NOI Narrative_Citro80 Run Way | Lee, MA 01238 | (413)243-4122 | FAX (877)335-7282 | www.berkshireengineering.com
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Notice of Intent
Under Massachusetts Wetlands Protection Act MGL CH. 131, Section 40
For Properties Located at Assessors Map 25, Lot 78,
86 Riverbank Road, Northampton, MA 01060
July 2017
Project Location and Site Description:
The project is proposed by John Citro in the Town of Northampton, MA. The project location includes
the lot designated on the Assessors Map 25, Lot 78, 86 Riverbank Road. Surrounding land use consists
of a sparsely populated residential community. Lot sizes vary in the community but are typically
between one-quarter acre and three acres. Lot 78 size is approximately 0.109 acres according to
recorded survey information on file at the Hampshire County, Massachusetts Registry of Deeds. The
subject parcel is developed with a single-family home, asphalt driveway, concrete walk, trailer, stairs,
decks, and dock. The applicant wishes to demolish the existing single-family home and one of the
attached decks, and reconstruct them within the same footprint.
Existing Conditions:
The property known as 86 Riverbank Road is a residential use in common ownership consisting of five
side by side parcels (Map 25, Lots 1, 2, 78, 79, and 83), totaling a size of 0.988 acres, to the north of
Riverbank Road. The parcel falling in the center of the five (Lot 78) is developed with a single-family
house and associated decks, asphalt drive, concrete walk, and dock. A portion of the single-family house
extends onto the parcel to the West (Lot 79). A trailer and asphalt driveway are also located on Lot 79,
to the Northwest of the single-family home. The three remaining parcels, Lots 1, 2, and 83, are currently
undeveloped. The Connecticut River run adjacent to the northerly property boundaries of all five
parcels.
Ground cover at the site consists of both lawn and wooded areas. A mixture of deciduous and
coniferous trees line the three undeveloped parcels, while the developed parcels consist mostly of
unmaintained lawn with a few mature trees scattered throughout. The Connecticut River is present
along the northerly property boundary, North of the single-family home. The topography at the site is
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very steep with nearly 1:1 grades sloping down from the single-family house towards the northerly
property boundary where the Connecticut River runs adjacent. A relatively flat envelope, extending from
Riverbank Road, surrounds the asphalt drive and a majority of the single-family house. Storm water
runoff migrates via sheet flow from South to North and discharges to the Connecticut River. The natural
topography of the lot directs storm flow across the unmaintained lawn toward the river. The flow path
varies in length and range is measured between 50-25 feet prior to entering the resource area. NRCS
Soil Mapping indicates the existence of Hadley silt loam soil type at the subject parcel, with 3 to 8 %
slopes and a hydrologic soil classification “B” (See Appendix C).
Proposed Work:
The applicant proposes to demolish the existing damaged single-family house located on Lot 78, and
reconstruct a new house within the same footprint. The applicant also seeks to remove and replace the
existing decks (upper and lower), attached to the northerly side of the house that is to be demolished,
within the same footprint. The proposed structures, both the building and the decks, will be constructed
on a 2-inch helical pier foundation. In addition, a 12-inch stone diaphragm will be installed below the
proposed structures. Portions of the work fall within areas deemed jurisdictional under the
Massachusetts Wetlands Protection/Rivers Act and therefore an Order of Conditions is required. Means
and methods of work are outlined on the accompanying project plans and in narrative form in Appendix
A and B of this report.
Determination of Resource Areas – Definition, Critical Characteristics, and Boundary:
The Resource Areas located within the project vicinity include: Bordering Land Subject to Flooding, and
Riverfront to the Connecticut River.
Available USGS Quadrangle, FEMA, NHESP, Mass DEP Wetlands, NRCS Soil Mapping, current and historic
aerial photographs, as well as field recovered information were consulted in determining the
jurisdictional resource areas effecting the subject parcel. Please reference aerial photographs and
relevant mapping attached as Appendix C and D.
A. Bordering Land Subject to Flooding
Bordering Land Subject to Flooding is an area with low, flat topography adjacent to and inundated by
flood waters rising from creeks, rivers, streams, ponds, or lakes. It extends from the banks of these
waterways and water bodies; where a bordering vegetated wetland occurs, it extends from said
wetland. The boundary of Bordering Land Subject to Flooding is estimated as the maximum extent of
flood water which results from the 100-year storm frequency. This boundary can be determined from
available flood profile data provided by the Federal Emergency Management Agency (FEMA). According
to FEMA Community Panel #250167 0002 A, portions of the applicant’s parcel fall within the mapped
100-year floodplain (Map Zone A13) and the 100-YR flood elevation for this location is determined. The
site topographic survey uses a datum elevation referenced to a nearby benchmark located on the base
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of a traffic control pole on the Route 9 bridge. The 100-yr floodplain elevation at this location
encompasses all areas falling below the 125’ elevation and subsequently includes all of parcel 78.
B. Riverfront Area
A river is a naturally flowing body of water that empties into any ocean, lake, pond, or other river and
which flows throughout the year. Rivers included streams that are perennial because surface water
flows within them throughout the year. A river or stream shown as perennial on the current United
States Geological Survey (USGS) or more recent map provided by the Department is perennial. USGS
Quadrangle mapping displays the Connecticut River travelling adjacent to the northerly property
boundary of the subject parcel. Topographic mapping validates the presence of the river along the
northerly property boundary. All of the proposed work falls within the inner riparian zone of the
Riverfront Area to the Connecticut River.
C. Bank (Naturally Occurring Banks and Beaches)
A Bank is the portion of the land surface which normally abuts and confines a water body. It can occur
between a water body and a Bordering Vegetated Wetland. Under this definition, Bank is occurring
along the edge of the Connecticut River. A Bank can be partially or totally vegetated, or it can be
comprised of exposed soil, gravel or stone. The Bank of the Connecticut River has been defined in the
field according to the lower of either the mean annual high water mark or the first observable break in
slope along the Bank in the vicinity of the project. This area is characterized by a break in slope and the
presence of exposed soil. No disturbance to the Bank is required as part of the proposed work; however,
all of the proposed work falls within the 200-foot Riverfront Area to the Connecticut River.
D. Estimated Habitats of Rare Wildlife (for inland wetlands)
The project is located within jurisdictional priority habitat polygon as shown on current Natural Heritage
and Endangered Species Program (NHESP) mapping (Refer to Appendix C). A fully completed copy of this
Notice of Intent has been sent to the Program for final determination. The project is not believed to be
exempt from MESA filing.
Wetlands Protection Act Analysis:
Following are the Performance Standards associated with the proposed disturbance under the Wetlands
Protection and Rivers Act (WPA). The text of the WPA is followed by our response on how we meet each
applicable Standard.
A. Land Subject to Flooding (Bordering and Isolated Areas)
310 CMR 10.57(4)(a)(1): Compensatory storage shall be provided for all flood storage volume that will be
lost as the result of a proposed project within Bordering Land Subject to Flooding, when in the judgment
of the issuing authority said loss will cause an increase or will contribute incrementally to an increase in
the horizontal extent and level of flood waters during peak flows.
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Response: The project includes demolishing the existing home, with a First Floor (FF) elevation of
122.39’, and replacing it with a new home within the same footprint, with a FF elevation of 125.25’
which is above the floodplain elevation of 125’. Removal of the existing building will generate a total cut
of 1,374.17 CF in the floodplain, while the construction of the proposed building will only generate
961.70 CF of fill in the floodplain since the FF elevation of the new building will be raised slightly above
the floodplain elevation. The replacement of the upper and lower decks attached to the north side of
the home also falls below the floodplain elevation. Removal of the existing decks will generate a total
cut of 291.87 CF in the floodplain, while the construction of the proposed decks will only generate
240.52 CF of fill in the floodplain. In addition, the construction of a front and side entrance landing and
stairs is proposed in the floodplain elevation. The new entrances will generate a total of 51.04 CF of fill
in the floodplain.
The project includes the installation of (40) screw driven helical piers to support the new house and
decks. All piers are anticipated within the floodplain; however, the piers will be installed within the same
footprint as the existing foundation. As a result, the area required to complete the installation of the
piers within the floodplain will not generate any additional fill within the resource area. Each pier is a 2-
inch diameter post. The area required to complete the installation of the (40) piers within the floodplain
accumulates to 0.87 SF. Assuming the existing structures currently sit on a foundation of (40) 6-inch by
6-inch piers, at a minimum, totaling an area of 9 SF; the installation of the proposed helical piers would
result in a 10.7 CF reduction in fill (8 SF area with a 18-inch depth assumed), resulting in an increase in
available floodplain storage. Since the amount of cut at each incremental elevation is so minuscule, the
installation of the piers was neglected in the below calculations for additional floodplain storage. In
addition, the removal and replacement of 12-inches of soil with 12-inches of crushed stone below the
proposed structures will yield a very modest increase in available floodplain storage as well. The
application proposes to remove all spoils generated from the helical pier installation from the
floodplain; therefore, no additional flood storage is lost due to subsurface elements.
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COMPENSATORY STORAGE CALCULATIONS
INCREMENTAL ELEVATION PROPOSED
FILL (CF)
PROPOSED
CUT (CF)
VOLUME
CHANGE (CF)
110 FT TO 111 FT 0 0 0
111 FT TO 112 FT 0 0 0
112 FT TO 113 FT 0 0 0
113 FT TO 114 FT 0 0 0
114 FT TO 115 FT 0 0 0
115 FT TO 116 FT 0 0 0
116 FT TO 117 FT 0 0 0
117 FT TO 118 FT 19.58 19.58 0
118 FT TO 119 FT 101.23 101.23 0
119 FT TO 120 FT 0 0 0
120 FT TO 121 FT 0 0 0
121 FT TO 122 FT 0 822.06 822.06
122 FT TO 123 FT 0 723.17 723.17
123 FT TO 124 FT 12.52 0 -12.52
124 FT TO 125 FT 1,119.93 0 -1,119.93
TOTALS:
Total Addition
1,253.27 CF
Total Removal
1,666.03 CF
Additional Storage
412.77 CF
(15.29 CY)
B. Riverfront Area
310 CMR 10.58(5) Redevelopment Within Previously Developed Riverfront Areas; Restoration and
Mitigation.
Notwithstanding the provisions of 310 CMR 10.58(4)(c) and (d), the issuing authority may allow work to
redevelop a previously developed riverfront area, provided the proposed work improves existing
conditions. Redevelopment means replacement, rehabilitation or expansion of existing structures,
improvement of existing roads, or reuse of degraded or previously developed areas. A previously
developed riverfront area contains areas degraded prior to August 7, 1996 by impervious surfaces from
existing structures or pavement, absence of topsoil, junkyards, or abandoned dumping grounds. Work to
redevelop previously developed riverfront areas shall conform to the following criteria:
(a) At a minimum, proposed work shall result in an improvement over existing conditions of the
capacity of the riverfront area to protect the interests identified in M.G.L. c. 131 § 40. When a lot
is previously developed but no portion of the riverfront area is degraded, the requirements of310
CMR 10.58(4) shall be met.
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Response: The proposed work shall result in an improvement over the existing conditions. The capacity
of the riverfront area to achieve the performance standards noted in the act will be enhanced through
the stabilization of the subsurface below the proposed structures with the installation of a stone
diaphragm and the continued monitoring and removal of invasive species of trees and shrubs along the
riverfront.
(b) Stormwater Management to be in accordance with DEP standards.
Response: No stormwater management is required according to standards established by the
Department.
(c) Within 200-foot riverfront areas, proposed work shall not be located closer to the river than
existing conditions or 100 feet, whichever is less, or not closer than existing conditions within 25-
foot riverfront areas, except in accordance with 310 CMR 10.58(5)(f) or (g).
Response: Within the 200 FT Riverfront Area, no proposed work is located closer than existing
conditions. The closest existing structure, the existing dock, is located approximately 0 FT from the mean
annual high water mark of the Connecticut River. The proposed deck is planned to be approximately 19
FT from the river, while the existing deck that it is to replace is currently 19 FT from the river.
(d) Proposed work, including expansion of existing structures, shall be located outside the riverfront
area or toward the riverfront area boundary and away from the river, except in accordance with
310 CMR 10.58(5)(f) or (g).
Response: The proposed work, including the proposed building and decks, is not located any closer to
the river than the existing conditions.
(e) The area of proposed work shall not exceed the amount of degraded area, provided that the
proposed work may alter up to 10% if the degraded area is less than 10% of the riverfront area,
except in accordance with 310 CMR 10.58(5)(f) or (g).
Response: The existing lot contains degraded areas calculated at 1,832 SF. These areas include the
existing foundation for the single-family home and decks, (40) 6”x6” piers; existing trailer; concrete
walkway; entry stairs; asphalt driveway; and dock. With the proposed development, the lot will contain
degraded areas at 3,845 SF. Only 2,579 SF of the total degraded area proposed on the lot is due to the
“new work” and 1,266 SF of the existing degraded area is to remain. A 2,055 SF area of stone diaphragm
is proposed below the house and decks footprint; however, the stone diaphragm is a pervious surface.
The remaining 1,790 SF of proposed degraded area consists of the impervious surfaces on the subject
parcel. The impervious area increase totals approximately 524 SF and consists of the proposed
foundation for the new home and decks, (40) 2” diameter helical piers; new front and side entry stairs
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and landings; a vertical curb proposed along the southerly side of the new home; and a reconstructed
concrete walkway (See Wetlands Permitting Plan attached in Appendix D). and was not used when
calculating the degraded area on the lot. 10% of the total RA is calculated at 4,304 SF. Since the
proposed work will alter less than 10% of the riverfront area, the applicant does not need to meet the
requirements of 310 CMR 10.58(5)(f) or (g).
(f) When an applicant proposes restoration on-site of degraded riverfront area, alteration may be
allowed notwithstanding the criteria of 310 CMR 10.58(5)(c), (d), and (e) at a ratio in square feet
of at least I: I of restored area to area of alteration not conforming to the criteria. Areas
immediately along the river shall be selected for restoration. Alteration not conforming to the
criteria shall begin at the riverfront area boundary. Restoration shall include:
I. removal of all debris, but retaining any trees or other mature vegetation; grading to a
topography which reduces runoff and increases infiltration; coverage by topsoil at a
depth consistent with natural conditions at the site; and seeding and planting with an
erosion control seed mixture, followed by plantings of herbaceous and woody species
appropriate to the site; The area of proposed work shall not exceed the amount of
degraded area, provided that the proposed work may alter up to 10% if the degraded
area is less than 10% of the riverfront area, except in accordance with 310 CMR
10.58(5)(f) or (g).
Response: The project meets 310 CMR 10.58(5)(e) therefore mitigation and/or restoration is not
required. The applicant does not propose restoration on-site of degraded Riverfront Area.
(g) When an applicant proposes mitigation either on-site or in the riverfront area within the same
general area of the river basin, alteration may be allowed notwithstanding the criteria of 310
CMR 10.58(5)(c), (d), or (e) at a ratio in square feet of at least 2:1 of mitigation area to area of
alteration not conforming to the criteria or an equivalent level of environmental protection
where square footage is not a relevant measure. Alteration not conforming to the criteria shall
begin at the riverfront area boundary. Mitigation may include off-site restoration of riverfront
areas, conservation restrictions under M.G.L. c. 184, §§ 31 to 33 to preserve undisturbed
riverfront areas that could be otherwise altered under 31 0 CMR 10.00, the purchase of
development rights within the riverfront area, the restoration of bordering vegetated wetland,
projects to remedy an existing adverse impact on the interests identified in M.G.L. c. 131, § 40 for
which the applicant is not legally responsible, or similar activities undertaken voluntarily by the
applicant which will support a determination by the issuing authority of no significant adverse
impact. Preference shall be given to potential mitigation projects, if any, identified in a River
Basin Plan approved by the Secretary of the Executive Office of Environmental Affairs.
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Response: The project meets 310 CMR 10.58(5)(e) therefore mitigation and/or restoration is not
required. Other than monitoring the area for invasive species, with invasive removal efforts being
completed when necessary, and the general mitigation requirement provided in Appendix A, the
applicant does not propose mitigation on-site of the degraded Riverfront Area.
(h) The issuing authority shall include a continuing condition in the Certificate of Compliance for
projects under 310 CMR 10.58(5)(f) or (g) prohibiting further alteration within the restoration or
mitigation area, except as may be required to maintain the area in its restored or mitigated
condition. Prior to requesting the issuance of the Certificate of Compliance, the applicant shall
demonstrate the restoration or mitigation has been successfully completed for at least two
growing seasons.
Response: The applicant will abide by any continuing conditions included in the Order issued by the
Commission and recorded with the Registry of Deeds. It is anticipated that the order would prohibit any
further alteration of the mitigation area consistent with the provisions of 310 CMR 10.58 (5)(h). The
applicant shall not request a Certificate of Compliance for a minimum of 2 growing seasons after
completion of the proposed work, and shall submit satisfactory evidence to the Commission that the
mitigation effort has been successful.
Further clarification on how the applicant proposes to meet the required redevelopment standards is
outlined below using the DEP printed checklist for guidance entitled, “9 Steps for evaluation of 10.58(5)
Redevelopment Projects.”
9 Steps…..
1. Total Area of Riverfront on lot= 43,037.28 SF
2. Present footprint containing degraded areas (prior to the Act)
1,832 SF - Existing single-family home and decks foundation, trailer, stairs, concrete walkway,
asphalt driveway and dock.
3. Existing area of degradation on lot in percent= 4.3%
The proposed encroachment is located the same or greater distance from the river.
4. Existing dock = 0 FT
Existing deck (to be removed) = 19 FT, Proposed deck = 19 FT.
Location was chosen due to existing developed areas in project location.
5. Proposed footprint containing degraded areas (including existing degraded areas to remain)
3,845 SF – Proposed single-family home and decks foundation, trailer, new entry stairs and
landings, vertical curb, reconstructed concrete walkway, asphalt driveway and dock.
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Area of existing degradation to remain= 1,266 SF (existing impervious surface area)
Area of proposed degradation due to “new work” under the definition in the WPA= 2,579 SF
(2,055 SF stone diaphragm area and 524 SF proposed impervious surface area). Area of
proposed impervious surfaces fall within same footprint of existing impervious surfaces. Area of
proposed pervious stone diaphragm falls within same footprint of existing single-family home
and decks.
6. The project meets or exceeds DEP Stormwater Management Policy Requirements. Project is
exempt (Single Family Home).
7. The proposed site will improve the overall capacity of the Riverfront Area through improved
drainage, and continued monitoring and removal of invasive species.
8. The project does meet 310 CMR 10.58(5)(e) therefore mitigation and/or restoration is not
required.
Total Area of Restoration = 0 SF
9. The project does meet 310 CMR 10.58(5)(e) therefore further mitigation is not required.
Total Area of Mitigation = 0 SF
C. Bank
310 CMR 10.54(4)(a): ... any proposed work on a Bank shall not impair the following:
the physical stability of the bank; the water carrying capacity of the existing channel within the bank;
groundwater and surface water quality;4. the capacity of the bank to provide breeding habitat, escape
cover and food for fisheries;5. the capacity of the bank to provide important wildlife habitat functions.
(see 310 CMR 10.54(4),5.
Response: No work is proposed along the Bank of the river and up gradient work areas are proposed to
incorporate erosion and sedimentation controls. The closest anticipated Riverfront Area disturbance is
to occur +/- 19 feet from this resource area.
List of Appendices:
Appendix A – General Mitigation Requirements
Appendix B – Work Sequence
Appendix C – Relative Site Data/Mapping (Aerial, FEMA Map, MassDEP Wetlands Map, NHESP Map,
USGS Quad Map, NRCS Soils Map)
Appendix D – Wetlands Permitting Plan