Lucas Environmental, LLC

Responsibilities

• Conduct natural resource evaluations including, but not limited to wetland delineations, wildlife habitat evaluations, and rare species surveys.
• Develop permit strategies for projects in various market sectors.
• Lead federal, state, and local wetland related permitting efforts.
• Develop and/or review technical reports and documents.
• Perform construction oversight and environmental monitoring.
• Mentor and train staff as the company grows.
• Manage budgets and write proposals.

Skills and Abilities

• Excellent verbal and written communication skills.
• Ability to prioritize and manage multiple tasks and projects on short deadlines.
• Ability to interact with clients.
• Ability to delineate wetland resource areas independently.
• Self-motivated with attention to detail and ability to work independently.

Qualifications

• 7-12 years of experience.
• B.S. in environmental science, natural resources, wetland science, or a related field is required.  M.S. is a plus.
• Demonstrated experience with local, state, and federal wetland regulations in Massachusetts is required.  Experience in other New England states is preferred.
• Must have the ability to conduct tasks independently.
• Expertise in identifying plants, insects, birds, reptiles, and/or amphibians.
• Rare species experience is preferred.
• Certifications such as PWS, CWS, RPSS, CPESC, etc. are a plus.
• Ability to use and make maps with GIS is required.

This position may involve working in remote field locations, and may include night/weekend shifts, and/or working in challenging weather conditions. A vehicle is required.  This position requires the ability to work cooperatively as part of a team.

About LE

Lucas Environmental, LLC was founded in 2008, built on the principles of performing quality work and providing reliable service, in the field and in the office.  As a small business working in the Boston area, our responsibilities include preparation and coordination of the environmental science aspects of a variety of project types including residential and commercial development, municipal reviews, railroad and roadways, and telecommunications facilities.

LE offers an opportunity to work on a wide range of challenging and exciting projects.  We provide an environment that promotes learning and professional growth, a competitive base salary, a retirement plan with a company match, a commission based bonus program, and health and dental insurance.

Please send your letter of interest and resume to Christopher Lucas, Lucas Environmental, LLC, 67 Coddington Street, Suite 204, Quincy, Massachusetts 02169, or e-mail to cml@lucasenvironmental.net.

LE is proud to be an Equal Opportunity Employer.

The Town Brook Enhancement project entails the realignment of 1,700 linear feet of primarily culverted river from Quincy Center to a new location.  The new alignment consists of approximately 1,200 linear feet of stream channel of which approximately 264 linear feet is open channel, proposed as smelt spawning habitat. The Town Brook Enhancement Project Monitoring Plan (“Protocol”) was prepared by URS in conjunction with Lucas Environmental, LLC in February 2013, revised April 2013, per the requirements of the Final Order of Conditions (“FOC”) and Water Quality Certification (“WQC”) for the Town Brook Enhancement Project (MassDEP File No. 59-1261).  The purpose of the Protocol was to identify the monitoring program to be implemented for the 2013 through 2015 smelt spawning seasons within Town Brook.  The monitoring program includes several components consisting of water quality sampling, flow measurements, smelt egg assessment, and wetland planting monitoring as outlined in the Protocol.

The FOC and WQC have several requirements for the monitoring program that the City of Quincy was required to implement upon completion of the diversion of Town Brook into the newly constructed channel.  The new channel construction was completed and the Town Brook flows were diverted from the existing culvert into the new alignment on March 8, 2013.  Discussions with the Division of Marine Fisheries (DMF) were initiated following the diversion to finalize the Protocol and begin the monitoring program.

If you are interested in learning more about rainbow smelt, Town Brook, or the monitoring program, please contact Chris Lucas.

Wetlands Protection Act Exemptions for Minor Activities in the Buffer Zone

The changes exempt certain minor activities related to highway safety operation and maintenance work and utility installation work proposed solely in the buffer zone of wetland resource areas. For example did you know the repair and replacement of an existing driveway is now exempt as long as the driveway occupies the same footprint and disturbed areas are stabilized within 14 days? The changes also provide standards for the specified types of utility maintenance and roadwork that qualify as exempt minor activities.

Renewable Energy Access Limited Project

The regulations establish a new limited project type for the construction of a new access roadway, or the repair and replacement of an existing access roadway, needed to transport equipment to renewable energy project sites through inland resource areas and for certain coastal resource areas. Such limited projects may be permitted if designed and constructed in a manner that avoids, minimizes, and mitigates adverse impacts to resource areas and complies with the specified conditions, to the maximum extent practicable.

Stormwater Management Structures

The regulatory revisions provide that stormwater management systems designed, constructed, and installed after November 18, 1996 (the effective date of the Stormwater Policy) do not create jurisdictional resource areas or buffer zones. The revision also provides that this provision include stormwater systems that were improved after November 1996 provided that the improvement complies with the Wetlands Regulations.

Combined Permit Applications

The regulation changes allow proponents to file combined applications to create streamlined permitting mechanisms for the review and permitting of projects subject to multiple regulatory requirements, specifically Chapter 91 and the 401 Water Quality Certification Regulations.

Ecological Restoration Projects

The regulations establish a general permit for streamlining the permitting process for certain ecological restoration projects. The six categories of restoration projects include dam removals, freshwater culvert repair or replacement, culvert replacement to eliminate tidal restrictions, stream daylighting, rare species habitat restoration, and improved fish passage.

The revised regulations can be found at http://www.mass.gov/eea/agencies/massdep/water/regulations/310-cmr-10-00-wetlands-protection-act-regulations.html.

The first two options involve on-site/off-site permittee-responsible mitigation.  This is essentially where mitigation is conducted by the permittee within the project parcel or on a nearby off-site parcel.  The third option is mitigation banking.  This involves preservation, enhancement, restoration, or creation of aquatic ecosystems by a sponsor for the purpose of compensating for unavoidable impacts to wetland resources.  A certain number of “credits” are associated with each mitigation bank.  When a permittee has unavoidable impacts, it may purchase credits to offset those impacts.  The last option, and the topic of this article, is in-lieu fee (ILF).  ILF involves the payment of a fee “in-lieu” of permittee-responsible mitigation.  The fee is commensurate with the expected cost of replacing the wetland functions lost as a result of proposed work.  Upon payment of the fee, the permittee transfers the legal responsibility for implementing mitigation to a program sponsor.  The sponsor determines the location and type of mitigation.  The idea behind the ILF program is that the monies acquired from permittees will go to mitigation projects that will be more beneficial and achieve a higher rate of success than permittee-responsible mitigation.

On May 23, 2014, the U.S. Army Corps of Engineers (USACE) approved the Massachusetts Department of Fish & Game (MA DFG) to become the administrator and sponsor of an in-lieu fee program in Massachusetts.  Permittees subject to USACE jurisdiction (it is not allowed for projects subject to the Massachusetts Wetlands Protection Act [MA WPA] only) will now have the in-lieu fee option for projects where permittee-responsible mitigation is impractical or impossible.  A summary of the program, taken from the USACE New England District website, is below:

• ILF mitigation shall occur only after compliance with the standard progression of avoidance and minimization.
• ILF may be used as compensatory mitigation for impacts from selected projects that are eligible (Category 2 – Pre-Construction Notification) for the Massachusetts General Permits (MA GPs). Projects that do not meet all criteria of the MA GPs but have impacts within the applicable size limits of the MA GPs are eligible. [Note that the USACE no longer refers to Category 1 or Category 2, but rather Self-Verification and Pre-Construction Notification, respectively. Look for an article soon on this.]
• ILF may also be used in the resolution of unauthorized activities as agreed upon by the USACE, Federal, and State review agencies.
• If approved, USACE permits will be conditioned to require payment of ILF to the Department of Fish & Game Environmental Mitigation Expendable Trust. No work may be performed under the permit until receipt of written verification that required ILF has been deposited.
• Fees may be adjusted annually based on experience and changes in costs of project implementation.

There will be four geographically distinct “service areas” associated with the program (known as: Berkshire/Taconic, Connecticut River, Quabbin/Worcester Plateau, and Coastal).  Each service area will have specific mitigation projects (to be determined by the MA DFG), and fees will go towards projects within the same service area as proposed impacts.  Fees differ between each service area, but are generally similar. [Fees currently average $13.84 per square foot, and $125.00 per linear foot.]

While the Massachusetts ILF program represents an exciting opportunity for our clients, there is a big issue related to how the program will be reconciled with the MA WPA and Local bylaws/ordinances.  The MA WPA requires that mitigation occur within the same property where impacts occurred.  This requirement is based on a belief that mitigation is most effective when it occurs where (or at least within the same watershed) the functions were lost.  While there would technically be no net loss in function, permanent, adverse impacts are still likely within the parcel or local watershed where the loss occurred.  Putting science aside, it would also be quite difficult to convince a Conservation Commission in one town to sacrifice their own aquatic resources and replicate them in another.  Clearly this is a significant issue, one that may prevent complete implementation of the program for the foreseeable future.

We will continue to provide updates as we begin to understand better how the program will play out.  In the meantime, it is likely the permittee-responsible mitigation will continue to be the go-to option for projects subject to the Clean Water Act.  If there is a situation where a project is subject to the Clean Water Act or Rivers and Harbors Act only, ILF may be an option.  Don’t hold your breath, though, as it is rare to see project only subject to the Clean Water Act and not the WPA!