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Home My WebLink AboutMS-18-07 - Supplemental - 0000 Kennedy Drive (5)CWSRF DRAFT EID 2017 Facilities Engineering Division Environmental Report and Environmental Information Document Project Name Kennedy Drive Stormwater Pond 3 Improvement Project Address Project Location Kennedy Drive, South Burlington, Vermont Drinking Water System Name NA WSID No. NA State Assigned Drinking Water Revolving Loan (DWSRF) Number RF3-_ NA ___ Wastewater and/or Stormwater System Name ___Kennedy Drive Pond 3 Stormwater Pond_ __________ List Existing Permit Numbers: Act 250 Land Use Permit #4C1122 and amendments; Stormwater Permit 1-1582c; Wetlands Conditional Use Determination #2001-282 State Assigned Clean Water Revolving Loan (CWSRF) Number ___ All Projects: USEPA Grant (STAG) Number ______________________________________________ Federal Fiscal Years (s) of USEPA Grant Appropriation I.) Please provide below a brief description of the project including the purpose and need as detailed in the Preliminary Engineering Report. Refer to the Addendum #3 to the Hadley Road Sanitary Sewer Service Area Preliminary Engineering Report, dated February 19, 2016 – Kennedy Drive Stormwater Pond #3 Improvement Sponsorship Project, dated July 2, 2018, prepared by Hoyle, Tanner & Associates, Inc, hereinafter referred to as the PER Addendum #3. The level of detail and the amount of information provid ed in this environmental report should be commensurate with the magnitude of construction activities and their potential impact on environmental and historical resources. If, for example, a project is likely to have no or very minimal effects, the project representative needs to formally request a Categorical Exclusion in Section V, make simple statements in EnvRep-103 EnvRep-103 EnvRep-103 EnvRep-103 CWSRF DRAFT EID 2017 the spaces provided in Section VI, and attach any additional information like a qualified consultant assessment or determination letters, permits from regulatory authorities, and mapping when available. Projects limited to the existing footprint of a building (e.g., a UV disinfection project) will not generally need to submit an environmental report at all (not applicable to USDA funding). A more involved and complex project will go through the same review checklist but there will need to be more analysis, explanation, and documentation provided before SRF staff can issue a Categorical Exclusion or a Finding of No Significant Impact (FNSI). Please note that if the project does not meet the Categorical Exclusion criteria mentioned in VII.d.1 of the DWSRF State Environmental Review Process and/or Section VIII of the SRF Environmental Review Procedures, the authorized project representative shall describe the consequences of a specific activity on a specific resource and establish and discuss any mitigation measure(s) necessary to avoid or minimize any adverse impacts to an environmental or historical resource (see Section VII of this report). Even though applicants are required to integrate and consider environmental and historical values during a proposed project’s planning and design, it is the responsibility of SRF review staff to independently evaluate and verify accuracy of information supplied in this environmental report. The SRF staff takes final responsibility for the scope and content of this environmental report. In order to expedite the application process and SRF review and approval of a proposed project, applicants are strongly encouraged to consult early and frequently with our staff to ensure that all environmental issues are described, evaluated, and impacts appropriately considered and mitigated. If a determination is made that an Environmental Assessment or an Environmental Impact Statement is required, the SRF staff will be responsible for initiating the preparation of this document internally or by a third party. Through a memorandum of understanding between United States Department of Agriculture -Rural Development and the Vermont Agency of Natural Resources, this environmental report format is acceptable to both funding agencies. However, please note that Categorical Exclusion eligibility, public comment, and public notice requirements may differ among the funding agencies. II.) Will the project expand capacity to serve more than 500 additional users or a 30% increase in the existing population, whichever is greater? YES NO Wastewater projects: Will the project increase hydraulic (flow) treatment capacity by more than 20%, or increase influent 5-day biochemical oxygen demand (BOD5) organic treatment capacity by more than 30%? YES NO Provide a capacity statement with a chart indicating the existing and proposed hydraulic and organic capacities and indicate the percent change. If there are differences in the permitted vs. physical capacities, include all capacity information. III.) All projects: Will the project take place in an area designated by the Environmental Protection Agency as a Sole Source Aquifer? YES NO IV.) Drinking water projects: Does the project call for a new withdrawal of groundwater or surface water? YES NO Wastewater or stormwater projects: Does the project include a new discharge to surface water or groundwater? YES NO V.) DRINKING WATER PROJECTS: Will the project result in a 30% increase in groundwater or surface water withdrawal at an existing site? YES NO VI.) Do you believe your project qualifies for a Categorical Exclusion in accordance with the Environmental Review Procedures for projects funded through the Vermont/EPA Drinking Water Revolving Loan Program and/or the Vermont/EPA Clean Water Revolving Loan Program, based on the following environmental information and documentation? YES NO CWSRF DRAFT EID 2017 If yes, please fill out only Section VII below. If no, you must fill out Sections VII and VIII for all affected environmental and historical considerations (essentially if you answer “yes” in Section VII you will need to follow-up with mitigation measures or an alternative action plan in Section VIII). VII.) Environmental and Archeological Checklist Considerations Yes or No *Basis for Determination and Documentation A.) Air Quality: Will there be any changes to air quality: emissions, noise, dust, odor, etc? Is an Air Pollution Control Permit required? Is your digester unequipped and operated without a flare? Other than the digester flare noted above, are there any other combustion devices at your facility, including but not limited to: stationary internal combustion engines such as diesel generators/ pumps, boilers or space heaters greater than 3 million BTU, or combustion turbines and/or boilers? Note: Emergency generators/pumps are only subject to limited requirements provided they are used strictly for emergency purposes (includes limited emergency demand response programs) and do not participate in peak shaving programs. No The project includes the retrofit of an existing stormwater treatment pond to a gravel wetland. No changes in air quality are anticipated. B.) Water Quality and Quantity: Will there be negative direct impacts to water quality or quantity? No Completion of this project will treat the Channel Protection Volume (CPv) and Water Quality Volume (WQv) targets, and reduce the peak flow of the 1-yr storm event by 49.5%. There will be a positive environmental benefit of better phosphorous, nitrogen, heavy metals, and bacteria removal with the gravel wetland compared to the existing Pond 3 stormwater detention pond. The project will also treat stormwater runoff from a larger contributing area. C.) Wetlands/Water Resources: Will there be construction in Class II or III wetlands? No There will be no construction in the adjacent delineated wetland. Existing Pond 3 is partially located within the 50’ buffer of a Class II wetland situated to the west. Construction of the proposed Pond 3 improvement will have impacts to the 50’ wetland buffer. Retrofit of Pond 3 to a gravel wetland is considered an allowed use of an existing structure (AU 6.12) and is anticipated to impact approximately 221 sf of the existing wetland buffer that is outside of the existing Pond 3 footprint. Refer to Wetland Office Email dated 5/1/18 in Attachment A. CWSRF DRAFT EID 2017 D.) Floodplains, Floodways and Fluvial Erosion Hazard Zones (Flood Hazard Areas): Will the project involve construction in a 500 or 100-year floodplain, floodway or fluvial erosion hazard zone, or impact floodplain development? No. The proposed project is located outside of the FEMA mapped floodplain. Refer to Floodplain River Corridor Office Email dated 5/4/18 in Attachment B. E.) Stream Alterations: Will the project involve construction in a stream? No F.) Stream Crossings: Will the project involve directional drilling under a stream and/or an aerial crossing over a stream? No G.) Dam Safety: Does the project involves impoundment of more than 500,000 CF of water? No H.) Endangered Species: Is the project likely to adversely affect an endangered or threatened species? No The project is the retrofit of an existing located stormwater treatment pond. The project area is located in existing disturbed area and paved municipal roadway land uses. I.) Historic Preservation: Will the project adversely affect cultural resources such as archeological or historic sites and/or National Landmark? No The existing Pond 3 site was previously disturbed for the original pond construction. The Act 250 Land Use Permit #4C1122 that covers the existing Pond 3 construction indicated that a consulting historian reviewed the project and determined there were no resources on or eligible for the National Register of Historic Places. Consulting archeologists conducted a Phase I field survey of the area of sensitivity for archeological resources, and found no resources of importance. The project was cleared for historic resources with a “No Historic Properties Affected” determination on December 21, 2001. See Attachment C. J.) Wild and Scenic Recreational Rivers: Is the project within a quarter-mile of a river on the National Park Service’s Nationwide Rivers Inventory? Will the project impact a wild, scenic or recreational river area and create conditions inconsistent with the character of the river? No CWSRF DRAFT EID 2017 K.) Public Lands: Will the project adversely impact formally-classified local, state, and federal lands (e.g., parks, natural areas, wildlife management areas, and wilderness areas)? No The project is the retrofit of an existing located stormwater treatment pond. The project area is located in existing disturbed area and paved municipal roadway land uses. L.) Farmland: Will the project convert Agricultural Soils to non-agricultural uses? No There are no agricultural soils located at the project site. M.) NEPA: Is there a controversy with respect to environmental effects of the project based on reasonable and substantial issues? No N.) NEPA: Is the project significantly greater in scope than normal projects for the area? No O.) NEPA: Does the project have significant unusual characteristics? No P.) NEPA: Does the project establish a precedent for future action or represent a decision in principle about future actions with potentially significant environmental effects (cumulative impact based on current information)? No Q.) NEPA: Does the project have significant adverse direct or indirect effects on parkland, other public lands, or areas of recognized scenic or recreational value? No R.) Population: Will the project provide new drinking water facilities to serve populations of over 2000 persons, and/or wastewater or stormwater facilities in communities of over 10,000 persons? No S.) Socio-economics: Is the project known or expected to have a significant negative effect on the quality of the human environment? Is there potential for significant changes to the socio- economic make-up of the area? Is the project cost-effective? No, No, Yes The project is not expected to have a significant negative effect on the quality of the human environment. There is no potential for significant changes to the socio-economic make-up of the area. The project is cost- effective. CWSRF DRAFT EID 2017 T.) Land Use: Is additional Land Use and Development Act (Act 250) review and approval necessary? Yes A permit amendment is required as the proposed project is a material change to the existing pond. The Land Use Permit Amendment #4C1122-1 application was filed with the District #4 Environmental Commission on 5-18-18 and a decision is currently pending. U.) Growth: Does the project contribute to growth outside of designated growth centers? No V.) Cumulative Impacts: Will the project cause other significant environmental impacts, including secondary impacts? No The completed project will treat the contributing Channel Protection Volume (CPv) and Water Quality Volume (WQv), and will reduce the peak flow of the 1-yr storm event by 49.5%. In addition, there will be a positive environmental benefit of better phosphorous, nitrogen, heavy metals, and bacteria removal with the gravel wetland compared to the existing Pond 3 stormwater detention pond. VIII.) Mitigation Measures and/or Alternative Plans of Action (if applicable, in order to minimize adverse effects). Explain how mitigation measures will be achieved and monitored (Special Grant Condition or review of Plans and Specifications). Remember to consider structural and non -structural methods. Affected Environmental or Archeological Resources Mitigation Measures or Alternative Plan of Action A.) Wetlands The proposed project will be constructed completely outside of the mapped Class II wetland. Construction impacts within the 50’ buffer will be minimized through implementation of an Erosion Prevention and Sediment Control Plan by the Contractor, and conformance with the requirements of DEC’s Low Risk Site Handbook for Erosion Prevention and Sediment Control. Kirstin DiPietro Worden, P.E. July 2, 2018 Environmental Engineer Prepared By Date Title i Reviewed By Date Auth6rized Representative *Basis for Determination and Documentation The basis for determination and documentation information must be traceable and establish the factual data to support the response to each question. Any environmental concerns that are raised by federal, state, or local agencies or the public must be addressed as completely as possible and resolved before the environmental report will be considered complete. All supporting documentation (e.g., correspondence and exhibits) should be attached and easily cross-referenced back into the main body of the environmental report. Types of information to be included in this column are outlined below. 1. FIELD OBSERVATION: A site visit that does not usually involve any testing or measurements. FIELD OBSERVATION is an important method for Initial screening of the issues, but for some of the categories it may be inadequate for final evaluation. Support documentation should include date of the site visit and by whom. 2. PERSONAL CONTACT: Personal contacts are useful when the individual contacted is an accepted authority on the subject(s) and the interview is documented. Supporting documentation should include the name, organization, and title of the person contacted and the date of the conversation. Copies of mitten site inspection reports and determinations by regulaloryauthonties on applicabilityof regulations and permitrequlmments should be attached. 3. PRINTED MATERIALS: These are useful sources of detailed information, materials such as comprehensive land use plans, maps, statistical surveys, and studies. Information must be current, i.e., not so old that changing conditions make them irrelevant and must represent accepted methodologies. Citations for the material should include enough information so that an outside reviewer can locate the specific reference. 4. SPECIAL STUDY: This is a study conducted for an individual factor or resource, and should be performed by a qualified person using accepted methodologies. Some tests are relatively simple to perform but others may require elaborate equipment or personnel with additional expertise. The preparer is responsible for obtaining assistance from others In order to have the appropriate test or studies conducted. Copy of the study must be appended or referenced as for Printed Materials. S. CONTRIBUTOR EXPERIENCE: The professional judgment of the persons contributing to this environmental report can be useful provided their expertise is relevant. The contributor may have previous knowledge from familiarity with the area, or may have professional background to make judgments about a specific factor. Provide information of the person's qualification in addition to name, organization and position. C W SRF DRAFT EID 2017 1 Dave Wheeler From:Dipietro-Worden, Kirstin A. <kworden@hoyletanner.com> Sent:Tuesday, May 01, 2018 10:14 AM To:Dave Wheeler Cc:Schramm, Mike Subject:FW: Kennedy Drive - Wetland Buffer and definition of existing footprint Dave, I heard back from Tina yesterday. Scroll down to see her response in red…it looks like she agrees with my interpretation of buffer impact, which means we are under the 250 sf threshold and modifications are considered an Allowed Use and no wetlands permit is required. Kirstin From: Heath, Tina [mailto:Tina.Heath@vermont.gov] Sent: Monday, April 30, 2018 12:40 PM To: Dipietro-Worden, Kirstin A. <kworden@hoyletanner.com> Subject: RE: Kennedy Drive - Wetland Buffer and definition of existing footprint Hi Kirstin, Sorry for not getting back to you right away, I’ve been buried between vacation and the start of the field season. The existing footprint means the manipulated areas that were built for the treatment system- this would be the pond itself, berms, swales, access road, etc. If any filling, grading or clearing is proposed outside of the footprint and over the 250 sf threshold then it would need a permit. So if additional grading needs to be done, new rip rap installed at the ends of pipes, etc.- these types of expansions would cumulatively need to stay under the 250 sf threshold. The Wetland Program has a new GP (3-9026) currently on public notice that is specific to certain water quality improvement projects, such as stormwater retrofitting. We are anticipating many comments that will need to be addressed before the permit is finalized. I would advise that any retrofit projects being currently designed to continue under the current Program permit impact thresholds until the permit is finalized. You can check on the status of the general permit 3-9026 when you are ready to submit a permit application. The non-substantial expansion or modification of an existing structure (AU 6.12) will still be using the threshold of 250 sf to qualify as an allowed use (meaning no permit is required). Best, Tina Tina Heath, District Wetland Ecologist Chittenden County ACT 250 District Commission Application #: Exhibit #: Date Received: # 4, 6, 9 4C1122-1 021 5/16/18 ATTACHMENT A 2 802-490-6202 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. <kworden@hoyletanner.com> Sent: Friday, April 20, 2018 9:18 AM To: Heath, Tina <Tina.Heath@vermont.gov> Subject: Kennedy Drive - Wetland Buffer and definition of existing footprint Tina, We are at the point in the design of Kennedy Drive Pond 3 where I am trying to figure out the quantity (square footage) of impact to the buffer outside of the existing Pond 3 footprint so as to begin the permitting process with your department. I am struggling with the definition of what the existing footprint is for Pond 3. If I interpret it to be the existing STP site which includes the access area around the pond that is used for maintenance that extends to the bottom of berm slope and edge of cleared area and along outfall pipe, then I am below the 250 SF threshold of impact. I have attached a set of drawings that we prepared for the permit. Drawings P-3.1 and P-3.2 show the Pond 3 site plan existing and proposed, and show how I have interpreted the existing Pond 3 footprint within the wetland buffer (Existing and Proposed work at Pond 5 is also included in the set). Can you take a look at it and let me know if this interpretation is acceptable? This is acceptable and can be determined as an Allowed Use. Also, I am confused by the language in the draft wetland rule (highlighted below)…it seems to say that the impact threshold for retrofit of STPs is higher than 250 SF, at 500 SF or 5,000 SF for buffer impacts…Can you clarify what the threshold is and what would be applicable to this project? Draft wetland rule (https://anrweb.vt.gov/Pubdocs/DEC/ENB/ENB_V2/683-Wetlands%20WQI%20GP_v11_FINAL.pdf) 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, 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. 3 I guess once I have an answer on how much buffer impact there is, you can let me know what kind of permitting is required. If you want to discuss directly in a phone call, I am here until 3 pm today and will be in on Monday as well. After that I will be on vacation for the school spring break. Thank you, 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 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 2 Please let me know if you have any questions or would like to discuss further. Also, please contact me if there are any changes to the design that may have an impact on the inundation floodplain in this area. Thank you, Rebecca Pfeiffer Updated River Corridor mapping in the area of Pond 2 & 3: Rebecca Pfeiffer, CFM | Floodplain Regulatory Team Lead/Northwest VT Floodplain Manager River Corridor & Floodplain Protection Program 3 111 West Street Essex Junction, VT 05452 C 802-490-6157 | F 802-879-3871 PLEASE NOTE MY NEW EMAIL ADDRESS: Rebecca.Pfeiffer@vermont.gov Flood Ready Vermont: http://floodready.vermont.gov/ VT Floodplain Management Blog: http://vtfpm.blogspot.com/ VT ANR Natural Resources Atlas: http://anrmaps.vermont.gov/websites/anra/ River Corridor & Floodplain Protection Website: http://dec.vermont.gov/watershed/rivers/river-corridor-and-floodplain- protection From: Pfeiffer, Rebecca Sent: Wednesday, April 04, 2018 4:00 PM To: 'Dipietro-Worden, Kirstin A.' <kworden@hoyletanner.com> Cc: Alexander, Gretchen <Gretchen.Alexander@vermont.gov> Subject: RE: Kennedy Drive Stormwater Ponds Improvement Project - Curtesy Review Hi Kirstin, I have reviewed the plans for the conversion of Pond 2 & 3 to a gravel wetland, and the changes to piping for ponds 5&6. Ponds 5 &6 are definitely not jurisdictional for criterion 1D under Act 250 since Potash Brook is so far away from the site. I marked where I was assuming Ponds 2 & 3 to be so please correct me if I am wrong. Pond 2 wasn’t immediately noticeable from any of the imagery, so this is a site that I would definitely want to see out in the field. Under 1D, we define and comment on both inundation hazards using FEMA maps, and on erosion hazards using the ANR river corridor maps. I have reviewed the 50% design for Ponds 2 & 3 and I think that we’d likely want to visit the sites to get a sense of whether they would or would not be jurisdictional. They are both shown to be immediately adjacent to or within the FEMA floodplain (the gold yellow layer). I’d also want to confirm the river corridor maps for Pond 2 since we do have field data for this reach of the Potash Brook. I saw that both the ANR river corridor & the FEMA flood hazard area are on the plans, which was helpful in trying to get understanding of impact. I’ve cc’d Gretchen Alexander, our River Scientist that covers the Potash Brook watershed, as she would have accessed to the field assessment data for the Potash, and would finalize the river corridor delineation for Pond 2. Under Act 250, we have a standard of no loss of flood storage in the FEMA floodplain, so going to the site would help to understand the existing pond’s setting. I don’t know if you’re looking to do site visits at this time. If you are not looking for that level of input at this time, then I would like to see the site prior to any final design or an Act 250 submission. If you are at that point in your design now, then let’s plan a day to meet onsite. Thank you~ Rebecca ATTACHMENT C F] There are no buildings or structures in the APE. There are no historic buildings, structures, or landscapes in the Area of Potential Effect. See further explanation and justification below. ❑ There are historic buildings, structures, or landscapes in the Area of Potential Effect, but the project will have no effect, positive or negative, on them. See further explanation and justification below. Completion of this form in accordance with the VAOT PA evidences that FIM"A has satisfied its Section 106 responsibilities for this undertaking. IZ 21 c� Historic Preserva ro Officer D to Further explanation and justification for determination of No Historic Properties Affected All the buildings in the APE are less than SO years old. Distribution: Emily Wadhams, Vermont SHPO Don Allen, VAOT Project Manager Glenn Gingras, VAOT Environmental Specialist Central files via John Narowski Jed Merrow,' McFarland -Johnson, Inc. Photos Attached Map Attached