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Conservation commission signs off on Keolis wetland maps and issues negative determination for vegetation-management work
Summary
The Needham Conservation Commission voted to accept railroad wetland mapping under a positive 2A determination and issued a negative determination for the commuter-rail vegetation management plan after hearing how chemical applications and mechanical methods are limited in sensitive zones.
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The Needham Conservation Commission on March 13 accepted mapping for Keolis Commuter Rail and issued a negative determination for the company’s five-year vegetation management plan, actions the company needs before submitting its operational plan to the Massachusetts Department of Agricultural Resources.
The commission’s action came after Matt Donovan, representing Keolis, described a program that uses two annual road‑bed herbicide applications (late spring and late summer) delivered by a spray truck running directly on the track, plus additional brush-control work outside sensitive areas. Donovan said sensitive zones identified on the maps are restricted under CMR 11 and that the company uses only materials on the state’s approved “sensitive area” list for those locations.
Why it matters: Under state rules cited by Keolis (CMR 11), operators must limit chemical use in and near wetlands and submit a vegetation management plan (VMP) that shows where chemicals will and will not be used. The commission’s determinations clear the local procedural steps Keolis needs before filing its full VMP with the state.
Donovan told the commission the spray truck applies material directly onto the track ties with nozzles about 18 inches above ground and can shut off one or both booms when shoulder conditions or nearby standing water make spraying inappropriate. He said the road‑bed application can extend up to 12 feet from the track centerline; “yellow” zones on the maps will not receive shoulder treatment and will only be treated on the track itself when necessary, while blue zones receive restricted treatment schedules and closer monitoring.
Commissioners asked for operational details. Commissioner Fred asked about wind and rain limits; Donovan said applicators are licensed by the state and follow wind and rain restrictions, and Keolis typically deploys applicators over several days and schedules extra days to accommodate weather restrictions. Commissioner Sue asked to confirm a 10‑foot no‑spray buffer to wetland edges; Donovan said applicators and the accompanying environmental monitor will avoid spraying within 10 feet of standing water and other sensitive features.
The commission closed the hearing and voted to record a positive 2A determination for the submitted wetland maps and to issue a negative determination of applicability for the right‑of‑way maintenance included in the VMP. Commissioners present who recorded “aye” in the roll calls included Paulina (Commissioner), Bill (Commissioner), Fred (Commissioner), Reid (Commissioner), Sue (Commissioner) and Chairman Dave Harrower; Commissioner Clary recused from the first procedural vote and a separate member (identified on the record as recused) recused from the second vote. The commission asked staff to transmit the signed determination form to Keolis.
Commission direction and next steps: Keolis will receive the determination form and is expected to submit the full five‑year VMP to the state and to the commission later in the summer; the commission retains the ability to comment on the VMP at that time. The commission also noted that the VMP will list the exact state‑approved chemical mixtures used in sensitive areas and that Keolis will accompany applicators with environmental monitors on site.
For the record: Matt Donovan represented Keolis (Benesh) and spoke to operational details; Deb (Conservation staff) confirmed the company submits maps annually to Natural Heritage on priority habitats; the commission’s votes were taken by roll call.

