildlife. My kids enjoy all the different animals around the shore and area
and it would be really sad for them to loss this experience. We often walk to the lake to enjoy
the sunsets and I enjoy kayaking in the lake.
It involves a large increase in traffic on Route 104 (estimated by Claremont to be 4,262 extra
trips per dart) impacting surrounding neighborhoods, and all members of which would like to
use the lake for peaceful recreation. My mother is an elderly driver and enjoys been able to
still drive and drive our children around with her. Entering and exiting our neighborhood its
already hard at times due to the high volume of traffic on Route 104 and we fear it will
become worst and possibly dangerous. It should be noted, that for some surrounding
Sullivan.01
neighborhoods, Route 104 represented the only way in and out of the neighborhood, and
access to the public boating dock by members of the public is also dependent on access to
Route 104. In addition, it directly impacts the commuting route of the comminuting route of
all individuals in the local area who must use Route 104 to get to Route 24 and connecting
highways to go to work like my myself and my husbands specially since we are consider
essential personnel at our jobs and no matter need to be at our positions. Also extremely
important for my mother and my children to go to school, sports and/or doctors appointments.
It involves a large increase in water usage and Bridgewater is already on "Restricted Water
Usage".
The project will likely increase noise which will have a substantial impact on the activities of
local wildlife and the QUALITY of life of all nearby residents and all the members of the
public whom would like to use the lake peaceful recreation. We have many elderly people like
my mother and our neighbors who love to go for their peaceful walks or bike rides, young
moms walking their newborn children and kids just enjoying nature which now days is very
rare to see.
I am very concerned that specific aspects of this project will increase waste and trash in the
overall area and find its way into Lake Nippenicket and surrounding neighborhoods and areas.
My husband loves to go fishing with our boys and our boys go fishing with their friends
often. I would hate for them to lose that experience due to waste and trash that will likely
increase.
Increased air pollution will also be generated by the large number of cars that will need to use
a two-lane road. Once again, impacting the health and enjoyment of the lake by members of
the community and public.
A substantial amount of open space will destroyed by the project, impacting the beauty of the
lake, surrounding areas, and setting the stage for additional climate change impacts to the
immediate area.
Two sites of archaeological historical significance will be destroyed.
Finally, I also dispute the statement made by Claremont in the ENF Document/Report "The Sullivan.02
open space at the Project Site is not useable as it is along a busy corridor between Route 24
and Routh 495". This space could be used to support additional recreational activities for the
adjacent Boat Ramp/Parking Lot area by adding space for members of the community to
picnic and walk. Which during the pandemic we saw an increase of members of the public
utilizing and enjoying as a away to enjoy fresh air and nature. Many of us chose to lived here
because of the area's beauty and open space. We chose this quiet and beautiful area as a way to
escape the busy, overcrowded, annoying levels of noise, garbage, excessive traffic at all hours
of the day, absence of wild life, lack regards for nature and the need for QUALITY of life that
we experience when we lived in the city.
Thank you for your taking the time to read our concerns and your consideration on this
important matter.
Marc Sullivan
Sent from my iPhone
MARC SULLIVAN
Sullivan.01 It should be noted, that for some surrounding neighborhoods, Route 104 represented
the only way in and out of the neighborhood, and access to the public boating dock by
members of the public is also dependent on access to Route 104. In addition, it directly
impacts the commuting route of the comminuting route of all individuals in the local
area who must use Route 104 to get to Route 24 and connecting highways to go to work
like my myself and my husband’s specially since we are consider essential personnel at
our jobs and no matter need to be at our position.
Sullivan.02 I also dispute the statement made by Claremont in the ENF Document/Report "The
open space at the Project Site is not useable as it is along a busy corridor between Route
24 and Routh 495". This space could be used to support additional recreational activities
for the adjacent Boat Ramp/Parking Lot area by adding space for members of the
community to picnic and walk. Which during the pandemic we saw an increase of
members of the public utilizing and enjoying as a way to enjoy fresh air and nature.
Many of us chose to live here because of the area's beauty and open space. We chose
this quiet and beautiful area as a way to escape the busy, overcrowded, annoying levels
of noise, garbage, excessive traffic at all hours of the day, absence of wildlife, lack
regards for nature and the need for QUALITY of life that we experience when we lived
in the city.



View Comment
Comment Details

16558 Mark -- --

6-13-2022 Peterson -- Individual


Purvi Patel, (617)874-0668,
purvi.patel@mass.gov mhp4bwater@gmail.com 02324
Topic:dClaremont and invasive non-native vegetation
Comments
Claremont's other development at Lake Nippenicket, Axis at Lakeshore, 4100 Summit Dr, is overrun with invasive japanese knotweed. The invasive japanese knotweed has also overtaken site stormwater
management basins and wetland buffer zones. Japanese knotweed interferes with stormwater in¦ltration, increases site erosion, eliminates biodiversity, and takes away natural aesthetics, which puts all
wetland services at risk. There is also phragmites outbreak in delineated wetlands bordering 495, however, this stand of phragmites cannot be seen at present due to the height of the japanese knotweed.
Claremont's Lakeshore Center development is relatively new, however, it already has signs of japanese knotweed in stormwater management basins. Additionally, the entire strip of woodland buffer along the
long driveway, to Viva Lakeshore, is being overrun with multi§ora rose, buckthorn, autumn olive, etc... These invasive plants will slowly change soil conditions for native plants, displace the native plants, and will
continue their invasion deeper into the surrounding woodland and wetland. Any beauty of these natural areas, as mentioned in walking path plans, would be lost.
Attached are photos of:
Stormwater management basin at 4100 Summit Dr.
One shoot of japanese knotweed (circled in photo) in stormwater management basin at 2 Lakeshore Center. This one shoot was cut by property management on Saturday June 11, 2022. It would be
Peterson.01
important to know the controls in place to manage the beginnings of this invasion, as cutting the shoot is not going to remove the japanese knotweed.
How do Claremont's current and future property management plans address the invasive species that take away from the value of Bridgewater's natural resources?
Attachments
lakeshore center japanese knotweed basin low res.jpg(null)
axis stormwater basin low res.jpg(null)
Update Status
Status
Accepted SUBMITd
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MARK PETERSON
Peterson.01 How do Claremont's current and future property management plans address the
invasive species that take away from the value of Bridgewater's natural resources?
The Proponent strives to maintain a well-kept and attractive campus. The Operations and
Maintenance Plan for the stormwater system is discussed in Section 7.3.10.

From: Ramonita Mulero
Subject: Concerns about Claremont Proposed Project
Date: Monday, June 13, 2022 9:29:40 AM

I am a resident of the Lakeshore Neighborhood. I am concerned about the

Claremont Proposed Project and its impact on our lake and neighborhood. My
concerns about the Planned Project include:
Environment: It substantially impacts an Area of Critical Environmental

Concerns, the Hockomock Swamp, including Lake Nippennickets, a Great Pond and
its nearby wetlands. The project site falls within mapped rare species
habitat and I am concerned about the impact this project will have on the
surrounding wildlife. My grandkids love seeing all the different animals
around the shore and area and would hate for them to loss this experience.
TRAFFIC: It involves a large increase in traffic on Route 104 (estimated by

Claremont to be 4,262 extra trips per dart) impacting surrounding
neighborhoods, and all members of which would like to use the lake for
peaceful recreation. I am an elderly driver and enjoy the freedom I still
have while I drive. Entering and exiting our neighborhood its already tricky
at times due to the high volume of traffic on Route 104 which will become
worst and possibly dangerous. It should be noted, that for some surrounding
neighborhoods, Route 104 represented the only way in and out of the
neighborhood, and access to the public boating dock by members of the public Mulero.01
is also dependent on access to Route 104. In addition, it directly impacts
the commuting route of the comminuting route of all individuals in the local
area who must use Route 104 to get to Route 24 and connecting highways to go
to work (like my daughter and her husbands) or doctors appointments (like
myself or my grandchildren).
Water Usage: It involves a large increase in water usage and Bridgewater is

already on "Restricted Water Usage".
NOISE: The project will likely increase noise which will have a substantial
impact on the activities of local wildlife and the QUALITY of life of all
nearby residents and all the members of the public whom would like to use the
lake peaceful recreation. We get lots elderly people like myself who love to
go for their peaceful walks, young moms walking their newborn children and
kids just enjoying nature which now days is very rare to see.
WASTE/TRASH: I am very concerned that specific aspects of this project will

increase waste and trash in the overall area and find its way into Lake
Nippenicket and surrounding neighborhoods and areas. My grandsons love to go
fishing with their dad and their friends and I hate for them to lose that
experience due to waste and trash that more than like will increase.
POLLUTION: Increased air pollution will also be generated by the large number
of cars that will need to use a two-lane road. Once again, impacting the
health and enjoyment of the lake by members of the community and public.
LAND ALTERATION: A substantial amount of open space will destroyed by the
project, impacting the beauty of the lake, surrounding areas, and setting
the stage for additional climate change impacts to the immediate area.
ARCHAEOLOGICAL HISTORICAL SITE DESTRUCTION: Two sites of archaeological

historical significance will be destroyed.
OPEN SPACE: Finally, I also dispute the statement made by Claremont in the
ENF Document/Report "The open space at the Project Site is not useable as it Mulero.02
is along a busy corridor between Route 24 and Routh 495". This space could be
used to support additional recreational activities for the adjacent Boat
Ramp/Parking Lot area by adding space for members of the community to picnic
and walk. Which during the pandemic we saw an increase of members of the
public utilizing and enjoying as a away to enjoy fresh air and nature. Many
of us chose to lived here because of the area's beauty and open space.
Thank you for your consideration of my comments and concerns,
Ramonita Mulero
Lakewood Lane
Bridgewater, MA
RAMONITA MULERO
Mulero.01 It should be noted, that for some surrounding neighborhoods, Route 104 represented
the only way in and out of the neighborhood, and access to the public boating dock by
members of the public is also dependent on access to Route 104. In addition, it directly
impacts the commuting route of the comminuting route of all individuals in the local
area who must use Route 104 to get to Route 24 and connecting highways to go to work.
Mulero.02 I also dispute the statement made by Claremont in the ENF Document/Report "The
open space at the Project Site is not useable as it is along a busy corridor between Route
24 and Routh 495". This space could be used to support additional recreational activities
for the adjacent Boat Ramp/Parking Lot area by adding space for members of the
community to picnic and walk. Which during the pandemic we saw an increase of
members of the public utilizing and enjoying as a way to enjoy fresh air and nature.
Many of us chose to live here because of the area's beauty and open space.

From: MacDonald, Susan J
Subject: Lakeshore Center Phase IV
Attachments: Lakeshore letter.docx

Please see my concerns attached.
Thank you,
Susan MacDonald
Pleasant Street Resident
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opinions or advice contained in this email are subject to the terms and conditions expressed in
the governing KPMG client engagement letter.
***********************************************************************
To Whom it May Concern:
I am a current resident of Pleasant St. (Rt 104) and will be directly affected by Claremont Companies proposed
build for Lakeshore Center Phase IV. There has been a significant traffic impact as well as an increase in noise
pollution. This will involve an even larger increase in traffic on Rt 104 (estimated by Claremont to be 4,262
MacDonald.01
EXTRA trips per day). Rt 104 is the only way in and out of the neighborhood for many of us who live in the
impacted area. It affects all of the commuting routes for everyone in the area who have to use 104 to get to
Rt 24 and connecting highways. Not to mention the air pollution that will increase by the even larger number
of vehicles using a two-lane road. This will impact the health and enjoyment of the lake residents as well as
the recreational enjoyment for others.
I am very concerned about the substantial amount of open space that will be destroyed by the project, the
serene beauty of the lake as well as the surrounding areas. This will only set the stage for climate impacts to
the area in question. It will substantially impact an area of critical environmental concern the Hockomock
Swamp including both Lake Nippenicket, a Great Pond and its wetlands. I am concerned about the impact
that this project will have on the surrounding wildlife, the project site falls within a mapped area species
habitat. As stated in the Claremont report itself “The delicate balance of nature, wildlife and rare species
surrounding the lake and wetlands WILL DEFINITLY be disrupted’. As well as the two archaeological
historical significance that will be destroyed.
The trash has already been an issue when the hotel and first set of apartments went up. The noise is
absolutely awful and has on occasion woken us up in the middle of the night with the increase of trucks and
cars that use the road now.
The proposed 6,000 sq. ft restaurant site on the northside of Pleasant Street is not zoned for commercial use.
Claremont Co. wants to change the zoning. Why do we need yet ANOTHER hotel or 160 unit condominium
complex right next to Claremont Co. original builds:
x 4-building, 289-unit residential complex and 574 parking spaces occupy the western section.
x 96-room, 4-story hotel with 103 parking spaces on Lot 1;
x approximately 77,000 GSF, 3-story office building with 237 parking spaces on Lot 2;
x approximately 65,000 GSF, 4-story office building with 227 parking spaces on Lot 3;
x 300-unit, 5-story apartment complex with 600 parking spaces on Lot 5
I am also disputing the statement made by Claremont in the ENF document/Report: “The open space at the MacDonald.02
Project site in not useable as it is along a busy corridor between Rt 24 and Rt 495” This is the perfect spot to
support more recreational area for the adjacent boat ramp/parking lot area. A picnic area or just a walking
path with benches for a walk or to just sit and enjoy the lake. I’ve lived in Boston for more than half of my life,
I moved here for the peace and quiet and to hopefully retire comfortably and quietly in Bridgewater, but
Claremont Co. is making my dream an impossibility. When is enough, enough?
Thank you for your consideration.
S. MacDonald
SUSAN J. MACDONALD
MacDonald.01 This will involve an even larger increase in traffic on Rt 104 (estimated by Claremont to
be 4,262 EXTRA trips per day). Rt 104 is the only way in and out of the neighborhood
for many of us who live in the impacted area. It affects all of the commuting routes for
everyone in the area who have to use 104 to get to Rt 24 and connecting highways. Not
to mention the air pollution that will increase by the even larger number of vehicles
using a two-lane road. This will impact the health and enjoyment of the lake residents
as well as the recreational enjoyment for others.
MacDonald.02 I am also disputing the statement made by Claremont in the ENF document/Report:
“The open space at the Project site in not useable as it is along a busy corridor between
Rt 24 and Rt 495” This is the perfect spot to support more recreational area for the
adjacent boat ramp/parking lot area. A picnic area or just a walking path with benches
for a walk or to just sit and enjoy the lake. I’ve lived in Boston for more than half of my
life, I moved here for the peace and quiet and to hopefully retire comfortably and
quietly in Bridgewater, but Claremont Co. is making my dream an impossibility. When
is enough, enough?

From: Amanda J.G. Napior
Cc: Jeff Napior
Subject: Please oppose the development around Lake Nippenicket
Date: Tuesday, June 14, 2022 9:01:14 AM

Dear Ms. Patel,
My partner, Jeff Napior, and I are residents of Bridgewater, MA and writing to express
our concern regarding the “Lakeshore Center” project around Lake Nippenicket in
Bridgewater. Thank you for taking our messages during this period of public comment.
While this project raises many concerns, we will list four:
This project poses significant ecological danger to an area including wetlands, deemed of
“Critical Environmental Concern.” This project would also impact the habitats of rare
species. The proposed area for this project is one of fragile ecology, important not only
to the humans who live nearby but the diverse non-human creatures and their ecosystems
as well. We and they cannot bear the brunt of this proposed project.
Additionally, Bridgewater is already on restricted water usage. The 130,000 projected

Napior.01
additional gallons of water per day would be an enormous challenge to the existing
resources of our town, without significant investments in water transport infrastructure.
Similarly, the project report estimates an additional 4,262 car trips per day, amounting to
a traffic increase that would strain the capacity of Route 104. As with the increase to
water usage, such an increase in traffic would strain the capacity of the existing road, Napior.02
which is the only entrance/exit for the neighborhood. The increase in traffic is not nearly
a “quality of life” concern but one of safety: in the event of a fire or another disaster
requiring evacuation, the entire enlarged neighborhood would be stuck in a bottle neck.
Significant expansion to road infrastructure would be necessary for this dimension of the
project to be tenable.
This project even promises to “destroy” two sites of archeological historical significance,
a loss that strikes us as unconscionable in ways similar to the projected ecological
impacts.
Proponents may point out that a part of the proposal provides for an assisted retirement
community—an addition Bridgewater’s growing aging population will surely need in
years to come. The project also accounts for additional condominiums, which might help
aid the housing shortage in Massachusetts. However, the portion of the proposal for the
assisted living facility is only a small fraction of it, and none of the new housing would
serve those who most need affordable housing. Instead, this development seems to serve
the interests of profit, without care for the land or aims to serive a more inclusive
Bridgewater. This project does not serve the common good. Instead, this project would
place unacceptable strain on the fragile ecology, limited natural resources, and current
infrastructure of our town.
Please oppose this plan. Thank you again for your consideration and attention.
Kind regards,
Amanda and Jeff Napior

(413) 441-3464
316 Main Street Apt 1
Bridgewater MA 02324
AMANDA AND JEFF NAPIOR
Napior.01 Additionally, Bridgewater is already on restricted water usage. The 130,000 projected
additional gallons of water per day would be an enormous challenge to the existing
resources of our town, without significant investments in water transport
infrastructure.
measures.
Napior.02 Similarly, the project report estimates an additional 4,262 car trips per day, amounting
to a traffic increase that would strain the capacity of Route 104. As with the increase to
water usage, such an increase in traffic would strain the capacity of the existing road,
which is the only entrance/exit for the neighborhood. The increase in traffic is not
nearly a “quality of life” concern but one of safety: in the event of a fire or another
disaster requiring evacuation, the entire enlarged neighborhood would be stuck in a
bottle neck. Significant expansion to road infrastructure would be necessary for this
dimension of the project to be tenable.

From: Andrea Monteith
Subject: Fwd: EEA# 16558 Lakeshore Center Phase IV, Bridgewater, MA Comments
Date: Wednesday, June 15, 2022 6:28:40 AM
Attachments: Andrea Monteith Comments Claremont ENF 16558.pdf

---------- Forwarded message ---------
From: Andrea Monteith <amonteith118@gmail.com>
Date: Tue, Jun 14, 2022, 6:49 PM
Subject: EEA# 16558 Lakeshore Center Phase IV, Bridgewater, MA Comments
To: <purvi.patel@mass.gov>, <purvi.patel@state.mass.us>
Dear Ms. Patel,
Attached please find my comments for the above referenced ENF.
Thank you for your consideration of my comments and concerns.
Also, can you please verify receipt of the attached comments?
Thank you very much,
Andrea Monteith
255 Lakeside Dr, Bridgewater, MA 02324
amonteith118@gmail.com
June 11, 2022
Purvi Patel
Environmental Analyst
MEPA Office Executive Office of Energy and Environmental Affairs 100 Cambridge
Street, Suite 900 Boston, MA 02114
purvi.patel@state.mass.us
RE: EEA #16558 : Lakeshore Center Phase IV, Bridgewater MA
Dear Ms. Patel:

As a former board member of the Taunton River Watershed Alliance and longtime
resident of Bridgewater and the Lake Nippenicket area, I am submitting the following
comments on the Environmental Notification Form (ENF) for Lakeshore Center Phase
IV, published in the Environmental Monitor on May 25, 2022.
First and foremost, I concur with and support the comments submitted by the Lake
Nippenicket Action Focus team by its representative, Melissa Ramondetta.
Additionally, I have the following comments:
Designated Wild and Scenic River:
The proponent states in the ENF that “the project is within the watershed of the Taunton
River, which is designated as Wild and Scenic River, however, the Project is
approximately 2.5 miles northwest of the Taunton River as its closed point.”
Lake Nippenicket is the headwaters of the Town River. The Taunton River begins at
the confluence of the Matfield and Town Rivers in Bridgewater. In 2009, the Taunton
River was designated a Wild and Scenic River by the National Park Service. The
National Wild and Scenic Rivers Act of 1968 established a system to identify rivers that
possess “outstanding remarkable values” and to protect them “for the benefit and
enjoyment of present and future generations.”
Given that the wetlands on the subject property are hydrologically connected to Lake Monteith.01
Nippenicket, and Lake Nippenicket is the headwaters to the Town River, which is one of
two main tributaries that begin the Taunton River, the project could potentially impact the
“outstandingly remarkable” values and resources of the Taunton River.
1
LAND SECTION: Comprehensive Master Plan - November 2002
Open Space:
The proponent states that the “The open space at the Project Site is not usable as it is
along a busy corridor between Route 24 and Route 495.”
Lake Nippenicket and the surrounding area is currently used extensively by Bridgewater
and residents from other communities for walking, fishing, boating, and picnicking.
Furthermore, the proponent did not mention in their comments the Master Plan’s
identification of Lake Nippenicket and the surrounding area as follows:
The greatest natural setting within the community is the several hundred acres of
land surrounding Lake Nippenicket. The 500-acre great pond attracts a diversity
of waterfowl, amphibians, and mammals indigenous to the greater Hockomock
Swamp. The community should develop awareness programs for this resource
area.
Equally significant as a conservation resource is Lake Nippenicket. Its scenic
qualities are most readily appreciated as it borders Pleasant Street along the
lake’s southern shores. The lake also attracts many boaters during the warmer
months while many hikers throughout the year are drawn to the over 200 acres of
wilderness bordering its northern shores. Lake Nippenicket comprises a portion
of the Hockomock Swamp, which extends into several other communities. The
Massachusetts Executive Office of Environmental Affairs (EOEA) in 1990
designated most of the Hockomock Swamp, including the lake, as an Area of
Critical Environmental Concern (ACEC) as shown in Map 3-1. This designation
provides additional protection for what are recognized as being significant
environmental resources in the vicinity of Lake Nippenicket, Lakeside Drive and
Elm Street.
(Town of Bridgewater Comprehensive Master Plan - 2002)
Compatibility with adjacent land uses:

The proponent states in the ENF that the project site is bounded by Route 104, Route
24, and Route 495 and that the surrounding area is a mix of commercial and residential
uses and therefore the proposed project is compatible with these adjacent land uses.
The construction of Routes 24 and 495 have spurred development over the years of the
land adjacent to these major highways, however, that does not change the facts as to
why the land area was designated as an Area of Critical Environmental Concern
(ACEC) and at a very minimum, any development should be low impact and thus
protect the plant and animal habitat, the wetlands and their respective upland buffer
zones.
2
As stated earlier,the wetlands on the proposed project site are hydrologically connected
to Lake Nippenicket and also the Zone II Raynham aquifer. The wetlands act as a huge
water reservoir and also serve as the headwaters for the Town River, one of two major
tributaries that form the Taunton River.
. ")
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Conservation a nd Recreation
ACTC Boundaries by Type
- - Road/Rail based
dcr
Massachusetts
- - River based
Areas o f Critical Environment al
- - Wetland based
Concern (ACEC) Program
- - floodplain ba.<ied
Tusmap is intended t.obeused \\lllhlhe , ..,1 rit ten
boundary descripti onrontaired in the ACEC - - 1ideba»,d
designation document The mapped bw.nctary
- - Contou r based 0.25
is nol to be used.by itr.elffor definitive ACEC
l:xM.mdary delineati on or regulatory inte?pretatim. - - lblitica l boundary
miles
11>r review of sit~specific prr;oc,ts with rl the
- - Property Iine based
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Lake Nippenicket, a major water body included in the Hockomock Swamp ACEC Designation.
Inconsistency with the Old Colony Planning Council Regional Policy Plan - 2018
The proponent states the project is consistent with the plan as it will create temporary Monteith.02
and permanent jobs. However, most of the proposed development is some form of
housing (condominiums, 55+ housing, and assisted living), which will create limited
permanent employment. Additionally, the combination of the many potential new
residents to the area and any jobs that may be created will dramatically increase
automobile traffic that will exacerbate global warming and climate change.
Relative to open space impacts, Claremont states that the plan encourages growth in
previously developed areas, citing that the project is located within the existing
Lakeshore Center development. However, it is the proponent that has created the
existing development in this ACEC over the past twenty plus years and has already
caused significant damage to this fragile ecosystem. I highly encourage the proponent
to scale down any additional development so as not to permanently destroy an
additional 25.8 acres of the remaining upland and wetland habitat that currently exists,
potentially creating 14 additional acres of impervious area.
4
The proposed project is inconsistent with the Old Colony Council Regional plan as Monteith.03
stated below:
A Sustainable Place is where the use of resources resulting in emissions of
greenhouse gases and other pollutants are going down, not up; where the air
and waterways are accessible and clean; where land is used efficiently and
shared parks and public spaces are plentiful and easily visited.
(Old Colony Planning Council Regional Plan, 2018)
As currently proposed,the project will result in an increase of greenhouse gases and

other pollutants, reduce the air and water quality, and decrease the possibility of Monteith.04
Bridgewater and residents from adjoining towns having access to plentiful parks and
open space.
A model for sustainable communities includes neighborhoods sporting healthy

amounts of green space and shared vegetable gardens; mass transit; biking and
walking replacing the majority of automobile traffic; and mixed-use communities
where schools, residences and commercial spaces are near each other and are
powered by solar panels, geothermal heat pumps or windmills.
The proposed project is not located near mass transit, biking, or walking trails, and
therefore only increases automobile traffic. The proponent also does not address the Monteith.05
use of solar panels, wind, or any other renewable source of energy in the ENF.
The environment and our natural resources assets are preserved, protected and
restored under the sustainable planning approaches. Natural assets such as
wetlands and open space provide benefits, including clean air and water that are
essential for the health and vitality of the region’s residents and neighborhoods.
….The contributions of natural resources to human well-being are explicitly
recognized and valued and maintaining health is a primary objective.
As such, I encourage the proponent to reduce the size of the proposed project so these
natural assets are preserved and protected to the greatest extent possible.
Additionally, the Old Colony Planning Council encourages the development of housing
and job growth in urbanized areas in compact-walkable developments close to job
5
centers, public services, and transit access. None of these exist in the area where this Monteith.06
project is proposed.
The Council also urges the protection of the environment to help ensure the success of
climate-smart land use policies by preserving sensitive habitat, open space and cultural
resources.
Priority Habitat:
Although the proposed project site (excluding the Northern Site) is currently not
mapped as Priority or Estimated Habitat by the Massachusetts Natural Heritage and
Endangered Species Program, it was mapped as such prior to the current development
of the site (EOEA #4959). At that time there was a sizable yellow spotted turtle
population (which has since been delisted, but is still a Species of Conservation
Concern) and also the Eastern box turtle.
The Division has also determined that the proposed project will result in a Take of the
Eastern Box Turtle and a total of 14.4 acres of suitable habitat will be lost. As it is, the
existing development of the site has already fragmented suitable habitat for many
species, including the Eastern Box Turtle and the Yellow Spotted Turtle. (The current
Marriott Residence Inn is sited where there was an extensive population of the Yellow
Spotted Turtle.) It is disappointing to think that an additional 14 acres of the suitable
habitat will also be taken.
Stormwater Management:
Given the ACEC designation and significant wetlands on the parcels, I encourage the Monteith.07
proponent to explore Low Impact Development systems and practices that mimic
natural processes in order to protect water quality and associated habitat.
EPA currently uses the term green infrastructure to refer to the management of
wet weather flows that use these processes, and to refer to the patchwork of
natural areas that provide habitat, flood protection, cleaner air and cleaner water.
At both the site and regional scale, LID/GI practices aim to preserve, restore and
create green space using soils, vegetation, and rainwater harvest techniques.
LID is an approach to land development (or re-development) that works with
nature to manage stormwater as close to its source as possible. LID employs
principles such as preserving and recreating natural landscape features,
minimizing effective imperviousness to create functional and appealing site
drainage that treat stormwater as a resource rather than a waste product. There
6
are many practices that have been used to adhere to these principles such as
bioretention facilities, rain gardens, vegetated rooftops, rain barrels and
permeable pavements. By implementing LID principles and practices, water can
be managed in a way that reduces the impact of built areas and promotes the
natural movement of water within an ecosystem or watershed. Applied on a
broad scale, LID can maintain or restore a watershed's hydrologic and ecological
functions.
https://www.epa.gov/nps/urban-runoff-low-impact-development
In summary, given the ecological sensitivity (wetlands, upland habitat to many species
of both plants and animals in an ACEC) of the proposed development site and its
hydrological connection to Lake Nippenicket, a Massachusetts Great Pond that is
subject to Chapter 91 protection, I urge the proponent to significantly scale down any
development of the what is left of the original 150 plus acres of pristine upland and
wetlands. It is also imperative that consideration be given as to how the proposed
destruction of the extensive upland woodlands on the site and the expected immense Monteith.08
increase in automobile traffic and associated carbon emissions will impact us all relative
to climate change.
Thank you for the opportunity to comment and your consideration of my comments and
concerns,
Sincerely,
Andrea Monteith
255 Lakeside Drive, Bridgewater, MA 02324
amonteith118@gmail.com
7
ANDREA MONTEITH
Monteith.01 Given that the wetlands on the subject property are hydrologically connected to Lake
Nippenicket, and Lake Nippenicket is the headwaters to the Town River, which is one
of two main tributaries that begin the Taunton River, the project could potentially
impact the “outstandingly remarkable” values and resources of the Taunton River.
Please refer to Section 6.2.3. The vast wetland resource area of the Hockomock Swamp
surrounding Lake Nippenicket and the expansive wetland areas bordering the central
upland area provide substantial capacity to withstand the largest storms historically
experienced in this region. While climate changes and the possibility of substantial
increases in the expected stormwater runoff levels by the year 2070 are of concern, this
area is expected to accommodate the increases without impact to the Project site. The
impacts of the higher future rainfall events will result in greater stormwater peaks and
volume, but the wetland system will provide a substantial buffer, minimizing any
observable impacts to the area of the Lake. At the same time, the proposed stormwater
management system will preserve existing conditions by maintaining existing drainage
patterns and proportional discharges to the wetlands and the existing culverts on the site.
watersheds.
Monteith.02 The proponent states the project is consistent with the plan as it will create temporary
and permanent jobs. However, most of the proposed development is some form of
housing (condominiums, 55+ housing, and assisted living), which will create limited
permanent employment. Additionally, the combination of the many potential new
residents to the area and any jobs that may be created will dramatically increase
automobile traffic that will exacerbate global warming and climate change.
Traffic impacts are discussed in Chapter 4. As shown in Table 4-7, the critical stop-
controlled movements all at unsignalized study area intersections are shown to continue
to operate at LOS E or better under 2029 Build conditions during the weekday morning
and weekday afternoon peak hours. The signalized study area intersections are shown to
continue to operate at overall LOS B or better under 2029 Build conditions during the
weekday morning and weekday afternoon peak hours. The overall delay at the signalized
intersections is shown to increase by three seconds or less over No Build conditions.
Monteith.03 The proposed project is inconsistent with the Old Colony Council Regional plan as stated
below: A Sustainable Place is where the use of resources resulting in emissions of
greenhouse gases and other pollutants are going down, not up; where the air and
waterways are accessible and clean; where land is used efficiently and shared parks and

public spaces are plentiful and easily visited. (Old Colony Planning Council Regional
Plan, 2018)
Comment noted. The proposed Project has been carefully designed to protect natural
resources in compliance with all applicable local, state, and federal regulations.
Monteith.04 As currently proposed, the project will result in an increase of greenhouse gases and
other pollutants, reduce the air and water quality, and decrease the possibility of
Bridgewater and residents from adjoining towns having access to plentiful parks and
open space. A model for sustainable communities includes neighborhoods sporting
healthy amounts of green space and shared vegetable gardens; mass transit; biking and
walking replacing the majority of automobile traffic; and mixed-use communities where
schools, residences and commercial spaces are near each other and are powered by
solar panels, geothermal heat pumps or windmills. (Old Colony Planning Council
Regional Plan, 2018)
Comment noted. The proposed Project has been carefully designed to protect natural
resources in compliance with all applicable local, state, and federal regulations.
Monteith.05 The proposed project is not located near mass transit, biking, or walking trails, and
therefore only increases automobile traffic. The proponent also does not address the
use of solar panels, wind, or any other renewable source of energy in the ENF. The
environment and our natural resources assets are preserved, protected and restored

20221215 deir lakeshore center phase 4

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20221215 deir lakeshore center phase 4

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Draft Environmental Impact Report

Lakeshore Center Phase 4

Submitted by: Prepared by:

December 15, 2022

Lakeshore Center Phase 4

Submitted to: Prepared by:

Submitted by: In Association with:

December 15, 2022

1.0 PROJECT DESCRIPTION 1-1

2.0 ALTERNATIVES ANALYSIS 2-1

3.0 LAND ALTERATION, OPEN SPACE, AND FARMLAND CONVERSION 3-1

4.0 TRANSPORTATION 4-1

6491/Lakeshore Center Phase 4 i Table of Contents

4.4 2029 No Build Conditions 4-15

5.0 RARE SPECIES 5-1

6.0 AREA OF CRITICAL ENVIRONMENTAL CONCERN 6-1

7.0 WETLANDS AND STORMWATER 7-1

6491/Lakeshore Center Phase 4 ii Table of Contents

7.3.1.6 Pre-Development Conditions 7-10

8.0 WATER AND WASTEWATER 8-1

9.0 HISTORIC AND ARCHAEOLOGICAL RESOURCES 9-1

10.0 CLIMATE CHANGE ADAPTATION AND RESILIENCY 10-1

11.0 GREENHOUSE GAS ANALYSIS 11-1

6491/Lakeshore Center Phase 4 iii Table of Contents

11.2.3 Solar Photovoltaics 11-7

12.0 CONSTRUCTION PERIOD IMPACTS 12-1

13.0 MITIGATION AND DRAFT SECTION 61 FINDINGS 13-1

14.0 RESPONSE TO COMMENTS 14-1

Attachment A Transportation Data

6491/Lakeshore Center Phase 4 iv Table of Contents

Figure 1-1 USGS Locus Map 1-2

Figure 2-1 Aerial View of Proposed Site Plan 2-3

Figure 3-1 Lot 1 Grading Plan 3-4

Figure 4-1 Site Location Map 4-2

6491/Lakeshore Center Phase 4 v Table of Contents

Figure 7-1 Existing Stormwater Drainage Conditions 7-5

Table 2-1 Existing Amounts of Undeveloped Land by Parcel 2-1

Table 3-1 Land Alteration Summary 3-1

6491/Lakeshore Center Phase 4 vi Table of Contents

Table 4-1 ATR Summary 4-7

Table 7-1 Site Soils 7-4

Table 8-1 Anticipated Water Demand and Sewer Generation 8-1

Table 13-1 Summary of Mitigation Measures 13-2

Table 14-1 Secretary’s Certificate and Comment Letters 14-1

6491/Lakeshore Center Phase 4 vii Table of Contents

Claremont Companies, LLC (the “Proponent”) proposes to develop an approximately 68.2-acre

1.2 Project Site

6491/Lakeshore Center Phase 4 1-1 Project Description

Basemap: Nearmap Aerial, March 2022

Lakeshore Center Phase 4 Bridgewater, Massachusetts

Lakeshore Center Phase 4 Bridgewater, Massachusetts

1.3 Project Description

♦ A 1-story, approximately 1,800 SF café shop on Lot 1;

♦ A 5-story, 150-unit (200,000 SF) assisted living facility on Lot 4;

♦ A 4-story, 225-unit (307,400 SF) 55+ residential community on Lot 6;

6491/Lakeshore Center Phase 4 1-5 Project Description

Basemap: Nearmap Aerial, March 2022

Lakeshore Center Phase 4 Bridgewater, Massachusetts

1.4 Changes Since the ENF

Table 1-1 Comparison of the ENF and DEIR Preferred Alternatives

Lot ENF Alternative DEIR Preferred Alternative Change

North Restaurant (179 seats) Restaurant (179 seats)

1 Café Shop (1,800 SF) Café Shop (1,800 SF)

4 Assisted Living (150 units) Assisted Living (150 units)