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Industrial Drive Notice of Intent-NarrativeCover Letter WPA Form 3 – Notice of Intent Appendix A Project Narrative Section 1 Introduction 1.1 Project Background 1-1 Section 2 Existing Conditions 2.1 General 2-1 2.2 Methodology of Wetland Resource Area Delineations 2-1 2.3 Description of MAWPA Resource Areas 2-1 2.4 Rare Species 2-1 Section 3 Proposed Conditions 3.1 Protective Measures 3-1 Section 4 Regulatory Compliance 4.1 Limited Project Status 4-1 4.2 Jurisdictional Alterations 4-1 4.3 Performance Standards Compliance 4-1 4.4 Abutter Notification 4-2 Appendix B Figures Figure 1 – USGS Site Locus Figure 2 – Priority Resource Map Figure 3 – Orthophotograph Site Plan FEMA FIRMette Best Management Practice Typicals Appendix C Site Photographs Introduction This Notice of Intent (NOI) is being submitted on behalf of the Massachusetts Electric Company d/b/a National Grid (MECo) for a utility pole replacement project located within a utility easement off of Industrial Drive in Northampton, Massachusetts. The project will involve access to and replacement of one electrical distribution pole, Pole 9. A USGS Site Locus (Figure 1), DEP Priority Resource Area Map (Figure 2), Orthophotograph site plan (Figure 3) and FEMA FIRMette are provided in Appendix B. The project will include the restoration of temporarily disturbed areas near the pole to match pre-construction grades. 1.1 Project Background A notice of utility maintenance activities was submitted to the Northampton Conservation Commission notifying them of the work and that it is exempt from the Massachusetts Wetlands Protection Act. The Commission notified Tighe & Bond that the work is not considered exempt under the Northampton Wetlands Protection Ordinance (the Ordinance). Existing Conditions This section provides a site description and resource area characterization for the project area. Land use in the general vicinity of the project was determined based on direct observations made during site inspections and a review of information available through the Massachusetts Geographic Information System (MassGIS). 2.1 General The replacement of Pole 9 will occur within a utility ROW off of Industrial Drive in Northampton, Massachusetts. An Orthophotograph site plan of the project site is provided in Appendix B. Photographs of the project area are provided in Appendix C. 2.2 Methodology of Wetland Resource Area Delineations Wetland resource area investigations were conducted on July 10, 2013. Resource areas were delineated in accordance with Massachusetts Department of Environmental Protection (MassDEP) guidelines and 310 CMR 10.00, and the Northampton Wetlands Protection Ordinance (WPO). 2.3 Description of Resource Areas Tighe & Bond delineated resource areas with the following flag series: 1A series: 1A-1 through 1A-5 delineate a wet meadow/shrub swamp wetland within the utility easment. The wetland boundary approximately follows the extent of development. Typical vegetation identified includes glossy buckthorn (Frangula alnus), common reed (Phragmites australis), and sensitive fern (Onoclea sensibilis). 1B series: 1B-1 through 1B-6 delineate the mean annual high water line defining a depression which is being treated as a Presumed Vernal Pool under the WPO for the purposes of this NOI. 2.4 Rare Species The Massachusetts Natural Heritage and Endangered Species Program (NHESP) Atlas, 14th Edition, effective October 1, 2008, and datalayer maintained by Massachusetts Geographic Information System (MassGIS) were consulted during the preparation of this NOI. According to these resources the proposed work is not within an area identified by NHESP as Priority Habitat for Rare Species or Estimated Habitat for Rare Wildlife. Proposed Conditions The project consists of the replacement of one distribution pole, Pole 9. As part of the proposed work, the location of the new pole will be shifted approximately 3 feet to the south, further away from the edge of the presumed vernal pool. The pole will be installed with a truck or track mounted auger to approximately 8-feet below surface grade. Spoils generated from the replacement will be used as backfill for the hole, or will be deposited in an upland area. The old pole will be cut near the ground surface properly disposed off site. The underground portion of the pole will be left in place to minimize disturbance to the adjacent presumed vernal pool. Access to the site will be along the existing utility easement from the south. Wooden swamp mats will be used as necessary to access the area to limit impacts to wetlands. Some vegetation clearing and/or minor alterations of uneven topography may be required within the utility ROW to safely install swamp mats, access the pole, and complete the work. All work associated with replacing the pole will likely be conducted from swamp mats. 3.1 Protective Measures The following general measures will be employed to minimize impacts to the resource areas and to provide improvements to resource areas within the limits of the work area once construction is complete: Erosion and sedimentation controls consisting of silt soxx, straw wattles, weed free bales, or equivalent will be installed prior to soil disturbing activities as necessary based on site conditions. The pole will be accessed from the south to avoid crossing the presumed vernal pool, which is present across most of the ROW to the north of the pole. Any areas of disturbed soil will be mulched with hay or straw as necessary following the completion of work. Swamp mats will be installed as determined necessary to minimize the impact to wetland resource areas. Regulatory Compliance This section summarizes the project’s relationship to and compliance with the Northampton Wetlands Protection Ordinance. 4.1 Limited Project Status The proposed utility pole installation project activities qualify for consideration of exception to the performance standards per S337-10(E)(2)(c), as it qualifies as a Limited Project per 310 CMR 10.53-3d: The construction, reconstruction, operation and maintenance of underground and overhead public utilities, such as electrical distribution or transmission lines, or communication, sewer, water and natural gas lines, may be permitted, in accordance with the following general conditions and any additional conditions deemed necessary by the issuing authority: The issuing authority may require a reasonable alternative route with fewer adverse effects for a local distribution or connecting line not reviewed by the Energy Facilities Siting Council; Best available measures shall be used to minimize adverse effects during construction; The surface vegetation and contours of the area shall be substantially restored. 4.2 Jurisdictional Alterations The proposed project will result in an alteration of approximately 2 square feet for the installation of the new pole, located within the wetland and presumed vernal pool resource area. Up to approximately 414 linear feet of swamp mats will be installed within the wetland to serve as a Best Management Practice, minimizing the impact to the resource area. Assuming 16-foot wide mats are used, up to approximately 6,624 square feet of swamp mats will be installed within the wetland. Up to approximately 128 linear feet (2,048 square feet) of the total swamp mat crossing will be within the 100-foot Vernal Pool Resource Area. Some vegetation clearing and/or minor alterations of uneven topography may be required within the wetland, the Vernal Pool Resource Area, and/or the 100-foot Buffer Zone within the utility easement to safely install the swamp mats as necessary, access the area, and complete the work. The project will not create an increase in impervious area. 4.3 Performance Standards Compliance The Commission may permit the proposed temporary alterations within the above described resource areas and their associated protected zones as the project qualifies for exception to the performance standards per S337-10(E)(2)(c). The Project qualifies as a Limited Project per 310 CMR 10.53-3d. The project has been designed to minimize temporary impacts to resource areas by proposing an access route with the least amount of anticipated impacts to resource areas, and proposing protective measures described in Section 3 of this NOI.