11-002 NOI Response to Comments 082611.pdf
ProTerra Design Group, LLC Ph:(413)320-4918 1 Short Street, Suite 3 Fax:(413)320-4917 Northampton, MA 01060 www.proterra-design.com August 26, 2011 City of Northampton Conservation Commission
Office of Planning and Development City Hall Room 11 210 Main Street Northampton, MA 01060 RE: DEP File#: WE 246-0656 Response to Staff Comments Office of Planning and Development Upgrade
of a Gravel Access Road & Installation of a Telecommunications Facility Haydenville Road Leeds, MA Dear Commissioners: On behalf of the Applicant Global Tower Assets, LLC, and in cooperation
with the City of Northampton, we respectfully submit this response to the Memorandum from Ms. Sarah LaValley dated August 15, 2011. Our response follows the comments in bold. 1. Please
quantify the amount of temporary disturbance. The disturbance table appears to include both temporary and permanent disturbance. Note that the Ordinance requires that “The area of proposed
work shall not exceed the amount of degraded area.” The temporary disturbance disturbance is limited to the edge of traveled way where grading and crowning of the roadway cross‐section
spills into the wooded area and where erosion controls are installed. This will be allowed to revegetate as woods and grow to match existing conditions. No long term effects of the temporary
disturbance are anticipated. The area of work outside the degraded area on the roadway will be limited to stormwater improvements where necessary and as the current Massachusetts Stormwater
Regulations dictate their use and location. A revised disturbance table is provided under 5. 2. The narrative indicates that the stormwater improvements should result in an improvement
over existing conditions of the capacity of the resource area. Additional information is needed about how this will occur. It was necessary to implement BMP’s in accordance with the
MA Stormwater Handbook and Massachusetts Unpaved Roads Manual to improve conditions and allow year round vehicular access required of the cellular facility. The design design minimizes
impervious surfaces, maintains natural buffers, minimizes steep slopes and uses shall channels to manage runoff.
ProTerra Design Group, LLC Ph:(413)320-4918 1 Short Street, Suite 3 Fax:(413)320-4917 Northampton, MA 01060 www.proterra-design.com The current gravel woods road is cut into the landscape
and does not contain any ditches or meaningful crown to help control runoff. In a couple of spots the erosion was significant enough to warrant installation of waterbars to control runoff.
Although, the existing road is in suitable shape for light forestry activities as it was intended, additionally monthly traffic will quickly deteriorate this road. As is typical in redevelopment,
the maintenance and improvement of existing roadways including widening less than a single lane, adding shoulders, and improving existing drainage systems is typically allowed within
wetland buffers. If not properly managed, stormwater under the Commission’s jurisdiction has the potential to impair the interests of the act and bylaw. To address their potential impairment,
the Wetlands Protection Act under 310 CMR 10.05 (6) (k) requires that all industrial, commercial, institutional, office, residential, and transportation projects be managed according
to the stormwater standards. Stormwater BMP’s are proposed to result in an improvement over existing conditions. DEP has long maintained that stormwater BMP’s designed in accordance
with the standards established by the department are assumed to contribute to protection of the interests of the act specifically as they relate to flood control, storm damage prevention,
and prevention of pollution. 3. Please quantify the number of significant diameter trees within jurisdictional area to be removed. Are replacement plantings proposed? Approximately 15
trees greater than 12” will be removed within jurisdictional areas. No replacement plantings are proposed at this time as the majority of the site is thickly wooded. The clearing is
necessary to install the stormwater controls along the roadway. 4. The silt fence is proposed to be installed within the treeline. This should be moved closer to the roadway. The The
location of siltfence shown on the drawings was intended to follow the location approved on the AT&T plans submitted for the utility installation. Per your request, the siltfence will
be re‐located coincident with the tree clearing limit as shown on the plans. 5. It appears that the only location where alteration within the Protected Zone is located closer than existing
conditions is adjacent to Wetlands D and E. The roadway should be narrowed at these locations, or shifted so that new disturbance, if needed, will occur away from the resource area as
required by the Ordinance. The Applicant was able to address the permanent alteration in the “Protected Zone” by removing most of the road and drainage improvements outside of the 50
foot zone in the vicinity of wetlands D and E. In areas where the road passed within 50 feet of the wetland series D and E the road was transitioned and narrowed from 12 feet to 10 feet
to approximately coincide with the existing driveway width. A series of revised SK sheets
ProTerra Design Group, LLC Ph:(413)320-4918 1 Short Street, Suite 3 Fax:(413)320-4917 Northampton, MA 01060 www.proterra-design.com denoted SK‐1 through SK‐7 depict these edits. The
revised tables of disturbances are listed below. Significant reductions in buffer disturbance have been realized. Local Resource or Buffer Area Previously Degraded Proposed Temporary
Permanent Total 0‐50' Protected Zone 0 0 0 0 50‐100' Buffer Zone 2046 2654 2310 7010 0'‐100' Total 2046 2654 2310 7010 Table 6.1 ‐Revised Bordering Vegetated Wetlands (BVW) Buffer Disturbance
Local Resource or Buffer Area Previously Degraded Proposed Temporary Permanent Total 0‐50' Protected Zone 2012 1173 2249 5434 50‐100' Buffer Zone 2718 4557 3270 10545 0'‐100' Total 4730
5730 5519 15979 Table 6.2 ‐Revised Isolated Vegetated Wetlands (IVW) Buffer Disturbance 6. If points 1 and 5 cannot be met, restoration or mitigation could be provided according to 337‐10
E (2)h 5 or 6. The Applicant is not proposing any mitigation at this time as no direct impacts to the resource areas are proposed. Any disturbance of the “Protected Zone” is limited
to stormwater and temporary disturbances necessary to provide safe vehicular travel, to encourage driveway runoff to woodland buffers, and to direct erosive flows away from resource
areas. If you should have any questions or require any additional information, please do not hesitate to contact the undersigned at (413) 320‐4918. Professionally yours, PROTERRA DESIGN
GROUP, LLC. Jesse Moreno, PE Managing Partner cc: Global Tower Assets, LLC Elizabeth Thompson – Duval, Klasnick, & Pastel LLC DEP Enclosure