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MS-18-07 - Supplemental - 0000 Kennedy Drive
Dear Marla, Please find our responses below to the comments provided on the Kennedy Drive Pond 3 Retrofit and Expansion Project: 12.02E Standards for Wetland Protection (2) Encroachment into Class II wetlands is permitted by the City only in conjunction with issuance of a Conditional Use Determination (CUD) by the Vermont Department of Environmental Conservation and positive findings by the DRB pursuant to the criteria in (3) below. The applicant has submitted a letter from the State of Vermont Wetlands Program indicating that no wetland permit is needed for the proposed work. Therefore Staff considers that the Board cannot make use of on the findings of the Wetlands Program for evaluating compliance with the standards for wetland protection. Response: On October 17, 2017, Tina Heath, from the VTDEC Wetlands Program, conducted a site visit of Kennedy Drive Pond 3. In her October 23rd follow-up correspondence (see Attachment 1 – Heath Oct 23) she indicated, “The existing pond sits on a terrace above the large mapped wetland complex. Upgrade proposals are to expand the existing pond and create a new swale to redirect eh culvert outflow to the pond. The wetland should be delineated to determine how much of the proposal is within the 50-foot buffer zone. There are no significant concerns with this proposal at this time.” On June 8, 2018, April Moulaert, of PWS of North Woods Ecological Consulting, delineated the wetland and provided a Wetland Determination Data Form describing the Hydrology, Vegetation and Soil characteristics of the wetland, (see Attachment 2 – Moulaert Jun 8). Based on the wetland delineation, it was determined that new impact to the wetland buffer totaled 221 square feet (see Attachment 3 – Wetland Buffer Impact Plans). The City was not required to obtain a State Wetland permit, as modifications to the existing footprint of the stormwater treatment practice are considered an allowed use under §6.12 of the Vermont Wetland Rules and the new wetland buffer impact outside of the existing footprint is below the 250 square foot threshold that qualifies as an allowed use under §6.12 of the Vermont Wetland Rules. §6.12 of the Vermont Wetland Rules reads: The maintenance, reconstruction, or routine repair of structures and facilities (including ski trails, public transportation facilities, bulkheads, docks, piers, pilings, paved areas, houses, or other buildings) in compliance with the Vermont Wetland Rules in existence as of the date of their construction or in existence as of February 23, 1990 or additions to such structures or facilities which do not involve substantial expansion or modification in a wetland or buffer. The State currently has a draft Wetland General Permit that is being finalized that addresses this very issue. In order to reduce the regulatory burden on important water quality projects in the Lake Champlain watershed, the State has increased the allowed wetland and buffer impacts for stormwater treatment retrofit projects to 500 square feet of natural wetland or buffer impact and 5,000 square feet of managed buffer impact. See draft permit language below (as well as Attachment 4 – Draft Wetland General Permit 3-9026): Draft Wetlands General Permit 3-9026 Water Quality Improvement Projects in Significant Wetlands and Buffers b. Retrofit of Stormwater Treatment Practices. The Secretary has determined that the installation of certain Stormwater Treatment Practices (STPs) to address existing impervious surface is a critical step in implementing Total Maximum Daily Loads (TMDLs) in stormwater impaired watersheds, Lake Champlain, and Lake Memphremagog. Additionally, existing sites with three or more acres of impervious surface will require installation of STPs in order to meet the requirements of the forthcoming stormwater developed lands general permit, which is critical for meeting the Lake Champlain TMDL. The retrofit of stormwater infrastructure with STPs can result in improved water quality in these watersheds. Unless otherwise specified in this general permit, projects retrofitting existing impervious surfaces with stormwater STPs according to the terms of a validly-issued operational stormwater permit, authorization under the MS4 General Permit, TS4 General Permit, or Municipal Roads General Permit, may be eligible for coverage under this general permit, and may proceed with construction following registration of the project. To be eligible for coverage, projects must comply with the following conditions: i. Installation of STPs, including installation of multiple STPs that are part of a single retrofit project, must impact no more than 500 square feet of natural wetland or buffer, no more than 2,000 square feet of managed wetland, and no more than 5,000 square feet of managed buffer, resulting in no more than 5,000 total square feet of impact to any wetland or buffer. ii. Permittees must register the location and type of STPs to be constructed prior to commencing construction. Additionally, the project was required to obtain an Act 250 Permit Amendment (see Attachment 5 - 4C1122-1 notice and cos). Act 250 permitting includes review by State Wetlands staff under Criterion 1G - Wetlands, as well as River Corridor & Floodplain Protection Program staff under Criterion 1D - Floodways. The River Corridor & Floodplain Protection Program staff indicated in an email correspondence dated May 4, 2018, “On our 4/18 site visit, we met to see if the project would result in any filling or other impacts to the FEMA-mapped SFHA. Pond 3 is shown to be a bit further from the edge of the floodplain on the maps, and when we went on site, it was clearly located above the surrounding lower area that is mapped as floodplain. Therefore, Pond 3 is non-jurisdictional based on the work that is being proposed at this time.” (see Attachment 6 – Pfeiffer May 4). (3) Encroachment into Class II wetland buffers, Class III wetlands and Class III wetland buffers, may be permitted by the DRB upon finding that the proposed project’s overall development, erosion control, stormwater treatment system, provisions for stream buffering, and landscaping plan achieve the following standards for wetland protection: (a) The encroachment(s) will not adversely affect the ability of the property to carry or store flood waters adequately; The Project expands the size of the existing stormwater treatment practice and as a result, reduces the total size of the wetland by placement of embankment fill. Staff understands that conversion from a detention basin to a gravel wetland can sometimes result in a reduction of the ability of the stormwater practice to detain water. 2. The applicant has not submitted documentation demonstrating that the stormwater treatment practice will decrease peak flow rates to the wetland to compensate for the reduced wetland size, therefore Staff considers at this time it is not feasible to determine whether this criterion is met. Staff recommends the Board discuss this issue with the applicant. Response: While converting a detention basin into a gravel wetland can result in a reduction of the ability of the stormwater practice to detain water, this retrofit project also includes an expansion of the stormwater practice in order to increase the ability to detain water. The current treatment practice manages a Channel Protection Volume (CPv) of 0.223 acre-feet (9,714 cubic feet) for the associated impervious area currently draining to it (3.36 acres). It provides no treatment to the 2.76 acres of impervious surface that currently bypasses the detention pond and discharges directly to the wetland. The Existing Conditions Peak Discharge Flow Rate to the wetland is 3.13 cubic feet per second (cfs) during the 1-year, 24-hour storm. The expanded treatment system will manage a Channel Protection Volume (CPv) of 0.532 acre-feet (23,178 cubic feet) for the expanded drainage area (6.12 impervious acres total). The Proposed Conditions Peak Discharge Flow Rate is 1.58 cubic feet per second (cfs) during the 1-year, 24-hour storm. (see Attachment 7 – HydroCAD Report). In summary, the expansion project provides a 49.5% reduction in Peak Flow during the 1-year storm compared to existing conditions and provides 13,464 cubic feet of additional storage compared to existing conditions. Using the VTrans Pay Items in the Engineer’s Opinion of Probable Cost, dated 12/10/2018 (see Attachment 8 – Cost Estimate), the net difference between excavation (common, muck, trench) and fill (earth borrow, gravel(s), concrete, stone, topsoil, landscaping backfill, wetland soil, and pea stone, as well as the volume of the pipes) resulted in a net excavation of 19,340 cubic feet. Additionally, as noted previously, State River Corridor & Floodplain Protection Program staff noted in their review of the project that “Pond 3 is shown to be a bit further from the edge of the floodplain on the maps, and when we went on site, it was clearly located above the surrounding lower area that is mapped as floodplain.” (b) The encroachment(s) will not adversely affect the ability of the proposed stormwater treatment system to reduce sedimentation according to state standards; Staff understands that a gravel wetland is generally more protective of water quality than a detention basin. 3. The applicant has not submitted documentation of the performance of the proposed gravel wetland nor have they submitted documentation of State review and approval of the proposed reconfiguration, therefore Staff considers at this time it is not feasible to determine whether this criterion is met. Staff recommends the Board discuss this issue with the applicant. Response: As indicated by Stormwater Best Management Practice (BMP) Performance Analysis, Revised March 2010, Prepared for the EPA Region 1 by Tetra Tech, Inc. (see Attachment 9 – BMP Performance Curves), a gravel wetland is more protective of water quality than a detention basin. As noted in the table on page 154, a Gravel Wetland treating 1.0” of runoff from any land use provides a 61% Total Phosphorous (TP) pollutant reduction. By comparison, on page 175 of the PDF, a Wet Pond treating 1.0” of runoff from any land use provides a 17-18% Total Phosphorous (TP) pollutant reduction. Further, a gravel wetland is significantly more protective of water quality than an untreated stormwater discharge from 2.76 acres of impervious surfaces, as is the current condition at the project site. Based on a Simple Method for Pollutant Loadings calculation (see Attachment 10 – Simple Method) it is estimated that the project will provide a net benefit of reducing the phosphorous loading to the adjacent wetland and Lake Champlain by 8.4 pounds per year. The City has been working with the State on a technical review of the project. See the Attachment 11 correspondence dated 12/12/2018 from the State staff, Lynnette Claudon, PE, Chief Pollution Control Design Engineer; and Roger Bergeron, Chief Construction Engineer, indicating that their review comments have been addressed. (c) The impact of the encroachment(s) on the specific wetland functions and values identified in the field delineation and wetland report is minimized and/or offset by appropriate landscaping, stormwater treatment, stream buffering, and/or other mitigation measures. 4. The applicant has provided a landscaping plan demonstrating how the site will be restored at completion of work. They have not provided information demonstrating how this restoration will provide mitigation for the functions and values of the impacted wetlands. Staff recommends the Board discuss this issue with the applicant. Response: Pond 3 is located on Kennedy Drive adjacent to a Class II wetland. The greater wetland complex was delineated on June 8, 2018 by April Moulaert, PWS of North Woods Ecological Consulting (see Attachment 2). Ms. Moulaert determined that the wetland complex is composed of Phragmites australis (Common Reed) and Typha angustifolia (Narrowleaf Cattail) in the herb stratum. The surrounding buffer is composed of Quercus rubra (Red Oak), Acer saccharum (Sugar Maple), and Acer rubrum (Red Maple) in the tree stratum. The two maples are additionally found in the sapling stratum, as are Rhamnus cathartica (European Buckthorn), Fraxinus Americana (Common White Ash), and Tilia americana (Basswood). In the herb stratum, Maianthemum canadense (Canada-mayflower) and Rhamnus cathartica (European buckthorn) were located. A number of the species present in the Class II wetland and surrounding buffer are considered to be highly invasive. The non-native Phragmites australis or common reed, can rapidly form dense monocultures which crowd out or shade native vegetation. Over time, the stand becomes devoid of the diversity needed to support a thriving ecosystem. Similarly, the Narrowleaf cattail was introduced to New England and is capable of out-competing native marsh species to form monocultures. European buckthorn, introduced from Europe, was once a popular choice for hedgerows and boundaries in the late 1700’s. Scientists have since determined that the buckthorn fruits are easily spread by birds and other wildlife unable to fully digest the berries. Each fruit contains four seeds and can remain viable in the environment for five years. Common buckthorn forms thick hedges, crowding out native shrubs and herbaceous species, while providing little nutrition for wildlife. After meeting with Tina Heath—the Vermont Wetland Regulator representing Chittenden County, it was determined that due to the minimal wetland buffer impacts associated with the proposed project, it would not be necessary to obtain a Vermont Wetlands General Permit. Therefore, the requirement to provide mitigation of undue adverse impacts on the protected functions of the wetland through restoration or other efforts was not considered necessary. Although mitigation was not required by the state, the City of South Burlington—Stormwater Division recognized that creating a more diverse environment would benefit both the stormwater project and the greater wetland complex. In an effort to achieve this goal the proposed design, incorporates a number of native plantings to the slope of the gravel wetland. Included in this list are: Acer saccharinum (Silver maple), Acer rubrum (Red Maple), Swida Sericia (Red-osier dogwood), Pinus Strobus (White Pine), and Tsuga canadensis (Eastern Hemlock). The proposed species will help to create a diverse environment for native wildlife, providing habitat, food and shelter—all while providing stabilization efforts on the slopes of the project. In addition to the landscaped areas of the project, the contractor will be placing Marsh, Swamp and Bog Seed Mix supplied by Vermont Wetland Plant Supply, within the gravel wetland cells. The seed mix is composed of native species that are capable of thriving in landscapes inundated with water. Once established, the mix is intended to provide habitat for amphibians and birds. These efforts will greatly improve the conditions of the ecosystem surrounding the project. Regards, Dave Wheeler the presumption of significance and is presumed Class II. Thank you, Kirstin From: Heath, Tina [mailto:Tina.Heath@vermont.gov] Sent: Monday, October 23, 2017 12:07 PM To: Dipietro‐Worden, Kirstin A. <kworden@hoyletanner.com>; April Moulaert <april@northwoodsecological.com> Cc: Schramm, Mike <mschramm@hoyletanner.com>; Kerrie Garvey <kerrie@watershedca.com>; Dave Wheeler (dwheeler@sburl.com) <dwheeler@sburl.com>; Andres Torizzo <andres@watershedca.com> Subject: RE: Kennedy Drive Ponds Expansion Study Hi all, Thank you for meeting with me last week on October 17 to review the seven stormwater ponds along Kennedy Drive. And thanks for digging up the wetlands permit for the Kennedy Drive expansion. Unfortunately I can’t find any paper files here at my office and it’s tough to determine what’s what in the CUD/ site plans. Does the City have a copy of the original application? Five existing ponds are proposed for retrofit and expansion upgrades to satisfy the Potash Brook FRP and capture additional off‐site runoff. Below is a jurisdictional summary of each pond we visited. The ponds correspond to the site maps we had at the visit. Pond 1: The proposal is to significantly expand the pond towards the west. There are mapped wetlands nearby associated with Potash Brook, and a wetland swale/finger that extends from this complex towards the road where there’s a culvert. This swale would also be considered Class II because it’s contiguous to the larger complex. The expansion would likely impact wetland and buffer and would be difficult to approve with a permit. Alternative sites and designs will need to looked in to that could avoid wetland and buffer impact. Pond 2: The existing pond is located adjacent to mapped Class II wetlands, and it appears that a berm may separate the two. The proposal is to expand the pond in the opposite direction of the wetlands and retrofit a gravel wetland. Because of how close the pond is to the wetlands it is necessary to determine if this pond was originally constructed in upland or wetland. This will give us a sense of where the actual wetland boundary and 50 foot buffer zone is located for delineation purposes. Depending on the boundary, the expansion would either require a permit or be outside of wetland jurisdiction. And in general, if retrofit upgrades like a gravel wetland can be installed within the existing footprint of the pond infrastructure then these types of projects are considered an allowed use. Pond 3: The existing pond sits on a terrace above the large mapped wetland complex. Upgrade proposals are to expand the existing pond and create a new swale to redirect the culvert outflow to the pond. The wetlands should be delineated to determine how much of the proposal is within the 50‐foot buffer zone. There are no significant concerns with this proposal at this time. Pond 4: Upgrades proposed include the expansion of the pond to the southeast. There is an unnamed stream that flows around the perimeter of the existing pond. There is a wetland associated with the stream and is Class II based on presumptions. Expanding into this wetland and buffer would unlikely be permitted, and alternatives would need to be looked into. Pond 5 and Pond 6: no changes to pond 5, abandoning pond 6. Pond 7: This pond is proposed to be expanded, mapped Class II wetlands are nearby. Wetlands would need to be delineated, current proposal would likely impact buffer. The expansion should be reconfigured to minimize impacts as much as possible. Based on discussions at the site visit there’s possibility the expansion could be reconfigured to avoid the buffer zone. Let me know if you have additional questions or concerns. Best, Best, Tina Tina Heath, District Wetland Ecologist Chittenden County 802‐490‐6202 tina.heath@vermont.gov Vermont Department of Environmental Conservation 111 West St Essex Junction, Vermont 05452 www.watershedmanagement.vt.gov See what we’re up to on our Blog, Flow. From: Dipietro‐Worden, Kirstin A. [mailto:kworden@hoyletanner.com] Sent: Thursday, October 12, 2017 2:05 PM To: April Moulaert <april@northwoodsecological.com>; Heath, Tina <Tina.Heath@vermont.gov> Cc: Schramm, Mike <mschramm@hoyletanner.com>; Kerrie Garvey <kerrie@watershedca.com>; Dave Wheeler (dwheeler@sburl.com) <dwheeler@sburl.com>; Andres Torizzo <andres@watershedca.com> Subject: Kennedy Drive Ponds Expansion Study April and Tina, I preparation of next week’s site visits, I wanted to forward updated maps prepared by WCA showing the expansion concepts for each of the Kennedy Drive ponds. The attached maps represent the most recent updates to existing and proposed drainage areas, existing and proposed pond footprints, and proposed drainage connection concepts. Let us know if you have any questions. Also, I plan to attend next Tuesday’s (10/17) site visits to answer any engineering related questions about the proposed concepts. Please let me know where to meet you and if we are still planning on a 10:45 am start. Thanks, Kirstin Kirstin DiPietro Worden, PE Environmental Engineer Licensed in: VT 125 College Street, 4th Floor | Burlington, VT 05401 (802) 860-1331 kworden@hoyletanner.com www.hoyletanner.com This communication and any attachments to this are confidential and intended only for the recipient(s). Any other use, dissemination, copying, or disclosure of this communication is strictly prohibited. If you have received this communication in error, please notify us and destroy it immediately. Hoyle, Tanner & Associates, Inc. is not responsible for any undetectable alteration, virus, transmission error, conversion, media degradation, software error, or interference with this transmission or attachments to this transmission. Hoyle, Tanner & Associates, Inc. | info@hoyletanner.com Project/Site: Applicant/Owner:State: Investigator(s): Lat: Soil Map Unit Name:NWI classification: x Are Vegetation , Soil , or Hydrology Yes Are Vegetation , Soil , or Hydrology SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc. No X No X X No X Yes X WETLAND DETERMINATION DATA FORM – Northcentral and Northeast Region Kennedy Drive- Pound 3 City/County: South Burlington/ Chittenden Sampling Date: 6/8/18 Landform (hillside, terrace, etc.): Hillside Local relief (concave, convex, none): Linear Slope %: 5 VT Sampling Point: Up April Moualert, PWS Section, Township, Range: Hinesburg fine sandy loam Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.) Subregion (LRR or MLRA): LRR R 44° 27'15"N Long: 73° 10'14"W Datum: significantly disturbed? Are “Normal Circumstances” present? No naturally problematic? (If needed, explain any answers in Remarks.) Hydrophytic Vegetation Present? Yes Wetland Hydrology Present? Yes If yes, optional Wetland Site ID: Is the Sampled Area Hydric Soil Present? Yes within a Wetland? Yes No Remarks: (Explain alternative procedures here or in a separate report.) HYDROLOGY Wetland Hydrology Indicators:Secondary Indicators (minimum of two required) Primary Indicators (minimum of one is required; check all that apply) Surface Soil Cracks (B6) Surface Water (A1) Water Marks (B1) Hydrogen Sulfide Odor (C1) Crayfish Burrows (C8) Sediment Deposits (B2) Oxidized Rhizospheres on Living Roots (C3) Saturation Visible on Aerial Imagery (C9) Water-Stained Leaves (B9) Drainage Patterns (B10) High Water Table (A2) Aquatic Fauna (B13) Moss Trim Lines (B16) Saturation (A3) Marl Deposits (B15) Dry-Season Water Table (C2) Iron Deposits (B5) Thin Muck Surface (C7) Shallow Aquitard (D3) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Microtopographic Relief (D4) Drift Deposits (B3) Presence of Reduced Iron (C4) Stunted or Stressed Plants (D1) Algal Mat or Crust (B4) Recent Iron Reduction in Tilled Soils (C6) Geomorphic Position (D2) Water Table Present? Yes No Depth (inches): Sparsely Vegetated Concave Surface (B8)FAC-Neutral Test (D5) Field Observations: Surface Water Present? Yes No Depth (inches): Remarks: No (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Saturation Present? Yes No Depth (inches):Wetland Hydrology Present? US Army Corps of Engineers Northcentral and Northeast Region – Version 2.0 Sampling Point: (Plot size: 1. 2. 3. 4. 5. 6.(A/B) 7. Sapling/Shrub Stratum (Plot size:x 1 = 1.x 2 = 2.x 3 = 3.x 4 = 4.x 5 = 5.Column Totals:(B) 6. 7. Herb Stratum (Plot size: 1. 2.4 - Morphological Adaptations1 (Provide supporting 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. (Plot size: 1. 2. 3. 4.X VEGETATION – Use scientific names of plants.Up Tree Stratum 30 ) Absolute % Cover Dominant Species? Indicator Status Dominance Test worksheet: Quercus rubra 40 Yes FACU Number of Dominant Species That Are OBL, FACW, or FAC:Acer saccharum 30 Yes FACU 3 (A) Acer rubrum 10 No FAC Total Number of Dominant Species Across All Strata: 7 (B) Percent of Dominant Species That Are OBL, FACW, or FAC: 42.9% Acer saccharum 30 Yes FACU Prevalence Index worksheet: 10 Yes FAC FAC species 40 120 0 0 Total % Cover of: 0 Acer rubrum Fraxinus americana 5 No FACU UPL species 0 0 Rhamnus cathartica 10 Yes FAC FACU species 130 80 =Total Cover 640 Prevalence Index = B/A = 3.76 Tilia americana 5 No FACU 170 (A) 15 )OBL species Multiply by: FACW species 0 520 60 =Total Cover 1 - Rapid Test for Hydrophytic Vegetation 5 )2 - Dominance Test is >50% Hydrophytic Vegetation Indicators: Maianthemum canadense 20 Yes FACU 3 - Prevalence Index is ≤3.0 1 Rhamnus cathartica 10 Yes FAC Problematic Hydrophytic Vegetation1 (Explain) 1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. data in Remarks or on a separate sheet) Sapling/shrub – Woody plants less than 3 in. DBH and greater than or equal to 3.28 ft (1 m) tall. Definitions of Vegetation Strata: Tree – Woody plants 3 in. (7.6 cm) or more in diameter at breast height (DBH), regardless of height. Woody Vine Stratum )Woody vines – All woody vines greater than 3.28 ft in height. Herb – All herbaceous (non-woody) plants, regardless of size, and woody plants less than 3.28 ft tall.30 =Total Cover Hydrophytic Vegetation Present? Yes No Remarks: (Include photo numbers here or on a separate sheet.) =Total Cover US Army Corps of Engineers Northcentral and Northeast Region – Version 2.0 Sampling Point: X SOIL Up Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type 1 4-12 10YR 4/3 Loamy/Clayey Loc2 Texture Remarks Sandy100 Hydric Soil Indicators:Indicators for Problematic Hydric Soils3: Histosol (A1) Polyvalue Below Surface (S8) (LRR R,2 cm Muck (A10) (LRR K, L, MLRA 149B) Histic Epipedon (A2)MLRA 149B)Coast Prairie Redox (A16) (LRR K, L, R) Black Histic (A3) Thin Dark Surface (S9) (LRR R, MLRA 149B) 5 cm Mucky Peat or Peat (S3) (LRR K, L, R) Hydrogen Sulfide (A4) High Chroma Sands (S11) (LRR K, L)Polyvalue Below Surface (S8) (LRR K, L) 1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains.2Location: PL=Pore Lining, M=Matrix. Thick Dark Surface (A12) Depleted Matrix (F3) Piedmont Floodplain Soils (F19) (MLRA 149B) Sandy Mucky Mineral (S1) Redox Dark Surface (F6) Mesic Spodic (TA6) (MLRA 144A, 145, 149B) Stratified Layers (A5) Loamy Mucky Mineral (F1) (LRR K, L) Thin Dark Surface (S9) (LRR K, L) Depleted Below Dark Surface (A11) Loamy Gleyed Matrix (F2) Iron-Manganese Masses (F12) (LRR K, L, R) 0-4 10YR 2/2 100 Stripped Matrix (S6) Marl (F10) (LRR K, L) Other (Explain in Remarks) Dark Surface (S7) 3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic. Sandy Gleyed Matrix (S4) Depleted Dark Surface (F7) Red Parent Material (F21) Sandy Redox (S5) Redox Depressions (F8) Very Shallow Dark Surface (F22) Yes No Remarks: This data form is revised from Northcentral and Northeast Regional Supplement Version 2.0 to include the NRCS Field Indicators of Hydric Soils, Version 7.0, 2015 Errata. (http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_051293.docx) Restrictive Layer (if observed): Type: Depth (inches): Hydric Soil Present? US Army Corps of Engineers Northcentral and Northeast Region – Version 2.0 Project/Site: Applicant/Owner:State: Investigator(s): Lat: Soil Map Unit Name:NWI classification: x Are Vegetation , Soil , or Hydrology Yes x Are Vegetation , Soil , or Hydrology SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc. X No X No X X No x x x x x X x x x Yes X Remarks: No (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Saturation Present? Yes No Depth (inches): 0 Wetland Hydrology Present? Water Table Present? Yes No Depth (inches): 0 Sparsely Vegetated Concave Surface (B8)FAC-Neutral Test (D5) Field Observations: Surface Water Present? Yes No Depth (inches): Iron Deposits (B5) Thin Muck Surface (C7) Shallow Aquitard (D3) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Microtopographic Relief (D4) Drift Deposits (B3) Presence of Reduced Iron (C4) Stunted or Stressed Plants (D1) Algal Mat or Crust (B4) Recent Iron Reduction in Tilled Soils (C6) Geomorphic Position (D2) Remarks: (Explain alternative procedures here or in a separate report.) HYDROLOGY Wetland Hydrology Indicators:Secondary Indicators (minimum of two required) Primary Indicators (minimum of one is required; check all that apply) Surface Soil Cracks (B6) Surface Water (A1) Water Marks (B1) Hydrogen Sulfide Odor (C1) Crayfish Burrows (C8) Sediment Deposits (B2) Oxidized Rhizospheres on Living Roots (C3) Saturation Visible on Aerial Imagery (C9) Water-Stained Leaves (B9) Drainage Patterns (B10) High Water Table (A2) Aquatic Fauna (B13) Moss Trim Lines (B16) Saturation (A3) Marl Deposits (B15) Dry-Season Water Table (C2) Is the Sampled Area Hydric Soil Present? Yes within a Wetland? Yes No significantly disturbed? Are “Normal Circumstances” present? No naturally problematic? (If needed, explain any answers in Remarks.) Hydrophytic Vegetation Present? Yes Wetland Hydrology Present? Yes If yes, optional Wetland Site ID: Enosburg and Whately soils PEM Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.) Subregion (LRR or MLRA): LRR R 44° 27'15" N Long: 73° 10' 14"W Datum: WETLAND DETERMINATION DATA FORM – Northcentral and Northeast Region Kennedy Drive- Pond 3 City/County: South Burlington/ Chittenden Sampling Date: 6/8/18 Landform (hillside, terrace, etc.): Depression Local relief (concave, convex, none): None Slope %: 0 VT Sampling Point: Wet April Moulaert, PWS Section, Township, Range: US Army Corps of Engineers Northcentral and Northeast Region – Version 2.0 Sampling Point: (Plot size: 1. 2. 3. 4. 5. 6.(A/B) 7. Sapling/Shrub Stratum (Plot size:x 1 = 1.x 2 = 2.x 3 = 3.x 4 = 4.x 5 = 5.Column Totals:(B) 6. 7. Herb Stratum (Plot size:X 1.X 2.4 - Morphological Adaptations1 (Provide supporting 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. (Plot size: 1. 2. 3. 4.X Remarks: (Include photo numbers here or on a separate sheet.) =Total Cover Hydrophytic Vegetation Present? Yes No Herb – All herbaceous (non-woody) plants, regardless of size, and woody plants less than 3.28 ft tall.100 =Total Cover Sapling/shrub – Woody plants less than 3 in. DBH and greater than or equal to 3.28 ft (1 m) tall. Definitions of Vegetation Strata: Tree – Woody plants 3 in. (7.6 cm) or more in diameter at breast height (DBH), regardless of height. Woody Vine Stratum )Woody vines – All woody vines greater than 3.28 ft in height. OBL Problematic Hydrophytic Vegetation1 (Explain) 1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. data in Remarks or on a separate sheet) =Total Cover 1 - Rapid Test for Hydrophytic Vegetation 5 )2 - Dominance Test is >50% Hydrophytic Vegetation Indicators: Phragmites australis 90 Yes FACW 3 - Prevalence Index is ≤3.0 1 Typha angustifolia 10 No =Total Cover 190 Prevalence Index = B/A = 1.90 100 (A) )OBL species Multiply by: FACW species 90 0 UPL species 0 0 FACU species 0 Prevalence Index worksheet: FAC species 0 0 10 10 Total % Cover of: 180 1 (B) Percent of Dominant Species That Are OBL, FACW, or FAC: 100.0% 1 (A) Total Number of Dominant Species Across All Strata: VEGETATION – Use scientific names of plants.Wet Tree Stratum ) Absolute % Cover Dominant Species? Indicator Status Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: US Army Corps of Engineers Northcentral and Northeast Region – Version 2.0 Sampling Point: X x XYes No Remarks: This data form is revised from Northcentral and Northeast Regional Supplement Version 2.0 to include the NRCS Field Indicators of Hydric Soils, Version 7.0, 2015 Errata. (http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_051293.docx) Restrictive Layer (if observed): Type: Depth (inches): Hydric Soil Present? Stripped Matrix (S6) Marl (F10) (LRR K, L) Other (Explain in Remarks) Dark Surface (S7) 3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic. Sandy Gleyed Matrix (S4) Depleted Dark Surface (F7) Red Parent Material (F21) Sandy Redox (S5) Redox Depressions (F8) Very Shallow Dark Surface (F22) Polyvalue Below Surface (S8) (LRR K, L) 1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, MS=Masked Sand Grains.2Location: PL=Pore Lining, M=Matrix. Thick Dark Surface (A12) Depleted Matrix (F3) Piedmont Floodplain Soils (F19) (MLRA 149B) Sandy Mucky Mineral (S1) Redox Dark Surface (F6) Mesic Spodic (TA6) (MLRA 144A, 145, 149B) Stratified Layers (A5) Loamy Mucky Mineral (F1) (LRR K, L) Thin Dark Surface (S9) (LRR K, L) Depleted Below Dark Surface (A11) Loamy Gleyed Matrix (F2) Iron-Manganese Masses (F12) (LRR K, L, R) 0-1 10YR 2/1 Hydric Soil Indicators:Indicators for Problematic Hydric Soils3: Histosol (A1) Polyvalue Below Surface (S8) (LRR R,2 cm Muck (A10) (LRR K, L, MLRA 149B) Histic Epipedon (A2)MLRA 149B)Coast Prairie Redox (A16) (LRR K, L, R) Black Histic (A3) Thin Dark Surface (S9) (LRR R, MLRA 149B) 5 cm Mucky Peat or Peat (S3) (LRR K, L, R) Hydrogen Sulfide (A4) High Chroma Sands (S11) (LRR K, L) Mucky Loam/Clay Loc2 Texture Remarks Mucky Loam/Clay SOIL Wet Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type 1 1-12 10YR 4/1 US Army Corps of Engineers Northcentral and Northeast Region – Version 2.0 CITY OF SOUTH BURLINGTON575 DORSET STREET, SOUTH BURLINGTON, VERMONT 05403HOYLE, TANNER & ASSOCIATES, INC125 COLLEGE STREET, BURLINGTON, VERMONT 05401WATERSHED CONSULTING ASSOCIATES, LLC430 SHELBURNE ROAD, BURLINGTON, VERMONT 05406VERMONT SURVEY AND ENGINEERING, INC.79 RIVER STREET, SUITE 201, MONTPELIER, VERMONT 05602APRIL 2018PREPARED BY:125 COLLEGE STREET - 4TH FLOORBURLINGTON, VERMONT 05401CITY OF SOUTH BURLINGTON, VERMONTKENNEDY DRIVE STORMWATER PONDSWETLAND BUFFER IMPACTSDRAFTSUBMITTALREVIEWI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 G-00.dwg, 5/1/2018 3:14:25 PM, 1:2 DDKENNEDY DRIVEDNOTE:SITE PLAN8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P3-1P3-12KENNEDY DRIVE POND 3 EXISTING SITE PLAN SYMBOLDESCRIPTIONLEGEND:EXISTINGI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P3-1.dwg, 5/1/2018 3:14:29 PM, 1:2 DDDKENNEDY DRIVESITE PLAN8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P3-2P3-23KENNEDY DRIVE POND 3 PROPOSED SITE PLAN WITH WETLAND BUFFER IMPACTS SYMBOLDESCRIPTIONLEGEND:EXISTINGSYMBOLDESCRIPTIONPROPOSEDI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P3-2.dwg, 5/1/2018 3:14:36 PM, 1:2 DKENNEDY DRIVENOTES:SITE PLAN8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P3-3P3-34KENNEDY DRIVE POND 3 LANDSCAPING PLAN PLANT TABLESYMBOLCOMMON NAMELEGEND:I:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P3-3.dwg, 5/1/2018 3:14:43 PM, 1:2 KENNEDY DRIVENOTE:8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P5-1P5-15KENNEDY DRIVE POND 5 EXISTING SITE PLANSITE PLANSYMBOLDESCRIPTIONLEGEND:EXISTINGI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P5-1.dwg, 5/1/2018 3:14:48 PM, 1:2 KENNEDY DRIVESITE PLAN8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P5-2P5-26KENNEDY DRIVE POND 5 PROPOSED SITE PLAN WITH WETLAND BUFFER IMPACTS SYMBOLDESCRIPTIONLEGEND:EXISTINGSYMBOLDESCRIPTIONPROPOSEDI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P5-2.dwg, 5/1/2018 3:14:54 PM, 1:2 DDKENNEDY DRIVE8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P6-1P6-17KENNEDY DRIVE POND 6 EXISTING SITE PLANSITE PLANI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P6-1.dwg, 5/1/2018 3:15:01 PM, 1:2 DDKENNEDY DRIVESITE PLAN8KENNEDY DRIVE STORMWATER POND IMPROVEMENT PROJECT 107873 c DRAFT107873 P6-2P6-28KENNEDY DRIVE POND 6 PROPOSED SITE PLAN LEGEND:SYMBOLDESCRIPTIONPROPOSEDI:\107873 - Kennedy Drive Pond\2-CADD\Exhibits\BUFFER IMPACTS\107873 P6-2.dwg, 5/1/2018 3:15:07 PM, 1:2 Vermont Department of Environmental Conservation Agency of Natural Resources Watershed Management Division One National Life Drive, Main Bldg., 2nd Floor [phone] 802-828-1535 Montpelier, VT 05620 [fax] 802-828-1544 To preserve, enhance, restore, and conserve Vermont's natural resources, and protect human health, for the benefit of this and future generations. NOTICE OF DRAFT WETLAND GENERAL PERMIT #3-9026 The Secretary of the Agency of Natural Resources is issuing a draft Wetland General Permit for public comment pursuant to 10 V.S.A. §905b and §9.7 of the Vermont Wetland Rules (VWR). The General Permit is for certain specified water quality improvement projects conducted within Class II wetlands and associated buffer zones. Activities eligible for coverage under this general permit are limited to specific practices that are intended to improve water quality either by mitigating known pollution sources, or by reducing flood hazards. Eligible activities are limited by square footage thresholds, and by the type of impacted wetland. Project proponents may self-verify coverage and must register the activity with the Vermont Wet lands Program, except for farm practices described in the permit. The specific water quality improvement projects include stream crossing structure replacement, failed wastewater system replacement, retrofits for Stormwater treatment practices, and Vermont Natural Resources Conservation Services Conservation Practice Standards on farms for access roads, heavy use protection areas, stream crossings, trails and walkways, and artificial wetlands. The NRCS Practice Standards can be found at: https://efotg.sc.egov.usda.gov/references/public/VT/TABLE_OF_CONSERVATION_PRACTI CES.pdf. The Secretary is issuing a General Permit in order to more effectively and efficiently regulate and protect Vermont’s significant wetlands. The Secretary reserves the right to require an individual permit or different general permit if deemed necessary to protect wetlands. Although individuals may self-verify their project’s eligibility, Wetlands Program Staff are available to consult. This consultation is particularly helpful for determining if the wetland is a bog, fen, or vernal pool which would need to be avoided for permit coverage. This General Permit does not supersede any existing Vermont Wetland Rule exemptions or allowed uses. Below is a list of activities which would not be eligible for this proposed general permit because the activities do not need any permit for the activities: Food and Crop Area Exemption: wetland areas used to grow food or crops in connection with farming activities that have been in ordinary rotation since February 23, 1990 are excluded from regulation under the VWR. From February 23, 1990 to present, all new farming activities within significant wetlands or their buffer zones fall under the Vermont Wetland Rules. This exclusion expires when the area is no longer used to grow food or crops, or is no longer in ordinary rotation. When the exclusion expires, the area may then be considered a Class II wetland, and therefore will then also be subject to the 50 foot buffer zone again. For example, this exemption expires whenever a pasture or hayfield wetland will be turned into a walkway or access road because the structure is not growing food or crop. Allowed Use §6.12 The maintenance, reconstruction, or routine repair of structures and facilities (including ski trails, public transportation facilities, bulkheads, docks, piers, pilings, paved areas, houses, or other buildings) in compliance with the Vermont Wetland Rules in existence as of the date of their construction or in existence as of February 23, 1990 or additions to such structures or facilities which do not involve substantial expansion or modification in a wetland or buffer. Allowed Use §6.13 Emergency repair, cleanup, or maintenance of structures and facilities (including utility poles and lines, public transportation facilities, bulkheads, docks, piers, pilings, paved areas, houses, or other buildings), or emergency actions required to provide for public health, safety and welfare for disaster relief in connection with a federal or state- designated disaster. Complete copies of the draft permit can be obtained by writing to the address below, or by clicking on the following link: https://enb.vermont.gov/ Any person may file comments in writing on the draft Wetland General Permit through May 9, 2018 with: 1 STATE OF VERMONT AGENCY OF NATURAL RESOURCES DEPARTMENT OF ENVIRONMENTAL CONSERVATION WETLANDS GENERAL PERMIT 3-9026 Water Quality Improvement Projects in Significant Wetlands and Buffers I. Purpose The Secretary of the Vermont Agency of Natural Resources (Secretary) hereby issues this general permit pursuant to 10 V.S.A. § 905b and §§ 9.8 and 9.9 of the Vermont Wetland Rules (VWR) (effective April 1, 2017), for the purpose of expediting the permitting process for certain specified water quality improvement projects conducted in significant wetlands and their buffer zones. II. Findings Pursuant to 10 V.S.A. § 913 and Section 9 of the Vermont Wetland Rules (VWR), any activity in a Class II wetland or its associated buffer zone is prohibited unless it is an allowed use, or it is authorized by a permit, conditional use determination, or order issued by the Secretary. Pursuant to Section 9.8 of the VWR, the Secretary may issue general permits authorizing discrete categories of activities or uses in discrete categories of Class II wetlands. The Secretary may, at his or her discretion, issue a nonreporting general permit (VWR § 9.9(g)). Activities and uses eligible for authorization under a general permit must be found to comply with the VWR and have no undue adverse effect on the protected functions and values of the impacted wetland. This finding must be based on an evaluation of both the direct and immediate effects of the proposed activity on the wetland, as well as the cumulative or ongoing effects of the activity on the wetland. Activities eligible for coverage under this general permit are limited to specific practices that are intended to improve water quality either by mitigating known pollution sources, or by reducing flood hazards. Eligible activities are limited by square footage thresholds, and by the type of impacted wetland. If eligible projects are conducted in accordance with the terms and conditions of this permit, there will be minimal or no alteration of the physical and vegetative wetland characteristics that provide the following functions: water storage for flood water and storm runoff (VWR §5.1), surface and groundwater protection (§5.2), fisheries habitat (§5.3), wildlife and migratory bird habitat (§5.4), and erosion control through binding and stabilizing the soil (§5.10). Potential impacts to exemplary wetland natural communities (§5.5), and threatened and endangered species habitat (§5.6), are limited through the Limitations on Coverage in Part V of this general permit. Given the limited nature of the activities eligible for coverage under this general permit, no potential impacts are predicted for education and research in natural science (§5.7), recreational value and economic benefits (§5.8), and open space and aesthetics (§5.9). Based on the factors described above, if an eligible project is conducted in accordance with the terms and 2 conditions of this general permit, The Secretary has determined that the activity will comply with the Vermont Wetland Rules and will not result in undue adverse impacts to wetland functions and values. In determining whether coverage under this general permit should be granted, the Secretary has evaluated the potential effect of the eligible activities on the basis of both their direct and immediate effects as well as on the basis of any cumulative or on- going effects. III. Definitions a. Managed Areas means Class II wetland and buffer areas that have been managed and maintained, including mowed lawns, mowed road shoulders, parking areas, roads, hayfields, managed pasture, and croplands. This category does not include managed forest or land that has been allowed to lay fallow for three or more years. The clearing of woody vegetation from a natural wetland to create a managed wetland requires a wetlands permit. b. Natural Areas means Class II wetland and buffer areas that are naturally vegetated and that have not been managed or have been minimally managed. This category includes forested swamps, shrub swamps, marshes, thickets, and areas managed for silviculture. c. Practice means any activity eligible for coverage under this general permit. d. Project means a plan proposed by a person that includes the construction of one or more practices eligible for coverage under this general permit. A project shall specify the location and design of the practices that will be constructed, as well as the timeframe within which construction shall take place. For STP projects described in subpart (b) below, the retrofits for a parcel or specified development are considered a single project. A Flow Restoration Plan may consist of multiple projects and shall not be considered a single project for the purposes of this permit . A perso n shall not intentionally subdivide the components of a project in order to qualify for coverage under this general permit. IV. Activities Eligible for Coverage Under this General Permit Activities eligible for coverage under this general permit include certain water quality improvement projects on farms, certain retrofit stormwater treatment projects, and replacement of stream crossing structures and failed wastewater treatment systems. To be eligible for coverage under this general permit, an activity must meet the conditions and criteria listed in subparts a), b), c), or d) of this part, as well as the General Conditions listed in Part VI. Permitting thresholds for activities are based on whether the proposed activity takes place in a “managed” or “natural” wetland. a. Water Quality Improvement Projects on Farms. The Secretary has determined that certain water quality improvement practices, when conducted according to the standards listed below, result in reduced impact to significant wetlands, and a net reduction in pollutant loading to waters of the state. When conducted on land that is actively used for farming activities as defined in Section 3 3.1(a) of the Vermont Wetland Rules, the activities listed below may be eligible for coverage under this general permit, and may proceed without notification to the Secretary. To be eligible for non-reporting coverage, project activities must comply with the impact thresholds identified below, and must be conducted in accordance with the Natural Resources Conservation Service (NRCS) Conservation Practice Standards for Vermont, specified below. The activities eligible for non-reporting coverage are as follows: i. Construction of Stream Crossings and Trails and Walkways: 1. Co nstruction of Stream Crossings, in accordance with NRCS Practice Standard and Implementation Requirements #578. Individual stream crossings shall impact no more than 500 square feet of natural wetland or buffer, or 5,000 square feet of managed wetland or buffer, resulting in impacts of no more than 5,000 square feet total to managed or natural wetland and buffer. 2. Construction of Trails and Walkways, in accordance with NRCS Practice Standard and Implementation Requirements #575. Individual trails and walkways shall impact no more than 500 square feet of natural wetland or buffer, or 5,000 square feet of managed wetland or buffer, resulting in impacts of no more than 5,000 square feet total to managed or natural wetland and buffer. ii. Other Water Quality I mprovement Projects on Farms: Construction of the following practices shall be subject to the impact thresholds identified below. Construction of more than one the following practices shall cumulatively result in impacts of no more than 5,000 square feet total to any wetland or buffer , as specified below: 1. Construction of access roads, in accordance with NRCS Practice Standard and Implementation Requirements #560, impacts no more than 500 square feet of natural wetland or buffer, or 5,000 square feet of managed wetland or buffer, resulting in impacts of no more than 5,000 square feet total to managed or natural wetland and buffer. 2. Designation and Construction of a Heavy Use Protection Area, in accordance with NRCS Practice Standard #561, impacting no more than 5,000 square feet of managed buffer, with no impacts to natural or managed wetland. 3. Construction of artificial wetlands, in accordance with NRCS Practice Standard #656, provided that the constructed wetland is built in a managed buffer, and does not impact more than 5,000 square feet of managed buffer, with no impacts to natural or managed wetlands. b. Retrofit of Stormwater Treatment Practices. The Secretary has determined that the installation of certain Stormwater Treatment Practices (STPs) to address existing impervious surface is a critical step in implementing Total Maximum Daily Loads (TMDLs) in stormwater impaired watersheds, Lake Champlain, and Lake Memphremagog. Additionally, existing sites with three or more acres of 4 impervious surface will require installation of STPs in order to meet the requirements of the forthcoming stormwater developed lands general permit, which is critical for meeting the Lake Champlain TMDL. The retrofit of stormwater infrastructure with STPs can result in improved water quality in these watersheds. Unless otherwise specified in this general permit, projects retrofitting existing impervious surfaces with stormwater STPs according to the terms of a validly-issued operational stormwater permit, authorization under the MS4 General Permit, TS4 General Permit, or Municipal Roads General Permit, may be eligible for coverage under this general permit, and may proceed with construction following registration of the project. To be eligible for coverage, projects must comply with the following conditions: i. Installation of STPs, including installation of multiple STPs that are part of a single retrofit project, must impact no more than 500 square feet of natural wetland or buffer, no more than 2,000 square feet of managed wetland, and no more than 5,000 square feet of managed buffer, result ing in no more than 5,000 total square feet of impact to any wetland or buffer. ii. Permittees must register the location and type of STPs to be constructed prior to commencing construction. c. Stream crossing structure replacement for Public Safety, Aquatic Organism Passage (AOP), or for Flood Resiliency Improvements. The Secretary has determined that certain impacts associated with stream crossing structure replacements that do not qualify as allowed uses under VWR § 6.12 are necessary to improve public safety, aquatic organism passage design, and improvements to stream flow and flood capacity. The allowed use in Section 6.12 of the VWR allows for the maintenance, reconstruction or routine repair of structures and facilities, if there is not substantial expansion beyond the existing footprint of the structure or additional impacts are not required to access the structure. But expansion of a crossing structure is often necessary to improve AOP and flood resiliency. Furthermore, t emporary access to make improvements or to allow for continued public use of the road is often necessary to implement the replacement. In order to be eligible for coverage under this general permit for activities outside of the footprint of an existing structure, replacements must obtain authorization from one of the following under the Vermont Department of Environmental Conservation Stream Alteration General Permit: E. General Permit Coverage for Emergency Protective Measures, or F. General Permit Coverage of Next -Flood Protective Measures. To be eligible for coverage impact totals from the complete project shall not exceed 5,000 square feet . Projects must comply with the following conditions : i. Expansion of the existing structure (expansion of culvert length, installation of wing walls, replacement with wider structure etc.) shall not result in more than 1,000 square feet of impact in wetland or buffer zone. ii. Temporary reroutes to allow for public travel and temporary access for construction purposes shall not result in more than 5,000 square feet of impact to wetland and buffer zone. All impact ed area shall be promptly 5 restored (return grade, seed, and mulch) upon the completion of the project, and shall be in place no longer than 12 months. Where temporary reroutes are necessary over forested wetland and buffer, stumps shall remain in place. d. Replacement of Failed Wastewater Systems in Managed Buffer Zones. The Secretary has determined that the prompt replacement of failed wastewater systems is necessary to abate health and environmental hazards associated with the discharge of contaminated water and sewage. To be eligible for coverage under this permit, there must be an immediate and ongoing health or environmental hazard associated with the failed system, the building structure serviced by the failed system in question must be occupied, and the system must still be in use at the time of failure. Projects must also meet the following criteria, and impacts from the new system installation shall not exceed 5,000 square feet of impact to managed buffer zone (eg lawn or other maintained buffer): i. There is no alternative location outside the wetland buffer that is reasonably available to the landowner that is adequately suited for wastewater disposal, including existing easements on adjoining property; ii. The new system will comply with the Wastewater System and Potable Water Supply Rules including the variance section for “best fix.” V. Obtaining Authorization a. Non-reporting Coverage: Individuals conducting water quality improvement projects on farms, pursuant to Part III(a) of this general permit, may proceed without application or notification to the Agency, provided that the project will meet the terms and conditions of this general permit. b. Registration of Project: For all other eligible projects, pursuant to Part III(b), (c), and (d) of this general permit, may proceed without application for coverage, but must register the project on the Agency’s website prior to beginning construction. Registration must include the title of the entity conducting the activity, the location of the activity, and a description of the activity. VI. Limitations on coverage The following activities are not eligible for coverage under this general permit: a. Activities that are allowed uses under §6 of the Vermont Wetland Rules. b. Activities within 50 feet of wetland areas used to grow food or crops that fall under the Farming Exemption in Section 3.1 of the Vermont Wetland Rules. Activities in these areas do not require permit coverage. c. Activities within a Class I wetland or buffer zone. d. Water quality improvement projects impacting more than the allowable square footage for each wetland and buffer type, and eligible activity. 6 e. Water quality improvement projects identified in Part III(2)(a) on land that is not actively used for farming activities. A property is considered to be actively used for farming when farming activities are continuously conducted on the property. f. Activities affecting wetlands significant for the Rare, Threatened, or Endangered (RTE) Species Habitat function pursuant to §5.6 of the Vermont Wetland Rules. This limitation may be waived if the applicant has received approval from the Department of Fish and Wildlife's Natural Heritage Inventory. g. Activities located in or adjacent to (within 50 feet of) bogs, fens, or vernal pools. Bogs, fens, and vernal pools are identified on the ANR Atlas, which is found at: https://anrmaps.vermont.gov/websites/WetlandProjects/default.html. The Wetlands Program may be contacted to verify if a wetland is one of these types of wetlands. h. Activities in or adjacent (within 50 feet) to wetlands that are significant for the Exemplary Wetland Natural Community function pursuant to §5.5 of the Vermont Wetland Rules. This limitation may be waived if the applicant has received approval from the Department of Fish and Wildlife's Natural Heritage Inventory Program. i. Activities in or adjacent (within 50 feet) to wetlands at or above 2,500 feet in elevation (headwaters wetlands). j. Unpermitted as-built projects that required a permit and did not obtain one in violation of the Vermont Wetland Rules. k. With the exception of stream crossings and trails and walkways as defined in Part IV(a)(i) of this general permit, activities that are components of a single project or planned phases of a multiphase project, where the entire project exceeds the eligibility thresholds in Part IV of this general permit , are not eligible for coverage. A Flow Restoration Plan may consist of multiple projects and shall not be considered a single project for the purposes of this general permit. VII. Relation to Other Permits Activities eligible for coverage under this general permit may also require a permit pursuant to other local, state, and federal laws, including a federal wetlands permit pursuant to Section 404 of the Clean Water Act, 33 U.S.C. § 1344. Applicants are responsible for determining if any such permits apply to their proposed activities and obtaining any such permits. VIII. Required Best Management Practices a. Best Management Practices Applicable to All Eligible Projects: i. Steps shall be taken to prevent the transport of sediment into any wetland or other surface water and to promote re-vegetation following the completion of work: 1. If a construction stormwater permit is required (i.e. over an acre of soil disturbance), the permittee shall follow the terms and conditions of that permit. Otherwise, the permittee shall utilize recommended sediment and erosion controls as needed and as described in the Vermont Department of Environmental 7 Conservation's Low Risk Handbook for Erosion Prevention and Sediment Control, or other equivalent controls as approved by the Agency. 2. All sediment controls and construction fencing shall be installed prior to beginning any earthwork for the project and removed following the successful establishment of vegetation. 3. Disturbed soils shall be seeded and mulched within 48 hours of final grading. Appropriate wetland seed mixes shall be used within wetlands. Appropriate erosion control/conservation seed mixes shall be used within buffers. All areas shall be stabilized within wetlands and buffer zones and mulched with straw or weed-free hay to limit the spread of invasive species. ii. If the impact is temporary in nature, stockpiling of material shall be done on filter fabric or equivalent in the wetland and buffer zone. Temporarily removed wetland soils shall be put back in place in the reverse order that they were removed and restored to their prior condition to match the original soil profile. iii. Removed and stockpiled materials shall be located outside of wetlands and buffer zones and at least 50 feet from surface waters, and appropriate erosion controls measures as described above shall be used. iv. Impacts from equipment access to the project site shall be limited by utilizing existing or low impact routes using the following sequence of options listed in order of preference: 1. Access should be limited to upland areas or existing maintained roads to the extent practicable; 2. Access on other existing primitive roads or existing managed areas (as defined in Section III(1)a) in wetlands or buffer zones; 3. Where existing roads are not an option for access, minimize rutting and earth disturbing activities by: 4. Accessing wetland areas with mats or under frozen or dry conditions. Winter construction under frozen conditions may minimize ground disturbance and reduce impacts to wildlife; 5. Delineating the limits of disturbance using a combination of silt fence, flagging, and/or snow fence; 6. Using low-ground pressure or track vehicles in wetlands to minimize compaction and rutting; 7. Minimizing equipment use in wetlands and limiting vehicle trips; and 8. Restoring the project site in order to reverse soil compaction and stabilize the soil on the site, and replanting the site if vegetation has been destroyed. v. Waste disposal and equipment refueling shall be limited to areas outside wetlands and buffer zones and at least 50 feet from surface waters. vi. Final earthwork shall return wetlands and buffer zones to the original grade. 8 vii. The potential for the introduction and spread of invasive species in wetlands and buffer zones shall be decreased by using the following methods: 1. All equipment shall be cleaned so as to contain no observable soil or vegetation prior to work in wetlands and buffer zones to prevent the spread of invasive species; 2. If removed material contains invasive species, care should be taken to dispose of the material in a manner that does not spread the invasive species to new areas b. Activity-Specific Best Management Practices: i. Installation of underground facilities in wetlands or buffer zones: 1. Trenches shall be filled, mulched, and seeded immediately or upon final inspection of the line; 2. If a directional bore is required, the depth of the bore beneath the wetland shall not puncture a confining layer essential to maintain wetland hydrology; 3. If drilling or boring is required, drilling fluid shall be composed of bentonite clay, clean water, and Agency approved additives (e.g., "environmentally safe" drill soap or polymers). ii. Activities in surface water body margins: 1. Soil and vegetation disturbance shall be minimized to avoid unnecessary impacts to waterbodies: a. Avoid removing vegetation until just before beginning construction that disturbs the soil; b. Minimize the area of bare soil within the approved work zone as much as possible; c. Maintain as much of a naturally vegetated buffer as possible around wetlands and surface waters to slow runoff and trap sediments; d. Phase construction to minimize the extent of soils disturbed simultaneously; and e. Dredged material shall be properly disposed of and dewatering of dredged material must take place such that a turbid discharge to waters of the State does not occur; IX. General Conditions a. All activit ies shall be completed, operated, and maintained in accordance with the conditions of this general permit. Any permit noncompliance constitutes a violation of 10 V.S.A. Chapter 37 and may be cause for an enforcement action or revocation and reissuance, modification, or termination of the permittee's authorization under this general permit. b. For projects requiring registrat ion, t he permittee shall register their project with the Vermont Wetlands Program prior to the start of construction. 9 c. Activities must be designed and constructed to avoid and minimize impacts, both temporary and permanent, to wetlands, buffers and wetland functions and values to the maximum extent practicable at the project site. Consideration of mitigation (avoiding, minimizing, or restoring) is required to the extent necessary to ensure that the adverse effects to protected wetland function and value are no more than minimal. For NRCS practices, consideration of avoidance and minimization of impacts must be consistent with the Wetland Protection Policy required for all NRCS technical assistance and funding. d. Permittees must comply with the required best management practices listed in Section VII of this general permit . e. This permit does not relieve the permittee of the responsibility to comply with any other applicable federal, state, and local laws, regulations, and permits. f. The Agency maintains continuing jurisdiction over a project authorized under this general permit and may at any time order remedial measures if it appears likely that undue adverse impacts to protected wetland functions and values are or will occur. X. Appeals Pursuant to 10 V.S.A. Chapter 220, any appeal of this decision must be filed with the clerk of the Environmental Division of the Superior Court within 30 days of the date of the decision. The Notice of Appeal must specify the parties taking the appeal and the statutory pro vision under which each party claims party status; must designate the act or decision appealed from; must name the Environmental Division; and must be signed by the appellant or the appellant’s attorney. In addition, the appeal must give the address or location and description of the property, project, or facility with which the appeal is concerned and the name of the applicant or any permit involved in the appeal. The appellant must also serve a copy of the Notice of Appeal in accordance with Rule 5(b)(4)(B) of the Vermont Rules for Environmental Court Proceedings. For further information, see the Vermont Rules for Environmental Court Proceedings, available on line at www.vermontjudiciary.org. The address for the Environmental Division is: 32 Cherry St.; 2nd Floor, Suite 303; Burlington, VT 05401 (Tel. # 802-828-1660). XI. Effective Date and Permit Term This permit shall become effective upon signing and shall expire five years from the date of signing. State of Vermont Agency of Natural Resources Emily Boedecker, Commissioner Department of Environmental Conservation By: 10 Pete LaFlamme, Director Watershed Management Division ACT 250 NOTICE MINOR APPLICATION #4C1122-1 10 V.S.A. §§ 6001 - 6093 On May 18, 2018, City of South Burlington, 575 Dorset Street, South Burlington, VT 05403 filed application #4C1122-1 for a project generally described as retrofit construction of three existing stormwater treatment ponds along Kennedy Drive - Ponds 3, 5, and 6. The Project is located along Kennedy Drive (Pond 3 – north side of Kennedy Drive, west of Manor Woods and Timberlane cross streets; Pond 5 – south side of Kennedy Drive and north of Windridge Court parking lot; and Pond 6 – on Kennedy Drive, east of Windridge Court drive) in South Burlington, Vermont. The District #4 Environmental Commission is reviewing this application under Act 250 Rule 51 -- Minor Applications. A copy of the application and proposed permit are available for review at the office listed below. The application and a draft permit may also be viewed on the Natural Resources Board's web site (http://nrb.vermont.gov) by clicking on "Act 250 Database" and entering the project number “4C1122-1”. No hearing will be held and a permit may be issued unless, on or before June 15, 2018, a person notifies the Commission of an issue or issues requiring the presentation of evidence at a hearing or the Commission sets the matter for hearing on its own motion. Any hearing request must be in writing to the address below, must state the criteria or subcriteria at issue, why a hearing is required and what additional evidence will be presented at the hearing. Any hearing request by an adjoining property owner or other interested person must include a petition for party status. Prior to submitting a request for a hearing, please contact the district coordinator at the telephone number listed below for more information. Prior to convening a hearing, the Commission must determine that substantive issues requiring a hearing have been raised. Findings of Fact and Conclusions of Law will not be prepared unless the Commission holds a public hearing. If you feel that any of the District Commission members listed on the attached Certificate of Service under “For Your Information” may have a conflict of interest, or if there is any other reason a member should be disqualified from sitting on this case, please contact the district coordinator as soon as possible, no later than prior to the response date listed above. The Applicant has requested a partial waiver of notice to adjoining landowners, pursuant to Act 250 Rule 10(F). The District Commission has granted the waiver request based on the determination that the adjoining landowners whose notice has been waived, reasonably could not be affected by the proposed project and that serving notice on all the adjoining landowners constitutes a significant administrative burden without corresponding public benefit. Should a hearing be held on this project and you have a disability for which you are going to need accommodation, please notify us by June 15, 2018. Parties entitled to participate are the Municipality, the Municipal Planning Commission, the Regional Planning Commission, affected state agencies, and adjoining property owners and other persons to the extent they have a particularized interest that may be affected by the proposed project under the 10 criteria. Non-party participants may also be allowed under 10 V.S.A. Section 6085(c)(5). Dated at Essex Junction, Vermont this 22nd day of May, 2018. By: /s/Stephanie H. Monaghan Stephanie H. Monaghan District #4 Coordinator 111 West Street Essex Junction, VT 05452 802/879-5662 stephanie.monaghan@vermont.gov Y:\NRB\Essex\DISTRICTS\DIST4\PROJECTS\4C1001-4C1250\4C1122\4C1122-1\Published Documents\District Commission Documents\4C1122-1.minor.notice.docx State of Vermont __________________________________________________________ LAND USE PERMIT AMENDMENT This is a PROPOSED permit; please submit any written comments to Stephanie H. Monaghan, 111 West Street, Essex Junction, VT 05452 by June 15, 2018. A permit will NOT be issued until the District Commission receives and reviews the following information: 1. Construction General Permit issued by the ANR-DEC Watershed Management Division. CASE NO: 4C1122-1 LAWS/REGULATIONS INVOLVED City of South Burlington 10 V.S.A. §§ 6001 - 6093 (Act 250) 575 Dorset Street South Burlington, VT 05403 District Environmental Commission #4 hereby issues Land Use Permit Amendment #4C1122-1, pursuant to the authority vested in it by 10 V.S.A. §§ 6001-6093. This permit amendment applies to the lands identified in Book 78, Page 164; and Book 681, Pages 394-453 of the land records of South Burlington, Vermont, as the subject of deeds to City of South Burlington; and Book 175, Pages 428-429, of the land records of South Burlington, Vermont, as the subject of a deed to Windridge Homeowners Association. This permit specifically authorizes the retrofit construction of three existing stormwater treatment ponds along Kennedy Drive - Ponds 3, 5, and 6. The Project is located along Kennedy Drive (Pond 3 – north side of Kennedy Drive, west of Manor Woods and Timberlane cross streets; Pond 5 – south side of Kennedy Drive and north of Windridge Court parking lot; and Pond 6 – on Kennedy Drive, east of Windridge Court drive) in South Burlington, Vermont. Jurisdiction attaches because the Project constitutes a material change to a permitted development or subdivision, and thus requires a permit amendment pursuant to Act 250 Rule 34. 1. The Permittee, and its assigns and successors in interest, is obligated by this permit to complete, operate and maintain the project as approved by the District Commission in accordance with the following conditions. 2. The project shall be completed, operated and maintained in accordance with the conditions of this permit and the permit application, plans, and exhibits on file with the District Environmental Commission and other material representations. The approved plans are: Sheet G-0.1 - “General Notes, Legend and Drawing Index,” dated April 6, 2018 (Exhibit # ); Sheet G-0.2 - “General Notes,” dated April 6, 2018 (Exhibit # ); Page 2 Land Use Permit #4C1122-1 Sheet C-1.3 - “Kennedy Drive Pond 3 Existing Site Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-1.4 - “Kennedy Drive Pond 3 Proposed Site Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-1.5 - “Kennedy Drive Pond 5 Existing Site Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-1.6 - “Kennedy Drive Pond 5 Proposed Site Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-1.7 - “Kennedy Drive Pond 6 Existing Site Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-1.8 - “Kennedy Drive Pond 6 Proposed Site Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-2.4 - “Kennedy Drive Pond 3 Landscaping Plan,” dated April 6, 2018 (Exhibit # ); Sheet C-3.3 - “Erosion Control Details,” dated April 6, 2018 (Exhibit # ); Sheet P3-1 - “Kennedy Drive Pond 3 Existing Site Plan,” dated April 2018 (Exhibit # ); Sheet P3-2 - “Kennedy Drive Pond 3 Proposed Site Plan with Wetland Buffer Impacts,” dated April 2018 (Exhibit # ); Sheet P3-3 - “Kennedy Drive Pond 3 Landscaping Plan,” dated April 2018 (Exhibit # ); Sheet P5-1 - “Kennedy Drive Pond 5 Existing Site Plan,” dated April 2018 (Exhibit # ); Sheet P5-2 - “Kennedy Drive Pond 5 Proposed Site Plan with Wetland Buffer Impacts,” dated April 2018 (Exhibit # ); Sheet P6-1 - “Kennedy Drive Pond 6 Existing Site Plan,” dated April 2018 (Exhibit # ); Sheet P6-2 - “Kennedy Drive Pond 6 Proposed Site Plan,” dated April 2018 (Exhibit # ); “Total Area Plan ROW-A,” dated 09-03-04 (Exhibit # ); “Total Area Plan ROW-B,” dated 09-03-04 (Exhibit # ); and “Total Area Plan ROW-C,” dated 09-03-04 (Exhibit # ). 3. All conditions of Land Use Permit #4C1122 and amendments are in full force and effect except as further amended herein. 4. The Permittee shall comply with all of the conditions of the following Agency of Natural Resources Permit: a. Authorization of Notice of Intent # under Construction General Permit #3-9020 issued on (date) by the ANR Watershed Management Division 5. Any nonmaterial changes to the permit listed in the preceding condition shall be automatically incorporated herein upon issuance by the Agency of Natural Resources. Page 3 Land Use Permit #4C1122-1 6. Representatives of the State of Vermont shall have access to the property covered by this permit, at reasonable times, for the purpose of ascertaining compliance with Vermont environmental and health statutes and regulations and with this permit. 7. A copy of this permit and plans shall be on the site at all times throughout the construction process. 8. No change shall be made to the design, operation or use of this project without a permit amendment issued by the District Commission or a jurisdictional opinion from the District Coordinator that a permit is not required. 9. Pursuant to 10 V.S.A. § 8005(c), the District Commission may at any time require that the permit holder file an affidavit certifying that the project is in compliance with the terms of this permit. 10. The conditions of this permit and the land uses permitted herein shall run with the land and are binding upon and enforceable against the Permittee and their successors and assigns. 11. Construction hours shall be limited to Monday through Friday from 7:00AM to 5:00PM. 12. The Permittee shall apply and maintain water and/or other agents approved by the Watershed Management Division in the Project’s Erosion Prevention and Control Plan on all roadways or disturbed areas within the project during construction and until pavement and/or vegetation is fully established to control dust. 13. At a minimum, the Permittee shall comply with the Department of Environmental Conservation’s Low Risk Site Handbook for Erosion Prevention and Sediment Control (2006). 14. The Permittee shall comply with Exhibits #001 and __ (Schedule B; and Erosion Control Details) for erosion prevention and sediment control. The Permittee shall prevent the transport of any sediment beyond that area necessary for construction approved herein. All erosion prevention and sediment control devices shall be periodically cleaned, replaced and maintained until vegetation is permanently established on all slopes and disturbed areas. 15. All mulch, siltation dams, water bars and other temporary devices shall be installed immediately upon grading and shall be maintained until all roads are permanently surfaced and all permanent vegetation is established on all slopes and disturbed areas. Topsoil stockpiles shall have the exposed earth completely mulched and have siltation checks around the base. 16. All areas of disturbance must have temporary or permanent stabilization within 14 days of the initial disturbance. After this time, any disturbance in the area must be stabilized at the end of each work day. The following exceptions apply: i) Stabilization is not required if work is to continue in the area within the next 24 hours and there is no precipitation forecast for the next 24 hours. ii) Stabilization is not required if the work is occurring in a self-contained excavation (i.e. no outlet) with a depth of 2 feet or greater (e.g. house foundation excavation, utility trenches). 17. All disturbed areas of the site shall be stabilized, seeded and mulched immediately upon completion of final grading. All disturbed areas not involved in winter construction shall Page 4 Land Use Permit #4C1122-1 be mulched and seeded before October 1. Between the periods of October 1 to April 15, all earth disturbing work shall conform with the “Requirements for Winter Construction” standards and specifications of the Department of Environmental Conservation’s Low Risk Site Handbook for Erosion Prevention and Sediment Control (2006). 18. In addition to conformance with all erosion prevention and sediment control conditions, the Permittee shall not cause, permit or allow the discharge of waste material into any surface waters. Compliance with the requirements of this condition does not absolve the Permittee from compliance with 10 V.S.A. (§§ 1250-1284) Chapter 47, Vermont's Water Pollution Control Law. 19. Any extracted stumps shall be disposed of on-site above the seasonal high water table and not in any wetland, or at a State approved landfill, so as to prevent groundwater pollution. 20. The Permittee and all assigns and successors in interest shall continually maintain the landscaping as approved in Exhibits # (Kennedy Drive Pond 3 Proposed Site Plan; Kennedy Drive Pond 5 Proposed Site Plan; and Kennedy Drive Pond 3 Landscaping Plan) by replacing any dead or diseased plantings within the season or as soon as possible after the ground thaws, whichever is sooner. 21. Prior to any site work, the Permittee shall install and maintain temporary fencing along the tree line and around trees to be retained as depicted on Exhibits # (Kennedy Drive Pond 3 Proposed Site Plan; Kennedy Drive Pond 5 Proposed Site Plan; and Kennedy Drive Pond 3 Landscaping Plan). 22. No exterior lighting or signage is proposed in conjunction with the Project. 23. The Permittee shall provide each prospective purchaser of any interest in this Project a copy of the Land Use Permit Amendment before any written contract of sale is entered into. 24. Pursuant to 10 V.S.A. § 6090(b)(1) this permit amendment is hereby issued for an indefinite term, as long as there is compliance with the conditions herein. Notwithstanding any other provision herein, this permit shall expire three years from the date of issuance if the Permittee has not commenced construction and made substantial progress toward completion within the three year period in accordance with 10 V.S.A. § 6091(b). 25. All site work and construction shall be completed in accordance with the approved plans by October 1, 2021, unless an extension of this date is approved in writing by the Commission. Such requests to extend must be filed prior to the deadline and approval may be granted without public hearing. 26. The Permittee shall file a Certificate of Actual Construction Costs, on forms available from the Natural Resources Board, pursuant to 10 V.S.A. § 6083a(g) within one month after construction has been substantially completed or two years from the date of this permit, whichever shall occur first. Application for extension of time for good cause shown may be made to the District Commission. If actual construction costs exceed the original estimate, a supplemental fee based on actual construction costs must be paid at the time of certification in accordance with the fee schedule in effect at the time of application. Upon request, the Permittee shall provide all documents or other information Page 5 Land Use Permit #4C1122-1 necessary to substantiate the certification. Pursuant to existing law, failure to file the certification or pay any supplemental fee due constitutes grounds for permit revocation. The certificate of actual construction costs and any supplemental fee (by check payable to the "State of Vermont") shall be mailed to: Natural Resources Board, 10 Baldwin Street, Montpelier, VT 05633-3201; Attention: Certification. 27. Failure to comply with any condition herein may be grounds for permit revocation pursuant to 10 V.S.A. sec. 6027(g). Dated at Essex Junction, Vermont, this day of June, 2018. By__________________________ Thomas A. Little, Chair District #4 Commission Members participating in this decision: Parker Riehle Monique Gilbert Any party may file a motion to alter with the District Commission within 15 days from the date of this decision, pursuant to Act 250 Rule 31(A). Any appeal of this decision must be filed with the Superior Court, Environmental Division within 30 days of the date the decision was issued, pursuant to 10 V.S.A. Chapter 220. The Notice of Appeal must comply with the Vermont Rules for Environmental Court Proceedings (VRECP). The appellant must file with the Notice of Appeal the $265 entry fee required by 32 V.S.A. § 1431. The appellant must also serve a copy of the Notice of Appeal on the Natural Resources Board, 10 Baldwin Street, Montpelier, VT 05633-3201, and on other parties in accordance with Rule 5(b)(4)(B) of the Vermont Rules for Environmental Court Proceedings. Decisions on minor applications may be appealed only if a hearing was held by the district commission. Please note that there are certain limitations on the right to appeal. See 10 V.S.A. § 8504(k). For additional information on filing appeals, see the Court’s website at: http://www.vermontjudiciary.org/GTC/environmental/default.aspx or call (802) 828-1660. The Court’s mailing address is: Vermont Superior Court, Environmental Division, 32 Cherry Street, 2nd Floor, Suite 303, Burlington, VT 05401. Y:\NRB\Essex\DISTRICTS\DIST4\PROJECTS\4C1001-4C1250\4C1122\4C1122-1\Published Documents\District Commission Documents\4C1122-1.draft.permit.docx CERTIFICATE OF SERVICE I hereby certify on this 22nd day of May 2018, a copy of the foregoing ACT 250 NOTICE OF MINOR APPLICATION #4C1122-1, was sent by U.S. mail, postage prepaid to the following individuals without email addresses and by email to the individuals with email addresses listed. Note: any recipient may change its preferred method of receiving notices and other documents by contacting the District Office staff at the mailing address or email below. If you have elected to receive notices and other documents by email, it is your responsibility to notify our office of any email address changes. All email replies should be sent to nrb-act250essex@vermont.gov. City of South Burlington 575 Dorset Street South Burlington, VT 05403 stormwater@sburl.com Thomas DiPietro, Deputy DPW Director/SW Superintendent 104 Landfill Road South Burlington, VT 05403 tdipietro@sburl.com kworden@hoyletanner.com Donna Kinville, City Clerk Chair, City Council/Chair, City Planning Commission City of South Burlington 575 Dorset Street South Burlington, VT 05403 dkinville@sburl.com Chittenden County Regional Planning Commission 110 West Canal Street, Suite 202 Winooski, VT 05404 rmahony@ccrpcvt.org Elizabeth Lord, Land Use Attorney Agency of Natural Resources 1 National Life Drive, Davis 2 Montpelier, VT 05602-3901 anr.act250@vermont.gov FOR YOUR INFORMATION District #4 Environmental Commission Thomas Little, Chair Parker Riehle/Monique Gilbert 111 West Street Essex Junction, VT 05452 Barry Murphy/Vt. Dept. of Public Service 112 State Street, Drawer 20 Montpelier, VT 05620-2601 barry.murphy@vermont.gov Craig Keller/John Gruchacz/Jeff Ramsey/C. Clow VTrans Policy, Planning & Research Bureau One National Life Drive, Drawer 33 Montpelier, VT 05633 craig.keller@vermont.gov; john.gruchacz@vermont.gov jeff.ramsey@vermont.gov; christopher.clow@vermont.gov Vt. Agency of Agriculture, Food & Markets 116 State Street, Drawer 20 Montpelier, VT 05620-2901 AGR.Act250@vermont.gov Division for Historic Preservation National Life Building, Drawer 20 Montpelier, VT 05620 scott.dillon@vermont.gov james.duggan@vermont.gov NRCS, District Conservationist Natural Resources Conservation Service 68 Catamount Park, Ste. B Middlebury, VT 05753 marybeth.whitten@vt.usda.gov Winooski NRCD Office 617 Comstock Road, Suite 1 Berlin, VT 05602 whiterivernrcd@gmail.com Ethan Tapper, County Forester/FPR John Gobeille, ANR/Dept. of Fish & Wildlife 111 West Street Essex Junction, VT 05452 ethan.tapper@vermont.gov john.gobeille@vermont.gov Seven Days/Classified Ad Section 255 South Champlain Street, PO Box 1164 Burlington, VT 05402 classifieds@sevendaysvt.com Green Mountain Power Corporation c/o Kim Jones 163 Acorn Lane Colchester, VT 05446 kim.jones@greenmountainpower.com Kate Talbot/Vermont Gas Systems PO Box 467 Burlington, VT 05402 ktalbot@vermontgas.com Efficiency Vermont 128 Lakeside Ave., Suite 401 Burlington, VT 05401 pics@veic.org Michael Barsotti, Water Quality Director Champlain Water District 403 Queen City Park Road South Burlington, VT 05403 mike.barsotti@champlainwater.org ADJOINING LANDOWNERS Available via: https://anrweb.vt.gov/ANR/vtANR/Act250SearchResults.aspx?Num=4 C1122-1 Dated at Essex Junction, Vermont, this 22nd day of May, 2018. Natural Resources Board Technician 879-5614 christine.commo@vermont.gov Y:\NRB\Essex\DISTRICTS\DIST4\PROJECTS\4C1001-4C1250\4C1122\4C1122-1\Published Documents\District Commission Documents\4C1122-1 cos.docx 1 Dave Wheeler From:Pfeiffer, Rebecca <Rebecca.Pfeiffer@vermont.gov> Sent:Friday, May 04, 2018 1:37 PM To:Dipietro-Worden, Kirstin A.; Dave Wheeler Cc:Alexander, Gretchen; ANR - Act 250 Subject:RE: Kennedy Drive Stormwater Ponds Improvement Project - Curtesy Review Hello Kirstin & Dave, This email is a follow-up to our site visit on Wednesday, April 18th. We met to look at any potential floodplain or river corridor impacts from the conversion/improvements to the existing Kennedy Drive stormwater ponds 2 & 3. As Kirstin had stated below, these improvements would be reviewed under Act 250, and our office would be reviewing impacts to floodplains or river corridors under Criterion 1D – Floodways. Under Criterion 1D, the Agency of Natural Resources defines the floodway (called the ANR floodway) using the FEMA Special Flood Hazard Area (SFHA) to assess inundation floodplain areas and at the ANR River Corridor maps to assess impacts that may exacerbate riverine erosion hazards. In my 4/4 email below, I have a screenshot from the ANR Atlas that shows the FEMA-mapped Special Flood Hazard Area (SFHA) in gold and the ANR-mapped River Corridor shown in light yellow in the area around ponds 2 & 3. Inundation Flood Hazards: For both Ponds 2 & 3, the FEMA mapped floodplain is shown to be adjacent to the area of the ponds, especially for pond 2. On our 4/18 site visit, we met to see if the project would result in any filling or other impacts to the FEMA-mapped SFHA. Pond 3 is shown to be a bit further from the edge of the floodplain on the maps, and when we went on site, it was clearly located above the surrounding lower area that is mapped as floodplain. Therefore, Pond 3 is non-jurisdictional based on the work that is being proposed at this time. For pond 2, the 50% plan set that you had sent for my review shows the edge of the FEMA SFHA cutting into the western side of the existing pond. As we discussed on site, the proposal is to raise the existing berm on the western side by ~3’ and convert the pond into a gravel wetland. The proposal also includes a cut of material on the upslope side on the SE part of the pond in order to expand the pond’s capacity. From our discussion it appears that pond 2 would be considered to be located in the “ANR floodway” for the purposes of Act 250. When we review proposals located in the ANR floodway, our Flood Hazard Area & River Corridor Protection Procedure spells out the standards that we use to make recommendations to the District Commission for 1D considerations. When looking at inundation floodplain impacts, our policy is to maintain flood storage, i.e. for any fill or flood storage is lost due to a proposal, then that flood storage is regained on the site. For pond 2, we do not have any concerns based on the plans as reviewed and as we discussed on site 4/18/18. Although the berm on the western edge of the pond will be raised by ~ 3’, some new flood storage will be created within the pond. Additionally, the large Potash Brook wetland floodplain complex already provides an abundant amount of flood water storage, so the small volume of fill being added at the edge of this large floodplain would not appear to have an adverse impact on flood water storage. River Corridor/Erosion Hazards: In an earlier email exchange, we had determined that there were no river corridor impacts from the stormwater pond conversions. I’ve included a screen shot of the updated river corridor for the area around Pond 2 & 3. The river corridor for the site is actually a bit more narrow than what is shown on the ANR Atlas, since there has been a field assessment for the Potash Brook in this location. The field data helped Gretchen to refine the corridor, and that new corridor based on field data is shown below. The orange-lined corridor is what is found on the ANR Atlas, while the red-lined corridor is the updated corridor based on field data. Therefore, the project does not appear to have any impacts that may affect riverine erosion hazards. ACT 250 District Commission Application #: Exhibit #: Date Received: # 4, 6, 9 4C1122-1 020 5/16/18 ATTACHMENT B Pond 3 - Proposed Condition (Expanded DA) - Other flows above WQv Pond 3 - Proposed Condition (Expanded DA) - WQv 1S DA (with expansion) 14S DA (with expansion) WQv only (modified CN) 22S Existing DA (including new area identified by SB) 24S Expanded Portion of DA Only 3P Existing Pond as Constructed 17P Proposed gravel wetland 2-28-18 18P Proposed gravel wetland 2-28-1821P Node is just for combining flows - no storage Routing Diagram for Kennedy Pond 3 Updated 4 4 18 - Design Update - Expanded Existing Condition Prepared by Microsoft, Printed 12/18/2018 HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Subcat Reach Pond Link Kennedy Pond 3 Updated 4 4 18 - Design Update - Expanded Existing Condition Printed 12/18/2018Prepared by Microsoft Page 2HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Area Listing (all nodes) Area (acres) CN Description (subcatchment-numbers) 3.469 39 >75% Grass cover, Good, HSG A (1S, 22S, 24S) 1.174 61 >75% Grass cover, Good, HSG B (1S, 24S) 0.279 74 >75% Grass cover, Good, HSG C (1S, 22S, 24S) 8.581 97 Modified CN (14S) 7.743 98 Paved parking, HSG A (1S, 22S, 24S) 3.558 98 Paved parking, HSG B (1S, 24S) 0.940 98 Paved parking, HSG C (1S, 22S) 25.744 88 TOTAL AREA Kennedy Pond 3 Updated 4 4 18 - Design Update - Expanded Existing Condition Printed 12/18/2018Prepared by Microsoft Page 3HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Soil Listing (all nodes) Area (acres) Soil Group Subcatchment Numbers 11.212 HSG A 1S, 22S, 24S 4.732 HSG B 1S, 24S 1.219 HSG C 1S, 22S, 24S 0.000 HSG D 8.581 Other 14S 25.744 TOTAL AREA Kennedy Pond 3 Updated 4 4 18 - Design Update - Expanded Existing Condition Printed 12/18/2018Prepared by Microsoft Page 4HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Ground Covers (all nodes) HSG-A (acres) HSG-B (acres) HSG-C (acres) HSG-D (acres) Other (acres) Total (acres) Ground Cover Subcatchment Numbers 3.469 1.174 0.279 0.000 0.000 4.922 >75% Grass cover, Good 1S, 22S, 24S 0.000 0.000 0.000 0.000 8.581 8.581 Modified CN 14S 7.743 3.558 0.940 0.000 0.000 12.241 Paved parking 1S, 22S, 24S 11.212 4.732 1.219 0.000 8.581 25.744 TOTAL AREA Kennedy Pond 3 Updated 4 4 18 - Design Update - Expanded Existing Condition Printed 12/18/2018Prepared by Microsoft Page 5HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Pipe Listing (all nodes) Line# Node Number In-Invert (feet) Out-Invert (feet) Length (feet) Slope (ft/ft) n Diam/Width (inches) Height (inches) Inside-Fill (inches) 1 3P 270.32 269.00 150.0 0.0088 0.010 15.0 0.0 0.0 NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 6HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Time span=0.00-275.00 hrs, dt=0.01 hrs, 27501 points Runoff by SCS TR-20 method, UH=SCS, Weighted-Q Reach routing by Stor-Ind+Trans method - Pond routing by Stor-Ind method Runoff Area=8.581 ac 71.32% Impervious Runoff Depth=1.26"Subcatchment 1S: DA (with expansion) Flow Length=1,605' Slope=0.0007 '/' Tc=154.2 min CN=WQ Runoff=2.87 cfs 0.902 af Runoff Area=8.581 ac 0.00% Impervious Runoff Depth=1.65"Subcatchment 14S: DA (with expansion) Flow Length=1,605' Slope=0.0007 '/' Tc=85.3 min CN=97 Runoff=5.78 cfs 1.181 af Runoff Area=4.268 ac 78.77% Impervious Runoff Depth=1.39"Subcatchment 22S: Existing DA (including Flow Length=1,496' Slope=0.0006 '/' Tc=146.2 min CN=WQ Runoff=1.64 cfs 0.494 af Runoff Area=4.314 ac 63.95% Impervious Runoff Depth=1.13"Subcatchment 24S: Expanded Portion of Flow Length=636' Slope=0.0031 '/' Tc=39.9 min CN=WQ Runoff=3.07 cfs 0.408 af Peak Elev=274.07' Storage=0.232 af Inflow=1.64 cfs 0.494 afPond 3P: Existing Pond as Constructed Primary=1.31 cfs 0.494 af Secondary=0.00 cfs 0.000 af Outflow=1.31 cfs 0.494 af Peak Elev=275.73' Storage=23,178 cf Inflow=2.87 cfs 0.902 afPond 17P: Proposed gravel wetland 2-28-18 Primary=1.58 cfs 0.914 af Secondary=0.00 cfs 0.000 af Outflow=1.58 cfs 0.914 af Peak Elev=275.87' Storage=24,323 cf Inflow=5.78 cfs 1.181 afPond 18P: Proposed gravel wetland 2-28-18 Primary=4.37 cfs 1.193 af Secondary=0.00 cfs 0.000 af Outflow=4.37 cfs 1.193 af Inflow=3.13 cfs 0.902 afPond 21P: Node is just for combining flows - no storage Primary=3.13 cfs 0.902 af Total Runoff Area = 25.744 ac Runoff Volume = 2.986 af Average Runoff Depth = 1.39" 52.45% Pervious = 13.503 ac 47.55% Impervious = 12.241 ac NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 7HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Subcatchment 1S: DA (with expansion) Runoff = 2.87 cfs @ 13.88 hrs, Volume= 0.902 af, Depth= 1.26" Runoff by SCS TR-20 method, UH=SCS, Weighted-Q, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs NRCC 24-hr A 1-Year Rainfall=1.98" Area (ac) CN Description 1.735 39 >75% Grass cover, Good, HSG A 0.139 74 >75% Grass cover, Good, HSG C 3.871 98 Paved parking, HSG A 0.470 98 Paved parking, HSG C 0.587 61 >75% Grass cover, Good, HSG B 1.779 98 Paved parking, HSG B 8.581 Weighted Average 2.461 28.68% Pervious Area 6.120 71.32% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 154.2 1,605 0.0007 0.17 Lag/CN Method, Contour Length= 279' Interval= 1' Subcatchment 1S: DA (with expansion) Runoff Hydrograph Time (hours) 2702602502402302202102001901801701601501401301201101009080706050403020100Flow (cfs)3 2 1 0 NRCC 24-hr A 1-Year Rainfall=1.98" Runoff Area=8.581 ac Runoff Volume=0.902 af Runoff Depth=1.26" Flow Length=1,605' Slope=0.0007 '/' Tc=154.2 min CN=WQ 2.87 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 8HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Subcatchment 14S: DA (with expansion) WQv only (modified CN) Runoff = 5.78 cfs @ 13.08 hrs, Volume= 1.181 af, Depth= 1.65" Runoff by SCS TR-20 method, UH=SCS, Weighted-Q, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs NRCC 24-hr A 1-Year Rainfall=1.98" Area (ac) CN Description * 8.581 97 Modified CN 8.581 100.00% Pervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 85.3 1,605 0.0007 0.31 Lag/CN Method, Contour Length= 279' Interval= 1' Subcatchment 14S: DA (with expansion) WQv only (modified CN) Runoff Hydrograph Time (hours) 2702602502402302202102001901801701601501401301201101009080706050403020100Flow (cfs)6 5 4 3 2 1 0 NRCC 24-hr A 1-Year Rainfall=1.98" Runoff Area=8.581 ac Runoff Volume=1.181 af Runoff Depth=1.65" Flow Length=1,605' Slope=0.0007 '/' Tc=85.3 min CN=97 5.78 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 9HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Subcatchment 22S: Existing DA (including new area identified by SB) Runoff = 1.64 cfs @ 13.81 hrs, Volume= 0.494 af, Depth= 1.39" Runoff by SCS TR-20 method, UH=SCS, Weighted-Q, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs NRCC 24-hr A 1-Year Rainfall=1.98" Area (ac) CN Description 0.807 39 >75% Grass cover, Good, HSG A 0.099 74 >75% Grass cover, Good, HSG C 2.892 98 Paved parking, HSG A 0.470 98 Paved parking, HSG C 4.268 Weighted Average 0.906 21.23% Pervious Area 3.362 78.77% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 146.2 1,496 0.0006 0.17 Lag/CN Method, Contour Length= 112' Interval= 1' Subcatchment 22S: Existing DA (including new area identified by SB) Runoff Hydrograph Time (hours) 2702602502402302202102001901801701601501401301201101009080706050403020100Flow (cfs)1 0 NRCC 24-hr A 1-Year Rainfall=1.98" Runoff Area=4.268 ac Runoff Volume=0.494 af Runoff Depth=1.39" Flow Length=1,496' Slope=0.0006 '/' Tc=146.2 min CN=WQ 1.64 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 10HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Subcatchment 24S: Expanded Portion of DA Only Runoff = 3.07 cfs @ 12.54 hrs, Volume= 0.408 af, Depth= 1.13" Runoff by SCS TR-20 method, UH=SCS, Weighted-Q, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs NRCC 24-hr A 1-Year Rainfall=1.98" Area (ac) CN Description 0.927 39 >75% Grass cover, Good, HSG A 0.980 98 Paved parking, HSG A 1.779 98 Paved parking, HSG B 0.587 61 >75% Grass cover, Good, HSG B 0.041 74 >75% Grass cover, Good, HSG C 4.314 Weighted Average 1.555 36.05% Pervious Area 2.759 63.95% Impervious Area Tc Length Slope Velocity Capacity Description (min) (feet) (ft/ft) (ft/sec) (cfs) 39.9 636 0.0031 0.27 Lag/CN Method, Contour Length= 579' Interval= 1' Subcatchment 24S: Expanded Portion of DA Only Runoff Hydrograph Time (hours) 2702602502402302202102001901801701601501401301201101009080706050403020100Flow (cfs)3 2 1 0 NRCC 24-hr A 1-Year Rainfall=1.98" Runoff Area=4.314 ac Runoff Volume=0.408 af Runoff Depth=1.13" Flow Length=636' Slope=0.0031 '/' Tc=39.9 min CN=WQ 3.07 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 11HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Pond 3P: Existing Pond as Constructed Inflow Area = 4.268 ac, 78.77% Impervious, Inflow Depth = 1.39" for 1-Year event Inflow = 1.64 cfs @ 13.81 hrs, Volume= 0.494 af Outflow = 1.31 cfs @ 14.60 hrs, Volume= 0.494 af, Atten= 20%, Lag= 47.0 min Primary = 1.31 cfs @ 14.60 hrs, Volume= 0.494 af Secondary = 0.00 cfs @ 0.00 hrs, Volume= 0.000 af Routing by Stor-Ind method, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs Starting Elev= 270.57' Surf.Area= 0.038 ac Storage= 0.009 af Peak Elev= 274.07' @ 14.60 hrs Surf.Area= 0.084 ac Storage= 0.232 af (0.223 af above start) Plug-Flow detention time= 686.5 min calculated for 0.486 af (98% of inflow) Center-of-Mass det. time= 657.2 min ( 1,553.5 - 896.3 ) Volume Invert Avail.Storage Storage Description #1 270.34' 0.504 af Custom Stage Data (Conic) Listed below Elevation Surf.Area Inc.Store Cum.Store Wet.Area (feet) (acres) (acre-feet) (acre-feet) (acres) 270.34 0.036 0.000 0.000 0.036 270.67 0.039 0.012 0.012 0.039 270.99 0.043 0.013 0.025 0.043 271.32 0.046 0.015 0.040 0.047 271.65 0.050 0.016 0.056 0.051 271.98 0.054 0.017 0.073 0.055 272.31 0.059 0.019 0.092 0.060 272.63 0.064 0.020 0.111 0.065 272.96 0.068 0.022 0.133 0.070 273.29 0.075 0.024 0.157 0.077 276.90 0.119 0.347 0.504 0.125 Device Routing Invert Outlet Devices #1 Primary 270.32'15.0" Round Culvert L= 150.0' CMP, projecting, no headwall, Ke= 0.900 Inlet / Outlet Invert= 270.32' / 269.00' S= 0.0088 '/' Cc= 0.900 n= 0.010 PVC, smooth interior, Flow Area= 1.23 sf #2 Device 1 270.57'1.5" Vert. Orifice/Grate C= 0.600 #3 Device 1 273.90'64.0" W x 3.5" H Vert. Orifice/Grate C= 0.600 #4 Device 1 274.90'26.0" Horiz. Orifice/Grate C= 0.600 Limited to weir flow at low heads #5 Secondary 274.90'Custom Weir/Orifice, Cv= 2.62 (C= 3.28) Head (feet) 0.00 2.00 Width (feet) 4.00 20.00 NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 12HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Primary OutFlow Max=1.30 cfs @ 14.60 hrs HW=274.07' (Free Discharge) 1=Culvert (Passes 1.30 cfs of 8.25 cfs potential flow) 2=Orifice/Grate (Orifice Controls 0.11 cfs @ 8.93 fps) 3=Orifice/Grate (Orifice Controls 1.19 cfs @ 1.32 fps) 4=Orifice/Grate ( Controls 0.00 cfs) Secondary OutFlow Max=0.00 cfs @ 0.00 hrs HW=270.57' (Free Discharge) 5=Custom Weir/Orifice ( Controls 0.00 cfs) Pond 3P: Existing Pond as Constructed Inflow Outflow Primary Secondary Hydrograph Time (hours) 260240220200180160140120100806040200Flow (cfs)1 0 Inflow Area=4.268 ac Peak Elev=274.07' Storage=0.232 af 1.64 cfs 1.31 cfs 1.31 cfs 0.00 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 13HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Pond 17P: Proposed gravel wetland 2-28-18 Inflow Area = 8.581 ac, 71.32% Impervious, Inflow Depth = 1.26" for 1-Year event Inflow = 2.87 cfs @ 13.88 hrs, Volume= 0.902 af Outflow = 1.58 cfs @ 15.33 hrs, Volume= 0.914 af, Atten= 45%, Lag= 87.3 min Primary = 1.58 cfs @ 15.33 hrs, Volume= 0.914 af Secondary = 0.00 cfs @ 0.00 hrs, Volume= 0.000 af Routing by Stor-Ind method, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs Starting Elev= 271.50' Surf.Area= 4,176 sf Storage= 909 cf Peak Elev= 275.73' @ 15.33 hrs Surf.Area= 11,784 sf Storage= 23,178 cf (22,268 cf above start) Plug-Flow detention time= 1,488.8 min calculated for 0.893 af (99% of inflow) Center-of-Mass det. time= 1,433.5 min ( 2,338.2 - 904.6 ) Volume Invert Avail.Storage Storage Description #1 269.00' 2,024 cf forebay (Prismatic) Listed below (Recalc) #2 271.50' 3,523 cf cell 1 (Prismatic) Listed below (Recalc) #3 274.00' 15,151 cf cell 1 + forebay (Prismatic) Listed below (Recalc) #4 271.50' 14,077 cf cell 2 (Prismatic) Listed below (Recalc) 34,775 cf Total Available Storage Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 269.00 108 0 0 270.00 241 175 175 271.00 600 421 595 273.00 829 1,429 2,024 Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 271.50 2,052 0 0 272.00 2,260 1,078 1,078 273.00 2,630 2,445 3,523 Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 274.00 4,110 0 0 275.00 4,724 4,417 4,417 276.00 5,372 5,048 9,465 277.00 6,000 5,686 15,151 Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 271.50 1,467 0 0 272.00 1,652 780 780 273.00 2,014 1,833 2,613 274.00 2,401 2,208 4,820 275.00 2,811 2,606 7,426 276.00 3,245 3,028 10,454 277.00 4,000 3,623 14,077 NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 14HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Device Routing Invert Outlet Devices #1 Primary 270.60'1.4" Vert. Orifice/Grate C= 0.600 #2 Primary 275.60'36.0" Horiz. Orifice/Grate C= 0.600 Limited to weir flow at low heads #3 Secondary 275.90'6.0' long x 10.0' breadth Broad-Crested Rectangular Weir Head (feet) 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60 Coef. (English) 2.49 2.56 2.70 2.69 2.68 2.69 2.67 2.64 Primary OutFlow Max=1.56 cfs @ 15.33 hrs HW=275.73' (Free Discharge) 1=Orifice/Grate (Orifice Controls 0.12 cfs @ 10.84 fps) 2=Orifice/Grate (Weir Controls 1.44 cfs @ 1.18 fps) Secondary OutFlow Max=0.00 cfs @ 0.00 hrs HW=271.50' (Free Discharge) 3=Broad-Crested Rectangular Weir ( Controls 0.00 cfs) Pond 17P: Proposed gravel wetland 2-28-18 Inflow Outflow Primary Secondary Hydrograph Time (hours) 260240220200180160140120100806040200Flow (cfs)3 2 1 0 Inflow Area=8.581 ac Peak Elev=275.73' Storage=23,178 cf 2.87 cfs 1.58 cfs 1.58 cfs 0.00 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 15HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Pond 18P: Proposed gravel wetland 2-28-18 Inflow Area = 8.581 ac, 0.00% Impervious, Inflow Depth = 1.65" for 1-Year event Inflow = 5.78 cfs @ 13.08 hrs, Volume= 1.181 af Outflow = 4.37 cfs @ 13.60 hrs, Volume= 1.193 af, Atten= 24%, Lag= 31.2 min Primary = 4.37 cfs @ 13.60 hrs, Volume= 1.193 af Secondary = 0.00 cfs @ 0.00 hrs, Volume= 0.000 af Routing by Stor-Ind method, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs Starting Elev= 271.50' Surf.Area= 4,176 sf Storage= 909 cf Peak Elev= 275.87' @ 13.60 hrs Surf.Area= 11,931 sf Storage= 24,323 cf (23,414 cf above start) Plug-Flow detention time= 1,142.0 min calculated for 1.172 af (99% of inflow) Center-of-Mass det. time= 1,107.0 min ( 1,956.3 - 849.2 ) Volume Invert Avail.Storage Storage Description #1 269.00' 2,024 cf forebay (Prismatic) Listed below (Recalc) #2 271.50' 3,523 cf cell 1 (Prismatic) Listed below (Recalc) #3 274.00' 15,151 cf cell 1 + forebay (Prismatic) Listed below (Recalc) #4 271.50' 14,077 cf cell 2 (Prismatic) Listed below (Recalc) 34,775 cf Total Available Storage Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 269.00 108 0 0 270.00 241 175 175 271.00 600 421 595 273.00 829 1,429 2,024 Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 271.50 2,052 0 0 272.00 2,260 1,078 1,078 273.00 2,630 2,445 3,523 Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 274.00 4,110 0 0 275.00 4,724 4,417 4,417 276.00 5,372 5,048 9,465 277.00 6,000 5,686 15,151 Elevation Surf.Area Inc.Store Cum.Store (feet) (sq-ft) (cubic-feet) (cubic-feet) 271.50 1,467 0 0 272.00 1,652 780 780 273.00 2,014 1,833 2,613 274.00 2,401 2,208 4,820 275.00 2,811 2,606 7,426 276.00 3,245 3,028 10,454 277.00 4,000 3,623 14,077 NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 16HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Device Routing Invert Outlet Devices #1 Primary 270.60'1.4" Vert. Orifice/Grate C= 0.600 #2 Primary 275.60'36.0" Horiz. Orifice/Grate C= 0.600 Limited to weir flow at low heads #3 Secondary 275.90'6.0' long x 10.0' breadth Broad-Crested Rectangular Weir Head (feet) 0.20 0.40 0.60 0.80 1.00 1.20 1.40 1.60 Coef. (English) 2.49 2.56 2.70 2.69 2.68 2.69 2.67 2.64 Primary OutFlow Max=4.35 cfs @ 13.60 hrs HW=275.87' (Free Discharge) 1=Orifice/Grate (Orifice Controls 0.12 cfs @ 10.99 fps) 2=Orifice/Grate (Weir Controls 4.23 cfs @ 1.69 fps) Secondary OutFlow Max=0.00 cfs @ 0.00 hrs HW=271.50' (Free Discharge) 3=Broad-Crested Rectangular Weir ( Controls 0.00 cfs) Pond 18P: Proposed gravel wetland 2-28-18 Inflow Outflow Primary Secondary Hydrograph Time (hours) 260240220200180160140120100806040200Flow (cfs)6 5 4 3 2 1 0 Inflow Area=8.581 ac Peak Elev=275.87' Storage=24,323 cf 5.78 cfs 4.37 cfs 4.37 cfs 0.00 cfs NRCC 24-hr A 1-Year Rainfall=1.98"Kennedy Pond 3 Updated 4 4 18 - Design Update - Ex Printed 12/18/2018Prepared by Microsoft Page 17HydroCAD® 10.00-14 s/n 04887 © 2015 HydroCAD Software Solutions LLC Summary for Pond 21P: Node is just for combining flows - no storage [40] Hint: Not Described (Outflow=Inflow) Inflow Area = 8.582 ac, 71.32% Impervious, Inflow Depth = 1.26" for 1-Year event Inflow = 3.13 cfs @ 12.54 hrs, Volume= 0.902 af Primary = 3.13 cfs @ 12.54 hrs, Volume= 0.902 af, Atten= 0%, Lag= 0.0 min Routing by Stor-Ind method, Time Span= 0.00-275.00 hrs, dt= 0.01 hrs Pond 21P: Node is just for combining flows - no storage Inflow Primary Hydrograph Time (hours) 2702602502402302202102001901801701601501401301201101009080706050403020100Flow (cfs)3 2 1 0 Inflow Area=8.582 ac 3.13 cfs 3.13 cfs Kennedy Drive Stormwater Ponds Improvement Project Engineer's Opinion of Probable Project Cost POND 3 12/10/2018 201.11 Clearing and Grubbing, Including Individual Trees and Stumps 0.22 ACRE $60,000 $13,200 203.15 Common Excavation 1,300 CY $30 $39,000 203.20 Muck Excavation 530 CY $30 $16,000 203.30 Earth Borrow Fill (allowance)360 CY $30 $10,800 204.20 Trench Excavation of Earth 320 CY $30 $9,600 301.15 Subbase of Gravel (pipe bedding)50 CY $35 $1,800 301.25 Subbase of Crushed Gravel, Coarse Graded (drive) 70 CY $45 $3,200 541.25 Class B Concrete (for concrete footers) 1.3 CY $500 $700 613.10 Stone Fill, Type I (Hydraulic Inlet and Collars) 5 CY $50 $300 622.10 Insulation Board 0.98 MFBM $1,200 $1,200 649.31 Geotextile Under Stone Fill, Type II 160 SY $4 $700 649.41 Geotextile Under Underdrain (under gravel layer) 560 SY $4 $2,300 649.515 Geotextile for Silt Fence, Woven Wire Reinforced 170 SY $10 $1,700 651.15 Seed (Outside Wetland)22 LB $50 $1,100 651.29 Straw mulch 0.9 TON $500 $500 651.35 Topsoil (4" topsoil on side slopes and outside wetland) 252 CY $40 $10,100 652.10 Erosion Protection & Sediment Control Plan 1 LS $5,000 $5,000 652.30 Maintenance of EPSC Plan (N.A.B.I.) 1 LU $2,000 $2,000 653.20 Temporary Erosion Matting 650 SY $2 $1,300 653.35 Vehicle Tracking Pad 60 CY $50 $3,000 653.42 Filter Bag 2 EACH $500 $1,000 653.50 Barrier Fence - temporary construction 100 LF $25 $2,500 656.20 Evergreen Trees (White Pine, B&B, 2-2.5" Caliper) 9 EACH $175 $1,600 656.20 Evergreen Trees (Canandian, B&B, 2-2.5" Caliper) 10 EACH $175 $1,800 656.30 Deciduous Trees (Silver Maple, B&B, 2-2.5" Caliper) 2 EACH $250 $500 656.30 Deciduous Trees (Red Maple, B&B, 2-2.5" Caliper) 5 EACH $250 $1,300 656.35 Deciduous Shrubs (Redosier Dogwood) 100 EACH $75 $7,500 656.80 Lanscaping Backfill, Truck Measurement 70 CY $60 $4,200 900.608 Wetland Soil 4 140 CY $50 $7,000 900.608 3/4" gravel (26" thick in cell 1, 24" thick in cell 2) 280 CY $35 $9,800 900.608 Pea Stone - Choker Layer - 3/8" stone (3") 40 CY $50 $2,000 900.61 9" Stone Fill, (swale and spillways)90 CY $65 $5,900 900.620 24" HDPE Risers 4 EACH $2,500 $10,000 900.620 Flared End Section 2 EACH $300 $600 900.620 Seepage Collars 7 EACH $300 $2,100 900.620 Catch Basin - 4' Diameter 2 EACH $5,000 $10,000 900.620 Beehive Grate 1 EACH $1,500 $1,500 900.620 Removable Trash Rack 1 EACH $1,500 $1,500 900.640 24" HDPE Pipe 110 LF $65 $7,200 900.640 8" HDPE Perforated Pipe 80 LF $35 $2,800 900.640 8" HDPE Pipe 62 LF $30 $1,900 900.640 Magnetic Locating Tape 100 LF $2 $200 900.645 Wetland Seed - Marsh/Swamp/Bog Mix 8 LB $100 $800 900.645 Wetland Seed - Detention Basin Mix 5 LB $100 $500 900.690 Dewatering 1 LS $20,000 $20,000 Subtotal 1 $227,700 635.11 Mobilization/Demobilization (5%)$11,400 900.645 Bonds & Insurance (2%)$4,600 Subtotal $243,700 Construction Contigency (14%)$33,300 $277,000 Total Cost Construction Construction Subtotal VTrans Pay Item # Item Description Total Quantity Unit Unit Price Kennedy Drive Stormwater Ponds Improvement Project Engineer's Opinion of Probable Project Cost POND 3 12/10/2018 Total Cost Construction VTrans Pay Item # Item Description Total Quantity Unit Unit Price Kennedy Drive Ponds Retrofit Study (1/6 of total) 1 LS $5,050 $5,050 Soil Borings and Testing 1 LS $8,400 $8,400 Wetland Delineation (1/3 of total)1 LS $400 $400 Survey (1/4 of total)1 LS $2,810 $2,810 Final Design Engineering (1/3 of total) 1 LS $16,833 $16,833 Permitting 1 LS $5,000 $5,000 $38,493 Bid and Construction Phase Engineering 2 $38,000 $38,000 Administrative 1 LS $3,000 $3,000 Easement Assistance 1 LS $0 $0 Legal 1 LS $3,000 $3,000 $6,000 $359,493 $360,000 Acreage of Contributing Watershed Treated 7.12 Retrofit Cost per Acre Treated $50,562 Notes: 1.) Construction cost quantities include Contractor's 15% Overhead and Profit. 3.) Project costs are in 2018 dollars (ENR Construction Cost Index for February 2018 = 10889.17. 4.) Assumes that hydric soils onsite can be reused for gravel wetland soil. Cost is to stockpile, test, and place. USE 2.)Bid and construction phase engineering is calculated as per the State of Vermont Pacilities Engineering Division Engineering Fee Allowance Guidance Document, effective September 1, 2011. Actual bid and construction services cost may vary based on final arrangement of bid package and Owner's construction services to be provided. Bid and Construction Phase Engineering Bid and Construction Phase Engineering Subtotal Other Costs Other Costs Subtotal TOTAL PROJECT COSTS Engineering Engineering Subtotal i Stormwater Best Management Practices (BMP) Performance Analysis Revised Document: March 2010 (Original Document: December 2008) Prepared for: United States Environmental Protection Agency – Region 1 5 Post Office Square, Suite 100 Boston, MA 02109 Prepared by: Tetra Tech, Inc. 10306 Eaton Place, Suite 340 Fairfax, VA 22030 BMP Performance Curve: Infiltration Basin 153 BMP Performance Curve: Gravel Wetland Prepared for: United States Environmental Protection Agency – Region 1 One Congress Street, Suite 1100 Boston, MA 02114 Prepared by: Tetra Tech, Inc. 10306 Eaton Place, Suite 340 Fairfax, VA 22030 September 2008 154 BMP Performance Table BMP Name: Gravel Wetland Depth of Runoff Treated (inches) Land Use Pollutant 0.1 0.2 0.4 0.6 0.8 1.0 1.5 2.0TSS 48% 61% 82% 91% 95% 97% 99% 99%TP 19% 26% 41% 51% 57% 61% 65% 66%Commercial Zn 57% 68% 83% 88% 90% 90% 91% 92%TSS 47% 61% 82% 91% 96% 97% 99% 99%TP 19% 27% 42% 51% 58% 61% 65% 66%Industrial Zn 40% 54% 74% 84% 88% 90% 90% 91%TSS 47% 62% 82% 92% 96% 98% 99% 99%TP 19% 26% 41% 51% 57% 61% 65% 66%High-Density Residential Zn 46% 59% 78% 86% 89% 90% 91% 91%TSS 53% 68% 86% 94% 97% 98% 99% 99%TP 20% 27% 42% 51% 57% 61% 65% 66%Medium-Density Residential Zn 21% 32% 52% 67% 76% 82% 89% 91%TSS 51% 65% 83% 92% 96% 97% 99% 99%TP 21% 28% 42% 51% 57% 61% 64% 66%Low-Density Residential Zn 16% 26% 46% 61% 71% 78% 87% 90% Annual Pollutant Loading Rates Pollutant load (lbs/acre-year) Land use TSS TP Zn Commercial 1117.77 1.66 2.33 Industrial 745.22 1.43 0.45 High-Density Residential 465.08 1.10 0.79 Medium-Density Residential 274.63 0.55 0.11 Low-Density Residential 72.11 0.042 0.043 174 BMP Performance Curve: Wet Pond Prepared for: United States Environmental Protection Agency – Region 1 One Congress Street, Suite 1100 Boston, MA 02114 Prepared by Tetra Tech, Inc. 10306 Eaton Place, Suite 340 Fairfax, VA 22030 September 2008 BMP Performance Curve: Wet Pond 175 BMP Performance Table BMP Name: Wet Pond Depth of Runoff Treated (inches) Land Use Pollutant 0.1 0.2 0.4 0.6 0.8 1.0 1.5 2.0TSS 30% 44% 60% 68% 74% 77% 83% 86%TP 2% 4% 8% 11% 15% 18% 24% 30%Commercial Zn 59% 71% 80% 85% 87% 89% 92% 93%TSS 30% 45% 60% 69% 74% 78% 83% 87%TP 2% 4% 8% 11% 15% 18% 24% 30%Industrial Zn 50% 64% 77% 82% 86% 88% 91% 93%TSS 30% 44% 60% 69% 74% 78% 83% 87%TP 2% 4% 8% 11% 15% 18% 24% 30%High-Density Residential Zn 53% 71% 78% 83% 86% 88% 91% 93%TSS 34% 48% 62% 70% 75% 78% 84% 87%TP 2% 4% 8% 11% 14% 17% 24% 30%Medium-Density Residential Zn 33% 49% 65% 73% 78% 82% 87% 90%TSS 33% 47% 61% 69% 74% 78% 83% 86%TP 2% 4% 8% 11% 14% 17% 24% 30%Low-Density Residential Zn 28% 43% 60% 69% 75% 79% 85% 89%Annual Pollutant Loading Rates Pollutant load (lbs/acre-year) Land use TSS TP Zn Commercial 1117.77 1.66 2.33 Industrial 745.22 1.43 0.45 High-Density Residential 465.08 1.10 0.79 Medium-Density Residential 274.63 0.55 0.11 Low-Density Residential 72.11 0.042 0.043 Kennedy Drive Pond 3South Burlington, VermontSimple Method for Pollutant LoadingsSimple Method - Phosphorous LoadingNo STP Existing Detention Pond Existing UntreatedProposed Upgraded Gravel WetlandPhosphorous Reduction (lbs/yr)Annual Load = (0.226 (P * Pj * Rv) * C * A) * T 16.377.327.446.388.38Where:0.226 =Simple Method CoefficientP =Yearly rainfall depth (inches)Pj =Fraction of rainfall events producing runoff (0.90)Rv =0.05 + 0.009 * (% site imperviousness (Ia)) 0.690.760.630.69C =Flow weighted mean concentration of pollutant (mg/L)A =Area of contributing watershed (acres)8.584.274.318.58T= Treatment Removal Rate (%)1,20 0.18 0 0.61Ia=Impervious Area (acres)6.123.362.766.12P =33.9National Climate Data CenterPj =0.9Coefficient = 0.226Table 1: Pollutant Concentration Values ( C )TSS TP NO3 Cu Zn(mg/L) (mg/L) (mg/L) (mg/L) (mg/L)Cropland 145 0.56 4.06 0.0015 0.016Forest 51 0.11 0.80 0 0Industrial 149 0.32 1.89 0.058 0.671Meadow 51 0.80 0.11 0 0Open 51 0.80 0.11 0 070 0.55 1.83 0.047 0.176142 0.40 0.76 0.054 0.3291. EPA BMP Performance Curve: Gravel Wetland, Land Use: Commercial http://www.deq.virginia.gov/Portals/0/DEQ/Water/Guidance/152005.pdfTransportationSources:https://www3.epa.gov/region1/npdes/stormwater/assets/pdfs/BMP-Performance-Analysis-Report.pdf2. Recommendations of the Expert Panel to Define Removal Rates for Urban Stormwater Retrofit Projects https://www.chesapeakebay.net/documents/Final_CBP_Approved_Expert_Panel_Report_on_Stormwater_Retrofits--_long.pdf3. Chesapeake Bay TMDL Special Condition Guidance, Appendix V.D - BMP Enhancement, Conversion, and Restoration (05/18/2015)December 18, 2018LandUseResidential 1 Dave Wheeler From:Bergeron, Roger <Roger.Bergeron@vermont.gov> Sent:Wednesday, December 12, 2018 7:33 AM To:Claudon, Lynnette; Dipietro-Worden, Kirstin A. Cc:Reilly, John D.; Dave Wheeler; Tom Dipietro Subject:RE: Kennedy Drive SW Pond 3 Improvements - Final Submission of Plans and Specifications for Bid Approval Kirstin: All set with me also. Roger Bergeron Chief Construction Engineer Phone: 802-760-8135 E-mail: roger.bergeron@vermont.gov Department of Environmental Conservation FACILITIES ENGINEERING DIVISION National Life Building MAIN 1 1 National Life Drive Montpelier, VT 05620-3510 Construction website: http://dec.vermont.gov/facilities-engineering/water-financing/srf/srfstep3 “National Life Building requires a security access badge. Please make arrangements before visiting and allow extra time” Note: Emails to and from state employees, regarding state business, are public records. From: Claudon, Lynnette <Lynnette.Claudon@vermont.gov> Sent: Monday, December 10, 2018 12:36 PM To: Dipietro-Worden, Kirstin A. <kworden@hoyletanner.com>; Bergeron, Roger <Roger.Bergeron@vermont.gov> Cc: Reilly, John D. <jreilly@hoyletanner.com>; Dave Wheeler <dwheeler@sburl.com>; Tom Dipietro <tdipietro@sburl.com> Subject: RE: Kennedy Drive SW Pond 3 Improvements - Final Submission of Plans and Specifications for Bid Approval Kirstin, I got them. All set with me. ~Lynnette From: Dipietro-Worden, Kirstin A. <kworden@hoyletanner.com> Sent: Monday, December 10, 2018 12:27 PM To: Claudon, Lynnette <Lynnette.Claudon@vermont.gov>; Bergeron, Roger <Roger.Bergeron@vermont.gov> Cc: Reilly, John D. <jreilly@hoyletanner.com>; Dave Wheeler <dwheeler@sburl.com>; Tom Dipietro <tdipietro@sburl.com> Subject: Kennedy Drive SW Pond 3 Improvements - Final Submission of Plans and Specifications for Bid Approval 2 Lynnette and Roger, I have finished incorporating your review comments on the 100% submission. Attached please find the final design drawings and specifications for the Kennedy Drive Pond 3 project for approval to bid. Please let me know if you have any questions and confirm receipt of attachments. Thank you, Kirstin Kirstin DiPietro Worden, PE Associate Licensed in VT Responsive. Consistent. 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