WheelchairCurbCutsTier2KeyesMainSignedTier II: Site-Specific Environmental Assessment
Version 1: Tier II Checklist 1
HUD Grant Number: B-19-MC-25-0027
Date of Field Inspection: Date Review Initiated:
Inspector Name: Reviewer Name:
Name of Program: Florence Wheelchair Curb Cut Ramps
Street Address:
Property ID: GPS Coordinates (Lat/Long) :
Project Description: The City of Northampton will install wheelchair sidewalk curb cuts across the City to bring them into conformance with current Americans with Disabilities (ADA) and American Access Board (AAB) standards. The exact locations were not identified during the Tier 1 Review, but the City will use this Site-Specific Assessments to finish the Tier 2 Review.
Site Specific:
City of Northampton
The proposed project involves installing wheelchair curb cuts to conform with the ADA and AAB standards.The proposed site does not increase the overall footprint of the existing impervious surface. The proposed site does not alter historical properties directly. The proposed site does not alter wetlands or drainage patterns.The proposed site is not within a floodplain.
May 3, 2021
Keith Benoit
42.33542714277062, -72.67212518067028
70 Main & Keyes St., Florence, MA 01062
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Five curb cuts on Main St. at Keyes Street. Three on the south side of Main St. and two on the North side.
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Tier II: Site-Specific Environmental Assessment
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Site-Specific Findings
STATUES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR 50.4 AND 58.6
Airport Hazards
24 CFR Part 51 Subpart D
Not applicable. Compliance determined in Tier 1. There is a municipal airport in the City, but it is unlikely that a curb cut will be requested within 2,500 feet of the airport. The City has a prioritization matrix from the 2018 "Public Sidewalk Inventory Analysis Report" that it will use to install curb cuts and there are other areas in the City that are higher on the list. The City will reject requests for curb cuts within 2,500 ft. of the airport. The project is compliant with 24 CFR Part 51 Subpart D.
Coastal Barrier Resources
Coastal Barrier Resources Act, as amended by the Coastal Barrier Improvement Act of 1990 [16 USC 3501]
Flood Insurance
Flood Disaster Protection Act of 1973 and National Flood Insurance Reform Act of 1994 [42 USC 4001-4128 and 42 USC 5154a]
Not applicable. Compliance determined in Tier 1. This project is not located in a CBRS unit and therefore this project is compliant with 16 USC 3501, the City is not within a Coastal Barrier Resource area.
Not applicable. Compliance determined in Tier 1. This project does not provide financial assistance for mobile home, building, or insurable property. Therefore, the project is compliant with 42 USC 4001-4128 and 42 USC 5154a.
Clean Air Act
Clean Air Act, as amended, particularly section 176(c) & (d); 40 CFR Parts 6, 51, 93
Not applicable. Compliance determined in Tier 1. This project does not include new construction or conversion of land use facilitating the development of public, commercial, or industrial facilities or five or more dwelling units. It is therefore compliant with the Clean Air Act (42 USC 7401 et seq.) as amended particularly Section 176(c) and (d) (42 USC 7506(c) and (d)).
Coastal Zone Management
Coastal Zone Management Act, sections 307(c) & (d)
Not applicable. Compliance determined in Tier 1. This project is not in and does not affect any Coastal Zones. It is not subject to state review. It is therefore compliant with the Coastal Zone Management Act, sections 307(c) & (d)].
Contamination and Toxic Substance
24 CFR Part 50.3(i) & 58.5(i)(2)
Evaluate the site for contamination. Do any of the following apply to the subject property? (1) Property is listed on an EPA Superfund National Priorities or Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) List, or equivalent State list; (2) Property is within 3,00 feet of a landfill site, hazardous waste or solid waste cleanup site; (3) Has an underground storage tank (which is not a residential fuel tank); (4) Known or suspected to be contaminated by toxic chemicals or radioactive materials; or (5) During site reconnaissance of subject property and visible adjoining properties, inspector has observed potential environmental concerns.
1. Evaluation
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No → Provide a map or other documentation of absence or presence of contamination and explain evaluation of site contamination in the Worksheet Summary.>> Based on the response, the review is in compliance with this section. Continue to the Worksheet Summary below.
Yes → Describe the findings, including any recognized environmental conditions (RECs), in Worksheet Summary below. Continue to Question 2.
2. Mitigation
Document the mitigation needed according to the requirements of the appropriate federal, state, tribal, or local oversight agency. If the
adverse environmental impacts cannot be mitigated, then HUD assistance may not be used for the project at this site.
Can adverse environmental impacts be mitigated?
Adverse environmental impacts cannot feasibly be mitigated
→ Project cannot proceed at this location
Yes, adverse environmental impacts can be eliminated through mitigation.
→ Provide all mitigation requirements and documents. Continue to Question 3.
3. Describe how compliance was achieved. Include any of the following that apply: State Voluntary Clean-up Program, a No Further
Action letter, use of engineering controls, or use of institutional controls.
If a remediation plan or clean-up program was necessary, which standard does it follow?
Complete removal
Risk-based correction action (RBCA)
Other
Worksheet Summary
Compliance Determination
Provide a clear description of your determination and a synopsis of the information that it was based on, such as:
•Map panel numbers and dates
•Names of all consulted parties and relevant consultation dates
•Names of plans or reports and relevant page numbers
•Any additional requirements specific to your region
Compliance documentation can be found attached to this Tier II Checklist. Page(s) _____________
Are formal compliance steps or mitigation required?
Yes
No
Endangered Species
Endangered Species Act of 1973, particularly section 7; 50 CFR Part 402
Not applicable. Compliance determined in Tier 1. This project does not involve any activities that have the potential to affect species or habitats. There are no endangered species or critical habitats in Northampton. While the exact project areas have yet to be determined, all activities proposed will be entirely limited to modification of previously existing paved streets and sidewalks.
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Wheelchair curb cuts are 2,115 ft. (upstream) from the only site identified on the toxic release inventory (BI-QEM
INC, 238 NONOTUCK ST., FLORENCE, MA 01062). Of the 1,248 lbs. of formaldehyde that was released in 2019,
1,007 lbs. ( 80%) was released into the air. The remaining 241 lbs. was released at an off-site disposal facility. The
facility has a downward trend in overall releases, where in the year 2007 they released 9,000 lbs. and by 2019 they
were releasing 1,248 lbs. This produced a Risk-Screening Environmental Indicators (RSEI) score of 2,568 for 2019.
Wheelchair project is not likely to effect the release of chemicals at the facility.
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The project does not include any expansion of developed or degraded areas, and no vegetation removal or soil excavation is proposed. It is therefore compliant with the Endangered Species Act of 1973, particularly section 7; 50 CFR Part 402.
Explosive and Flammable Hazards
24 CFR Part 51 Subpart C
Not applicable. Compliance determined in Tier 1.
The proposed project does not involve development, construction, rehabilitation that will increase residential densities, or conversion
of land use. Furthermore, The proposed HUD-assisted project itself is not the development of a hazardous facility (a facility that mainly stores, handles or processes flammable or combustible chemicals such as bulk fuel storage facilities and refineries). Therefore, the
review is in compliance with 24 CFR Part 51 Subpart C.
Farmland Protection
Farmland Protection Policy Act of 1981, particularly sections 1504(b) and 1541; 7 CFR Part 628
Not applicable. Compliance determined in Tier 1. This project does not involve activities that include new construction, acquisition of undeveloped land or conversion that could convert agricultural land to a non-agricultural use. Furthermore, important farmland in the City of Northampton is in a low population density area and curb cuts will not be required there. The proposed project is in compliance with 7 CFR Part 628.
Floodplain Management
Executive Order 11988, particularly section 2(a); 24 CFR Part 55
Provide a FEMA/FIRM map showing this site.
1.Does your project site occur in a base floodplain, have an impact on the base floodplain [See also 24 CFR 55.12(c)(6)] or indirectly support floodplain development?
Yes → Continue to Question 2, attach Site Plans of project.
No → Based on the response, the review is in compliance with this section. Continue to the Worksheet
Summary below.
Select the applicable floodplain using the FEMA map or the best available information: 2.
Floodway → Continue to Question 3, Floodways
500-year floodplain (B Zone or shaded X Zone) → Continue to Question 4, 500-year Floodplains
100-year floodplain (A Zone) → The 8-Step Process is required. Continue to Question 5, 8-Step process
3. Floodways
Is this a functionally dependent use?
Yes
The 8-Step Process is required. Work with HUD OEE to determine a way to satisfactorily continue with this project. Provide a
completed 8-Step Process, including the early public notice.
→Continue to Question 5, 8-Step Process
No
Federal assistance may not be used at this location unless a 55.12(c) exception applies. You must either choose an alternate site or cancel
the project at this location.
4. 500-year Floodplain
Is this a critical action?
No → Based on the response, the review is in compliance with this section. Continue to the Worksheet
Summary below
Yes → Continue to Question 5, 8-Step Process
Continue to Question 7: Evaluate Alternatives
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5. 8-Step Process
In any of the Questions, 1-4 did the 8-Step Process apply?
Yes, the 8-Step Process applies, Begin Public Review Process and Continue to Question 7, Evaluate Alternatives No, continue to Worksheet Summary
7. Evaluate Alternatives: Identify and evaluate at least three alternatives, including when possible, alternative sites outside the floodplain or wetland, alternative actions, and the “no action” option.
8. Identify Adverse & Beneficial Impacts including direct and indirect support of other floodplain and wetland development that
might result from the project. Analyze the following factors: (1) Natural environment (topography, habitat, hazards); (2) Social concerns (aesthetics, historic and cultural values, land use patterns); (3) Economic aspects (costs of construction, transportation and relocation); and (4) Legal considerations (deeds, leases).
9. Mitigation
For the project to be brought into compliance with this section, all adverse impacts must be mitigated. Explain in detail the
exact measures that must be implemented to mitigate for the impact or effect, including the timeline for implementation.
Mitigation and Resilience Measures: Mitigation and resilience measures that will reduce the risk of loss of life and property and increase the ability to shelter in place will be considered eligible activities. These measures can be applied to homes that are structurally sound and meet all requirements. Mitigation activities may include, but are not limited to the following:
•Wet Floodproofing
•Dry Floodproofing
•Construction of a flood barrier
•Incorporation of interior modification/retrofit measures
Which of the following mitigation/minimization measures have been identified for this project in the 8-Step ? Select all that
apply.
Permeable surfaces
Natural landscape enhancements that maintain or restore natural hydrology
Planting or restoring native plant species
Bioswales
Evapotranspiration
Stormwater capture and reuse
Green or vegetative roofs with drainage provisions
Natural Resources Conservation Service conservation easements or similar easements
Floodproofing of structures
Elevating structures including free-boarding above the required base flood elevations
6. Public Review Process Complete? Attach any public notices or other documentation.Yes
No
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10. Reevaluate Alternatives in light of the information gained to determine if the proposed action is still practicable. If new construction is to be located in a floodplain or wetland, apply accepted floodproofing and other measures. To achieve flood
protection, wherever practicable elevate the structures above the flood level rather than fill in land.
11. Announced and Explained Decision to Public: Attach public notice and decisions.
Yes
No
12. Implement proposal with appropriate mitigation.Implement proposed action in compliance with minimization plans and flood insurance
requirements
Worksheet Summary
Compliance Determination
Provide a clear description of your determination and a synopsis of the information that it was based on, such as:
•Map panel numbers and dates
•Names of all consulted parties and relevant consultation dates
•Names of plans or reports and relevant page numbers
•Any additional requirements specific to your region
This project does not occur in the floodplain and has not affect on the floodplain. The area of disturbance will be a
one for one replacement with current impermeable surface. Attached is map showing 500 year floodplain.
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Either provide the memo itself or a link to it here. Explain and justify the other determination here:
→ Continue to the Worksheet Summary
Yes, because the project includes activities with potential to cause effects (direct or indirect). Continue to Step 1.
Step 1—Initiate Consultation
Use the When to Consult with Tribes Checklist within Notice CPD-12-006: Process for Tribal Consultation to determine if you should
invite tribes to consult on a particular project. Use the Tribal Directory Assessment Tool (TDAT) to identify tribes that may have an
interest in the area where the project is located. Note that consultants may not initiate consultation with Tribes.
Select all consulting parties below (check all that apply):
State Historic Preservation Officer (SHPO)
Advisory Council on Historic Preservation
Indian Tribes, including Tribal Historic Preservation Officers (THPOs) or Native Hawaiian Organizations (NHOs)
List all tribes that were consulted here and their status of consultation:
Other Consulting Parties
List all consulting parties that were consulted here and their status of consultation:
The Section 106 Process
After determining the need to do a Section 106 review, initiate consultation with regulatory and other interested parties, identify and evaluate
historic properties, assess effects of the project on properties listed on or eligible for the National Register of Historic Places, and resolve any
adverse effects through project design modifications or mitigation.
Note that consultation continues through all phases of the review.
Step 1: Initiate consultation
Step 2: Identify and evaluate historic properties
Step 3: Assess effects of the project on historic properties
Step 4: Resolve any adverse effects
1.Is Section 106 review required for your project?
No, because the project consists solely of activities listed as exempt in a Programmatic Agreement (PA).
Either provide the PA itself or a link to it here. Mark the applicable exemption or include the text here:
Historic Preservation
National Historic Preservation Act of 1966, particularly sections 106 and 110; 36 CFR Part 800
→ Continue to the Worksheet Summary.
No, because the project consists solely of activities included in a No Potential to Cause Effects memo or other determination [36 CFR
800.3(a)(1)]
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MACRIS was searched for nearby properties (70 Main Street) and no historic properties were identified.
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Describe the process of selecting consulting parties and initiating consultation here:
Provide all correspondence, notices, and notes (including comments and objections received) and continue to Step 2.
Step 2—Identify and Evaluate Historic Properties
Define the Area of Potential Effect (APE), either by entering the address(es) or providing a map depicting the APE. (Attach an
additional page if necessary.)
Gather information about known historic properties in the APE. Historic buildings, districts and archeological sites may have been
identified in local, state, and national surveys and registers, local districts, municipal plans, town and county histories, and local history
websites. If not already listed on the National Register of Historic Places, identified properties are then evaluated to see if they are
eligible for the National Register.
In the space below, list historic properties identified and evaluated in the APE.
Every historic property that may be affected by the project should be listed. For each historic property or district, include the National
Register status, whether the SHPO has concurred with the finding, and whether information on the site is sensitive. Attach an
additional page if necessary.
Provide the documentation (survey forms, Register nominations, concurrence(s) and/or objection(s), notes, and photos) that justify your
National Register Status determination.
Was a survey of historic buildings and/or archeological site done as part of the project?
Yes → Provide survey(s) and report(s) and continue to Step 3.
Additional notes:
No → Continue to Step 3.
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Step 3—Assess Effects of the Project on Historic Properties
Only properties that are listed on or eligible for the National Register of Historic Places receive further consideration under Section 106.
Assess the effect(s) of the project by applying the Criteria of Adverse Effect (36 CFR 800.5). Consider direct and indirect effects as
applicable as per HUD guidance.
Choose one of the findings below—No Historic Properties Affected, No Adverse Effect, or Adverse Effect; and seek concurrence
from consulting parties.
No Historic Properties Affected
Document reason for finding:
No historic properties present. → Provide concurrence(s) or objection(s) and continue to the Worksheet
Historic properties present, but project will have no effect upon them. → Provide concurrence(s) or objection(s) and continue to
the Worksheet Summary.
If consulting parties concur or fail to respond to user’s request for concurrence, project is in compliance with this section. No further
review is required. If consulting parties object, refer to (36 CFR 800.4(d)(1) and consult further to try to resolve objection(s).
No Adverse Effect
Document reason for finding:
Does the No Adverse Effect finding contain conditions?
Yes
Check all that apply:
Avoidance
Modification of project
Other
Describe conditions here:
→ Monitor satisfactory implementation of conditions. Provide concurrence(s) or objection(s) and continue to the Worksheet
Summary
No → Provide concurrence(s) or objection(s) and continue to the Worksheet Summary.
If consulting parties concur or fail to respond to user’s request for concurrence, project is in compliance with this section. No further
review is required. If consulting parties object, refer to (36 CFR 800.5(c)(2)) and consult further to try to resolve objection(s).
Adverse Effect
Document reason for finding:
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Copy and paste applicable Criteria into text box with summary and justification.
Criteria of Adverse Effect: 36 CFR 800.5
Notify the Advisory Council on Historic Preservation of the Adverse Effect and provide the documentation outlined in 36 CFR 800.11(e).
The Council has 15 days to decide whether to enter the consultation (Not required for projects covered by a Programmatic Agreement).
→ Continue to Step 4
Step 4—Resolve Adverse Effects
Work with consulting parties to try to avoid, minimize or mitigate adverse effects. Refer to HUD guidance and 36 CFR 800.6 and 800.7.
Were the Adverse Effects resolved?
Yes
Describe the resolution of Adverse Effects, including consultation efforts and participation by the Advisory Council on Historic
Preservation:
For the project to be brought into compliance with this section, all adverse impacts must be mitigated. Explain in detail the
exact measures that must be implemented to mitigate for the impact or effect, including the timeline for implementation.
→ Provide signed Memorandum of Agreement (MOA) or Standard Mitigation Measures Agreement (SMMA). Continue to the Worksheet
Summary.
No
The project must be cancelled unless the “Head of Agency” approves it. Either provide approval from the “Head of Agency” or cancel the
project at this location.
Describe the failure to resolve Adverse Effects, including consultation efforts and participation by the Advisory Council on
Historic Preservation and “Head of the Agency”:
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Explain in detail the exact conditions or measures that must be implemented to mitigate for the impact or effect, including the
timeline for implementation.
→ Provide signed Memorandum of Agreement (MOA) or Standard Mitigation Measures Agreement (SMMA). Continue to the Worksheet
Summary
Worksheet Summary
Compliance Determination
Provide a clear description of your determination and a synopsis of the information that it was based on, such as:
•Map panel numbers and dates
•Names of all consulted parties and relevant consultation dates
•Names of plans or reports and relevant page numbers
•Any additional requirements specific to your region
Compliance documentation can be found attached to this Tier II Checklist. Page(s) _____________
Are formal compliance steps or mitigation required?
Yes
No
Noise Abatement and Control
Noise Control Act of 1972, as amended by the Quiet Communities Act of 1978; 24 CFR Part 51 Subpart B
Not applicable. Compliance determined in Tier 1. This project does not involve New construction for residential use, rehabilitation of an existing residential property, or research demonstration project and therefore in compliance with the Noise Control Act of 1972.
Sole Source Aquifers
Safe Drinking Water Act of 1974, as amended, particularly section 1424(e); 40 CFR Part 149
Not applicable. Compliance determined in Tier 1. This project does not consist solely of acquisition, leasing, or rehabilitation of an existing building and it is not within a sole source aquifer. It is therefore compliant with the Safe Drinking Water Act of 1974 (42 U.S.C. 201, 300f et seq., and 21 U.S.C. 349).
Wetland Protection
Executive Order 11990, particularly sections 2 and 5
1. Does this project involve new construction as defined in Executive Order 11990, expansion of a building’s footprint, or ground
disturbance?
The term “new construction” shall include draining, dredging, channelizing, filling, diking, impounding, and related activities and any
structures or facilities begun or authorized after the effect date of the Order.
No → Based on the response, the review is in compliance with this section. Continue to the Worksheet Summary below.
Yes → Continue to Question 2
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2. Will the new construction or other ground disturbance impact an on– or off-site wetland?
The term “wetlands” means those areas that are inundated by surface or ground water with a frequency sufficient to support, and under
normal circumstances does or would support, a prevalence of vegetative or aquatic life that requires saturated or seasonally saturated
soil conditions for growth and reproduction. Wetlands generally include swamps, marshes, bogs, and similar areas such as sloughs,
potholes, wet meadows, river overflows, mud flats, and natural ponds. Wetlands under E.O. 11990 include isolated and non-jurisdictional
wetlands.
No, a wetland will not be impacted in terms of E.O. 11990’s definition of new construction.
→ Based on the response, the review is in compliance with this section. Continue to the Worksheet Summary below. Provide a map
or any other relevant documentation to explain your determination.
Yes, there is a wetland that will be impacted in terms of E.O. 11990’s definition of new construction.
→ You must determine that there are no practicable alternatives to wetland development by completing the 8-Step Process.
Provide a completed 8-Step Process as well as all documents used to make your determination, including a map. Be sure to
include the early public notice and the final notice with your documentation.
Continue to Question 3.
3. For the project to be brought into compliance with this section, all adverse impacts must be mitigated. Explain in detail the exact
measures that must be implemented to mitigate for the impact or effect, including the timeline for implementation.
Which of the following mitigation actions have been or will be taken? Select all that apply:
Permeable surfaces
Natural landscape enhancements that maintain or restore natural hydrology through infiltration
Native plant species
Bioswales
Evapotranspiration
Stormwater capture and reuse
Green or vegetative roofs with drainage provisions
Natural Resources Conversation Service conservation easements
Compensatory mitigation
Worksheet Summary
Compliance Determination
Provide a clear description of your determination and a synopsis of the information that it was based on, such as:
•Map panel numbers and dates
•Names of all consulted parties and relevant consultation dates
•Names of plans or reports and relevant page numbers
•Any additional requirements specific to your region
Compliance documentation can be found attached to this Tier II Checklist. Page(s) _____________
Are formal compliance steps or mitigation required?
Yes
No
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Wild and Scenic Rivers
Wild and Scenic Rivers Act of 1968, particularly section 7(b) and (c)
Not applicable. Compliance determined in Tier 1. This project is not within proximity of a NWSRS river as defined by the Wild and Scenic Rivers Act (16 U.S.C. 1271-1287), particularly section 7(b) and (c) (16 U.S.C. 1278(b) and (c)) and therefore in compliance.
Environmental Justice
Executive Order 12898
Not applicable. Compliance determined in Tier 1. No adverse environmental impacts were identified outright in any of the other compliance review portions of this project's total environmental review. Proposed measures to mitigate any possible adverse effect were included in other review portions, such as site selection and ensuring all HUD, EPA, and Mass DEP requirements are fulfilled during the project. Any impact that is disproportionately impactful towards low-income and/or minority communities will be mitigated through public engagement and other appropriate measures. When completed, the project will impact low-income and/or minority communities in a positive manner.
The proposed project complies with environmental requirements for funding.
The proposed project does not comply with environmental requirements for funding.
Review Completed by:
Name: _________________________________________________________ Date: ___________________________________________
______________________________________________________________ Signature:
Certifying Officer:
Name: ________________________________________________ Date: __________________________________________________________
__________________________________________________________________ Signature:
Finding of this Tier II Site Specific Review
May 3, 2021
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Keith Benoit
Mayor David J. Narkewicz
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Document Path: J:\mxd\sidewalk_curb_cuts_20210430.mxdCoordinate System: NAD 1983 StatePlane Massachusetts Mainland FIPS 2001Projection: Lambert Conformal ConicDatum: North American 1983False Easting: 200,000.0000False Northing: 750,000.0000Central Meridian: -71.5000Standard Parallel 1: 41.7167Standard Parallel 2: 42.6833Latitude Of Origin: 41.0000Units: Meter
Date: 5/5/2021NORTHAMPTON
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