Cons Comm Maple Ave Ridley9/27/2019
Please accept this summary of comments we made at the 9/26/2019 Conservation Commission
hearing regarding proposed wetlands construction at 25 Maple Ave.
1) The Notice of Intent (NOI) ecological report suggests that the status of stream that
borders the property is unclear, and that the flow may be intermittent or dry at times.
a. The town classifies this stream as perennial.
b. We can confirm this based on decades of observation. The stream is also home
to a large frog population, turtles, and the surrounding area is full of wildlife.
2) The NOI portrays the proposed building site as "degraded due to the lack of topsoil and
the presence of dumped construction debris "
a. Construction debris and piles of soil on the property are the result of activity by
the applicant (from the creation of a gravel parking lot).
b. Areas of bare or open earth in the area of the Sycamore tree are the result of
test pits dug by the applicant.
c. The property is almost fully forested, with lush undergrowth. The soil that is
there now seems to be fully able to support plant life. Removal of trees and
construction may in fact destabilize the soil.
3) The applicant's stormwater report (pg. 8) states that "The site does not contain land
with higher pollutant loads…" than the surrounding area.
a. The entire site sits above a plume of contamination from the old gas
manufacturing plant that existed in the Round House area.
b. While the contamination is supposed to exist at deeper levels than proposed
excavations, this has not been thoroughly tested, and we have concerns about
the possible health effects of digging in the area and who is responsible/liable if
contaminants are unearthed.
c. We have concerns about how unearthed contaminants could affect the wetland
area.
d. We are surprised that the contamination is not mentioned in the applicant's
filings.
e. We periodically smell tar odors coming from the river bank area, and suspect
that some contamination may be shallower than is assumed.
4) The project is being inappropriately presented as a redevelopment project.
a. Based on our reading of the MA State Wetlands Act 310 CMR, section 4
(development) and section 5 (redevelopment), we understand that
"redevelopment" means that the applicant can be allowed to build within buffer
zones provided that they make improvements to the property. "Development" in
the same area would require that the applicant meet higher standards and that
the buffer zones would be more strictly enforced.
b. The "re-development" classification depends on the presence of "degraded"
land. The land is not "degraded"…it has been steadily improving since the area
was created after the 1936 floods and subsequent redirection of the Mill River
This improvement is thanks to the trees and plants that have filled the area. As
mentioned above, conditions used as justification for "degraded" and thus
"redevelopment" classification was in part created by the applicants themselves
(construction debris).
c. Proposed improvements (adding topsoil, plantings, removal of invasive
vegetation) are not needed except perhaps to repair damage from the
applicant's test pits and proposed construction.
The land is doing fine (is not degraded), most of it is within protected buffer zones, and it
benefits the public to have wooded and wild areas close to town.
Requests:
1. Please have an arborist survey the land to determine what exactly would be lost if the
proposed project is approved.
2. If the project is to be allowed, consider constraints that would reduce the size of the
building and parking lot, which could save the large trees and avoid some of the
buffered areas. In 2015 the applicant submitted a permit application for a smaller
building, and we hope that's still a possibility.
3. Visit the property before the trees drop their leaves, or at least view it in Google maps
(satellite view).
4. Please proceed with caution on what we are willing to sacrifice in the interest of infill.
5. Treat this as a development project rather than redevelopment, and require the
applicant to meet corresponding standards.
Thanks,
Margaret Tomasko
Mandaryn Gerry
Graham Ridley
36 Wilson Ave
Jean LaPlante
30 Wilson Ave