NOI applicationDeval L. Patrick, Governor
Timothy P, Murray, Lt. Governor
_._ Jeffrey B._MLillan;_Secretary_ &.CEO_..._ __.._...
Luisa Paiewonsky, Administrator
I
l
ssDo "
- Massachusetts Department of Transportation
Highway Division .
January 31, 2011
Mr. Kevin Lake, Chairman
Northampton Conservation Commission .
210 Main Street
Room 1 1
Northampton, MA 01060
Re: Notice of Intent
Tree•Cutting
District 2 Administration Building
Dear Mr. Lake:
We are pleased to submit you a Notice of Intent for tree cutting at the MassDOT, District 2
Office Building.
The MassDOT Highway Division (formerly MassHighway) is an agency of State Government
and as such is exempt from local Conservation Commission by -laws and fees. -
Payment for the public notice to be published in the,local newspaper will be provided by Mr.
Suher. His mailing address is a follows:
Mr..Eric Suher
Dadgayagoh Ma, LLC .
P.O. Box 7,90
Holyoke, MA 01040
Once a public hearing has been scheduled, or if you have any questions regarding this
request, please contact Timothy Meyer, District Environmental Engineer, at (413) 582- 0543.'
Sincerely,
Albert R. Stegemann, P.E.
District Highway Director
Received By:
(Signature) (Date)
TM/ I ' " `
C- Mark Stinson, DEP (Please print name)
Encl. . .
O L 1 IVUI LI I IVI ILJ, I VVIU.IdI I IIJLUI I, IVIl1 V I VOV j
Tel: 413 - 582_ -0599, Fax: 413- 582 -0596
www.mass.g'ov /massdot
Leading the Nation in Transportation Excellence
NORTHAMPTON
TREE CUTTING AT MASSDOT DISTRICT 2
811 N. KING STREET
INDEX SHEET
1.
WPA Form 3
Notice of Intent printed from eDEP 1/31/11
2.
NOI Wetland
Fee Transmittal Form
3.
Exhibit 1 =
Project Description Narrative
4.
Exhibit 2 -
U.S.G.S. Map
5.
Exhibit 3 -
Environmental Features
6.
Exhibit 4 -
Aerial Photo
7.
Exhibit 5 -
Tree Photos
# of Sheets
9
1
1
1
1
1
2
Massachusetts Department of Environmental Protection Provided byMassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent eDEP Transaction #:363277
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town:NORTHAMPTON
A.General Information
3. Project Location:
a. Street Address 811 N. KING STREET
b. City/Town NORTHAMPTON c. Zip Code 01060
d. Latitude 42.36324N e. Longitude 72.63731W
f. Map/Plat # 08 g.Parcel/Lot # 11
2. Applicant:
Individual r Organization .
a. First Name ALBERT b.Last Name S•TEGEMANN, P.E.
c. Organization MASSDOT
d. Mailing Address 811 N .KING STREET
e. City/Town . NORTHAMPTON f. State MA g. Zip Code 01060.
b. Phone Number 413 -582 -0599 i. Fax 413 -582 -0596. j. Email timothy.meyer@state.ma.us
3.Property Owner: _
more than one owner
a. First Name b. Last Name
c. Organization
d. Mailing Address
e. City/Town f.State g. Zip Code .
h. Phone Number i. Fax j.Email
4.Representative: _
a. First Name TIMOTHY b.. Last Name MEYER
c. Organization MASSDOT
d. Mailing Address 811 N. KING STREET
e. City/Town . NORTHAMPTON %f. State MA g. Zip Code 01060
h.Phone Number 413 -582 -0543 i.Fax 413 -582 -0596 j.Email timothy.meyer@state.ma.us
5.Total WPA Fee Paid (Automatically inserted from NOI Wetland Fee Transmittal Form):
a.Total Fee Paid 500.00 b.State Fee Paid 237.50 c.City/Town Fee Paid 262.50
6.General Project Description:
THE WORK WILL CONSIST OF THE CUTTING AND REMOVAL OF 13 DEAD OR DYING WILLOW TREES AND THE
PLANTING OF TREES WITHIN THE FRONT LAWN AREA OF THE MASSDOT PROPERTY AT 811 N. KING STREET.
IN ORDER TO AVOID IMPACTS TO RESOURCE AREAS AND BUFFER ZONES, WORK WILL BE CONDUCTED
WHEN THE SOIL IS FROZEN AND ABLE TO SUPPORT NECESSARY EQUIPMENT. TREE PLANTINGS WILL OCCUR
IN THE BUFFER ZONE.
7aTroject Type:
1. ❑ Single Family Home 2. C Residential Subdivision
3. ❑ Limited Project Driveway Crossing 4. C Commercial/Industrial
5. IJ Dock/Pier 6. E. Utilities
7. ❑ Coastal Engineering Structure 8. C Agriculture (eg., cranberries, forestry)
Page 1 of 9 * ELECTRONIC COPY
Massachusetts Department of Environmental Protection Provided byMassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent eDEP Transaction #:363277
City/Town:NORTHAMPTON
Ll
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
9. U Transportation 10. r' Other
7b.Is any portion of the proposed activity eligible to be treated as a limited project subject to 310 CMR 10.24 (coastal) or 310 CMR
10:53 (inland)?
1. ❑ Yes r No If yes, describe which limited project applies to this project:
2. Limited Project
B.Property recorded at the Registry of Deeds for:
a.County: b.Certificate: c.Book: d.Page:
HAMPSHIRE 0 0
B. Buffer Zone & Resource Area Impacts (temporary & permanent)
1.Buffer Zone & Resource Area Impacts (temporary& permanent):
This is a Buffer Zone only project - Check if the project is located only in the Buffer Zone of a Bordering
Vegetated Wetland, Inland Bank, or Coastal Resource Area.
2.Inland Resource Areas: (See 310 CMR 10.54 10.58, if not applicable, go to Section B.3. Coastal Resource Areas)
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
a. C! Bank
1. linear feet 2. linear feet
- -_ - -- --- - _ _
b. r Bordering Vegetated Wetland 0 0
1. square feet 2. square feet
c. ❑ Lend under Waterbodies and Waterways
1. linear feet :2. linear feet
3. cubic yards dredged
d. El Bordering Land Subject to Flooding _ _ .
1. square feet 2. square feet
3. cubic feet of flood storage lost 4. cubic feet replaced
e. ❑ Isolated Land Subject to Flooding
1. square feet
2. cubic feet of flood storage lost , 3. cubic feet replaced
f. D Riverfront Area
1. Name of Waterway (if any)
2. Width of Riverfront Area (check one) ❑ 25 ft. - Designated Densely Developed Areas only
C 100 ft. - New agricultural projects only'
200 ft. - All other projects
3. Total area of Riverfront Area on the site of the proposed project
square feet
4. Proposed Alteration of the Riverfront Area:
a. total square feet b. square feet within 100 ft. c. square feet between 100 ft. and 200 ft.
Page 2 of 9 * ELECTRONIC COPY
Massachusetts Department of Environmental Protection Provided byMassDEP:
Bureau of Resource Protection Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent eDEP Transaction #:363277
City/Town:NORTHAMPTON
Ll
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
5. Has an alternatives analysis been done and is it attached to this NOI? ❑ Yes U No
6. Was the lot where the activity is proposed created prior to August 1, 1996? r-1 Yes r No
3.Coastal Resource Areas: (See 310 CMR 10.25 - 10.35)
Resource Area Size of Proposed Alteration Proposed Replacement (if any)
A
a. ❑ Designated Port Areas Indicate size under Land under the ocean below,
b. ❑ Land Under the Ocean
1. square feet
2. cubic yards dredged
c. IJ Barrier Beaches Indicate size under Coastal Beaches and/or Coatstal Dines, below
d. fJ Coastal Beaches
1. square feet 2. cubic yards beach nourishment
e. ❑ Coastal Dunes
1. square feet 2. cubic yards dune nourishment
f. ❑ Coastal Banks
1. linear feet
g. ❑ Rocky Intertidal Shores
1. square feet
h. O Salt Marshes
1. square feet 2. sq ft restoration, rehab, crea.
i ❑'Land Under Salt Ponds
.. 1. square feet
2: cubic yards dredged
j. ❑ Land Containing Shellfish
1. square feet
k. ❑ Fish Runs Indicate size under Coastal Banks, Inland Bank, Land Under the Ocean', and/or inland Land
Under Waterbodies and Waterways, above
1. cubic yards dredged
1. ❑ Land Subject to Coastal
Storm Flowage 1. square feet
4.Restoration/Enhancement
FJ Restoration/Replacement
If the project is for the purpose of restoring or enhancing a wetland resource area in addition to the square footage that has been
entered in Section B.2.b or B.3.h above, please entered the additional amount here.
r
a. square feet of BV W b. square feet of Salt Marsh
S.Prcjects Involves Stream Crossings
❑ Project Involves Streams Crossings
If the project involves Stream Crossings, please enter the number of new stream crossings /number of replacement stream crossings.
Page 3 of 9 * ELECTRONI.0 COPY
------ ____ -------- _..__.__ - - - -- ___..__ ______ _....__ -_.__ _ -
Massachusetts Department of Environmental Protection Provided byMassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent eDEP Transaction #:363277
Cityrf own:NORTHAMPTON
Ll
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 -
a. number of new stream crossings b. number of replacement stream crossings
Page 4 of 9 * ELECTRONIC COPY
ILI Massachusetts Department of Environmental Protection Provided byMassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent ( eDEP Transaction #:363277
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town:NORTHAMPTON
C. Other Applicable Standards and Requirements
Streamlined Massachusetts Endangered Species Act/Wetlands Protection Act Review
1. Is any portion of the proposed project located in Estimated Habitat of Rare Wildlife as indicated on the most recent Estimated
Habitat Map of State - Listed Rare Wetland Wildlife published by the Natural Heritage of Endangered Species program ( NHESP)?
a. ❑ Yes r No
If yes, include proof of mailing or hand delivery of
NOI to:
Natural Heritage and Endangered Species
Program
Division of Fisheries and Wildlife
Route 135, North Drive
Westborough, MA 01581
b. Date of map:FROM MAP VIEWER
If yes, the project is also subject to Massachusetts Endangered Species Act (MESA) review (321 CMR 10.18)....
c. Submit Supplemental Inforn for Endangered Species Review * (Check boxes as they apply)
1. ❑ Percentage /acreage of property to be altered:
(a) within Wetland Resource Area
percentage /acreage
(b) outside Resource Area
percentage /acreage
2. D Assessor's Map or right -of -way plan of site
3. ❑ Project plans for entire project site, including wetland resource areas and areas outside of wetland jurisdiction, showing
existing and proposed conditions, existing and proposed tree /vegetation clearing line, and clearly demarcated limits of work **
a. C Project description (including description of impacts outside of wetland resource area & buffer zone)
b. ❑ Photographs representative of the site
c. C MESA filing fee (fee information available at:
http: / /www. mass. gov /dfwele /dfw /nhesp /regulatory review /mesa/mesa home.htm
Make check payable to "Natural Heritage & Endangered Species Fund" and mail to NHESP at above address
Projects altering 10 or more acres of land, also submit:
d. (J Vegetation cover type map of site
e. Fi Project plans showing Priority & Estimated Habitat boundaries
d. OR Check One of the following
1. ❑ Project is exempt from MESA review. Attach applicant letter indicating which MESA exemption applies. (See 321 CMR
10. 14, http: / /www. mass. gov /dfwele /dfw /nhesp /regulatory review / mesa/mesa exemptions.htm the NOI must still be sent to
NHESP if the project is within estimated habitat pursuant to 310 CMR 10.37 and 10.59.)
2. ❑ Separate MESA review ongoing.
a. NHESP Tracking Number
b. Date submitted to NHESP
3. ❑ Separate MESA review completed
Include copy of NHESP "no Take" determination or valid Conservation & Management Permit with approved plan.
* Some projects not in Estimated Habitat may be located in Priority Habitat, and require NHESP review...
2. For coastal projects only, is any portion of the proposed project located below the mean high waterline or in a fish run?
Page 5 of 9 * ELECTRONIC COPY
Massachusetts Department of Environmental Protection Provided by MassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent eDEP Transaction #:363277
City/Town :NORTHAMPTON
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
a. r Not applicable - project is in inlan d resource area only
b. D Yes D No If yes, include proof of mailing or hand delivery of NOI to either:
South Shore - Cohasset to North Shore - Hull to
Rhodeblsland, and the Cape & Islands: New Hampshire:
Division of Marine Fisheries -
Division of Marine
Southeast Marine Fisheries Station
Fisheries -
Attn: Environmental Reviewer
North Shore, Office
12143 Purchase street - 3rd floor
Attn: Environmental
New Bedford, MA 02740-6694'
Reviewer
30 Emerson Avenue
Gloucester, MA 01930
If yes, it may require a Chapter 91 license. For coastal towns in the Northeast Region, please contact MassDEP's Boston Office.
For coastal towns in the Southeast Region, please contact MassDEP's Southeast Regional office.
3. Is any portion of the proposed project within an Area of Critical Environmental Concern (ACEC)?
a. D Yes r Nd
If yes, provide name of ACEC (see instructions to
WPA Form 3 or DEP Website for ACEC locations).
Note: electronic filers click on Website.
b. ACEC Name
4. Is any portion of the proposed project within an area designated as an Outstanding Resource Water (ORW) as designated in the
Massachusetts Surface Water Quality Standards, 314 CMR 4.00?
a. D Yes r' No
5. Is any portion of the site subject to a Wetlands Restriction Order under the Inland Wetlands Restriction Act (M.G.L.c. 131, § .
40A) or the Coastal Wetlands Restriction Act (M.G.L.c. 130, § 105)?
a. U Yes G No
6. Is this project subject to provisions of the MassDEP Stormwater Management Standards?
a. D Yes, Attach a copy of the Stormwater Report as required by the Stormwater Management Standards per 310 CMR 10.05
(6)(k) -(q) and check if:
1 r , Applying for Low Impact Development (LID) site design credits (as described in Stormwater Management Handbook
Vol.2, Chapter 3)
2. D A portion of the site constitutes redevelopment
3. U Proprietary BMPs are included in the Stormwater Management System
b. r No, Explain why the project is exempt:
1. D Single Family Home
2. U Emergency Road Repair
3. ❑ Small Residential Subdivision (less than or equal to 4 single- family houses or less than or equal to 4 units in multi- family
housing project) with no discharge to Critical Areas.
D. Additional Information
Applicants must include the following with this Notice of Intent (NOI). See instructions for details.
Online Users: Attach the document transaction number (provided on youir receipt page) for any of the following information you
submit to the Department by regular mail delivery.
1. C USGS or other map of the area (along with a narrative description, if necessary) containing sufficient information for the
Page 6 of 9 * ELECTRONIC COPY
Ll Massachusetts Department of Environmental Protection Provided by MassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3'- Notice of Intent eDEP Transaction #:363277
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40 City/Town:NORTHAMPTON
Conservation Commission and the Department to locate the site. (Electronic filers may omit this item.)
2. F Plans identifying the location of proposed activities (including activities proposed to serve as a Bordering Vegetated Wetland
[BVW] replication area or other mitigating measure) relative to the boundaries of each affected resource area.
3. F11 Identify the method for BVW and other resource area boundary delineations (MassDEP BVW Field Data Form(s).
Determination of Applicability, Order of Resource Area Delineation, etc.), and attach documentation of the methodology.
4. G List the titles and dates for all plans and other materials submitted with this NOI.
a. Plan Title: b. Plan Prepared By: c.'Plan Signed /Stamped By: c. Revised Final Date: ` e. Scale:
EXHIBIT 4 TIMOTHY MEYER 12/2/10 NO SCALE
EXHIBIT 3 ENV TIMOTHY MEYER 12/23/10 NO SCALE
FEATURES MAP
EXHIBIT 2 USGS MAP TIMOTHY MEYER 12/23/10 NO SCALE
EXHIBIT 1 PROJECT TIMOTHY MEYER January 2011 NO SCALE
NARRATIVE
5. ❑ If there is more than one property owner, please attach a list of these property owners not listed on this form.
6. ❑ Attach proof of mailing for Natural Heritage and Endangered Species Program, if needed.
7. r Attach proof of mailing for Massachusetts Division of Marine Fisheries, if needed.
8. R Attach NOI Wetland Fee Transmittal Form.
9. ❑ Attach Stormwater Report, if needed.
1
J
0
Page 7 of 9 * ELECTRONIC COPY
Massachusetts Department of Environmental Protection Provided by MassDEP:
Bureau of Resource Protection - Wetlands MassDEP File M.
WPA Form 3 - Notice of Intent eDEP Transaction #;363277
t
Massachusetts Wetlands Protection Act M.G.L..c. 131, §40 City/Town:NORMAMPTON
E.Fees
Fee Exempt: No filing fee shall be assessed for projects of any city, town, county, or district of the Commonwealth, federally recognized Indian
tribe housing authority, municipal housing authority, or the Massachusetts Bay Transportation Authority.
Applicants must submit the following information (in addition to pages I and 2 of the NOI Wetland Fee Transmittal Form) to confirm fee payment:
:32I (/ 2,51 11
2. Municipal Check Number 3. Check date
32/ 1
4. State Check Number 5: Check date
.✓70vrv72ZA1 t�.it2/S L L C
6. Payer name on check: First Name 7. Payer name on check: Last Name
F.Signatures. and Submittal Requirements
I hereby certify under the penalties of perjury that the foregoing Notice of Intent and accompanying plans, documents, and supporting data are true
and complete to the best of my knowledge. I understand that the Conservation Commission will place notification of this Notice in a local newspaper at
the expense of the applicant in accordance with the wetlands regulations, 310 CMR 10.05(5)(a).
I further certify under penalties of perjury that all abutters were notified of this application, pursuant to the requirements of M.G.L. c. 131, § 40. Notice
must be made by Certificate of Mailing or in writing by hand delivery or certified mail (return receipt requested) to all abutters within 100 feet of the
property line of the project location.
1/31/2011
0
Albert Stegemann / 2. Date
MassDOT
,0
'r innothi Meyer
For Conservation Commission:
1/31/2011
4. Date
1/31/2011
6. Date
Two copies of the completed Notice of Intent (Form 3), including supporting plans and documents, two copies of the NOI Wetland Fee Transmittal
Form, and the city /town fee payment, to the Conservation Commission by certified mail or hand delivery.
For MassDEP:
One copy of the completed Notice of Intent (Form 3), including supporting plans and documents, one copy of the NOI Wetland Fee Transmittal Form,
and a copy of the state fee payment to the MassDEP Regional Office (see Instructions) by certified mail or hand delivery.
Other:
If the applicant has checked the "yes" box in Section C, Items 1 -3, above, refer to that section and the Instructions for additional submittal requirements.
The original and copies must be sent simultaneously. Failure by the applicant to send copies in a timely manner may result in dismissal of the
Notice of Intent.
1
Page 8 of 9 * ELECTRONIC COPY
Massachusetts Department of Environmental Protection Provided byMassDEP:
Bureau of Resource Protection - Wetlands MassDEP File #:
WPA Form 3 - Notice of Intent eDEP Transaction #:363277
City/Town:NORTHAMPTON
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Massachusetts Department of Environmental Protection
Bureau of Resource Protection - Wetlands
WPA Form 3 - Notice of Wetland FeeTransmittal
Form
i
Massachusetts Wetlands Protection Act M.G.L. c. 131, §40
Are you exempted from Fee? 171 (YOU HAVE SELECTED NO')
Note: Fee will be exempted if you are one of the following:
• City/Town/County/District
• Municipal Housing Authority
• Indian Tribe Housing Authority
• MBTA
State agencies are only exempt if the fee is less than $100
Fees
Activity Type Activity Activity Fee RF Multiplier Sub Total
Number
H.) CONTROL VEGETATION IN 1 500.00 500.00
DEVELOPMENT;
City/Town share of filling fee State share of filing fee Total Project Fee
$262.50 $237.50 $500.00
Page 1 of 1 * ELECTRONIC COPY
Exhibit 1
PROJECT DESCRIPTION NARRATIVE
The work being proposed is the cutting and removal of dead or dying willow trees that
pose a hazard to maintenance personnel due to their deteriorated condition (see
attached photos, Exhibit 5).
The work to cut and remove the trees will be conducted during frozen ground
conditions, anticipated to be the latter half of February, to prevent unecessary vegetation
and soil disturbance. The trees will be cut above ground level with minimal or no
disturbance to surrounding vegetation. No excavation will be required as the stumps
are to remain.
Equipment access to the trees will mostly be within and from the buffer zone. It is
anticipated that minimal encroachment to resource areas will result, as the cutting
equipment being used has a horizontal reach of approximately 20
Trees will be cut using a track mounted shear. Once felled and removed from resource
areas, the trees will be pulled to a tub grinder located near the west end of the visitor
parking area of the MassDOT Administration Building. Wood chips will be direct loaded
to trailer dumps and removed from the site. Tree stumps will not be removed. The work
is expected to require 3 to 5 work days, depending on weather and work conditions.
No permanent impacts, new structures or changes in grading are proposed. By using
these specific methods, impacts to vegetation and disturbance of soil are avoided.
ABUTTER NOTIFICATION EXEMPTION
Chapter 472 of the Acts of 1993, Section 2, states "(t)he notification required by section
one of this act shall not apply to projects of the department of highways."
PROJECT IMPACTS
The impacts can be classified as an alteration of a wetland as a result of the proposed
removal of 13 dead or dying willow trees. There are no physical impacts to wetland
resource areas, as the work will mostly be conducted from the buffer zone and under
frozen ground conditions. No work will be conducted if conditions are such tha.t the
ground will not capable of supporting the tree removal equipment . "
BVW DELINEATION
The BVW boundary is basically an herbaceous area abutting a channel that was
constructed within the MassDOT Administration Office property, to carry runoff from 1 -91
and Route 5 , T! he BVW is - s hown on Exhibit 4 and its boundary is indicative of the limits
of the mowed /maintained lawn. Wetland vegetation includes Purple Loosestrife, Reed .
Canary Grass, Swamp Milkweed and Cattails. The Weeping Willow Trees were planted.
as part of the original development and are designated FACW- by the USDA for Region
1, and FAC +%FACW national indicator status.
PARTY RESPONSIBLE FOR PERFORMING WORK
Eric Suher
Dadgayagoh Ma, LLC
P.O. Box 790
Holyoke, MA 01040
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BankofAmericai
MOUNTAIN PARK, LLC
o
'.
ADMINISTRATIVE OFFICE
P.O. BOX 790
HOLYOKE, MA 01041 -0790
5- 13/110
I
DATE
AMOUNT
1/28/11
237.50
PAY
Two Hundred Thirty -Seven and 50/100 Dollars
TO THE
ORDER
DEPARTMENT OF ENVIROMENTAL PROTECTION
OF
-
AUTHORIZED SIGNATURE
_ _ __
11 3 2 L911' :1:0 L 1000 L 381:
_ . _ _ ____ _ _ _. __ _._ _.,. .. _. _ .
004604 2 38 L 2 211'
_ _ _. _.__ ___.__ _ .... _ -__ . ..... .
__._. ...
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— - 3'218;.
BankofAmerica.
MOUNTAIN PARK, LLC.��®
ADMINISTRATIVE OFFICE
P.O. BOX 790
HOLYOKE, MA 01041 -0790
5- 13/110
I
DATE
AMOUNT i
1/28/11
262.50
PAY
Two Hundred Sixty -Two and 50/100 Dollars
TO THE
ORDER
CITY OF NORTHAMPTON
OF. ,
AUTHORIZED SIGNATURE
11 3 2 LBO 1:0 L L000 L 38
004604 2 38 L 2 20
I