Phone: -------------------- Applicant's Representative: Michael - - PDF document

BSC GROUP

33 Waldo Street

Worcester, MA 01608

October 4,2012 Wellesley Wetlands Protection Committee Attn: Diane Torres, Asst. NRC Director 525 Washington Street Wellesley, Massachusetts 02482 Re: Wellesley Country Club New Maintenance Facilities Project; DEP File No. 324-647 Wellesley, Massachusetts Response to Questions Raised at the September 12th Hearing Dear Members of the Committee: On behalf of the Wellesley Country Club, this letter addresses the questions raised by the Wetlands Protection Committee (WPC) at the September 13th hearing as well as questions raised in Mr. Patrick Gamer's (reviewer for an abutters group) letter of September 14th• The Wetlands Protection Committee asked the Applicant to address four items:

1.

Provide construction details on the drywell drain at the end ofthe proposed swale. An additional detail for the proposed drywell drain has been provided on Sheet C5.2 (detail 9) which is submitted to the WPC with this letter. 2. Can the end of the proposed infiltration swale and the drywell be moved out of the Inner Riparian Zone? At the WPC's request, we have shortened the infiltration swale so that the entire swale and its terminus (the drywell drain) is outside the Inner Riparian Zone. This system is sized to infiltrate 100% of the runoff from the 100-year event. Terminating the swale slightly upslope from where it was originally shown means that there is a small part of the watershed closest to the proposed GrassPave™ system that will not flow towards the swale. This area will be captured in the GrassPave™ system described below. To anticipate the abutters' question, this letter also addresses the siting of the drywell within the Outer Riparian Zone. 310 CMR 10.58(4)(d)1 states: "The calculation of square footage of alteration shall exclude areas of replication or compensatory flood storage required to meet performance standards for other resource areas, or any area of restoration within the riverfront area. The calculation also shall exclude areas used for structural stormwater management measures, provided there is no practicable alternative to siting these structures within the

Tel: 508-792-4500 800-288-8123 Fax: 508-792-4509 www.bscgroup.com Engineers EnVironmental Scientists

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3. Does any portion of the proposed project require a waiver from the Bylaw's performance standards for vernal pools or buffer zones?

D Yes

~ No I(ves, complete and submit a Requestfor Wellesley Wetland Regulations Waiver Form with this Notice ofIntent. 4. Does the proposed project require a Drainage Review under Wellesley's Bylaws, Sec. XVIC?

(Note: All projects, not otherwise subject to Section XVIA (Site Plan Approval), involving grading or re- grading ofland to planned elevations and/or removal or disturbance of the existing vegetative cover, over an area of one acre or more require a Drainage Review under Section XVIC.)

D Yes

~ No I(yes, submit a grading and drainage plan with this Notice ofIntent 5. Total Wellesley Wetland Bylaw Fee (from fee transmittal form): $---.previously submitted_

Wellesley Bylaw Fee Check Number Wellesley Country Club Payor name on check: First Name Check date Payor name on check: Last Name

Submittal Requirements: Seven copies of this form (and WPA Form 3 if applicable), including all supporting plans and documents and pages 1 and 2 of the Notice ofIntent Wetland Fee Transmittal Form (if applicable) shall be submitted to the Wellesley Wetlands Protection Committee by certified mail or hand delivery. All applications shall be accompanied by the bylaw filing fee (from 5 above) made payable to the Town of Wellesley, one copy of the list of abutters and one copy of the abutter notification form. For Applications filed under the Massachusetts Wetlands Protection Act, a separate check made payable to the Town of Wellesley for the Town portion of the State filing fee (noted on WPA Form 3 Wetland Fee Transmittal form) shall be submitted at the time of filing.

Town of Wellesley Wetland Protection Bylaw (Section 44)

Notice of Intent

Applicant Name & Address: Property Owner Name & Address: Applicant's Representative:

Martin Ryan Wellesley Country Club

294 Wellesley Avenue

Wellesley.

MA 02481

Phone: (781) 235 - 7533 x2 02 Phone:--------------------

Michael Toohill,

PWS CE

Coneco Engineers and Scientists,

Inc.

99 Market Street

Lowell,

MA 01852

Phone: (978) 364-5101 x101 Mail Original Order of Conditions to:

[]

Applicant

• r

D Applicant's Representative

1. This applicatio@is not being filing simultaneously with a Notice of Intent under the Massachusetts Wetlands Protection Act (please circle one). 2. Additional Resource Areas subject to the Wellesley Wetland Protection Bylaw are listed below.

Please check all that apply. Attach a narrative and supporting documentation describing how project will meet all Bylaw performance standards for each resource area altered.

3. Does any portion of the proposed project require a waiver from the Bylaw's performance standards for vernal pools or buffer zones?

• Yes

~ No

I(ves, complete and submit a Requestfor Wellesley Wetland Regulations Waiver Form with this Notice ofIntent. 4. Does the proposed project require a Drainage Review under Wellesley's Bylaws, Sec. XVIC?

(Note: All projects, not otherwise subject to Section XVIA (Site Plan Approval), involving grading or re- grading ofland to planned elevations and/or removal or disturbance of the existing vegetative cover, over an area of one acre or more require a Drainage Review under Section XVIC.)

• Yes

~ No I(yes, submit a grading and drainage plan with this Notice ofIntent 5. Total Wellesley Wetland Bylaw Fee (from fee transmittal form):

$ 1,775.00,

27288

Wellesley Bylaw Fee Check Number

__Wellesley Country Club

Payor name on check: First Name

8/16/2010

Check date Payor name on check: Last Name

Submittal Requirements: Seven copies of this form (and WPA Form 3 if applicable), including all supporting plans and documents and pages 1 and 2 of the Notice ofIntent Wetland Fee Transmittal Form (ifapplicable) shall be submitted to the Wellesley Wetlands Protection Committee by certified mail or hand delivery. All applications shall be accompanied by the bylaw filing fee (from 5 above) made payable to the Town of Wellesley, one copy of the list of abutters and one copy of the abutter notification form. For Applications filed under the Massachusetts Wetlands Protection Act, a separate check made payable to the Town of Wellesley for the Town portion of the State filing fee (noted on WPA Form 3 Wetland Fee Transmittal form) shall be submitted at the time of filing.

Responses to the Wellesley WPC: WCC Maintenance Facility Project October 4, 2012 Page 2

riverfront area and provided a wildlife corridor is maintained (e.g. detention basins shall not be fenced)." Since the pitch of the land in this area is towards the location

• f the proposed swale and the only structural measure (the drywell) needs to be

situated at the end of the swale, there is no practicable alternative to siting the swale in the outer riparian zone. This area is already disturbed and is included in the proposed restoration zone. The proposed system will represent an improvement to Riverfront Area and is protective of the interests specified in the Wetlands Protection Act. 3. Please provide additional information regarding the uses of the access from Brookside Road. At the September 13th hearing, the Applicant stated that this access point may be used up to once a week during the golf season and that access was not limited to maintaining the proposed comfort station. The golf course superintendent was consulted about this and he feels that the use will more likely be once a month. This access point, which has been in existence since the 1960's, serves several valuable functions to operations at the Club.

• First, this is one of the designated access points (Emergency Access Gate

#1) for fire, police, and EMTs to enter onto the course in an emergency. This location was chosen for the proposed comfort station/lightning shelter because it is the furthest point away from the Clubhouse. For that reason there is an existing emergency phone to the Clubhouse which will be integrated into the lightning shelter.

• Second, following construction of the proposed comfort station, there may

be a periodic need to maintain the water and wastewater systems. Routine stocking of disposables can be done by accessing the facility from the course, but plumbing and mechanical repairs will require access from Brookside Road. Access to this facility will be less frequent than the access currently required for the port-a-potties the comfort station will replace.

• Third, this access point has long been valuable to course operations.

Accessing the golf holes in the northeast comer of the property requires crossmg Academy Brook which traverses the course. Routine maintenance (mowing, turfcare) equipment crosses on the 13th fairway under which Academy Brook flows through a culvert or (in the case of smaller equipment) across

• ne of the cart path bridges. On occasion a large piece of equipment needs

to access the golf holes west of Emergency Access Gate #1 for non-routine maintenance work. This is an infrequent occurrence, made even more infrequent by the fact that this area is being restored and not used for

• perations. But access from the road is still necessary to the Club, and this

access point is one that has been in continuous use since these golf holes were built in the 1960's. 4. Can the gravel path be partially removed? Is there an alternative to gravel that will serve the same purpose? The revised plans being submitted with this letter (Sheets C2.2 and C4.3) show an elimination of the existing gravel path and installation of a "grass paver" system in

Responses to the Wellesley WPC: WCC Maintenance Facility Project October 4,2012 Page 3

its place. The proposed grass paver system path will be shorter than the existing gravel path and will provide a stabilized access point for vehicular access and emergency vehicle parking. The proposed grass paver system also provides for stormwater infiltration. The proposed GrassPave™ system will be approximately 16 feet wide and 35 feet

• long. The existing gravel entrance is 16 feet wide, so there is no proposed increase

in access drive width and the length is shortened to 35 feet. Between the GrassPave™ system and Brookside Road a bituminous concrete reinforced entrance apnm (16 feet wide by 4 feet in length) is proposed to provide a necessary transition between the road surface and the GrassPave™ system and to maintain gutter flow along Brookside Road. Details ofthe proposed GrassPave™ system are shown on Sheet C5.2 (detail 8). In addition, the Club was asked by the Assistant NRC Director to provide a revised Town of Wellesley Wetland Protection Bylaw Notice of Intent Form. A revised form was filled out and submitted by email to the Assistant NRC Director

• n October 2nd. A copy of the form is attached. A copy of the original form is also

attached so that changes to proposed impacts from the original proposal to the current proposal can be viewed.

• Mr. Gamer's letter of September 14

th raises some questions which have been addressed

above or in previous letters to the WPC by the Applicant. I. The Alternatives Analysis (AA) has to be updated to reflect the revised proposal. The Alternatives Analysis process which started in 2010 has been continuously updated to reflect new alternatives and changes to the project. The latest changes and Alternatives to the newest proposal were included in our August 30

th and

September 12

th submittals to the WPC.

The result of the Riverfront Area Alternatives Analysis process that the Club has undertaken is that the potential impacts to Riverfront Area have been greatly reduced by choosing less impactful

• alternatives. This is, in fact, the point of the Riverfront Area Alternatives Analysis

process.

• Mr. Gamer insists that 5 additional questions regarding RA Alternatives Analysis

should be answered:

• Can access to service the comfort station be provided without driving from

Brookside Road through the RA? This question was answered above (WPC Question 3), and the Club will minimize the use of this access to service the comfort station as noted above, but it is important to point out that this access point has been in use by the Club since the 1960's and is a grandfathered use of RA per 310 CMR 10.58(6). Therefore the requirements of 310 CMR 10.58(4), including alternatives analysis, do not apply to the use or maintenance of this access.

• Responses to the Wellesley WPC: WCC Maintenance Facility Project

October 4, 2012 Page 4

Can utilities, particularly the proposed sewer force line, be run through the town community gardens parcel thus not impacting Brookside? The proposed utility (sewer, water, electric) routes were chosen based upon available infrastructure near the proposed comfort station site. The force main is proposed to be routed through an area proposed for restoration and

• utside the RA to the extent practicable. The force main is being routed in

the shoulder and paved way of Brookside Road to the closest existing municipal sewer system manhole. This routing does not require easements. Routing the utilities through the community gardens would require an easement from the Town, impair the gardens, and be impractical. It is not a "practicable and substantially equivalent economic alternative" to the proposed routing, under 310 CMR 10.58(4)(c).

• Can the comfort station itself be sited in an alternate location?

The comfort station is proposed in a location outside of RA and all buffer zones; therefore, this location is not subject to RA Alternatives Analysis. Nonetheless, the Club notes that no other location meets the criteria in the RA regulations. As noted in the requirements for Alternatives Analysis at 310 CMR 10.58(4)(c)(1): "An alternative is practicable and substantially equivalent economically if it is available and capable of being done after taking into consideration costs, existing technology, proposed use, and logistics, in light of overall project purposes." The comfort station/lightning shelter is proposed to be constructed along the pathway between the 13th green and 14th tees, a point which is furthest away from the clubhouse, near public utilities, and near an emergency access point. The proposed location is the ideal spot for this facility, considering its purpose.

• What are the additional access uses?

The uses for this legally grandfathered access point are detailed ill the response to WPC Question 3, above.

• Can all infrastructure within the RA be absolutely minimized within the

100-foot Inner Riparian Zone? This has been accomplished as detailed above and in our previous submittals to the WPC. 2.

• Mr. Gamer also made some design change suggestions as noted below:
• Change the design of the drainage swale to remove it from the Inner

Riparian Zone. This has been accomplished, but we wish to note that the original proposal was in a completely disturbed area and there was never a proposal to cut trees to build the system.

• Responses to the Wellesley WPC: WCC Maintenance Facility Project

October 4,2012 Page 5

Change the design of the access due to the Riverfront Area mandate. As noted above it is the Club's position that this access point is a lawfully grandfathered use within Riverfront Area and not subject to alternatives analysis. However, the Club has agreed to modify the proposal for maintaining the access as detailed above and on the revised plan sheets.

• Change the proposed mix in the swale from Wet Mix to a more upland seed

mIX.

The purpose of using seed mixes is to provide immediate stabilization and a range of seed stock. Restoration designers generally do not expect all of the species in the mix to take hold, but look for mixes that do well under a variety of conditions. If the WPC wishes the Applicant has no problem changing the proposed seed mix to be used in the infiltration swale provided the mix is robust and contains a variety of species. We would still propose to use a mix that contains both wetland and upland species.

• Do not use the wildflower mix; it will not grow as intended.

We too have extensive experience designing and monitoring wetland and upland systems and we feel that this mix is appropriate for this application. We chose this mix because it augments, not replaces, the existing herbaceous species mix. Again, the primary purpose is to promote vegetational cover and as ecologists we realize that speciation will change

• ver time.

We appreciate the opportunity to respond to the questions posed by you at the last Hearing. We feel that all relevant questions have been adequately peer reviewed, vetted by the public, and discussed before the Committee. We respectfully request that the Committee rule on the application at its October 4th meeting as delay would serve no public or wetland protection

• purposes. We look forward to discussing this project with you on October 4

th .

If you have any questions please feel free to contact me. Sincerely, Michael J. Toohill, PWS, CE Senior Environmental Scientist Cc: Marty Ryan, Bill Sansone, Michael Grimes, and Paul DeYesso; Wellesley Country Club Arthur Kreiger, Rebekah Lacey; Anderson & Kreiger LLP Les Shea; Wilder & Shea DEPNERO

Attach:

Responses to the Wellesley WPC: WCC Maintenance Facility Project October 4, 2012 Page 6

Revised Plan Sheets C2.2, C4.3, C5.2 Revised Town of Wellesley Wetland Protection Bylaw Notice of Intent Fonn Original Town of Wellesley Wetland Protection Bylaw Notice of Intent Fonn

Town of Wellesley Wetland Protection Bylaw (Section 44)

Notice of Intent

Applicant Name & Address: _Wellesley Country Club _ _ Attn Martin Ryan, General Manager _ _ 300 Wellesley Avenue _ _ Wellesley, MA 02481 _ Phone: _(781) 235-7333 x202 _ Property Owner Name & Address: _same as Applicant. _ Phone: -------------------- Applicant's Representative: Michael J. Toohill _ _ BSC Group, Inc _ 33 Waldo Street----------- _Worcester, MA 01608 _ Phone: 617-896-4519 _ Mail Original Order of Conditions to: cg] Applicant

• r

D Applicant's Representative

1.

This application is being filing simultaneously with a Notice of Intent under the Massachusetts Wetlands Protection Act. 2. Additional Resource Areas subject to the Wellesley Wetland Protection Bylaw are listed below. Please check all that apply. Attach a narrative and supporting documentation describing how project will meet all Bylaw performance standards for each resource area altered.