FINAL RESTORATION PLAN AND
ENVIRONMENTAL ASSESSMENT:

CHARLES GEORGE LAND RECLAMATION TRUST
LANDFILL SUPERFUND SITE

3.0 Environmental Consequences of Restoration Actions and Alternatives

CERCLA, NEPA, and MEPA require the Trustees to assess and disclose the potential effects of restoration alternatives. Chapter 3.0 discusses the potential benefits and consequences of each alternative, and evaluates each alternative according to the Criteria for Selection listed in table 1 (page 13) as a means of explaining why each alternative was not chosen as the preferred alternative. Table 4 shows how each of the alternatives was rated against the selection criteria of Table 1.

3.1 Effects of Alternative A: No Action

Under the no action alternative, injuries to groundwater, wetlands, migratory birds and migratory fish and their habitats would be uncompensated. Given sufficient time, natural processes should enable natural resources and associated services to recover to pre-injury levels. However, the time frame for such natural recovery has been estimated to be in terms of decades. In addition, the increment of resources and associated services lost to the public in the past and during the recovery period would not be compensated. Further, no benefits would be realized from the settlement with Charles George Landfill Inc. et al., and the obligations of the consent decree would not be met. This alternative was not rated against the selection criteria since under this alternative nothing would change.

3.2 Effects of Alternative B: On-Site Wetland Restoration

On-site restoration of wetlands would most proximally address the the services lost due to contamination. However, on-site opportunities are generally costly, and impractical or undesirable.

Sediment Capping

Capping of the sediments in Flint Pond Marsh, which would require one to two feet of fill, would alter the bottom contours of the wetland causing changes in wetland hydrology and associated plant communities. Considerable time and effort would be required to revegetate capped areas. Short-term irretrievable losses of wetland habitat would occur while remedial activities were

being conducted. Long-term impacts may also result from the changes in hydrology that arise from partially filling the wetland. This alternative was rated LOW for most of the selection criteria. This alternative would change the wetland to upland, rather than restore or replace the resources that were impacted. It was rated HIGH for proximity since it would address the immediate location of impact. This would be a costly alternative that would destroy wetland, therefore, it was rated LOW for cost effectiveness. This alternative would not enhance the public’s use of the resources, and therefore, was rated LOW for this criterion. It was rated MEDIUM for ecological benefit to the public because it would isolate the contaminated sediments but it would destroy the wetland. Further community involvement would not be expected. Since this alternative would be simple to perform it would be expected to have a HIGH likelyhood of success. The unnecessary capping of wetland would not comply with applicable state and federal wetland protection statutes, and is, therefore, rated LOW for meeting applicable laws.

Table 4. Evaluation of alternatives using the criteria for selecting restoration sites to compensate for ecological injury caused by the Charles George Landfill (see Table 1).

Sediment Removal

Sediment removal, or dredging wetland areas affected by contamination, would likely result in increased injury to wetlands due to physical habitat disturbance, particularly due to the removal of well developed wetland soil and existing vegetation. Following sediment removal, new soil would need to be brought in and the site revegetated. Losses in habitat value would occur until the dredged areas recovered from remedial activities. Dredging activities associated with sediment removal would also resuspend contaminants and possibly increase contaminant loads in currently less contaminated portions of the wetland. Finally, lowering contaminant levels in the areas which exceeded sediment biological effect levels would require significantly more funds than are currently available. At an estimated cost of excavation and disposal of $1,040,245/acre (ERM 1994), restoration of the 2.75 acres of the most contaminated sediments would cost approximately $3,656,803 (HMM 1990).

This alternative was rated LOW for most of the selection criteria. It was rated MEDIUM for the extent that it restores, replaces or enhances the natural resources that were injured because, although the issue of contaminated sediments would be resolved, the same mature, well-developed wetland could not in reality be replaced. It was rated HIGH for proximity to the injured resources since it would immediately address the location of impact. This alternative would cost more money than the Trustee Council has available for restoration, therefore, it was rated LOW for cost effectiveness. This alternative would not enhance the public’s use or enjoyment of the resources, therefore, it was rated LOW for this criterion. It was rated MEDIUM for environmental benefit to the public since it would remove the contaminated sediments but it would also severely impact the integrity of the wetland. Community involvement would not be expected with this alternative. Technically the project has a high likelihood of success, however, it is not a viable project because the expected costs are greater than the funds available, therefore it was rated LOW for this criterion. The unnecessary dredging of wetlands would not comply with wetland protection statutes, therefore, this alternative was rated LOW for compliance with applicable laws.

It should be noted that EPA’s Record of Decision determined that contamination of Dunstable Brook could warrant remediation. The sediments of Dunstable Brook were retested as part of the 1995 Five-Year Review. This round of testing indicated that environmental contaminants were present and available for uptake by biota used for the testing. EPA resampled the affected area in 1998 and found decreased concentrations of cPAHs. EPA recalculated the risk associated with the cPAH levels using revised relative potency factors and determined that the sediments no longer posed an unacceptable human health risk. Therefore, removal of sediments was determined to be unnecessary.

Erosion Sediment Removal

Removal of sediments that eroded into wetlands adjacent to the landfill due to the capping of the landfill would also likely result in increased injury to the wetlands due to physical disturbance, especially since the affected area has revegetated. With excavation carried out by heavy equipment it would be difficult to limit sediment removal to just the eroded sediments. Also, the affected areas have revegetated so the site would have to revegetate again after the eroded sediments were removed. This alternative was rated LOW for all of the criteria except it is located at the area of impact so was rated HIGH for proximity to the area of impact.

Wetland Creation

Conversion of uplands to wetlands is not feasible at the landfill site. Roads and staging zones at the landfill are unavailable for wetland creation opportunities due to the need to maintain their current functions. Although there is upland adjacent to Flint Pond and Flint Pond Marsh, no sites were found that are available for acquisition and that could technically be converted to wetland (based on topography). Also, unless the upland habitat is degraded (such as is the case with a sandpit), the upland habitat is already serving important functions and there may not be a net gain in ecological value in converting high quality upland habitat to wetland. Upland buffers also serve adjacent wetland habitat by filtering contaminants before they reach the wetlands and by providing wildlife habitat. Some species of wildlife are specific to the upland/wetland edge.

Conversion of uplands to wetlands would, therefore, result in irreversible losses of habitat services associated with those uplands.

This alternative was given a HIGH rating for the degree to which it could restore the injured resources since it would create additional wetland habitat, and HIGH for proximity to the injured resources since it would take place adjacent to the sites of impact. It was rated LOW for cost effectiveness since wetland creation is typically very costly. It was rated MEDIUM for public use since it should create more habitat for wetland wildlife viewing or hunting. It was rated MEDIUM for ecological benefit because it would create wetland habitat but possibly at the loss of other valuable habitat. It was rated LOW for continued community involvement as there would be no need or mechanism for this. It was rated LOW for expected project success since no viable location was found, and creation sites need to be chosen carefully if success is to be expected.

Management of Invasive Plants (Common Reed (Phragmites australis) and Purple Loosestife (Lythrum salicaria))

Wetland restoration through management of common reed and/or purple loosestrife in Flint Pond Marsh or wetlands adjacent to the landfill is not preferred as the primary alternative as it requires intensive on-going management, and because efforts are not consistently successful. Control measures for common reed in flooded situations such as Flint Pond Marsh include hydroraking, cutting below the annual water line, and herbicide application (glyphosate). However, none of these control measures are considered a permanent cure, but rather are methods for managing the spread of the species that may require on-going maintenance (Tiner 1998). Glyphosate is a broad-spectrum herbicide, and if it is not applied carefully, surrounding vegetation can be affected.

Chemical and physical control measures for purple loosestrife include application of broad-spectrum herbicides, hand-pulling, and mowing. These measures are intensive and expensive and relatively ineffective, particularly for large stands of purple loosestrife. Biological control, with the use of leaf-feeding beetles (Galerucella calmariensis and G. pusilla) and a root-boring weevil (Hylobius transversovittatus) is the only long-term strategy which has been recommended to reduce the invasion of this exotic plant (Malecki et. al. 1993). Biological control of purple loosestrife is now permitted in the Commonwealth of Massachusetts, however, written documentation of long-term studies indicating the best sites and methods are lacking. Therefore, the effort would be somewhat experimental. It is known that beetles survive poorly in wetlands that are persistently flooded as the beetles overwinter in the duff (surface soil) in purple loosestrife stands (Janice Taylor, USFWS, pers.comm.). Therefore, sites such as Flint Pond Marsh and one of the wetlands adjacent to the Charles George Landfill would be poor candidates for biological control of purple loosestrife. The small wetland adjacent to the landfill and right next to Dunstable Road, is choked with purple loosestrife and is not persistently flooded, and could, therefore, be a possible candidate for biological control of purple loosestrife. However, this site is relatively small (less than one acre), so only a small area of habitat would be benefitted.

This alternative was rated HIGH for extent of restoration of injured resources because this alternative would signficantly improve the habitat in the areas that were injured. It was also rated HIGH for proximity to the injured resources. It was rated MEDIUM for cost effectiveness because of the cost of purchasing the equipment and because control of invasive plants can require intensive labor to be successful. It was rated HIGH for extent of ecological benefit to the public because it should increase the wildlife use of the wetlands. It was also rated HIGH for ecological benefit to the public for the same reason. It was rated LOW for community involvement, with the exception of whomever would be responsible for the long-term management. It was rated LOW for expected success since success would require long-term intensive management. It was HIGH for compliance with applicable laws.

Control of Runoff from Route 3 into Flint Pond Marsh

Residents around Flint Pond raised the question as to whether storm runoff from Route 3, which is presently being directed to Flint Pond Marsh, could be directed elsewhere. The Trustee Council does not have any authority over Route 3, however, since planning for the Route 3 expansion is presently occurring, an opportunity exists for the drainage to be changed by the MassHighways. We are presently working with MassHighways to determine the present plans for the Route 3 section through Tyngsborough. However, we have been informed by the Massachusetts Department of Environmental Protection that the Commonwealth requires that stormwater discharges be treated, such as by a detention basin, before being discharged into a natural waterbody. Also, the U.S. Fish and Wildlife Service serves as an advisor to the U.S. Army Corps of Engineers on dredge and fill permits, which will provide another avenue for encouraging MassHighways to provide for discharging into detention basins before discharging into Flint Pond. Since this is not really a restoration to be undertaken by the Trustee Council it is not evaluated here in comparison to the other alternatives.

3.3 Effects of Alternative C: Off-Site Wetland Restoration

Off-site restoration of wetlands would compensate for many of the wetland services lost as a result of contamination from the Site. Wetland creation and/or enhancement near the sites impacted would provide additional wetland habitat to species of migratory birds that use wetlands. In addition, restoration efforts would also create or improve habitat for other wildlife species and provide other wetland functions. However, the Trustee Council was unable to find a site with good restoration potential that was available for acquisition. The sites that were found are described and their evaluations discussed (see Tables 1 and 4 on pages 13 and 33, respectively).

Brox Property on Flint Pond

This site offers limited opportunity for wetland restoration. The site is disturbed by historical excavation but the areas that were dug to the water table seem to be developing into productive wetland areas on their own. The upland portion remains relatively denuded and could benefit from the spreading of topsoil and revegetation. However, the upland would remain upland as it is too far above the water table to allow for wetland creation. Restoration of upland habitat would help support adjacent wetland habitat and Flint Pond. Acquisition of this property would protect it from potential future development. However, based on two conversations with a representative for the landowner, it does not appear that the landowner is interested in selling this property to the Trustee Council.

This alternative was rated MEDIUM for the extent to which it would restore the injured resources because it would provide a buffer for Flint Pond and adjacent wetlands, however, no wetlands would be created, restored, or enhanced. It was given a HIGH rating for proximity to injured resources since it is located adjacent to Flint Pond. Cost effectiveness is difficult to evaluate without having an appraisal of the property. It was given a HIGH rating for the extent that it would enhance the public’s ability to use and enjoy the public resource since it would likely be open for public use. It was given a MEDIUM rating for its environmental benefit to the public; it was not given a HIGH rating because of the lack of wetland restoration potential. It was given a HIGH rating for community involvement because public access would be expected. It was given a low rating for expectation of success since the owner does not appear to be willing to sell. This alternative would be expected to be in compliance with applicable laws.

Sandpit on Groton Road

This site was considered a potential restoration site because the upland was degraded (sandpit) and because there was a small pond of water on the site suggesting that a portion of the site has a shallow water table. However, the amount of wetland that could be created on the site is unknown and would require an extensive and expensive investigation to determine. Also, a large area of upland would need to be restored to a more productive state to make the wetland restoration worthwhile. This site is relatively far from the area of impact. The landowner could not be reached.

This site was rated HIGH for the extent to which it could replace the injured resources because theoretically the types of wetlands injured could be re-created and, therefore, increase the amount of habitat available to the animals that use those wetland habitats. It was given a LOW rating for the proximity to the injured resources. Cost effectiveness is difficult to evaluate without an appraisal of the property but this alternative would be expected to be costly. It was given a HIGH rating for public use since it would be expected to be open to the public. It was given a MEDIUM rating for environmental benefit because it is a relatively long distance from the area of impact and possibly only a small area of wetland could be created. Community involvement would be expected to continue since the property would be open for public use. The potential for technical success can not be evaluated without further study, however, the fact that the landowner could not be contacted makes the project unviable. This project would be in compliance with applicable laws.

Sandpit on Red Gate Rd/ Dunstable Rd/ and Brookview Circle

This site is considered to have good restoration potential because it has access to water; the site was excavated to the water table in some locations and the site is adjacent to Dunstable Brook. The site is an old sandpit, so quality habitat would not be altered to create wetland. Although some of the site has developed into wetland already, the topography is flat and lacks diversity, and the ponded areas lack depth. A berm between the site and Dunstable Brook impedes water exchange. Much of the site is vegetated with invasive plants: purple loosestrife chokes part of the site; a discrete stand of Phragmites seems to be expanding; Japanese knotweed is growing on the berm; and sugar locust trees are distributed throughout the site. The southeast corner of the site remains upland sandpit with relatively little vegetative development. Therefore, there is ample opportunity to improve the site. The challenge for this restoration is that the site is broken up into at least eight different small parcels with different owners. All of the landowners would have to be interested in participating for the project to be viable. The Trustee Council was interested enough in this project to hire the Natural Resources Conservation Service (NRCS) to survey the microtopography of the site so that a draft map of what the restoration might look like could be developed. Once this draft restoration map was developed and shown to the landowners, some of them decided not to participate, deeming this restoration alternative inviable.

This project was rated HIGH for the extent it restores, replaces, or enhances the resources injured since it would create wetland habitat of a type similar to what was injured. It was rated HIGH for proximity to the injured resources since Dunstable Brook was impacted a short distance upstream. It was rated HIGH for cost effectiveness since the site was already excavated, so the creation effort was essentially already started, and it could be partnered with a land protection alternative, the Regonini Properties. It was rated MEDIUM for the extent the alternative would enhance the public’s ability to use, enjoy or benefit from the natural resources. This is because the site should attract more wildlife to the area which would be enjoyed by the immediate landowners. It would also create more habitat by increasing the quality of the habitat, and the additional wildlife produced would also move to adjacent habitats. But this site would essentially be closed to the general public because it is ringed by private residences. It was rated HIGH for environmental benefit to the public because it would partially replace resources that were lost. It was rated MEDIUM for community involvement because there was potential for long-term active management by the landholder and adjacent landowners but the site would not be open to the general public. The project was rated MEDIUM for compliance with applicable laws because some existing low quality wetland would be altered to create higher quality wetland, which could be controversial.

Brox Property on Kendall Road behind Highway Department

This property was considered as a restoration site because the upland is degraded sandpit and there is a small pond on the property which indicates possible access to groundwater. Theoretically, it would be possible to create wetland around the perimeter of the pond, but groundwater studies would be required to determine exactly where the groundwater table is around the pond. In addition to creating wetland, an extensive amount of upland would need to be restored around the wetland for the habitat to be of value. A representative for the landowner indicated through a phone conversation that the owner was unlikely to be interested in selling this property.

This alternative was rated HIGH for the extent to which it would restore, replace, or enhance the natural resources that were injured since habitat similar to what was injured would be created. It was rated MEDIUM for proximity to injured resources since it is separated from Flint Pond by Kendall Road. It was rated LOW for cost-effectiveness because the effort, including the preliminary testing, would be costly and potentially only a small area of wetland would be created. It was rated HIGH for the extent that it would enhance public use because once the property was acquired it would be open for public use. It was rated MEDIUM for environmental benefit to the public because it would create similar habitat to what was injured but possibly only a small area. It was rated HIGH for continued public involvement since the property would be open for public use. It was rated LOW for the extent to which the project would be successful because a lot more needs to be known about the water table, and the landowner appears to be unwilling to sell. Compliance with applicable laws would be expected to be high.

Middle School Site on Westford Road

This site was considered a potential restoration site because it includes an old sandpit adjacent to Bridge Meadow Brook. Some of the sandpit was excavated to the water table and wetland vegetation has developed. There are two small areas, each about an acre in size: one on the north side of the brook and one on the south side of the brook. The berms along the banks of the brook could be breached to provide water to enhance wetlands areas and to help absorb flood waters. Construction of a middle school is planned for the area, making the enhanced wetland areas potentially “living laboratories”. However, recent development of housing around the wetlands, in conjunction with the nearby construction of a school limits the amount of surrounding upland available as habitat to support the wetland areas. The Town of Tyngsborough has been hesitant to give approval to the enhancements because the entire property may be needed for the school.

This alternative was rated HIGH for the extent to which it restores, replaces, or enhances the natural resources that were injured. It was rated MEDIUM for proximity to injured resources because it is not on Flint Pond or Dunstable Brook. It was rated MEDIUM for cost effectiveness because it is a relatively small area that would be enhanced and the habitat around it is compromised by development. It was rated HIGH for the extent to which it would enhance public use. It was rated MEDIUM for environmental benefit to the public because it could serve as a “living laboratory” for students at the middle school and would help absorb flood waters, however, the enhanced areas would be relatively small. It was rated HIGH for the extent it provides an oportunity for community involvement to continue because it could be used as a “living lab” for the school. It was rated LOW for the extent to which the project would be expected to be successful because, although it is technically feasible, the Town has not given an approval to the project because the land may be needed for The school.

3.4 Effects of Alternative D: Acquisition of Equivalent Resources

Acquisition of equivalent resources is generally selected only after in-kind restoration projects have been evaluated because it results in preservation of existing resources rather than in replacement of lost resources. This is reflected in Criterion A of the evaluation of alternatives (Table 3 on page 25), which is “the extent to which the alternative restores, replaces, or enhances the natural resources that were injured”. All of the acquisition alternatives were rated as LOW for this criterion except the Brox Property, which has good potential for active restoration. Since the acquisition alternatives were mostly rated the same for the criteria in Table 3, they are not discussed and compared in this section. Table 4 provides a new list of criteria for evaluating and comparing acquisition alternatives. This table is discussed in section 2.5.

3.5 Effects of Alternative E: On-Site Migratory Fish Restoration

            Fish Passage for Flint Pond: Migratory fish restoration through construction of fish passage at the two Flint Pond dams would involve a relatively high cost for a relatively small gain. Fish passage facilities would allow alewife and blueback herring, and American eel to migrate into Flint Pond. Herring may not have historically entered this tributary to the Merrimack River because it may not have provided the relatively deep, quiet water environments, prior to impounding, needed for spawning. The present condition includes the impounded Flint Pond, which could provide an opportunity for herring spawning. However, habitat is limited. Although the pond provides potentially 61 acres of spawning habitat, there is no additional habitat upstream, and the shallow depths of Flint Pond may cause the water temperatures to be too warm for juvenile herring. Further, the pond appears to be silting in, as evidenced by an increase in floating-leaved aquatic plants (primarily lilypads). Given the relatively high price tag of constructing fish passage at this location, estimated to be approximately $200,000, this alternative may not be cost-effective.

This alternative was rated HIGH for the extent that it restores, replaces, or enhances the natural resources that were injured because it would enhance the fishery that may have been injured. It was rated HIGH for proximity to injured resources since the work would take place at the site of injury. It was rated LOW for cost-effectiveness because of the high cost of the work and the relatively low likelyhood of success. It was rated MEDIUM for the extent to which the alternative will enhance the public’s ability to use, enjoy, or benefit from the resource because the project would theoretically bring herring into Flint Pond, but success of reproduction may be limited by high water temperatures. It was rated LOW for ecological benefit to the public because the success of the project is expected to be LOW. It was rated MEDIUM for the extent that it provides for continued community involvement because the fish ladder would require some on-going maintenance. It was rated LOW for the extent to which the project is expected to be successful. It was rated HIGH for compliance with applicable laws.

            Stabilization of Bank Erosion in the Merrimack River through Tyngsborough:

Abatement of bank erosion on the Merrimack River does not appear to be cost-effective. There are numerous locations on the Merrimack River in Tyngsborough and towns downstream with eroding, sloughing banks. The causes of the erosion range from natural processes to land development causing destabilization of the river banks. Excessive erosion results in degradation of aquatic habitat due to increased turbidity in the water column and siltation of the substrate. Placement of riprap is the most common method used to stabilize banks in rivers with significant ice scour, which is expected in a large river such as the Merrimack. Riprap is relatively costly, averaging $40 per linear foot. Riprap can also contribute to degradation of the river system by increasing water velocities which can aggravate erosion both upstream and downstream.

This alternative was rated LOW for the extent to which it restores, replaces, or enhances the natural resources that were injured. Although reducing erosion and, thus, turbidity would be beneficial to aquatic resources, it is unlikely that enough areas could be stabilized that turbidity could be reduced to a meaningful extent. Also, if riprap is used, it often degrades the aquatic habitat as much as it enhances it. It was rated MEDIUM for the proximity to injured resources because the areas of erosion extend up and down the Merrimack River. It was rated LOW for cost-effectiveness because bank stabilization in a large river is expensive and a lot of bank would need to be stabilized before turbidity would be reduced to a meaningful degree. It was rated LOW for the extent to which the alternative will enhance the public’s ability to use, enjoy, or benefit from the natural resources that were injured because stabilizing a few banks will not likely increase the number of fish in the river. It was rated LOW for extent of environmental benefit to the public because a lot of bank would need to be stabilized before there was a meaningful reduction in turbidity, and the riprap can do damage to the river system. It was rated LOW for continued ommunity involvement. It was rated MEDIUM for likelihood of success because technically the stabilization is possible in some locations, but the overall goal of improving habitat for migratory fish may not be met. It was rated MEDIUM for compliance with applicable laws because bank stabilization is frequently permitted when property is in danger but, otherwise, permitting can be difficult.

3.6 Effects of Alternative F: Off-Site Migratory Fish Restoration

Off-site restoration for migratory fish would compensate for injuries that possibly occurred due to the release of contamination from the Site into the Merrimack River. Since migratory fish move up and down through the watershed, an increase in reproduction in one portion of the watershed should ultimately contribute to a higher population throughout the watershed.

A proposal to survey the habitat of the Shawsheen River was received by the Trustee Council. Herring have been observed in the lowermost parts of the Shawsheen, which suggests that the upstream portions of the river should be investigated for their potential to provide habitat for migratory fish. However, without further assessment of the suitability of the habitat in the river, it is difficult to judge whether money would be well spent restoring migratory fish to this river system. The Trustee Council received another proposal to provide fish passage, and stocking and monitoring of shad and herring in the Concord River. It is already known that quality habitat is present in the upstream reaches of the Concord/Sudbury/Assabet Rivers. Therefore, since it is known that quality habitat exists in the Concord River, and conversely, since little is known about the suitability of the habitat in the Shawsheen River for migratory fish, it appears that restoration of migratory fish in the Concord River would be more prudent.

Restoration of historical fish runs would be consistent with on-going federal and state activities. Organizations involved with these activities in Massachusetts include: the Massachusetts Department of Fisheries, Wildlife, and Environmental Law Enforcement, the Massachusetts Division of Marine Fisheries, the Massachusetts Riverways Program, the U.S. Fish and Wildlife Service, the U.S. Army Corps of Engineers, as well as numerous non-profit organizations. Any dam work would be conducted during low-flow periods to minimize impacts on the river, however, the overall impact of constructing a fishway would be positive. No impacts on threatened and endangered species is expected. The construction of a fishway at the Talbot Mills Dam would be consistent with the Massachusetts Wetlands Protection Act (310 CMR 10.57 10.00), the Clean Water Act (Section 404), and the Rivers and Harbors Act (Section 10).

The Shawsheen River alternative was rated MEDIUM for the extent to which it restores, replaces, or enhances the natural resources that were injured because of the unknown probability of success. It was rated MEDIUM for proximity to the injured resources because, although it is located well outside of Tyngsborough, the same population of migratory fish would be addressed. It was rated LOW for cost-effectiveness because of the questions about the projects potential for success. It was rated MEDIUM for the extent the alternative would enhance the public’s ability to use, enjoy, or benefit from the resource because if the project was successful a fishery would be restored to the river for the public to utilize. However, since the amount of habitat available is in question it is not clear how much of a run is possible. It was rated MEDIUM for environmental benefit to the public for the same reasons as the previous criterion. It was rated MEDIUM for the extent that community involvement can continue because volunteers are often used to assist in monitoring fish returns and maintaining fish ladders. It was rated LOW for the extent the project is expected to be successful because of the many unknowns. It was rated HIGH for compliance with applicable laws.

The Concord River alternative was rated HIGH for extent to which the alternative restores, replaces or enhances the natural resources that were injured because it would restore runs of migratory fish to a large area of historical habitat. It was rated MEDIUM for proximity to the injured resources because, although it is located well outside of Tyngsborough the same population of migratory fish would be addressed. It was rated HIGH for cost effectiveness because the project is expected to be successful, and if it is successful, a substantial run of migratory fish will be restored to a large area of historical habitat. It was rated HIGH for the extent to which it will enhance the public’s use of the resource because a fishery will be restored to a substantial area of the Concord, Sudbury, and Assabet Rivers, which will benefit the entire watershed. It was rated HIGH for environmental benefit to the public for the same reason as the previous criterion. It was rated MEDIUM for the extent of continued community involvement because volunteers are often used to monitor fish returns and maintain fish ladders. It was rated HIGH for the likelihood of success because similar projects in other watersheds have been successful, and because quality spawning and incubation habitat has been documented in the system. It was rated HIGH for compliance with applicable laws.

Prepared by: The Charles George Natural Resources Trustee Council
Issued: September 2002