Loading...
2019.04.25 Staff Report.doc To: Conservation Commission From: Sarah LaValley RE: Staff Report, April 25 Commission Meeting 5:30 PM Notice of Intent for roadway improvements including drainage improvements and adding and replacing shoulders. Northampton DPW, Cross and Spring Streets right-of-way. Application Overview: The application proposes improvements to Spring and Cross Streets, many of which are already permitted pursuant to the DPW’s bundled Order of Conditions. New work requiring review includes addition of a gravel shoulder within riverfront area to the Mill River on Spring Street, and catchbasins that will connect to existing Mill River outfalls on both Spring and Cross Street, and addition of paved aprons to slow runoff and limit erosion. The work is proposed to address drainage and flooding concerns that have damaged the roadway. Work is a 310CMR ‘limited project.’ DEP Comments: [1] Please review the definition of stormwater redevelopment, 310 CMR 10.04 Redevelopment as well as 310 CMR 10.04 Stormwater Management System Improvement. There are two new point sources listed in the NOI. Staff response: Stormwater redevelopment includes: (a) maintenance and improvement of existing roadways including widening less than a single lane, adding shoulders, correcting substandard intersections, improving existing drainage systems and repaving; (b) development, rehabilitation, expansion and phased projects on previously developed sites provided the redevelopment results in no net increase in impervious area; and (c) remedial projects specifically designed to provide improved stormwater management such as projects to separate storm drains and sanitary sewers and stormwater retrofit projects. Stormwater Management System Improvement means: (a) expansion of a stormwater management system beyond its existing geographic footprint to provide treatment for additional stormwater volume, provide additional groundwater recharge or enhance groundwater recharge or pollutant removal capability such as the addition of treatment train components; or (b) modification to, or addition of, features within the existing geographic footprint of a stormwater management system to enhance groundwater recharge or pollutant removal capability, such as modifying outlet control structures. Staff Response: The application indicates that while new catchbasins are proposed to provide pretreatment, they will connect to existing drainlines. The Commission should clarify new vs. redevelopment work with the applicant. If new work, all stormwater standards must be met. [2] Per Stormwater Standard 7, A redevelopment project is required to meet the following Stormwater Management Standards only to the maximum extent practicable: Standard 2, Standard 3, and the pretreatment and structural stormwater best management practice requirements of Standards 4, 5 and 6. Existing stormwater discharges shall comply with Standard 1 only to the maximum extent practicable. A redevelopment project shall also comply with all other requirements of the Stormwater Management Standards and improve existing conditions. It is not clear that Standard 7 has been met. [4] The Commission should wait to close the public hearing until NHESP has issued its determination Staff response: NHESP has issued a comment letter confirming that the project will not result in a take of endangered species, and did not require any conditions. Consistency with the Wetlands Protection Act and Northampton Wetlands Ordinance, Staff Recommendation: The project should result in an overall improvement, by increasing treatment of runoff to waterways. Discuss identified concerns, and issue and Order of Conditions with standard conditions. The project proposes addition of gravel shoulders to slow roadway runoff in areas where it flows directly from pavement to surrounding areas. The Commission should discuss any measures necessary to prevent gravel from entering resource areas, while noting that erosion along roadways already contributes to aggradation in waterways. The project includes stone aprons at stormwater discharge points. The Commission should discuss whether a vegetated alternative is possible, noting that they will discharge to permanent open space in some locations. Erosion controls and bmp’s to limit resource area disturbance during construction are not highlighted. Discuss these and condition as/if necessary. Discuss whether vegetated alternatives to paved aprons are possible. 5:40 PM Notice of Intent for roadway improvements including drainage work, repaving, and adding guardrail. Northampton DPW, Chesterfield Road right-of-way. Application Overview: The application proposes improvements Chesterfield Road, many of which are already permitted pursuant to the DPW’s bundled Order of Conditions. These include guardrails, paving, and drainage work. New work requiring review includes two new stormwater outfalls to bordering land subject to flooding. These are a preferred resource alternative to direct deposition of roadway drainage into the Brook. The work is proposed to address drainage and flooding concerns that have damaged the roadway. Work is a 310CMR ‘limited project.’ DEP had no comments on the application. Consistency with the Wetlands Protection Act and Northampton Wetlands Ordinance, Staff Recommendation: The project should result in an overall improvement, by increasing treatment of runoff to waterways. Discuss identified concerns, and issue and Order of Conditions with standard conditions. The project includes a stone apron at the discharge point to BLSF. The Commission should discuss whether a vegetated alternative is possible, noting that they will discharge to permanent open space in some locations. Erosion controls and bmp’s to limit resource area disturbance during construction are not highlighted. Discuss these and condition as/if necessary. Certificate of Compliance, MassDOT, 155 Locust Street, DEP File 246-0726 A Certificate of Compliance to indicate that this Order is ‘invalid’ and work was not begun, will need to be issued to allow the Commission to consider a new application for this parcel. 5:50 PM Notice of Intent for dumping ground remediation within bordering vegetation wetland and riverfront to unnamed stream. Work to include landfill excavation, removal of buried solid waste, and restoration to pre-construction conditions. MassDOT. 155 Locust Street, Map ID 23B-013 Application Overview, Staff Recommendation to Continue Hearing The application proposes removal of buried solid waste at the former Mass Highway garage on Locust Street, and restoration of the area. Work will include a temporary roadway for access, removal of waste with heavy equipment, screening and backfilling of clean soil, and creation of a restoration area with hydric soils and native plantings. The Commission previously issued Orders of Conditions for this work in 2014, and again in 2018. Proposed resource area impacts have increased significantly, from 0 lf to 300 lf of bank, 22,650 sf to 25,323 sf of riverfront, and 5500 to 10,976 sf of BVW. The project limits have increased slightly, but staff is not clear on the reason for the discrepancies. The applicant should provide additional information on the project, updates, and modifications, at the hearing. The work also requires review under a Notice of Project Change pursuant to the Massachusetts Environmental Policy Act, and a Water Quality Certificate from DEP. The work is not subject to the local Wetlands Ordinance. Wetland boundaries will need to be reconfirmed, and marked in the field. DEP Comments: MassDEP recommends the Commission keep the NOI hearing open until the 401 WQC has been issued so there is no conflict between permits. Staff agrees.