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2021-03-22 Stockman Review - 1087 Westhampton Rd STOCKMAN ASSOCIATES LLC • P.O. BOX 9 • ADAMS, MA 01220 PHONE: 413-743-1372 • WWW.STOCKMANASSOCIATES.COM March 22, 2021 Ms. Sarah LaValley, Conservation, Preservation, and Land Use Planner Northampton Conservation Commission Planning & Sustainability 210 Main St., Room 11 City Hall Northampton, MA 01060 Re: Stormwater Management Report & Permit 1087 Westhampton Road Northampton, MA Dear Ms. LaValley and Commissioners: Per request of our client, Mr. Tim Seney, the following letter has been provided in review of the Stormwater Management Report for 1087 Westhampton Road in the City of Northampton prepared by Berkshire Design Group (BDG) dated February 18, 2021 as well as the subsequent Stormwater Management Permit Application approval by the City of Northampton Department of Public Works. Also included with the review are the March 22, 2021 Notice of Intent materials prepared by BDG. Stockman Associates LLC has reviewed these documents under the MA Wetlands Production Act regulations [310 CMR 10.53(1)] and the City of Northampton Wetlands Protection Ordinance Chapter 337. We offer the following comments. 310 CMR 10.53(1) In their May 28, 2020 Order of Conditions, the Northampton Conservation Commission approved the construction of a single-family driveway and associated stormwater management features within Buffer Zone to protected Bordering Vegetated Wetlands. Prior to the start of work, the Order required that the permittee obtain a stormwater permit for the development of a house and driveway from the Northampton Department of Public Works (DPW). See special condition #34. • The February 18, 2021 report and associated March 11, 2021 Stormwater Permit Plan were approved by the City of Northampton DPW on March 11, 2021. 2 | PAGE • As the Commission is aware, based on their approval OOC, driveway access to the house site cannot be obtained from the common drive to the west due to denial from the City Planning Department. As such, the driveway access is limited to Westhampton Road. In compliance with 310 CMR 10.53(1), the originally approved site plans as well as the newly approved stormwater management plan, avoid impacts to protected Bordering Vegetated Wetlands and limit Buffer Zone impacts, locating the limit of work at least 50-FT from the BVW boundary. • The approved stormwater management plan further complies with the regulation of 310 CMR 10.53(1) by clearly defining the limit of disturbance, requiring erosion controls, and preserving natural vegetation closer to the protected BVW. • Based on DPW approval and the materials prepared by Berkshire Design Group, the stormwater management plan complies with the MA DEP Stormwater Standards. o The stormwater design utilized ground-truth soil data obtained from the site. o The stormwater design incorporates LID/ESSD techniques including the creation of smaller subject catchment areas, rain garden and infiltration basins. The stormwater design also mimics sheet flows to the maximum extent possible. Stable (riprap) capture and conveyance techniques are limited to areas were topographic and Buffer Zone constraints apply. o The design model utilizes the coefficient for pavement, demonstrating forethought that although the driveway will be gravel during construction, it may ultimately be paved. This results in the infiltration system overperforming under gravel conditions and appropriately performing should the driveway be paved. • It is our opinion that the stormwater site plan revisions can be approved by the Northampton Conservation Commission under the requirements of special condition #34. However, it is our understanding that the permittee is submitting a formal request for an Amended Order of Conditions, should the Conservation Commission deem that process necessary for approval. Northampton Wetlands Protection Ordinance Chapter 337 In their May 28, 2020 Order of Conditions, the Northampton Conservation Commission denied the construction of a single-family driveway and associated stormwater management features within Buffer Zone to protected Bordering Vegetated Wetlands. Based on the Order and discussion during the requisite public hearing, the basis for denial was attributed to concerns regarding stormwater management. Subsequent to the denial a revised stormwater management plan has been prepared and approved by the City of Northampton DPW. 3 | PAGE • Berkshire Design Group has calculated the proposed buffer zone impacts. The limit of work associated with the driveway and stormwater management features within the 50 feet to 100 feet from wetlands totals 20,599-SF. In compliance with §337-10 Performance standards subpart E. (1), the proposed work is less than 20% of the area within the 50-FT to 100-FT buffer zone (17.8%). • In compliance with §337-10 Performance standards subpart E. (2), the limit of work for the proposed project has been located outside of the 50-foot Protection Zone. • Furthermore, the construction of a single-family driveway to gain access to a buildable upland is a limited project under 310 CMR 10.53(3)(e), which states limited project status for “The construction and maintenance of a new roadway or driveway of minimum legal and practical width acceptable to the planning board, where reasonable alternative means of access from a public way to an upland area of the same owner is unavailable…”. As such, under the City of Northampton Wetlands Protection Ordinance, the proposed project meets the exemption as a limited project under §337-10 Performance standards subpart E. (2)(c). • It is our opinion that the revised project complies with the applicable Performance standards under the City of Northampton Wetlands Protection Ordinance Chapter 337. More specifically, the revised stormwater management plan employs LID/ESSD techniques and utilizes features that are designed to improve water quality, prevent erosion, and promote groundwater infiltration. Due to a scheduling conflict, I will likely be unable to attend the Commission’s April 8, 2021 public hearing. As such, I offer these comments in advance of the hearing for the Commission’s consideration. Please do not hesitate to contact me with any questions or comments at (413) 743-1372 or at emily@stockmanassociates.com. Sincerely, Emily Stockman, MS, PWS Senior Scientist/Owner Stockman Associates LLC CC: Mr. Time Seney Mr. Tom Miranda Mr. Chris Chamberland (Berkshire Design Group)