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File No 246-0767 Response to Comments.pdf An Equal Opportunity Employer M/F/V/H February 15, 2023 GZA File No. 15.0167000.00 Northampton Conservation Commission 210 Main Street Northampton, MA 01060 Re: DEP File WE 246-0767, Response to MassDEP Comments Notice of Intent – Rocky Hill Road Northampton, MA 01060 Dear Conservation Commission Members: On behalf of the City of Northampton (“City”, “Applicant”), GZA GeoEnvironmental, Inc. (GZA) offers the following responses to the Massachusetts Department of Environmental Protection (MassDEP) Western Regional Office comments dated February 2, 2023, regarding the proposed Rocky Hill Road Project. Our response format below includes MassDEP’s comment first, followed by bold type that indicates GZA’s response on behalf of the City. MassDEP Comments and GZA Responses [1] Unless otherwise overcome by the applicant and approved by the commission, the presumptions of the interests of the Act are based on the regulatory presumptions found in the preamble to each resource area, not the incomplete list noted in the narrative. GZA recognizes that the preamble to each resource area states the regulatory presumption as to the interests of the Act provided by each resource area. The discussion of specific items regarding the interests provided by each resource area within the Project limits included in the narrative was intended to draw particular attention to those interests given the existing conditions present at the site. At this time, GZA does not seek to overcome the presumptions stated in the regula- tions. [2] The parties should note the provisions of 310 CMR 10.53(7). “The Notice of Intent for any projects involving the construction, repair, replacement or expansion of public or private infrastructure shall include an operation and maintenance plan to ensure that the infrastructure will continue to func- tion as designed. Implementation of the operation and maintenance plan as approved by the Issuing Authority shall be a continuing condition that shall be set forth in the Order of Conditions and the Certificate of Compliance.” A Stormwater Management System Operation and Maintenance Plan for Ice Pond was approved by the Office of Planning and Development for the City of Northampton and was recorded in 2019 at the Hampshire County Registry of Deeds (Book 13287 Page 105). It has been and will continue to be the responsibility of the Ice Pond Association to maintain the system. February 15, 2023 GZA No. 15.0167000.00 Response to DEP Comments Page | 2 Proactive by Design [3] Guidance on dewatering is attached to this file number notification email, if that operation is required to be conducted. GZA reviewed the referenced information on construction dewatering. The Project is not subject to time-of-year re- strictions, nor is it mapped as a “cold-water fishery” as defined at 310 CRM 10.04 and 314 CMR 9.02. If aquatic organisms are observed within the work area following installation of the water control features, they will be relo- cated upstream of the proposed cofferdam. The plans submitted with the Notice of Intent application show the location of the proposed temporary cofferdam to isolate the area of alteration from flowing water. During re-construction of the low-level outlet, incoming stream flows will be routed through the proposed bypass pump and directed into the existing high-flow outlet which dis- charges into the culvert that flows underneath Rocky Hill Road. Given the existing infrastructure, Rocky Hill Pond Brook will not backwater into the work area. Separate/temporary energy dissipation or erosion and sediment control measures are not required at the bypass discharge location as the bypass flows will be discharged into the existing concrete structure and be routed through the existing downstream conveyance. As needed, the construction area protected by the cofferdam will be dewatered by pumping from a filtered low-level sump. Discharge from the sump will be pumped to a Dirtbag® sediment filtration geotextile bag or equivalent prior to discharge back into the resource area. As shown on the plans, a sedimentation barrier is proposed immediately up- stream of the low-level sump to separate stormwater from the existing berm from surface water entering the work site from the adjacent bordering vegetated wetland and stream. Areas of disturbed substrate in the work area will be stabilized prior to the re-establishment of flow to the new low-level outlet. Thank you for this opportunity to clarify the proposed Project. We trust that our responses adequately address the com- ments submitted by MassDEP. We look forward to working with the Commission towards the issuance of an Order of Conditions. Sincerely, GZA GeoEnvironmental, Inc. Rosalie Starvish, MS, P.E., CFM, CPMSM Daniel M. Nitzsche, CPESC, CESSWI, SE Senior Project Manager Consultant / Reviewer Nathaniel Russel, P.E. Principal-in-Charge Cc: David Veleta – City of Northampton MassDEP-WERO